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Environmental
Assurance for
NASA
Systems



Ted Biess
NASA Headquarters
Environmental Management Division
February 7, 2007
Outline
• Alignment with Mission
• Environmental Assurance Context
• Example Environmental Impact on Shuttle
• Focus, Definition, and Goals
• Organizational Structure
   – Principal Centers
   – International Component
   – Partnerships
• Trends
• Summary
• Contracts and Resources
Alignment with
    Mission
Compliance
‘End of Pipe’
Environmental Management
  Drivers, Context, and Issues
• Activity is driven by external requirements
  (e.g., statutes, Executive Orders, public
  outcry)
  – Regulatory framework is the main driver for
    change
• Identify, quantify, measure, monitor,
  review and assess environmental
  problems.
• Sometimes in conflict with mission goals
Agency Strategic Goals
    Fly the Shuttle as safely as possible until its retirement, not later
1   than 2010.
    Complete the International Space Station in a manner consistent
2   with NASA’s International Partner commitments and the needs of
    human exploration.
    Develop a balanced overall program of science, exploration, and
3   aeronautics consistent with the redirection of the human spaceflight
    program to focus on exploration.
    Bring a new Crew Exploration Vehicle into service as soon as
4   possible after Shuttle retirement.
    Encourage the pursuit of appropriate partnerships with the
5   emerging commercial space sector.
    Establish a lunar return program having the maximum possible
6   utility for later missions to Mars and other destinations.
Environmental Management
     Goals to Support Mission
    Direct Mission Support
1   Provide direct mission support by integrating
    environmental considerations into programs
    and projects.

2   Proactive Risk Mitigation
    Proactively reduce NASA’s exposure to
    institutional, programmatic and operational risk.

3   Protect Mission Resources
    Pursue environmental initiatives designed to
    restore, protect and enhance mission
    resources.
Alignment with Mission

             Environmental Management
                     Division Management & Support

   Protection of             Direct Mission          Proactive Risk
Mission Resources               Support                Mitigation
  Environmental                  National            Environmental
Functional Reviews           Environmental            Assurance
                            Policy Act (NEPA)
   Cleanup and                                        Center Future
   Remediation                                         Operational
                            Cultural & Historic
  Environmental               Preservation             Assurance
 Management Sys.
                           Regulated Materials           Energy
   Emerging
  Contaminants
   Recycling &
 Affirmative Proc.
Environmental
 Assurance
   Context
System Inputs & Outputs
                  Model
                              OUTPUTS
  INPUTS
                              waste heat


raw materials                 solid waste       waste
                                                stream
                              air emissions
                 attributes                     ‘end
                 determine                        of
fuels / energy     inputs     water emissions
                                                pipe’
                     and
                  outputs     usable products
Impacts of Design Decisions
                                            Lifecycle Cost
                                                         Operations and Support
                            System Acquisition
            $                               Production
                         System
                          R&D
      100
       95                                      Lifecycle cost
       85                                      locked in
       70                                                                          Lifecycle cost
                                                                                   expended
       50
                                                                                            Disposal
                                                                        60%                  Cost?
                           10%                  30%
       10
                                                                                                    Time
   Concept                            Production and            Initial                  Out of
 Exploration                          Development               Operational              Service
       Concept and          Full Scale                          Capability
          Validation        Development
From W. J. Larson & L. K. Pranke (1999) Human Spaceflight: Mission Analysis and Design
Managing to External
                Requirements
• Agency Regulations                         •   Executive Order 13287 - Preserve America
• Archaeological Resources Protection Act    •   Fish and Wildlife Coordination Act
• Biobased Product Procurement               •   Global Climate Protection Act
  Requirements                               •   Green Computer (EPEAT) Procurement
• Clean Air Act (CAA)                            Requirements
• Clean Water Act (CWA)                      •   ISO14001 - Environmental Management
• Safe Drinking Water Act                        Standard
• Comprehensive Environmental Response,      •   Landfill Disposal Standards
  Compensation, and Liability Act (CERCLA)   •   Local Regulations
• Costal Zone Management Act                 •   Marine Mammal Protection Act
• Emergency Planning and Community           •   Migratory Bird Treaty Act
  Right-to-Know Act (EPCRA)                  •   National Environmental Policy Act (NEPA)
• Endangered Species Act (ESA)               •   National Historic Preservation Act
• Energy Policy Act of 2005                  •   Occupational Safety and Health Act
• Executive Order 11988 - Floodplain             (OSHA)
  Management                                 •   Pollution Prevention Act (PPA)
• Executive Order 11990 - Protection of      •   Resource Conservation and Recovery Act
  Wetlands                                       (RCRA)
• Executive Order 12114 - Environmental      •   State Regulations
  Effects Abroad of Major Federal Actions    •   Superfund Amendments and
• Executive Order 12898 - Environmental          Reauthorization Act (SARA)
  Justice                                    •   Toxic Substances Control Act (TSCA)
• Executive Order 13148 - Greening the
  Government
Trends for Long-Life Systems                                                                                             ?

         Increasing Env. Regulation
                                                                                                                                 ?

                    Increased regulation
                    means increased
                                                                                                                               ?
                    operational
                    restrictions,
                    mandated controls,                                                                   What will be the
                    cost uncertainty,                                                                    added
                                                                                                         effects/regulation
                    and schedule delays                                                                  from more liberal
                                                                                                         Administrations
                                                                                                         and Congresses?




                                                                                                       2010   2020    2030    2040

                                                                             Apollo          Shuttle          VSE
Source: J. A. Cusumano, New Technology for the Environment, Chemtech, 1992, 22(8), 482–489
Includes DDT&E and operations – environmental
  factors act primarily in the ops phase


Adapted from Ares 1 SRR Presentation, Nov 6-7, 2006
NASA incurs O&M
                                                      costs and risks
                                                      associated with
                                                      environmental
                                                      issues




Adapted from Ares 1 SRR Presentation, Nov 6-7, 2006
Example
 Environmental
Impact on Shuttle
Ozone Hole Discovered in 1985
                                               NASA and NOAA
                                               Announce Ozone Hole is
                                               a Double Record Breaker
                                                  October 19, 2006
                                                  From September 21-30, 2006
                                                  the average area of the ozone
                                                  hole was the largest ever
                                                  observed, at 10.6 million
                                                  square miles. This image,
                                                  from Sept. 24, the Antarctic
                                                  ozone hole was equal to the
                                                  record single-day largest area
                                                  of 11.4 million square miles,
                                                  reached on Sept. 9, 2000. The
                                                  blue and purple colors are
                                                  where there is the least ozone,
                                                  and the greens, yellows, and
                                                  reds are where there is more
                                                  ozone.
http://www.nasa.gov/vision/earth/lookingatearth/ozone_record.html
Shuttle Ozone Depleting
 Substance (ODS) Applications
                                       External Tank


                                        Solid Rocket Boosters

                      External Tank:
                      4 TPS Foams               Orbiter
Forward SRB/ET
  Attach Strut




                             RSRM               Orbiter
                                                Applications:
                                                Main Propulsion
 SRB/ET Attach                                  System and
     Ring           Aft SRB/ET                  Power Reactant
                 Attach Struts (3)              Storage and
                                                Distribution
                                                System
      Aft
   Stiffener
   Rings (3)      Locations of HCFC
                  141b foams are
        RSRM:     noted in blue          Space Shuttle
        Nozzle                           Main Engines
Thermal Protection System (TPS)
     Development Timeline
1988   Initiated CFC 11 blowing agent replacement investigations

       Made decision to implement HCFC 141b as near drop-in replacement
       rather than pursue Essential Use Exemption. Initiated detailed
1991   development activities and design verification testing with HCFC 141b.
       Estimated completion date 1996.

       Began development of ODS-free (without HCFC 141b) foam; estimated
1992   completion by 2003 which is phase-out date of all Class II ODS.

       Initiated production implementation of 3 out of 4 CFC 11 foams with
1993   formulations containing HCFC 141b

2002   Replaced remaining CFC 11 foam with HCFC 141b alternate

       HCFC 141b phased out in US. ODS-free foam is not available. Resources
2003   and attention is overtaken by Columbia Accident and Return to Flight

       NASA still requires Essential Usage Exemption for continued use of
2007   HCFC 141b within SSP. No plans for development of ODS-free foam due
       to Shuttle retirement in 2010.
Elimination of Ozone Depleting
    Substances within NASA
                                                    ODS Usage - kg (pounds)
              End Use Classification
                                                  1991       2004        Reduction
      Foam Blowing                                 36110      11530
      (Thermal Protection System Foams)
                                                                           68%
                                                   (79600)    (25400)
      Rubber Cleaning, Surface Activation, and    385100      10700
      Bonding
                                                                           97%
                                                  (849000)    (23500)
      Solvent Cleaning, Precision Cleaning,      1171000      23000
      and Cleanliness Verification
                                                                           98%
                                                 (2600000)    (50700)
                                                  130200      19000
      Refrigeration and Operational Cooling                                85%
                                                  (287000)    (41800)
                                                    3720            95
      Fire Suppression                                                     97%
                                                    (8200)      (210)

• ODS elimination has been a priority within NASA
• The majority of ODS usage has been eliminated
• Mission critical uses remain for existing space vehicles, and
  possibly for future programs
Environmental
   Assurance
Focus, Definition,
   and Goals
Environmental Assurance Focus
Risks posed by the Program to the
environment
• Identified under NEPA through the Environmental Impact Statement
  (EIS) process prior to Program inception
• The EIS describes programmatic options and addresses
  environmental considerations associated with each



Risks posed to the Program by
environmentally-related drivers
• Real-time risks from a new environmental driver
• Real-time risks from configuration issues/changes that trigger an
  existing driver
Environmental Assurance
           Definition

Environmental Assurance is the
proactive detection, analysis,
mitigation, and communication of
environmentally driven risks to NASA
mission-required research,
development, fabrication, processing
and operations.
Environmental Assurance Goals
1.   Identify, analyze, and measure environmentally
     driven programmatic and institutional risks.
2.   Communicate environmentally driven
     programmatic and institutional risks to appropriate
     owners (when possible, in early phases of program
     and project planning and execution)
3.   Team/partner with risk owners to proactively
     reduce risk’s impact, likelihood, and scope (e.g.,
     may apply to multiple programs and projects)
      – Influence regulatory authorities
      – Acquire special waivers, if possible, from regulating
        organization
      – Identify and validate appropriate solutions for mitigation of
        environmentally driven risks. As needed, adapt high-TRL
        technology and/or increase TRL for new technology for
        NASA’s use.

The risk owners (e.g., programs and projects) will have day-to-day
responsibility for management of their risks.
Environmental
 Assurance
  Structure
Environmental Assurance Structure
  Environmental Management       Leadership &
        Division (EMD)           Coordination
       NASA Headquarters


 Regulatory Risk Analysis and    Principal Centers
   Communication (RRAC)
            MSFC


   Technology Evaluation for
 Environmental Risk Mitigation
        (TEERM) - KSC


   Centro Para Prevenção da
                                 Partner Organization
           Poluição
             (C3P)
        Lisbon, Portugal
Leadership & Coordination - EMD
                                • Provides management
Environmental Management
                                  oversight of Principal
      Division (EMD)
     NASA Headquarters            Centers
                                • Interfaces with partner
                                  organizations - SEA, JGPP,
Regulatory Risk Analysis and      JANNAF, CAASSC
  Communication (RRAC)
           MSFC                 • Coordinates activity with
                                  regulatory agencies
                                • Provides legislative
  Technology Evaluation for
                                  support, policy review, and
Environmental Risk Mitigation
       (TEERM) - KSC              guidance


  Centro Para Prevenção da
          Poluição
            (C3P)
       Lisbon, Portugal
Principal Center – RRAC
                                • Performs regulatory review
Environmental Management
                                  and impact analysis
      Division (EMD)
     NASA Headquarters          • Captures and analyzes
                                  emerging risks

Regulatory Risk Analysis and    • Develops mitigation
  Communication (RRAC)            options
           MSFC
                                • Recommends actions for
                                  influencing regulatory
                                  authorities
  Technology Evaluation for
Environmental Risk Mitigation   • Communicates risks to
       (TEERM) - KSC              NASA programs and
                                  projects
  Centro Para Prevenção da
          Poluição
            (C3P)
       Lisbon, Portugal
Principal Center – TEERM
                                • Leads work to identify and
Environmental Management
                                  test environmentally
      Division (EMD)
     NASA Headquarters            preferable alternative
                                  materials and processes
                                • Analyzes materials and
Regulatory Risk Analysis and      processes
  Communication (RRAC)
           MSFC                   • Manages joint test
                                    projects
                                  • Disseminates test
  Technology Evaluation for         results
Environmental Risk Mitigation
       (TEERM) - KSC              • Develops risk mitigation
                                    options
  Centro Para Prevenção da      • Participates with partners
          Poluição                on joint projects – C3P and
            (C3P)                 Joint Group on Pollution
       Lisbon, Portugal           Prevention (JGPP)
Partner Organization – C3P
                                • Works with multiple
Environmental Management
                                  European partners
      Division (EMD)
     NASA Headquarters          • Conducts joint projects
                                  focusing on elimination of
                                  hazardous materials to
Regulatory Risk Analysis and      meet emerging EU regs.
  Communication (RRAC)
           MSFC                 • Operates in ways similar to
                                  TEERM
                                • Monitors European projects
  Technology Evaluation for
                                  concerning elimination of
Environmental Risk Mitigation
       (TEERM) - KSC              hazardous material
                                • Provides conduit into
  Centro Para Prevenção da        European Union for other
          Poluição                activities of interest to
            (C3P)                 NASA (e.g., energy,
       Lisbon, Portugal           REACH, lead-free solder)
Partnerships
                                                           • EMD serves on Steering
           Shuttle Environmental                             Committee
             Assurance (SEA)
                                                           • RRAC and TEERM participate


         Joint Group on Pollution                          • EMD is a member
            Prevention (JGPP)
                                                           • RRAC is implementation lead


                                                           • Participate within Safety and
   Joint Army, Navy, NASA and Air
           Force (JANNAF)                                    Environmental Protection
                                                             Subcommittee (SEPS)

                                                           • EMD is a member
Department of Defense Clean Air
Act Services Steering Committee                            • Provides insight into impacts
         (DOD CAASSC)                                        from regulation
RRAC - Regulatory Risk Analysis and Communication   TEERM - Technology Evaluation for Environmental Risk Mitigation
Trends
Environmental Assurance
                  Risk Drivers
Government Requirements
• EHS-related statutes, regulations, executive orders, or policies that set
  requirements
Other Environment, Health, and Safety Considerations
• Considerations related to environment, health or safety
• Often, but not always, related to “government requirements”
Vendor Economics & Issues
• Vendor decisions to change formulations, cease production of a material, or
  otherwise impact materials and processes
• Often related to the other drivers
Technology and Market-Based Forces
• Technology advances can reduce manufacturers’ incentives to produce
  technologically obsolete materials
• Global trends in materials selection and procurement can impact materials
  availability by reducing production viability of certain low-volume items
Natural Disasters
• Manufacturing facilities and infrastructure damage by earthquake, hurricane, fire
  and other disasters can affect manufacturers’ ability or willingness to produce
  materials
US Regulatory Trends and Issues
    Create New External Requirements
•   New U.S. air emission requirements
•   More international requirements and pressures to manage
    chemical/material risk
•   Expansion of climate change measures
•   More restrictive requirements for worker, public, and
    environmental safety




•   NASA will continue to comply with external requirements (US)
•   Implementation of external requirements without understanding
    mission impacts may compromise both implementation of
    requirements and NASA’s ability to execute its mission
    effectively
•   NASA will choose how to meet external requirements to
    maximize mission success
Environmental Regulatory
       Landscape
   International        United States

       Multi-Lateral
      Environmental      U.S. Federal
    Agreements (MEAs)    Regulations



Foreign Statutes             State and Local
and Regulations               Regulations
Multilateral Environmental Agreements
    (MEAs) Generated Risk Drivers
 • Future ratification of MEAs could initiate U.S.
   activities to comply with new requirements,
   either through existing laws and regulations or
   development of new ones
 • Growing influence by Europe, China, and
   others in setting global environmental agenda
   and standards
 • Diminished U.S. role in international arena
   with respect to
    – Prioritization of environmental issues
    – International requirements development
    – Environmental problem solving
Key Multilateral Environmental
          Agreements (MEAs)
    Multilateral Environmental        Initial              Ratified
      Agreements (MEAs)              Agreement
                                                 Parties   by U.S.               Focus

Montreal Protocol                      1989       189        Yes      ODS phaseout
Basel Convention                       1992       167        No       recyclables trade
Convention on Biological Diversity     1992       188        No       biodiversity/access &benefits
Law of the Sea                         1994       149        No       ocean governance
Chemical Weapons Convention            1997       176        Yes      weapon bans/ inspections
Biosafety Protocol                     2003       131        No       LMOs commodities
LRTAP – Heavy Metals                   2003        27        Yes      heavy metals
LRTAP – POPs                           2003        25        No       chemical bans
Rotterdam PIC Convention               2004       102        No       chemicals trade
Stockholm POPs Convention              2004       119        No       chemical bans
Kyoto Protocol                         2005       160        No       climate change
International Influences on
       Material Selection and Use
Multilateral Environmental Agreements (MEAs)
• Persistent Organic Pollutants (POPs)
• Long-Range Transboundary Air Pollution (LRTAP)

European Union
• Registration, Evaluation, and Authorization of Chemicals
  (REACH)
• Restriction of Hazardous Substances (RoHS)
• Waste Electrical and Electronic Equipment (WEEE)

Asia
• Emerging RoHS-like laws in China and Korea
Partial List of Materials and
      Processes of Concern
• Trichloroethane
• Precision Cleaning and Cleanliness Verification Processes
  Requiring ODSs (HCFC 225 and HCFC 225g)
• TPS and Cryoinsulation Containing ODS (HCFC 141b)
• Chromate Primers
• Cadmium Plating
• Hexavalent Chromium Conversion Coating
• Paint Strippers Containing Methylene Chloride
• Lead Based Solid Film Lubricants
• Paints Containing Perchloroethylene
• High-Level Volatile Organic Compound (VOC) Coatings
• Alkaline Cleaners Containing Hexavalent Chromium
• Hazardous Air Pollutant (HAP) Inks
• Methyl Ethyl Ketone
• Materials and Products Containing Perfluoroalkyl Sulfonates
• Materials Containing Brominated Flame Retardants
• Materials Requiring Perfluorooctanoic Acid (PFOA)
Summary
Summary
• We are leveraging and refocusing
  environmental capabilities at Centers and
  Headquarters to develop Environmental
  Assurance in support of mission
• Environmental Assurance practiced at NASA
  will work to proactively identify,
  communicate, and mitigate risks to mission
  in a changing regulatory and resource-
  constrained climate to maximize options for
  programs and projects.
Contacts and
 Resources
Contacts and Resources
James Leatherwood                             Chris Brown
Director, Environmental Management Division   Technology Evaluation for Environmental
202.358.3608                                  Risk Mitigation
james.leatherwood-1@nasa.gov                  321.867.8463
                                              christina.m.brown@nasa.gov
David Amidei
Environmental Assurance for NASA Systems
                                              Steve Glover
                                              Shuttle Environmental Assurance
202.358.1866
                                              256.544.5016
damidei@nasa.gov
                                              steve.e.glover@nasa.gov

Ted Biess
Environmental Assurance for NASA Systems
                                              Paul Robert
                                              Center Operational Assurance
202.358.2272
                                              202.358.1305
theodore.biess-1@nasa.gov
                                              paul.robert-1@nasa.gov

Sharon Scroggins
Regulatory Risk Analysis and Communication
256.544.7932
sharon.scroggins@nasa.gov
Websites
Environmental Management Division
http://oim.hq.nasa.gov/oia/emd/index.html

Technology Evaluation for Environmental Risk
Mitigation
http://acqp2.nasa.gov/

FedCenter (Government Environmental Portal)
http://www.fedcenter.gov/

Clean Joint Group on Pollution Prevention
http://www.jgpp.com/index.html
Backup
Montreal Protocol
                                          • Antarctic ozone hole discovered
                                            in late 1985
                                          • Governments recognized the
                                            need for stronger measures to
                                            reduce the production and
                                            consumption of a number of
                                            CFCs and Halons
                                          • Adopted on 16 September 1987
                                            in Montreal Canada
                                          • Signed by President Reagan on
                                            April 5, 1988
                                          • Came into force on 1st January
                                            1989, when it was ratified by 29
                                            countries and the European
                                            Economic Community


http://ozone.unep.org/Treaties_and_Ratification/2B_montreal_protocol.asp
NASA Systems and Processes Requiring
  Ozone Depleting Substances (ODS)
• Foam Blowing (Thermal Protection System
  Foams)
• Rubber Cleaning, Surface Activation, and
  Bonding
• Solvent Cleaning, Precision Cleaning, and
  Cleanliness Verification
• Refrigeration and Operational Cooling
• Fire Suppression
Requirement for Essential Usage
      Exemption from EPA
• NASA is required to actively search for alternatives to
  materials and processes which use phased out ODS
• NASA is required to perform semiannual usage reports
  and submit them to the EPA

Recent Feedback from EPA
• The document mentions that different alternatives have been tested, but it
  gives no indication if those tests are ongoing and at what level, what
  substances, etc - NASA needs to be more explicit. There is no mention of a
  reduction in their use of ODS over time, unlike in other sections of the
  document.
• It is problematic for NASA to state that it has "[no] plans to seek replacement
  for implementation on [Space Shuttle Program]" (pg 12 in table 4.1). The
  petition process as currently designed requires anyone who seeks an
  exemption to be actively searching for alternatives and documenting that
  search in their petitions. EPA expects an affirmative statement about NASA’s
  research plans for ODS substitutes for new vehicles. (Seema Schappelle,
  Bella Maranion, and Suzie Kocchi)
The NASA Organizational Chart
Chief Safety & Mission Assurance
                                   Office of the                          Chief of Staff
                                   Administrator
 Program Analysis & Evaluation         Administrator                     Inspector General
                                    Deputy Administrator
 Chief Engineer                    Associate Administrator               NASA Advisory Groups



Mission Directorates                                    Mission Support Offices
 Aeronautics Research                                        Chief Financial Officer
 Exploration Systems                                         Chief Information Officer
 Science                                                     General Counsel
 Space Operations                                            Integrated Enterprise Mgmt Program

                                                             Innovative Partnership Program
NASA Centers                                                 Security & Program Protection
 Ames Research Center
                                                             Chief Health & Medical Officer
 Dryden Flight Research Center
                                                             Institutions & Management
 Glenn Research Center
                                                               NASA Shared Services Center
 Goddard Space Flight Center                                   Human Capital Management
                                                               Infrastructure and Administration
 Jet Propulsion Laboratory                                     Diversity and Equal Opportunity
                                                               Procurement
 Johnson Space Center
                                                               Small & Disadvantaged Business Utilization
 Kennedy Space Center
                                                             Strategic Communications
 Marshall Space Flight Center                                   Education
 Langley Research Center                                        External Relations
                                                                Legislative Affairs
 Stennis Space Center                                           Public Affairs
Impacts of Design Decisions




•   For a typical product, 70% of the cost of development, manufacture and
    use is determined in its design phase.
•   Graphs are analogous for environmental impacts
•   Engaging in upfront product design can increase efficiency, reduce
    waste of materials and energy, reduce costs, impart new performance
    and capabilities, incorporate “inherently benign”
Environmental Management
Environmental Performance           Initiatives


                                                            Environmental
                                                             Assurance
                                                                 2006

                                               Pollution
                                              Prevention
                                                 1992

                                 Compliance
                                   1969


                                          Mission Success
Environmental Management
              Initiatives
Compliance (initiated in 1969)
• Comply with Environmental Regulations
• Creates unexpected consequences (e.g., costs, etc.) that threaten
  mission
• Seen as a burden

Pollution Prevention (initiated in 1992)
•   Attempt to prevent environmental hazards and costs
•   Improve control of environmental performance
•   Save funding by avoiding expenditures from environmental damage
•   Save funding from avoiding cost of compliance

Environmental Assurance (initiated in 2006)
• Focus on increasing environmental quality, improving cost
  effectiveness, and reducing risks to mission
• Enlarges trade space for mission
• Seek situations where there is a win for mission and a win for the
  environment
Key U.S. Federal Laws
                Regulation                  Published                       Focus
                                                        environmental assessments for proposed
National Environmental Policy Act (NEPA)      1969
                                                        Actions
Clean Air Act (CAA)                           1970      ODS phaseout, hazardous air pollutants
                                                        regulation discharge of pollutants to
Clean Water Act (CWA)                         1977
                                                        waterways
Comprehensive Environmental Response,
                                              1980      cleanup of hazardous substances
Compensation, and Liability Act (CERCLA)
Emergency Planning and Community Right-
                                              1986      reporting releases of chemical hazards
to-Know Act (EPCRA)
                                                        protection of threatened and endangered
Endangered Species Act (ESA)                  1973
                                                        species
Occupational Safety and Health Act (OSHA)     1970      protection of worker safety
Pollution Prevention Act (PPA)                1990      national policy for pollution prevention
Resource Conservation and Recovery Act
                                              1976      hazardous waste management
(RCRA)
Superfund Amendments and
                                              1986      cleanup of hazardous substances
Reauthorization Act (SARA)
Toxic Substances Control Act (TSCA)           1976      chemical usage tracking
Global Climate Protection Act                 1987      guidance for national climate program
Example of Indirect Impact on
          Supply Chain
Restriction of Hazardous Substances (RoHS)
• Effective 1 July 2006
• Bans several materials used in new electrical and
  electronic equipment (EEE)

 - Lead
 - Cadmium
 - Mercury
 - Hexavalent Chromium
 - PBB and PBDE flame
   retardants

                                 Tin whisker growing from the case of one
                                 relay in the direction of an adjacent relay.
Past NASA Environmental
     Assurance Successes
Preparation and Negotiation of 2
Exemption Petitions for Continued
Production and Use of HCFC 141b
 – Blowing agent currently is used in mission-critical
   thermal protection systems (TPS)
 – Storing (stockpiling) HCFC 141b poses unacceptable
   risk of instability and contamination
 – Continued production of this banned substance is
   essential to SSP
 – These exemptions allow for the procurement of fresh
   material for use in External Tank TPS; RSRM Nozzle
   Foam Plug; Orbiter’s cryogenic insulation; and
   Booster bolt catchers, repairs and closeouts.
Past NASA Environmental
            Assurance Successes
Active NASA participation in the rulemaking negotiation process
for several National Emission Standards for Hazardous Air
Pollutants (NESHAPs) regulations
   – significant benefits to space operations by influencing several categories
   – rules under the Clean Air Act requiring stringent control measures for reducing HAP
     emissions

Aerospace NESHAP: obtained exemptions from surface coating and cleaning requirements
for space vehicles
Rocket Engine Test Firing NESHAP: convinced EPA that it is impractical to impose
emission limitations on rocket engine test firing operations
Miscellaneous Metal Parts and Products NESHAP: On-site NASA metal surface coating
& related operations were excluded from this rule
Plastic Parts and Products NESHAP: On-site NASA plastic & composite surface coating
& related operations were excluded from this rule
Defense Land Systems and Miscellaneous Equipment (DLSME) NESHAP (ongoing):
On-site NASA non-flight hardware surface coating, cleaning and paint removal operations
will likely have only limited restrictions that are tailored to NASA systems and requirements
Risk Characterization
        Risk = f(Hazard, Exposure)
      Risk = f(Hazard, Dose, Time)




National Academy of Sciences, 1983.
NASA Risk Statement Structure
      Given that          there is a possibility that
     CONDITION              CONSEQUENCE
                                  will occur
• Must be a FACT or      • Must have a
  perceived to be          NEGATIVE impact to
  FACT                     the CONDITION
• Must be REALITY
  BASED                      Additionally, a single event
• Can have NO                could trigger several risks
  uncertainty attached       and have multiple
                             consequences

A good risk statement must be ACTIONABLE and have
ONE condition and ONE consequence per statement
Example EA Risk

                                             there is a
          Given that
                                           possibility that
• The SSP utilizes Class I and Class
  II ozone-depleting substances
                                        • ODS will be specified for
  (ODS) for critical precision            development and O&M of Cx
  cleaning and cleanliness
  verification operations                 systems
• Cx systems have shuttle-heritage      • NASA will not have access to
• Some LOX systems currently do
  not have substitutes for these          needed supplies of ODS
  ODSs (e.g., CFC 113, HCFC 225) for
  critical precision cleaning and       • Cx systems will not have
  cleanliness verification operations     ability to perform critical
• All Class II ODS production will be
  discontinued and usage will be          precision cleaning and
  highly regulated in the US by           cleanliness verification
  January 1, 2015
                                          operations
The Twelve Principles of Green
              Chemistry
1.  Prevention. It is better to prevent waste than to treat or clean up waste after it has been created.
2.  Atom Economy. Synthetic methods should be designed to maximize the incorporation of all
    materials used in the process into the final product.
3. Less Hazardous Chemical Syntheses. Wherever practicable, synthetic methods should be
    designed to use and generate substances that possess little or no toxicity to human health and the
    environment.
4. Designing Safer Chemicals. Chemical products should be designed to effect their desired
    function while minimizing their toxicity.
5. Safer Solvents and Auxiliaries. The use of auxiliary substances (e.g., solvents, separation
    agents, etc.) should be made unnecessary wherever possible and innocuous when used.
6. Design for Energy Efficiency. Energy requirements of chemical processes should be recognized
    for their environmental and economic impacts and should be minimized. If possible, synthetic
    methods should be conducted at ambient temperature and pressure.
7. Use of Renewable Feedstocks. A raw material or feedstock should be renewable rather than
    depleting whenever technically and economically practicable.
8. Reduce Derivatives. Unnecessary derivatization (use of blocking groups, protection/ deprotection,
    temporary modification of physical/chemical processes) should be minimized or avoided if possible,
    because such steps require additional reagents and can generate waste.
9. Catalysis. Catalytic reagents (as selective as possible) are superior to stoichiometric reagents.
10. Design for Degradation. Chemical products should be designed so that at the end of their
    function they break down into innocuous degradation products and do not persist in the
    environment.
11. Real-time analysis for Pollution Prevention. Analytical methodologies need to be further
    developed to allow for real-time, in-process monitoring and control prior to the formation of
    hazardous substances.
12. Inherently Safer Chemistry for Accident Prevention. Substances and the form of a substance
    used in a chemical process should be chosen to minimize the potential for chemical accidents,
    including releases, explosions, and fires.
*Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 1998, p.30.
The Twelve Principles of Green
             Engineering
1.  Inherent Rather Than Circumstantial. Designers need to strive to ensure that all materials and
    energy inputs and outputs are as inherently nonhazardous as possible.
2. Prevention Instead of Treatment. It is better to prevent waste than to treat or clean up waste after
    it is formed.
3. Design for Separation. Separation and purification operations should be designed to minimize
    energy consumption and materials use.
4. Maximize Efficiency. Products, processes, and systems should be designed to maximize mass,
    energy, space, and time efficiency.
5. Output-Pulled Versus Input-Pushed. Products, processes, and systems should be "output
    pulled" rather than "input pushed" through the use of energy and materials.
6. Conserve Complexity. Embedded entropy and complexity must be viewed as an investment
    when making design choices on recycle, reuse, or beneficial disposition.
7. Durability Rather Than Immortality. Targeted durability, not immortality, should be a design goal.
8. Meet Need, Minimize Excess. Design for unnecessary capacity or capability (e.g., "one size fits
    all") solutions should be considered a design flaw.
9. Minimize Material Diversity. Material diversity in multicomponent products should be minimized to
    promote disassembly and value retention.
10. Integrate Material and Energy Flows. Design of products, processes, and systems must include
    integration and interconnectivity with available energy and materials flows.
11. Design for Commercial "Afterlife". Products, processes, and systems should be designed for
    performance in a commercial "afterlife."
12. Renewable Rather Than Depleting. Material and energy inputs should be renewable rather than
    depleting.



 * Anastas, P.T., and Zimmerman, J.B., "Design through the Twelve Principles of Green Engineering", Env. Sci. and Tech., 37, 5, 95 ? 101, 2003.
U.S. Climate Change Proposals
            Climate Change Legislative Proposals in
                        U.S. Congress

  120
  100
   80
   60
   40
   20
   0
        1997-1998     1999-2000     2001-2002         2003-2004



Note: President Bush’s 2007 State of the Union address
Worker Safety
• OSHA
  – Hexavalent Chromium PEL Reduction
  – Crystalline Silica Exposure Standard
  – Beryllium Exposure Standard
  – Explosives Standard
• State Requirements
• International Requirements
JCAA/JG-PP Lead-Free Solder Testing for High-Reliability
                      Applications
European Union RoHS Directive
• Reduction of Hazardous Substances (RoHS)
    – EU Directive banning “placing on market” new electronic equipment containing specific
       levels of the following after July 1, 2006
         • Lead, Cadmium, Mercury, hexavalent chromium, polybrominated biphenyl (PBB),
            polybrominated diphenyl ether (PBDE) flame retardants
    – Seeks to reduce the environmental impact of EEE by restricting the use of certain
       hazardous substances during manufacture
    – Related legislation underway in China and Japan
• Consumer electronics are driving commercial market to lead-free alternatives
    – Lead-free brings new and re-emerging failure modes in electronics
    – Most consumer electronics are throw away
    – NASA has unique operating environment which drive additional requirements
    – Electronic industry minimally impacted by aerospace requirements
         • Estimated aerospace use = 1% solder and components
• Primary lead-free impacts
    – Lead-free solder issues
    – Tin whisker failures
    – Availability of leaded solder and components
    – New processes / configuration control
• Commercial solution strategies for lead-free may not apply to Military / Aerospace
   applications
JCAA/JG-PP Lead-Free Solder Testing for High-Reliability
                      Applications
Background
• International collaborative effort
    – Project begun under the auspices of the U.S. DoD’s Joint Group on Pollution Prevention
       (JG-PP), then turned over to the DoD’s Joint Council on Aging Aircraft (JCAA)
       (concerned about numerous lead-free solder logistical and repair issues)
    – DoD, NASA, U.S. and European defense and space OEMs, and component & solder
       suppliers
    – Project Completed
         • Results highly anticipated by NASA & industry. Issues critical for Constellation
            program risk reduction.
         • Findings of high value to hundreds of stakeholders. No one else looking at lead-free
            solder for high reliability applications as in depth
Next Step
• NASA Lead-Free Electronics Project
    – Data generated from the this project is required to gain a better understanding of how
       lead-free electronics will perform in high-reliability aerospace applications.
    – Even though NASA and the aerospace community are exempt from lead-free laws and
       regulations, there may not be enough suppliers available to meet needs
    – Military and aerospace OEMs are receiving unwanted electronics components with lead-
       free finishes

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Biess ted

  • 1. Environmental Assurance for NASA Systems Ted Biess NASA Headquarters Environmental Management Division February 7, 2007
  • 2. Outline • Alignment with Mission • Environmental Assurance Context • Example Environmental Impact on Shuttle • Focus, Definition, and Goals • Organizational Structure – Principal Centers – International Component – Partnerships • Trends • Summary • Contracts and Resources
  • 3. Alignment with Mission
  • 5. Environmental Management Drivers, Context, and Issues • Activity is driven by external requirements (e.g., statutes, Executive Orders, public outcry) – Regulatory framework is the main driver for change • Identify, quantify, measure, monitor, review and assess environmental problems. • Sometimes in conflict with mission goals
  • 6. Agency Strategic Goals Fly the Shuttle as safely as possible until its retirement, not later 1 than 2010. Complete the International Space Station in a manner consistent 2 with NASA’s International Partner commitments and the needs of human exploration. Develop a balanced overall program of science, exploration, and 3 aeronautics consistent with the redirection of the human spaceflight program to focus on exploration. Bring a new Crew Exploration Vehicle into service as soon as 4 possible after Shuttle retirement. Encourage the pursuit of appropriate partnerships with the 5 emerging commercial space sector. Establish a lunar return program having the maximum possible 6 utility for later missions to Mars and other destinations.
  • 7. Environmental Management Goals to Support Mission Direct Mission Support 1 Provide direct mission support by integrating environmental considerations into programs and projects. 2 Proactive Risk Mitigation Proactively reduce NASA’s exposure to institutional, programmatic and operational risk. 3 Protect Mission Resources Pursue environmental initiatives designed to restore, protect and enhance mission resources.
  • 8. Alignment with Mission Environmental Management Division Management & Support Protection of Direct Mission Proactive Risk Mission Resources Support Mitigation Environmental National Environmental Functional Reviews Environmental Assurance Policy Act (NEPA) Cleanup and Center Future Remediation Operational Cultural & Historic Environmental Preservation Assurance Management Sys. Regulated Materials Energy Emerging Contaminants Recycling & Affirmative Proc.
  • 10. System Inputs & Outputs Model OUTPUTS INPUTS waste heat raw materials solid waste waste stream air emissions attributes ‘end determine of fuels / energy inputs water emissions pipe’ and outputs usable products
  • 11. Impacts of Design Decisions Lifecycle Cost Operations and Support System Acquisition $ Production System R&D 100 95 Lifecycle cost 85 locked in 70 Lifecycle cost expended 50 Disposal 60% Cost? 10% 30% 10 Time Concept Production and Initial Out of Exploration Development Operational Service Concept and Full Scale Capability Validation Development From W. J. Larson & L. K. Pranke (1999) Human Spaceflight: Mission Analysis and Design
  • 12. Managing to External Requirements • Agency Regulations • Executive Order 13287 - Preserve America • Archaeological Resources Protection Act • Fish and Wildlife Coordination Act • Biobased Product Procurement • Global Climate Protection Act Requirements • Green Computer (EPEAT) Procurement • Clean Air Act (CAA) Requirements • Clean Water Act (CWA) • ISO14001 - Environmental Management • Safe Drinking Water Act Standard • Comprehensive Environmental Response, • Landfill Disposal Standards Compensation, and Liability Act (CERCLA) • Local Regulations • Costal Zone Management Act • Marine Mammal Protection Act • Emergency Planning and Community • Migratory Bird Treaty Act Right-to-Know Act (EPCRA) • National Environmental Policy Act (NEPA) • Endangered Species Act (ESA) • National Historic Preservation Act • Energy Policy Act of 2005 • Occupational Safety and Health Act • Executive Order 11988 - Floodplain (OSHA) Management • Pollution Prevention Act (PPA) • Executive Order 11990 - Protection of • Resource Conservation and Recovery Act Wetlands (RCRA) • Executive Order 12114 - Environmental • State Regulations Effects Abroad of Major Federal Actions • Superfund Amendments and • Executive Order 12898 - Environmental Reauthorization Act (SARA) Justice • Toxic Substances Control Act (TSCA) • Executive Order 13148 - Greening the Government
  • 13. Trends for Long-Life Systems ? Increasing Env. Regulation ? Increased regulation means increased ? operational restrictions, mandated controls, What will be the cost uncertainty, added effects/regulation and schedule delays from more liberal Administrations and Congresses? 2010 2020 2030 2040 Apollo Shuttle VSE Source: J. A. Cusumano, New Technology for the Environment, Chemtech, 1992, 22(8), 482–489
  • 14. Includes DDT&E and operations – environmental factors act primarily in the ops phase Adapted from Ares 1 SRR Presentation, Nov 6-7, 2006
  • 15. NASA incurs O&M costs and risks associated with environmental issues Adapted from Ares 1 SRR Presentation, Nov 6-7, 2006
  • 17. Ozone Hole Discovered in 1985 NASA and NOAA Announce Ozone Hole is a Double Record Breaker October 19, 2006 From September 21-30, 2006 the average area of the ozone hole was the largest ever observed, at 10.6 million square miles. This image, from Sept. 24, the Antarctic ozone hole was equal to the record single-day largest area of 11.4 million square miles, reached on Sept. 9, 2000. The blue and purple colors are where there is the least ozone, and the greens, yellows, and reds are where there is more ozone. http://www.nasa.gov/vision/earth/lookingatearth/ozone_record.html
  • 18. Shuttle Ozone Depleting Substance (ODS) Applications External Tank Solid Rocket Boosters External Tank: 4 TPS Foams Orbiter Forward SRB/ET Attach Strut RSRM Orbiter Applications: Main Propulsion SRB/ET Attach System and Ring Aft SRB/ET Power Reactant Attach Struts (3) Storage and Distribution System Aft Stiffener Rings (3) Locations of HCFC 141b foams are RSRM: noted in blue Space Shuttle Nozzle Main Engines
  • 19. Thermal Protection System (TPS) Development Timeline 1988 Initiated CFC 11 blowing agent replacement investigations Made decision to implement HCFC 141b as near drop-in replacement rather than pursue Essential Use Exemption. Initiated detailed 1991 development activities and design verification testing with HCFC 141b. Estimated completion date 1996. Began development of ODS-free (without HCFC 141b) foam; estimated 1992 completion by 2003 which is phase-out date of all Class II ODS. Initiated production implementation of 3 out of 4 CFC 11 foams with 1993 formulations containing HCFC 141b 2002 Replaced remaining CFC 11 foam with HCFC 141b alternate HCFC 141b phased out in US. ODS-free foam is not available. Resources 2003 and attention is overtaken by Columbia Accident and Return to Flight NASA still requires Essential Usage Exemption for continued use of 2007 HCFC 141b within SSP. No plans for development of ODS-free foam due to Shuttle retirement in 2010.
  • 20. Elimination of Ozone Depleting Substances within NASA ODS Usage - kg (pounds) End Use Classification 1991 2004 Reduction Foam Blowing 36110 11530 (Thermal Protection System Foams) 68% (79600) (25400) Rubber Cleaning, Surface Activation, and 385100 10700 Bonding 97% (849000) (23500) Solvent Cleaning, Precision Cleaning, 1171000 23000 and Cleanliness Verification 98% (2600000) (50700) 130200 19000 Refrigeration and Operational Cooling 85% (287000) (41800) 3720 95 Fire Suppression 97% (8200) (210) • ODS elimination has been a priority within NASA • The majority of ODS usage has been eliminated • Mission critical uses remain for existing space vehicles, and possibly for future programs
  • 21. Environmental Assurance Focus, Definition, and Goals
  • 22. Environmental Assurance Focus Risks posed by the Program to the environment • Identified under NEPA through the Environmental Impact Statement (EIS) process prior to Program inception • The EIS describes programmatic options and addresses environmental considerations associated with each Risks posed to the Program by environmentally-related drivers • Real-time risks from a new environmental driver • Real-time risks from configuration issues/changes that trigger an existing driver
  • 23. Environmental Assurance Definition Environmental Assurance is the proactive detection, analysis, mitigation, and communication of environmentally driven risks to NASA mission-required research, development, fabrication, processing and operations.
  • 24. Environmental Assurance Goals 1. Identify, analyze, and measure environmentally driven programmatic and institutional risks. 2. Communicate environmentally driven programmatic and institutional risks to appropriate owners (when possible, in early phases of program and project planning and execution) 3. Team/partner with risk owners to proactively reduce risk’s impact, likelihood, and scope (e.g., may apply to multiple programs and projects) – Influence regulatory authorities – Acquire special waivers, if possible, from regulating organization – Identify and validate appropriate solutions for mitigation of environmentally driven risks. As needed, adapt high-TRL technology and/or increase TRL for new technology for NASA’s use. The risk owners (e.g., programs and projects) will have day-to-day responsibility for management of their risks.
  • 26. Environmental Assurance Structure Environmental Management Leadership & Division (EMD) Coordination NASA Headquarters Regulatory Risk Analysis and Principal Centers Communication (RRAC) MSFC Technology Evaluation for Environmental Risk Mitigation (TEERM) - KSC Centro Para Prevenção da Partner Organization Poluição (C3P) Lisbon, Portugal
  • 27. Leadership & Coordination - EMD • Provides management Environmental Management oversight of Principal Division (EMD) NASA Headquarters Centers • Interfaces with partner organizations - SEA, JGPP, Regulatory Risk Analysis and JANNAF, CAASSC Communication (RRAC) MSFC • Coordinates activity with regulatory agencies • Provides legislative Technology Evaluation for support, policy review, and Environmental Risk Mitigation (TEERM) - KSC guidance Centro Para Prevenção da Poluição (C3P) Lisbon, Portugal
  • 28. Principal Center – RRAC • Performs regulatory review Environmental Management and impact analysis Division (EMD) NASA Headquarters • Captures and analyzes emerging risks Regulatory Risk Analysis and • Develops mitigation Communication (RRAC) options MSFC • Recommends actions for influencing regulatory authorities Technology Evaluation for Environmental Risk Mitigation • Communicates risks to (TEERM) - KSC NASA programs and projects Centro Para Prevenção da Poluição (C3P) Lisbon, Portugal
  • 29. Principal Center – TEERM • Leads work to identify and Environmental Management test environmentally Division (EMD) NASA Headquarters preferable alternative materials and processes • Analyzes materials and Regulatory Risk Analysis and processes Communication (RRAC) MSFC • Manages joint test projects • Disseminates test Technology Evaluation for results Environmental Risk Mitigation (TEERM) - KSC • Develops risk mitigation options Centro Para Prevenção da • Participates with partners Poluição on joint projects – C3P and (C3P) Joint Group on Pollution Lisbon, Portugal Prevention (JGPP)
  • 30. Partner Organization – C3P • Works with multiple Environmental Management European partners Division (EMD) NASA Headquarters • Conducts joint projects focusing on elimination of hazardous materials to Regulatory Risk Analysis and meet emerging EU regs. Communication (RRAC) MSFC • Operates in ways similar to TEERM • Monitors European projects Technology Evaluation for concerning elimination of Environmental Risk Mitigation (TEERM) - KSC hazardous material • Provides conduit into Centro Para Prevenção da European Union for other Poluição activities of interest to (C3P) NASA (e.g., energy, Lisbon, Portugal REACH, lead-free solder)
  • 31. Partnerships • EMD serves on Steering Shuttle Environmental Committee Assurance (SEA) • RRAC and TEERM participate Joint Group on Pollution • EMD is a member Prevention (JGPP) • RRAC is implementation lead • Participate within Safety and Joint Army, Navy, NASA and Air Force (JANNAF) Environmental Protection Subcommittee (SEPS) • EMD is a member Department of Defense Clean Air Act Services Steering Committee • Provides insight into impacts (DOD CAASSC) from regulation RRAC - Regulatory Risk Analysis and Communication TEERM - Technology Evaluation for Environmental Risk Mitigation
  • 33. Environmental Assurance Risk Drivers Government Requirements • EHS-related statutes, regulations, executive orders, or policies that set requirements Other Environment, Health, and Safety Considerations • Considerations related to environment, health or safety • Often, but not always, related to “government requirements” Vendor Economics & Issues • Vendor decisions to change formulations, cease production of a material, or otherwise impact materials and processes • Often related to the other drivers Technology and Market-Based Forces • Technology advances can reduce manufacturers’ incentives to produce technologically obsolete materials • Global trends in materials selection and procurement can impact materials availability by reducing production viability of certain low-volume items Natural Disasters • Manufacturing facilities and infrastructure damage by earthquake, hurricane, fire and other disasters can affect manufacturers’ ability or willingness to produce materials
  • 34. US Regulatory Trends and Issues Create New External Requirements • New U.S. air emission requirements • More international requirements and pressures to manage chemical/material risk • Expansion of climate change measures • More restrictive requirements for worker, public, and environmental safety • NASA will continue to comply with external requirements (US) • Implementation of external requirements without understanding mission impacts may compromise both implementation of requirements and NASA’s ability to execute its mission effectively • NASA will choose how to meet external requirements to maximize mission success
  • 35. Environmental Regulatory Landscape International United States Multi-Lateral Environmental U.S. Federal Agreements (MEAs) Regulations Foreign Statutes State and Local and Regulations Regulations
  • 36. Multilateral Environmental Agreements (MEAs) Generated Risk Drivers • Future ratification of MEAs could initiate U.S. activities to comply with new requirements, either through existing laws and regulations or development of new ones • Growing influence by Europe, China, and others in setting global environmental agenda and standards • Diminished U.S. role in international arena with respect to – Prioritization of environmental issues – International requirements development – Environmental problem solving
  • 37. Key Multilateral Environmental Agreements (MEAs) Multilateral Environmental Initial Ratified Agreements (MEAs) Agreement Parties by U.S. Focus Montreal Protocol 1989 189 Yes ODS phaseout Basel Convention 1992 167 No recyclables trade Convention on Biological Diversity 1992 188 No biodiversity/access &benefits Law of the Sea 1994 149 No ocean governance Chemical Weapons Convention 1997 176 Yes weapon bans/ inspections Biosafety Protocol 2003 131 No LMOs commodities LRTAP – Heavy Metals 2003 27 Yes heavy metals LRTAP – POPs 2003 25 No chemical bans Rotterdam PIC Convention 2004 102 No chemicals trade Stockholm POPs Convention 2004 119 No chemical bans Kyoto Protocol 2005 160 No climate change
  • 38. International Influences on Material Selection and Use Multilateral Environmental Agreements (MEAs) • Persistent Organic Pollutants (POPs) • Long-Range Transboundary Air Pollution (LRTAP) European Union • Registration, Evaluation, and Authorization of Chemicals (REACH) • Restriction of Hazardous Substances (RoHS) • Waste Electrical and Electronic Equipment (WEEE) Asia • Emerging RoHS-like laws in China and Korea
  • 39. Partial List of Materials and Processes of Concern • Trichloroethane • Precision Cleaning and Cleanliness Verification Processes Requiring ODSs (HCFC 225 and HCFC 225g) • TPS and Cryoinsulation Containing ODS (HCFC 141b) • Chromate Primers • Cadmium Plating • Hexavalent Chromium Conversion Coating • Paint Strippers Containing Methylene Chloride • Lead Based Solid Film Lubricants • Paints Containing Perchloroethylene • High-Level Volatile Organic Compound (VOC) Coatings • Alkaline Cleaners Containing Hexavalent Chromium • Hazardous Air Pollutant (HAP) Inks • Methyl Ethyl Ketone • Materials and Products Containing Perfluoroalkyl Sulfonates • Materials Containing Brominated Flame Retardants • Materials Requiring Perfluorooctanoic Acid (PFOA)
  • 41. Summary • We are leveraging and refocusing environmental capabilities at Centers and Headquarters to develop Environmental Assurance in support of mission • Environmental Assurance practiced at NASA will work to proactively identify, communicate, and mitigate risks to mission in a changing regulatory and resource- constrained climate to maximize options for programs and projects.
  • 42.
  • 44. Contacts and Resources James Leatherwood Chris Brown Director, Environmental Management Division Technology Evaluation for Environmental 202.358.3608 Risk Mitigation james.leatherwood-1@nasa.gov 321.867.8463 christina.m.brown@nasa.gov David Amidei Environmental Assurance for NASA Systems Steve Glover Shuttle Environmental Assurance 202.358.1866 256.544.5016 damidei@nasa.gov steve.e.glover@nasa.gov Ted Biess Environmental Assurance for NASA Systems Paul Robert Center Operational Assurance 202.358.2272 202.358.1305 theodore.biess-1@nasa.gov paul.robert-1@nasa.gov Sharon Scroggins Regulatory Risk Analysis and Communication 256.544.7932 sharon.scroggins@nasa.gov
  • 45. Websites Environmental Management Division http://oim.hq.nasa.gov/oia/emd/index.html Technology Evaluation for Environmental Risk Mitigation http://acqp2.nasa.gov/ FedCenter (Government Environmental Portal) http://www.fedcenter.gov/ Clean Joint Group on Pollution Prevention http://www.jgpp.com/index.html
  • 47. Montreal Protocol • Antarctic ozone hole discovered in late 1985 • Governments recognized the need for stronger measures to reduce the production and consumption of a number of CFCs and Halons • Adopted on 16 September 1987 in Montreal Canada • Signed by President Reagan on April 5, 1988 • Came into force on 1st January 1989, when it was ratified by 29 countries and the European Economic Community http://ozone.unep.org/Treaties_and_Ratification/2B_montreal_protocol.asp
  • 48. NASA Systems and Processes Requiring Ozone Depleting Substances (ODS) • Foam Blowing (Thermal Protection System Foams) • Rubber Cleaning, Surface Activation, and Bonding • Solvent Cleaning, Precision Cleaning, and Cleanliness Verification • Refrigeration and Operational Cooling • Fire Suppression
  • 49. Requirement for Essential Usage Exemption from EPA • NASA is required to actively search for alternatives to materials and processes which use phased out ODS • NASA is required to perform semiannual usage reports and submit them to the EPA Recent Feedback from EPA • The document mentions that different alternatives have been tested, but it gives no indication if those tests are ongoing and at what level, what substances, etc - NASA needs to be more explicit. There is no mention of a reduction in their use of ODS over time, unlike in other sections of the document. • It is problematic for NASA to state that it has "[no] plans to seek replacement for implementation on [Space Shuttle Program]" (pg 12 in table 4.1). The petition process as currently designed requires anyone who seeks an exemption to be actively searching for alternatives and documenting that search in their petitions. EPA expects an affirmative statement about NASA’s research plans for ODS substitutes for new vehicles. (Seema Schappelle, Bella Maranion, and Suzie Kocchi)
  • 50. The NASA Organizational Chart Chief Safety & Mission Assurance Office of the Chief of Staff Administrator Program Analysis & Evaluation Administrator Inspector General Deputy Administrator Chief Engineer Associate Administrator NASA Advisory Groups Mission Directorates Mission Support Offices Aeronautics Research Chief Financial Officer Exploration Systems Chief Information Officer Science General Counsel Space Operations Integrated Enterprise Mgmt Program Innovative Partnership Program NASA Centers Security & Program Protection Ames Research Center Chief Health & Medical Officer Dryden Flight Research Center Institutions & Management Glenn Research Center NASA Shared Services Center Goddard Space Flight Center Human Capital Management Infrastructure and Administration Jet Propulsion Laboratory Diversity and Equal Opportunity Procurement Johnson Space Center Small & Disadvantaged Business Utilization Kennedy Space Center Strategic Communications Marshall Space Flight Center Education Langley Research Center External Relations Legislative Affairs Stennis Space Center Public Affairs
  • 51. Impacts of Design Decisions • For a typical product, 70% of the cost of development, manufacture and use is determined in its design phase. • Graphs are analogous for environmental impacts • Engaging in upfront product design can increase efficiency, reduce waste of materials and energy, reduce costs, impart new performance and capabilities, incorporate “inherently benign”
  • 52. Environmental Management Environmental Performance Initiatives Environmental Assurance 2006 Pollution Prevention 1992 Compliance 1969 Mission Success
  • 53. Environmental Management Initiatives Compliance (initiated in 1969) • Comply with Environmental Regulations • Creates unexpected consequences (e.g., costs, etc.) that threaten mission • Seen as a burden Pollution Prevention (initiated in 1992) • Attempt to prevent environmental hazards and costs • Improve control of environmental performance • Save funding by avoiding expenditures from environmental damage • Save funding from avoiding cost of compliance Environmental Assurance (initiated in 2006) • Focus on increasing environmental quality, improving cost effectiveness, and reducing risks to mission • Enlarges trade space for mission • Seek situations where there is a win for mission and a win for the environment
  • 54. Key U.S. Federal Laws Regulation Published Focus environmental assessments for proposed National Environmental Policy Act (NEPA) 1969 Actions Clean Air Act (CAA) 1970 ODS phaseout, hazardous air pollutants regulation discharge of pollutants to Clean Water Act (CWA) 1977 waterways Comprehensive Environmental Response, 1980 cleanup of hazardous substances Compensation, and Liability Act (CERCLA) Emergency Planning and Community Right- 1986 reporting releases of chemical hazards to-Know Act (EPCRA) protection of threatened and endangered Endangered Species Act (ESA) 1973 species Occupational Safety and Health Act (OSHA) 1970 protection of worker safety Pollution Prevention Act (PPA) 1990 national policy for pollution prevention Resource Conservation and Recovery Act 1976 hazardous waste management (RCRA) Superfund Amendments and 1986 cleanup of hazardous substances Reauthorization Act (SARA) Toxic Substances Control Act (TSCA) 1976 chemical usage tracking Global Climate Protection Act 1987 guidance for national climate program
  • 55. Example of Indirect Impact on Supply Chain Restriction of Hazardous Substances (RoHS) • Effective 1 July 2006 • Bans several materials used in new electrical and electronic equipment (EEE) - Lead - Cadmium - Mercury - Hexavalent Chromium - PBB and PBDE flame retardants Tin whisker growing from the case of one relay in the direction of an adjacent relay.
  • 56. Past NASA Environmental Assurance Successes Preparation and Negotiation of 2 Exemption Petitions for Continued Production and Use of HCFC 141b – Blowing agent currently is used in mission-critical thermal protection systems (TPS) – Storing (stockpiling) HCFC 141b poses unacceptable risk of instability and contamination – Continued production of this banned substance is essential to SSP – These exemptions allow for the procurement of fresh material for use in External Tank TPS; RSRM Nozzle Foam Plug; Orbiter’s cryogenic insulation; and Booster bolt catchers, repairs and closeouts.
  • 57. Past NASA Environmental Assurance Successes Active NASA participation in the rulemaking negotiation process for several National Emission Standards for Hazardous Air Pollutants (NESHAPs) regulations – significant benefits to space operations by influencing several categories – rules under the Clean Air Act requiring stringent control measures for reducing HAP emissions Aerospace NESHAP: obtained exemptions from surface coating and cleaning requirements for space vehicles Rocket Engine Test Firing NESHAP: convinced EPA that it is impractical to impose emission limitations on rocket engine test firing operations Miscellaneous Metal Parts and Products NESHAP: On-site NASA metal surface coating & related operations were excluded from this rule Plastic Parts and Products NESHAP: On-site NASA plastic & composite surface coating & related operations were excluded from this rule Defense Land Systems and Miscellaneous Equipment (DLSME) NESHAP (ongoing): On-site NASA non-flight hardware surface coating, cleaning and paint removal operations will likely have only limited restrictions that are tailored to NASA systems and requirements
  • 58. Risk Characterization Risk = f(Hazard, Exposure) Risk = f(Hazard, Dose, Time) National Academy of Sciences, 1983.
  • 59. NASA Risk Statement Structure Given that there is a possibility that CONDITION CONSEQUENCE will occur • Must be a FACT or • Must have a perceived to be NEGATIVE impact to FACT the CONDITION • Must be REALITY BASED Additionally, a single event • Can have NO could trigger several risks uncertainty attached and have multiple consequences A good risk statement must be ACTIONABLE and have ONE condition and ONE consequence per statement
  • 60. Example EA Risk there is a Given that possibility that • The SSP utilizes Class I and Class II ozone-depleting substances • ODS will be specified for (ODS) for critical precision development and O&M of Cx cleaning and cleanliness verification operations systems • Cx systems have shuttle-heritage • NASA will not have access to • Some LOX systems currently do not have substitutes for these needed supplies of ODS ODSs (e.g., CFC 113, HCFC 225) for critical precision cleaning and • Cx systems will not have cleanliness verification operations ability to perform critical • All Class II ODS production will be discontinued and usage will be precision cleaning and highly regulated in the US by cleanliness verification January 1, 2015 operations
  • 61. The Twelve Principles of Green Chemistry 1. Prevention. It is better to prevent waste than to treat or clean up waste after it has been created. 2. Atom Economy. Synthetic methods should be designed to maximize the incorporation of all materials used in the process into the final product. 3. Less Hazardous Chemical Syntheses. Wherever practicable, synthetic methods should be designed to use and generate substances that possess little or no toxicity to human health and the environment. 4. Designing Safer Chemicals. Chemical products should be designed to effect their desired function while minimizing their toxicity. 5. Safer Solvents and Auxiliaries. The use of auxiliary substances (e.g., solvents, separation agents, etc.) should be made unnecessary wherever possible and innocuous when used. 6. Design for Energy Efficiency. Energy requirements of chemical processes should be recognized for their environmental and economic impacts and should be minimized. If possible, synthetic methods should be conducted at ambient temperature and pressure. 7. Use of Renewable Feedstocks. A raw material or feedstock should be renewable rather than depleting whenever technically and economically practicable. 8. Reduce Derivatives. Unnecessary derivatization (use of blocking groups, protection/ deprotection, temporary modification of physical/chemical processes) should be minimized or avoided if possible, because such steps require additional reagents and can generate waste. 9. Catalysis. Catalytic reagents (as selective as possible) are superior to stoichiometric reagents. 10. Design for Degradation. Chemical products should be designed so that at the end of their function they break down into innocuous degradation products and do not persist in the environment. 11. Real-time analysis for Pollution Prevention. Analytical methodologies need to be further developed to allow for real-time, in-process monitoring and control prior to the formation of hazardous substances. 12. Inherently Safer Chemistry for Accident Prevention. Substances and the form of a substance used in a chemical process should be chosen to minimize the potential for chemical accidents, including releases, explosions, and fires. *Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 1998, p.30.
  • 62. The Twelve Principles of Green Engineering 1. Inherent Rather Than Circumstantial. Designers need to strive to ensure that all materials and energy inputs and outputs are as inherently nonhazardous as possible. 2. Prevention Instead of Treatment. It is better to prevent waste than to treat or clean up waste after it is formed. 3. Design for Separation. Separation and purification operations should be designed to minimize energy consumption and materials use. 4. Maximize Efficiency. Products, processes, and systems should be designed to maximize mass, energy, space, and time efficiency. 5. Output-Pulled Versus Input-Pushed. Products, processes, and systems should be "output pulled" rather than "input pushed" through the use of energy and materials. 6. Conserve Complexity. Embedded entropy and complexity must be viewed as an investment when making design choices on recycle, reuse, or beneficial disposition. 7. Durability Rather Than Immortality. Targeted durability, not immortality, should be a design goal. 8. Meet Need, Minimize Excess. Design for unnecessary capacity or capability (e.g., "one size fits all") solutions should be considered a design flaw. 9. Minimize Material Diversity. Material diversity in multicomponent products should be minimized to promote disassembly and value retention. 10. Integrate Material and Energy Flows. Design of products, processes, and systems must include integration and interconnectivity with available energy and materials flows. 11. Design for Commercial "Afterlife". Products, processes, and systems should be designed for performance in a commercial "afterlife." 12. Renewable Rather Than Depleting. Material and energy inputs should be renewable rather than depleting. * Anastas, P.T., and Zimmerman, J.B., "Design through the Twelve Principles of Green Engineering", Env. Sci. and Tech., 37, 5, 95 ? 101, 2003.
  • 63. U.S. Climate Change Proposals Climate Change Legislative Proposals in U.S. Congress 120 100 80 60 40 20 0 1997-1998 1999-2000 2001-2002 2003-2004 Note: President Bush’s 2007 State of the Union address
  • 64. Worker Safety • OSHA – Hexavalent Chromium PEL Reduction – Crystalline Silica Exposure Standard – Beryllium Exposure Standard – Explosives Standard • State Requirements • International Requirements
  • 65. JCAA/JG-PP Lead-Free Solder Testing for High-Reliability Applications European Union RoHS Directive • Reduction of Hazardous Substances (RoHS) – EU Directive banning “placing on market” new electronic equipment containing specific levels of the following after July 1, 2006 • Lead, Cadmium, Mercury, hexavalent chromium, polybrominated biphenyl (PBB), polybrominated diphenyl ether (PBDE) flame retardants – Seeks to reduce the environmental impact of EEE by restricting the use of certain hazardous substances during manufacture – Related legislation underway in China and Japan • Consumer electronics are driving commercial market to lead-free alternatives – Lead-free brings new and re-emerging failure modes in electronics – Most consumer electronics are throw away – NASA has unique operating environment which drive additional requirements – Electronic industry minimally impacted by aerospace requirements • Estimated aerospace use = 1% solder and components • Primary lead-free impacts – Lead-free solder issues – Tin whisker failures – Availability of leaded solder and components – New processes / configuration control • Commercial solution strategies for lead-free may not apply to Military / Aerospace applications
  • 66. JCAA/JG-PP Lead-Free Solder Testing for High-Reliability Applications Background • International collaborative effort – Project begun under the auspices of the U.S. DoD’s Joint Group on Pollution Prevention (JG-PP), then turned over to the DoD’s Joint Council on Aging Aircraft (JCAA) (concerned about numerous lead-free solder logistical and repair issues) – DoD, NASA, U.S. and European defense and space OEMs, and component & solder suppliers – Project Completed • Results highly anticipated by NASA & industry. Issues critical for Constellation program risk reduction. • Findings of high value to hundreds of stakeholders. No one else looking at lead-free solder for high reliability applications as in depth Next Step • NASA Lead-Free Electronics Project – Data generated from the this project is required to gain a better understanding of how lead-free electronics will perform in high-reliability aerospace applications. – Even though NASA and the aerospace community are exempt from lead-free laws and regulations, there may not be enough suppliers available to meet needs – Military and aerospace OEMs are receiving unwanted electronics components with lead- free finishes