targeting specific chemicals reduction efforts - iis7proceedings.ndia.org/jsem2007/3995_dunn.pdf ·...

Targeting Specific Chemicals for HM and Pollution

Reduction Efforts

Presented By: Timothy P. Dunn, Portsmouth Naval Shipyard

Coauthored By: Jessica C. Klotz, Naval Surface Warfare Center, Carderock

Keeping America’s Navy #1 in the World


Why Target Chemicals?

• EPA List of Lists identifies over 1300 specific chemicals that THEY are concerned about.

• Limited funds are available for research and development to reduce chemical use.

• Your facility or command may be too small to make change occur by yourself.


The Approach

• Prioritize the EPA List of Lists to develop three tiers:– Prohibited– Controlled– Chemicals of Concern

• Identify the chemicals to be targeted for Pollution Prevention


Prioritizing Steps

• Define what regulatory categories to use• Assign score values for each regulatory

category• Assign weight factors for subsets of

regulatory categories• Compute chemical ranks• Define the tier cutoff levels


Define What Regulatory Categories To Use

• Carcinogens• Reproductive Hazards• OSHA• CERCLA / SARA / EPCRA • Stockholm Persistent Organic Pollutants

(POPs)• EPA Persistent BioAccumulative Toxins

(PBTs)


Define What Regulatory Categories To Use (2)

• Safe Drinking Water Act• Clean Air Act• RCRA 1976• Clean Water Act• Marine Pollutants• Greenhouse Gases• Perfluorocarbons


Define What Regulatory Categories To Use (3)

• Department of Transportation Hazardous Materials

• Clean Air Act SOCMI• Reactive Chemicals• Oxidizing Compounds• Pyrophoric Compounds• Other Regulatory Requirements

– Materials of Evolving Regulatory Interest Team (MERIT)


Assign Score Values

• Each regulatory category is assigned a score based on the relative impact on human health and the environment. A higher value means more impact.

• For examples:– Carcinogens have a higher score value than green

house gases.– Reproductive hazard chemicals have a higher

score value than OSHA Hazardous Chemicals


Assign Weight Factors

• Within each regulatory category there are subsets that may need to be evaluated. A higher weight factor means more impact.

• For example: Chemicals with high OSHA Permissible Exposure Limits (PEL) have weight factors less than the more Hazardous Chemicals with lower OSHA PELs.


Ranks

• A database was used to compute the chemical ranks.

• The database is built to:– Add new chemicals from future regulatory

changes– Add new regulatory categories– Adjust the values and weights as public

perception changes


High

Moderately High

Moderate

Moderately Low

Low

Ranking Thermometer


Define Tier Cutoff Levels

• Review the list in rank order. Define what rank where each tier is cutoff.


Define Tier Cutoff Levels (2)

• Prohibited Chemicals: – Have been determined to pose the highest

level of risk to human health and the environment.

– Weapons system acquisition programs, technical authority warrant holders, and activities shall limit the use of Prohibited Chemicals to the maximum extent practicable based on the performance of risk assessments and cost analyses.


EXAMPLE: Prohibited Chemicals

• Benzene• 1,1,1-Trichloroethane• Perchloroethylene• Toluene



• Controlled Chemicals:– Have been determined to pose a moderate level

of risk to human health and the environment.– Weapons system acquisition programs, technical

authority warrant holders, and activities shall reduce the use of Controlled Chemicals based on the performance of risk assessments and cost analyses.


EXAMPLE: Controlled Chemicals

• Hydrofluoric Acid• CFC-11• CFC-12• Barium and Barium Compounds



• Chemicals of Concern– The chemicals in this category have been

determined to pose the lowest level of risk to human health and the environment.


What Next?

• Publish the Prohibited and Controlled Chemical List (PCCL).

• Promote the PCCL to other Navy commands.

• Promote the PCCL to other DOD command and activities.


Identify NAVSEA Target Chemicals List (TCL)

• Only Prohibited Tier chemicals.• Further evaluated for use in Naval Sea

Systems Command (NAVSEA).• If used in NAVSEA, then further

evaluated against criteria that are given importance factors


Importance Factors of the TCL Criteria

• Usage Quantity• Disposal Quantity• Public and Employee Perception• Possibility of Exposure• Ease of Elimination


Usage Quantity Value

• The value assigned to assess the relative amount of use of the target chemical. The data supporting this are the amounts of target chemicals procured or, if available, the amount actually used.


Disposal Quantity Value

• A value assigned to assess the relative amount of disposal of the target chemical. The data supporting this are the amounts of target chemicals disposed of via waste disposal or even recycling.


Public and Employee Perception Value

• The value assigned to assess public and employee views on the target chemical. This represents the current public and employee perception of a specific chemical. The value is assigned based on reading technical journals, employee interviews and viewing media resources such as newspapers, and TV news.


Possibility of Exposure

• A value assigned to assess the relative possibility for exposure to the target chemical. This is based on mishap reports, how the chemical is used, and frequency of exposure.


Ease of Elimination Value

• A value assigned to assess the possibility of reducing/eliminating the target chemical. The value is assigned based on reading technical journals, employee interviews, pollution prevention assessments, and vendor inquiries.


Do The Math

• For each chemical to be evaluated:– Assign a value for each criteria.– Multiply the criteria value by the

importance factor to get a criteria rank– Add up the 5 criteria ranks to get a

composite rank• The formula:

– Composite rank= Σ(Criteria Importance Factor*Value)


The Way Ahead?

• Identify processes and products that use the targeted chemicals.

• Publish the TCL with generic examples of chemical uses.

• Submit requests for studies to reduce or eliminate the uses of TCL chemicals.

• Share the entire target chemical selection process with other Navy and DOD commands and activities.

targeting specific chemicals reduction efforts - iis7proceedings.ndia.org/jsem2007/3995_dunn.pdf ·...

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