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NAVAL SEA SYSTEMS COMMAND NAVAL SEA SYSTEMS COMMAND ANTIFOULING PROGRAM ANTIFOULING PROGRAM

NATIONAL PAINT & COATINGS ASSOCIATIONINTERNATIONAL 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 QualifiedProducts List.

•• Registration or Reformulation of new products.

• Discuss potential future cooperative work with coating vendors todevelop products that meet Navy needs.

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DirectorSurvivability Division

Robert E. Bowser

DirectorShip Structures & Materials Division

E. Dail Thomas

Deputy CDM

Surface Ships Structural Integrity Dept. Head

David A. Qualley(Acting)

Submarine Structural Integrity Dept Head

W. Will

Materials Department Head

Jon Fallick

Corrosion Control Dept. Head

Beau E. Brinckerhoff(Acting)

Shipboard Environmental

Protection Dept HeadA. Budzichowski

Competency Domain Manager (CDM)Ship Integrity & Performance

Michael R. KistlerSEA 05P

SEA 05PB

SEA 05P1 SEA 05P2

SEA 05P21

SEA 05P22

SEA 05P24

SEA 05P25

SEA 05P23

R&SE Director

SHIP INTEGRITY & PERFORMANCE (SI&P)

AdminEvent (Tina) Brewer

Pre-decisional

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Corrosion Control Dept. HeadBeau E. Brinckerhoff

(Acting)

SHIP INTEGRITY & PERFORMANCE (SI&P)Corrosion Control & Coatings Organization

Senior Engineer, CoatingsMark Ingle

Senior Engineer, Cathodic ProtectionAndrew Seelinger

Engineer, Non-skid & DeckingMike Evans

Engineer, Tank CoatingsVACANT

Engineer, Topside & Freeboard CoatingsVACANT

Pre-decisional

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ANTIFOULING COATING PROGRAMNavy 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 PROGRAMNavy Needs to Reduce Costs for Fuel

• OPNAV investigating alternative means of reducing fuel costs.

F-76 fuel cost increasedBy 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 wemeasure cost savings on Navy & U.S. Coast Guard (USCG) craft.

0

50

100

150

200

250

300

350

400

2004 2005 2006

DDGLHD

$K/ship

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ANTIFOULING COATING PROGRAMEnvironmental 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 & civilianships 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

Source: EPA UNDS OUTREACH BRIEF (Fall 2003).

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FOULING PREVENTIONUNDS PROGRAM APPROACH

Joint EPA/DoD RulePhase I

Phase II

Phase III

Identify and Characterize Discharges

Final Rule Published

Joint EPA/DoD Rule

DoD Rule

Establish MPCD Performance Standards

Develop Implementing Instructions

Final Rule Expected 2007

Negotiation

ANTIFOULING STANDARD DUE 2007.

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ANTIFOULING COATING PROGRAMEnvironmental 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 paintsthat 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 requiredand takes a minimum of 38-months.

11Approximate Time (From Application Submittal)

NAVSEA ApplicationReview

Recoatability (3 months)

AcceleratedStorage Stability

(30 days)

ConductProduct Testing

Ablation/erosion rate VolatilesNonvolatile VehicleToxicityFlash PointConsistencyMetal (Pb) ContentDry TimesSag ResistanceCondition in ContainerColorPartially full containerSpraying propertiesBrushing propertiesRolling propertiesPressure cycling

2 months 38 months Minimum

Star

t

PassResistance to Tropical Biofouling Organism Attachment

PANEL TEST(12 months or 24 months)

Fail

Fail

Pass

4 months

Fail

Product Approved&

Placed on QPL

General Criteria- RequiredTests/inspections to

Qualify product

Entry Criteria- perquisitesFor the Navy toconsider product

Pass

Shelf Life (24 months)

Cathodic ProtectionCompatibility(3 months)

14-28 months

From Provide Qualification Application to NAVSEA

DCMA Audit

NEHC Review

Resistance to Tropical Biofouling Organism AttachmentSHIP PATCH TEST

Government (Minimum 12 months)Or Commercial (Minimum 24 months)

Pass

Resistance to Tropical BiofoulingOrganism Attachment

SHIP FULL TEST Government (Minimum 12 months)

Or Commercial (Minimum 24 months)

Pass

26-52 months

Panel Test sPositive Results

CompileSubmission

Package

ModifyProduct

Correct Facility

Deficiencies

Product Test Path

Performance Test Path

Decision/Action

Typical Government Field Testing Path

Less Likely Government Field Testing Path

Submit toNAVSEA 05Q

Fail

ModifyProduct

Complete Performance

Testing

Pass

Fail

ModifyProduct

Fail

ModifyProduct

ModifyProduct

Complete Performance

Testing

Acceptable

Unacceptable

ModifyProduct

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

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ANTIFOULING COATING PROGRAMOperational Requirements

• CFFC & NAVSEA are reducingship operating costs byextending drydock cycle:

•• Current cycle is 73-months

•• 12-year life-cycle extensionalready authorized for CVN, LHD, and LHA test ships.NAVSEA authorized dockingextension for all ships using“Condition Based” maintenance.

• Navy antifouling coating system applied with three coatsof 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 significantlyreduce 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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ENVIRONMENTAL &

PERFORMANCE GOALS

OPTION 2: LOW-COPPERCO-BIOCIDE COATING• COMMERCIAL PRODUCTS • SOME CO-BIOCIDES,

NOT EPA REGISTERED.• SHORT HALF-LIFE

(e.g., 10-hour) BIOCIDES.

OPTION 3: FOUL-RELEASENON-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.

ANTIFOULING COATING PROGRAMPROGRAM APPROACH

MIL-PRF-24647D category

One vendor’s products failed ship test

Two vendor’s products under small-scale tests

BEST OPTION 2 PRODUCTS

Don’t currently meet Navy needs.

MIL-PRF-24647D INCLUDESCATEGORY.

International Intersleek includedon MIL-PRF-24647D Qualified Products List

Two other products in qualification testing.

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ANTIFOULING COATING PROGRAMMIL-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 yearsApplication 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 PROGRAMMIL-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-24647ablative control.

12 Mon.Nov-05

18 Mon.May-06

24 Mon.Nov-06

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

12 Mon.Jan-05

18 Mon.Jul-05

24 Mon.Jan-06

6 Mon.Jul-04

I-1d-1 I-1d-1 I-1d-1 I-1d-1

Option 1

MIL-PRF-24647 control

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NAVSEA ANTIFOULING COATING PROGRAM PANEL TEST RESULTS

FR 50 / 10%

0 5 10 15 20 25 30 35 40 45

Option 1 - Coating 1

Option 1 - Coating 2

Option 2 - Coating 1

Option 2 - Coating 2

Cu Ablative Control 1

Cu Ablative Control 2

Months

Waterline

Submerged

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

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01020304050

60708090

100

1 2 3 4 5 6 7 8 9 10 11 12

Exposure Cycles

Perc

ent F

oulin

g

Soft Fouling Hard Fouling

FOULING ACCUMULATION ON

EXPOSED PANEL

ANTIFOULING COATING QUALIFICATIONOption 3, Foul-release Coating Panel Evaluation

010

2030

405060

7080

90100

1 2 3 4 5 6 7 8 9 10 11 12

Exposure Cycle

Per

cent

Rem

aini

ng F

oulin

g

% Remaining @ 20 kts % Remaining @ 30 kts

FOULING RELEASE IN

FLOW CHANNEL

MIL-PRF-24647D

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FOULING RELEASE IN FLOW CHANNEL(POOR PERFORMER)

0

10

20

30

40

50

60

70

80

1 2 3 4 5

Exposure Cycles

Per

cent

Rem

aini

ng F

oulin

g

% Remaining @ 20 kts % Remaining @ 30 kts

COATING QUALIFICATIONFOUL-RELEASE PANEL TEST RESULTS

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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 PROGRAMFoul-Release Ship Test Results

OPTION 3 FOUL-RELEASE COATINGS

• DURABILITY ISSUE IS CRITICAL FORARMED-FORCES VESSELS. ANY SCRATCH OR DEFECT CAN LEADTO TENACIOUS FOULING GROWTH.

• ARMED FORCES VESSELSREGULARLY CLEANED DURINGLONG PIER-SIDE PERIODS. CLEANING DAMAGES COATING.

• MARINE ORGANISMS GROWAT SCRATCHES AND BECOME VERY DIFFICULT TO REMOVE.

Silicone topcoat

Epoxy Primer

Steel Hull

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ANTIFOULING COATING PROGRAMSHIPBOARD TESTING TO DATE

USCG MATINICUS(Option 1 & 2)

USS AVENGER(Option 1)

USS RENTZ (Option 1 & 2)

USCG 41’ UTILITY BOAT(Option 1)

USCG 41’ UTILITY BOAT(New Option 3)

USCG MARLIN(Option 1 & 2)

• NAVSEA patch tests on navy ships & USCG craft in fouling-prone, warm water.

• Testing initiated in 2001 through 2006, Testing in 2007

USCG 41’ UTILITY BOAT(Option 1)

USS JOHN PAUL JONES(Option 1 & 2)

USCG KNIGHT ISLAND (Option 1 – test patch)

USS ALDIE(Option 1 & 2)

USCG 47’ LIFEBOAT(Option 1)

USCG CUSHING(Option 1)

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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, 2005Master 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.

ABC-3

Option 1

ABC-3

Option 1

June 2005April 2006

Option 1 / BRA-640 full-immersion panels, 18 months Biscayne Bay, FL

ANTIFOULING COATING PROGRAMFull Ship Test of Option 1 Failed in 2006

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Antifouling System: Option 1 applied over universal primerto 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, cleanedDec. 2006 pulled for zincs, cleaned well.

Performance so good, USCG want more coating.

Batelle test site, 48 month, full immersion results

Option 1 Coating Control

Pressure wash, algae easily removed, polishing apparent.

Some hard fouling on welds, not a speed problem.

ANTIFOULING COATING PROGRAMPatch Test of Option 1 Performing Well

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ANTIFOULING COATING TESTINGUSS JOHN PAUL JONES (DDG-53) PATCH TEST INSTALL

TEST PATCHES

INSTALLED TEST PATCHES OF

OPTION 1 & OPTION 2 COATINGS,

ALSO INSTALLED BILGE KEEL

PANELS OF MORE DEVELOPMENTAL

OPTION 1 & OPTION 2 SYSTEMS.

PATCHES INSTALLED, March, 2004

BRA 640 COPPERABLATIVE COATING

EPOXY PRIMER

STEEL HULL

TEST COATING (TWO COATS, ONE BLACK AND ONE RED)

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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-2requires navy to learn how to use Option 3 coating – 6-year dockingcycle, 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.”

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ANTIFOULING COATING TESTINGNew, Option 3 Product May Perform Well on Lower Speed Ships

● New Option 3 Product Introduced to Navy and Commercialindustry 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 withspeeds in excess of 10 knots can achieve> 6% fuel savings because amphiphillic coating is smoother and has a lower coefficient of frictionthan standard Intersleek.

● NAVSEA testing Option 3 on test panelsand 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 PROGRAMProgram Progress Summary

• NAVSEA learned that Econea biocide used in many Option 1 formulas hasbeen registered by U.S. EPA on 23 April 2007.

•• Two Option 1 products that use Econea have accumulatedrequired panel and patch/ship test data to be listed on NAVSEA MIL-PRF-24647 QPL as Application 1 - Less than 3 yearssystems.

•• QPL listing will allow more data collection and expansion of shiptests for eventual Application 2 – Less than 7 year listing.

• NAVSEA has renewed level of interest in Option 3 coatings that are beingformulated to function well on slower vessels and that can withstand themechanical 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 arelimited by cost to bring to market, paint chemistry may have to change to ensurelong-term performance.

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• 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.Need antifouling coatings for these ships.

NAVY ANTIFOULING PROGRAMFUTURE PROGRAM PLANS

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Backup slidesBackup slides

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FOULING PREVENTIONOVERALL PROGRAM GOALS

• U.S. NAVY NEEDS TO CONTROL UNDERWATER-HULL FOULINGUSING 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 FUELCOSTS ($130K/year PER DDG)& $60K PER CVN-68 CLEANING.

•• REDUCE NOISE.

• NAVSEA GOAL IS TO ADOPT NEW, ADVANCED COATING SYSTEMSFOR 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 ANTIFOULINGCOULD BECOME U.S. NAVY STANDARD.

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TOTAL ANNUAL COPPER LOADINGSNon-Oily

Machinery Wastewater

<1%485 lbs (220 kg)

Firemain Systems

2%8,618 lbs(3,909 kg)

Other<1%

691 lbs (314 kg)

U/W Ship Husbandry

1%4,279 lbs (1,941 kg)

Hull Coating Leachate

64%216,657 lbs (98,274 kg)

Distillation &RO Brine

<1%2,649 lbs(1,201 kg)

S/W Cooling Discharge

32%112,100 lbs(50,847 kg)

Total Cu Load = 345,480 lb/yr

(156,707 kg/yr)

Source: Technical Development Document Phase I Uniform National Discharge Standards forVessels of the Armed Forces EPA 821-R-99-001, April 1999

*Estimates are for all discharges and vessels covered by UNDS within contiguous zone (<12 nm)

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NAVSEA ANTIFOULING COATING PROGRAM GOALS

COATING THAT MEETS NAVSEA

NEEDS

VOC < 400 g/l

Cu RELEASE < 10 ug/cm2/dayOR 50% OF ABC-3/BRA-640OR NO COPPER

EPA REGISTERED IN U.S.

SUPPORT 12-year DOCKINGWITHOUT CLEANING

WITHSTAND 35-knot FLOWAPPLICABLE USING NAVYSTANDARD EQUIPMENT (COMPARABLE TO ABC-3,

BRA-640, HEMPEL OLYMPIC)

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NAVSEA ANTIFOULING COATING PROGRAM GOALS

COATING THAT MEETS NAVSEA

NEEDS

VOC < 400 g/lCAN USE OXOL.

Cu RELEASE < 10 ug/cm2/dayOR 50% OF BRA-640OR NO COPPERASTM-D-6442 METHOD,90-DAY PERIOD.

EPA REGISTERED IN U.S.

SUPPORT 12-year DOCKINGWITHOUT CLEANINGCAN ACCEPT CLEANINGSANALOGOUS TO CURRENTCOATINGS.

WITHSTAND 35-knot FLOW APPLICABLE USING NAVYSTANDARD EQUIPMENT CAN USE HIGH-SOLIDSPUMPS.CANNOT HAVE NUMEROUSEXTRA COATS OR DRY TIME.

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ANTIFOULING COATING PROGRAMOperational 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.

FFG DDG CG LSD CVN

KEY POINT: CLEANING CAN REMOVE 30% TO 51% OF ONE ENTIRE COAT OFANTIFOULING PAINT.

AVERAGE COATING LOSS RATE (mils/cleaning) NORMAL COATING

POLISHING RATE IS 1.0 TO 1.5 mils / year

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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).