APPENDICES

Appendix A: ACRONYMS

Appendix B: APPROVAL AUTHORITY

Specifications and Standards: Obtaining Approval for Change

P2 in Maintenance

The common dilemma installations now experience is that they are governed by environmental regulations yet are required under military technical orders or manuals to use specific chemicals that can be in direct violation of environmental regulations.

A facility should not incorporate a P2 change to maintenance technology or procedure without approval. The approval authority for a particular process or system must concur with this change. Approval will be contingent on whether the suggested alternative is actually appropriate for the particular situation.

There is not often a "drop in" P2 replacement universally acceptable as an alternative to traditionally used practices. Specific P2 options typically need to be developed for specific processes. For example, methylene chloride is a universal paint stripper that works well in a variety of processes under any atmospheric condition. In contrast the P2 alternatives to methylene chloride have been found to be sensitive to temperature and humidity.

What to do:

For now, the process begins with a typical maintenance procedure, such as applying a coating to an aircraft at a depot. Engineering directives, process standards, Local Process Specifications, or Local Engineering Specifications govern applications of coatings. Other facets of military maintenance have different names for these types of technical reference manuals such as Guide Specifications, Standard Operating Procedures, Technical Manuals, Lubrication Orders, or Technical Orders.

• Contact the owner of the document and request a viable alternative.
• Depending on the urgency of the intended change, simply wait for the appropriate testing that needs to be conducted for a manual change revision. In some cases an urgent rapid action change may be requested.
• If this approach does not work, then request, through your chain of command, a review of policies being implemented in light of Acquisition Reform. A "top down" mandate may help effect change.

The new product or method must be able to perform satisfactorily. There are a number of engineering questions that will have to be thought through and answered carefully. For example, when considering solvent substitution the following questions should be asked:

• What is the current cleaning process and equipment?
• What are the parts or components for which the product is to be used?
• What is the material composition of the parts (plastic, steel, aluminum, etc.)?
• What is the physical geometry of the parts (flat plate, blind holes, etc.)?
• Why is the substitute needed?
• What is the purpose of cleaning the parts?
• What is the skill level of the personnel using the product or conducting the cleaning?

The Standard Protocol For Selecting General Cleaning Agents and Processes prepared by the Army is a good example of a document that provides a decision tree analysis to help users select appropriate alternatives. This document can be found on the Enviro$en$e website which is listed in Appendix C. The substitution process can be complex. Implementing P2 in other types of processes will have an entirely different set of questions.

Local directives are developed under "Cognizant Field Activities" or an "Engineering Support Activity". For example, each depot provides maintenance on a particular weapons platform. A depot will therefore be the Cognizant Field Activity for a specific technical order. The Cognizant Field Activity has the authority to identify and approve an alternative product. There are also technical manuals that are not local directives that specify maintenance actions. An example is NAVAIR 01-1A-5019 "Cleaning and Corrosion Control Manual for Aircraft Surfaces" (in the Navy, this manual is maintained at NADEP North Island, CA). These technical manuals typically require MILSPEC products. MILSPECs define technical requirements and the technical manual describes how the MILSPEC will be used in a process. Technical manuals may also call out for products on a "Qualified Products List" (QPL). Although in light of Acquisition Reform, as manuals are updated you will begin to see a shift to the use of consensus based industry standards. Some examples of consensus based industry standards are American Society for Testing Materials (ASTM) standards, Society for Protective Coatings (SPC) standards and National Association of Corrosion Engineers (NACE) standards.

In the Army, changes to Technical Manuals (TMs) or Lube Orders (LOs) would come through the owner, usually the Aviation and Missile Command (AMCOM), or Tank and Automotive Command (TACOM). Assistance is available from the Army Environmental Center (AEC). The AEC hotline is (800) USA-3845 or (410) 671-1699/DSN 584.

Regardless of what the specific technical instruction is called, someone is the owner of the document and has the authority to make changes. How willing that author is to make changes depends on a variety of influences. MILSPECs also have an "owner", this owner is usually called the "custodian".

A problem with the implementation of P2 is that it can take a long time before a technical manual is updated. Some manuals are updated more frequently than others. Some manuals can be updated within a relatively short period of time, while others literally take years to update. One of the goals under Acquisition Reform is to institute a "Single Process Initiative Block Change" or "Block Change". If a MILSPEC is not "state of the art" and the usual process to instigate a change is not made within 30 days, it is possible for a Block Change to be made. Block Changes are not commonly found yet, and only occur under contract using a new initiative called the Joint Test Protocol. Seven of the major suppliers of weapon systems i.e. McDonnell Douglas, Texas Instruments, Boeing, Hughes, Pratt & Whitney, General Electric and Lockheed Martin have been specifically granted authority to institute a Block Change.

Example of Approval Granted

The first example of success in instituting a Block Change under a JG-APP initiative was validated at Texas Instruments on 14 April 1996. The change resulted in over a $5 million savings through cost avoidance in Engineering Change Proposal (ECP) implementation. An ECP is needed to change a hazardous material. The change completed 151 contract changes and affected 3,458 technical drawings. The change involved application of high volatile topcoats and primers.

Examples of Approval Not Granted

1. Hundreds of Army lube orders call for P-D-680 dry cleaning and degreasing solvent. The question of whether aqueous (either room temperature sinks or hot water, dishwasher style) parts washers as a process are a suitable replacement for room temperature parts washing with P-D-680 cannot be addressed by the owner of the MILSPEC for P-D-680, but must be addressed by the owner of the TO or LO, or local directive. In the Army, there are hundreds of LOs which call out P-D-680, and it may be that none direct the use of aqueous parts washers, although these are approved in some cases in the other Services.

2. Aluminum Ion Vapor Deposition can in some cases be used in place of cadmium plating. There is general agreement that this process is not a suitable replacement for all types of parts. However, there is disagreement over which parts may be coated with the IVD system. For example the Navy Seahawk helicopter is essentially the same as the Army Blackhawk helicopter. However, there are several Seahawk parts which have been approved for use with IVD in the Navy, while the corresponding part in the Blackhawk has not been approved for use with IVD in the Army.

P2 in Procurement

The Defense Supply Center, General Services Administration, and the Defense Logistic Agency have publications and catalogues which list many alternative products effective for P2. However, the presence of a product in a catalogue does not guarantee it has been approved for your particular application.

Specifications and Standards: Integrating P2 into Acquisition

Acquisition of supplies and application of military specifications (MILSPECs) or military standards to maintenance processes are two of the most important influences on the implementation of P2. They are also two of the most complex processes and currently undergoing complete revision within the DoD.

To better integrate P2 into weapon systems management, DoD has initiated a number of efforts to change policies, practices, and documents that influence weapon system development. Simultaneously, DoD is undertaking a vigorous effort to streamline and reengineer the acquisition system. The effort, formally known as "Acquisition Reform," has five elements:

• Meet warfighter needs--i.e. provide weapons that military commanders need to protect our national security
• Be a smart buyer--use continuous reengineering and application of lessons learned to make good business decisions when buying equipment
• Procure the best value goods and service--when possible, buy commercially available products instead of defense-unique equipment
• Maintain a timely, flexible, responsive and efficient system
• Eliminate, to the maximum extent practicable, government-unique terms and conditions

Former Defense Secretary William Perry stated that to the maximum extent practicable, commercial standards shall be used instead of MILSPECs. MILSPECs have been a major stumbling block for innovative technological progression. The vision within Acquisition Reform is that life cycle management that considers environmental ramifications will begin at the point of development and purchase of every weapon system. Every weapon system has a headquarters manager: in the Army and Navy/Marine Corps the managers are called Program Managers (e.g. F-18 Program Manager), and in the Air Force they are called Single Managers (e.g. F-15 Single Manager). Integrated product teams are developed to support these managers with specific requirements. Depots are part of the Integrated Product Teams.

The basic thrust of Acquisition Reform is to reduce cost by eliminating military-unique contract and procurement costs and other procedures that delay the development of weapon systems. These initiatives have a direct impact on DoD’s implementation of section 3-303 of EO 12856. The shift of emphasis from military-unique standards and specifications to commercial standards or performance-based specifications means that DoD can judiciously revise military specifications and standards as required by section 3-303(b) of Executive Order (EO) 12856. In many cases, a military-unique standard that requires the use of toxic chemicals or extremely hazardous substances may be replaced by a commercial standard that does not specifically require the use of a toxic chemical or extremely hazardous substance. The Army "Standard Protocol for Selecting General Cleaning Agents and Processes" is an example of establishing minimum requirements for testing which must be met by all replacement or alternative cleaning products. The core elements of this standard protocol are identical to the draft ASTM standard, and will be superseded by the final ASTM standard guide when it is published.

Similarly, efforts to restructure the process by which weapon systems are reviewed during the acquisition process may affect approaches to ensure that a weapon system incorporates P2. Instead of adding new internal regulations that prescribe how a weapon system program manager should incorporate P2, the new practice may be to hold individual program managers accountable for the weapon system's performance, including its environmental impact. The best way to integrate P2 into the process is by increasing education, training, and accountability, rather than by adding regulations.

DoD has initiatives underway to advance P2 in weapon system development in the following areas: weapon system review procedures and instructions, life-cycle costing, specification and standards, commercial standards, and weapon systems manufacturing.

DoD Instruction 5000.2, "Defense Acquisition Management Policies and Procedures," requires that program managers develop a programmatic environmental, safety and health evaluation (PESHE), which functions as an environmental master plan for a weapon system. The purpose of the PESHE is twofold. First, it provides acquisition managers with environmental information needed to support program decisions and, second, it identifies the specific actions the program office must take to comply with the National Environmental Policy Act (NEPA). The PESHE is initiated during the concept exploration phase of weapon system development and is continually updated through the system acquisition life cycle. The PESHE serves as the primary vehicle for integrating environmental, safety, and occupational health considerations into a program's acquisition strategy early in the acquisition cycle. Information in the PESHE includes:

• A description of the program and the current acquisition phase
• A description of the alternative(s) applicable to the decision
• An analysis of the environmental effects and potential for significant impacts
• A description of the available P2 measures
• A listing of key environmental compliance requirements
• An analysis of NEPA compliance requirements and milestones
• An analysis of potential mitigation actions

Safety is another very important consideration. Alternatives may not have VOCs or HAPs, but they may have other undesirable properties, such as toxicity, corrosivity, reactivity or flammability. Toxicity clearances can be requested through your supporting Surgeon’s office. More information may be found at http://128.174.5.51/denix/DOD/Redirect/redirect.cgi?url=http://chppm-www.apgea.army.mil/tox/.

In summary, until these changes take affect, maintenance activities for the most part are still governed by MILSPECs referenced in technical manuals. There are ways to incorporate P2 within the DoD, but for many opportunities the process of change is not simple. It will require initiative and extensive follow up. There are many instances where P2 can be implemented but is not because of outdated reliance on MILSPECs or reluctance to accept innovative effective changes. This is not to say one should be foolhardy and ignore MILSPECs. Thorough investigation of all implications need to be considered and this document is evidence of the many successes that can be achieved.

Examples of Potential to Change through Acquisition:

Aircraft Sealants: A depot level aircraft maintenance shop may need to stock as many as 50 different aircraft sealant products because of what is specified. The top and bottom blister may each have a different sealant specified. The apparent reason for this is not that two separate products are actually needed, but rather that there were two separate engineers specifying products for those two areas. One is familiar with one sealant product, the other with another. Or perhaps that is what his predecessor specified and he continues the tradition. However, only 3 or 4 different types may be needed. The DoD should participate in non-government standards organizations to develop a classification system for sealants based on physical and chemical properties and performance. This type of participation is not limited to just sealants, but rather to all areas of specified products, including those which do not have environmental impacts. However, there are logistical and environmental implications of having 50 sealants available in a shop: there is increased likelihood for shelf-life expiration in the supply system, and product going bad in the shop. Moving to industry standards should circumvent this difficulty, and also allow the selection of the products that are environmentally preferable.

POC: Corpus Christi Army Depot, Charles Gawenis DSN 861-4170

How to Recommend an Air Force Tech Order (TO) Change
(Reprinted from untitled AF/AETC guidance document)

Often a pollution prevention option will identify a potential change that does not comply with a TO. In your zeal to implement new options, don’t forget that the TO is law!

TOs are designed to protect people, property, and the environment. Do not violate TOs, but remember that TOs can and should be changed when a better way of doing something is identified.

The following is a "road map" of the steps necessary to change a TO. We have divided the process into six "easy" steps!

This process is lengthy, but not impossible. You can get your option through the system when you know how the system works and how to properly complete the required paperwork.

Remember, the positive changes you make have greater implications than just benefiting the Air Force [and DoD]. You also benefit personally by saving your tax dollars, protecting your health, and ensuring the quality of the environment for future generations. Plus, you may get a suggestion award ($$$) if your option proves to be a good one!

STEP 1 - Work With Base Personnel to Evaluate Your Option

In Step 1, we will cover how to work with your supervisor and other Base personnel to identify an option.

• You have identified an option that you will think will prevent pollution.
• You and your supervisor will discuss the option and review the TO requirements, contacting your organization’s EC, who coordinates with the Environmental Flight, Bioenvironmental Engineering, and Hazardous Material Pharmacy. Does your option violate any TO requirements?
• Is a TO change necessary? If the option does not violate the TO, work with your supervisor and determine whether funds and resources are available to implement the option. If you have the funds, implement your option, consulting with the EF, BE, HMP, and your organization’s environmental monitor as needed.
• If the option does violate the TO, discuss the TO change with your supervisor and decide whether additional information is needed. Use the P2 resources available to determine if a similar change has been introduced at another DoD installation. Don’t reinvent the wheel!

STEP 2 - Work With HQ Personnel to Evaluate Your Option

Once you have exhausted all your Base resources, it is time to start going "off-base" with your option.

• Your supervisor should contact your shop Functional Manager at the MAJCOM HQ to discuss the option. If they decide it is not a good option, hold on to it. Technology and needs change rapidly, and your option may be just what is needed in a few months or something may happen to give you just the right angle to make your option work.
• If everyone thinks the option has potential, charge ahead!
• Is additional data or testing needed to evaluate your option? If not, you have all the data you need; go ahead to Step 3.
• If you need more data, does your shop have the funds, time, and manpower to collect it? If so, gather the data and conduct any needed assessments. If not, seek both funding and manpower assistance from environmental flight (EF). If the EF cannot help, another source to help you research your option is the ESOH Technical Planning and Integrated Product Team (TPIPT) at Brooks AFB.
• Use all the data you have gathered to assess whether the option is still a good one. If it is, you are ready to go to Step 3. If not, hold on to your option. You may be able to use it later.

STEP 3 - Begin The TO Change With Base Personnel

In Step 3, you begin the formal TO change process. You have done all your homework and are ready to complete the paperwork.

• Begin by completing the necessary forms to start the TO change. If your option recommends or suggests changes that may alter equipment, you will need to complete:

• AF Form 1000, Suggestion Form
• AF Form 1067, Modification Proposal

For any other TO modification submit:

• AF Form 1000, Suggestion Form
• AFTO Form 22, Technical Order Change Form

If your option requires identifying or replacing EPA hazardous materials and ODSs, submit the AFTO form as "urgent."

• Submit the completed forms to the Product Improvement Manager (PIM) in the Quality Support Office (QSO).
• Once the PIM has reviewed and approved your forms, the forms are forwarded to the HQ MAJCOM Functional Office (HQ/LGMMQ).

STEP 4 - The TO Change Request Elevates to HQ

All the activities in Step 4 take place at the MAJCOM HQ level. This step primarily involves your shop’s Functional Manager.

• The HQ MAJCOM Functional Office sends your forms to the Functional Manager. He reviews the forms and determines how to fund the option.
• Upon completion and approval, the Functional Manager will forward the forms to the Air Logistics Command (ALC) Single Manager responsible for your proposed TO change.

STEP 5 - The Single Manager Makes The Final Decision

Step 5 is where the final decision about your option will be made. The Single Managers are responsible for the weapons systems in their charge and any associated TOs. Each weapon system is assigned to a Single Manager.

• The Single Manager is responsible for taking the required actions to change the TO.

STEP 6 - Implement Your Option or Proceed to Funding

Congratulations! You have made it to the last step. The Single Manager has approved your option and has initiated the change.

• Once your option is approved, your Functional Manager works with your shop Group Commander to implement your TO change.
• If funds are not needed, implement your option right away.
• If you need money to implement, you can seek assistance from the Environmental Flight.
• Proceed to funding. To fund your project, you will have to convince others that your option is a good one. You can now say the TO requires it.

The Single Manager denied your request and provided you with a solid reason. If not, then have them send a written response containing the reason.

• If you understand the reasoning and you agree shelve the idea until it is warranted in the future.
• If you still think the change in the TO is justified then enlist support from EF, BE, HMP, and other people involved in the environmental arena such as AFCEE and HSC.

Hazardous Material Reduction Prioritization Process

In addition to the TO change process outlined (AFTO Form 22 and AFF 1000), there is a second method that can be used to change a TO. The Hazardous Material Reduction Prioritization Process (HMRPP) is designed to connect the people who use hazardous material with the owners of the processes that need these materials.

This is how HMRPP works:

• Several new questions have been added to the ESOH TPIPT Technology Needs Survey. These questions will be used by MAJCOM to compile the ESOH needs for weapon systems.
• The needs are summarized and sent to HQ AFMC Pollution Prevention IPT, where further consolidation takes place.
• The needs are then forwarded to the appropriate Single Manger (SM), SM Team, Center, or Lab. The SM and others evaluate the needs, and any TOs that are called into question are reviewed and modified, if possible, to meet the needs.

Note: Although the names and acronyms vary from one Service to another (Technical Order (TO) vs. Technical Manual (TM); Single Manager vs. Program Manager), many of the principles presented here apply throughout the Services. For further information on how it works in your Service, contact

Army POC: Randy Cerar, USAEC, (410) 612-6839/DSN 584

Navy POC: Scott Mauro, NFESC, (805) 982-4889/DSN 551

How to Recommend a Military Specification (MILSPEC) Change

Changing a MILSPEC has much broader implications and affects more weapon systems and publications than changing a TO or TM. To request a change to a military specification (MILSPEC) use Form DD 1426, which is attached to the back of every published MILSPEC. Contact the proponent or preparing activity published in the MILSPEC and send them a copy of all the relevant information you have. Keep in touch with them about the progress of the request.

Appendix D: REGULATORY INFORMATION

Clean Air Act And Toxic Release Inventory Reporting Requirements
Applicability To Painting And Depainting Solvents

From Pollution Prevention and the Clean Air Act: Benefits and Opportunities for Federal Facilities, Volume II (EPA 300-B-96-009B, May 1996)

¹ Both the HAP and TRI lists identify Glycol Ethers as a chemical category for those Glycol Ethers which are derivitives of Mono-, Di-, or Tri- Ethylene Glycol. Ethylene Glycol is also listed as an individual compound on both lists.

Governing Department Of Defense and Service
Regulations for Pollution Prevention

Department of Defense (DoD)

1. DoD Directive 4210.15 Hazardous Material Pollution Prevention (27 July 1989)
2. DoD Regulation 5000.2-R Mandatory Procedures for Major Defense Acquisition Programs (MDAPs) and Major Automated Information System (MAIS) Acquisition Programs (4 November 1996)

Air Force

1. Air Force Instruction 32-7080 Pollution Prevention Program
2. Air Force Instruction 32-7001 Environmental Budgeting
3. Air Force Instruction 63-188 Engineering, Research, Development, and Acquisition

Army

1. Army Regulation 200-1 Environmental Protection and Enhancement (21 February 1997)

Marine Corps

1. MCO P5090.2 Environmental Compliance and Protection Manual (26 September 1991)
2. MCBUL 4440 Hazardous Material Consolidation Program (22 May 1997)

Navy

1. OPNAVINST 5090.1B Environmental and Natural Resources Program Manual (1 November 1994)

2. OPNAVINST 4110.2 Hazardous Material Control and Management (20 June 1989)

Initiatives to Reauthorize The PPA

The National Pollution Prevention Roundtable is the largest membership organization in the country devoted solely to promoting P2, i.e. source reduction. The P2 Roundtable is working on initiatives to reauthorize the Pollution Prevention Act (PPA). There are a number of problems they seek to address, many of which have been experienced within DoD:

• Multi-media, prevention-based environmental protection approaches are not routinely considered.
• The current Federal environmental framework is not designed to adequately foster pollution prevention, provide flexibility for innovation within industry and within state and local governments. The current laws also do not send appropriate environmental cost signals to consumers and industry, resulting in an inefficient use of resources and pollution.
• Even with conventional and costly end-of-pipe control and treatment technologies, the nation's air, land and water resources are still being impacted--often by small difficult to manage pollution from dispersed and persistent sources.
• Funding is a major problem. Prevention-based programs are competing for resources with traditional well-funded end-of-pipe environmental management programs.

The P2 Roundtable seeks to assess and strengthen the PPA of 1990. The PPA has been considered to be fairly ineffective. The Act has a limited mandate and competes with major end-of-pipe environmental statutes such as the Clean Air Act (CAA), the Clean Water Act (CWA), and the Resource Conservation and Recovery Act (RCRA), which all contain strong requirements and enforcement provisions.

The P2 Roundtable further recommends amending the PPA to create a multi-media prevention based unified statute, to link or supersede the other single media environmental management laws.

Appendix E: EPA PROGRAMS & RESOURCES

Significant New Alternatives Policy Program (SNAP)

The list created and maintained by the EPA suggests alternatives to Class I and Class II Ozone Depleting substances. The list includes substitutes for applications such as aerosols, adhesives, coatings, inks, foam blowing, fire suppression, refrigeration, solvents, sterilants, and tobacco expansion. A copy of the list can be obtained from http://www.epa.gov/ozone/title6/snap/.

Design for the Environment

The Design for the Environment (DfE) program works with several industry sectors to identify cost-effective alternatives to existing products and processes that reduce risks to workers and the environment while maintaining or improving performance and product quality. A typical DfE industry project includes developing a Cleaner Technologies Substitutes Assessment (CTSA) and a communication and implementation strategy. CTSAs provide detailed environmental, economic, and performance information on traditional and alternative manufacturing methods and technologies. To help industry implement some of the new technologies identified during CTSA development, DfE provides a variety of outreach tools, including fact sheets, bulletins, pollution prevention case studies, software, videos, and training materials. There are five DfE projects of potential interest to DoD:

• Printed Wiring Board Project
• Screen Printing Project
• Lithography Project
• Flexography Project
• Garment and Textile Care Program (note: EPA desires to prototype "Wet Cleaning" and other types of non-solvent based cleaning within the DoD. Currently there is only 2% market penetration of alternatives to dry cleaning. If DoD were to successfully implement these alternatives, it would be a great boon to the emerging technologies.)
• Metal Finishing Project

http://www.epa.gov/dfe/

EPA Publications

EPA Pollution Prevention Directory (EPA 742-B-94-005)
USEPA, (202) 260-7751
401 M Street, SW (3404), Washington, DC 20460

Contains information on Federal, state, and local resources, as well as university centers that are conducting pollution prevention research and training.

Pollution Prevention and the Clean Air Act: Benefits and Opportunities for Federal Facilities Volumes I and II
(EPA 300-B-96-009A and EPA 300-B-96-009B)
USEPA, (202) 260-1023
401 M Street, SW (7409), Washington, DC 20460

Guides to Pollution Prevention:

ACCESS EPA (GPO Stock #: 055-000-00509-5)

A comprehensive directory to major information and services and collections of EPA and other public sector organizations. ACCESS EPA includes many online information resources such as bulletin boards, databases, and EPA scientific models.

Sources of EPA documents:

ORD Publications (G-72), (513) 569-7562
26 W. Martin Luther King Drive
Cincinnati, OH 45268-1072

Government Printing Office
710 North Capitol Street, NW
Washington, DC 20401

Pollution Prevention Information Clearinghouse
USEPA, (202) 260-1023
401 M Street, SW (7409), Washington, DC 20460
home page: http://size=3>www.epa.gov/opptintr/p2home
The clearinghouse is a distribution center for EPA documents and fact sheets dealing with source reduction and pollution prevention. It also provides a reference and referral service for pollution prevention questions.

Appendix F: DoD P2 SERVICES

Joint Service Pollution Prevention Technical Library

The Joint Service Pollution Prevention Technical Library is a valuable source of information for anyone interested in pollution prevention. It contains the following:

1) The Joint Service P2 Opportunity Handbook. This was designed to identify available "off-the-shelf" pollution prevention (P2) technologies, management practices, and process changes that will reduce the amount of hazardous waste and solid waste being generated at joint service industrial facilities. The handbook was prepared by the Naval Facilities Engineering Service Center (NFESC), under the direction of the Office of the Chief of Naval Operations (CNO-N45) and the Naval Facilities Engineering Command (NAVFAC), the Air Force Center for Environmental Excellence (AFCEE), the Army Environmental Center (AEC), and Headquarters Marine Corps (HQMC).

2) The P2 Equipment Book. This is a product of the Chief of Naval Operation's (N45) Pollution Prevention Equipment Program (PPEP). The book is valuable for identifying commercially available P2 technologies already being purchased or evaluated by the Navy. In it you will find equipment summaries containing detailed information on equipment characteristics, implementation requirements, benefits, associated costs, and contacts for further assistance.

3) DLA's Environmental Products Catalog. This is a user-friendly publication which clearly suggests alternatives to previously used products or processes. These alternatives may be non-ozone depleting, less toxic, or promote recycling and waste minimization. The catalog also has an extensive contacts section which will help customers request additional information. To order the products listed in the Environmental Products Catalog, visit the Defense Logistics Service Center (DLSC). A password may be required in some sections.

It is available on the worldwide web at http://enviro.nfesc.navy.mil/p2library/ or contact Larry Hill at lhill@nfesc.navy.mil

The HAP Status Binder

The purpose of this document is to assist persons responsible for facility environmental compliance to achieve timely compliance with hazardous air pollutant (HAP) regulations resulting from the Clean Air Act Amendments of 1990 (CAA90) by enabling early identification of funding requirements. This document: (1) updates the status of Federal HAP regulations; and (2) identifies DoD and EPA contacts and other information resources. Long and complex regulations are summarized with a focus on those parts that apply to the DoD. This resource keeps the Services up-to-date on the status of National Emission Standards for Hazardous Air Pollutants (NESHAPs), certain New Source Performance Standards/Emission Guidelines (NSPS/EG) and Control Technique Guidelines (CTG) that affect the Military. Appendices are dedicated to those NESHAPs, NSPS/EG and CTG's that are significant such as the Halogenated Solvent Cleaning NESHAP and the Hospital/Medical/Infectious Waste Incinerators NSPS/EG.

This resource was prepared and is updated by the Naval Facilities Engineering Service Center, and can be found on the web at <http://www.denix.osd.mil/denix/DOD/Library/HAP/hapindex.html

The Air Force Environment, Safety, and Occupational Health (ESOH)
Technical Planning Integrated Product Team (TPIPT)

The ESOH TPIPT is a resource available to help Air Force customers identify their ESOH technology needs. In FY 96, more than 360 needs were identified. ESOH TPIPT can help you identify an existing solution for your P2 needs or develop a new solution.

The ESOH TPIPT collects the needs that are identified by personnel in the field, using a 20-question survey. The forms can be completed in hard copy or by using ESOH TPIPT’s software package.

The survey serves as a validation tool and as a platform where various needs can be ranked and stacked in order of priority. Your requirements will be classified into one of three general approaches for resolution.

1. Administrative and/or Policy Needs - Those that deal with issues that may require new or modified policy changes
2. Education/Training Needs - Those that can be solved through implementing or making available an information source or training effort.
3. Technology Needs - Those that are neither administrative/policy nor education/training. There are three general types of potential solutions to technology needs:

• Current off-the-shelf technology is available and meets your application requirements.
• Current off-the-shelf technology is available that may require some design modification to fit your particular application.
• No technology exists that will meet your needs and a research and development effort will be required to develop a solution. Needs which require an R&D solution are perhaps the most difficult and require several years to accomplish. Solutions to needs of this type are largely the responsibility of the Air Force Research Laboratory.

The following are the FY 96 (and current) ranking criteria:

• Mission impairment
• Pervasiveness
• Environment hazard severity
• Human health severity
• Regulatory risk
• Cost of not fixing the problem
• Air Force goals and political sensitivity

Annually, a "Technology Needs Call" is conducted to gather requirements from all over the Air Force. Your MAJCOM will provide notification of when this will occur for FY 98. Or, if you miss the annual Needs Call, you can contact HSC/XRE at DSN 240-2129 to submit your requirements out of the normal collection cycle.

If ESOH TPIPT does not accept your need, hold on to it and see if something new develops.

If ESOH TPIPT accepts your need, they will gather information, conduct any necessary testing, and send all the data and information to you.

Many of the Air Force Success stories mentioned above were taken from the Air Force FY 96 Pollution Prevention Pillar Needs Assessment Report, 5 July 1996. This report can be accessed on the Internet URL: http://www.wl.wpafb.af.mil/pprevent/

Air Force Environmental Helpline

PRO-ACT Helpline
(210) 536-4214/DSN 240 or (800) 233-4356

Navy Pollution Prevention Equipment Program

The Pollution Prevention Equipment Program (PPEP) was established by the Chief of Naval Operations (CNO 451) to help the support the Fleet in meeting the goals established by Executive Order (EO) 12856. This EO requires all Federal agencies to reduce the amount of toxic hazardous waste generated by 50% by CY99 using CY94 as the base line year. The program was set up to procure, deliver, install, and provide a complete Integrated Logistics Support (ILS) package to Navy activities for commercially available P2 equipment.

To manage the program a central steering committee was set up to provide overall management of the program as well as any technical support required by the activities in choosing the appropriate P2 equipment for their requirements. The committee consists of the CNO 451, which chairs the committee, NAVFACENGCOM Code 40, the budget officer for the program, major claimants, and the two procuring agencies: Naval Facilities Engineering Service Center (NFESC) and Naval Air Warfare Center (NAWC) Lakehurst.

Each year Navy activities provide to the steering committee, through their major claimants, a list of their P2 requirements. The committee reviews the list, verifying the requests meet guidelines set up by the committee for procurement of the equipment, and then approves the list. The requirements are then divided between the two procuring agencies NFESC and NAWC Lakehurst. The procuring agencies coordinate with the claimants and the activities to arrange for the procurement, delivery, site preparation (if required), installation, training, and start up of each piece of equipment. Also, a complete Integrate Logistics Support (ILS) package is provided to assure long term operations of the equipment including maintenance schedules, spare parts lists, a supply of consumable spares, training requirements, operator safety requirements, and any information required to maintain the equipment.

To support the activities future needs a P2 Equipment Handbook was setup to provide activities information on all P2 equipment currently being procured under the program. This handbook will help activities choose the appropriate piece of equipment that will reduce the waste stream being generated. Navy activities are required to coordinate all requests with their P2 Plans. The P2 Equipment Handbook is available on the ESC and CNO Homepage.

The Air Force and Marine Corps have used this program on a limited basis to purchase equipment and the Army is considering using this program. If the program is successful, all DoD agencies may choose to use the P2 equipment purchase program. The equipment purchased through this program is listed on the next few pages, however equipment is not limited to these items.

When procuring equipment through other channels it is important to plan for contingencies. Air Force Human Systems Center (HSC/OEBQ) has source sampled many types of P2 emission reduction technologies. Some of these technologies have not passed the emissions criteria claimed in the manufacturer literature. It is important to ensure that the manufacturers of P2 technologies are responsible for their products’ performance. This dilemma should be resolved before the technology is purchased and a mechanism should be installed to provide for the case when the technology does not meet the stated criteria. Equipment available through this program is listed on the following page.

Equipment Available through PPEP:

Navy Fleet Assistance Support and Technology Transfer (FASTT)

The FASTT Team can help Fleet operators and maintainers meet environmental requirements. FASTT is a joint program of the Commander in Chief Pacific Fleet (CINCPACFLT), Commander in Chief Atlantic Fleet (CINCLANTFLT), Naval Sea Systems Command (NAVSEA), Naval Air Systems Command (NAVAIR), with active participation by the Naval Facilities Command (NAVFAC) and the Naval Supply Command (NAVSUP).

Army Pollution Prevention Investment Fund (P2IF)

The objective of the Army Pollution Prevention Investment Fund (P2IF) is to fund cost effective installation level P2 projects which support Department of Defense (DoD) P2 Measures of Merit; reduce hazardous material purchase, use, and disposal; and reduce or eliminate environmental compliance requirements. The P2IF is a centrally disbursed fund under which Major Army Commands (MACOMs) compete for funding based upon cost benefit and economic pay back period. Initially, the P2IF supplements what MACOMs have been able to fund. Ultimately, it will be fully integrated with the Environmental Program Requirements (EPR) process. P2IF projects are assessed for Army-wide applicability and the potential for central procurement to achieve economies of scale.

Response from the field to the January 1997 project call was excellent. From the initial submissions, 63 projects generally met the criteria. P2IF projects are prioritized, based primarily on payback potential, utilizing the Pollution Abatement and Prevention Analysis (PAPA) methodology developed by the U. S. Army Concepts Analysis Agency (CAA) and approved by the U.S. Army Cost and Economic Analysis Center (CEAC). In FY97 the P2IF disbursed year-end funding to 8 projects at 7 installations. The following projects were funded in FY97:

Interested Army installations, facilities and MACOMs may obtain application information from Mr. Bill Nelson at the Army Environmental Center (USAEC).

E-mail: wcnelson@aec.apgea.army.mil
Phone: (410) 671-1248/DSN 584
Fax: (410) 671-1675/DSN 584

Army Environmental Helpline

Army Environmental Information Response Line
(410) 671-1699/DSN 584 or (800) 872-3845

Joint Group on Acquistion Pollution Prevention (JG-APP)

The JG-APP is led by flag rank officers from the Air Force, Army, Marine Corps, Navy, and the Defense Contract Management Command (DCMC) who report to the Joint Logistic Commanders. The Joint Pollution Prevention Advisory Board (JPPAB) is comprised of working level managers from the Joint Services and Defense Logistics Agency (DLA).

Program Objective

• Reduce/eliminate hazardous materials by fostering joint service cooperation
• Avoid duplication of effort; share technology
• Provide single interface to defense acquisition community and defense contractors. The focus is on contractor design, manufacturing, and remanufacturing locations. The goal is to identify defense contractors with multiple defense contracts, for multiple services, and for multiple acquisition managers.

The National Defense Center for Environmental Excellence (NDCEE) Concurrent Technologies Corporation (CTC), through the NDCEE program, is providing engineering and technical support to the JPPAB, the defense contractors, and affected program managers/single program officers.

The Joint Test Protocol (JTP) contains the critical requirements and tests necessary to qualify potential alternatives to a selected target hazardous material and process for the particular application.

The following is a list of contractors and the corresponding weapons platforms under development. Materials and processes with potential for P2 are identified.

1. Contractor: Boeing Company-McDonnell Aircraft and Missiles Systems (BC-MAMS) (formerly McDonnell Douglas Aerospace-East)
   Potential Programs/Owners: AV-8B, C-17, F-15, F/A-18, Harpoon/SLAM, T-45 TS
   Material(s) Identified: Chromium (chromated primers)
2. Contractor: Hughes Missile Systems Company (HMSC), Tucson, AZ
   Potential Programs/Owners: ACM, AMRAAM, Phalanx, RAM, Standard Missile, Stinger, Tomahawk, and TOW
   Material(s) Identified/Programs Impacted: Chrome, Chrome Conversion Coatings and High VOC coatings
3. Contractor: Boeing Defense and Space Group (BD&SG), Seattle, WA and Boeing Helicopters (BH), Philadelphia, PA
   Potential Programs/Owners: A-6, AGM131A, AGM-86, ASW, B-2, B-1B, B-52H, CH-46, CH-47, E-3A, E-4B, E-6, E-8A, E-767, EELV, FO-E-3A, F-22, IUS, JSF, KC-135, V-22, Minuteman, PeaceKeeper, Avenger, Comanche, Shuttle Upper Stage
   Material(s) Identified/Programs Impacted: Cadmium
4. Contractors: Joint Group on Acquisition Pollution Prevention (JG-APP)/Propulsion Environmental Working Group (PEWG) (AlliedSignal Engines, Allison Engine Company, General Electric Aircraft Engines, (GEAE) Pratt & Whitney-United Technologies Corporation (P&W-UTC), Williams International)
   Potential Programs/Owners: F100, F101, F103, F107, F108, F110, F112, F117, F118, F119, F404/F414, J52, LM2500, T53, T55, T56, T64, T406, T700, T800, TF30, TF33, TF39 engines
   Material(s) Identified: Lead as found in dry film lubricants (DFLs)
5. Contractor: Lockheed Martin Electronics & Missiles and Information Systems Companies (LM), Orlando, FL
   Potential Programs/Owners: AEGIS, AGTS, ALS, AN/AAS-18, AV-8B, COFT (SAUDI/KUWT), CASS Lot4, CASS Lot5+, CECOM, COFT, Comanche, Patriot, CVI, DDG, ET, F-14 IRST, F-22 MLD, F/A-18, HAGS, Hellfire II, IVACC, Javelin, LANTIRN, LAV, LLLTV, Longbow FCR, Longbow Missile, Predator, PT2000, RPCP, TADS/PNVS, TDT, UEC, WCMD
   Material(s) Identified: Toluene, methyl ethyl ketone (MEK), xylenes, methyl isobutyl ketone (MIBK)
6. Contractor: Pratt & Whitney - United Technologies Corporation (P&W-UTC), West Palm Beach, FL
   Potential Programs/Owners: Engines - F119 & 100, TF-30, TF-33 (AF); J-52 & TF-30 (N), and SSME (NASA)
   Material(s) Identified/Programs Impacted: Chromium - Zinc chromate primer
7. Contractor: Raytheon TI Systems, Inc. (RTIS) (formally Texas Instuments Defense Systems and Electronics), Dallas, Texas
   Potential Programs/Owners: P3, JSOW, HARM, F/A-18, PVWY III, F3 Production, F-16, Lantirn, M1A2-CITV, AVENGER, Javelin, HTI
   Material(s) Identified/Programs Impacted: High Volatile Organic primers and topcoats containing MEK, Toluene, and Xylene (MIL-P-23377, MIL-C-22750, MIL-C-46168, MIL-C-83286)

URL: http://www.jgapp.com

Appendix G: HOW TO INCORPORATE P2

How is P2 done?

1. Identify a problem area.
2. Collect information on the process. Inventory all waste streams and costs associated with each stream. Establish relevant baselines.
3. Involve those who work with the process.
4. Understand the process. Think logically about the way things are done and ask questions. "Why do we do it that way?"
5. Collect information on the options. Check this document, the Joint Service P2 Technical Library, and other sources of information.
6. Obtain approval. Most procedures of concern are governed by Lubrication Orders (LOs), Technical Orders (TOs), or Technical Manuals (TMs). In order to change a material, a step in the process, or a piece of equipment, it is necessary to get the proper approval from the owner or custodian of the military specification or standard, or LO/TO/TM. See Appendix B.
7. Choose from the alternatives.

Note: Steps 6 and 7 do not necessarily happen in sequence, but to some extent happen in parallel. In some cases step 6 will be unnecessary. In some cases step 6 will make step 7 unnecessary. If a decision is to be made, consider short and long term plans, costs, and maintenance, and include the input of those whom the change would impact.

8. Obtain funding.
9. Include training when appropriate. Sometimes the lack of training or ineffective training has resulted in dissatisfaction with the change. This often happens with a switch to new types of paints or delivery systems (e.g. high volume low pressure (HVLP) paint guns).
10. Follow up and track progress. Track data to compare with the baseline.