NAVAL SEA SYSTEMS COMMAND ANTIFOULING PROGRAM

NATIONAL PAINT & COATINGS ASSOCIATION INTERNATIONAL MARINE & OFFSHORE COATINGS EXPO June 2007 Mr. Mark Ingle, P.E. (202) 781-3665 Inglemw@navsea.navy.mil

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OBJECTIVES
• Summarize Naval Sea Systems Command (NAVSEA) reorganization
changes in key coatings & corrosion control staff.

• Summarize NAVSEA Advanced Antifouling Coating Program goals:
•• Need to lower ship operating costs. •• Environmental drivers of change. •• NAVSEA goals.

• Summarize NAVSEA Advanced Antifouling Coating Program
accomplishments: •• Listing of copper-free products on MIL-PRF-24647 Qualified Products List. •• Registration or Reformulation of new products.

• Discuss potential future cooperative work with coating vendors to
develop products that meet Navy needs.
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SHIP INTEGRITY & PERFORMANCE (SI&P)

R&SE Director

Competency Domain Manager (CDM) Ship Integrity & Performance Michael R. Kistler Deputy CDM

SEA 05P
SEA 05PB

Admin Event (Tina) Brewer

SEA 05P1

Director Survivability Division Robert E. Bowser

Director Ship Structures & Materials Division E. Dail Thomas

SEA 05P2

SEA 05P21
Surface Ships Structural Integrity Dept. Head David A. Qualley (Acting) Materials Department Head Jon Fallick

SEA 05P24

Submarine Structural Integrity Dept Head W. Will

Corrosion Control Dept. Head SEA 05P23 Beau E. Brinckerhoff (Acting)

SEA 05P22

Pre-decisional

Shipboard Environmental Protection Dept Head A. Budzichowski

SEA 05P25

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SHIP INTEGRITY & PERFORMANCE (SI&P) Corrosion Control & Coatings Organization
Corrosion Control Dept. Head Beau E. Brinckerhoff (Acting)

Senior Engineer, Coatings Mark Ingle Senior Engineer, Cathodic Protection Andrew Seelinger Engineer, Non-skid & Decking Mike Evans Engineer, Tank Coatings VACANT Engineer, Topside & Freeboard Coatings VACANT

Pre-decisional 4

ANTIFOULING COATING PROGRAM Navy Needs to Reduce Coating Costs
• Navy under pressure to reduce acquisition & life-cycle costs for ships. Goal is to obtain 313 ship Navy in current budgetary environment. • Reducing acquisition painting costs: - Does a surface need to be painted (e.g., aluminum ships)? - Can alternative technologies be used to reduce coating costs (e.g., single-coat, composite stand-alone tanks)? • Reducing coating maintenance application costs by applying LEAN principles on all parts of paint process and focusing on specific cost-saving concepts: - Universal Paint Requirements.
- Graduated Quality Assurance (QA) & Paperless QA. - Paint Application Warranty. - Heavy Metals Coating Removal Management. - Advanced Technology: Improved foul release coatings, longer life coatings, Heat Induction Coating Removal, & Single Coat.
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ANTIFOULING COATING PROGRAM Navy Needs to Reduce Costs for Fuel
• OPNAV investigating alternative means of reducing fuel costs.
400 350 300 250
$K/ship 200

150 100 50 0 2004 2005 2006

DDG LHD

F-76 fuel cost increased By 50% from $1.47/gal in 2005 TO $2.21/gal in 2006

• NAVSEA collecting data on commercial fleets that are paying a premium price for foul-release coatings to realize fuel savings. •• One vendor claims 6% fuel savings. •• Another vendor claims 2% fuel savings. NAVSEA conducting additional demonstrations on foul-release; can we measure cost savings on Navy & U.S. Coast Guard (USCG) craft.
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ANTIFOULING COATING PROGRAM Environmental Drivers of Change
• World-wide antifouling coating environmental regulations are changing:
•• International Maritime Organization (IMO) tributyl tin ban. •• Canada, 40 ug/cm2/day limit on copper emissions from antifouling paints. •• Sweden has copper emissions limits on antifouling coatings in Baltic, 200 ug/cm2/14-day. •• Netherlands bans cleaning or scrubbing of copper-bearing antifouling. INTERNATIONAL PRECEDENTS ESTABLISHED FOR BIOCIDE & Cu REGULATION

• Local water-quality issues in ports with military & civilian ships leading to new domestic regulations.
•• San Diego violates federal water quality standards – California evaluating new regulations. San Diego Regional Water Quality Board issued a 20-year plan to phase out copper-bearing paints. •• Puget Sound Naval Shipyard (PSNS) has had NOVs for copper discharge from drydocks. •• Hull-coating leachate is identified UNDS discharge. NUMERICAL UNDS COPPER EMISSION LIMIT TO BE PROPOSED IN 2007.

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UNIFORM NATIONAL DISCHARGE STANDARDS Hull Coating Leachate
Constituents that leach, dissolve, ablate, or erode from the paint on the hull into the surrounding seawater Marine Pollution Control Devices (MPCDs) given full technical evaluation: – Establish a maximum allowable copper release rate. – Advanced antifouling coatings. – Foul-release coatings. Performance standard is expected to be based on a combination of all three MPCDs – coating selection will be vessel dependent:

STEEL, COMPOSITE, RIGID HULL

ALUMINUM

FLEXIBLE 8

Source: EPA UNDS OUTREACH BRIEF (Fall 2003).

FOULING PREVENTION UNDS PROGRAM APPROACH

Phase I

Identify and Characterize Discharges

Joint EPA/DoD Rule

Final Rule Published

Phase II

Establish MPCD Performance Standards

Joint EPA/DoD Rule

Final Rule Expected 2007

ANTIFOULING STANDARD DUE 2007.

Phase III

Develop Implementing Instructions

DoD Rule

Negotiation

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ANTIFOULING COATING PROGRAM Environmental Rules Changing
• Numerical UNDS copper emission limit to be proposed in 2007. Specific provisions of UNDS regulations are deliberational and cannot be presented. 1. UNDS Rules are coming in 2007, all current MIL-PRF-24647 QPL coatings may be at compliance risk. 2. UNDS rule likely to be based on ASTM-D-6442 data over 90 days. 3. Future UNDS numerical limit on copper emissions, with compliance testing. 4. Meeting goals discussed publicly by NAVSEA since 2001 for paints that release 50% less copper than vendor’s MIL-PRF-24647 QPL coatings would reduce UNDS compliance risk. 5. Requalification of reformulated coatings with NAVSEA is required and takes a minimum of 38-months.

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From Provide Qualification Application to NAVSEA NAVSEA Application Review Entry Criteria- perquisites For the Navy to consider product General Criteria- Required Tests/inspections to Qualify product

Fail

Modify Product

QUALIFICATION TESTING OF MIL-PRF-24647 TYPE I, II, & IV ANTI FOULING COATINGS
Product Test Path Performance Test Path

Pass

Pass

Resistance to Tropical Biofouling Organism Attachment PANEL TEST (12 months or 24 months) Fail
Correct Facility Deficiencies

Fail

Modify Product

Decision/Action Typical Government Field Testing Path

DCMA Audit

Pass
Conduct Product Testing Ablation/erosion rate Volatiles Nonvolatile Vehicle Toxicity Flash Point Consistency Metal ( Pb) Content Dry Times Sag Resistance Condition in Container Color Partially full container Spraying properties Brushing properties Rolling properties Pressure cycling

Cathodic Protection Compatibility (3 months)

Less Likely Government Field Testing Path

Panel Test s Positive Results

Resistance to Tropical Biofouling Organism Attachment SHIP PATCH TEST Government (Minimum 12 months) Or Commercial (Minimum 24 months)
Modify Product

Fail

Modify Product

Pass Resistance to Tropical Biofouling Organism Attachment SHIP FULL TEST Government (Minimum 12 months) Or Commercial (Minimum 24 months) Pass
Modify Product

Fail

Modify Product

Unacceptable
NEHC Review Complete Performance Testing

Acceptable

Accelerated Storage Stability (30 days) Recoatability (3 months) Shelf Life (24 months) Start

Fail
Compile Submission Package

Product Approved & Placed on QPL
Complete Performance Testing

Pass Submit to NAVSEA 05Q

2 months

4 months

14-28 months

26-52 months

Approximate Time (From Application Submittal)

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38 months Minimum

ANTIFOULING COATING PROGRAM Operational Requirements
• CFFC & NAVSEA are reducing
ship operating costs by extending drydock cycle:

•• Current cycle is 73-months •• 12-year life-cycle extension already authorized for CVN, LHD, and LHA test ships. NAVSEA authorized docking extension for all ships using “Condition Based” maintenance. • Navy antifouling coating system applied with three coats of antifouling paint (red/black/red) to achieve 12-year cycle. • Navy antifouling coatings must withstand service life that includes: - 55% inactivity pier-side, - Diver cleaning of coatings, - Brief dockings for specific repairs.
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NAVSEA ANTIFOULING COATING PROGRAM GOALS
ENVIRONMENTAL:
•• Coatings must comply with current & future air emission regulations (e.g., 400 g/l VOC, HAP, etc.). •• Antifouling coatings must eliminate or significantly reduce copper emissions by 50% (i.e., < 10 ug/cm2/day). •• Antifouling coatings must be EPA registered. •• Coatings must be applicable using “standard” personal protective equipment. •• Coating must obtain NEHC approval.

TECHNICAL:
•• Coatings must satisfy Navy operating cycle. •• Goal is for coating to last for 12-years without hull cleaning (or with no more cleaning than current products). •• Vendors must commit resources to register and sell coatings in the United States.

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ANTIFOULING COATING PROGRAM PROGRAM APPROACH
ENVIRONMENTAL & PERFORMANCE GOALS OPTION 3: FOUL-RELEASE NON-TOXIC COATINGS • COMMERCIAL COATINGS. • NAVSEA SPECIFICATION REVISION IN PROGRESS. • TEST INSTALLATIONS ON MCM-1 & MCM-14.

OPTION 1: NON-COPPER • DEVELOPMENTAL COATINGS. • NOT EPA REGISTERED. • SHORT HALF-LIFE (e.g., 10-hour) BIOCIDES.

OPTION 2: LOW-COPPER CO-BIOCIDE COATING • COMMERCIAL PRODUCTS • SOME CO-BIOCIDES, NOT EPA REGISTERED. • SHORT HALF-LIFE (e.g., 10-hour) BIOCIDES. BEST OPTION 2 PRODUCTS Don’t currently meet Navy needs.

MIL-PRF-24647D INCLUDES CATEGORY. International Intersleek included on MIL-PRF-24647D Qualified Products List Two other products in qualification testing.

MIL-PRF-24647D category One vendor’s products failed ship test Two vendor’s products under smallscale tests

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ANTIFOULING COATING PROGRAM MIL-PRF-24647D
• NAVSEA issued “new” MIL-PRF-24647D “Paint System Anticorrosive and Antifouling, Ship Hull” on 16 February 2005. •• Specification “types” follow program options. •• Specification includes a Type IV non-polishing, biocidal coating. •• Simplified “applications” help Navy avoid drydock extension system confusion: Application 1 - Less than 3 years. Application 2 - Less than 7 years. Application 3 - Less than 12 years Application 4 – Less than 2 years, for use on high-speed craft. • Performance requirements – not a material specification. When implemented, will include UNDS limitations. Performance validated on: 1. Panels. 2. Patches. 3. Full ship hull tests.

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ANTIFOULING COATING PROGRAM MIL-PRF-24647D Coating Qualification Testing
▪ Option 1 Coatings tested on Static Exposure rafts in Biscayne Bay or Batelle Site at Ponce Inlet evaluated for performance vs. MIL-PRF-24647 ablative control.

Option 1
I-11-2
6 Mon. May-05

I-11-2

12 Mon. Nov-05

I-11-2

18 Mon. May-06

I-11-2

24 Mon. Nov-06

6 Mon. Jul-04

12 Mon. Jan-05

18 Mon. Jul-05

24 Mon. Jan-06

MIL-PRF-24647 control

I-1d-1

I-1d-1

I-1d-1

I-1d-1

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NAVSEA ANTIFOULING COATING PROGRAM PANEL TEST RESULTS
FR 50 / 10%
Option 1 - Coating 1

Option 1 - Coating 2

Option 2 - Coating 1 Waterline Submerged Option 2 - Coating 2

Cu Ablative Control 1

Cu Ablative Control 2

0

5

10

15

20 Months

25

30

35

40

45

FR BETWEEN 40 AND 60 RESULTS IN NAVY PERFORMING UNDERWATER HULL CLEANING

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ANTIFOULING COATING QUALIFICATION Option 3, Foul-release Coating Panel Evaluation
100 90 80 70 60 50 40 30 20 10 0 1 2 3 4 5 6 7 8 9 10 11 12 Exposure Cycles

Percent Fouling

FOULING ACCUMULATION ON EXPOSED PANEL

Soft Fouling

Hard Fouling
100 90 Percent Remaining Fouling 80 70 60 50 40 30 20 10 0 1 2 3 4 5 6

MIL-PRF-24647D

FOULING RELEASE IN FLOW CHANNEL

7

8

9

10

11

12

Exposure Cycle

% Remaining @ 20 kts

% Remaining @ 30 kts 18

COATING QUALIFICATION FOUL-RELEASE PANEL TEST RESULTS
FOULING RELEASE IN FLOW CHANNEL (POOR PERFORMER)
80 Percent Remaining Fouling 70 60 50 40 30 20 10 0 1 2 3 Exposure Cycles % Remaining @ 20 kts % Remaining @ 30 kts 4 5

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ANTIFOULING COATING QUALIFICATION Option 3 Coating to be Listed on QPL
● Flow channel damaged in Rita (October, 2005). Channel repaired in Sept. 2006. Option 3, “third” exposure period Sept. 2006 – counting time even without cycles. Option 3 panel test completed in March 2007. Using commercial ship for ship test.
Before (top) and after 30kt exposure (“third” test cycle) Before (top) and after 20kt exposure (“third” test cycle)

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NAVY ANTIFOULING PROGRAM Foul-Release Ship Test Results
OPTION 3 FOUL-RELEASE COATINGS
• DURABILITY ISSUE IS CRITICAL FOR ARMED-FORCES VESSELS. ANY SCRATCH OR DEFECT CAN LEAD TO TENACIOUS FOULING GROWTH. • ARMED FORCES VESSELS REGULARLY CLEANED DURING LONG PIER-SIDE PERIODS. CLEANING DAMAGES COATING. • MARINE ORGANISMS GROW AT SCRATCHES AND BECOME VERY DIFFICULT TO REMOVE.
Silicone topcoat Epoxy Primer Steel Hull

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ANTIFOULING COATING PROGRAM SHIPBOARD TESTING TO DATE
• NAVSEA patch tests on navy ships & USCG craft in fouling-prone, warm water. • Testing initiated in 2001 through 2006, Testing in 2007
USS ALDIE (Option 1 & 2)

USS JOHN PAUL JONES (Option 1 & 2) USS RENTZ (Option 1 & 2) USS AVENGER (Option 1) USCG MARLIN (Option 1 & 2) USCG KNIGHT ISLAND (Option 1 – test patch)

USCG 41’ UTILITY BOAT (Option 1) USCG 41’ UTILITY BOAT (Option 1) USCG 41’ UTILITY BOAT (New Option 3) USCG MATINICUS (Option 1 & 2) USCG CUSHING USCG 47’ LIFEBOAT (Option 1) 22 (Option 1)

ANTIFOULING COATING PROGRAM Full Ship Test of Option 1 Failed in 2006
Antifouling test system: red top coat of option 1 over abc-3. EPA EUP granted in Nov. 2004 for USCG KNIGHT ISLAND (WPB-1348) based in Tampa, FL. Test system application: February, 2005 Master Marine – Bayou La Batre, LA Inspected: June 2005, & April 2006 • Soft fouling & hard fouling apparent. USCG had speed problems. • Hull only cleaned with abrasive pads. • Option 1 not as good as Cu ablative.
April 2006 June 2005 ABC-3 ABC-3 Option 1 Option 1 23
Option 1 / BRA-640 fullimmersion panels, 18 months Biscayne Bay, FL

ANTIFOULING COATING PROGRAM Patch Test of Option 1 Performing Well
Antifouling System: Option 1 applied over universal primer to aluminum hull of USCG 47-foot motor lifeboat operating in San Juan, PR. Test System Applied: Jan. 9 - 22, 2005 Inspected: Aug. 2005 light algae growth. April 2006 cleaning needed, cleaned Dec. 2006 pulled for zincs, cleaned well.

Performance so good, USCG want more coating.
Batelle test site, 48 month, full immersion results

Pressure wash, algae easily removed, polishing apparent.

Some hard fouling on welds, not a speed problem.

Option 1 Coating

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Control

ANTIFOULING COATING TESTING USS JOHN PAUL JONES (DDG-53) PATCH TEST INSTALL
TEST COATING (TWO COATS, ONE BLACK AND ONE RED) BRA 640 COPPER ABLATIVE COATING EPOXY PRIMER STEEL HULL

PATCHES INSTALLED, March, 2004 TEST PATCHES

INSTALLED TEST PATCHES OF OPTION 1 & OPTION 2 COATINGS, ALSO INSTALLED BILGE KEEL PANELS OF MORE DEVELOPMENTAL OPTION 1 & OPTION 2 SYSTEMS.

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NAVY ANTIFOULING TESTING NAVSEA Renewed Interest in Option 3 Coatings
● NAVY INTEREST IN FOUL RELEASE COATINGS STIMULATED BY: ●● Procurement of aluminum hull, General Dynamics, LCS-2 requires navy to learn how to use Option 3 coating – 6-year docking cycle, no approved copper-free antifouling, shipbuilder preference. ●● Commercial industry is paying 28% to 35% cost premium to install foul-release coatings. 1. Savings from 2% to 6% on fuel. 2. Increase in speed from 1 to 2 knot. 3. Reduced coating weight (up to 70% vs. 12-year cuprous oxide). 4. Reduced time in drydock to apply system (one fewer coat). 5. Easy to clean & stable in drydock. 6. Inherently low VOC & environmentally acceptable. 7. Warranty:
“High speed craft should use Option 3 . When operational parameters are above 50% activity and 25 knots service speed, Option 3 vendor will issue a performance guarantee against fouling.” 26

ANTIFOULING COATING TESTING New, Option 3 Product May Perform Well on Lower Speed Ships
● New Option 3 Product Introduced to Navy and Commercial industry in May 2007. ●● Fluorinated polymer with silicone resin. ●● Amphiphillic surface (i.e., with mixed hydrophobic and hydrophillic areas) inhibit organism settlement and adhesion. ●● Surface is smoother than conventional silicone-based Intersleek 425. ● Option 3 vendor reporting that vessels with speeds in excess of 10 knots can achieve > 6% fuel savings because amphiphillic coating is smoother and has a lower coefficient of friction than standard Intersleek. ● NAVSEA testing Option 3 on test panels and on patches on U.S. Coast Guard 47-foot lifeboat based in Fort Pierce, FL. Coating to be installed in June 2007.

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NAVY ANTIFOULING PROGRAM Program Progress Summary
• NAVSEA learned that Econea biocide used in many Option 1 formulas has been registered by U.S. EPA on 23 April 2007. •• Two Option 1 products that use Econea have accumulated required panel and patch/ship test data to be listed on NAVSEA MIL-PRF-24647 QPL as Application 1 - Less than 3 years systems. •• QPL listing will allow more data collection and expansion of ship tests for eventual Application 2 – Less than 7 year listing. • NAVSEA has renewed level of interest in Option 3 coatings that are being formulated to function well on slower vessels and that can withstand the mechanical damage that can occur on Navy ships. NAVSEA Working with consultants to provide coating vendors with additional antifouling ideas/concepts: •• Development of solvent-free, hydrolyzable, Option 1 coatings. Allows thick layer, with fast polish rate to control fouling. •• Use fast polish rate to boost performance. • NAVSEA Interested in coating vendors looking in new directions. Biocides are limited by cost to bring to market, paint chemistry may have to change to ensure long-term performance.
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NAVY ANTIFOULING PROGRAM FUTURE PROGRAM PLANS
• Future advanced antifouling program plans include: •• Development & testing of additional Option 1 coatings. NAVSEA will work with all vendors to test new products. •• Reformulate Option 2 coatings to meet regulatory limits. •• Conduct additional tests of Option 3 coatings. •• Monitor already initiated tests. New Navy ships will challenge existing antifouling coatings. •• •• •• •• Smaller, faster craft (e.g., 120 m or 370 ft.) Budget pressure to save fuel & drydock dollars. Aluminum hulls. Smaller crews, less maintenance.

Need antifouling coatings for these ships.

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Backup slides

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FOULING PREVENTION OVERALL PROGRAM GOALS
• U.S. NAVY NEEDS TO CONTROL UNDERWATER-HULL FOULING
USING ENVIRONMENTALLY ACCEPTABLE METHODS. FOULING CONTROL IS IMPORTANT TO ALLOW NAVY SHIPS TO:
•• ATTAIN CRITICAL SPEED – 2% SPEED LOSS. •• MINIMIZE OPERATING EXPENSES: 6% TO 45% INCREASE IN FUEL COSTS ($130K/year PER DDG) & $60K PER CVN-68 CLEANING. •• REDUCE NOISE.

• NAVSEA GOAL IS TO ADOPT NEW, ADVANCED COATING SYSTEMS FOR FLEET-WIDE IMPLEMENTATION. •• CURRENT U.S. NAVY FLEET UNDERWATER-HULL AREA,
99% COATED WITH COPPER ABLATIVE – 12,434,472 ft2 or 1,155,200 m2 •• FOUL-RELEASE COATING APPLIED TO 26,635 ft2 or 2,660 m2

EFFECTIVE, COPPER-FREE OR REDUCED COPPER ANTIFOULING COULD BECOME U.S. NAVY STANDARD. 31

TOTAL ANNUAL COPPER LOADINGS
Firem ain System s 2% 8,618 lbs (3,909 kg) Non-Oily Machinery Wastew ater <1% 485 lbs (220 kg)

Total Cu Load = 345,480 lb/yr
U/W Ship Husbandry 1% 4,279 lbs (1,941 kg)

(156,707 kg/yr)

Other <1% 691 lbs (314 kg) Hull Coating Leachate 64% 216,657 lbs (98,274 kg)

S/W Cooling Discharge 32% 112,100 lbs (50,847 kg)

Distillation & RO Brine <1% 2,649 lbs (1,201 kg)
*Estimates are for all discharges and vessels covered by UNDS within contiguous zone (<12 nm) Source: Technical Development Document Phase I Uniform National Discharge Standards for Vessels of the Armed Forces 32 EPA 821-R-99-001, April 1999

NAVSEA ANTIFOULING COATING PROGRAM GOALS

VOC < 400 g/l Cu RELEASE < 10 ug/cm2/day OR 50% OF ABC-3/BRA-640 OR NO COPPER SUPPORT 12-year DOCKING WITHOUT CLEANING COATING THAT MEETS NAVSEA NEEDS

WITHSTAND 35-knot FLOW

EPA REGISTERED IN U.S.

APPLICABLE USING NAVY STANDARD EQUIPMENT (COMPARABLE TO ABC-3, BRA-640, HEMPEL OLYMPIC)

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NAVSEA ANTIFOULING COATING PROGRAM GOALS
VOC < 400 g/l CAN USE OXOL. Cu RELEASE < 10 ug/cm2/day OR 50% OF BRA-640 OR NO COPPER ASTM-D-6442 METHOD, 90-DAY PERIOD. SUPPORT 12-year DOCKING WITHOUT CLEANING CAN ACCEPT CLEANINGS ANALOGOUS TO CURRENT COATINGS.

COATING THAT MEETS NAVSEA NEEDS

WITHSTAND 35-knot FLOW

EPA REGISTERED IN U.S.

APPLICABLE USING NAVY STANDARD EQUIPMENT CAN USE HIGH-SOLIDS PUMPS. CANNOT HAVE NUMEROUS EXTRA COATS OR DRY TIME.
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ANTIFOULING COATING PROGRAM Operational Requirements
• Underwater-hull cleanings are critical to obtaining 12-year service life.
Cleanings are conducted on a “Condition Based” process in which fouling is compared with established foul ratings.

AVERAGE COATING LOSS RATE (mils/cleaning)

NORMAL COATING POLISHING RATE IS 1.0 TO 1.5 mils / year
CG LSD CVN

FFG

DDG

KEY POINT: CLEANING CAN REMOVE 30% TO 51% OF ONE ENTIRE COAT OF ANTIFOULING PAINT.
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UNIFORM NATIONAL DISCHARGE STANDARDS HULL COATING LEACHATE
PHASE II INITIATION OF TECHNICAL ACTIVITIES: – MARCH 1999. COMPLETION OF BATCH ONE TECHNICAL ANALYSIS: – AUGUST 2003. PHASE II BATCH ONE PROPOSED RULE: – JANUARY 2005. PHASE II BATCH ONE FINAL RULE: – SEPTEMBER 2005.

Source: EPA UNDS OUTREACH BRIEF (Fall 2003).

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