SEVENTH SUPPLEMENTAL BRIEFThis is a featured page

MUTUAL AID SOCIETY OF AMERICA, INC. 103 Methodist St., Cecilia, KY 42724 Cell) 270-307-4857; Office) 270-862-4537 Skype) 270-872-4493; Fax. 270-862-4379 email) jimmiller5417@gmail.com
August 27, 2011
Mr. Joseph Williams
Associate Regional Counsel
Office of Regional Counsel
USEPA Region 5 (C-14J)
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 886-6631(phone)
(312) 692-2965(fax) Email) Williams.Joseph@epamail.epa.gov

Re: Notice of Dispute on behalf of Mutual Aid Society of America, Inc.; Seventh Supplemental Brief, EPA GLNPO-2011-is-2-1356
Dear Mr. Williams:
The Fifth Supplemental Brief discussed the location and construction of the Silverfin low-cost, quick-start shipyard which was in lieu of the earlier description of a more traditional shipyard. The attached revised edition of that paper, entitled Silverfin Low-cost, Quick-Start Shipyard – Revised 8-26-11 entirely replaces the prior edition and changes the “tent” design to that of the Air Cell Pneumatic Building (identified in the revised paper as the Assembly I-Building - “I” for inflatable), pioneered by Lindstrand. There are a fair number of representative competitive manufacturers in the U.S., Canada, and UK. The revisions and new text are in Paragraph 1 below. Because the main focus of the proposed grant is the creation of working drawings, MASA has designated Google Sketch-Up as the main collaborative platform for the initial sketches, the preliminary plans and the final, working drawings for the ships and the shipyard. The extended discussion is in Paragraph 2 below. Heating during winter months is costly even in a LEEDS building. Moving the operation to the South in the winter and in the summer to the North makes sense economically for savings of energy costs for heating and cooling. Because the entire shipyard is highly portable, the change in location will not have a heavy cost impact. While “pick-up-and-go” ship yards are unheard of, the MASA plan for a “pick-up-and-go” shipyard is occasioned by the need to avoid damage from flood waters when the shipyard is located next to the Mississippi River and in a known flood plain. Paragraph 3 sets forth the reasoning and documentation in support of the “pick-up-and-go” shipyard.
  1. AIR CELL PNEUMATIC BUILDING
The revised edition of Silverfin Low-cost, Quick-Start Shipyard – Revised 8-26-11, changes the nature of the specification of the Assembly Building from a tent to a fully self-supporting Air Cell Pneumatic Building. Following is the new and revised arguments and documentation for this change in design: THE ASSEMBLY BUILDING An air-cell inflatable building (Assembly I-Building) will be erected which will enclose the assembly area for the hull and first deck of each ship. The area will be about 128 feet wide (48' for the hull, 40' for the work space inside the Assembly I-Building, and 40' for access around the Assembly I-Building on the outside) [39 m]. The length of this pad is 280' (180' for the hull, 60' for workspace inside the Assembly I-Building, and 40' for access outside the Assembly I-Building) [85 m]. The proto-typical Assembly I-Building is based on air-cell pneumatic buildings engineered by Lindstrand: http://www.lindstrandtech.com Air Cell Technology Pioneered by the Lindstrand team in 1999, air cell technology marked a new era in the history of inflatable fabric engineering and pneumatic architecture: “Air cell inflatables are advanced constructions (often referred to as pneumatic structures) made with two layers of material with fabric formers perpendicular in between. They are self-supporting and self-erectable by means of an air fan only with no need for foundation, hardware or guy wires. “Air cell inflatable buildings (or pneumatic buildings) act as permanent structures rather than temporary ones having high torsional stiffness, which allows them to withstand wind up to 80 knots and snow load up to 140kg/m2 [308 lbs/m2 = 308/9 sq/ft/m = 32 lbs/sq. ft] “Inflatable buildings can support loads on the roof and walls for lighting, lifting and other cabling requirements. They have great thermal and sound insulation properties, and tolerate temperatures from -30 °C to + 70°C. “Inflatable buildings manufactured by Lindstrand Technologies fully comply with the standards applicable to pneumatic buildings - Fire Retardancy Standards (BS 7837/5438) and Anti-Fungal Standards. “The life expectancy of inflatable buildings depends upon the climate in which they are installed and particularly the levels of UV light to which the pneumatic structures are exposed. An inflatable structure erected outdoors should survive for 10 years in the Tropics and for 20 years in European conditions. If the inflatables are kept indoors they will last almost indefinitely. “There are almost no limitations as to design geometry for the inflatable constructions – Lindstrand’s facilities are capable of producing almost anything in fabric. However, the building must have a sufficient air gap to create the required rigidity, and large flat horizontal areas are to be avoided. “Portable architecture brings no disruption to the site because inflatable buildings are manufactured entirely off-site and can usually be installed within a day. Pneumatic buildings and structures can be used in practically any environment and are ideally suited both for military and civil applications.
“Inflatable Storage and Decontamination Units http://www.lindstrandtech.com/storage.html Inflatable air cell structures are perfect storage and cover facilities: double skin design provides natural insulation and simplifies temperature control. Additionally, an optional Mylar coating can be used on the outer skin to provide a highly reflective coating, which reduces increases in temperature when used in sunny tropic or desert climates. [Emphasis added. We will need this reflective coating to aid the air conditioning by evaporative coolers which typically can only drop the air temperature by 15%].] “Inflatable structures have versatile storage applications ranging from food storage facilities to decontamination domes, which prevent unwanted agents leaking in the air. “Portable inflatable constructions are effective protection for fragile and valuable objects that are kept outdoors.”
Cold Storage Building
Contact information:
Tel: +44 (0) 1691 671 888 email: sales@lindstrandtech.com

The Assembly I-Building will be made of translucent poly-cloth, white, IR, UV, and weather resistant. Sides will be of the same material. The Assembly I-Building will be made in sections 40' wide and reaching from the bottom of one side, across the top and to the bottom of the other side. In keeping with the admonition by Lindstrand, the curvilinear profile will be similar the the above Cold Storage Building. Three foot flaps will be made to cover where the sections join. A half-inch polypropylene rope will be welded into reinforced sections of the Assembly I-Building around the perimeter of each section, across the ridge, at the shoulder of the roof and sides and along the bottom edge of the sides. A four foot flap will be added beyond the rope at the bottom of each side as a bed for a “torus” (water filled tube, 1 meter in diameter) can be placed on the flap to keep out air movement and rodents. More on the torus later in this article. Each end -wall will be enclosed. In the middle 50' of the end wall facing the river, a section will be made which is open. A flap 56' wide flap will cover this opening which will overlap the outboard sides of the end walls by about 3'. This is the “hanger door” which allows the partially completed ship to be moved out of the Assembly I-Building on to the Assembly Pad At the bottom of the “hanger door”, a pocket is made and a 2” PVC pipe installed along the bottom so as to give it some rigidity. Water can be added inside the pipe to give it some weight. This door is attached to the gable end wall at about 22' in height. When we need to bring the ship under construction out of the Assembly I-Building, we attach helium balloons to the bottom of the “hanger door” and raise it and any portion of the Assembly I-Building necessary to allow for the ship to move out of the Assembly I-Building. The “ridge line” is reinforced by using a 2” PVC pipe to define the ridge in addition to the embedded poly rope. This pipe is inserted in a pocket or loops welded to the vertex of the “roof”. It may be permissible to create a partially welded seam where the internal batts are welded so that the PVC pipe and the rope may be joined with zip-lock ties. The PVC pipe and rope will support light fixtures and possibly polycloth AC ducts. The Assembly I-Building will have four passage doors, two on each end-wall near the corners. The size, shape and configuration of the Air Cell buildings as a single story building is very amorphous. An example is the Dolphin's Stadium.

STANCHIONS In order to stabilize the Assembly I-Building, we install stanchions at each 40' point along the sidewalls and on each side of the end-wall major door openings. These are 55 gallon drums, buried 2' into the gravel bed. Inside the drum we put a 4” x 4” x 6' post and fill the drum with concrete. Within 6” of the top of the post, we install 1/2” diameter eye bolts. A 1/2” poly rope is attached to an eye-bolt and run to the corresponding eye bolt in the stanchion directly opposite on the other side of the building. The rope needs to align with a “valley” between the air-cells and be slick so movement does not abrade the building skin. The “inside” edge of each drum is about 4' distant from the bottom of the side-wall to allow room for the “torus”. The excavated gravel is used as backfill and compacted with a “powder puff” compressed air-drive compactor. ROOF The roof is supported and stabilized by using helium balloons inside the Assembly I-Building along the ridge line, probably at 20' intervals. These balloons are tethered to inside concrete filled 30 gallon drums on each side and enough slack in the rope and the fill/vacuum tube so that they remain stationary at the vertex. Flexible gas hoses serve each balloon so that they can be individually inflated and deflated. Deflation is accomplished by use of a vacuum pump which parses the gas to a high pressure compressor which refills the compressed gas storage tanks. In case of a coming high wind, the entire Assembly I-Building can be collapsed over the work-in-progress and secured. In case of a coming flood, the entire Assembly I-Building can be raised by filling the helium balloons and it and the work-in-progress moved and loaded on the Silverfin Builder or 40' flat bed semi-trailers. In the event we relocated the shipyard, the entire shipyard would be struck and taken aboard the Silverfin Builder.
  1. GOOLE SKETCH-UP
Google Sketchup Pro v.8 will allow all team professionals to graphically display their ideas in either 3d or 2d, then when ready, dimension them in 2d or 3d into scaled drawings with notes. These dimensional working drawings will be suitable for construction. During this generative process, the parties can participate in synchronous, real-time peer communication over the Web by asynchronously by opening the latest version of a given file, then editing it, then saving the file. The parties can use this interactive, web-based program and add-ons on their whiteboards, computer displays including tablets and pads. Collaborators can use Skype in video conference mode while they interact with each other, all the while drawing on the whiteboards. This approach allows an Engineer in Japan to discuss the design of the the PV Shpelar substrates with engineer in UK who is designing the Air Cell Pneumatic Building on which they will be installed, in either real-time or asynchronously. While most design firms have been steeped in AutoCAD, Sketchup is far ahead in terms of ease of use and an easy learning curve in that there are a huge number of tutorials on YouTube for free use. Wiley has published a “Bible” for advanced users of Sketchup Pro. The beginner can start with the free download and when comfortable with the technology, move to the Pro version. AutoCAD users can import their files directly into Sketchup. Rather than attempt to describe all of the features and uses of Sketchup, attached please find the paper on the subject: Google Sketchup.
  1. PICK-UP-AND-GO SHIPYARD
Most, if not all, traditional shipyards are ponderous, permanent affairs and not given to re-purposing when the shipyard is closed. Caruthersville, MO, suffered the closing of the Trinity Industries shipyard with the loss of about 500 highly skilled, highly paid metal workers. Over the last 20-30 years most of the capital steel vessels have been built in foreign shipyards because of the huge difference in labor costs. It's time to re-invent the ship building industry in the U.S. by using locally sourced, renewable Black Locust, Southern Yellow Pine and, hopefully, locally sourced bamboo, in order to build wooden ships which don't rust. We can start on that path with a grant from EPA for the working drawings. We have the design criteria to the point of practical completion. The location of nearly all river-side shipyards exposes them to serious damage from floods and extensive delays in construction, thus adversely impacting cash flow and worker employment. MASA's design for the shipyard by-passes these impacts by choosing design criteria which allows the entire yard to be struck and loaded on a barge or flat-bed trailers and thus avoid the devastating effects of flood waters. The choice of the technologies for the Assembly Building is critical to the success of this choice. The tent is a good solution, but not the best. Helium lift balloons avoid the costly use of a crane and a host of workers. Unlike a circus tent, we don't need elephants to raise or lower the tent poles for the Assembly I-Building. Our “risk management” approach is not to fight the flood waters with insurance premiums, but with common-sense ways of treating the flood waters not as “the enemy”, but taking them in stride. The cost savings including no, or greatly reduced, flood insurance premiums, a minimal interference with the production of the work-in-progress, and very little post-flood damage clean-up. Considering the nature of the Air Cell Technology, the Carp Catcher's crew can easily learn to raise the Assembly I-Building and deflate it. The carbon footprint as compared to a typical steel girder framework with steel sheeting, is a very small fraction, especially if one does a zero-sum analysis from the time the iron ore is mined to when the steel is in place. The combination of light weight and the pliable structure of the Air Cell Pneumatic Building allows the CC crew to move quickly at low cost to prevent flood and high wind damage The structure is “light weight” as opposed to traditional building materials . Shipping, handling and erection costs are a pittance of the cost of traditional steel buildings, when considering the multiple layers of the “chain of supply”. The portability of the entire shipyard moving between summer and winter locations will yield substantial energy savings over the life cycle of the shipyard. Use of the Econo Energy space heaters and boilers which re-use waste oil, is another substantial savings; this units are easily transported. The PEX radiant heating tubes simply stay in the gravel pad until their next use. Water or water/glycerol mix will fill the “torus” warm water generating tubes placed at the foot of the side walls. These tubes, about three feet in diameter by 40 feet, will convert the Sun's radiant energy into warm water which can be parsed to the PEX tubes during cool weather, thereby avoiding the use of the more costly energy systems using waste oil. Supplemental heat for the radiant energy system can also be provided by the Econo Heat boilers and a heat-exchange tank. [www.econoheat.com ] EPA has exempted units of 500,000 BTU and lower from the emissions regulations. Scientific testing of these type of waste oil boilers has proved they reduce emissions by half as compared to large power plants burning coal or No. 6 bulk fossil fuel. When forced air ducts are to be used, they can be built-in to the building fabric and are self-suspended by welding to the underside of the roof fabric. The cold air from the evaporative coolers can easily be routed to the work locations by down-draft ducts from the overhead main supply ducts. This approach, plus local fans, brings the cooling air into immediate contact with the workers. Use of low-heat LED lighting is another innovation not only to reduce heat generated by lighting, but also to reduce energy costs. The MASA plan is to design the LED lighting system as an “off-grid” source of illumination by using the Kyosemi Shpelar PV panels which will be glued to the outside of the “roof” of the Assembly I-Building. Direct current from the PV panels will keep the Zinc-Air Battery Bank charged so that the LED's will light the work area during the dark hours. The environmental footprint will be extremely light. The land is relatively flat and at the river's edge. It has a history of being used for a ship landing and is currently being used by a boat club. The compensating planting of bamboo will directly off-set the few trees to be selectively removed. The environmental review will likely be less complicated and will occur much faster. In addition to avoiding the impact of floods, hurricanes, tornadoes, expensive heating and cooling seasons, we need to be able to deal with “local politics”. Should the local policies “un-invite” Carp Catchers from a location, it will always have alternate locations in which to continue operations. We would hope to be a major, positive contributor to the local economy in which each shipyard is located. Best of all, our workers will also be mobile as we will encourage them to use the services of one or more local trailer parks and rental housing. Disruptions will be minimal because each worker will essentially have two home communities. As compared to life in the military with moves every two or so years, the Carp Catcher's shipyard workers lives will be much more stable.

Respectfully submitted, James E. Miller, BA, BS, JD President, Mutual Aid Society of America, Inc.
Cc: Michael Russ: russ.michael@epa.gov; Dave Cowgill, Phone: 312-353-3576; Email: cowgill.david@epa.gov' Attachments: Google Sketchup


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