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EnvironmentalAssurance forNASASystemsTed BiessNASA HeadquartersEnvironmental Management DivisionFebruary 7, 2007
Outline• Alignment with Mission• Environmental Assurance Context• Example Environmental Impact on Shuttle• Focus, Definiti...
Alignment with    Mission
Compliance‘End of Pipe’
Environmental Management  Drivers, Context, and Issues• Activity is driven by external requirements  (e.g., statutes, Exec...
Agency Strategic Goals    Fly the Shuttle as safely as possible until its retirement, not later1   than 2010.    Complete ...
Environmental Management     Goals to Support Mission    Direct Mission Support1   Provide direct mission support by integ...
Alignment with Mission             Environmental Management                     Division Management & Support   Protection...
Environmental Assurance   Context
System Inputs & Outputs                  Model                              OUTPUTS  INPUTS                              w...
Impacts of Design Decisions                                            Lifecycle Cost                                     ...
Managing to External                Requirements• Agency Regulations                         •   Executive Order 13287 - P...
Trends for Long-Life Systems                                                                                             ?...
Includes DDT&E and operations – environmental  factors act primarily in the ops phaseAdapted from Ares 1 SRR Presentation,...
NASA incurs O&M                                                      costs and risks                                      ...
Example EnvironmentalImpact on Shuttle
Ozone Hole Discovered in 1985                                               NASA and NOAA                                 ...
Shuttle Ozone Depleting Substance (ODS) Applications                                       External Tank                  ...
Thermal Protection System (TPS)     Development Timeline1988   Initiated CFC 11 blowing agent replacement investigations  ...
Elimination of Ozone Depleting    Substances within NASA                                                    ODS Usage - kg...
Environmental   AssuranceFocus, Definition,   and Goals
Environmental Assurance FocusRisks posed by the Program to theenvironment• Identified under NEPA through the Environmental...
Environmental Assurance           DefinitionEnvironmental Assurance is theproactive detection, analysis,mitigation, and co...
Environmental Assurance Goals1.   Identify, analyze, and measure environmentally     driven programmatic and institutional...
Environmental Assurance  Structure
Environmental Assurance Structure  Environmental Management       Leadership &        Division (EMD)           Coordinatio...
Leadership & Coordination - EMD                                • Provides managementEnvironmental Management              ...
Principal Center – RRAC                                • Performs regulatory reviewEnvironmental Management               ...
Principal Center – TEERM                                • Leads work to identify andEnvironmental Management              ...
Partner Organization – C3P                                • Works with multipleEnvironmental Management                   ...
Partnerships                                                           • EMD serves on Steering           Shuttle Environm...
Trends
Environmental Assurance                  Risk DriversGovernment Requirements• EHS-related statutes, regulations, executive...
US Regulatory Trends and Issues    Create New External Requirements•   New U.S. air emission requirements•   More internat...
Environmental Regulatory       Landscape   International        United States       Multi-Lateral      Environmental      ...
Multilateral Environmental Agreements    (MEAs) Generated Risk Drivers • Future ratification of MEAs could initiate U.S.  ...
Key Multilateral Environmental          Agreements (MEAs)    Multilateral Environmental        Initial              Ratifi...
International Influences on       Material Selection and UseMultilateral Environmental Agreements (MEAs)• Persistent Organ...
Partial List of Materials and      Processes of Concern• Trichloroethane• Precision Cleaning and Cleanliness Verification ...
Summary
Summary• We are leveraging and refocusing  environmental capabilities at Centers and  Headquarters to develop Environmenta...
Contacts and Resources
Contacts and ResourcesJames Leatherwood                             Chris BrownDirector, Environmental Management Division...
WebsitesEnvironmental Management Divisionhttp://oim.hq.nasa.gov/oia/emd/index.htmlTechnology Evaluation for Environmental ...
Backup
Montreal Protocol                                          • Antarctic ozone hole discovered                              ...
NASA Systems and Processes Requiring  Ozone Depleting Substances (ODS)• Foam Blowing (Thermal Protection System  Foams)• R...
Requirement for Essential Usage      Exemption from EPA• NASA is required to actively search for alternatives to  material...
The NASA Organizational ChartChief Safety & Mission Assurance                                   Office of the             ...
Impacts of Design Decisions•   For a typical product, 70% of the cost of development, manufacture and    use is determined...
Environmental ManagementEnvironmental Performance           Initiatives                                                   ...
Environmental Management              InitiativesCompliance (initiated in 1969)• Comply with Environmental Regulations• Cr...
Key U.S. Federal Laws                Regulation                  Published                       Focus                    ...
Example of Indirect Impact on          Supply ChainRestriction of Hazardous Substances (RoHS)• Effective 1 July 2006• Bans...
Past NASA Environmental     Assurance SuccessesPreparation and Negotiation of 2Exemption Petitions for ContinuedProduction...
Past NASA Environmental            Assurance SuccessesActive NASA participation in the rulemaking negotiation processfor s...
Risk Characterization        Risk = f(Hazard, Exposure)      Risk = f(Hazard, Dose, Time)National Academy of Sciences, 1983.
NASA Risk Statement Structure      Given that          there is a possibility that     CONDITION              CONSEQUENCE ...
Example EA Risk                                             there is a          Given that                                ...
The Twelve Principles of Green              Chemistry1.  Prevention. It is better to prevent waste than to treat or clean ...
The Twelve Principles of Green             Engineering1.  Inherent Rather Than Circumstantial. Designers need to strive to...
U.S. Climate Change Proposals            Climate Change Legislative Proposals in                        U.S. Congress  120...
Worker Safety• OSHA  – Hexavalent Chromium PEL Reduction  – Crystalline Silica Exposure Standard  – Beryllium Exposure Sta...
JCAA/JG-PP Lead-Free Solder Testing for High-Reliability                      ApplicationsEuropean Union RoHS Directive• R...
JCAA/JG-PP Lead-Free Solder Testing for High-Reliability                      ApplicationsBackground• International collab...
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  1. 1. EnvironmentalAssurance forNASASystemsTed BiessNASA HeadquartersEnvironmental Management DivisionFebruary 7, 2007
  2. 2. Outline• Alignment with Mission• Environmental Assurance Context• Example Environmental Impact on Shuttle• Focus, Definition, and Goals• Organizational Structure – Principal Centers – International Component – Partnerships• Trends• Summary• Contracts and Resources
  3. 3. Alignment with Mission
  4. 4. Compliance‘End of Pipe’
  5. 5. Environmental Management Drivers, Context, and Issues• Activity is driven by external requirements (e.g., statutes, Executive Orders, public outcry) – Regulatory framework is the main driver for change• Identify, quantify, measure, monitor, review and assess environmental problems.• Sometimes in conflict with mission goals
  6. 6. Agency Strategic Goals Fly the Shuttle as safely as possible until its retirement, not later1 than 2010. Complete the International Space Station in a manner consistent2 with NASA’s International Partner commitments and the needs of human exploration. Develop a balanced overall program of science, exploration, and3 aeronautics consistent with the redirection of the human spaceflight program to focus on exploration. Bring a new Crew Exploration Vehicle into service as soon as4 possible after Shuttle retirement. Encourage the pursuit of appropriate partnerships with the5 emerging commercial space sector. Establish a lunar return program having the maximum possible6 utility for later missions to Mars and other destinations.
  7. 7. Environmental Management Goals to Support Mission Direct Mission Support1 Provide direct mission support by integrating environmental considerations into programs and projects.2 Proactive Risk Mitigation Proactively reduce NASA’s exposure to institutional, programmatic and operational risk.3 Protect Mission Resources Pursue environmental initiatives designed to restore, protect and enhance mission resources.
  8. 8. Alignment with Mission Environmental Management Division Management & Support Protection of Direct Mission Proactive RiskMission Resources Support Mitigation Environmental National EnvironmentalFunctional Reviews Environmental Assurance Policy Act (NEPA) Cleanup and Center Future Remediation Operational Cultural & Historic Environmental Preservation Assurance Management Sys. Regulated Materials Energy Emerging Contaminants Recycling & Affirmative Proc.
  9. 9. Environmental Assurance Context
  10. 10. System Inputs & Outputs Model OUTPUTS INPUTS waste heatraw materials solid waste waste stream air emissions attributes ‘end determine offuels / energy inputs water emissions pipe’ and outputs usable products
  11. 11. Impacts of Design Decisions Lifecycle Cost Operations and Support System Acquisition $ Production System R&D 100 95 Lifecycle cost 85 locked in 70 Lifecycle cost expended 50 Disposal 60% Cost? 10% 30% 10 Time Concept Production and Initial Out of Exploration Development Operational Service Concept and Full Scale Capability Validation DevelopmentFrom W. J. Larson & L. K. Pranke (1999) Human Spaceflight: Mission Analysis and Design
  12. 12. Managing to External Requirements• Agency Regulations • Executive Order 13287 - Preserve America• Archaeological Resources Protection Act • Fish and Wildlife Coordination Act• Biobased Product Procurement • Global Climate Protection Act Requirements • Green Computer (EPEAT) Procurement• Clean Air Act (CAA) Requirements• Clean Water Act (CWA) • ISO14001 - Environmental Management• Safe Drinking Water Act Standard• Comprehensive Environmental Response, • Landfill Disposal Standards Compensation, and Liability Act (CERCLA) • Local Regulations• Costal Zone Management Act • Marine Mammal Protection Act• Emergency Planning and Community • Migratory Bird Treaty Act Right-to-Know Act (EPCRA) • National Environmental Policy Act (NEPA)• Endangered Species Act (ESA) • National Historic Preservation Act• Energy Policy Act of 2005 • Occupational Safety and Health Act• Executive Order 11988 - Floodplain (OSHA) Management • Pollution Prevention Act (PPA)• Executive Order 11990 - Protection of • Resource Conservation and Recovery Act Wetlands (RCRA)• Executive Order 12114 - Environmental • State Regulations Effects Abroad of Major Federal Actions • Superfund Amendments and• Executive Order 12898 - Environmental Reauthorization Act (SARA) Justice • Toxic Substances Control Act (TSCA)• Executive Order 13148 - Greening the Government
  13. 13. Trends for Long-Life Systems ? Increasing Env. Regulation ? Increased regulation means increased ? operational restrictions, mandated controls, What will be the cost uncertainty, added effects/regulation and schedule delays from more liberal Administrations and Congresses? 2010 2020 2030 2040 Apollo Shuttle VSESource: J. A. Cusumano, New Technology for the Environment, Chemtech, 1992, 22(8), 482–489
  14. 14. Includes DDT&E and operations – environmental factors act primarily in the ops phaseAdapted from Ares 1 SRR Presentation, Nov 6-7, 2006
  15. 15. NASA incurs O&M costs and risks associated with environmental issuesAdapted from Ares 1 SRR Presentation, Nov 6-7, 2006
  16. 16. Example EnvironmentalImpact on Shuttle
  17. 17. Ozone Hole Discovered in 1985 NASA and NOAA Announce Ozone Hole is a Double Record Breaker October 19, 2006 From September 21-30, 2006 the average area of the ozone hole was the largest ever observed, at 10.6 million square miles. This image, from Sept. 24, the Antarctic ozone hole was equal to the record single-day largest area of 11.4 million square miles, reached on Sept. 9, 2000. The blue and purple colors are where there is the least ozone, and the greens, yellows, and reds are where there is more ozone.http://www.nasa.gov/vision/earth/lookingatearth/ozone_record.html
  18. 18. Shuttle Ozone Depleting Substance (ODS) Applications External Tank Solid Rocket Boosters External Tank: 4 TPS Foams OrbiterForward SRB/ET Attach Strut RSRM Orbiter Applications: Main Propulsion SRB/ET Attach System and Ring Aft SRB/ET Power Reactant Attach Struts (3) Storage and Distribution System Aft Stiffener Rings (3) Locations of HCFC 141b foams are RSRM: noted in blue Space Shuttle Nozzle Main Engines
  19. 19. Thermal Protection System (TPS) Development Timeline1988 Initiated CFC 11 blowing agent replacement investigations Made decision to implement HCFC 141b as near drop-in replacement rather than pursue Essential Use Exemption. Initiated detailed1991 development activities and design verification testing with HCFC 141b. Estimated completion date 1996. Began development of ODS-free (without HCFC 141b) foam; estimated1992 completion by 2003 which is phase-out date of all Class II ODS. Initiated production implementation of 3 out of 4 CFC 11 foams with1993 formulations containing HCFC 141b2002 Replaced remaining CFC 11 foam with HCFC 141b alternate HCFC 141b phased out in US. ODS-free foam is not available. Resources2003 and attention is overtaken by Columbia Accident and Return to Flight NASA still requires Essential Usage Exemption for continued use of2007 HCFC 141b within SSP. No plans for development of ODS-free foam due to Shuttle retirement in 2010.
  20. 20. Elimination of Ozone Depleting Substances within NASA ODS Usage - kg (pounds) End Use Classification 1991 2004 Reduction Foam Blowing 36110 11530 (Thermal Protection System Foams) 68% (79600) (25400) Rubber Cleaning, Surface Activation, and 385100 10700 Bonding 97% (849000) (23500) Solvent Cleaning, Precision Cleaning, 1171000 23000 and Cleanliness Verification 98% (2600000) (50700) 130200 19000 Refrigeration and Operational Cooling 85% (287000) (41800) 3720 95 Fire Suppression 97% (8200) (210)• ODS elimination has been a priority within NASA• The majority of ODS usage has been eliminated• Mission critical uses remain for existing space vehicles, and possibly for future programs
  21. 21. Environmental AssuranceFocus, Definition, and Goals
  22. 22. Environmental Assurance FocusRisks posed by the Program to theenvironment• Identified under NEPA through the Environmental Impact Statement (EIS) process prior to Program inception• The EIS describes programmatic options and addresses environmental considerations associated with eachRisks posed to the Program byenvironmentally-related drivers• Real-time risks from a new environmental driver• Real-time risks from configuration issues/changes that trigger an existing driver
  23. 23. Environmental Assurance DefinitionEnvironmental Assurance is theproactive detection, analysis,mitigation, and communication ofenvironmentally driven risks to NASAmission-required research,development, fabrication, processingand operations.
  24. 24. Environmental Assurance Goals1. Identify, analyze, and measure environmentally driven programmatic and institutional risks.2. Communicate environmentally driven programmatic and institutional risks to appropriate owners (when possible, in early phases of program and project planning and execution)3. Team/partner with risk owners to proactively reduce risk’s impact, likelihood, and scope (e.g., may apply to multiple programs and projects) – Influence regulatory authorities – Acquire special waivers, if possible, from regulating organization – Identify and validate appropriate solutions for mitigation of environmentally driven risks. As needed, adapt high-TRL technology and/or increase TRL for new technology for NASA’s use.The risk owners (e.g., programs and projects) will have day-to-dayresponsibility for management of their risks.
  25. 25. Environmental Assurance Structure
  26. 26. Environmental Assurance Structure Environmental Management Leadership & Division (EMD) Coordination NASA Headquarters Regulatory Risk Analysis and Principal Centers Communication (RRAC) MSFC Technology Evaluation for Environmental Risk Mitigation (TEERM) - KSC Centro Para Prevenção da Partner Organization Poluição (C3P) Lisbon, Portugal
  27. 27. Leadership & Coordination - EMD • Provides managementEnvironmental Management oversight of Principal Division (EMD) NASA Headquarters Centers • Interfaces with partner organizations - SEA, JGPP,Regulatory Risk Analysis and JANNAF, CAASSC Communication (RRAC) MSFC • Coordinates activity with regulatory agencies • Provides legislative Technology Evaluation for support, policy review, andEnvironmental Risk Mitigation (TEERM) - KSC guidance Centro Para Prevenção da Poluição (C3P) Lisbon, Portugal
  28. 28. Principal Center – RRAC • Performs regulatory reviewEnvironmental Management and impact analysis Division (EMD) NASA Headquarters • Captures and analyzes emerging risksRegulatory Risk Analysis and • Develops mitigation Communication (RRAC) options MSFC • Recommends actions for influencing regulatory authorities Technology Evaluation forEnvironmental Risk Mitigation • Communicates risks to (TEERM) - KSC NASA programs and projects Centro Para Prevenção da Poluição (C3P) Lisbon, Portugal
  29. 29. Principal Center – TEERM • Leads work to identify andEnvironmental Management test environmentally Division (EMD) NASA Headquarters preferable alternative materials and processes • Analyzes materials andRegulatory Risk Analysis and processes Communication (RRAC) MSFC • Manages joint test projects • Disseminates test Technology Evaluation for resultsEnvironmental Risk Mitigation (TEERM) - KSC • Develops risk mitigation options Centro Para Prevenção da • Participates with partners Poluição on joint projects – C3P and (C3P) Joint Group on Pollution Lisbon, Portugal Prevention (JGPP)
  30. 30. Partner Organization – C3P • Works with multipleEnvironmental Management European partners Division (EMD) NASA Headquarters • Conducts joint projects focusing on elimination of hazardous materials toRegulatory Risk Analysis and meet emerging EU regs. Communication (RRAC) MSFC • Operates in ways similar to TEERM • Monitors European projects Technology Evaluation for concerning elimination ofEnvironmental Risk Mitigation (TEERM) - KSC hazardous material • Provides conduit into Centro Para Prevenção da European Union for other Poluição activities of interest to (C3P) NASA (e.g., energy, Lisbon, Portugal REACH, lead-free solder)
  31. 31. Partnerships • EMD serves on Steering Shuttle Environmental Committee Assurance (SEA) • RRAC and TEERM participate Joint Group on Pollution • EMD is a member Prevention (JGPP) • RRAC is implementation lead • Participate within Safety and Joint Army, Navy, NASA and Air Force (JANNAF) Environmental Protection Subcommittee (SEPS) • EMD is a memberDepartment of Defense Clean AirAct Services Steering Committee • Provides insight into impacts (DOD CAASSC) from regulationRRAC - Regulatory Risk Analysis and Communication TEERM - Technology Evaluation for Environmental Risk Mitigation
  32. 32. Trends
  33. 33. Environmental Assurance Risk DriversGovernment Requirements• EHS-related statutes, regulations, executive orders, or policies that set requirementsOther Environment, Health, and Safety Considerations• Considerations related to environment, health or safety• Often, but not always, related to “government requirements”Vendor Economics & Issues• Vendor decisions to change formulations, cease production of a material, or otherwise impact materials and processes• Often related to the other driversTechnology and Market-Based Forces• Technology advances can reduce manufacturers’ incentives to produce technologically obsolete materials• Global trends in materials selection and procurement can impact materials availability by reducing production viability of certain low-volume itemsNatural Disasters• Manufacturing facilities and infrastructure damage by earthquake, hurricane, fire and other disasters can affect manufacturers’ ability or willingness to produce materials
  34. 34. US Regulatory Trends and Issues Create New External Requirements• New U.S. air emission requirements• More international requirements and pressures to manage chemical/material risk• Expansion of climate change measures• More restrictive requirements for worker, public, and environmental safety• NASA will continue to comply with external requirements (US)• Implementation of external requirements without understanding mission impacts may compromise both implementation of requirements and NASA’s ability to execute its mission effectively• NASA will choose how to meet external requirements to maximize mission success
  35. 35. Environmental Regulatory Landscape International United States Multi-Lateral Environmental U.S. Federal Agreements (MEAs) RegulationsForeign Statutes State and Localand Regulations Regulations
  36. 36. Multilateral Environmental Agreements (MEAs) Generated Risk Drivers • Future ratification of MEAs could initiate U.S. activities to comply with new requirements, either through existing laws and regulations or development of new ones • Growing influence by Europe, China, and others in setting global environmental agenda and standards • Diminished U.S. role in international arena with respect to – Prioritization of environmental issues – International requirements development – Environmental problem solving
  37. 37. Key Multilateral Environmental Agreements (MEAs) Multilateral Environmental Initial Ratified Agreements (MEAs) Agreement Parties by U.S. FocusMontreal Protocol 1989 189 Yes ODS phaseoutBasel Convention 1992 167 No recyclables tradeConvention on Biological Diversity 1992 188 No biodiversity/access &benefitsLaw of the Sea 1994 149 No ocean governanceChemical Weapons Convention 1997 176 Yes weapon bans/ inspectionsBiosafety Protocol 2003 131 No LMOs commoditiesLRTAP – Heavy Metals 2003 27 Yes heavy metalsLRTAP – POPs 2003 25 No chemical bansRotterdam PIC Convention 2004 102 No chemicals tradeStockholm POPs Convention 2004 119 No chemical bansKyoto Protocol 2005 160 No climate change
  38. 38. International Influences on Material Selection and UseMultilateral Environmental Agreements (MEAs)• Persistent Organic Pollutants (POPs)• Long-Range Transboundary Air Pollution (LRTAP)European Union• Registration, Evaluation, and Authorization of Chemicals (REACH)• Restriction of Hazardous Substances (RoHS)• Waste Electrical and Electronic Equipment (WEEE)Asia• Emerging RoHS-like laws in China and Korea
  39. 39. Partial List of Materials and Processes of Concern• Trichloroethane• Precision Cleaning and Cleanliness Verification Processes Requiring ODSs (HCFC 225 and HCFC 225g)• TPS and Cryoinsulation Containing ODS (HCFC 141b)• Chromate Primers• Cadmium Plating• Hexavalent Chromium Conversion Coating• Paint Strippers Containing Methylene Chloride• Lead Based Solid Film Lubricants• Paints Containing Perchloroethylene• High-Level Volatile Organic Compound (VOC) Coatings• Alkaline Cleaners Containing Hexavalent Chromium• Hazardous Air Pollutant (HAP) Inks• Methyl Ethyl Ketone• Materials and Products Containing Perfluoroalkyl Sulfonates• Materials Containing Brominated Flame Retardants• Materials Requiring Perfluorooctanoic Acid (PFOA)
  40. 40. Summary
  41. 41. Summary• We are leveraging and refocusing environmental capabilities at Centers and Headquarters to develop Environmental Assurance in support of mission• Environmental Assurance practiced at NASA will work to proactively identify, communicate, and mitigate risks to mission in a changing regulatory and resource- constrained climate to maximize options for programs and projects.
  42. 42. Contacts and Resources
  43. 43. Contacts and ResourcesJames Leatherwood Chris BrownDirector, Environmental Management Division Technology Evaluation for Environmental202.358.3608 Risk Mitigationjames.leatherwood-1@nasa.gov 321.867.8463 christina.m.brown@nasa.govDavid AmideiEnvironmental Assurance for NASA Systems Steve Glover Shuttle Environmental Assurance202.358.1866 256.544.5016damidei@nasa.gov steve.e.glover@nasa.govTed BiessEnvironmental Assurance for NASA Systems Paul Robert Center Operational Assurance202.358.2272 202.358.1305theodore.biess-1@nasa.gov paul.robert-1@nasa.govSharon ScrogginsRegulatory Risk Analysis and Communication256.544.7932sharon.scroggins@nasa.gov
  44. 44. WebsitesEnvironmental Management Divisionhttp://oim.hq.nasa.gov/oia/emd/index.htmlTechnology Evaluation for Environmental RiskMitigationhttp://acqp2.nasa.gov/FedCenter (Government Environmental Portal)http://www.fedcenter.gov/Clean Joint Group on Pollution Preventionhttp://www.jgpp.com/index.html
  45. 45. Backup
  46. 46. Montreal Protocol • Antarctic ozone hole discovered in late 1985 • Governments recognized the need for stronger measures to reduce the production and consumption of a number of CFCs and Halons • Adopted on 16 September 1987 in Montreal Canada • Signed by President Reagan on April 5, 1988 • Came into force on 1st January 1989, when it was ratified by 29 countries and the European Economic Communityhttp://ozone.unep.org/Treaties_and_Ratification/2B_montreal_protocol.asp
  47. 47. NASA Systems and Processes Requiring Ozone Depleting Substances (ODS)• Foam Blowing (Thermal Protection System Foams)• Rubber Cleaning, Surface Activation, and Bonding• Solvent Cleaning, Precision Cleaning, and Cleanliness Verification• Refrigeration and Operational Cooling• Fire Suppression
  48. 48. Requirement for Essential Usage Exemption from EPA• NASA is required to actively search for alternatives to materials and processes which use phased out ODS• NASA is required to perform semiannual usage reports and submit them to the EPARecent Feedback from EPA• The document mentions that different alternatives have been tested, but it gives no indication if those tests are ongoing and at what level, what substances, etc - NASA needs to be more explicit. There is no mention of a reduction in their use of ODS over time, unlike in other sections of the document.• It is problematic for NASA to state that it has "[no] plans to seek replacement for implementation on [Space Shuttle Program]" (pg 12 in table 4.1). The petition process as currently designed requires anyone who seeks an exemption to be actively searching for alternatives and documenting that search in their petitions. EPA expects an affirmative statement about NASA’s research plans for ODS substitutes for new vehicles. (Seema Schappelle, Bella Maranion, and Suzie Kocchi)
  49. 49. The NASA Organizational ChartChief Safety & Mission Assurance Office of the Chief of Staff Administrator Program Analysis & Evaluation Administrator Inspector General Deputy Administrator Chief Engineer Associate Administrator NASA Advisory GroupsMission Directorates Mission Support Offices Aeronautics Research Chief Financial Officer Exploration Systems Chief Information Officer Science General Counsel Space Operations Integrated Enterprise Mgmt Program Innovative Partnership ProgramNASA Centers Security & Program Protection Ames Research Center Chief Health & Medical Officer Dryden Flight Research Center Institutions & Management Glenn Research Center NASA Shared Services Center Goddard Space Flight Center Human Capital Management Infrastructure and Administration Jet Propulsion Laboratory Diversity and Equal Opportunity Procurement Johnson Space Center Small & Disadvantaged Business Utilization Kennedy Space Center Strategic Communications Marshall Space Flight Center Education Langley Research Center External Relations Legislative Affairs Stennis Space Center Public Affairs
  50. 50. Impacts of Design Decisions• For a typical product, 70% of the cost of development, manufacture and use is determined in its design phase.• Graphs are analogous for environmental impacts• Engaging in upfront product design can increase efficiency, reduce waste of materials and energy, reduce costs, impart new performance and capabilities, incorporate “inherently benign”
  51. 51. Environmental ManagementEnvironmental Performance Initiatives Environmental Assurance 2006 Pollution Prevention 1992 Compliance 1969 Mission Success
  52. 52. Environmental Management InitiativesCompliance (initiated in 1969)• Comply with Environmental Regulations• Creates unexpected consequences (e.g., costs, etc.) that threaten mission• Seen as a burdenPollution Prevention (initiated in 1992)• Attempt to prevent environmental hazards and costs• Improve control of environmental performance• Save funding by avoiding expenditures from environmental damage• Save funding from avoiding cost of complianceEnvironmental Assurance (initiated in 2006)• Focus on increasing environmental quality, improving cost effectiveness, and reducing risks to mission• Enlarges trade space for mission• Seek situations where there is a win for mission and a win for the environment
  53. 53. Key U.S. Federal Laws Regulation Published Focus environmental assessments for proposedNational Environmental Policy Act (NEPA) 1969 ActionsClean Air Act (CAA) 1970 ODS phaseout, hazardous air pollutants regulation discharge of pollutants toClean Water Act (CWA) 1977 waterwaysComprehensive Environmental Response, 1980 cleanup of hazardous substancesCompensation, and Liability Act (CERCLA)Emergency Planning and Community Right- 1986 reporting releases of chemical hazardsto-Know Act (EPCRA) protection of threatened and endangeredEndangered Species Act (ESA) 1973 speciesOccupational Safety and Health Act (OSHA) 1970 protection of worker safetyPollution Prevention Act (PPA) 1990 national policy for pollution preventionResource Conservation and Recovery Act 1976 hazardous waste management(RCRA)Superfund Amendments and 1986 cleanup of hazardous substancesReauthorization Act (SARA)Toxic Substances Control Act (TSCA) 1976 chemical usage trackingGlobal Climate Protection Act 1987 guidance for national climate program
  54. 54. Example of Indirect Impact on Supply ChainRestriction of Hazardous Substances (RoHS)• Effective 1 July 2006• Bans several materials used in new electrical and electronic equipment (EEE) - Lead - Cadmium - Mercury - Hexavalent Chromium - PBB and PBDE flame retardants Tin whisker growing from the case of one relay in the direction of an adjacent relay.
  55. 55. Past NASA Environmental Assurance SuccessesPreparation and Negotiation of 2Exemption Petitions for ContinuedProduction and Use of HCFC 141b – Blowing agent currently is used in mission-critical thermal protection systems (TPS) – Storing (stockpiling) HCFC 141b poses unacceptable risk of instability and contamination – Continued production of this banned substance is essential to SSP – These exemptions allow for the procurement of fresh material for use in External Tank TPS; RSRM Nozzle Foam Plug; Orbiter’s cryogenic insulation; and Booster bolt catchers, repairs and closeouts.
  56. 56. Past NASA Environmental Assurance SuccessesActive NASA participation in the rulemaking negotiation processfor several National Emission Standards for Hazardous AirPollutants (NESHAPs) regulations – significant benefits to space operations by influencing several categories – rules under the Clean Air Act requiring stringent control measures for reducing HAP emissionsAerospace NESHAP: obtained exemptions from surface coating and cleaning requirementsfor space vehiclesRocket Engine Test Firing NESHAP: convinced EPA that it is impractical to imposeemission limitations on rocket engine test firing operationsMiscellaneous Metal Parts and Products NESHAP: On-site NASA metal surface coating& related operations were excluded from this rulePlastic Parts and Products NESHAP: On-site NASA plastic & composite surface coating& related operations were excluded from this ruleDefense Land Systems and Miscellaneous Equipment (DLSME) NESHAP (ongoing):On-site NASA non-flight hardware surface coating, cleaning and paint removal operationswill likely have only limited restrictions that are tailored to NASA systems and requirements
  57. 57. Risk Characterization Risk = f(Hazard, Exposure) Risk = f(Hazard, Dose, Time)National Academy of Sciences, 1983.
  58. 58. NASA Risk Statement Structure Given that there is a possibility that CONDITION CONSEQUENCE will occur• Must be a FACT or • Must have a perceived to be NEGATIVE impact to FACT the CONDITION• Must be REALITY BASED Additionally, a single event• Can have NO could trigger several risks uncertainty attached and have multiple consequencesA good risk statement must be ACTIONABLE and haveONE condition and ONE consequence per statement
  59. 59. Example EA Risk there is a Given that possibility that• The SSP utilizes Class I and Class II ozone-depleting substances • ODS will be specified for (ODS) for critical precision development and O&M of Cx cleaning and cleanliness verification operations systems• Cx systems have shuttle-heritage • NASA will not have access to• Some LOX systems currently do not have substitutes for these needed supplies of ODS ODSs (e.g., CFC 113, HCFC 225) for critical precision cleaning and • Cx systems will not have cleanliness verification operations ability to perform critical• All Class II ODS production will be discontinued and usage will be precision cleaning and highly regulated in the US by cleanliness verification January 1, 2015 operations
  60. 60. The Twelve Principles of Green Chemistry1. Prevention. It is better to prevent waste than to treat or clean up waste after it has been created.2. Atom Economy. Synthetic methods should be designed to maximize the incorporation of all materials used in the process into the final product.3. Less Hazardous Chemical Syntheses. Wherever practicable, synthetic methods should be designed to use and generate substances that possess little or no toxicity to human health and the environment.4. Designing Safer Chemicals. Chemical products should be designed to effect their desired function while minimizing their toxicity.5. Safer Solvents and Auxiliaries. The use of auxiliary substances (e.g., solvents, separation agents, etc.) should be made unnecessary wherever possible and innocuous when used.6. Design for Energy Efficiency. Energy requirements of chemical processes should be recognized for their environmental and economic impacts and should be minimized. If possible, synthetic methods should be conducted at ambient temperature and pressure.7. Use of Renewable Feedstocks. A raw material or feedstock should be renewable rather than depleting whenever technically and economically practicable.8. Reduce Derivatives. Unnecessary derivatization (use of blocking groups, protection/ deprotection, temporary modification of physical/chemical processes) should be minimized or avoided if possible, because such steps require additional reagents and can generate waste.9. Catalysis. Catalytic reagents (as selective as possible) are superior to stoichiometric reagents.10. Design for Degradation. Chemical products should be designed so that at the end of their function they break down into innocuous degradation products and do not persist in the environment.11. Real-time analysis for Pollution Prevention. Analytical methodologies need to be further developed to allow for real-time, in-process monitoring and control prior to the formation of hazardous substances.12. Inherently Safer Chemistry for Accident Prevention. Substances and the form of a substance used in a chemical process should be chosen to minimize the potential for chemical accidents, including releases, explosions, and fires.*Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 1998, p.30.
  61. 61. The Twelve Principles of Green Engineering1. Inherent Rather Than Circumstantial. Designers need to strive to ensure that all materials and energy inputs and outputs are as inherently nonhazardous as possible.2. Prevention Instead of Treatment. It is better to prevent waste than to treat or clean up waste after it is formed.3. Design for Separation. Separation and purification operations should be designed to minimize energy consumption and materials use.4. Maximize Efficiency. Products, processes, and systems should be designed to maximize mass, energy, space, and time efficiency.5. Output-Pulled Versus Input-Pushed. Products, processes, and systems should be "output pulled" rather than "input pushed" through the use of energy and materials.6. Conserve Complexity. Embedded entropy and complexity must be viewed as an investment when making design choices on recycle, reuse, or beneficial disposition.7. Durability Rather Than Immortality. Targeted durability, not immortality, should be a design goal.8. Meet Need, Minimize Excess. Design for unnecessary capacity or capability (e.g., "one size fits all") solutions should be considered a design flaw.9. Minimize Material Diversity. Material diversity in multicomponent products should be minimized to promote disassembly and value retention.10. Integrate Material and Energy Flows. Design of products, processes, and systems must include integration and interconnectivity with available energy and materials flows.11. Design for Commercial "Afterlife". Products, processes, and systems should be designed for performance in a commercial "afterlife."12. Renewable Rather Than Depleting. Material and energy inputs should be renewable rather than depleting. * Anastas, P.T., and Zimmerman, J.B., "Design through the Twelve Principles of Green Engineering", Env. Sci. and Tech., 37, 5, 95 ? 101, 2003.
  62. 62. U.S. Climate Change Proposals Climate Change Legislative Proposals in U.S. Congress 120 100 80 60 40 20 0 1997-1998 1999-2000 2001-2002 2003-2004Note: President Bush’s 2007 State of the Union address
  63. 63. Worker Safety• OSHA – Hexavalent Chromium PEL Reduction – Crystalline Silica Exposure Standard – Beryllium Exposure Standard – Explosives Standard• State Requirements• International Requirements
  64. 64. JCAA/JG-PP Lead-Free Solder Testing for High-Reliability ApplicationsEuropean Union RoHS Directive• Reduction of Hazardous Substances (RoHS) – EU Directive banning “placing on market” new electronic equipment containing specific levels of the following after July 1, 2006 • Lead, Cadmium, Mercury, hexavalent chromium, polybrominated biphenyl (PBB), polybrominated diphenyl ether (PBDE) flame retardants – Seeks to reduce the environmental impact of EEE by restricting the use of certain hazardous substances during manufacture – Related legislation underway in China and Japan• Consumer electronics are driving commercial market to lead-free alternatives – Lead-free brings new and re-emerging failure modes in electronics – Most consumer electronics are throw away – NASA has unique operating environment which drive additional requirements – Electronic industry minimally impacted by aerospace requirements • Estimated aerospace use = 1% solder and components• Primary lead-free impacts – Lead-free solder issues – Tin whisker failures – Availability of leaded solder and components – New processes / configuration control• Commercial solution strategies for lead-free may not apply to Military / Aerospace applications
  65. 65. JCAA/JG-PP Lead-Free Solder Testing for High-Reliability ApplicationsBackground• International collaborative effort – Project begun under the auspices of the U.S. DoD’s Joint Group on Pollution Prevention (JG-PP), then turned over to the DoD’s Joint Council on Aging Aircraft (JCAA) (concerned about numerous lead-free solder logistical and repair issues) – DoD, NASA, U.S. and European defense and space OEMs, and component & solder suppliers – Project Completed • Results highly anticipated by NASA & industry. Issues critical for Constellation program risk reduction. • Findings of high value to hundreds of stakeholders. No one else looking at lead-free solder for high reliability applications as in depthNext Step• NASA Lead-Free Electronics Project – Data generated from the this project is required to gain a better understanding of how lead-free electronics will perform in high-reliability aerospace applications. – Even though NASA and the aerospace community are exempt from lead-free laws and regulations, there may not be enough suppliers available to meet needs – Military and aerospace OEMs are receiving unwanted electronics components with lead- free finishes

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