Sustainable Painting Operations for the Total Army

1. Sustainable Painting Operations for the Total Army Presented at Joint Services Environmental Management Conference & Exhibition April 14, 2005 Mr. Patrick Taylor Dr. Daniel Verdonik Hughes Associates, Inc.

2. Outline • Approach • Risk Mitigation • Program Areas • De-Painting • Rubber to Metal Bonding • CARC and Other Paints • Solvents / Cleaners / Thinners • Sealants, Adhesives & Miscellaneous Coatings • Munitions Coatings • Implementation • Conclusion

3. Two Parts of the Equation Provide Solutions GetFunding

4. Questions… • What Are the Bad Actors? • Which Ones Are Easy and Which Are Hard? • Will the Alternatives End Up Costing More than the Controls? • Are there Hidden Implementation Costs to the PMs? • Is this Approach Going to Fail and Force Me to Install the Controls Anyway?

5. …Answers • What Are the Bad Actors? • Over 500 Suspected (Based on MMPP/PPP) • Site Visits, Detailed Databases in Hand • Which Ones Are Easy and Which Are Hard? • Easy: De-Painting, Non-Munitions Coatings & Sealants • Hard: Solvents, Munitions Coatings • Potential Alternatives Identified • Will the Alternatives End Up Costing More than the Controls? • NO • Are there Hidden Implementation Costs to the PMs? • Cost is Major Driver in Downselects • Picture Looks Good Overall – PMs Will Be Involved • Is this Approach Going to Fail and Force Me to Install the Controls Anyway? • Our Track Record Says NO!

6. Program Areas

7. Mitigating Risk • RDECs Developed Original Program Plans and Estimates • Collected Data from Army Industrial Base Facilities • Identified the Bad Actors, How Much, Where, on What • Performed Industrial Base Operational Analyses • Prioritized Bad Actors – Easy to Hard • Identified Opportunities for EPA Negotiations • Performed Trade Studies • Analyzed COTS, GOTS, and the Gaps • Estimated Costs of Alternatives and Alternative Approaches • Prepared Roadmaps to Implementation (by Industrial Site and by Commodity) • Risk Mitigation Plan • Verified RDEC Program Plans and Estimates • Work with Vendors & Suppliers • Negotiations with EPA • RDEC Involvement, PM Implementation • No Basic Research or Applied Research

8. De-Painting • Bad Actors – 1 • Performed at Depots and Troop Installations • Advanced Technology Development: FY03-FY06 • Trade Study Identified 34 Potential Alternatives • Selected 18 for Performance Evaluation • Coordinate Depot Implementation • Technology Demonstration at ANAD • Demonstration / Validation: FY06-FY08 • Performed at Three Sites: CCAD, LEAD, and ANAD • Coordinate PM Approval • Operations & Maintenance • 24 Specifications / Documents Identified • SOPs, TMs, DMWRs, etc. Will be Modified • ANAD High Volume Dip Tank • Two Approaches for ANAD • Alternative Materials – Higher Risk • Housekeeping and Dip Tank Changes – Low Risk • No Cost Trade-Off – Both Options have Zero Net Cost • Reduced Material Costs More than Cover Changes • Covered Through AWCF/CIP 5% Army Usage 15% VOHAPs

9. Rubber to Metal Bonding • Bad Actors – 2 • Performed Only at RRAD • Advanced Technology Development: FY06 • Reformulate 2 Existing Adhesives – Change Solvents • Evaluate 3 COTS Alternatives • Coordinate RRAD Implementation • Demonstration / Validation: FY06-FY07 • Conduct Qualification / Validation Testing • Support PEO GCS and PEO CS&CSS Approval • Operations & Maintenance • 3 Specifications and 5 DMWRs/SOPs • Cost Trade-Off • Scrubber: Capital Investment + Annual Maintenance • Alternative COTS Materials: Capital Investment + Higher Annual Material Cost • Reformulated Materials: No Cost Difference

10. CARC and Other Paints 45% Army Usage 40% VOHAPs • Bad Actors – 22 • Performed Everywhere Except Ammo Plants • Aerosols – Expect to be Exempted • CARC Family: 9 Specifications – No Cost • Re-Formulated CARC has No Cost Changes • New CARC More Durable, More Expensive (~$20/ GL) • PM Can Choose Best Option • Non-CARC: 13 Specifications • Advanced Technology Development: FY03-FY06 • Re-Formulate 5 and Evaluate 20 COTS • Coordinate Depot Implementation • Demonstration / Validation: FY06–FY08 • Downselect and DEM/VAL 13 at Depots • DEM/VAL CARC at 3 Remaining Depots • Coordinate PM Approvals • Operations & Maintenance • 13 Specifications • Cost Trade-off • No Performance Gains – Expect Comparable Cost

11. Solvents / Cleaners / Thinners • Bad Actors – 100 • Performed Everywhere • Trade Study Identified 350 Potential Alternatives with 33 Solvent, 19 Cleaner, and 12 Thinner Specifications) • Advanced Technology Development: FY03-FY06 • Joint Service Solvent Substitution Methodology • Sharing Costs • Evaluate 40 – Downselect to 8 for DEM/VAL • Demonstration / Validation: FY06-FY08 • DEM/VAL at LEAD, CCAD, ANAD, and TYAD • Coordinate PM Approval • Transition through TM to Field • Operations & Maintenance • Revise 3 Specifications, Develop 1 New Specification • Cancel / Inactivate for Army Coating Use 61 Specifications • Cost Trade-Off • CCAD Experience – $1M to $2M per Year (Aerospace Rule) • Requires Process Relocations • New Solvents Generally Cost More • Cost Validated During Downselect • Working with EPA on Emission Standards / Limits 20% Army Usage 40% VOHAPs

12. Sealants, Adhesives & Misc. Coatings • Bad Actors 400 out of 1500 • Many Low Use – Expect to be Exempted • Many Small Container Sizes – Expect to be Exempted • Performed Everywhere • Advanced Technology Development: FY04-FY07 • ASTM Test Standard • Evaluate 100 materials • Downselect 60 to 75 for DEM/VAL • Demonstration / Validation: FY06–FY08 • Qualification Less Complicated and Smaller Scale • DEM/VAL Up to 75 Materials • PM Approval Expected for 400 Current Materials • Operations & Maintenance • 25 Specification Changes Anticipated • Cost Trade-off • Requires Process Relocations • New Materials Generally Cost More • Cost Validated During Downselect 30% Army Usage 5% VOHAPs

13. Munition Coatings • Bad Actors – 33 • Performed at All Plants except 1 • Joint Service Requirements – Investigating Shared Cost • Delayed Compliance Date for Munitions • Clean Air Act Emissions Reductions in Other Areas • Good Performance Demonstrated by the Army in Exceeding Reductions Gained by Aerospace, Shipbuilding NESHAPs • EPA Working with Us – This Program Shows Commitment • Ammunition Coatings Drivers – Throughput & Costs • Changes Require Round Qualifications • GOCO / AAP Implementation is Intricate • Analyses Identified 33 Different Coatings at AAPs • Advanced Technology Development: FY04-FY09 • 33 Reformulations and Laboratory Validations • Demonstration / Validation: FY06-FY10 • 30 Round Qualifications • Operations & Maintenance: FY06-FY11 • 33 Specification Revisions • Drawing / TDP Changes • Coordinating PEO Ammo IB Approval

14. Implementation • Operations & Maintenance funds FY06-FY11 • Tied Directly to Non-Munition Areas • Non-Specification Document / TDP Changes • 99 TMs & TBs Identified • Commodity Management • NSNs • Prevent Re-Introduction of Bad Actors • Reduce Recordkeeping Burden and Costs • RDT&E Management Support: FY06-FY09 • Provide Direct Support to PMs & Depots for Implementation • Annual Management Oversight • Coordination with EPA

15. Sealants, Adhesives & Misc. Coatings 400 100 30% 5% Program Areas Process Area Bad Actors Alternatives Identified Usage VOHAP Emissions De-Painting 1 18 5% 15% CARC and Other Paints 22 25 45% 40% Solvents / Cleaners / Thinners 100 350 20% 40%

16. De-Painting 1 18 <1% <1% Sealants, Adhesives & Misc. Coatings 400 100 30% 5% Without ANAD Methylene Chloride Process Area Bad Actors Alternatives Identified Usage VOHAP Emissions CARC and Other Paints 22 25 50% 45% Solvents / Cleaners / Thinners 100 350 20% 50%

17. Bottom Line • Compliance-Driven Option: Install and Operate Controls $XXXM • Pollution Prevention Option: Reformulate, Qualify & Implement Alternatives $ XXM