National Emissions Standards for Hazardous Air Pollutants NESHAP A Significant Impact to The U.S. Army Thomas A. Bush

1. National Emissions Standards for Hazardous Air Pollutants (NESHAP)A Significant Impactto The U.S. ArmyThomas A. BushHughes Associates, Inc. 1. The depots, arsenals, ammo plants and RDEC�s were introduced to the new NESHAP requirements during the summer of 2001. 2. The requirements were briefed to same during an annual environmental workshop hosted by the then AMCIS, 17-19 July 2001. 3. An ad-hoc data call was used to scope the potential impact.1. The depots, arsenals, ammo plants and RDEC�s were introduced to the new NESHAP requirements during the summer of 2001. 2. The requirements were briefed to same during an annual environmental workshop hosted by the then AMCIS, 17-19 July 2001. 3. An ad-hoc data call was used to scope the potential impact.

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4. 4 �Surface Coating� NESHAPs 1. NESHAP apply to all industry - commercial or Federal. 2. NESHAP emanate from the Clean Air Act and are promulgated by EPA on a phased basis. 3. The top two NESHAP, aerospace and marine coatings, currently exist and we are in compliance. 4. The middle four (in blue) are still in negotiation, but publication is imminent. Compliance date will be FY06 regardless. The two in italics, will probably be rolled into the Misc Metal Parts and Processes (MMPP) rule MMPP and plastic parts and products rule will be published at same time. If the Army does it right, compliance or elimination of MMPP will solve all four rules regardless of where the requirements end up. 5. The bottom four rules (in black) are rules that are in development and will be published in the future. 6. AMC IS ENGAGED in the negotiation process.1. NESHAP apply to all industry - commercial or Federal. 2. NESHAP emanate from the Clean Air Act and are promulgated by EPA on a phased basis. 3. The top two NESHAP, aerospace and marine coatings, currently exist and we are in compliance. 4. The middle four (in blue) are still in negotiation, but publication is imminent. Compliance date will be FY06 regardless. The two in italics, will probably be rolled into the Misc Metal Parts and Processes (MMPP) rule MMPP and plastic parts and products rule will be published at same time. If the Army does it right, compliance or elimination of MMPP will solve all four rules regardless of where the requirements end up. 5. The bottom four rules (in black) are rules that are in development and will be published in the future. 6. AMC IS ENGAGED in the negotiation process.

5. 5 Existing Regulations Aerospace, certain parts of: Fixed-Wing Aircraft Rotary-Wing Aircraft Missiles Rockets Shipbuilding All Navy Vessels Army Watercraft LACV-30? Large Appliances Bare Base Equipment (Harvest Eagle/Falcon, etc.) Temporary Port Equipment Base Camp Equipment (Force Provider, Mobile Kitchens, ECUs, etc DOD Weapon SystemsAffected by Coatings NESHAPs

6. 6 Aerospace

7. 7 Mixed NESHAPS

8. 8 Existing: Shipbuilding

9. 9 DOD Weapon SystemsAffected by Coatings NESHAPs Promulgated Rules with Compliance Date in Future Large Appliances Air Conditioners Heaters Laundry Systems

10. 10 Proposed Regulations Metal Furniture Furniture used in field equipment Furniture used in tactical shelters Paper and Other Web Products Ordnance MREs and Other Food Packaging Fabric Coating, Printing and Dyeing BDUs MOPP Gear Vehicle Covers / Roofs Tent Seam Sealing DOD Weapon SystemsAffected by Coatings NESHAPs

11. 11 DOD Weapon SystemsAffected by Coatings NESHAPs Proposed Regulations continued Miscellaneous Metal Parts and Products Ground Combat Vehicles Ordnance, Other Than Missiles and Rockets Support Equipment - Tent Poles, Shipping Containers, etc. Vehicles - HMMWV, 2� ton, 5 ton, etc. Ground Support Equipment Railcars Shelters Environmental Control Units? (Heaters and Air Conditioners)

12. 12 DOD Weapon SystemsAffected by Coatings NESHAPs Known Upcoming Regulations Plastic Parts and Products Ground Combat Vehicles Ordnance, Other Than Missiles and Rockets Troop Support - Tent Poles, Shipping Containers, etc. Vehicles - HMMWV, 2� ton, 5 ton, etc. Ground Support Equipment Helmets and Body Armor Shelters Many of the Same Systems as for MMPP

13. 13 Weapons Systems

14. 14 Weapons Systems

15. 15 Weapons Systems

16. 16 Weapons Systems

17. 17 Weapons Systems

18. 18 Non-Weapon System MaintenanceActivities Affected Surface Coating Process GSA Vehicles Lawnmowers Range Targets Facility Maintenance Excluded Hobby Shops Will be Excluded from MMPP and presumably all others R&D Facility Exclusion

19. 19 Regulated Process VOHAPs From Entire Surface Coating Process Cleaning / Degreasing Paint Stripping (If Applicable) Painting Including Thinner Cleaning Between Coatings Adhesives Sealants Stenciling and Marking Post Painting Clean-up Window Cleaning Paint Gun Cleaning Paint Booth Cleaning VOHAPs from Rubber to Metal Bonding Process

20. 20 Example of Regulated Process

21. 21 AMC Costs for Compliance Do Nothing - AMC Installations Out of Compliance NOVs, Fines and Work Stoppage Cause Must Fund for AMC Installations to Install Controls Plan & Program for Necessary Reformulation, Qualification, and Implementation Estimated P2 Program is on the order of $50M Smallest Portion is R&D 1. LTG Beauchamp memo, dtd 13 Feb 02, subj: Mission Impacts of the Impending NESHAPs, requested a determination of how each installation would fulfill it�s mission requirements if no additional funds were available to assist in complying with the new law (NESHAP). 2. Data returns and subsequent analysis: First Bullet - 14 of the 17 �major source� installations indicated they would have to shut down in order to avoid NOV�s and daily fines. There did not appear to be an efficient way to off-load mission requirements via contract or the ability to combine mission load at a reduced number of installations to reduce the traditional compliance resource burden. Second Bullet - cost of using traditional control technology (e.g., air scrubbers) to comply with the new NESHAP by FY06. Resources required FY06 and out cover the costs to operate, maintain, record and report. New control technology under development would not significantly reduce the overall bill. Third Bullet - cost of P2. Low technical risk (CARC work completed) - medium resource risk because of POM timing. Compliance achieved, but FY06/07 costs include completion of manufacturing process change. Costs imbedded in FY06 and out (approx $600K+) ensures new material does not creep in that would force a compliance issue all over again.1. LTG Beauchamp memo, dtd 13 Feb 02, subj: Mission Impacts of the Impending NESHAPs, requested a determination of how each installation would fulfill it�s mission requirements if no additional funds were available to assist in complying with the new law (NESHAP). 2. Data returns and subsequent analysis: First Bullet - 14 of the 17 �major source� installations indicated they would have to shut down in order to avoid NOV�s and daily fines. There did not appear to be an efficient way to off-load mission requirements via contract or the ability to combine mission load at a reduced number of installations to reduce the traditional compliance resource burden. Second Bullet - cost of using traditional control technology (e.g., air scrubbers) to comply with the new NESHAP by FY06. Resources required FY06 and out cover the costs to operate, maintain, record and report. New control technology under development would not significantly reduce the overall bill. Third Bullet - cost of P2. Low technical risk (CARC work completed) - medium resource risk because of POM timing. Compliance achieved, but FY06/07 costs include completion of manufacturing process change. Costs imbedded in FY06 and out (approx $600K+) ensures new material does not creep in that would force a compliance issue all over again.

22. 22 Goal: HAP-Free Coatings systems must comply with most stringent regulation Must determine which regulations may apply to a coating/solvent Reporting Units alone are complicated Difficult to determine most stringent regulation without detailed analysis Paint by Paint Formulation by Formulation Batch by Batch Goal: HAP-Free Solvents and De-painters Reduce/ Eliminate need for Record-keeping Eliminates need for detailed material composition Eliminates calculation of HAP content HAP-Free others where practical Certain High-Performance applications may still require High HAPs Keep below High Performance HAP limits Requires Commodity Management Wherever possible, eliminate HAPs, increasing Solids/HAPs ratio