>> THANK YOU FOR COMING TO THE
FEDERAL ENVIRONMENTAL SYMPOSIUM
DAY 2 AND TRACK 2.
THIS IS MARK AND A WILL BE
MANAGING THE EMERGING CHEMICAL
TRACKER AND I WANT TO GIVE A
WARM WELCOME TO MR. PETRO DA
SILVA WITH FIVE YEARS OF
EXPERIENCE.
WITH VARIOUS PROJECTS INCLUDING
REMEDIATION AND WILL PRESENT TO
US TODAY ON MACHINE LEARNING
STRATEGY FOR PFAS CONTAMINATION.
>> WELCOME EVERYBODY.
I'LL TALKING ABOUT MY IN PFAS IN
DRINKING WATER WELLS.
I HAVE A SPECIALIZATION IN WATER
RESOURCES FROM UCLA.
I AM WORKING TO GET MY P.E. IN
CALIFORNIA.
I HAVE FIVE YEARS EXPERIENCE IN
THE PRESENTATION WAS DONE FOR MY
MASTER'S AND MY TOPIC WAS
FOCUSSED ON HOW A.I. CAN BE USED
TO SOLVE ENVIRONMENTAL PROBLEMS
AND MANY ISSUES RESOLVED AROUND
CONTAMINANTS.
I SAMPLED FOR PFAS AND PEOPLE
MAYBE UNCONSCIOUSLY TO THE
SUBSTANCE.
THE PRESENTATION WILL START BY
GIVING A BRIEF INTRODUCTION ON
PFAS AND MONITORING EFFORTS IN
OUR AREA OF INTEREST,
CALIFORNIA.
OUR GOAL WAS TO GO OFF PREVIOUS
STUDIES USING MACHINE LEARNING
AND USE THE RESULTS FOR SAMPLING
TO BE PRIORITIZED AND I'VE
GLEANED FROM WORK ON THE PROJECT
FUTURE RESEARCH OPPORTUNITIES
AND AN OVERVIEW OF HOW MACHINE
LEARNING IS BEING USED FOR OTHER
SIMILAR APPLICATIONS.
WHAT ARE PFAS?
IT'S A GROUP OF TOXIC AND
PERSISTENT CONTAMINANTS AS LONG
CHAIN ORGANIC MOLECULES AND HAVE
A HYDRO PHILIC HEAD AND THERE'S
THOUSAND OF CHEMICALS SUCH AS
TEXTILES AND STAIN-RESISTANT
COATINGS, SUR FACTANTS AND PEFKT
-- SPECIFICALLY A FIRE FIGHTING
FOAM TO SUPPRESS FIRES.
MOST CHEMICALS ARE SIMILAR IN
AND PROPERTIES AND FAIRLY MOBILE
AND STABLE IN THE ENVIRONMENT.
THE PERSISTENT IS USE TO THE
BOND DIFFICULT TO BREAK CAUSING
THEM TO BE RESISTANT TO
DEGRADATION.
THE MOBILITY COMES FROM THE
SURFACTANT AND IT'S BEEN LINKED
TO ENDOCRINE DESCRIPTION AND
IT'S AN ELUSIVE ENVIRONMENTAL
POLLUTANT.
TO A QUICK OVERVIEW OF THE TIME
LINE OF THE PFAS EMERGENCE AND
AWARENESS IN THE U.S., PFAS WAS
FIRST DEVELOPED IN THE 1930s AND
'40s BY DUPONT AND USED IN MANY
APPLICATIONS.
IT'S GOOD AS AN OIL, WATER OR
STAIN REPELLENT AND STABLE AND
FRICTION RESISTANT AND UTILIZED
IN AEROSPACE, AUTOMOBILE AND
MANY OTHER INDUSTRIES AND THERE
WAS GROWING AWARENESS OF THE
AFFECT OF PFAS DUE TO INCIDENCE
OF IMPROPER DISPOSAL.
PFAS LATENT WASTE AND COMPANIES
WERE STARTING TO BE PRESSURED TO
DEVELOP LESS TOXIC SUBSTITUTES.
GOVERNMENT AGENCIES BEGAN
EFFORTS TO CHARACTERIZE PFAS
CONTAMINATION SPEARHEADED BY THE
EPA AND STATE OF MICHIGAN.
THERE WAS A SAMPLE OF WATER
SYSTEMS AS PART OF THE THIRD
UNREGULATED CONTAMINANT
MONITORING RULE AND FOUND
WIDESPREAD CONTAMINATION OF PFAS
ALL OVER THE COUNTRY.
OUR MAIN TAKEAWAY IS IT'S BEEN
IN USE OVER 70 YEARS AND
ADDRESSING THE ISSUE IS
RELATIVELY NEW.
IN 2017 THE U.S. EPA FOUND
THRESHOLDS AND STANDARDS OF 70
PARTS PER TRILLION AND THE EPA
REDUCED THE ADVISORY LEVEL FOR
THE CHEMICALS AS WELL AS ADDING
OTHERS TO THE LIST.
IT SHOWS CONSUMPTION OF WATER
WITH THESE LEVELS IS POTENTIALLY
DANGEROUS.
IN 2023 THE EPA IMPOSED THE
STANDARD FOR SIX PFAS CHEMICALS.
THEY'RE MEANT TO BE MINIMUM
ENFORCE AND LEVELS AND THE
PROPOSED RULE STILL BE FINALIZED
WITH THE COMMENT PERIOD ENDING
BUT IF ADOPTED WATER SYSTEMS
WOULD HAVE TO MONITOR AND NOTIFY
THE PUBLIC.
THE CURRENT METHODS FOR
MEASURING IS EPA METHODS 533 AND
537.1.
THE DETECTION ON THE COMPOUNDS
RANGE AND AND -- STATES ARE
CONTINUING TO ESTABLISH THEIR
OWN REGULATIONS BASED ON
GUIDANCE BUT MANY STILL DON'T
HAVE STANDARDS IN PLACE AND
MICHIGAN AND MASSACHUSETTS ARE
LEADING THE CHARGE.
FOCUSSING IN ON CALIFORNIA THE
STATE CURRENTLY DOES NOT HAVE
ENFORCEABLE DRINKING WATER
STANDARDS BUT HAVE A
NOTIFICATION LEVEL FOR SOME PFAS
AND IT REQUIRE MUNICIPALITIES TO
NOTIFY CUSTOMERS OF THE PRESENCE
OF PFAS FOR HEALTH RISK AND
VULNERABLE POPULATIONS AND
REQUIRING THE MUNICIPALITIES TO
REMOVE IT FROM DISTRIBUTION AND
THEY'RE DEVELOPING CLEAN UP AND
ACTION PLANS.
WHAT IS BEING DONE TO MONITOR
FOR PFAS?
THERE ARE CURRENTLY THREE
MONITORING EFFORTS OCCURRING IN
CALIFORNIA.
THE MONITORING RULE IS PART OF
THE EPAs MONITORING FRAMEWORK
THAT REQUIRES PUBLIC WATER
SYSTEMS TO MONITOR FOR
CONTAMINANT.
ONE OF THE FIRST INCLUDED PFAS
AND ANOTHER LOOKS FOR 30
CHEMICAL COMPOUNDS.
THE UCMR RESULTS HAVE BEEN
RECENTLY RELEASED AND HAD
FINDINGS IN PUBLIC WATER SYSTEMS
AND THERE WAS THE CONTROL BOARD
AND CALIFORNIA ALSO ISSUED THESE
SEPARATE MONITORING ORDERS
REQUIRING PUBLIC WATER UTILITIES
TO MONITOR FOR PFAS.
THE MONITORING ORDER TYPICALLY
TARGETS NEAR SOURCES OR WHERE
PFAS HAS BEEN PREVIOUSLY DETECT
MOST RECENT WAS IN OCTOBER 2022
THAT TESTED NEAR SITES WITH
CONFIRMED PFAS CONTAMINATION
FROM PREVIOUS SAMPLING EVENTS.
FINALLY, THERE'S THE GROUND
WATER AMBIENT WATER MONITORING
AND ASSESSMENTS IN PARTNERSHIP
WITH THE U.S. GEOLOGICAL SURVEY,
CALIFORNIA LOOKS TO GROUND WATER
WELLS AND DOMESTIC WELLS AND
ALSO PERFORMS OTHER ASSESSMENT
PROJECTS TO CHARACTERIZE GRAND
WATER CONTAMINATION.
THE GAMMA PROGRAM IS AN
INITIATIVE DESIGN TO ASSESS THE
QUALITY OF CLINICAL RESEARCH'S
GROUND WATER RESOURCE.
IT WAS CREATED IN 2000 BY STATE
WATER RESOURCES CONTROL BOARD
AND EXTENDED TO IMPROVE
COMPREHENSIVE GROUND WATER
MONITORING EFFORTS AND TO
INCREASE THE PUBLIC AVAILABILITY
OF GROUND WATER QUALITY DATA.
THIS STORES A WEALTH OF
INFORMATION ON MULTIPLE
PARAMETERS INCLUDING PFAS
COLLECTED AND ORGANIZING FROM
SAMPLING EFFORTS IN THE PAST 20
YEARS INCLUDING PFAS DATA
COLLECTED FROM PREVIOUS UCMR AND
STATE MONITORING EFFORTS AND FOR
OTHERS TO BE UPLOADED.
CALIFORNIA WAS THE FOCUS MAINLY
DUE TO THE AVAIL AMOUNT OF PFAS
DATA STATEWIDE IN THE ACCESS
WATER QUALITY REPOSITORY.
THIS PROJECT WAS DONE IN MAY
2023 AND WITH THE INTEREST AND
EFFORT TO PFAS MONITORING
INCLUDING NEW RESULTS FROM UCMR5
THERE'S MORE DATA AVAILABLE
CURRENTLY.
THE CONTROL BOARD AND DIVISION
OF DRINKING WATER IS RESPONSIBLE
FOR REGULATING THE 24,000
MUNICIPAL DRINKING WATER WELLS
IN CALIFORNIA.
AS OF THIS ANALYSIS, ONLY 9.5%
OF THESE WELLS HAVE DATA FOR
PFAS MEANING THE EXTENT OF
CONTAMINATION AND THUS PUBLIC
EXPOSURE THROUGH DRINKING WATER
IS STILL RELATIVELY UNKNOWN.
AS MENTIONED PREVIOUSLY,
SAMPLING ANALYSIS OF PFAS IS
COSTLY AND LOGISTICALLY
INTENSIVE.
IT'S EVERYWHERE AND SPECIAL CARE
MUST BE TAKEN TO NOT CONTAMINATE
THE SAMPLE AND USING QUALITY
ASSURANCE AND CONTROL AND DOWN
TO NANOGRAMS PER LITER OR PARTS
PER TRILLION REQUIRE METHODS.
AS A RESULT, CHARACTERIZATION IS
PROCEEDING SLOWLY AND THEY FOCUS
ON WELLS NEAR KNOWN SOURCES OF
PFAS.
SOME MODELLING APPROACHES CAN
GIVE INSIGHT ON THE SPREAD IN
SOME ISOLATED SYSTEMS BUT
CURRENT EFFORTS DO NOT SCALE TO
GEOGRAPHICAL SYSTEMS.
AND HOW CAN WE OPTIMIZE OUR
MONITORING STRATEGY TO GET THE
MOST INFORMATION ABOUT THE
EXTENT OF PFAS RISK TO THE
PUBLIC WITH MINIMAL AMOUNTS OF
SAMPLING.
SO WHAT IS MACHINE LEARNING OR
M.L.?
IT'S A SUBSET OF A.I. THAT
ENABLES SYSTEMS TO LEARN MANY,
IMPROVE AND RECOGNIZE PATTERNS
FROM DATA WITHOUT EXPLICIT
PROGRAMMING AND USE SOFTWARE OR
ALGORITHM TO MAKE PREDICTIONS,
ELUCIDATE PATTERNS AND AUTOMATE
DECISION MAKE.
WE CAN THINK OF A.I. IN TERMS OF
A CHESS COMPUTER, A SIMPLE CHESS
A.I. WOULD CALCULATE WHAT MOVE
TO MAKE NEXT.
A MORE ADVANCED COMPUTER SYSTEM
WITH MACHINE LEARNING WOULD
LEARN YOUR PREFERRED MOVE AND
IT'S A MORE POWERFUL VERSION OF
A SYSTEM THAT CAN TYPICALLY
RECOGNIZE MORE INTRICATE
PATTERNS.
A MORE ADVANCED WITH -- SOME
DOWN SIDE INCLUDES THE NEED FOR
DATA AND COMPUTATIONAL RESOURCES
TO RUN THE PROGRAMS TO TRAIN AND
TEST THE MODELS.
THE DATA CAN BE CARRIED TO THE
RESULTS AND MAY BE DIFFICULT TO
SPOT AND CORRECT.
ANOTHER ISSUE THE ALGORITHMS CAN
ACT LIKE A BLACK BOX AND RESULTS
CAN BE SOMETIMES DIFFICULT TO
INTERPRET AND M.L. REQUIRES A
LOT OF DATA AND SOME TECHNICAL
DATA BUT IT DOES NOT REQUIRE IN
DEPTH OF THE KNOWLEDGE OF THE
VARIABLES TO MAKE ACCURATE
PREDICTIONS AND MODELS AND IT
CAN BE SUMMARIZED AND ANALYZED
BY A COMPUTER USING M.L. MODELS.
THEY CAN EXTRACT PATTERNS THAT
MAY BE MISSED IN OTHER
TECHNIQUES.
HERE'S A SIMPLIFIED
REPRESENTATION OF HOW TO DEVELOP
AN M.L. MODEL TO MAKE PREDICTS
FOR UNKNOWN DATA POINTS.
WE BEGIN BY TAKING OUR KNOWN
DATA SET AND FEEDING IT WITH
TRAINING DATA.
MODEL WILL FIT THE TRAINING DATA
AND COME UP WITH MODEL
PARAMETERS TO USE TO PREDICT
OUTPUTS.
THE REST OF THE DATA WILL BE
USED TO TEST THE DATA DEVELOPED
FROM THE M.L. ALGORITHM AND SEE
WHAT OUTPUT IT PREDICTS AN
COMPARE IT WITH THE REAL TEST
DATA TO SEE HOW ACCURATE THE
PREDICTS WERE.
BASED ON OUR RESULTS WE CAN THEN
TUNE OR MODEL TO TRY TO IMPROVE
THE PREDICTIONS.
THIS CAN BE DONE BY CHANGING
MODEL PARAMETERS OR TRYING
DIFFERENT MODELS AND INPUT
FEATURES.
ONCE WE HAVE A MODEL WE'RE
COMFORTABLE WITH THE ACCURACY WE
CAN APPLY IT TO OUR UNKNOWN DATA
POINTS AND MAKE PREDICTIONS.
M.L. TOOLS HAVE BEEN USED TO
PREDICT UNKNOWN WATER QUALITY
PARAMETERS IN THE PAST DECADE
WITH QUANTITY AND QUALITY OF
DATA AND THIS HAS BEEN USED TO
PREDICT WITH FAIRLY GOOD
ACCURACY AND DETERMINE AREAS
THAT MAY BE CONTAMINATED WITHOUT
NEEDING TO SAMPLE AND PAPER
DESCRIBED UTILIZING M.L. MODELS
TO DETECT CONTAMINANTS IN WATER
AND MOST WERE FOCUSSED ON
ARSENIC AND NITRATE AND THE MAIN
TAKEAWAYS WERE MODEL
CLASSIFICATION PERFORMANCE SUCH
ADDS DETERMINING IF A SITE IS
ABOVE OR BELOW A CONCENTRATION
THRESHOLD WAS BETTER THAN
PREDICTION OF CONTINUOUS
CONCENTRATIONS AN PREDICTIVE
PERFORMS IS IMPACTED BY THE
QUANT OF DATA AND INPUT
PARAMETERS USED IN THE MODEL
ANOTHER WAS USED TO PREDICT THIS
IN GROUND WATER WELLS AND
ANOTHER STUDY DONE WAS PUBLISHED
RECENTLY AFTER THE PUBLIC HEALTH
WAS COMPLETED BUT ALSO DEVELOPED
A MODEL TO PREDICT
CONCENTRATIONS USING DATA FROM
THE DATA SET.
THEY WERE ABLE TO DEVELOP A
COMPREHENSIVE PIPELINE AND
ACHIEVED HIGH PREDICTIVE
ACCURACY FOR INDIVIDUAL PFAS
COMPOUNDS.
OUR APPROACH WAS TO BUILD OF THE
METHODOLOGY AND WE CHOSE SIMILAR
PREDICTIVE VARIABLES AN
ADDITIONAL PARAMETERS AND
THERE'S INPUT FROM THE DATABASE
AND SITES TAKEN FROM THE EPA
ECHO DATABASE AN HYDRO LOGICAL
AND SOIL PROPERTIES FROM A
COUPLE DIFFERENT MODELS AND
SOURCES.
OUR ALGORITHM WAS A REGRESSION
AND CLASSIFICATION MODEL
COMBINED WITH THE SYNTHETIC
MINORITY OVER SAMPLING
TECHNIQUE.
IT WORKS BY TRAINING AN ENSEMBLE
OF DECISION TREES AND AVERAGING
THE PREDICTIONS.
THEY'RE GOOD AT EFFECTIVELY
HANDLING LARGE NUMERICAL AND
CATEGORICAL DATA AND CAN ADDRESS
ISSUES AND IDENTIFY SIGNIFICANT
PREDICTORS.
THE TECHNIQUE IS A COMMONLY USED
METHOD TO REDUCE BIAS AND
BALANCE THE DATA SET BY
CONCENTRATIONS WE WANTED TO
FOCUS ON.
WE STARTED BY COLLECTING OUR
INPUT DATA AND PREPARED IT FOR
THE MODEL.
THIS INCLUDED DETERMINING HOW TO
HANDLE DUPLICATE MISSING OR
NON-DETECT DATA AND COLLATING
SPECIAL DATA WITH WELL
LOCATIONS.
WE CHOSE TO HAVE CONTINUOUS
CONCENTRATIONS AND TO CLASSIFY
WHETHER THE WELLS EXCEEDED OR
WERE BELOW THE PROPOSED NATIONAL
PRIMARY DRINKING WATER MCLs.
THE PERFORMANCE OF THE MODEL WAS
EVALUATED USING A TEN FOLD
RANDOMIZATION TECHNIQUE USED TO
CALCULATION THE CONCENTRATIONS
AND THE ACCURACY RECALL AND
SPECIFICITY AND THE
CLASSIFICATION MODEL.
WE DIDN'T DO MUCH OPTIMIZATION
BY ADJUSTI IING PARAMETERS OR
IMPROVE PREDICTIVE PERFORMANCE
AND USED A MODEL TO FILL IN THE
BLANKS AND PREDICT
CONCENTRATIONS FOR PFAS CHEMICAL
FOR WELLS WITH NO SAMPLING DATA.
THESE FIGURES SHOW ESTIMATED
PFAS ESTIMATIONS ON A
LOGARITHMIC SCALE.
HERE'S THE RESULTS OF OUR
VALIDATION TESTS FOR OUR
CONTINUOUS MODEL.
THIS IS THE REPORT AND
PREDICTIVE MODELS.
THIS SHOWS THE SUM OF 16 PFAS
CHEMICAL FOR EACH WELL ON A
LOGARITHMIC SCALE.
OUR APPROACH WAS SUCCESSFULLY
ABLE TO IMPROVE THE DISCREET AND
CLASSIFICATION PERFORMANCE.
AND WE WERE ABLE TO ACHIEVE AN R
SQUARED .88 COMPARED TO .85
WHICH IS THE HIGHEST OF PAPERS
REVIEWED.
THOUGH DISCREET CONCENTRATION
NOT QUITE WHERE WE WANT THEM TO
BE, AS YOU CAN SEE I STILL HAVE
A SIGNIFICANT AMOUNT UNACCOUNTED
FOR AND PREDICTIVE POINTS MATCH
THE TEST DATA ASSOCIATED WITH.
POINTS WITHIN THE DOTTED RED
LINES ARE WITHIN PLUS OR MINUS
10% OF THE TEST DATA AND WE USE
ONE THIRD OF THE DATA POINTS
WITHIN THE PLUS OR MINUS 10%
RANGE.
HOWEVER, THE MODEL PERFORMED
BETTER AT CLASSIFICATION.
AS AN EXAMPLE, YOU CAN SEE THE
ORANGE BOXES THAT DEPICT A
THRESHOLD OF 30 PARTS PER
TRILLION.
THE MODEL WAS BETTER AT
DETERMINING WHICH POINTS WERE A
OR BELOW THE THRESHOLD BY EN
ENSURING THEY FELL WITHIN THE
BOX.
DRINKING WATER REGULATION
CLASSIFICATION MODEL HAD AN
ACCURACY RATE OF 89% AND ABLE TO
RECALL 83% OF ALL THE WELLS IN
EXCEEDENCE IN THE TEST DATA AND
OUR AREA RECEIVE AN OPERATING
CURVE FOR THE MODEL WAS .91.
WE CAN NOW APPLY THIS MODEL TO
OUR UNKNOWN DATA SET AND TRY TO
DRAW SOME CONCLUSIONS.
THE 24,000 DEPARTMENT OF
DRINKING WATER WELLS IN THE
DATABASE ONLY 2300 HAD PFAS DATA
AND 500 OR A FOURTH EXCEEDED THE
PROPOSED AMOUNT.
11 OF THESE ARE IN EXCEEDENCE
AND BASED ON OUR TEST WE CAN
ASSUME AROUND 10% OF THESE
PREDICTIVE WELLS ARE LIKELY
MISCLASSIFIED BUT GIVES AN IDEA
HOW MANY ARE LIKELY TO EXCEED
THE CRITERIA.
OUR TEST SHOWED OUR CONTINUOUS
MODEL LESS RELIABLE BUT NO
CONCENTRATIONS EXCEEDED THE
REPORTED VALUES WHICH SUGGESTS
CURRENT METHODOLOGY HAS BEEN
TARGETING HIGHLY CONTAMINATED
SITES.
HOWEVER, THE NUMBER OF UNKNOWN
DATA SIDES SUGGESTS GAPS IN
METHODOLOGY AND THIS WELLS THAT
HAVE LOWER CONCENTRATIONS NEAR
THE THRESHOLDS.
GEOGRAPHICALLY, WE IN EXCEED
WERE IN POCKETS AND POB LA --
POPULATED AREAS WITH PFAS
SAMPLING.
OUR PREDICTION HELPED FILL IN
THE GAPS IN THE DATABASE.
SOME EXPECTATIONS INCLUDE SANTA
CLARITA AND SIMI VALLEY AND WERE
PREDICTED TO HAVE A HIGH NUMBER
OF EXCEEDENCES OR HIGHER
CONCENTRATIONS.
THE NEXT PHASE OF OUR PROJECT
INVOLVED DRCHLING HO I-- DETERM
THE MODELLING ADULTS SINCE
THERE'S NO CAPABILITIES TO TREAT
PFAS AND DEPARTMENT OF DRINK
WATER WELLS HAVE A CONSERVATIVE
ESTIMATE OF EXPOSURE LEVELS BUT
NOT WHERE IT MAY HAVE A LARGE
PUBLIC HEALTH IMPACT.
LOCATIONS WITH HIGH CONTAMINATED
WELLS WITH A VULNERABLE WELL ARE
THE MOST AT RISK FOR SAMPLING
ATTENTION SHOULD BE GOING FIRST.
A LEVEL FOR COMMUNITY CAN BE
CALCULATED BY MULTIPLYING
PROBABILITY OF PFAS AND THE RISK
LEVEL PROVIDES A METRIC FOR THE
EXPOSURE TO A POPULATION AND
THIS CAN BE INCORPORATED INTO A
SAMPLING METHODOLOGY AND THE
ASSESSMENT HAS BEEN EVALUATED IN
CALIFORNIA.
IN 2019 CALIFORNIA SIGNED A
PRIORITY TO EACH OF THE GROUND
WATER BASINS.
THE PRIORITY RATING WAS BASED ON
THE OVERLYING POPULATION AND
PREDICTIVE GROWTH, THE DEGREE TO
WHICH POPULATION RELIES ON WATER
DRAWN FROM THE BASIN AS THE
PRIMARY WATER SOURCE AND OTHER
RISK QUALITY DEGRADATION.
THE PRIORITIZATION SCHEME IS
USED TO IDENTIFY AND PRIORITIZE
GROUND WATER BASINS FOR PLANNING
AND SUSTAINABILITY AND LOOK AT
PFAS EXPOSURE.
WITH OUR EXCEEDENCE PREDICTIONS
USED AS A PROBABILITY OF
EXPOSURE AND OUR BASIN
PRIORITIZATION AS A MAGNITUDE WE
WE CALCULATED A RISK SCORE FOR
EACH OF THE PRIORITY BASIN.
TO THE RIGHT WE HAVE A CHART
THAT SHOWS THE EXTENT OF
SAMPLING.
THE BLUE BARS REPRESENT THE
PROPORTION SAMPLED AND EXCEED
THE PROPOSED MCLs.
THE PINK ARE THE UNSAMPLED WELLS
PREDICTED TO EXCEED THE MCLs AND
THE GRAY BARS ARE THE WELLS
PREDICTED OR REPORTED TO NOT BE
IN EXCEEDENCE.
ANTELOPE VALLEY HAD A 4.0 RISK
SCORE BECAUSE THE BASIN WAS
DESIGNATED AS THE HIGHEST
PRIORITY AND OUR MODEL PREDICTED
THE WATER WELLS EXCEEDED AND IT
SUPPORTS MILITARY OPERATIONS AND
NEAR THE SACRAMENTO RIVER
PROVIDES CONDITIONS THAT MAY
PROMOTE PFAS TRANSPORT THROUGH
THE SOIL AND INTO THE WATER
TABLE.
ONE NOTE IS THE DATABASE DOES
NOT INCLUDE ALL DEPARTMENT OF
DEFENSE DATA SO THERE MAY BE
SOME SAMPLING DATA AVAILABLE NOT
IN THE DATABASE.
THIS HIGHLIGHTS THAT MANY
COMMUNITIES THAT RELY HEAVILY ON
THEIR LOCAL GROUND WATER
RESOURCES FOR POTABLE WATER AND
THUS ARE AND WAS NOT ADEQUATELY
SAMPLED FOR PFAS AND AND THERE
MAY BE MORE EXPOSURE.
AND WE CAN DEVELOP AN ITERATIVE
METHODOLOGY TO TARGET LOCATIONS
THAT MAY BENEFIT THE MOST FROM
PFAS SAMPLING EFFORTS.
AND MODEL CONDITIONS WITH THE
SCORE LIKE THE BASIN
PRIORITIZATION CAN HELP
REGULATORS DEVELOP A LIST OF
LOCATIONS AT HIGH RISK OF PFAS
CONTAMINATION AND EXPOSURE WHICH
CAN INFORM REGULATORS IN MAKING
DECISIONS WHERE FUNDS AND
EVIDENCE SHOULD BE FOCUSSED.
AS MORE DATA COMES IN, MODEL
PREDICTIONS WILL IMPROVE AND
THUS WILL HELP TO DEVELOP MORE
ACCURATE HIGHER QUALITY RISK
ASSESSMENTS.
CONTINUED RESEARCH AND
DEVELOPMENT OF M.L. MODEL
PIPELINE AND NEW ALGORITHMS WILL
HELP TO IMPROVE MODEL ACCURACY
AND RESULT IN MORE ROBUST RISK
ASSESSMENT.
ANOTHER MAJOR FOCUS OF
INVESTIGATION SHOULD ADDRESS
EXPOSURE TO FEED IN THE RISK
ASSESSMENT.
OUR APPROACH WAS RUDIMENTARY AND
DEMONSTRATES HOW OUR M.L. MODEL
RESULTS CAN FIT IN THE SCHEME
AND ASPECTS SUCH AS VULNERABLE
POPULATION AN DELINEATION AND
TREATMENT CAPABILITIES IN
ADDITION TO GROUND WATER
DEPENDENCE SHOULD BE CONSIDERED
TO GET MORE REPRESENTATIVE
THREAT SCORE FOR THE COMMUNITY.
MACHINE LEARNING IS A PROMISING
TOOL THAT CAN OPTIMIZE SAMPLING
EFFORTS AND TARGET LOCATIONS
WHERE PFAS WOULD HAVE THE
BIGGEST IMPACT CONCEIVABLY
HELPING REDUCE PUBLIC HEALTH
IMPACT FOR LESS TIME AND MONEY.
THIS METHODOLOGY IS ONLY
POSSIBLE IN CALIFORNIA DUE TO
THE WEALTH OF PFAS DATA
AVAILABLE.
WHILE THE STRATEGY CAN BE
EXTENDED, A SIMILAR WEALTH OF
DATA IS REQUIRED TO MAKE
REASONABLY ACCURATE PREDICTIONS.
THERE'S NO GROUND WATER NATIONAL
REPOSITORY BUT SOME STATES
MAINTAIN THEIR OWN DATABASES
THAT COULD BE LEVERAGED.
TO FORM THIS ON A NATIONAL
SCALE, MORE PLATFORMS WILL BE
NECESSARY.
CURRENTLY MODELS THAT PREDICT
CONTINUOUS CONCENTRATION ARE NOT
VIABLE AND NEW METHODS ARE
NEEDED TO IMPROVE ACCURACY.
CLASSIFICATION ARE GOOD FOR
SCREENING AND PRIORITIZATION
PLANS BUT NOT SUITABLE FOR
SOMETHING LIKE EPIDEMIOLOGICAL
STUDY.
FURTHER RESEARCH IN PREDICTIVE
FEATURES AND HANDLING NON
DEFECTS AND TEMPORAL DATA AND
OTHER TECHNIQUES WILL HELP BOOST
PREDICTIVE POWER.
THE TOOL MAY BE USED FOR OTHER
CONTAMINANTS AND OTHER
GEOGRAPHIC LOCATIONS AS LONG AS
THERE'S SUFFICIENT DATA TO MAKE
REASONABLE PREDICTION.
OUR APPROACH IS ONE OF THE MANY
APPLICATIONS IN ENVIRONMENTAL
FIELD.
THERE WAS A PAPER THAT REVIEWED
THE APPLICATIONS OF ML TOOLS AND
WATER RESOURCES DISCOVERED
MACHINE LEARNING IS BEING
DEVELOPED AND APPLIED TO THE
CONSTRUCTION, MONITORING AND
SIMULATION, EVALUATION AND
OPTIMIZATION OF VARIOUS WATER
TREATMENT AND MANAGEMENT
SYSTEMS.
ADDITIONALLY, MACHINE LEARNING
CAN'T PROVIDE SOLUTIONS FOR
WATER POLLUTION CONTROL AND
SECURITY MANAGEMENT.
THIS STUDY ANALYZED 45
METHODOLOGIES AND THE MAIN
DRAWBACKS INCLUDED DEPENDENCE ON
HIGH QUALITY DATA AND THE
SPECIFICITY ALGORITHMS AND MAY
NOT BE APPLICABLE TO WIDER
APPLICATIONS AND APPLICATION
REQUIRES PERSONNEL TO HAVE
BACKGROUND KNOWLEDGE IN MACHINE
LEARNING AND THE SYSTEM YOU'RE
APPLYING IT TO.
REGARDLESS THE PAPER CONCLUDE
THE METHODS WAS A POWERFUL AND
PROMISING TOOL FOR SOLVING WATER
RESOURCE AND ENVIRONMENTAL
PROBLEMS.
THERE'S THE TOXICITY OF
MICROPLASTIC EXPLORER IS AN
ONLINE TOOL DEVELOPED BY THE
SOUTHERN CALIFORNIA WATER
COASTAL RESEARCH PROJECT TO
EXPLORE DATA.
THERE'S AN OPEN ACCESS DATABASE
INCLUDING TOXICITY DATA FROM
HUNDREDS OF PEER-REVIEWED PAPER.
THE ALLOWS TO PREDICT
CONCENTRATIONS WITH THE MACHINE
LEARNING TOOL SIMILAR IN THE
PROJECT AND THERE'S THE
U.S. DEPARTMENT OF ENERGY
PROJECT THAT IS RESEARCHING NEW
LONG-TERM MONITORING FRAMEWORK
IN SITES AND THERE'S DEVELOPMENT
OF VARIOUS TOOLS FOR ADVANCED
ANALYSIS OF SOIL AND GROUND
WATER DATA.
THIS INCLUDES DEVELOPMENT OF
MACHINE LEARNING MODEL FOR
CONCENTRATIONS BASED ON
MEASURABLE AMOUNTS AND
QUANTIFYING AMOUNTS LOOKING AT
FLOODING AND DROUGHT.
AND BEFORE I END I WANT IT GIVE
SPECIAL THANKS TO SOME OF MY
TEAM MEMBERS, MY ADVISER FROM
UCLA AND EVERYONE AT POTOMAC
HUDSON FOR THEIR SUPPORT AND PHE
SUPPORTED THE PROJECT AND MY
EDUCATION AT UCLA AND WE
SPECIALIZE AT TACKLING DEEP
ENVIRONMENTAL PROJECTS AN
ENVIRONMENTAL ANALYSIS AND
DOCUMENTATION AND SITE
EVALUATION CHARACTERIZATION.
IF YOU'D LIKE TO LEARN MORE
QUESTION OUR SERVICES AT PHE,
DON'T HESITATE TO REACH OUT TO
ME.
I DON'T KNOW IF WE HAVE TIME FOR
QUESTIONS BUT IF YOU HAVE
ADDITIONAL QUESTIONS FEEL FREE
TO REACH OUT.
>> I'M NOT SURE IF WE HAVE TIME.
>> I MAY NOT USE ALL MY TIME IF
HE WANTS TO ANSWER QUESTIONS.
>> CAN YOU SEE THE CHART?
THE QUESTION IS THE PREDICTIONS
ARE BASED ONLY ON GROUND WATER
TESTING INFO.
IS THERE A REASON WHY DATA ON
PFAS FROM AGRICULTURAL SITES IS
NOT BEING INCLUDED?
>> THE DATA DOES INCLUDE
PRESENTEE OF THAT AND
AGRICULTURAL AND SOME PRIVATE
WELL WATER SOILS AS WELL.
FOR THIS SPECIFIC PROJECT WE
WANTED TO LIMITED OUR SCOPE
SINCE IT WAS VERY BROAD IN
ANALYSIS WE DECIDED TO FOCUS ON
DRINKING WATER SINCE THAT WAS
THE MAIN PATHS OF INTION --
INGESTION OF PFAS TO THE PUBLIC
AND LOOK AT PRIVATE WATER AS
WELL.
OUR NEXT PRESENTATION IS GOING
TO BE ON DOD INITIATIVES TO
REDUCE GREEN HOUSE GAS SUPPLY
EMISSIONS FOR THE SECRETARY OF
DEFENSE FOR ENVIRONMENT AND
ENERGY RESILIENCE.
AND HER DUTIES, DR. MEIER
COORDINATES POLICIES AND
PROGRAMS TO OPTIMIZE RESILIENCE
AND ENHANCING GREEN HOUSE GAS
MITIGATION.
SHE HAS LED THE DEVELOPMENT OF
PROCESSES TO DRIVE DECISION
LOGIC FOR ENVIRONMENTAL DATA
STRUCTURES.
>> THANK YOU VERY MUCH.
THERE HAS BEEN A SLIGHT SHIFT IN
THE OFFICE SINCE THAT BIO WAS
SENT IN IT WAS FORMALLY A DEPUTY
ASSISTANT FOR DEFENSE AND WE'RE
NOW THE SUSTAINABILITY OFFICE
AND WORK WITHIN THE CHIEF
SUSTAINABILITY OFFICER'S OFFICE.
DR. OWENS IS OUR ASSISTANT
SECRETARY OF DEFENSE FOR
INSTALLATIONS AN ENVIRONMENT.
OUR TEAM HAS A VERY LARGE
PORTFOLIO.
PART OF MY WORK IS GREEN HOUSE
GASES AND OUR SUPPLY CHAIN.
I WANTED TO START OFF A LITTLE
BIT TALKING ABOUT HOW OUR
CHEMICAL PROGRAM FIT INTO THE
SUPPLY CHAIN INITIATIVE AND WHY
IT'S IMPORTANT TO THINK ABOUT
THIS.
AND HYDROFLOUROCARBON NOT QUITE
EMERGING CHEMICALS.
TAY -- THEY ARE REGULATED AND
WANTED TO TALK ABOUT HOW THEY'RE
BEING PROCESSED AND HOW WE'RE
CONSIDERING THEM AND HOW THAT
TRANSLATES TO OUR SUPPLY CHAIN
MISSION AT THE DEPARTMENT OF
DEFENSE.
LOOKING AT OUR SUPPLY CHAIN WE
HAVE SEVERAL INITIATIVES FOR
GREEN HOUSE GAS MITIGATION AND
IF YOU'RE NOT FAMILIAR WITH HOW
GREEN HOUSE GASES ARE ACCOUNTED
FOR WE HAVE SCOPE 1 AND WE RENT
IT AND IT'S OUR HOUSE AND THE
THINGS WE OPERATE AND USE AND
THE ENERGY ASSOCIATED WITH
OPERATING THOSE THINGS.
SO YOU PARK IT IN YOUR GARAGE WE
HAVE SHIPS AND TANKS AND PLANES
THAT WE FIT IN OUR GARAGE SO
THERE'S ENERGY AND WHEN WE TALK
ABOUT ENERGY SUPPLIERS AND SCOPE
1 EMISSIONS ARE EVERYTHING WE
HAVE AND OWN THE FUEL TO SUPPORT
THAT.
SCOPE 2 EMISSIONS IS EVERYTHING
OFFSITE AND THE CORRELATION WITH
OUR ENERGY SUPPLIERS SAY SCOPE 2
EMISSIONS BUT PART OF OUR OVER
ALL SUPPLY CHAIN AND THE FULL
LIFE CYCLE IN THE PRODUCTS WE
BUY.
WE ALSO HAVE EQUIPMENT ON THE
PLATFORMS THAT ARE HYDRO
FLUOROCARBONS AND THE FUEL AND
WE WANT TO LOOK FOR GLOBAL
WARMING POTENTIAL LOWER THAN THE
CURRENT PRODUCTS WE'RE USING.
THOSE ARE OUR SCOPE 1 AND 2
EXAMPLES AND WHILE FOCUS ON THE
LOWER GLOBAL WARMING POTENTIAL
AND THE HYDROFLOUROCARBONS TODAY
AND THERE'S ANOTHER TALK.
THIS IS A SALES PITCH FOR DOING
SUSTAINABLE PRODUCT SESSION--
THE DEPARTMENT OF DEFENSE IS
MISSION FIRST AND FOR US TO
MAINTAIN MISSION AND ENSURE THAT
RESILIENCE, WE HAVE TO PUT OUR
PROCUREMENT REQUIREMENTS IN A
WAY THAT MAKE SURE THE MISSION
SPECIFICATIONS ARE THE
REQUIREMENT AND BENEFIT TO THE
GOVERNMENT AND ENVIRONMENT WE
WANT TO BALANCE THE OTHER
SUSTAINABLE OPPORTUNITIES AND
WE'RE LOOKING FOR ALTERNATIVES
AND PART OF OUR SYSTEM TO MAKE
SURE WE'RE SEEKING OR MAKING OUR
MISSION RESILIENT WE'RE MAKING
SURE IT CAN CONTRIBUTE TO LOWER
GLOBAL WARMING POTENTIAL.
NOW THE AMERICAN INNOVATION AND
MANUFACTURING ACT AND IT WILL
ALIGN WITH THE AMENDMENT TO THE
MONTREAL PROTOCOL.
IT REQUIRES AN 85% REDUCTION IN
HFCs BY 2023 AND ALLOWS OR
AUTHORIZES THE EPA TO ADDRESS
HFCs BY LOOKING AT THE
INDUSTRIES ACROSS THE UNITED
STATES.
AS PART OF THE FEDERAL
GOVERNMENT WE'RE ALSO WE HAVE TO
USE A SPECIAL ALLOCATION TO
ENSURE THE DOD'S MISSION.
WE SUBMIT AND ENSURE WE HAVE
THOSE MISSION-CRITICAL
ALLOCATIONS EVERY YEAR AND
COORDINATE CLOSELY WITH THE EPA.
THERE'S THE FACILITATION OF
TRANSITION TO TECHNOLOGIES.
A LOT OF THAT IS COMMERCIAL
TRANSITION.
DOD HAS WORKED TO HELP
UNDERSTAND OUR SPECIFICATION
REQUIREMENTS AND CONDUCTING
RESEARCH AND WE'LL TALK A LITTLE
BIT ABOUT THAT AND LOOKING AT
THE LAST BLUE BULLET, RECENTLY
IN OCTOBER WAS THE PROPOSED RULE
FOR RELEASES FOR RECLAMATION AND
REQUIREMENTS FOR US TO USE
RECLAIMED MATERIALS.
AND WE ARE LOOKING TO EPA AND
OTHERS TO HELP US UNDERSTAND THE
QUALITY AND QUANTITY OF
RECLAIMED MATERIAL TO HELP
SUPPORT MISSION REQUIREMENTS.
THAT'S SOMETHING WE WOULD LOVE
TO TALK TO TALK TO INDUSTRY
EXPERTS WHERE POSSIBLE AND HELP
UNDERSTAND THOSE CAPABILITIES.
SO A LITTLE BIT ABOUT THAT
ALLOCATION ALLOWANCE REDUCTIONS.
SO THE ALLOCATIONS SPECIFIC
APPLICATIONS SPECIFIC
ALLOCATIONS -- SAY THAT TEN
TIMES FAST, ARE ABOUT 2% OF THE
BASE YEAR ALLOWANCES.
SO IT DOESN'T SEEM LIKE VERY
MUCH.
IT ISN'T VERY MUCH.
IT'S ONLY 2% OF THE TOTAL
ALLOWANCES PROVIDERS ARE ALLOWED
TO MANUFACTURER.
90% MANUFACTURING QUANTITY AS OF
LAST YEAR AND THIS YEAR STARTED
THE FIRST 60% MANUFACTURING
CAPABILITIES AND SO THAT
FRACTION THAT 2% FRACTION MIGHT
GROW OVER TIME AND THAT'S THE
EXPANSION OF THE GREEN OVER
TIME, IT MAY NOT GET THAT BIG
BUT OBVIOUSLY THERE ARE A
CERTAIN LEANING ON THE RELIANCE
OF THOSE MISSION-CRITICAL
ALLOCATIONS AS WE START PUSHING
THROUGH THOSE NEXT PHASES OF
DRAW DOWN.
AND SO THE APPLICATIONS BECOME
MORE AND MORE IMPORTANT OVER
TIME.
WITH 2% OF THE TOTAL PRODUCTION
WHY ARE WE FOCUSSED ON HFCs?
THE REASON IS BECAUSE THEY GET
SUCH HIGH GLOBAL WARMING
POTENTIAL, HUNDREDS OF THOUSANDS
OF TIMES OF THAT THE CO2 FOR THE
SAME AMOUNT OF TIME.
IT HAS A HUGE LIFE TIME IN THE
ATMOSPHERE.
THE COMPOUNDING VOLUME IN THE
ATMOSPHERE WITH THE HIGHER
CAPABILITY OF HOLDING THAT
ENERGY IS THE FOCUS OF THAT
REGULATION.
SO MISSION CRITICAL MILITARY END
USES.
IT HAS A DEFINITION IN THE 40CFR
AND THESE ARE IMPACTS DIRECTLY
TO THE NATIONAL DEFENSE.
NECESSARY FOR DEPLOYMENT,
TESTING, PRODUCTION, TRAINING,
OPERATION, MAINTENANCE OF FARM
VESSELS.
THERE'S SPECIFIC TO SIMILAR
WEAPONS AND CAPABILITIES IN OUR
TRAINING.
SO DOD IN '22 SIGNED COMMITMENT
MEMORANDUM TO ENABLE THE WORKING
GROUP TO COORDINATE WITH THE
SERVICES.
THE AIM ACT WORKING GROUP SIT
WIN THE CLEANER ACT COMMITTEE
AND INCLUDES THE NAVY AND
INCLUDES OUR COMPONENT SERVICES.
THE PURPOSE IS TO HELP
COORDINATE AND UNDERSTAND HOW WE
ACCOUNT FOR, REQUEST AND MANAGE
THE MISSION CRITICAL MILITARY
END USE.
THE PROCESS AND THE FACILITATION
THROUGH THAT ACQUISITION OF
MCMAU ALLOCATIONS THROUGH THE
TRANSFERRAL TO THE PRODUCERS IS
MANAGED AND TO BE REPORTED TO
THE EPA BIANNUALLY.
WE COMMITTED TO THE PROCESS AND
CONTINUED TO LOOK FOR HFC
TECHNOLOGIES AND LOWER EXCHANGE
VALUES FOR HFCs.
A LOT OF TRANSITIONS HAPPEN
COMMERCIALLY AND CONTINUE TO AND
WE CONTINUE TO SEEK INDUSTRY
ENGAGEMENT TO HELP DRIVE
OPPORTUNITIES FOR INNOVATION AND
UNDERSTAND WHERE WE CAN MEET NEW
MISSION SPECIFICATIONS.
SO THERE'S A LOT OF DISCUSSION
ABOUT RISKS OF NEW CHEMICALS OR
NEW OPPORTUNITIES TO THE PERSONS
OR THE MISSION.
SO DOD HAS A HIGH STANDARD FOR
CONDUCTING THESE DIFFERENT
ASSESSMENTS AND MAKING SURE THAT
ANY ALTERNATIVES WE COMMIT TO
SHIFTING INTO OUR SYSTEMS IS
GOING TO BE SOMETHING THAT IS
SAFE FOR OUR PERSONNEL AND NOT
GOING TO PLACE ADDITIONAL RISK
TO THE MISSION.
WE SEEK TO UNDERSTAND
CAPABILITIES AND THE QUALITY AND
QUANTITY OF RECLAIMED MATERIAL.
THAT'S ANOTHER AREA OF INTEREST.
AND DOD THE ARMY COMPLETED
ELIMINATION STUDY AND WE HAVE A
RESEARCH AND DEVELOPMENT ARM
THAT WE CAN CONTINUE TO LOOK BUT
WE HAVE A FEW STUDIES AND WE'RE
CERTAINLY LOOKING FOR MORE.
BUT WE'RE LOOKING FOR NOT
INCLINED OR LOWER GLOBAL WARMING
POTENTIAL REPLACEMENT.
THOSE ARE PUBLICLY AVAILABLE AS
WELL.
SO LOOKING TO SPECIFY NEW
ALTERNATIVES AND TECHNOLOGIES
FOR THOSE HIGH GLOBAL WARMERS
AND WE WANT TO SPECIFICALLY
ADDRESS CHANGES FOR THOSE MCMAU
APPLICATIONS.
WHILE THE COMMERCIAL INDUSTRY
CONTINUES WE HAVE CERTAIN
APPLICATIONS ON OUR
INSTALLATIONS THAT MAY BE
COMMERCIALLY RELATE AND FOR OUR
MISSION CRITICAL APPLICATIONS WE
ARE CERTAINLY LOOKING TO
INDUSTRY TO HELP US IDENTIFY
POTENTIAL EXCHANGE HFCs.
WE ARE ALSO LOOKING TO THEM TO
INCREASE OTHER EFFICIENCIES AND
REDUCE WASTE.
UNDERSTANDING WHERE THEY CAN
POTENTIALLY USE RECLAIMED
MATERIAL AND INCREASE RECYCLING
AND CIRCULARITY.
A BROADER PICTURE OF SUSTAINABLE
PURCHASING.
AND THEN LOOKING TO THE CLEAN
ENERGY INFRASTRUCTURE AND WHERE
THEY CAN LEVERAGE AND WHERE WE
CAN SUPPORT AND GAIN ADDITIONAL
CO-BENEFITS OF STRENGTHENING
THEIR SUPPLY.
AND ENERGY.
SO ONGOING EFFORTS.
WE CONTINUE TO WORK WITH EPA ON
THE RECLAMATION OPPORTUNITY OWN
ALLOWANCE TRANSFER PROCESS.
EVERY FIVE YEARS WE JUSTIFY OUR
REQUIREMENTS FOR ONGOING NEED
FOR MCMUs.
WE'RE CURRENTLY IN THE PROCESS
RIGHT NOW.
INDUSTRY MANUFACTURERS CONTINUE
TO SAY WE ARE LOOKING FOR
OPPORTUNITIES TO CHANGE SO IF
THERE'S ANYONE ON THE CALL OR
ANYONE THAT WOULD LIKE TO CATCH
UP WITH US LATER, WE'RE LOOKING
FOR TRANSITION OPPORTUNITIES FOR
HFCs.
AND THEN WE'RE ALSO TONG ASSESS
OUR UNDERSTANDING OF THE
CHEMICALS AND OPPORTUNITIES FOR
THE TRANSITION.
SO WE WRITE NEW REQUIREMENTS FOR
NEW EQUIPMENT AND EXPECT THAT
LOWER GLOBAL WARMING POTENTIAL
OR NOT IN KIND HFCs AND WE'RE
LOOKING TO THOSE TRANSITION AND
RETROFITS BUT WE HAVE TO KEEP IN
MIND THE ASSESSMENT OF THE RISK
TO PERSONNEL AND MISSION AND
CONTINUE TO CONDUCT THOSE
ASSESSMENTS.
AND WHILE WEAVER DOING THAT, WE
ENCOURAGE THE CHEMICAL AND
SUPPLY CHAIN TRANSPARENCY TO
HELP SUPPORT ENVIRONMENT SAFETY
AND OCCUPATIONAL HEALTH.
S AND WITH THAT THAT'S DOD'S
TRANSITION WITH HFCs.
AND WITH THAT THAT'S DOD'S
TRANSITION WITH HFCs.
AND WITH THAT THAT'S DOD'S
TRANSITION WITH HFCs.
AND WITH THAT THAT'S DOD'S
TRANSITION WITH HFCs.
>> THANK YOU SO MUCH, DR. MEIER.
I'M WATCHING THE INBOX FOR
QUESTIONS.
I'M SURE I HAVE TONS OF
QUESTIONS BUT BECAUSE I HAVE
SOME BACKGROUND EXPERIENCE IN
HFC MANAGEMENT AND I'M ACTUALLY
HELP
HELPING PUT TOGETHER SOME
TRAINING MATERIALS ON USING S.
WHAT KIND OF DATA MODELLING ARE
YOU DOING TO HELP CONNECT AND
MANAGE THE APPROPRIATE SUPPLY
CHAINS FOR HFC PRODUCT PHASE
OUT?
HOW DO YOU FIND THE MOST
APPROPRIATE ALTERNATIVES FOR
INSTALLATION BASED ON BOTH OF
COURSE WHAT'S AVAILABLE FOR EACH
LOCATION BUT ALSO HOW MUCH WOULD
GO INTO JUST TRANSPORTING IT?
>> THAT'S A GREAT QUESTION.
I'M GLAD YOU ASKED THAT BECAUSE
IT IS SOMETHING WE HAVE THOUGHT
HARD ABOUT.
FIRST OF ALL, WE'VE JUST HIRED A
CONTRACTOR TO HELP US WITH DATA
MANAGEMENT.
WE HAVE SOME UNDERSTANDING AND
CERTAINLY DLA HAS SOME ACTIVITY
WITH HOW WE'RE APPROACHING
SUPPLY CHAIN MANAGEMENT.
BUT FOR HFC SPECIFICALLY, WE'VE
RELIED ON MANUAL EXCEL FILE
TRACKING OF SOME OF THESE
REQUIREMENTS AND EACH HAS THEIR
OWN PROCESS BUT WE'RE CURRENTLY
WORKING ON A WAY TO PULL THOSE
PIECES OF INFORMATION INTO A
MORE SYSTEMATIC PROCESS SO WE
CAN HAVE A BETTER UNDERSTANDING
OF PREDICTION AND WHILE WE'RE
DOING THAT BEING ABLE TO
INCORPORATE NEW INFORMATION OF
TRANSITION ALTERNATIVES AND
CAPABILITIES WITH TIME AND HELP
DO A QUALITY CHECK OF WHERE TO
VERIFY OUR ELIGIBILITY FOR EACH.
FOR EACH OF THOSE SYSTEMS THAT
REQUIRE THE ALLOWANCE OUR TEAM
LEADS ESSENTIALLY VALIDATE
THEY'RE MISSION CRITICAL
DEVELOPMENTS AND USING THAT
ELIGIBILITY WE LOOK AT THOSE AND
WOULD LIKE THAT SYSTEM TO BE
ABLE TO IDENTIFY WHERE
OPPORTUNITY FOR THOSE RESOLUTION
AS THEY COME IN SO WE WOULD
HOPEFU
HOPEFULLY FLAGGING OF THE
AUTOMATIC CAPABILITIES.
WE DON'T HAVE IT YET BUT THAT'S
THE PLAN.
>> ALL RIGHT, AWESOME.
A FOLLOW-UP QUESTION WOULD BE
THE AIM WORKING GROUP YOU HAVE,
CAN ANYONE JOIN THOSE?
I KNOW THERE'S SOME PEOPLE IN
THE ARMY CLEAN AIR LEADERS TEAM
I MANAGE THAT WOULD BE
INTERESTED WITH THAT EFFORT.
>> I DON'T THINK THERE'S A
LIMITATION.
I HAVE OUR AIM ACT CHAIR.
SHE'S THE CHAIR OF OUR TEAM.
IT IS DOD ONLY BUT THE SERVICE
IS NOT CONTRACT SO WHILE THERE'S
PRIMARY SUPPORT AT THE SCENE --
I MISSED, SORRY, OOPS.
I'M GOING STOP SHARING NOW
BECAUSE THAT'S NOT WHAT I WANTED
YOU TO SEE.
I'LL SEND THAT TO YOU IN THE
CHAT.
>> GREAT, NEW.
-- GREAT, THANK YOU.
>> SO IF ANYONE SAY MANAGER OF
DOD WE WOULD WELCOME
PARTICIPATION.
AND IDEAS FOR ALTERNATIVES.
THAT'S THE POINT.
>> NEXT UP WE HAVE KELSEY
HENDRICKSON BUT FIRST, THANK
YOU DR. MEIER FOR YOUR WORK AND
YOUR THEY DID A GREAT JOB
GETTING THE INFORMATION TOGETHER
AND BEING INTERESTED IN GREEN
HOUSE GAS EMISSIONS REDUCTION
I'M ESPECIALLY INTERESTED.
>> OKAY.
I THINK WE'LL GET STARTED ON THE
NEXT PRESENTATION.
THIS IS GOING DOB BY KELSEY
HENDRICKSON WHO WILL BE
PRESENTING ON THE DOD
SUSTAINABILITY MATERIAL
ALTERNATIVES RECOMMENDATIONS
TOOL.
THESE IN THE RISK MANAGEMENT
PROGRAM.
SHE ADDRESSED ENVIRONMENTAL,
CHEMICAL PUBLIC HEALTH RISK AND
HELPS IN OCCUPATIONAL HEALTH
MANAGEMENT AND HAS BEEN WORKING
AT CMRMP TO IDENTIFY RISK
ASSOCIATED WITH RISK AND HAS AN
MPM DEGREE IN ENVIRONMENTAL
HEALTH SCIENCE FROM GEORGE
WASHINGTON UNIVERSITY AND GIVE A
WARM WELCOME TO MS. KELSEY
HENDRICKSON.
YOU'RE ON THE AIR.
AND HFCs IS ONE OF THE CHEMICAL
GROUPS WE'RE LOOKING TO ADD DATA
TO FOR THE TOOL.
CHEMICALS AND MATERIALS ARE
VITAL FOR DEFENSE AND MAINTAIN
SECURITY.
THE DOD USES INFRASTRUCTURE, AND
PLATFORMS MADE FROM AND DEPEND
ON CHEMICALS AND MATERIALS.
THIS COULD BE BATTERIES OR
BUILDING REFRIGERANTS,
MUNITIONS, AIRCRAFT, YOU NAME IT
EVERYTHING HAS CHEMICAL IN IT
AND OFTEN OUR GROUP IS FOCUSSED
ON CHEMICAL CLASSES SUCH AS
SOLVENTS, PHTHALATES AMONG
OTHERS.
SO AT THE DOD, THE CHEMICAL
PROGRAM IS TO MANAGE RISK
ASSOCIATES WITH CHEMICALS AND
MATERIALS DOD USES.
WE EVALUATE THE CRITICALITY OF
DOD CHEMICAL AND MATERIAL USE,
ASSESS AVAILABILITY OF
ALTERNATIVES AND TRY TO IDENTIFY
AND COMMUNICATE MANAGEMENT
OPTIONS TO MITIGATE THOSE
MISSION RISKS.
TO DO THAT OUR PROGRAM IS
PRIMARILY FOCUSSED ON FIVE AREAS
LOOKING AT EMERGING CHEMICALS OR
ECs, SUSTAINABLE, CHEMISTRY,
CHEMICAL SUPPLY CHAIN AND
CHEMICAL RELATION AND HOW ALL
THOSE AREAS INTERSECT AND ARE
INTERWOVEN.
AND JUST TO QUICKLY DEFINE
EMERGING CHEMICALS AS DEFINED BY
THE DOD, THESE ARE CHEMICALS
RELEVANT TO DOD HAVING A
PERCEIVED OR REAL THREAT TO
HUMAN HEALTH FOR THE ENVIRONMENT
WITH NEW OR CHANGING TOXICITY OR
REGULATORY STANDARDS WITH NEW
SCIENCE OR DETECTION CAPABILITY
OR EXPOSURE PATHWAYS.
WE USED A THREE STEP SCAN ACTION
PROCESS TO REVIEW THE REGULATORY
ACTIONS FOR THE CHEMICALS OF
INTEREST AND TRIED TO IDENTIFY
POSSIBLE IMPACT TO DOD AND
ESTABLISH CORRESPONDING RISK
MITIGATION ACTIONS.
OUR PROGRAM LOOKS TO EVOLVING
DRIVERS ACROSS THE GLOBE.
HERE IN THE U.S. THAT MEANS
LOOKING AT THE TOXIC SUBSTANCES
CONTROL ACT AS WELL AS NATIONAL
DEFENSE AUTHORIZATION ACT
REQUIREMENT SUP AS THE ONE FOR
SUSTAINABLE CHEMISTRY.
IN EUROPE WE LOOK TO THE REACH
REGULATION AND LOOK TO SOMETHING
LIKE THE AMENDMENT TO THE
MONTREAL PROTOCOL AND THERE'S
MORE ACROSS THE GLOBE.
THEY REQUIRE RBT AND E OF
CHEMICAL ALTERNATIVES TO FIND
THINGS LESS HAZARDOUS AND
SUSTAINABILITY AND THIS HELPS
FOR OBSOLESCENCE OR MISSION
CRITICAL CHEMICALS SINCE
DOMESTIC AND INTERNATIONAL
ENTITIES ARE INCREASINGLY
LOOKING TO REGULATE BY CLASS AND
CATEGORY OPPOSED TO SINGLE
CHEMICALS.
I THINK OF THE PROPOSED PFAS
RESTRICTION AS AN EXAMPLE OF
LOOKING AT REGULATE BROAD CLASS
OF THE CHEMICALS.
OUR PROGRAM LOOKS AT USE OF
SPECIFIC CHEMICALS IN DOD
SYSTEMS AND TCE IN BATTERY
SEPARATORS.
METHOLINE CHLORIDE AND DETERMINE
WHERE THE REGULATIONS MAY CREATE
THE MOST PRESSING NEED FOR
SUSTAINABLE CHEMICAL ALTERN
ALTERNATIVES.
ENGINEERS THROUGHOUT DOD ARE
UNDER PRESSURE TO IMPROVE
PERFORMANCE.
PERFORMANCE OF MATERIALS, MAYBE
REDUCE CORROSION AND WEAR ON
SYSTEMS AND OVER ALL REDUCE THE
COST OF ACQUISITION OF A WEAPON
SYSTEM AND STAINSMENT FOR THE
SYSTEM.
-- SUSTAINMENT FOR THE SYSTEM
AND IN DOD WHERE MATERIALS HAVE
TO BE QUALIFIED AND MEET
SPECIFIC PERFORMANCE STANDARDS
CAN OFTEN TAKE EXTENSIVE TIME
PERIODS AND SO IT'S A PRESSING
NEED ESPECIALLY WHEN WE KNOW A
REGULATORY EFFORT MAY BE COMING.
AND THERE'S INVESTMENT AND USE
OF SUSTAINABLE CHEMICALS AND
MATERIAL ALTERNATIVES.
THE SMART TOOL IS DESIGN TO
RAPIDLY ASSESS HOW EMERGING
CHEMICALS ARE USED WITHIN DOD
AND USE A CHEMICAL PROCESS
INTERSECTION TO DESCRIBE WHERE
AND HOW IT IT THESE ARE USED AND
LINK THE CHEMICALS AND PROCESSES
TO ALTERNATIVES.
AND REDUCE THE RISK OF
REGRETTABLE SUBSTITUTIONS AND
MITIGATING IMPACTS TO MISSION
READINESS AND LIFE CYCLE COSTS.
AND THERE'S A LOOK AT REDUCING
CADMIUM AND OTHERS AND REDUCE
THE USE OF HEX CHROME AT THE DOD
DEPOTS AND OTHER CHANGE LOOKED
AT FOR HEXCHROME AND THE
REGULATION TO REDUCE OTHER
CHEMICALS AND AN ENTERPRISE
CHROMIUM FREE TECHNOLOGY
SELECTION TOOL WAS DEVELOPED TO
ASSIST THE DOD IN IMPLEMENTING
CHROME-FREE SUSTAINMENT
TECHNOLOGY IN A MANNER THAT
WOULD MITIGATE IMPACT READINESS
AND LOOK AT COST OR SUSTAINMENT.
THE DATABASE WAS ORIGINALLY
CREATED IN MICROSOFT ACCESS AND
PROVIDED THE USER WITH THE
ABILITY TO QUERY AND FILTER
USING CHEMICALS, PROFESSIONS AND
MILITARY SERVICES AND
INSTALLATIONS TO GENERATE SIMPLE
GRAPHICS AND REPORTS.
SO SKIPPING AHEAD, AND FUNDED
THE DEVELOPMENT OF PROOF OF
CONCEPT DATABASE INTO A TOOL
THAT COULD BE ULTIMATELY
POPULATED WITH DATA ACROSS
SERVICE.
THIS IS TO INCORPORATE
ADDITIONAL AVAILABILITY DATA,
EXPAND THE FUNCTIONALITY IN
RESPONSE TO USER REQUIREMENTS
AND DEMONSTRATE AND EVALUATE THE
TOOL PROTE 250I7 IN A FULL SCALE
OPERATIONAL SYSTEM WITH
TRANSITIONAL PARTNERS.
THE FIRST PHASE OF WHAT WE'RE
CALLING ACTIVITY 1 IS TO DO
OUTREACH TO THE MILITARY
SERVICES AND DOD COMPONENTS.
AND THIS IS REALLY TO IDENTIFY
DATA CAPS AND CAPTURE USER NEEDS
AND REQUIREMENTS
SOME OUTREACH PARTNERS INCLUDE
THE AIR FORCE, LIFE CYCLE
MANAGEMENT CENTER, ARMY,
AVIATION AND MISSILE COMMAND,
ARMY TANK, AUTOMOTIVE AND
ARMAMENTS AND THE FLEET
READINESS CENTER.
THOSE STAKEHOLDERS ARE KIND OF
EVOLVING AS WE DEVELOP THE TOOL
AND WE WORK WITH DIFFERENT
PROGRAMS TO FIT THE NEEDS OF THE
TOOL.
SECOND PHASE OF THE FIRST
ACTIVITY IS TO INCORPORATE THE
INFORMATION INTO THE PROTOTYPE
TOOL.
AND TRANSITION THE TOOL FROM
MICROSOFT ACCESS TO A
WEB-ENABLED ENVIRONMENT.
SO THIS INCLUDES THINGS LIKE
DESIGN AND MOCK UPS, BACK END
APPLICATION DEVELOPMENT, AND
DEPLOYING AND TRANSITIONING TO
DENNEX WHICH IS DOD'S CLOUD
PLATFORM FOR SHARING
INSTALLATION, ENERGY,
ENVIRONMENT, SAFETY AND HEALTH
INFORMATION.
AND THE SECOND ACTIVITY
DEMONSTRATE THE TOOL WITH OUR
TRANSITION PARTNERS AND THIS IS
WHERE WE ARE NOW.
WE'RE TRYING TO CAPTURE FEEDBACK
FROM DEMONSTRATIONS AND UPDATE
THE TOOL AS NEEDED FOR
DEPLOYMENT.
AND THEN FINALLY WE'RE LOOKING
TO DEVELOP A FINAL REPORT AND
BRIEFING AND THIS REPORT IS ALSO
GOING TO INCLUDE A USER'S GUIDE
AND RECOMMENDATION FOR REACHING
TECHNOLOGY READINESS LEVEL OR
TR9.
THE DATABASE FORMAT OF THE TOOL
ALLOWS FOR A LIVING TOOL THAT
CAN BE EASILY UPDATED AS NEW
INFORMATION IS COLLECTED.
THE PROTOTYPES USER INTERFACE
CONSISTS OF A QUERY FORM THAT
ALLOWS USERS TO GENERATE
CUSTOMIZABLE DASHBOARDS AND
REPORTS AND BASED ON USER NEEDS
AND TALKING TO VARIOUS
STAKEHOLDERS THAT WE IDENTIFY
DURING PROTOTYPE DEVELOPMENT,
WE'RE BASICALLY LOOKING AT FOUR
DIFFERENT REPORT STYLES THAT CAN
BE OUGHT -- AUTOMATICALLY
CREATED AND AS THE TECHNOLOGY
ADVANCES AND AAS PART OF THE
PROTOTYPE TO SYSTEM OUR TEAM IS
GOING FROM ACCESS TO TECHNOLOGY
AND SQL SERVER AND MICROSOFT
DOT-NET CORE INTERFACE.
THIS MORE DYNAMIC FORMAT ALLOWS
INFORMATION USEFUL TO DECISION
MAKERS TO LOOK WHERE THERE'S GAP
AND LOOK AT GAPS AND START A
FRAMEWORK TO PLAN, COORDINATE
OUR RESOURCES AND SUCCESSFULLY
IMPLEMENT REDUCTION AND
ELIMINATION TECHNOLOGIES WHERE
POSSIBLE.
AND THERE'S NUMEROUS SOURCES OF
DATA FROM DOD EVENTUALLY BUT IN
THIS ROUND OF DEVELOPMENT WE'RE
FOCUSSING ON INCORPORATING DATA
FROM DEFENSE WHICH STANDS FOR
THE ADVANCED SURFACE ENGINEERING
TECHNOLOGIES FOR SUSTAINABILITY
EVENTS.
ASSETS PROVIDES DEFENSE
ORGANIZATION WITH INFORMATION
AND ASSISTANCE TO IMPROVE WEAPON
SYSTEMS PERFORMANCE AND LIFE
CYCLE COST WHILE ALSO REDUCING
OR ELIMINATING ENVIRONMENTAL
SAFETY AND OCCUPATIONAL HEALTH
IMPACTS FROM CODINGS AND
TREATMENT PROCESSES THAT MIGHT
USE LIGHT HEX VALENT CHROMIUM OR
CADMIUM AS WELL AS COATINGS THAT
CONTAIN OTHER VOLATILE ORGANIC
COMPOUNDS.
AND WE'RE UPDATED VIA THE SMART
TOOL TO PROVIDE ACCESS TO
INFORMATION NEEDED TO MAKE
INFORMED DECISIONS ON THE USE OF
ALTERNATIVES TO MATERIALS AND
TECHNOLOGIES FOR SURFACE
ENGINEERING THAT MIGHT POSE
ENVIRONMENTAL OR HEALTH HAZARDS.
AND THIS INFORMATION INCLUDES
DETAILED ENGINEERING DATA,
BACKGROUND DOCUMENTS AND
INFORMATION ON PROCESSES AND
PRODUCTS VALIDATED, AUTHORIZED
OR IMPLEMENTED.
IN ADDITION, WE'RE ALSO LOOKING
AT USING OR ARE USING CHEMICAL
USAGE DATA FROM SERVICES
GATHERED FROM SYSTEMS WHICH
STANDS FOR ENTERPRISE
ENVIRONMENTAL SAFETY
OCCUPATIONAL HEALTH MANAGEMENT
INFORMATION SYSTEM.
AND WE'RE ALSO LOOKING TO
HOPEFULLY INCORPORATE DATA FROM
DEFENSE OCCUPATIONAL AND
READINESS SYSTEM AND THAT'S MORE
ON THE EXPOSURE SIDE OF DATA.
.
SO THE DEVELOPMENT OF SMART
INVOLVES PART OF NERG WITH
APPROPRIATE DOD DECISION MAKERS
AND STAKEHOLDERS.
REPRESENTING DIFFERENT GROUPS
AND THOSE MIGHT INCLUDE
ENVIRONMENTAL RESTORATION OR
DRINKING WATER MANAGEMENT WEAPON
SYSTEMS, ACQUISITION FOLKS,
DEPOTS, SAFETY AND OCCUPATIONAL
HEALTH PERSONNEL AND OTHERS AS
NEEDED TO DEFINE THE
REQUIREMENTS, COLLECT RELEVANT
DATA AND THEN DEVELOP A
CENTRALIZED SOURCE OF
INFORMATION TO INFORM THE
DASHBOARD.
THE TOOL ALSO HAS QUERYING
CAPABILITIES SO USERS CAN SEARCH
BY CHEMICAL, PROCESS, SERVICE,
DEPOT, INSTALLATION AND
ALTERNATIVE AND CAN CREATE
CUSTOM DASHBOARDS AND REPORTS.
THESE MAY DESCRIBE THE CHEMICAL
PROCESS AND USAGE AND DESCRIBE
ALTERNATIVE TECHNOLOGIES BY
INITIATIVE AND LOOK AT
TECHNOLOGY GAPS AND BARRIERS TO
IMPLEMENTATION FOR THE
ALTERNATIVES.
AND THEN AND I'LL USE CHROMIUM
FOR WHAT THE TOOL CAN CAPTURE
AND SOME VISUALS.
WE HAVE EIGHT OF HISTORICAL DATA
ON CHROMIUM AND DRIVERS AND
WE'RE IN THE PROCESS OF ADDING
DATA FOR OTHER CHEMICALS AND
MATERIALS BUT OUR CHROMIUM DATA
IS PROBABLY THE MOST EXTENSIVE
AT THIS POINT.
CHROMIUM HAS A LOT OF DRIVERS
AND THERE'S RESTRICTIONS.
THERE WERE ADOPTED CHANGES FOR
THE EXPOSURE LEVELED IN CHROMIUM
REQUIRING THE REPLACEMENT OF
CHROMIUM AND MEDICAL MONITORING.
DOD IS ALSO POSSIBLY CHANGING
REQUIREMENTS WITH RESPECT TO
CHROMIUM.
THERE'S THE DOD WIDE MEMO FOR
HEX VALENT USE OF CAVALENT USE
RESTRICTIONS IN CALIFORNIA AND
THERE'S FEDERAL MOVEMENT ON
HEXAVALENT CHROMIUM AND THE
INTEGRATED RISK INFORMATION
SYSTEM ON HEXAVALENT CHROMIUM
TOXICITY IS EXPECTED TO BE
RELEASED IN 2024, ANY TIME NOW.
THE EXTERNAL PEER-REVIEW REPORT
WAS RELEASED IN SEPTEMBER.
FOLLOWING THE IRIS ASSESSMENT
IT'S ON THE WORK PLAN LIST SO
THERE PAY BE ADDITIONAL
REGULATIONS COMING FOR CHROMIUM
AS WELL THOUGH THERE'S NO TIME
LINE FOR THAT RIGHT NOW.
SO WITH THIS INCREASE IN THE
RATE OF CHANGE IN POLICY, THE
TOOL CAN SUPPORT MORE RAPID AND
CONSISTENT DECISION MAKING FOR
CHEMICALS SUCH AS HEXAVALENT
CHROMIUM.
AND THIS PROVIDES ADDITIONAL
DETAILS ON THE ADOPTED CHANGES I
REFERENCED.
FOR BOTH HEXAVALENT CHROMIUM
THRESHOLD LIMIT VALUES
RECOMMENDED DROPPED MULTIPLE
ORDERS OF MAGNITUDE FROM THE OLD
VALUES TO NEW VALUES AND THESE
CHANGES CAN HAVE REAL IMPACTS ON
DOD AND THEY MIGHT RANGE FROM
HAVING TO MODIFY SIMPLE METHODS
TO INCREASING MEDICAL
SURVEILLANCE, POSSIBLY PROVIDING
ADDITIONAL TRAINING OR
INCREASING HAZARD COMMUNICATION.
ALL THESE REQUIREMENTS
NECESSITATE THE NEED FOR
SUSTAINABLE ALTERNATIVES IN
CASES LIKE THIS.
UNDERSTANDING HOW CHEMICALS ARE
USED WITHIN DOD IS REALLY
ESSENTIAL TO DEVELOPING EXPOSURE
MITIGATION STRATEGIES AS WELL AS
ALTERNATIVE TECHNOLOGIES TO
REPLACE THEM.
SMART RELIES HEAVILY ON WHAT
WE'RE CALLING THE CHEMICAL
INTERSECTION TO DESCRIBE WHERE
AND HOW A CHEMICAL IS USED AND
THEN THE LINKING PROCESS TO
ALTERNATIVES WITHIN THE TOOL.
YOU CAN SEE HERE THIS IS A
VISUAL MAP BUT IT'S NOT ENOUGH
TO SIMPLY HAVE AN ALTERNATIVE
FOR A PARTICULAR CHEMICAL.
YOU NEED TO HAVE AN ALTERNATIVE
FOR EVERY PARTICULAR CONDITION
OF USE OR PROCESS THAT A
CHEMICAL IS INVOLVED IN.
AND THE CHEL CAL -- CHEMICAL
PROCESS FOR PLATING, CONVERSION
CODING AND AN OWE -- ANNODIZING
AND IT'S IMPORTANT HERE IN THE
PICTURE YOU LOOK ACROSS THE
ENTERPRISE TO LOOK HOW AND LOOK
AT THE ALTERNATIVES REFERENCED
ARE CHEMICAL ALTERNATIVES.
THEY MAY BE THE TRADE NAMES AND
SOME MAY REPLACE THEM ALTOGETHER
SUCH AS LASER REMOVAL.
DEF
THIS IS DATA FROM DIFFERENT
SOURCES.
THIS IS SHOWING HOW THE CHEMICAL
SELECTION INTERFACE TO DRILL
DOWN TO CERTAIN CHEMICALS OR
GROUPS OF INTEREST.
THEN HERE YOU CAN SEE HEXAVALENT
CHROMIUM AND USAGE ACROSS DOD
THROUGH 2017.
IT'S FURTHER DIVIDED INTO
PROCESS CATEGORIES BY COLOR.
YOU CAN SEE THE AEROSPACE
PRIMARIES AND CHROME PLATING
INTEREST THE LARGEST USES ACROSS
DOD.
AND CAN GO FROM THERE.
ON THE SIDE YOU'D BE ABLE TO
SELECT THIS IS JUST THE OVERVIEW
FOR HEXAVALENT CHROMIUM USES AND
YOU CAN DIG DOWN INTO THE
SPECIFIC PROCESSES AND GET MORE
SPECIFIC INFORMATION FROM THERE.
SO, HERE YOU SEE USAGE TOTALS
FOR JUST USES AND SEALANTS.
IT'S IMPORTANT TO NOTE THERE MAY
BE DRAMATIC CHANGES IN USAGE
ESPECIALLY WITH SOMETHING LIKE A
TANK TECHNOLOGY.
IF DURING A PARTICULAR YEAR IT
WASN'T NECESSARY TO DUMP AND
RECHARGE A TANK MAYBE USAGE
WOULD BE LOW ONE YEAR AND
MAINTAINING TANK CHEMISTRY.
HOWEVER SOME YEARS A COMPLETE
TANK DUMP AND RECHARGE IS
NECESSARY INFLATING THE CHEMICAL
USED IN THAT PARTICULAR YEARS.
THIS IS THE CASE WITH CHROME
PLATING AND MAY TREAT WITH
SEALERS ON THE CURRENT SLIDE.
IT'S IMPORTANT TO LOOK AT
MULTIPLE YEARS' WORTH OF DATA
WHEN YOU'RE TRYING TO DETERMINE
CHEMICAL USAGE BECAUSE YOU MAY
NOT USE OR PROCURE THE SAME YEAR
TO YEAR AND YOU'LL HAVE THE
ABILITY TO FILTER BY YEAR, BY
MILITARY SERVICE AND DRILL DOWN
INTO A PARTICULAR INSTALLATION
TO LOOK AT PARTICULAR
INSTALLATION WHERE YOU KNOW
USAGE AND WE HAVE A TAB FOR
EXPOSURE DATA.
AND THEN WE HAVE AN ALTERNATIVE
TAB.
SO HERE YOU CAN SEE THERE ARE
NINE LISTED ALTERNATIVES FOR
CHROME PLATING HEXAVALENT
CHROMIUM AND THIS ALTERNATIVE IN
PARTICULAR SHOWS DETAILS ON A
PROCESS WHERE WE LOOK AT THE
TRADE NAME FOR THE PRODUCT.
IT LOOKS FOR APPROVED USES OR
SYSTEMS AND BELOW ON THE SCREEN
IF YOU SCROLL DOWN IT SHOWS THE
PHYSICAL AND MECHANICAL
PROPERTIES OF THE ALTERNATIVE AS
WELL AS PROCESS PARAMETERS.
SO ALL OF THAT CAN HELP DECISION
MAKERS DECIDE WHETHER IT'S A
POSSIBLE ALTERNATIVE FOR THEM.
AND THE NEXT STEP IS TO PROVIDE
DATA EXPANSION TO INCLUDE
UPDATED CADMIUM AND CHROMIUM
DATA AS WELL AS OTHER CHEMICALS.
WE ARE LOOKING AT OTHER
CHEMICALS AND WE'LL FINISH
INCORPORATING DEFENSE
ENGINEERING DATA TO FLUSH OUT
SOME OF THE ALTERNATIVES THAT
ARE AVAILABLE.
WE'RE ALSO GOING TO CONTINUE TO
OPTIMIZE THE DASHBOARD AND
REPORTING CAPABILITIES,
INTEGRATE DATA WITH OTHER
PLATFORMS WHEN POSSIBLE AND
FINALLY TRANSITION THE TOOL TO
DENX THE DOD WIDE PLATFORM
AVAILABLE TO MILITARY SERVICES
AND CONTRACTOR PERSONNEL.
AND I THINK THAT'S IT.
SO I'VE LISTED MY CONTACT EMAIL
HERE AS WELL AS OUR SPONSOR, AND
HAPPY TAKE QUESTIONS HERE OR
OFFLINE IF YOU HAVE THEM.
THANK YOU.
YOU MENTIONED USING IT WITH
ACCESS AND SQL SERVER.
WILL THERE BE ADD ON FOR
INTEGRATION AS AN APP WITH
MICROSOFT TEAMS AND THE 365
SERVER?
>> WE DON'T HAVE PLANS TO
INTEGRATE WITH TEAM RIGHT KNOW
BUT HAVE FULLY TRANSITIONED OFF
ACCESS.
THAT'S THE INITIAL DATABASE AND
IT'S NOW GOING TO BE A WEB-BASED
TOOL.
YOU'D BE ABLE TO LOG IN ON THE
WEB AND DENX AND ACCESS THAT
TOOL.
WE'RE WORKING ON THAT PART OF
THE PROCESS RIGHT NOW.
>> SO ON DENX, OKAY.
>> WILL THERE BE A LIVE TRAINING
TOOL?
>> WE DON'T HAVE IT UP AND
RUNNING YET BUT IT'S PART OF THE
DELIVERABLE FOR THE PROJECT AND
HOPE TO VIT BY THE END OF JULY.
LOOKING AT A SUMMERTIME FRAME
FOR GETTING THIS PROJECT
TRANSITIONED.
>> AWESOME.
>> WILL THERE BE A MEMO ISSUED
ON USING IT?
>> I'M NOT SURE BUT IT'S A GREAT
IDEA TO COMMUNICATE IT OUT TO
VARIATION AUDIENCE.
I THINK WE'LL HAVE TO THINK A
COMMUNICATIONS PLAN AND HOW TO
GET THE WORD OUT.
>> SURE.
DOES ANYONE HAVE ANY QUESTIONS?
WE CAN LOOK AT THE INBOX.
DO YOU YOURSELF HAVE BACKGROUND
IN PROGRAMMING OR DATA ANALYSIS?
>> I DON'T.
I'VE HAD TO BE A FAST LEARNER.
MY BACKGROUND'S IN CHEMICALS AND
ENVIRONMENTAL ENGINEERING.
SO, WORKING WITH THE DEVELOPERS
TO PULL THIS TOGETHER SO
STARTING TO UNDERSTAND THE
WINDOW.
>> VERY COOL.
I CONFESS MOST ANY EXPERIENCE IN
DATA IS THROUGH ACCESS AND NEW
MICROSOFT IS SUN SETTING IT BUT
IT'S THE ONLY RELIABLE WAY FOR
SYNCHRONIZED DATA VERSE.
>> IT'S COMPLICATED.
>> RIGHT.
NOW WE HAVE OF COURSE THE POWER
PLATFORM ADMITTEDLY IT'S
BECOMING REDUNDANT AND NOW WE
HAVE EXCEL AND POWER V.I.
>> I HAVE BUT JUST A LITTLE BIT.
-- POWER B.I.
>> I HAVE BUT JUST A LITTLE BIT.
>> OKAY, THANK YOU SO MUCH FOR A
FANTASTIC PRESENTATION AND
LOOKING FORWARD TO THE TOOL AND
THANKS FOR YOUR HARD WORK AND
LOOK TO WORK IN THE FUTURE ON
GETTING IT OUT TO THE DOD.
LET'S GIVE A WARM WELCOME TO
MR. CHRISTOPHER RUA AT POTOMAC
HUDSON ENGINEER AND GRADUATE
FROM RUTGERS UNIVERSITY IN 2011
WITH A B.S. IN ENVIRONMENTAL
DESIGN AND WENT TO THE
UNIVERSITY OF MARYLAND
UNIVERSITY COLLEGE AND HAS BEEN
WITH PHE AND THERE'S A WIDE
RANGE OF STATE AND FEDERAL
COMPLIANCE AND WORKED IN PUERTO
RICO AND JAPAN WITH A FOCUS ON
HAZARDOUS WASTE MANAGEMENT.
YOU ARE ON THE AIR.
>> THANK YOU FOR THE
INTRODUCTION.
WELCOME, EVERYONE.
WE'LL TALK ABOUT THE NEW
HAZARDOUS WASTE RULES AND
THERE'S THREE MAIN RULES WE'LL
TALK ABOUT AND THE AEROSOL CANS
WASTE RULE AND NEW
PHARMACEUTICAL RULES.
HERE'S A QUICK OVERVIEW AND
OUTLINE OF WHAT WE'LL GO OVER
TODAY.
THIS WAS FROM A PRESENTATION
DESIGN TO BE LONGER.
I MIGHT -- I'VE REDUCED SOME OF
SLIDES BUT I'LL TRY GO THROUGH
THE EARLY SLIDES AS QUICKLY AS I
CAN THE BACKGROUND STUFF.
SO FIT IT ALL IN.
I ASSUME THE SLIDES WILL BE OR
CAN BE MADE AVAILABLE FOR
EVERYONE IF THEY WANT TO TAKE A
CLOSER LOOK AT THE EARLY SLIDES.
BASICALLY, WE'LL GO OVER THE
BACKGROUND AND HISTORY OF IT.
WE'LL GO OVER THE GOALS OF THE
NEW HAZARDOUS GENERATED
IMPROVEMENT RULE AND TALK ABOUT
THE NEW CHANGES.
THE ONES LESS STRINGENT AND LESS
STRINGENT AND I'LL HAVE A QUICK
SUMMARY OF THAT AND THEN WE'LL
TALK ABOUT THE AEROSOL CANS AND
PHARMACEUTICAL RULES.
I'M ASSUMING POST THE AUDIENCE
HAS A HIGH-LEVEL UNDERSTANDING
OF WHAT HAZARDOUS WASTE IS.
THE HISTORY WAS ESTABLISHED BY
EPA IN 1976 PART OF THE
ENVIRONMENTAL AWAKENING IN THE
LATE '60s AND EARLY '70s.
IT WAS PRIMARILY AIMED AT
ILLEGAL DUMPING ACTIVITIES.
IT WAS A LANDMARK LEGISLATION AT
THE TIME AND WAS A PRETTY BIG
DEAL AND AFFECTED A WIDE RANGE
OF INDUSTRIES AND SMALL
BUSINESSES.
THERE WASN'T ANY ONE SINGLE
EVENT THAT LED TO IT.
IT WAS A COMPILATION OF EVENTS
OVER TIME.
NOTE LIKE LOVE CANAL WHICH
CREATED THE EXXON VALDEZ.
AND HOW IS IT AFFECTIVE AND THE
MAIN PIECE IS IT TRACKS
HAZARDOUS WASTE FROM CRADLE TO
GRAVE FROM THE MOMENT IT'S
CREATED AT A FACILITY TO WHEN
IT'S DISPOSED OF AT TREATMENT
STORAGE AND DISPOSAL FACILITY.
IT'S BASICALLY WHEN IT'S DEN
RATED AND STORED ON SITE AND
TRANSPORTED FROM ONE PLACE TO
FORGE AND DISPOSED OF.
IT'S DONE THROUGH THE MANIFEST
SYSTEM EPA HAS ESTABLISHED.
IT COULD BE MODERATE TO A
REGULATORY BURDEN DEPENDING ON
HOW MUCH YOU GENERATE PER MONTH
AND WE'LL TALK ABOUT IT IN A
MINUTE.
THERE'S SIGNIFICANT FINDS FOR
NON COMPLIANCE.
THIS IS A MEDIA AREA HIGH ON
EPA'S RADARS AS YOU CAN IMAGINE
FOR THE ENVIRONMENTAL HEALTH AND
SAFETY IMPACTS OF IT.
SO WHEN WE DO OUR COMPLIANCE
INSPECTIONS, THIS IS ONE OF THE
AREAS THAT WE REALLY FOCUS ON
AND WHENEVER WE DO A MULTI-MEDIA
AUDIT, USUALLY THE MAJORITY OF
FINDINGS THAT WE HAVE COME FROM
HAZARDOUS WASTE MANAGEMENT.
SO THE PROBLEMS WITH THE OLD
RULE THERE WAS AMENDMENT AFTER
AMENDMENT OVER TIME.
SOME OF THE LANGUAGE IN IT WAS
VERY OUTDATED.
SOME REQUIREMENTS -- THERE WAS A
LOT OF AMBIGUITIES AND SIMPLE
THINGS LIKE TYPOS.
A LOT OF THIS WAS AMENDMENT TO
THE INITIAL ACT.
THE GOAL WAS TO MAKE IT MORE
USER FRIENDLY.
TE SECOND WAS TO ADD GREATER
FLEXIBILITY TO ALLOW SMALLER
BUSINESSES THAT GENERATE SMALLER
AMOUNTS OF HAZARDOUS WASTE TO
GIVE THEM REGULATORY RELIEF.
TO FILL IN SOME OF THE GAPS THAT
WERE IN THE ORIGINAL RULE AND
ALSO TO PROVIDE CLARITY FOR SOME
OF THOSE AMBIGUITIES I
MENTIONED.
AND THE OVER ALL GOAL WAS TO
FOSTER IMPROVED COMPLIANCE WITH
THE REGULATOR COMMUNITY.
OBVIOUSLY IN 30 MINUTES OR 25
MINUTES WE'RE NOT GOING TO GO
OVER EVERYTHING THAT CHANGED BUT
WE'LL FOCUS ON THE ONES MOST
LIKELY TO IMPACT BUSINESSES THE
4069 IMPORTANT ONES.
I ENCOURAGE EVERYONE TO TAKE A
DEEPER LOOK AT THE CFR IF THEY
HAVE FOR FURTHER DETAILS BEYOND
WHAT WE'RE GOING TO COVER TODAY.
SO FOR BACKGROUND, I TALKED
ABOUT HOW REGULATIONS KIND OF
DIFFER AND BECOME MORE STRINGENT
BASED ON HOW MUCH HAZARDOUS
WASTE YOU GENERATE IN A MONTH.
EPA HAS THREE CATEGORIES FOR
GENERATORS.
THE FIRST THREE HERE, VERY
SMALL, SMALL AND LARGE AND AS I
MENTIONED BASED LARGELY ON HOW
MUCH HAZARDOUS WASTE YOU
GENERATE PER MONTH.
THERE'S ALSO A LIMIT ON HOW MUCH
OVER ALL HAZARDOUS WASTE YOU CAN
STORE ON SITE AT ANY ONE TIME.
DEPENDING ON THE VOLUMES IS THE
CATEGORY YOU FALL INTO AND
OBVIOUSLY THE REGULATORY BURDEN
INCREASES THE MORE YOU GENERATE
AND THIS OVER HERE ON THE RIGHT
IS TREATMENT STORAGE AND
DISPOSAL FACILITY.
THOSE ARE THE END DESTINATIONS
FOR HAZARDOUS WASTE AND THE WAY
THEY'LL BE TREATED AND DISPOSED
OR STORED INDEFINITELY.
SOME OF THE ADMINISTRATIVE
CHANGES THAT OCCURRED WITH THE
HAZARDOUS WASTE IMPROVEMENT RULE
IS A BIG ONE IS ENFORCEMENT AND
BASICALLY EPA AND IT INTERPRETS
VIOLATIONS AND THEY SEPARATED
VIOLATIONS TO TWO CATEGORIES.
THE INDEPENDENT REQUIREMENTS AND
THE CONDITIONS FOR EXEMPTION.
THE INDEPENDENT REQUIREMENTS ARE
SORT OF TREATED AS THEY ALWAYS
HAVE BEEN AND IF YOU GET A
VIOLATION YOU GET FINED AND IT'S
PRETTY ABOVE BOARD AND THE
EXEMPTIONS ARE WHERE THE MAIN
CHANGE HAVE BEEN AND COULD
SIGNIFICANTLY INCREASE THE FINES
FOR THE REGULATED COMMUNITY
BECAUSE BASICALLY THEY SEE A
VIOLATION OF ANY OF THESE ITEMS
AS ESSENTIALLY MOVING YOU FROM
BEING JUST A GENERATOR TO THAT
TSDF WE TALKED ABOUT.
AND AS YOU CAN IMAGINE THE TSDF
HAS STRICT REGULATIONS.
THEORETICALLY, IF YOU'RE A SMALL
QUANTITY GENERATOR AND HAVE A
VIOLATION THAT EFFECTS ONE OF
THESE FOUR AREAS, THEY COULD IN
EPAs MIND IT COULD TREAT YOU
ADDS A TREATMENT STORAGE AND
DISPOSAL FACILITY AND GIVE YOU
FINES FOR EVERYTHING THAT A TSDF
IS SUPPOSED TO HAVE THAT YOU
DON'T HAVE.
YOU CAN IMAGINE IT COULD GIVE A
$70,000 PLUS FINE FOR EACH ONE
OF THOSE FOR EACH DAY THAT IT
HAPPENS.
EPA HAS SAID IT'S NOT REALLY
GOING TO DO THAT AND BY AND
LARGE WITH OUR CLIENTS WE
HAVEN'T SEEN THAT BUT IT'S A
POSSIBILITY AND SOMETHING WE
WANT TO MAKE SURE OUR CLIENTS
UNDERSTAND WHEN WE DO ECEs.
SOME OF THE OTHER ADMINISTRATIVE
CHANGES ARE MINOR.
THEY CHANGE THE WORDING AND IT'S
A VERY SMALL QUANTITY GENERATOR
THAT'S A NUANCE.
THEY USED TO JUST HAVE A
ONE-QUART LIMIT FOR ACUTE
HAZARDOUS WASTE AND NOW THEY
ADDED ONE KILOGRAM TO ACCOUNT
FOR SOLID MATERIALS.
THERE WAS REQUIREMENT FOR MOVING
HAZARDOUS WASTE FROM A SATELLITE
AREA TO ACCUMULATION AREA WHEN
IT WAS FULL WITHIN THREE DAYS
AND THERE WAS AMBIGUITY AS TO
WHETHER IT MEANT BUSINESS DAYS
OR THREE CALENDAR DAYS, 75 HOURS
SO THEY CLARIFIED THAT AND
ESTABLISHED THE TERM CENTRALIZED
ACCUMULATION AREA STORING ONSITE
ONCE IT GOT OUT OF THE SATELLITE
AREA UNTIL IT WAS PICKED UP.
AND HERE'S PART OF THE USER
FRIENDLY STREAMLINED HOW IT'S
ORGANIZED IN THE CFR TO MAKE IT
CLEARER.
SO YOU'RE NOT JUMPING BACK AND
FORTH FROM ONE SECTION TO
ANOTHER.
ALL RIGHT, SO ONE OF THE MORE
LESS STRINGENT REQUIREMENTS IS
NOW THAT VERY SMALLER QUANTITY
GENERATORS CAN SEND THEIR WASTE
TO A LARGE QUANTITY GENERATOR
INSTEAD OF TO A TSF AND WE'VE
SEEN THIS WHERE YOU MIGHT HAVE A
V.A. HOSPITAL AND THERE MAY BE A
CENTRAL HOSPITAL AND THEY HAVE
OUT PATIENT CLINICS THAT ARE
AFFILIATED WITH THEM.
THOSE CLINICS CAN HAVE THEIR
WASTE AND TRANSPORT TO THE MAIN
HOSPITAL AND LET THE MAIN
HOSPITAL DEAL WITH ALL THE
PAPERWORK.
SO WE'VE SEEN THAT WITH SOME
MILITARY INSTALLATIONS AS WELL.
A SMALL FACILITY CAN SEND THEIR
WASTE TO A BASE THAT FALLS THAT
THEY FALL UNDER THE COMMAND OF.
AND REQUIRED FOR THE VERY SMALL
TO BRING THEIR WASTE TO LARGE.
SO IT KIND OF REDUCE THE REGULAR
REGULATORY BURDEN ON THE LITTLE
GUYS.
EPISODIC EVENT SAY BIG ONE.
AS A MENTIONED THE HAZARDOUS
WASTE GENERATOR CATEGORIES ARE
BASED ON HOW MUCH WASTE YOU
GENERATE PER MONTH.
OCCASIONALLY YOU MAY EXCEED THAT
AND IN THE OLD DAYS IF YOU
EXCEEDED IT FOR ONE MONTH, THEN
YOU WERE THAT HIGHER CATEGORY
FOR THE REST OF THE YEAR.
THE NEW LAW ALLOWS YOU TO HAVE
ONE OR TWO EVENTS WHERE YOU
EXCEED PER YEAR IF YOU GET
PERMISSION FOR IT.
FOR A PLANNED EVENT AND A
PLANNED EVENT AND PLANNED AND
UNPLANNED.
A PLANNED HAVEN'T WOULD BE YOU
HAVE MATERIALS YOU DON'T USE
ANYMORE AND DO A SITE WIDE CLEAN
UP ONE MONTH AND GENERATE MORE
THAN YOU NORMALLY WOULD, YOU CAN
PETITION TO HAVE A PLANNED EVENT
BECAUSE YOU EXCEED THE ONE MONTH
FOR THE CLEAN OUT DOESN'T MEAN
YOU ARE THE HIGHER CATEGORY FOR
THE REST OF THE YEAR.
IT KIND GIVES YOU A PASS.
AND UNPLANNED ACTIVITY IS WHEN
YOU PETITION FOR AFTER IT
HAPPENED BECAUSE IT WAS
UNPLANNED.
LIKE AN ACCIDENT OR SOMETHING
FAILS OR LARGE SPILL AND YOU
HAVE A LOT OF CLEANUP MATERIALS
THAT ARE NOW HAZARDOUS WASTE.
IF YOU DO NOTIFICATIONS YOU CAN
GET PERMISSION TO NOT HAVE IT
COUNTED AGAINST YOU FOR THE
YEAR.
YOU CAN ASK FOR A SECOND ONE.
IF YOU HAVE A PLANNED EVENT YOU
CAN MAYBE HAVE AN UNPLANNED
EVENT AND MAYBE WE'LL GIVE YOU
PERMISSION FOR IT AND VICE VERSA
BUT YOU GET AT LEAST ONE BUT YOU
STILL HAVE TO GET PERMISSION AND
THEN HAVE THE POTENTIAL TO HAVE
TWO.
AS I TALKED ABOUT, ONE PER YEAR
AND AGAIN IF EPA SEES THAT EVERY
YEAR YOU'RE DOING THE SAME
THING, THEY MIGHT START TO NOT
WANT TO GIVE YOU PERMISSION
BECAUSE THEN THEY MIGHT SEE YOU
AS TRYING TO SKIRT THE
REGULATIONS ON PURPOSE.
BUT THEY WANT TO ALLOW IT SO YOU
CAN CLEAN OUT A LOT OF OLD
MATERIALS AND STUFF FOR EXAMPLE
AND NOT HAVE IT COUNT AGAINST
YOU.
THIS ONE THE 50-FOOT RULE, THAT
WAS JUST A MINOR THING ABOUT
STORING HAZARDOUS IGNITABLE
REACTIVE MATERIALS WITHIN 50
FEET OF THE PROPERTY LINE AND
NOW IF THE LOCAL FIRE MARSHAL
SAYS IT'S OKAY YOU CAN GET A
WAIVER FOR IT.
SO THAT COVERS SOME OF THE LESS
STRINGENT ASPECTS OF THE NEW
RULE AND NOW WE'LL FOCUS ON THE
MORE STRINGENT ASPECTS.
AND SO JUST TO BACK UP FOR A
SECOND, WHEN THE RULE CAME OUT
STATES WERE REQUIRED TO ADOPT A
MORE STRINGENT REQUIREMENT OF
THE RULE AND THEY HAD THE OPTION
TO ADOPT THE LESS STRINGENT
REQUIREMENTS.
AND THEY HAVE THE ADOPTION OF
THE RULE AND EVEN THOUGH THE
DEADLINE HAS PASSED AND THROUGH
THE STATE LEGISLATIVE PROCESSES
AND MOST THE STATES THAT ADOPT
THE RULE ADOPT THE LESS AND MORE
STRINGENT PROVISION.
THERE'S A HANDFUL OF STATES THAT
INCLUDED ONE OR MORE OF THE LESS
STRINGENT PROVISIONS BUT THEY
ADOPT THE WHOLE THING OR HAVEN'T
YET.
AND THE BIG ONES OF THE NEW
RULES ARE MAKING HAZARDOUS WASTE
DETERMINATIONS, RENOTIFYING IF
YOU'RE A SMALL QUANTITY
GENERATOR AND LABELLING
REQUIREMENTS FOR CONTAINERS AND
QUICK REFERENCE GUIDE AND
BIANNUAL REPORTING.
SO HOW DO YOU DETERMINE IF YOUR
WASTE IS A HAZARDOUS WASTE?
SO THERE'S TWO MAIN TYPES OF
HAZARDOUS WASTE, EITHER LISTED
WASTE OR CHARACTERISTIC WASTE
AND FOR THOSE THERE'S FOUR
CATEGORIES OF EACH.
AND LISTED WASTE IS BASICALLY
HHS BECAUSE OF WHERE IT COMES
FROM.
AND NO MATTER WHAT, IF IT COMES
FROM A CERTAIN PROCESS IT'S
AUTOMATICALLY CONSIDERED
HAZARDOUS WASTE OR CERTAIN
MATERIAL IS AUTOMATICALLY
HAZARDOUS WASTE.
A CHARACTERISTIC WASTE HAS TO
MEET ONE OR MORE OF THESE
CRITERIA TO BE CONSIDERED A
HAZARDOUS WASTE AND THERE'S
TESTING YOU CAN DO TO MAKE THAT
DETERMINATION.
THE TWO WAYS COMES FROM THE
LISTED WASTE AND COME FROM THE
PROCESS WAS THAT GENERATED THE
WASTE AND KNOW IF IT MEETS THE
CATEGORY BEING A HAZARDOUS WASTE
OR KNOW THIS IS WASTE AND THE
OTHER TYPE IS LABORATORY TESTING
TO SEE IF IT MEETS A
CHARACTERISTIC REQUIREMENT.
IMPORTANT THING IS DON'T GUESS.
GENERATORS BEING A LITTLE BIT
CAVALIER ABOUT THEIR GENERATOR
KNOWLEDGE MAYBE MAKE ASSUMPTIONS
ABOUT A WASTE THEY SHOULDN'T AND
EPA IS TRACKING DOWN ON THAT.
THIS IS A STEP MANY GENERATORS
STRUGGLE WITH AND THEY ESTIMATE
OF NON-COMPLIANCE IS 20% TO 30%
OF THE TIME THAT'S WASTE GOING
OUT AS NON-HAZARDOUS WASTE.
THERE'S POTENTIAL IMPACTS AND
PUBLIC HEALTH AND THE
ENVIRONMENT AND THEY STATED IN
THE FEDERAL REGISTER THIS IS A
COMPLIANCE PRIORITY OF THEIRS.
SO THERE'S NO LONGER ROOM FOR
MARGIN OF ERROR.
THEY'RE NOT GOING TO GIVE AS
MUCH AS LEEWAY AS THEY HAVE IN
THE PAST.
AGAIN, DON'T GUESS.
WHEN IN DOWN THE USE LABORATORY
TESTING.
SO FOR GENERATOR KNOWLEDGE, WHAT
DOES THAT MEAN EXACTLY?
IT'S KNOWING WHERE THE WASTE
CAME FROM OR WHAT'S IN THE WASTE
OR THE CHARACTERISTIC OF THE
WASTE.
SOME ARE VERY OBVIOUS.
SOME INDUSTRY FOLKS HAVE WORKED
WITH THE MATERIALS LONG ENOUGH
TO KNOW WHAT THE CHARACTERISTIC
ARE.
AND SAFETY DATA SHEETS CAN BE
USED THOUGH IF THEY'RE WRONG,
EPA IS GOING TO FINE YOU FOR
RELYING ON THE SAFETY DATA SHEET
RATHER THAN GOING AFTER THE
FOLKS THAT MADE THE SAFETY DATA
SHEET.
SO YOU CAN RELY ON THEM TO A
POINT BUT AT YOUR OWN RISK.
AND THERE'S SPECIFIC EPA TESTS
FOR THREE OF THE FOUR.
REACTIVITY IS A LITTLE VAGUE.
THEY GIVE SOME DETAILED
DESCRIPTIONS AND EXAMPLES OF
WHAT MEETS CHARACTERISTIC BUT
WHEN IN DOUBT ASSUME IT'S A
HAZARDOUS WASTE.
AND THEN WHEN DO YOU MAKE A
HAZARDOUS WASTING DETERMINATION?
YOU HAVE TO MAKE IT THE MOMENT
THE WASTE IS GENERATED BEFORE
ANYTHING ELSE, YOU HAVE TO SAY
THIS IS A HAZARDOUS WASTE.
YOU CAN CONTINUE TO KEEP AN EYE
ON THE WASTE AS YOU STORE IT
BECAUSE AND THERE'S REQUIREMENTS
YOU HAVE TO FOLLOW EVEN IF IT'S
NO LONGER HAZARDOUS AND IF THE
SOLVENT DRIED OUT AND IT'S NO
LONGER FLAMMABLE IT GOES TO NON
HAZARDOUS BUT THERE'S STILL
REQUIREMENTS.
AND EVEN SOMETIMES NON-HAZARDOUS
WASTE MAY SEPARATE INTO A
HAZARDOUS AND NON-HAZARDOUS
COMPONENT.
MAKE THE DETERMINATION AT THE
BEGINNING AND TRACK THE WASTE
STORED ON SITE TO MAKE SURE THE
CHARACTERISTIC DON'T CHANGE.
THIS NOTIFICATION IS SO EPA
KEEPS TRACK OF WHO IS STILL IN
BUSINESS OR NOT AND FOR LARGE
QUANTITY GENERATORS THAT I HAVE
TO DO A REPORT EVERY TWO YEARS
SO EPA IS AWARE IF THEY STILL
EXIST.
A LOT OF TIMES HAD EPA
GENERATORS THAT WENT OUT OF
BUSINESS BUT STILL WERE ON THEIR
BOOKS AND THIS DOESN'T TELL YOU
WHAT THE HAZARDOUS IS SO THAT
ONE DOESN'T CUT AND SAY WHETHER
IT'S FLAMMABLE OR TOXIC OR NOT.
THERE'S REQUIREMENTS FOR ALARM
SYSTEMS AND NOW THEY NEED TO BE
EVERYWHERE ON SITE WHERE YOUR
GENERATING HAZARDOUS WASTE.
AND FOR LARGE QUANTITY
GENERATORS THEY NEED A
CONTINGENCY PLANS.
EPA WANTS QUICK REFERENCE GUIDES
WHICH ARE GIVEN OUT TO FIRST
RESPONDERS IN THE AREA THAT'S A
SHORTENED VERSION AND EXECUTIVE
SUMMARY OF THE CONTINGENCY PLAN
TO QUICKLY SEE THE HAZARDS ON
SITE SO WHEN THEY COME TO A FIRE
AT A FACILITY THEY WANT TO BE
AWARE OF WHAT CHEMICAL HAZARDS
ARE PRESENT BEFORE THEY ENTER.
AND HERE'S A QUICK CHECKLIST OF
WHAT THE QUICK REFERENCE GUIDE
NEEDS TO INCLUDE.
SORRY FOR MOVING THROUGH THESE
SLIDES QUICKLY BUT THE SLIDES
CAN BE MADE AVAILABLE IF ANYONE
HAS QUESTIONS.
AND WHAT LARGE QUANTITY
GENERATORS NEED TO INCLUDE, ALL
THE HAZARDOUS WASTE GENERATED
THROUGHOUT THE YEAR NOT JUST THE
MONTHS THEY EXCEED THEIR
CATEGORY AND INCLUDE THE WASTE
FROM A SMALL QUANTITY GENERATOR.
HERE'S A QUICK SUMMARY OF THE
MORE STRINGENT ASPECTS AND THE
REPORTING REQUIREMENTS FROM THE
THANK YOU RULE.
WE'LL TALK ABOUT THE AEROSOL CAN
OF UNIVERSAL WASTE.
IT'S A SPECIAL CATEGORY OF
HAZARDOUS WASTE.
THE TYPES OF MATERIALS ANY
BUSINESS SMALL OFFICE CAN
GENERATE THE IDEA IS GIVE A
REGULATORY BURDEN SO THEY'RE NOT
TREATED AS ONE THAT GIVES LARGE
UNIVERSAL WASTE.
THE IDEA WAS TO PROMOTE
RECYCLING AND THE UNIVERSAL
WASTE INCLUDED BATTERIES,
MERCURY CONTAINING EQUIPMENT AND
VARIOUS TYPES OF LAMPS INCLUDING
FLUORESCENT AND A LOT OF STATES
HAVE THEIR OWN CATEGORIES AND
THESE ARE THE MOST COMMON ONES
WE SEE.
AEROSOL CANS ARE ADDED TO THE
UNIVERSAL WASTE AND REGULATED
LESS STRINGENTLY AND YOU CAN
STORE AS MUCH UNIVERSAL WASTE
AND WON'T AFFECT IF YOU'RE VERY
SMALL, SMALL OR LARGE.
YOU CAN STORE IT ON SITE FOR A
LONGER PERIOD OF TIME UP TO A
YEAR.
YOU CAN MANAGE THE CANS HAS AS
IMPACT OR NON-ENTRY BUT THE CANS
MUST BE RECYCLED TO REMAIN IN
THE UNIVERSAL WASTE CATEGORY BUT
THE CONTENTS NEEDS TO BE
CATEGORIZED AND MANAGED AS
HAZARDOUS WASTE ACCORDINGLY.
ON THE LEFT IS FILTERED TO
COLLECT EMISSIONS.
AND THIS IS A GENERAL HIGH LEVEL
WITH THE HEALTH CARE FACILITIES
AND PHARMACIES SO YOUR LOCAL CVS
AND WALGREENS HAVE A LESS
REGULATORY BURDEN WHEN DEALING
WITH THE PHARMACEUTICALS BECAUSE
THERE ARE SOME PHARMACEUTICALS
SUCH AS THOSE THAT CONTAIN
SILVER IODINE OR CHEMOTHERAPY
DRIVES AND THINGS LIKE THAT.
WHAT THE NEW RULE SAYS INSTEAD
OF MANAGING THOSE AS HAZARDOUS
WASTE, IT'S GIVING LEEWAY
SIMILAR TO UNIVERSAL WASTE.
KEY COMPONENTS WAS ONE AN
IMMEDIATE BAN ON HAZARDOUS WASTE
PHARMACEUTICALS YOU CAN NOW NOT
PUT A PHARMACEUTICAL WASTE DOWN
THE DRAIN.
NICOTINE REPLACEMENT THERAPY AND
NICORRETTE GUM AND SUCH WAS
REGULATED AND THE EPA NO LONGER
CONSIDERS THESE TO BE HAZARDOUS
WASTE AND E CARTRIDGE STILL
CONSIDERED ACUTE HEAT ADVISORY.
HAZARDOUS WASTE.
AND SOME BENEFITS OF THE NEW
RULE I CAN MANAGE THEM ALL THE
SAME AND WHEN PUT IT ON THE
HAZARDOUS WASTE MANIFEST YOU CAN
USE A SIMPLE CODE.
SORRY, THAT'S THE ENDS OF THE
PRESENTATION.
SORRY I WENT KIND OF LONG.
THERE'S NOT A WHOLE LOT OF TIME
FOR QUESTIONS AND ANSWERS AND
THANK YOU FOR GOING THROUGH THAT
AND WILL SLIDES BE MADE
AVAILABLE TO FOLKS?
CAN THEY BE?
>> YES, ALL SLIDES AND
RECORDINGS AVAILABLE TO
ATTENDEES AFTER THE SYMPOSIUM.
AND FIRST OF ALL, THANK YOU VERY
MUCH FOR THIS PRESENTATION AND
NEVER FEEL THE NEED TO APOLOGIZE
FOR GOING A BIT LONG WHEN IT
COMES TO HAZARDOUS WASTE.
I KNOW THE ENTIRE UNIVERSITY OF
REGULATIONS AND WATCH THE INBOX.
NOTHING YET.
WHEN IT COMES TO MANAGING
AEROSOL CANS THAT'S ALWAYS BEEN
A PARTICULAR RECOMMENDATION DO
YOU OFFER WHEN IT COMES TO
MANAGING UNIVERSAL WASTE OR
HAZARDOUS WASTE IN GENERAL
WHATTED ARE THE BIGGEST
CHALLENGES WHEN IT COMES TO NOT
ONLY TEACHING ABOUT THE NEW
IMPROVEMENT RULES BUT HAZARDOUS
WASTE IN GENERAL.
>> FOR HAZARDOUS WASTE THERE'S A
NOT AN AWARENESS REQUIREMENT IN
THE REGULATION.
WE SEE FOLKS HAVE TROUBLE WITH
THE LABELLING.
THERE'S SPECIFIC LABELLING
REQUIREMENTS AND PEOPLE DON'T
OFTEN USE THAT EXACT LANGUAGE
THEY'RE SUPPOSED TO AND THE
STRICT ONE-YEAR LIMIT FOR
UNIVERSAL WASTE FOLKS ALWAYS
SEEM TO FORGET ABOUT THE
BATTERIES.
SOMETIMES WE SEE BATTERIES
TREATED AS UNIVERSAL WASTE THAT
DON'T NEED TO BE.
SOMETIMES DON'T SEE THE
TERMINALS TAPED OFF TO PREVENT
SPARKING.
THAT'S SOME OF WHAT WE SEE.
AS FAR AS THE HAZARDOUS WASTE
IMPROVEMENT RULE THE MOST COMMON
IS NOT PUTTING THE HAZARD OF THE
PECTO GRAMS ON THE CONTAINERS.
PEOPLE FORGET THAT OR PUT THE
WASTE CODE F003 OR SOMETHING
LIKE THAT BUT THOSE DON'T COUNT
BECAUSE TO A LAYMAN NOBODY KNOWS
THE HAZARD THAT REPRESENTS.
I THINK HEARING THE NEXT
PRESENTATION COME IN.
>> I DO HAVE ONE E-MAIL QUESTION
FROM CRYSTAL WEAVER.
THIS PRESENTATION WAS FABULOUS.
>> THANK YOU.
I APPRECIATE THAT.
>> CAN YOU TALK ABOUT THE
TRAINING REQUIREMENT.
>> SURE.
THERE'S TRAINING REQUIRED FOR
THE NEW PHARMACEUTICAL RULE
MAKING SURE FOLKS IN THE
PHARMACEUTICAL ARE PROVIDE WITH
TRAINING LIKE ANYONE ELSE AND
THE REQUIREMENTS DIFFER FROM
LARGE TO SMALL.
SMALL CAN BE DONE WITH A POSTER
BEING PUT UP OR ON THE JOB
TRAINING.
LARGE QUANTITY REQUIRES
SOMETHING MORE FORMAL.
I CAN GIVE A MORE DETAILED
ANSWER LATER ON WITH UNIVERSAL
WASTE IT CAN BE TYNES YOU JUST
HAVE TO MAKE SURE NEW EMPLOYEES
GET IT AT LEAST ONCE.
>> CALIFORNIA IS LAGGING
IMPLEMENTATION.
>> THAT'S ONE OF THE STATES
DRAGGING ITS FEET.
>> THANK YOU AGAIN AND I
APPRECIATE IT AND FORWARD WITH
SHARING THE SLIDES.
I BELIEVE WE'LL HAVE A QUICK
BREAK FOR LUNCH AND SEE YOU ALL
BACK HERE AT 1400 EST FOR THE
NEXT PRESENTATION IN
ENVIRONMENTAL PLANNING.
THANK YOU VERY MUCH.
THIS NEXT PRESENTATION IN THE
PLANNING TRACK FOR TODAY.
WE HAVE DR. HENDRICKSON ON
INTEGRATING SUSTAINABLE
CHEMISTRY PRINCIPLES TO MITIGATE
MISSION IMPACTS AND INCREASE
RESILIENCE SHE'S THE PRINCIPLE
ENVIRONMENTAL ENGINEER AND
SUPPORTS THE OFFICE OF THE
ASSISTANT SECRETARY OF DEFENSE
FOR ENERGY, INSTALLATIONS AND
ENVIRONMENTAL IN THE CHEMICAL
AND MATERIAL RISK MANAGEMENT
PROGRAM.
SHE HAS 15 YEARS OF EXPERIENCE
ADDRESSING ENVIRONMENTAL AND
CHEMICAL AND MENTAL HEALTH RISKS
AN AND HAS HUMAN HEALTH RISK
ASSESSMENT AND HAS BEEN WITH THE
CMR TO IDENTIFY ASSET AND MANAGE
RISK ASSOCIATED WITH CHEMICALS
AND MATERIALS USED BY THE
DEPARTMENT OF DEFENSE.
SHE HAS AN MPH IN ENVIRONMENTAL
HEALTH SCIENCE FROM GEORGE
WASHINGTON UNIVERSITY AND
ENVIRONMENTAL DEGREE FROM LEHIGH
UNIVERSITY.
YOU CAN TURN ON YOUR CAMERA AND
YOU ARE GOOD TO GO.
>> THANK YOU, MARK.
I APOLOGIZE TO EVERYONE WHO
ALREADY LISTENED TO ME SPEAK
TODAY AND WE HAVE A FEW PEOPLE
OUT ON LEAVE AND WE'RE DOING
SOME FILLING IN.
THIS AFTERNOON I'M GOING TO TALK
MORE BROADLY THAN IS DID TH
THISSTHIS
MORNING IN MITIGATING IMPACT AND
INCREASE RESILIENCE.
NEARLY ALL THE GOODS WE USE
EVERY DAY IN THE UNITED STATES
ARE MANUFACTURED OR PRODUCED
USING CHEMICAL PROCESSES AND
PRODUCTS.
MANY RELY ON CHEMISTRY AND
ENERGY, HEALTH, AGRICULTURE,
COMMUNICATIONS AND MORE.
CHEMICAL INNOVATION AND
DEVELOPMENT NEEDS TO CONSIDER
IMPACTS AMONG ALL SECTORS AS
WELL AS BALANCING TE -- THE
TRADE-OFFS BETWEEN THEM.
AND DRILLING IN A LITTLE BIT,
CHEMICALS AND MATERIALS ALSO ARE
VITAL TO PROVIDE THE U.S. AND
OUR ALLIES WITH CAPABILITIES
NEEDED FOR DEFENSE AND TO
MAINTAIN GLOBAL SECURITY.
THE DOD USES CRITICAL
INFRASTRUCTURE, EQUIPMENT,
WEAPON SYSTEMS AND PLATFORMS
MADE FROM AND DEPEND AND
CHEMICALS AND MATERIALS.
THIS COULD BE SOLVENTS IN
BATTERIES, HYDROFLUOROCARBONS IN
BUILDING REFRIGERANTS.
AND FLAME RETARDANTS AND
AIRCRAFTS AND THE LIST GOES ON
AND ON AND MOST EVERYTHING THE
DOD USES HAS CHEMICALS AND
MATERIALS.
AT TO THE DOD THE MISSION OF THE
CHEMICAL AND MATERIAL RISK
MANAGEMENT PROGRAM IS TO PROTECT
READINESS, PEOPLE IN THE
ENVIRONMENT BY IDENTIFYING AND
MANAGING RISKS ASSOCIATED WITH
THE CHEMICALS AND MATERIALS THAT
DOD USES.
WE EVALUATE AND ASSET THE
AVAILABILITY OF ALTERNATIVES AND
TRY TO IDENTIFY AND COMMUNICATE
MANAGEMENT OPTIONS TO MITIGATE
MISSION RISK.
AND THIS LOOK AT FIVE AREAS AND
HOW THEY INTERSECT.
LOOKING AT EMERGING CHEMICALS,
SUSTAINABLE CHEMISTRY, CHEMICAL
SUPPLY CHAIN AND REGULATION.
FOR DOD, EMERGING CHEMICAL OR
ECs ARE DEFINED AS CHEMICALS
RELEVANT TO THE DOD HAVING A
PERCEIVED OR REAL LET IT TO
HUMAN HEALTH OR THE ENVIRONMENT
WITH NEW OR CHANGING TOXICITY OR
REGULATORY STANDARDS THAT ARE A
RESULT OF NEW SCIENCE, DETECTION
CAPABILITIES OR EXPOSURE
PATHWAYS.
OUR PROGRAM USES A THREE-STEP
SCAN-WATCH ACTION PROCESS TO
REVIEW THE SCIENCE AND
REGULATORY ACTION FOR CHEMICALS
OF INTEREST.
IDENTIFY POSSIBLE IMPACTS OF DOD
AND THEN ESTABLISH CORRESPONDING
RISK MITIGATION ACTIONS.
AS PART OF THAT CHEMICAL
REGULATION FOCUS AREA, OUR
PROGRAM LOOKS AT EVOLVING
REGULATORY DRIVERS ACROSS THE
GLOBE.
HERE IN THE U.S. WE PRIMARILY
FOCUS ON THE TOXIC SUBSTANCES
CONTROL BUT IN TERMS OF
SUSTAINABLE CHEMISTRY WE'VE
LOOKED TO THE NATIONAL DEFENSE
AUTHORIZATION ACT REQUIREMENTS
FOR SUSTAINABLE CHEMISTRY.
WE ALSO LOOK ACROSS THE GLOBE IN
EUROPE AT REACH REGULATION AND
THE AMENDMENT TO ADOPT
SUSTAINABLE CHEMISTRY APPROACHES
TO AND ENTITIES ARE STARTING TO
REGULATE BY CLASS OR CATEGORY
OPPOSED TO SINGLE CHEMICALS.
WE'RE LOOKING AT THE PROPOSED
AND WE CAN LOOK AT REACH.
WE CAN LOOK AT HYDRAULIC FLUIDS
AND TRYING TO LOOK AT
REGULATIONS TO DETERMINE WHERE
REGULATIONS MIGHT CREATE THE
MOST PRESSING NEEDS FOR
SUSTAINABLE CHEMICAL
ALTERNATIVES.
AND THIS CAN TAKE TIME SOMETIMES
OVER 20 YEARS.
WHEN OFTEN THE REGULATORY PHASE
OUTS FOR THE CHEMICALS ARE OFTEN
THREE TO FIVE YEARS MAYBE SO
THERE CAN BE THIS GAP BETWEEN A
REGULATORY OR MARKET FADES OUT
OF CHEMICAL AND IT'S CRITICAL
DOD PREPARES TO DEAL WITH
CHEMICAL OBSOLESCENCE AND THE
NEED FOR SUSTAINABLE
ALTERNATIVES BY UNDERTAKING A
MORE STRATEGIC LONG-TERM VIEW OF
MITIGATING RISK FROM CLASS-BASED
REGULATORY CHANGES.
THEY'RE ACCELERATING CHANGE FROM
EXISTING CHEMICALS.
SO IT'S IMPORTANT FOR DOD TO
IMPLEMENT A SUSTAINABLE
CHEMISTRY APPROACH TO ADVANCE
NATIONAL CAPABILITIES AND THE
SUSTAINABILITY IS A NATIONAL
SECURITY OPPORTUNITY AND
SUSTAINABLE CHEMISTRY CAN
PROVIDE DOD WITH ADVANTAGES.
THE FIRST IS THAT SUSTAINABLE
CHEMICALS CAN IMPROVE MISSION
PERFORMANCE.
FOR CERTAIN CHEMISTRIES THERE
CAN BE ADVANTAGES AND BETTER
PERFORMANCE.
THIS CAN ALLOW FOR LESS MATERIAL
TO BE USED AND EASE LOGISTIC CAL
ISSUES IN THE FIELD.
ANOTHER MISSION DRIVER FOR DOD
IS COST AND THIS MAY MEAN USING
AND DISPOSING LESS CHEMICAL OVER
LIFE CYCLE PROVIDING BETTER
VALUE TO DOD OVER TIME.
WE HAVE BEEN HEAVILY FOCUSSED ON
MATERIAL AVAIL ABILITY AND
THERE WAS THE PHASE OUT OF PFAS
OR FROM LIABILITY OR
REGULATIONS.
SOMETIMES THIS SHIFT THE MARKET
OVERSEAS AS WELL.
AND REDUCED DEPENDENCY ON FOSSIL
FUELS AS THEY INCREASE
TRANSPARENCY IN THE SUPPLY CHAIN
IT CAN ADDRESS VULNER ABILITIES
AND THIS FITS IN WELL WITH
EO14081 AND THE DOD BIO
MANUFACTURING STRATEGY, DOD IS
LOOKING TO ADDRESS ISSUES AMONG
CHEMICAL OBSOLESCENCE BY
INVESTING TO DEVELOP MATERIALS
WITH NOVEL PROPERTIES AND SOURCE
MISSION CRITICAL MATERIALS
DOMESTICALLY WITHOUT RELYING ON
FEDERAL SUPPLY CHAINS.
THIS INVESTMENT PROVIDES
OPPORTUNITIES TO DEVELOP A
PIPELINE OF SUSTAINABLE
CHEMICALS WHILE BUILDING
ENDUR
ENDURING ADVANTAGES AND
MODERNIZING IN THE INDUSTRIAL
STRATEGY.
AND FINALLY ON SUSTAINABLE
CHEMISTRY CAN REDUCE EXPOSURE TO
HAZARDOUS MATERIALS.
THIS MEANS LOWER IMPACT OF
PERSONNEL TO OPERATIONS, LAND,
AND REDUCE HEALTH AND
ENVIRONMENTAL IMPACTS OVER ALL.
SO TODAY I WANT TO QUICKLY QUACK
LIEU THE ACTIONS TO INTEGRATE
SUSTAINABLE CHEMISTRY AT DOD.
SOME EFFORTS INCLUDE SUPPORTING
THE EXECUTIVE OFFICE OF THE
PRESIDENT ON SUSTAINABLE
CHEMISTRY STRATEGY PLANNING A
PATH FORWARD FOR ALTERNATIVES
ASSESSMENT AND CONDUCTING THE
LANDSCAPE ASSESSMENT OF CHEMICAL
ACTIVITIES AND IDENTIFYING
OPPORTUNITIES AND LOOKING AT
FEEDSTOCK AND UPDATING POLICY
FOR SUSTAINABLE MANAGEMENT AND
ACQUISITION AND DEVELOPING TOOLS
SUCH AS THE SUSTAINABLE
MATERIALS RECOMMENDATION TOOLS I
TALKED ABOUT EARLIER THIS
MORNING.
AND THERE'S AN AGENCY WORKING
GROUP S AND THERE WERE HEALTH
CONCERNS LOOKING AT ISSUES FOR
EMERGING CHEMICALS ACROSS THE
BOARD, PFAS AND ALSO ADDRESSING
SUSTAINABLE CHEMISTRY.
OUR TEAM HAS BEEN HELPING IN THE
LANDSCAPE ASSESSMENT AND
STRATEGIC PLANNING.
I WANTED TO INCLUDE THE REPORT
BECAUSE IT BRINGS THE FEDERAL
LANDSCAPE FOR SUSTAINABLE
CHEMISTRY RELEASED IN 2023 AND
INCLUDES CONSENSUS DEFINITION
FOR SUSTAINABLE CHEMISTRY WHICH
WAS SOMEWHAT HARD TO FIND BEFORE
THIS.
I'M NOT GOING TO READ IT BECAUSE
IT'S FAIRLY LONG BUT LOOKS TO
CHEMISTRY WITH INTENTIONAL
DESIGN OF CHEMICALS THAT DOESN'T
IMPACT HUMAN HEALTH AND THE
ENVIRONMENT, PROMOTES
CIRCULARITY AND CONTRIBUTES TO
ECONOMIC RESILIENCE.
THE SUSTAINABLE CHEMISTRY
STRATEGY SHOWS A BROAD
MULTI-DISCIPLINARY APPROACH
SIMILAR TO OTHER STRATEGIES AND
STRIVES TO BALANCE
CONSIDERATIONS FOR THE
ENVIRONMENT, SOCIETY AND ECONOMY
AND BALANCE THOSE AREAS.
SUSTAINABLE CHEMISTRY GOES TO
ADOPTION AND REQUIRES THE
HOLISTIC FEDERAL APPROACH
INCLUDING THINGS LIKE
ENVIRONMENTAL JUSTICE, POLLUTION
PREVENTION, SCALABLE SOLUTIONS
OF PRODUCTS AND ALSO TO THE
ECONOMY FOR COMPETITIVENESS AND
NATIONAL SECURITY AND TRADE.
CURRENTLY FINDING ALTERNATIVES
CAN BE A COSTLY AND LENGTHY
PROCESS.
SOCIAL PRESSURES AND REGULATORY
PHASEOUTS CAN LEAD TO REG
REGRETTREG
REGRETTABLE SUBSTITUTIONS AND
IT'S IMPORTANT TO ANALYZE
PERFORMANCE TESTING AND CONDUCT
ALTERNATIVES.
OFTEN OUR DOD INTERESTS OVERLAP
WITH THOSE OF THE DEFENSE
INDUSTRIAL BASED COMPANIES AS
WELL AS OTHER COMPANIES SEEKING
ALTERNATIVES FOR RELATED
CRITICAL SECTORS.
THIS COULD BE FOR HEALTH CARE,
I.T., CHEMICAL MANUFACTURING,
ETCETERA.
WE RECENTLY KICKED OFF AN
ALTERNATIVE CENTERS OF
EXCELLENCE.
THIS WILL HELP STAKEHOLDER
CONDUCT PRE-COMPETITIVE
COLLABORATIVE ASSESSMENTS FOR
CHEM CALVES CONCERN.
-- CHEMICALS OF CONCERN.
IT'S DESIGN TO BE A
PUBLIC-PRIVATE PARTNERSHIP TO
TRANSITION TO SAFER MORE
SUSTAINABLE CHEMICALS AND RIGHT
NOW THE DOD AND THE EPA ARE
PARTNERING TO ESTABLISH THIS
INITIAL CENTER OF EXCELLENCE AND
FOR A PILOT PROJECT.
THE PILOT PROJECT IS MEANT TO BE
A PROOF OF CONCEPT FOCUSSING ON
ONE PARTICULAR CHEMICAL OF
REGULATORY CONCERN AND
IMPORTANCE TO THE DOD MISSION
AND THE PROTRUDE A ROODE MAP --
ROAD MAP FOR EXPOSURE PATHS WAYS
AND POTENTIAL ALTERNATIVES AND
IDENTIFY ANY ADDITIONAL RESEARCH
AND DOD IS IN THE PHASE WHERE
WE'RE SEEKING INPUT FROM
INDUSTRY REGARDING THE CHEMICAL
CHOICE FOR THE CHEMICAL PRODUCT
AND TRYING TOFIDE FUNDING
PARTNERS FOR THE FULL
ASSESSMENT.
THE VALUE IS IT CAN PROVIDE
SHARED ASSESSMENTS, INCREASED
QUALITY AND CONSISTENCY OF
THROUGH A THIRD PARTY, OBJECTIVE
EXEMPTION OF PERFORMANCE AND
BARRIERS FOR COMMERCIALIZATION
AND ADOPTION AND OVER ALL MORE
SUCCESSFUL AND EXPEDITED
MARKETPLACE ADOPTION OF SAFER
ALTERNATIVES.
OUR OFFICE IS IDENTIFYING
REGULATIONS AN TECHNIQUES THAT
DRIVE THE ADOPTION OF
SUSTAINABLE CHEMISTRY.
THIS INCLUDES LOOKING AT
IDENTIFYING DOD REQUIREMENTS AND
CAPABILITIES FOR SUSTAINABLE
CHEMISTRY, IDENTIFYING IMPACTS
ON THE SUPPLY CHAIN AND
INDUSTRIAL BASE, LOOKING
PARTICULARLY AT THE STATE OF THE
STA
SUSTAINABLE CHEMISTRY SECTOR AND
BARRIERS AND OPPORTUNITIES TO
FACILITATE SUSTAINABLE CHEMISTRY
AND BARRIERS ARE LACK OF
ADOPTION AND SCALE-UP
CHALLENGES.
WE HAVE A NUMBER OF ONGOING
EFFORTS TO IMPROVE CONTENT
EXPOSURE.
DOD LACKS CONTENT ON THE GOOD IT
SERVICES AN THIS OPENS UP THE
ABILITY FOR SUPPLY CHAIN
DISRUPTIONS.
THE F35 HAS AROUND 50,000
INDIVIDUAL PARTS ALL OTHER RIGIG
FROM FOREIGN MATERIALS AND THE
FURTHER BACK IT'S HARDER TO
ASSESS THE ORIGIN OF THE RAW
MATERIALS.
WHILE DOD CAN OFTEN IDENTIFY
DIRECT CONSUMABLES LIKE THE
CHEMICALS OF INTEREST THEMSELVES
OR ITEMS CONTAINING THE
CHEMICALS IT'S OFTEN HARDER TO
IDENTIFY ARTICLES THAT MAY BE
MANUFACTURED WITH THE CHEMICAL
INTEREST.
THERE'S CHALLENGES IN ABSTAINING
DATA AND FULL SUPPLY CHAIN
INFORMATION AND GENERALLY THE
EXTENSIVE SCOPE AT DOD.
IT HAS OVER 35,000 VENDORS SO
IT'S DIFFICULT TO GET A GRASP ON
THE ENTIRE SUPPLY CHAIN AND THE
CHEMICAL COMPONENTS IN THE
PURCHASES.
WE'RE WORKING ON POLICY TO
DETERMINE CHEMICAL AND MATERIAL
CONTENT IN WEAPONS SYSTEMS AND
PRODUCTS AN PROCUREMENT WITH
ACCESS TO MISSION CRITICAL USAGE
AND ENCOURAGE SAFE USE BY DOD
PERSONNEL AND ADOPT ALTERNATIVES
WHEN POSSIBLE.
TO IMPLEMENT THE EFFORTS WE'RE
WORKING WITH THE DEFENSE
LOGISTICS AGENCY, THEIR LEADING
TECHNICAL EFFORTS TO STORE
DIGITAL DATA FOR THE FULL
FORMULATION OF PRODUCTS
PURCHASED BY THE DOD, CHEMICALS,
ARTICLES OR WEAPONS.
WE ALSO REQUESTS PARTICIPATION
FOR DISCLOSURE USING XML
STANDARDS AND TO PERFORM PROOF
OF CONCEPT PILOT PROGRAM TO
SUPPORT REQUIREMENT FOR FULL
DISCLOSURE.
DOD CLOSED HERE JANUARY BUT WE
EXTENDED IT THROUGH JANUARY AND
WE'RE STARTING TO TAKE NEXT
STEPS BASED ON THE RFI
RESPONSES.
WE KNOW COLLECTING CHEMICAL DATA
EARLY IS IMPORTANT FROM A COST
PERSPECTIVE HOWEVER, PROGRAM
MANAGERS HAVE A DIFFICULT TASK
ASSESSING SAFETY AND HEALTH RISK
AT MILESTONES WHEN THE CHEMICAL
DATA IS LIMITED.
BEFORE YOU HAVE A LACK OF
CHEMICAL DATA DOESN'T MEAN HAVE
YOU A LACK OF RISK.
DATA COLLECTION IN THE EARLY
PHASE OF ACQUISITION CAN AFFECT
THE SYSTEM LATER ON AND CAN HELP
SAVE COSTS ON HEALTH AND
ENVIRONMENTAL LIABILITIES,
CLEANUP COSTS OR HAZARDOUS WASTE
DISPOSAL OR HEALTH CARE COST FOR
VETERANS.
THE DOD HAS EXISTING HEALTH
CONSIDERATIONS FOR TOXIC
MATERIALS IN ACQUISITION
PROGRAMS.
MILITARY SERVICES HAVE THEIR OWN
STANDARDS AND APPROACHES FOR
IDENTIFYING AND ADDRESSING
HAZARDS.
THIS COULD INCLUDE COLLECTING
THE RIGHT CHEMICAL AND PHYSICAL
TOX DATA EARLY ENOUGH IN THE
PROCESS TO PROACTIVELY SELECT
CHEMICALS OF LESS CONCERN.
DOD ALSO LOOKS TO EXTERNAL
REGULATIONS AND INDUSTRY
STANDARDS SUCH AS THOSE FROM THE
STANDARD TO IDENTIFY AND ADDRESS
HAZARDS OF CHEMICALS AND
MATERIALS.
OUR PROGRAM IS LOOKING TO
LEVERAGE POLICIES AN ADVANCE
CHEMICAL WIDE MANAGEMENT THAT
DRIVES DESIGN IN SUSTAINABLE
CHOICES.
THIS IS BECOMING MORE AND MORE
OF A NECESSITY AS MANY EXISTING
CHEMICALS THAT ARE NEEDED FOR
DOD SYSTEMS ARE AT RISK FOR
OBSOLESCENCE.
AGAIN FROM PHASEOUTS AND
REGULATIONS.
TO MITIGATE IMPACT THERE'S
INCREASING RECOGNITION BUT DOD
HAS TO PROACTIVELY TRANSITION TO
SUSTAINABLE CHEMICAL ALTERNATIVE
TO ENHANCE OUR WEAPON SYSTEM
RESILIENCE, MAINTAIN SAFETY AND
READINESS AND IMPROVE
ENVIRONMENTAL MANAGEMENT.
DOD HAS BEEN UNDERTAKING EFFORTS
FOR YEARS TO EVALUATE AND
TRANSITION TO SUSTAINABLE
CHEMISTRIES AND WE FACE
CHALLENGES ON LACKING CHEMICAL
CONTENT AND SUPPLY CHAIN
TRANSPARENCY INFORMATION COULD
BE RELUCTANCE FROM THE BASE OR
RESOURCING.
DOD WILL NEED TO IDENTIFY
POLICIES AN LESSONS LEARNED
ACROSS THE DEPARTMENT, PERFORM
GAP ANALYSIS AND DEVELOP AN
ENTERPRISE WIDE APPROACH TO
IMPROVE HAZARDOUS AWARENESS AND
INTEGRATION IN THE DOD WEAPONS
SYSTEM AND FURTHER SUPPORT
SUSTAINABLE CHOICES AND LATER ON
IN THE ACQUISITION LIFE CYCLE.
THIS WOULD AVOID COSTS FROM
MISINFORMED CHEMICAL USES AND
EMPOWER COLLABORATION ACROSS THE
DOD.
LESSONS LEARNED FROM PROGRAMS
HERE AND THERE IMPLEMENTING
SAFER, SUSTAINABLE CHOICE.
AND TOOLS TO SUSTAINABLE
CHEMICALS AND I GAVE A PRESENT
IN SMART I WON'T GO INTO DETAIL
HERE BUT THE GOAL IS TO HELP
DECISION MAKERS UNDERSTAND HOW
AND WHERE CHEMICALS ARE USED
WITHIN THE DOD AND THEN LINK
THOSE CHEMICALS AND PROCESSES TO
APPROVED ALTERNATIVES.
WE LOOKED AT HEXAVALENT CHROMIUM
AND SOME OF THE PROCESSES THAT
HAVE ALTERNATIVES.
AND WHICH ONES HAVE ONES
APPROVED AND AVAILABLE FOR DOD
USE.
THAT'S ALL I HAVE TODAY.
I WANTED TO PUT MY CONTACT
INFORMATION UP HERE AS WELL AS
FOR DR. PATRICIA UNDER WOOD THE
DIRECTOR OF THE PROGRAM AND OUR
PROGRAM.
HAPPY TO TAKE QUESTIONS OFFLINE.
THANK YOU.
>> THANK YOU SO MUCH, MS.
HENDRICKSON.
THAT WAS A FANTASTIC
PRESENTATION.
WATCHING THE INBOX FOR
QUESTIONS.
SORRY IF I MISSED IT EARLIER BUT
WHAT'S THE EXPECTED RELEASE DATE
FOR THIS AND WHAT TRAINING WILL
BE AVAILABLE FOR THE NEW SMART
TOOL?
WE'RE AIMING TO HAVE THE
PROTOTYPE UP AND AVAILABLE FOR
SUMMER.
LOOKING FOR A SUMMER RELEASE.
WILL THIS TOOL INCLUDE OR
INCORPORATE SOME OF THE IT GSA
GREEN BUILDING STANDARDS OR
GREEN PROCUREMENT POLICY AND I
KNOW THERE'S THE GREEN PROVING
GROUND POLICY THEY WERE TRYING
TO IMPLEMENT?
>> THAT'S A GOOD POINT.
WE DON'T HAVE THAT IN THERE
RIGHT NOW.
WE'RE SPECIFICALLY LOOKING AT
CERTAIN DOD USES OF CHEMICALS
AND SOMETHING TO KEEP IN MIND AS
WE'RE LOOKING TO INCORPORATE
OTHER SOURCES OF INFORMATION.
>> ONE OTHER QUESTION I CAN
THINK OF MS. HENDRICKSON , HOW
OFTEN IS THE CHEMICAL DATABASE
UPDATED TO REFLECT NEW
REQUIREMENTS OR REGULATIONS FROM
ANY OSHA RULINGS OR FOR THAT
MATTER DOT REGULATIONS?
>> WE COULD BE INTERESTED IN
TAKING DATA FROM ANY CHEMICAL.
WE'VE BEEN FOCUSSING ON A SET OF
SOLVENTS AND MEDALS RIGHT NOW
HEAVILY USED BY DOD BUT COULD
EXPAND THAT TO OTHER CHEMICALS
IN THE FUTURE.
>> AWESOME.
NOT SEEING QUESTIONS IN THE
INBOX AS OF YET.
WELL, THANK YOU AGAIN SO MUCH
FOR THIS. PLEASE THANK
YOUR CO-WORKERS AS WELL.
GOOD AFTERNOON.
MY NAME IS JESSICA LAMPERT AND A
SENIOR STAFF MEMBER AT MATERIAL
AND CHEMICAL RISK MANAGEMENT
TEAM UNDER CONTRACT TO THE
OFFICE OF THE ASSISTANT
SECRETARY OF DEFENSE FOR ENERGY,
INSTALLATIONS AND THE
ENVIRONMENT.
TODAY I WILL WILL BE SPEAKING ON
THE EUROPEAN PROPOSED
RESTRICTION AND POTENTIAL
IMPLICATION FOR THE DEPEND OF
DEFENSE.
-- DEPARTMENT OF DEFENSE.
THERE IS CURRENTLY A GROWING
BODY OF LITERATURE LINKING
EXPOSURE TO VARIOUS TYPES OF
PFAS WITH ADVERSE ENVIRONMENTAL
AND HUMAN HEALTH AFFECTS.
HOWEVER, THE MAJORITY OF
EPIDEMIOLOGIC EVIDENCE HAS
MAINLY FOCUSSED ON THE LEGACY
EFFECTS OF SELECT LONG CHAIN
PFAS CHEMICALS.
THE CHALLENGE IS THAT THE USE
HAVE BECOME IMMESHED IN THE
FABRIC OF OUR DAY TO DAY LIVES
IN WAYS THAT AREN'T EASILY
REPLICABLE.
ARE FOR THE DOD THE THERMAL AND
CHEMICAL PROPERTIES ARE REQUIRED
FOR MISSION READINESS AND
REGULATORS HAVE TO SCULPT
PROPERTIES TO PROTECT HUMAN
HEALTH BY ENSURING THE CORRECT
CHEMICALS ARE ACCURATELY LET
REGULATED.
ON FEBRUARY 7, 2023 THERE WAS A
PROPOSAL UNDER THE EUROPEAN
CHEMICAL RELATION ARE REACH
REGULATION AUTHORIZATION AND
EVALUATION AND RESTRICTION OF
CHEMICALS.
THE PROPOSAL WAS TO RESTRICT THE
MANUFACTURING AND USE OF HIGHLY
DIVERSE PFAS CHEMICALS.
THIS COULD IMPACT THE ROBUSTNESS
AND RESILIENCE OF OUR SUPPLY
CHAIN.
THROUGHOUT THE TALK WELL LOOK AT
CHALLENGES AND THE LACK OF
CHEMICAL AND MATERIAL CONTENT
INFORMATION IN THE VALUE CHAIN
PETING NEED TO SIMULTANEOUSLY
PHASE OUT CHEMICALS THAT MAY
POSE A RISK TO HUMAN HEALTH AND
THE ENVIRONMENT AND THE NEED
INTEREST TO MAINTAIN READINESS
AND INFRASTRUCTURE.
PFAS ARE MOLECULES OF CARBON
FLOWING BOND LINKED IN A CHAIN.
ONE OF THE CHARACTERISTIC
FEATURES IS ITS STRENGTH.
DUE TO THE INTRINSIC ELECTRICITY
OF THE FLUORON AND THE LENGTH OF
THE CARBON FLOURINE CHAIN, THE
BRANCHING STRUCTURE AND
ADDITIONAL OF OTHER CHEMICALS
AND THE FUDGESAL GROUP IMPACTS
PFAS'S CHEMICAL EXPRESSION.
IT OFFERS A UNIQUE SET OF
TECHNICAL CHARACTERISTICS WITH
LOCO EFFICIENTS OF FRICTION AND
THESE MAKE THE CHEMICAL
SUBSTITUTION CHALLENGING.
BEFORE REPLACEMENT FOR PFAS CAN
BE IDENTIFIED, WE MUST FIRST
CLARIFY WHAT IS PFAS.
THIS QUESTION IS MORE
CHALLENGING THAN ONE MIGHT
ANTICIPATE.
DESPITE THE STUDIES AND
REGULATIONS UNDER DEVELOPMENT,
THERE'S STILL NOT A CONSENSUS
DEFINITION OF PFAS AS A CLASS OF
CHEMICALS THE DEFINITION BASED
ON THE 2021 DEFINITION DEFINES
PFAS AS ANY SUBSTANCE THAT
CONTAINS AT LEAST ONE
FLUORONATED METHYL ATOM AND THIS
INCORPORATES 38,000 HIGHLY
DIVERSE CHEMICAL STRUCTURES.
THE FAST MAJORITY HAVE NOT BEEN
STUDIED FOR THEIR IMPACT ON THE
OR HUMAN HEALTH.
CONVERSELY, THE TOXIC SUBSTANCE
CONTROL ACT RELEASED IN 2021 HAD
A QUARTER OF THE CHEMICALS IN
THE PROPOSED REGULATION.
THE PFAS DEFINITION AS CURRENTLY
WRITTEN PROPOSE TO INCLUDE
SUBSTANCES PREVIOUSLY NOT
CONSIDERED TO BE PFAS SUCH AS
PTFE, COMMONLY KNOWN AS TEFLON
OR F GASES USED IN REFRIDGERANT
AND WILL HAVE DISRUPTIONS TO
DOWN STREAM PRODUCTS.
THE RESTRICTION ROAD MAP USES A
GENERIC RISK APPROACH THAT
LEVERAGES CLASSIFICATION
LABELLING TO DRIVE DOWN STREAM
REGULATIONS.
INTENT IS TO LEVERAGE GENERIC
RISK BY UTILIZING EXISTING
HAZARD CATEGORIES AND EXPANDING
THOSE CATEGORIES TO DRIVE DOWN
STREAM REGULATIONS TO IN TURN
LEAD TO SUSTAINABLE PRODUCT
DEVELOPMENT INCLUDING NON-PFAS
ALTERNATIVES.
THE DOSSIER SEEKS TO REGULATE
ALL PFAS APART FROM ACTIVE
INGREDIENTS IN MEDICINE,
PESTICIDES AN BIOCIDAL
SUBSTANCES WITH EQUIVALENT
HAZARD AND RISK BASED ON THE
COMMON CHARACTERISTIC OF BEING
VERY PERSISTENT.
THEY LIST A NUMBER OF EXEMPTION
AND MOST ALLOW FOR AN 18 MONTH
OR VARIED PERIODS AND THERE'S
UNLIMITED TIME DERRIGATIONS.
TO ALLOW FOR A SMOOTH
TRANSITION, THE PROPOSED
RESOLUTION LEAVES ROOM TO
MITIGATE UNWANTED EFFECTS DUE TO
THE SUDDEN EVERYONE AVAILABILITY
OF PRODUCTS, HOWEVER, IT CANNOT
BE PRESUMED THAT USES WITH NO
KNOWN ALTERNATIVES WILL BE
PROVIDED AN EXEMPTION.
THIS MAY BE INSUFFICIENT TO
INCENTIVIZE THE CONTINUED
MANUFACTURING AND THIS HAS
SUPPLY CHAIN IMPLICATIONS AND
CHALLENGE COULD LEAD TO
MISINTERPRETATION BY
STAKEHOLDERS OR THE
DISCONTINUATION OF PFAS
MANUFACTURING.
FOR EXAMPLE, 3M ANNOUNCED IN
DECEMBER OF 2022 IT'S INTENT TO
EXIT PFAS MANUFACTURING BY 2025.
THIS POSES AN IMMEDIATE RISK OF
OBSOLESCENCE FOR PRODUCTS AND
TECHNOLOGY THAT RELY ON 3Ms PFAS
PRODUCT LINES SUCH AS RELIANT
COOLING TECHNOLOGY.
THERE COULD BE AN IMPACT ON
COMPANIES DOING BUSINESS IN,
THROUGH OR EUROPEAN UNION AND
LIKELY AFFECT THE PRODUCT AND
DISTRIBUTION OF CHEMICALS,
MIXTURES OF CHEMICALS AND
MANUFACTURED PRODUCTS.
THIS COULD HAVE A SUBSTANTIAL
IMPACT ON DOD AND DEFENSE
INDUSTRIAL BASE'S ABILITY TO
PROCURE GOODS AND SERVICES AN
CAN IMPACT OPERABILITY WITH
ALLIES.
THERE'S A NUMBER OF POTENTIAL
DEROGATION WITH RELEVANCE
INCLUDING REFRIGERANTS,
AIRCRAFT, HYDRAULIC FLUIDS,
PRECISION CLEANING FLUIDS AND
SEMI CONDUCTORS.
MANY DON'T HAVE A KNOWN
ALTERNATIVE OR THOSE THAT HAVE
BEEN DEVELOPED DO NOT MEET THE
REQUIRED PERFORMANCE
CHARACTERISTICS.
FOR EXAMPLE, UV ADHESIVES
CONTAINING PTFE ARE USED BY THE
SEMICONDUCTOR INDUSTRY AND A
CONSERVATIVE ESTIMATE SUGGESTS
DEVELOPING AN ALTERNATIVE WOULD
REQUIRE MORE THAN 10 YEARS.
THE PROPOSED REACH RESTRICTION
HAS A 10 YEAR DEROGATION PERIOD
FOR THE INDUSTRY THAT WILL
LIKELY NOT BE SUFFICIENT TIME
FOR MANUFACTURERS TO RESEARCH,
DEVELOP AND ADEQUATELY TEST AN
ALTERNATIVE.
WE DON'T ANTICIPATE RELEASE OF
THE FINAL RESTRICTION UNTIL 2025
WHICH MEANS THE RESTRICTION
WOULD BECOME EFFECTIVE SOMEWHERE
BETWEEN 2025 AND 2027 THE DOD
AND THE DEFENSE INDUSTRIAL BASE
IS LEFT WITH A FAIR AMOUNT OF
REGULATORY UNCERTAINTY FOR
SEVERAL YEARS.
MANY TECHNOLOGIES SUPPORTING THE
PLATFORMS CONTAINING PFAS OR
REQUIRED PFAS PRODUCTS IN THEIR
MANUFACTURE FROM CORROSION
PREVENTION TO DEGREESING PFAS IN
ITS FORMS CONTINUE TO PROVIDE
VITAL FUNCTIONS IN THE SUPPLY
CHAIN.
THE DOD RECOGNIZES THE
IMPORTANCE OF SUBSTITUTING PFAS
WHERE POSSIBLE HOWEVER, THERE
ARE SIGNIFICANT TECHNOLOGICAL
CHALLENGES TO BE OVERCOME DUE TO
THE CRITICAL FUNCTIONALITY THAT
IFS PROVIDES THROUGHOUT THE
SUPPLY CHAIN.
PFAS PREVENTS IN GASEOUS FORMS
AND NEED TO WORK TO ACHIEVE
RESULTS.
FOR EXAMPLE, PFAS CLEANING
FLUIDS AND LUBRICANTS CAN HAVE
DEPENDENCIES ON ONE ANOTHER.
IN THIS EXAMPLE, ALL PFAS
CONTAINING LUBRICANTS MUST BE
SUBSTANCES BEFORE THE PFAS
CLEANING FLUIDS CAN BE REPLACED
BY A NON-PFAS ALTERNATIVE.
IN THIS CASE REMOVING PFAS FROM
CERTAIN PROCESSES CAN RESULT IN
DETERIORATION OF PERFORMANCE
LEADING TO SAFETY HAZARDS.
IT'S CONTINUE THE DOD CONTINUE
TO PROVIDE SERVICE MEMBERS WITH
TECHNOLOGY MEETING THE
PERFORMANCE SPECIFICATIONS AND
ENSURES THE EQUIPMENT IS ABLE TO
PERFORM SAFELY AND RELIABLY IN
THE OFTEN HARSH ENVIRONMENTAL
CONDITIONS IN WHICH THEY MUST
OPERATE.
NOT ONLY ARE THEY CRITICAL TO
THE MISSION SUCCESS AND
READINESS BUT CRITICAL
INFRASTRUCTURE AND INFORMATION
TECHNOLOGY AND CRITICAL
MANUFACTURING, HEALTH CARE,
RENEWABLE ENERGY AND
TRANSPORTATION.
THE INFRASTRUCTURE PROVIDES
SERVICES THAT UNDER PIN AMERICAN
SOCIETY THE PRESIDENTIAL POLICY
ADVANCES A NATIONAL UNITY OF
EFFORT TO STRENGTHEN AND
MAINTAIN SECURE FUDGING AND
RESILIENT CRITICAL
INFRASTRUCTURE.
MANY OF WHICH REQUIRE PFAS IN
SOME ESSENTIAL WAY.
DOD IS RELIANT ON THE PROPERTIES
TO ACHIEVE RESILIENCE.
THE EFFORTS TIE TOO THE NATIONAL
CLIMATE CHANGE STRATEGY AND ARE
ESSENTIAL FOR PROMOTING
RENEWABLE ENERGY AND A GREEN
ECONOMY.
THIS CRITICAL INFRASTRUCTURE
MUST BE SECURE AND ABLE TO
WITHSTAND AND RAPIDLY RECOVER
FROM ALL HAZARDS.
DOD CONTINUES TO ELEVATE CLIMATE
CHANGE AS A NATIONAL SECURITY
PRIORITY INTEGRATING CLIMATE
CONSIDERATIONS INTO THE
STRATEGIES AND PARTNER
ENGAGEMENTS.
IN 2023 ALONE THEY HAD RENEWABLE
PROJECTS AMOUNTING TO 227.
PFAS AS IT IS DEFINED BY THE
PROPOSED REACH RESTRICT IS
CURRENTLY EMPLOYED IN LITHIUM
BATTERIES, TURBINES AND SOLAR
PANELS.
THEY PROVIDE FUEL CELLS AND
BARRIERS THAT PROVIDE
WEATHERABILITY AND PANELS AND
FLUORONATED CHEMICALS ARE USED
IN MANY PRODUCTS AND IT'S
COMPLICATED AND TO ALIGN WITH
THE WHITE HOUSE REDIRECTIVE --
DIRECTIVE THE DOD HAS DOUBLES
DOWN ON EFFORTS TO INSTALL
RENEWABLE ENERGY INFRASTRUCTURE
AT ITS FACILITIES.
JANUARY 24 OF THIS YEAR THE DOD
ANNOUNCED IT WILL INSTALL SOLAR
PANELS IN THE PENTAGON AND IT'S
NOT ALONE.
IT'S ONE OF 31 GOVERNMENT SITES
THAT HAVE RECEIVED $104 MILLION
IN ENERGY DEPARTMENT GRANTS
EXPECTED TO DOUBLE THE AMOUNT OF
CARBON FREE ELECTRICITY AT
FEDERAL FACILITIES AND CREATE A
27 MEGAWATTS OF CLEAN ENERGY.
THESE EFFORTS ARE PART OF A
LARGER INITIATIVE TO LEVERAGE
FEDERAL SPENDING TO ADDRESS
CLIMATE CHANGE RESPONSIBILITIES
BY PROMOTING RENEWABLE GREEN
INFRASTRUCTURE AND SOURCES AND
RESILIENCE CIRCULAR ECONOMY.
DOD HAS TAKEN ACTION TO
TRANSITION IT'S CARBON FREE
ENERGY USE BY 2030.
THE DOD HAS MADE PROGRESS IN
CLIMATE RESILIENCE AND
ENVIRONMENTAL REMEDIATION.
TO MEET THESE GOALS THE DOD IS
INVESTING IN MICROGRID
TECHNOLOGY AND ELECTRICAL
VEHICLES TO SUPPORT MISSION
REQUIREMENTS.
HYBRID TECHNOLOGY THAT LEVERAGES
AUXILIARY BATTERY POWER AND
MICROGRIDS TO PROVIDE STABILITY
OF OPERATION IN INSTALLATIONS AS
WELL AS IN THE FIELD AND MANY
MORE.
THE DOD IS CURRENTLY WORKING TO
ACHIEVE TWO FEDERALLY MANDATED
RENEWABLE ENERGY GOALS.
IT'S MAKING GREAT STRIDES
TOWARDS MEETING THESE
OBJECTIVES.
AS ILLUSTRATED IN THE FIGURE,
THE DOD HAS MADE STEADY PROGRESS
TOWARDS ACHIEVING ITS GOAL OF
ACQUIRING ITS PORTFOLIO FROM
RENEWABLE ENERGY RESOURCES.
WHILE THE GOAL OF THE PFAS
PROPOSAL IS TO REDUCE, RESTRICT
AND EVENTUALLY ELIMB FATE NATE
THE USE-- EELIMINATE OF PFAS,
SOME DON'T HAVE ALTERNATIVES AND
FOR PRODUCTS THAT DO, THEY MAY
NOT BE DROP-IN REPLACEMENTS.
ALTERNATIVE DESIGN CHANGE MAY BE
REQUIRED.
SOLUTIONS MAY NOT BE BACKWARDS
COMPATIBLE TO THE DESIGNS
EQUIPMENT ALREADY IN SERVICE.
TECHNICAL REQUIREMENTS MAY
REQUIRE TESTING AND DEVELOPMENT.
THIS IS ESPECIALLY TRUE FOR
COMPONENTS AND SUBSTANCES USED
IN DOD EQUIPMENT THAT OFTEN
REQUIRE BESPOKE PARTS AND HIGHER
DEGREES OF SCRUTINY PRIOR TO
BEING QUALIFIED.
THE TIME LINE TO QUALIFY MAY BE
LENGTHY AND IN MANY CASES
UNKNOWN.
WE FACE A POTENTIAL CHEMICAL
DISCONTINUATION GAP BETWEEN THE
TIME LINE FOR THE PROPOSED
CHEMICAL REGULATIONS AND TIME
REQUIRED TO REENGINEER PRODUCTS
WE CURRENTLY RELY ON EVERY DAY.
THE E.U.'S PROPOSED REGULATION
HAS THE POTENTIAL TO IMPACT AN
UNPRECEDENTED NUMBER OF DOWN
STREAM PRODUCTS WHICH WOULD
LIKELY RESULT IN A SCALE DOWN OF
PFAS USED IN SECTORS OF
STRATEGIC IMPORTANCE TO THE DOD.
THAT BEING SAID, WE MUST STRIKE
THE RIGHT BALANCE BETWEEN FUTURE
OBLIGATIONS AND ENSURING OUR
INFRASTRUCTURE IS SECURE AND
RESILIENT AND RESTRICTING THE
USE OF POTENTIALLY HAZARDOUS
CHEMICALS.
WHILE THE FIRST PRIORITY IS TO
SEEK NON-TOXIC PFAS-FREE
ALTERNATIVES AND PFAS CONTINUES
TO BE NECESSARY AND SOME
SUBSTITUTIONS ARE NOT ADEQUATE
AN IT'S IMPORTANT TO CONSIDER
MANUFACTURING PROCESSES AND
RECOGNIZE THE DOD SEEKS TO
ADVANCE THESE PROCESSES TO
PROTECT HUMAN HEALTH.
WITH THAT I'LL OPEN THE FLOOR TO
QUESTIONS.
THANK YOU FOR YOUR TIME.
>> THANK YOU FOR THE
PRESENTATION.
AGAIN, I AM TRULY SORRY FOR
SCREWING UP THE SCHEDULE LIKE
THAT.
I'M SURE THERE'S PLENTY OF
QUESTIONS.
I CAN THINK OF A COUPLE RIGHT
NOW.
WHAT STIPULATIONS DO WE HAVE IN
PLACE TO ENSURE ANY NEW
SUBSTITUTE FOR CHEMICALS FOR
PFAS FOLLOW THE GREEN
PROCUREMENT GUIDELINES SET FORTH
BY BOTH THE DOD AND DSA AND HOW
CAN WE ENSURE THEY DON'T HAVE
THE TRANSPORTATION THE
TRANSPORTATION DON'T HAVE AN
EQUAL OR GREATER HAVE A
MANAGEABLE CARBON FOOTPRINT.
>> I'M NOT SURE I UNDERSTAND
YOUR QUESTION.
I'M SORRY?
>> I'M NOT VERY COHERENT.
WHAT DO WE HAVE IN PLACE TO
ENSURE SUBSTITUTE CHEMICAL WOULD
FULFILL THE ROLE PFAS PLAYS
DON'T REQUIRE SIGNIFICANT
GREENHOUSE GAS EMISSION IN THEIR
CREATION AND TRANSPORTATION.
>> THERE'S FOLKS WHO HAVE
GREATER KNOWLEDGE BASED ON THIS
TOPIC I BELIEVE THE CHALLENGE
THAT WE FACE IS NOT SO MUCH THE
ALTERNATIVES DO OR DO NOT HAVE
GREATER GREEN HOUSE GAS
EMISSIONS BUT THE CURRENT
TECHNOLOGY WE'RE USING TO COMBAT
GREEN HOUSE GAS EMISSIONS IE THE
USE OF RENEWABLE TECHNOLOGIES
AND THE USE OF ELECTRIC
BATTERIES AND THAT TYPE OF THING
DON'T HAVE EXISTING ALTERNATIVES
THAT MEET OUR SPECIFICATION AND
REQUIREMENTS FOR MISSION
READINESS, AS A RESULT, SINCE
WE'RE TRYING TO CHEW GUM AND
TALK AT THE SAME TIME FOR LACK
OF A BETTER TERM THE FACT IS
THAT IF WE WERE TO HAVE A
DEROGATION THAT WOULD IMPEDE THE
ACCESS TO TO THIS TECHNOLOGY IT
WOULD IMPANTH OUR ABILITY --
IMPACT OUR ABILITY THE
INITIATIVES AND COMBAT
INDIRECTLY AT THE TIME.
THERE'S ALTERNATIVES BEING
CREATED ALL THE TIME AND WE VERY
MUCH HOPE THOSE WILL BE ABLE TO
BE IMPLEMENTED BUT THE TIME LINE
REQUIRED TO DO SO AND I DON'T IF
I ANSWERED YOUR QUESTION.
>> THAT'S VERY HELPFUL.
CAN YOU PROVIDE EXAMPLES HOW WE
ALREADY PROVIDED PFAS SUBSTANCES
AT THE DOD BRANCH?
>> THERE'S BEEN A GREAT STRIDE
IN THE AFFF MOVEMENT TO REPLACE
WITH ALTERNATIVES.
AND A MOONSHOT EFFORT ON THE
PART OF THE DOD TO CREATE FIRE
FIGHTING THAT HAS BEEN ABLE TO
MEET THE SPECIFICATION TO
PROVIDE THE SERVICE MEMBERS AND
CONTINUING TO NOT HAVE ISSUES
WITH FLUORONATING THE
ENVIRONMENT AND THAT'S A POSTER
CHILD FOR AN INITIATIVE THAT WAS
AN ENVIRONMENT BOTH AND ENSURE
THE SERVICE MEMBERS ARE
PROTECTED.
>> THANK YOU.
A QUESTION.
WHAT STRATEGIES DO E.U. AND NATO
MILITARY HAVE TO COMPLY WITH THE
PROPOSED RESTRICTIONS?
>> THAT'S UNDER DEVELOPMENT.
AS THEY'VE NOT BEEN PUT INTO
PLACE THERE'S NO POLICIES
DIRECTLY REFLECTIVE OF THE
RESTRICTION.
ONCE IT GOES INTO PLACE, THAT
WOULD CHANGE THAT SITUATION.
>> I DO APOLOGIZE I HAVE A
MEETING AT 3:10.
>> ONE QUICK QUESTION, IS THERE
A PHASEOUT SCHEDULE?
>> THEY HAVE THE DEROGATION
SCHEDULE AND WE HAVE
SUPPLEMENTAL MATERIALS.
THIS IS ON THEIR WEBSITE SO IF
YOU WANT TO REVIEW IT, I DO
RECOMMEND DOWNLOADING IT.
THE LINK IS HERE.
THEY HAVE A FAIRLY WELL
ORGANIZED SECTORIAL DEROGATION
SCHEDULE ASSUMING THE REGULATION
IS UNCHANGED BETWEEN NOW AND
WHEN ITS RELEASE DATE IS.
AND WHETHER THERE'S A PROPOSED
ALTERNATIVE UNDER THEIR
KNOWLEDGE BASE BUT THEY DID
RECEIVE AN UNPRECEDENTED NUMBER
OF COMMENTS THAT MAY RESULT IN A
SLOWER ROLL OUT THEIR
IMPLEMENTATION BECAUSE OF THE
COMMENTS RECEIVED AND THAT IS
SOMETHING THAT WILL PROBABLY
CHANGE OVER TIME.
>> EXCELLENT.
WE
WELL, I DON'T WANT TO KEEP YOU
PAST YOUR MEETING YOU HAVE.
THANK YOU FOR YOUR INCREDIBLE
PRESENTATION AND THANK YOU
CO-WORKERS FOR THEIR
CONTRIBUTIONS AS WELL.
>> THANK YOU VERY MUCH.
>> HOPE TO SEE YOU TOMORROW.
>> THANK YOU.
BYE.
>> THANK YOU FOR STAYING WITH US
FOR THE LAST TRACK.
TODD BRAUN IS THE CHAIR OF THE
ADMINISTRATIVE OFFICER AND
OVERSEES OPERATION AND
MAINTENANCE OF A CAMPUS AND
157,000 SQUARE FEET INDOOR
FIRING RANGE AND TRAINING TRACT
AND VEHICLE FLEET.
HE SERVED THE WATER PROGRAM
MANAGER AT FORT BASE ANDREWS,
MARYLAND.
HE SERVED IN THE AIR FORCE.
AND ERIC RUFFER MANAGES THE
ENVIRONMENTAL HEALTH AND SAFETY
PROGRAM FOR PERMITS, PLANS AN
REPORTS AND CAME TO FLETC FROM
WHERE HE SERVED AND SPENT 10
YEARS IN THE PRIVATE SECTOR.
SO, IF YOU ALL ARE READY,
WITHOUT FURTHER ADO, TAKE IT
AWAY.
>> THANK YOU.
AGAIN, MY NAME IS TODD BRAUN.
I'M THE ADMINISTRATIVE OFFICER
AT THE FEDERAL TRAINING CENTER
DELIVERY POINT IN MARYLAND.
AS MARK SAID WE ALSO HAVE
MR. ERIC RUFFER OUR
ENVIRONMENTAL PROTECTION
SPECIALIST.
THIS AFTERNOON WE'LL PRESENT OUR
PROCESS THAT WE UNDERTOOK IN
2022 AND '23 TO DEVELOP PLANS TO
REHABILITATE OUR INFRASTRUCTURE
USING AN ASSET MANAGEMENT
APPROACH TO STORMO -- STORM
WATER INFRASTRUCTURE.
WE BELIEVE IT TO BE UTILITY LIKE
GAS, WATER, SEWER AND ELECTRIC
AND HAS TO BE OPERATED AND
MAINTAINED LIKE ANY OTHER
UTILITY.
THAT WASN'T THE MIND SET MANY
YEARS.
THE STORM WATER INFRASTRUCTURE
WAS CONSIDERED TO BE OUT IN THE
FIELD.
SO IT WASN'T REALLY MANAGED OR
MAINTAINED VERY WELL.
NOW, BECAUSE OF YOUR
REQUIREMENTS GENERATE THE
MARYLAND DEPARTMENT OF
ENVIRONMENT WE HAVE TO LOOK AT
REGULATORY REQUIREMENTS.
A LOT OF THAT IS BECAUSE OF THE
REGULATORY REQUIREMENT TO MEET
DISCHARGES AND STOP THE
POLLUTION OF THE CHESAPEAKE BAY.
DWE
WE DID A FULL ASSESSMENT OF THE
STORM WATER AND ASSET MANAGEMENT
AND THERE'S ISO STANDARDS WHERE
YOU LOOK AT THE PROB ABIL ABILI
FAILURE WE USE THE SCORE AND YOU
EVALUATE THE RISK AND WEIGHT IT
AND WE USE THE ANALYTICAL
HIERARCHY PROCESS WE'LL TALK
ABOUT TO PUT TOGETHER A RISK
FRAMEWORK SO WE OBJECTIVELY
ASSIST RISK AND PRIORITIZE OUR
REHABILITATION PROGRAM.
AGAIN, THE OUTCOME HERE OF WHAT
WE GOT AND WHAT MAY BENEFIT YOU
IS A STANDARDIZED RISK FRAMEWORK
THAT ALLOWS PRIORITIZATION OF
YOUR MAINTENANCE ACTIVITIES AND
REPAIR PROJECTS.
THIS IS AN OVERVIEW OF WHAT
WE'LL DISCUSS TODAY.
AS YOU CAN SEE, THE TRAIN OVER
125 FEDERAL, STATE AND LOCAL
AGENCIES AROUND THE COUNTRY AND
EVEN THE WORLD.
WE HAVE INTERNATIONAL TRAINING
DIVISION THAT GOES TO DIFFERENT
COUNTRIES TO ASSIST WITH LAW
ENFORCEMENT ACTIVITIES.
THE LATEST WE HAVE COMPLETE
NUMBERS AND 90,000 GRADUATES IN
FY22.
THERE WERE FOUR DELIVERY POINTS
AND ONE IN GEORGE OUTSIDE
BRUNSWICK, VERY LARGE FACILITY
ABOUT 1600 ACRES AND THERE'S
ARTESIA AND MARYLAND.
YOU SEE THE TOTE ACREAGE AND
CHELTENHAM IS A WEEK DAY
OPERATION AND HAVE NO DORM TRIES
OR DINING FACILITIES.
WE JUST HANDLE COMMUTER
STUDENTS.
U.S. CAPITAL POLICE HAS A LARGE
TRAINING CENTER AND WE SUPPORT
THE DISTRICT OF COLUMBIA AND
METROPOLITAN POLICE DEPARTMENT
AND THEY TRAIN FOLKS.
CHELTENHAM IS SMALLER THAN THE
OTHERS.
WE HAVE ABOUT 371 ACRES.
THERE'S 49 BUILDINGS THE MEDIAN
AGE IN OUR BUILDINGS IS 55 YEARS
OLD AND 26 OF THE 49 WERE BUILT
BEFORE 1970.
OF COURSE A LOT OF THE
INFRASTRUCTURE PREDATES 1970 AND
WILL DEVELOP MORE THAT WAS
ACQUIRED FROM THE DEPARTMENT OF
ENERGY.
YOU CAN SEE WE'RE FORTUNATE IN
WE HAVE AERIAL PHOTOGRAPHY GOING
BACK TO THE 1930s.
IT WAS PURCHASED FROM A FARMER
FAMILY AND YOU SEE HOW IT'S
EVOLVED OVER THE YEARS.
SOME OF SURFACE FEATURES HAVE
CHANGED BUT THE MAJORITY OF THE
FOOT FRI PRINT IS THE SAME AND T
THE DEVELOPMENT WAS IN THE '30s,
'40s AND '50s AND OF COURSE THEY
WE HAVE WELL WATER HERE AT ONE
POINT HAD A COMBINED SEWER
SYSTEM WHICH FED INTO A SULA
GOON AND IN THE '70 THEY
CONNECTED IT AND IT WAS PIPED
DOWN AND THEY SEPARATED OUT MOST
OF THE STORM WATER.
WE'VE DONE THE REST OVER THE
LAST FEW YEARS.
WE HAVE ABOUT 12,000 LINEAR FEET
OF STORM WATER UNDERGROUND SEWER
LINES DATING BACK TO WHEN THE
FACILITY WITH US BUILT AND WE'VE
DONE WORK BUT THERE'S STILL
MAJOR DEFICIENCIES.
AND YOU'LL SEE HERE ARE
REGULATORY DRIVERS THE MAIN
REASON WHY WE'RE DOING THIS.
WE HAVE THE MARYLAND DEPARTMENT
OF THE ENVIRONMENT HAS A PERMIT
FOR DISCHARGES FROM STATE AND
FEDERAL AGENCIES WE CALL OUR MS4
PERMIT.
AND THEY'RE REQUIRING US TO
OPERATE AND MAINTAIN AND REPAIR
OR CONVEYANCES AN BEST
MANAGEMENT PRACTICES AND
CONTROLS TO ACHIEVE COMPLIANCE
WITH THE PERMIT.
FROM A POLLUTION POINT OF VIEW
IT HELPS US TO STOP POLLUTANTS
AND CONTAMINANTS FROM GETTING
INTO THE STORM SYSTEM.
BUT ALSO WE LOOK AT THE CLIMATE
CHANGE AND FACILITY RESILIENCE
WITH THE SYSTEM BEING AS
DEGRADED AS IT IS THE RESULT IS
INCREASED FLOODING, WATER
INTRUSION IN BUILDINGS, IMPACTS
ON BUILDINGS, HARDSCAPES AND
SIDEWALKS.
>> HERE'S THE OVER ALL PROCESS
IDENTIFIED FOR THE EFFORT.
WE KNEW THE MAJOR TASK WE WANTED
TO ACCOMPLISH BUT HAD TO TAKE A
DEEPER LOOK TO DETERMINE THE
INDIVIDUAL STEPS THAT WOULD BE
REQUIRED TO GET TO OUR
OBJECTIVE.
WE ALSO HAD TO IDENTIFY WHAT THE
END PRODUCT WOULD LOOK LIKE AND
WHAT FORM IT WOULD BE THE MOST
EFFICIENT AND EFFECTIVE.
A SINGLE CONTRACT WAS
ACCOMPLISHED AND THIS PROVIDED
CONTINUITY THROUGH ALL PHASES OF
THE PROCESS.
THE FIRST STEP WAS TO KNOW WHAT
WE HAD LIKE MANY GOVERNMENT
FACILITIES, OUR FACILITIES
HAVING BEEN AROUND SINCE THE
1940s CHANGED HANDS.
WHILE SOME OF THE RECORDS ALONG
THE WAY AND OUR RECORD INVENTORY
IS VASTLY INCOMPLETE SO WE KNEW
A FULL AUDIT OF OUR STORM WATER
ASSETS WAS REQUIRED AND STORM
PLANS AND PREVIOUS SURVEY
INFORMATION IN HARD COPY AND
DATABASES.
WHILE WE HAD A GOOD AMOUNT OF
INFORMATION AVAILABLE IN AUTO
CAD THE PLAN IS TO MOVE TO
G.I.S.
WE TOOK THE OPPORTUNITY TO
CREATE A G.I.S. DATABASE FOR OUR
STORM WATER INFRASTRUCTURE.
IN BUILDING THE DATABASE CREATED
CAPABILITIES IN THE FOLLOWING
PHASE OF THE PROJECT.
AFTER THE DATABASE WAS CREATED,
WE WERE ABLE TO GET GOING ON THE
ACTUAL CONDITION ASSESSMENT.
THE ASSESSMENT WAS PERFORMED IN
ACCORDANCE WITH NASCO STANDARDS
AND VISUAL ASSESSMENT AND THE
ASSET FORMS WERE DEVELOPED USING
GIS WITHIN ESRI FIELD MAPS AND
THIS ALLOWED FOR SEAMLESS DATA
COLLECTION AND PROCESSING.
I'LL NOTE OBSERVATIONS AND MEDIA
WERE ABLE TO BE COLLECTED
DIRECTLY IN THE APPLICATION.
IT IS IMPORTANT TO NOTE THIS WAS
A TOP SIDE INSPECTION ONLY.
NO CCTV WAS PERFORMED.
THE FIELD TEAM DID LOWER OUR
CAMERA POLE GRADE STRUCTURES BUT
YOU CAN ONLY OBSERVE THE FIRST
THREE OR FOUR FEET OF THE
HORIZONTAL PIPES AS THEY WERE
TORCHED.
CCTV WAS ONE OF THE
RECOMMENDATIONS MADE DEPENDENT
ON THE CONDITIONS OBSERVED AND
THE PHOTOGRAPHS AND OTHER
INFORMATION OBTAINED DURING THE
DESK TOP AUDIT.
ANOTHER NOTE IS THE STRUCTURAL
BEST MANAGEMENT PRACTICES WERE
NOT INCLUDED IN THE ASSESSMENT.
WE DO CONSIDER THEM TO BE PART
OF OUR STORM WATER
INFRASTRUCTURE BUT UNDER THE
MARYLAND MS4 PERMIT IT'S RIVERED
TO INSPECT AND MAINTAIN THE BMPs
ON A REGULAR BASIS SO AS NOT TO
INCLUDE THEM IN THE EFFORT.
THE END PRODUCT WAS A FULL
REPORT THAT PROVIDED
OBSERVATIONS AND EACH HAS A
REPORT IN EXAMPLES ON THE RIGHT
SIDE OF THE SLIDE.
ONCE THE DEFICIENCIES WERE
IDENTIFIED WE NEED TO KNOW HOW
TO PRIORITIZE OUR TIME AND
THAT'S WHERE RISK COMES INTO
PLAY.
THE THE COMBINATION OF TWO
FACTORS.
THE PROBABILITY OF FAILURE AND
THE CONSEQUENCE OF FAILURE.
WHILE THESE TWO FACTORS HAVE
HISTORICALLY BEEN USED TO ASSIGN
PRIORITY AND TYPICALLY THERE'S A
LARGE DEGREE OF SUBJECTIVITY IN
THE DECISION MAKING PROCESS AND
THAT'S WHAT WE WERE TRYING TO
AVID HERE.
WHERE WE WANTED TO GET TO WAS A
STANDARDIZED JUSTIFIABLE
FRAMEWORK TO ASSESS ALL RISK
ASSETS.
THE FIRST STEP IN DEVELOPING THE
FRAMEWORK WAS TO DEVELOP TE
CRITERIA.
THE PROBABILITY OF FAILURE OR
HOW LIKELY IT IS AN ASSET WILL
FAIL IS MORE STRAIGHTFORWARD
THAN THE CONSEQUENCE IN FAILURE.
IN OUR SCENARIO THERE WERE TWO
FACTORS.
THE ASSET CONDITION, DETERMINED
DURING THE CONDITION ASSESSMENT
AND ASSET MAINTENANCE AND THIS
LOOKED AT HOW MUCH WORK AN ASSET
REQUIRED TO RETURN TO GOOD
WORKING CONDITION.
IT ALSO LOOKED AT THE TIME FRAME
IN WHICH THE MAINTENANCE NEEDED
TON ACCOMPLISHED.
CAN IT BE DELAYED OR WAS FAILURE
OF THE ASSET IMMINENT.
FURTHERMORE, EACH FACTOR CAN
HAVE EQUAL WEIGHTING MAKE IT
EASIER TO ASSESS THE PROBABILITY
FAILURE SCORE AND THE POF SCORES
WERE ESTABLISHED.
THIS TABLE DEPICTS THE SCORES BY
ASSET TYPE AND WHAT THIS TABLE
DOES NOT SHOW THE BMPs WE CLAIM
UNDER THE PERMIT.
WHILE WE ARE AN ORDERLY
FACILITY, WE HAVE BEEN ABLE TO
IMPLEMENT A COMPREHENSIVE STORM
WATER MAINTENANCE PROGRAM WHICH
HAS HELPED OUR INFRASTRUCTURE.
THE MAJORITY OF OUR ASSETS WERE
ON THE LOWER END OF THE SCORING.
THIS IS PARTLY SKEWED BECAUSE OF
OUR MAINTENANCE PROGRAM WE
IMPLEMENTED AND ALSO THE FACT
THAT THE HORIZONTAL PIPES
RECEIVED SCORES OF ZERO BECAUSE
CERTAIN DATA WAS NOT ABLE TO BE
OBTAINED.
THE NEXT STEP WAS TO DEVELOP A
CONSEQUENCE OF FAILURE CRITERIA.
THIS STEP IS MORE INVOLVED AS
THE CRITERIA CAN SPAN A NUMBER
OF DIFFERENT CATEGORIES SUCH AS
THE MISSION, ECONOMIC IMPACTS
AND PUBLIC PERCEPTION AND
COMMUNITY IMPACT AND
ENVIRONMENTAL.
EACH CAN HAVE DIFFERENT FACTORS.
FOR EXAMPLE, THE ENVIRONMENTAL
CATEGORY CAN INCLUDE REGULATORY
COMPLIANCE, MEANING OF A PERMIT
OR RESOLUTION REQUIREMENT,
PROXIMITY TIE SENSITIVE AREA,
LIKELIHOOD OF FLOODING AND THE
LIKELIHOOD OF POTENTIAL
ENVIRONMENTAL LIABILITY.
THERE'S ALSO DIFFERENT METHODS
TO WEIGH THE FACTORS.
WE'RE DEVELOPING THE CONSEQUENCE
OF FAILURE, YOU WANT TO LACK AT
THE CURRENT MISSION, GOALS AND
COMMITMENT AND UNDERSTAND THE
POLICIES IN PLACE THAT DRIVE
YOUR OPERATION.
THE FAILURE CRITERIA WITH
DEFINITIONS FOR CRITERIA ITSELF
AND THE PROPOSED SCORING.
GET INPUT FROM THE STAKEHOLDERS
WITHIN YOUR AGENCY.
FINALLY YOU, WANT TO GET THE
SIGN-OFF FROM LEADERSHIP AS
THEY'LL BE THE BACKBONE FOR
GETTING THIS IMPLEMENTED.
AND HERE'S THE CONSEQUENCE OF
FAILURE FOR THE CHELTENHAM DTD.
WE SPOKE WITH MANY DIFFERENT
BRANCHES AT TE TRAINING DELIVERY
POINT INCLUDING FACILITY
MAINTENANCE AND TRAINING
MANAGEMENT AND SECURITY TO GET
THEIR INPUT ON WHAT THEY VIEW AS
POTENTIAL IMPACTS SHOULD BE
SHOULD THE STORM WATER
INFRASTRUCTURE ON SITE FAIL.
FROM THE INPUT WE RECEIVED WE
SETTLED ON FOUR CATEGORIES FOR
OUR CRITERIA ENVIRONMENTAL,
MISSION, ECONOMIC, ASSET SYSTEM
IMPACT AND TWO CATEGORIES HAD
MULTIPLE FACTORS.
DURING OUR CONVERSATIONS WITH
THE VARIOUS STAKEHOLDERS, WE
ASKED HOW THEY'D RATE THE
POTENTIAL IMPACTS AND THIS
HELPED WEIGH THE VARIOUS FACTORS
IDENTIFIED.
THERE WERE A FEW TO CONSIDER
WHEN DECIDING ON HOW TO WEIGH
THE CRITERIA.
YOU CAN PROVIDE EQUAL WEIGHT
ACROSS ALL FACTORS.
SO CATEGORY WEIGHTING WOULD BE
DETERMINED ON THE NUMBER OF
FACTORS WITHIN EACH CATEGORY.
OR YOU CAN PROVIDE EQUAL
WEIGHTING AND THE NUMBER OF
FACTORS WILL DETERMINE THE
FACTOR WEIGHT AND NOT THE
CATEGORY WEIGHT.
PLUS, WE CHOSE TO UTILIZE THE
FINAL OPTIONS AND USED THE
ANALYTICAL HIERARCHY PROCESS.
THIS OPTION ENABLED US TO USE
THE INPUT RECEIVED FROM THE
VARIOUS STAKEHOLDERS AND DEVELOP
THE WEIGHTING BASED ON PERCEIVED
IMPORTANCE OF EACH FACTOR.
THIS WEIGHTING PROCESS DOES HAVE
SOME LEVEL OF SUBJECTIVITY
BECAUSE IT CAN BE TAILORED
SPECIFICALLY TO THE END USER.
ONCE IT IS SET, IT DOES ALLOW
FOR STANDARDIZED WEIGHTING FOR
ALL CRITERIA ACROSS ALL ASSETS.
THE ANALYTICAL HIERARCHY PROCESS
HAS TWO PARTS.
FIRST, THE SCALE IS USED TO
ESTABLISH A HIERARCHICAL SCORE
FOR EACH OF THE FACTORS.
THEY'RE COMPARED IN A PAIR WISE
COMPARISON PAY TRIX.
CALCULATIONS -- MATRIX.
AND CALCULATIONS ARE IN THE PAIR
WISE TOOL AND FINAL WEIGHTING IS
ESTABLISHED.
THIS TABLE DEPICTED THE FINAL
WEIGHTING GENERATE THE PAIR WISE
COMPARISON TOOL AND PROVIDES THE
RELATIVE WEIGHTS OF EACH FACTOR
COMPARED TO THE OTHER AND THE
FINAL WEIGHTING IS PROVIDED IN
THE BLUE COLUMN ON THE RIGHT.
LIKE MANY OPERATIONAL GOVERNMENT
AGENCIES, THE MOST IMPORTANT
CRITERIA WAS THE POTENTIAL
IMPACT AND MISSION.
THIS WAS FOLLOWED BY THE
POTENTIAL IMPACT OF
TRANSPORTATION CORRIDORS AND
THAT WAS FOLLOWED BY
ENVIRONMENTAL COMPLIANCE,
CONSEQUENCES AND WHILE FLOODING
COULD HAVE MORE OF AN IMPACT ON
OUR MISSION, WE ARE CURRENTLY
ONLY EXPERIENCING LOCALIZED
FLOODING AND SO IN OUR CURRENT
STATE THE RISK OF FLOODING IS
ACTUALLY BEHIND ENVIRONMENTAL
COMPLIANCE.
NEXT, WAS ASSET SIZE AND CLASS
AND FINALLY THE LAST FACTOR WAS
EXPENSE.
USUALLY IF THERE'S AN ABSOLUTE
NEED FOR REPAIR AND MAINTENANCE,
FUNDING COULD BE OBTAINED TO
ADDRESS THE ISSUE.
THESE VALUES CAN CHANGE AS THE
CIRCUMSTANCES AT THE FACILITY
CHANGE.
IF MORE ROADS ARE BUILT,
TRANSPORTATION MAY GO DOWN
BECAUSE ALTERNATE ROUTES ARE
AVAILABLE.
ON THE FLIP SIDE, THE FLOODING
RISK CAN GO UP IF MORE ARE
IMPACTED DUE TO MORE SEVERE
STORMS AS CLIMATE CHANGE
CONTINUES TO BE AN ISSUE.
AND THIS TABLE IS THE FINAL
CONSEQUENCE OF FAILURES SCORE.
UNLIKE THE PROBABILITY OF
FAILURE, THE ASSETS LEAN MORE
TOWARDS THE HIGHER END.
AND NOTE THERE ARE NO ASSETS
WITH THE SCORE OF ONE.
THIS IS PARTLY BECAUSE THE
SCORING FOR THE CONSEQUENCE OF
FAILURE CRITERIA HAVE A SCORING
BETWEEN 1 AND 5 COMPARED TO THE
PROBABILITY OF FAILURE CRITERIA
HAVING THE SCORING OF ZERO TO 5.
FURTHERMORE, THERE ARE ALSO
ALWAYS BE SOME LEVEL OF
CONSEQUENCE IN MORE THAN ONE
CATEGORY.
FAILURE WITH AN ASSET MAY NOT
NECESSARILY IMPACT THE MISSION
OR TRANSPORTATION BUT THERE WILL
ALWAYS BE A FINANCIAL IMPACT AND
ENVIRONMENTAL CONSEQUENCE OR
IMPACT TO THE SYSTEM.
ONCE THE SCORING WAS COMPLETE,
THE DATA NOW HAD TO BE MANAGED.
THE DATA MANAGEMENT CAN BE
PERFORMED IN BOTH EXCEL WITH THE
SPREAD SHEET OR MANAGED WITH
GIS.
AND THERE ARE PROS AND CONS TO
BOTH MANAGEMENT SYSTEMS.
FOR AGENCIES THAT DO NOT USE
GIS, EXCEL IS PROBABLY THE WAY
TO GO.
THE DATA IN EXCEL MAY ALSO BE
EASIER TO ACCESS AND MANIPULATE
IF YOU'RE NOT FAMILIAR WITH GIS,
HOWEVER IT HAS THE CAPABILITY TO
PROVIDE VISUALIZATIONS IN
DIFFERENT WAYS INCLUDING LONG
SIDE INFRASTRUCTURE OR ASSET
TYPES LIKE BUILDING, TRAINING
VENUES OR OTHER UTILITIES.
AS THE DELIVERABLE OF THIS
PROJECT IT'S OBTAINED IN THE
GENERAL SPREAD SHEET AND FILE
CONTAINING ALL RISK DATA.
AND THIS IS THE PRIORITIZATION
TABLE CREATED USING EXCEL THE
SCORES FOR PROBABILITY AND
CONSEQUENCE OF FAILURE FACTORS
IN BOTH GREEN AND BLUE COLUMNS
AND IN THE GRAY COLUMNS IT
PROVIDES THE TOTAL SCORES FOR
PROBABILITY AND CONSEQUENCE OF
FAILURES.
THOSE TOTAL S DETERMINE THE
FINAL RISK SCORE.
AND BASED ON THE FINALLY RISK
SCORE, THESE ASSETS WERE THEN
CATEGORIZED INTO VARIOUS RISK
CATEGORIES.
VERY HIGH RISK, HIGH RISK AND
MODERATE AND LOW AND VERY LOW.
YOU CAN SEE NO ASSETS WITH HIGH
RISK.
THIS IS BECAUSE WE HAD ALREADY
ADDRESSED THE HIGHEST PRIORITY
ISSUES HOWEVER, WE ADDRESSED
THEM AFTER THEY WERE ALREADY AN
ISSUE AND HAD TO REACT TO THE
SITUATION.
AND THAT WAS ONE OF THE MAIN
DRIVERS FOR THE EFFORT TO GET A
FULL HANDLE ON OUR STORM WATER
INFRASTRUCTURE AND GET IN FRONT
OF THE MAJOR ISSUES BEFORE THEY
DEVELOP.
HERE'S THE VISUALIZATION USING
GIS.
THE HEAT MAP DEPICTS ALL THE
ASSETS WITHIN THE STORM WATER
CONVEYANCE SYSTEM AND WHERE THE
HIGHEST RISK IS LOCATED AND
WHERE WE NEED TO PRIORITIZE OUR
MAINTENANCE AND RESTORATION
EFFORTS.
THIS VISUALIZATION PROVIDES A
SIMPLE MEANS TO CONVEY THE SAME
INFORMATION FROM THE SPREAD
SHEET TO LEADERSHIP WHICH THEY
WILL APPRECIATE.
BACK TO YOU, TODD.
>> ALL RIGHT.
WELL, AS YOU CAN SEE, THERE ARE
MANY BENEFITS TO THIS RISK-BASED
FRAMEWORK.
THERE'S A LOT OF WORK, QUITE A
BIT OF EFFORT.
WE HAD A CONSULTANT HELP US BUT
YOU CAN SEE ALL THE VARIOUS
BENEFITS.
ONE THING WANT TO HIGHLIGHT
TLOEVON
THE LEFT ABOUT THE BUDGET AND
FORECAST.
THIS PROCESS GIVES US A GOOD
HARD DATA AND GOOD INTEGRITY AND
JUSTIFIABLE DATA SO WE GO TO ASK
FOR MONEY, IT GIVES US
CREDIBILITY BECAUSE WE CAN SHOW
WHY WE NEED THE MONEY AND FOR
WHAT.
AS A RESULT WE WERE ABLE TO GET
AN $11 MILLION BOGEY LAST YEAR
TO ADDRESS MANY OF OUR MAJOR
STORM WATER INFRASTRUCTURE
CONCERNS AND THIS YEAR WE'RE
DOING AN ASSESSMENT AND WE'LL DO
THAT THIS YEAR AND DOING SOME
DESIGN WORK FOR A LOT OF THE
HIGH RISK ITEMS TO GET THOSE
FIXED.
IT'S BEEN VERY GOOD TO US AND IT
WAS WELL LIKED BY THE FINANCIAL
FOLKS AND CFO.
WELL, I WANT TO THANK YOU FOR
OUR BRIEFING AND IF YOU HAVE ANY
QUESTIONS, YOU CAN THINK
ANYTHING OR WISH TO HAVE
ASSISTANCE WE CAN HELP YOU OUT
AND HERE'S OUR CONTACT
INFORMATION.
AGAIN, WE'RE AVAILABLE EITHER BY
E-MAIL OR PHONE.
SO IF THERE'S ANY QUESTIONS,
WE'D LIKE TO OPEN UP THE FLOOR
FOR ANY QUESTIONS.
DON'T BE SHY.
>> THANK YOU VERY MUCH IT WAS AN
INCREDIBLE PRESENTATION BEING A
FAN OF ANALYSIS AND STORM WATER
AND THE HEAT MAPS LOOKED SIMILAR
TO WHAT THE DEFENSE CLIMATE
ASSESSMENT TOOL RECOMMENDED WHEN
IT COMES TO AREAS OF GREATEST
RISK AND VULNERABILITY FOR
CLIMATE RISKS AND THREATS.
HAVE YOU IMPLEMENTS THIS FOR
CLIMATE ASSESSMENT SCENARIOS?
>> HERE, NO.
BUT WE HAVE STARTED LOOKING AT
THIS BEING PART OF DHS THERE'S A
CLUTCH PROFESSIONAL PROGRAM AND
SOMETHING WE BROUGHT UP WHERE
THE FOLKS WITHIN THE PROGRAM ARE
USING OTHER TOOLS AND THIS
SPECIFICALLY HAS NOT BEEN
INCORPORATED BUT THIS CAN BE
APPLIED TO DIFFERENT PROGRAMS,
DIFFERENT UTILITIES AND SO YES,
IT IS BEING EXPLORED.
IT JUST HAS NOT BEEN IMPLEMENTED
YET.
>> SCLEPT.
-- EXCELLENT.
>> WE USED THIS IN FOR EXAMPLE
OUR DRIVING TRAINING TRACK.
WE APPLIED RISK ASSESSMENT MODEL
TO THAT AND WORK ON REPAIRING
IT.
AND IF GET MONEY OR NOT I DON'T
KNOW AND WE'RE USING THE SAME
MOD
MODEL.
>> EXCELLENT.
DO YOU HAVE ANY PLANS TO
INCORPORATE FUTURE CLIMATE
SCENARIOS IN THE MODELLING TO
ASSUME YOU'RE IN A REGION WHERE
INCREASED COASTAL FLOODING MAY
BE AN ISSUE?
>> THIS WAS DRIVEN BY POTENTIAL
CLIMATE CHANGE.
AS THE INTENSITY AND FREQUENCY
OF STORMS INCREASES, WE ARE
EXPERIENCING MORE AND MORE
LOCALIZED FLOODING ISSUES.
UNDERSTANDING THE STORM WATER
CONVEYANCE IF IT'S NOT
MAINTAINED CAN IMPEDE THE
DISCHARGE OF FLOOD WATERS AND SO
YES, YOU KNOW, WE ARE LOOKING AT
THAT.
AS FAR AS TEMPERATURE CHANGES OR
EMISSIONS, IT HAS NOT BEEN
APPLIED TO THAT YET BUT FROM
CERTAIN CERTAIN CLIMATE CHANGE
ELEMENTS I WOULD SAY THIS IS
ABSOLUTELY A GOOD STARTING
POINT.
>> WHERE THIS WILL COME INTO
PLAY IS ON SUSTAINABILITY AND
RESILIENCE.
IT WILL HELP US TO SUSTAIN THE
FACILITY LONGER AND IT'S AN
85-YEAR-OLD FACILITY BUT ALSO
FOR RESILIENCE IN THAT WE CAN
RECOVER QUICKER WITH LESS
CONSEQUENCE TO ANY STORM OR
SEVERE WEATHER.
>> GREAT, THANK YOU.
NOT SEEING ANY NEW QUESTIONS
COMING IN THE INBOX BUT ONE
QUESTION IS HAVE YOU ADDRESSED
WILDFIRES.
>> IN MARYLAND WILDFIRES ARE NOT
READILY HAPPENING HERE.
THE AREA DOESN'T HAVE GREAT
CONCERN WITH WILDFIRES OR AT
LEAST NOT YET.
YEAH, IN THEORY, THIS PROCESS
COULD BE USED FOR THAT
IDENTIFYING RISK AREAS.
WE DID HAVE A FOREST SERVICE SO
IT WOULD BE INTERESTING TO GET A
TAKE WHETHER SOMETHING LIKE THIS
COULD BE USED OUT WEST LOOKING
AT THE FOREST AND PRECIPITATION
AND DEVELOPING HEAT MAPS.
>> WE GOT ONE QUESTION IN.
DID THE ARMY PURCHASE THE GPS
EQUIPMENT OR WAS THE MATERIALS
AND EQUIPMENT USED?
>> WE USED AN OUTSIDE VENDOR.
WE DID NOT USE THE ARMY CORE OF
ENGINEERS FOR THIS AND THEY HAD
ALL THEIR OWN EQUIPMENT.
>> OKAY.
>> I CAN IMAGINE IT'S NOT JUST A
QUESTION OF COST BUT TIME AND
REQUESTING GFE WALKIE-TALKIES
CAN TAKE MONTHS SO GETTING
APPROPRIATE GPS SURVEYING
EQUIPMENT IS PROBABLY FASTER TO
RELY ON WHAT THE CONTRACTORS
ALREADY HAVE.
>> RIGHT.
AND THE OTHER SIZED THAT IS OUR
CAPACITY.
FLOOD C IS A SMALL COMPONENT
WITHIN DHS AND OUR MAN POWER IS
LIMITED.
I REALLY DON'T HAVE THE CAPACITY
TO ABLE TO DO SOMETHING LIKE
THIS ON MY OWN AND HENCE WE HAD
TO SOURCE IT OUT.
>> NOR DO WE.
I'VE ALWAYS WANTED TO PLAY
AROUND WITH THE GPS TRIPODS AND
FIGURE OUT WHAT GOES INTO
STARING INTO THE SITE.
>> YEP.
>> WELL, MARK, I BELIEVE WE HIT
4:00 HERE.
WELL, THANK YOU BOTH SO MUCH AND
THANK YOU FOR THE SUPPORT AND
HELP WITH THIS AND THANK YOU FOR
A GREAT PRESENTATION AND THANK
YOU ALL IN THE AUDIENCE SO MUCH
FOR ATTENDING AND FOR YOUR 4290 03:24:37,164 FEEDBACK.