United States                  EPA-600/R-94-022
            Environmental Protection
            ABencv                     February 1994
<&EPA     Research and
            Development
            PROCEEDINGS:

            POLLUTION PREVENTION CONFERENCE ON

            LOW- AND NO-VOC COATING TECHNOLOGIES
            Prepared for
            Office of Pollution Prevention and Toxics
            Prepared by
           Air and Energy Engineering Research
           Laboratory
           Research Triangle Park NC 27711

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                        EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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 POLLUTION PREVENTION CONFERENCE ON
LOW- AND NO-VOC COATING TECHNOLOGIES
                May 25 through 27, 1993
                 San Diego, California
      Coleen M. Northeim and Ella J. Darden, Compilers
             RESEARCH TRIANGLE INSTITUTE
                    P.O. BOX 12194
      RESEARCH TRIANGLE PARK, NORTH CAROLINA 27709
                    Sponsored by:
          EPA Cooperative Agreement CR819541
          EPA Project Officer:  Michael Kosusko
    AIR AND ENERGY ENGINEERING RESEARCH LABORATORY
     RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
                     Provided for:
     U.S. ENVIRONMENTAL PROTECTION AGENCY
         OFFICE OF RESEARCH AND DEVELOPMENT
                WASHINGTON, DC 20460

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 POLLUTION PREVENTION CONFERENCE ON
LOW- AND NO-VOC COATING TECHNOLOGIES
                   Sponsored by:
     VS. ENVIRONMENTAL PROTECTION AGENCY
    AIR AND ENERGY ENGINEERING RESEARCH LABORATORY
             ORGANICS CONTROL BRANCH
          RESEARCH TRIANGLE PARK, NC 27711

                      and

          RESEARCH TRIANGLE INSTITUTE
          CENTER FOR ENVIRONMENTAL ANALYSIS
           POLLUTION PREVENTION PROGRAM
        RESEARCH TRIANGLE PARK, NC 27709-2194

                      and

 AMERICAN INSTITUTE FOR POLLUTION PREVENTION
             UNIVERSITY OF CINCINNATI
               CINCINNATI, OH 45221
                       11

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                                     TABLE OF CONTENTS

                                                                                          PAGE

INTRODUCTION  	vi

SESSION 1   OPENING	  1
       Welcome Address     Richard J. Sommerville/San Diego County
                             Air Pollution Control District	  3
       Keynote Address      Paul J. Eisele/Masco Corporation
                            A Manufacturing Company's View of Low VOC Coatings	  5
       Papers Presented:
              Coatings Research in the U.S. EPA's Organics Control Branch  	  13
              Using Life Cycle Analytical Techniques to Assess Alternative Coating Systems	  25

SESSION 2   TECHNOLOGIES	  41
       Papers Presented:
              Radiation Curing Technology: Ultraviolet (UV)
               and Electron Beam (EB) Processing	  43
              Environmental Compliant Thermoplastic Powder Coating  	  51
              Supercritical Fluid Spray Application of Low-Pollution Coatings
               for Plastic Substrates	  65
              Utilizing Dispersion Resins with Inorganic Solids in a New Formulary Blending
               Process to Achieve Synergistic Results of Performance (Expanded Abstract)	  77

SESSION 3   POWDER COATINGS  	:	  79
       Papers Presented:
              Advantages of Powder Coating	  81
              Aerospace Applications for Powder Coating at Hughes Aircraft Company	  89
              Fluoropolymer Coatings for Architectural, Automotive
               & General Industrial Applications	101

SESSION 4   FEDERAL PROGRAMS	113
       Papers Presented:
              U.S. Navy Compliance to Shipbuilding and Ship Repair Environmental Regulations	115
              Low-VOC Coatings Developed by DOE for
               Environmentally Conscious Manufacturers	139
              The Precedent-Setting Use of a Pollution Prevention Project in an EPA
               Enforcement Settlement:  The First Dollar-for-Dollar Penalty Offset	157
              Army Pollution Prevention Success Stories  	181

SESSION 5   ENCOURAGING POLLUTION PREVENTION	191
       Papers Presented:
              Pollution Prevention Opportunities in Coatings: Educating Those Who are
               Responsible for This Task	193
              Economic Incentives to Stimulate the Development and Diffusion of
               Low- and No-VOC Coating Technologies	205
              Pollution Prevention in the Wood Refinishing Industry  	219
              The Importance of Product Stewardship and  Its Impact
               on Pollution Prevention	227
                                               111

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                                     TABLE OF CONTENTS
                                             (Contd)
                                                                                          PAG
 SESSION 6    INORGANIC COATINGS	2-
        Papers Presented:
               Long-Term Corrosion Protection with Single-Coat, High-Ratio Zinc Silicate 	2-
               Two Surprises from Inorganic Zinc-Rich Silicate Coating
                A reactive semiconductor approach to surface protection	24
               A New Inorganic Coating for Magnesium Alloys with
                Superior Corrosion Resistance  	25
               Inorganic Chemistry as an Option for Formulating High Solids, Low- and
                Zero-VOC Architectural, and Industrial Maintenance Coatings	21

 SESSION 7    HIGH SOLIDS AND WATER-BASED COATINGS	28
        Papers Presented:
               The Development of Practical Zero-VOC Decorative Paints	28
               New Environmentally Acceptable Metal Coating Systems  	29
               Water-Reducible Polyurethane Coatings for Aerospace Applications	31

 SESSION 8    APPLICATIONS 1  	32
        Papers Presented:
               Water Based and UV-Cured Coatings for Plastics	32
               Water-Borne Lacquers for Aluminum Foil	33
              Lower-VOC Coating System  Conversion Costs
                for the Wood Furniture Industry	34
              Development of Ultra-Low VOC Wood Furniture Coatings	35

SESSION 9   AEROSPACE APPLICATIONS	36
       Papers Presented:
              Replacement of Chromated Epoxy Primers/Wash Primers for
                Ground Support Equipment and Space-Related Flight Hardware	36
              An Investigation of Flexibility Test Methods for
                Low-VOC Aerospace Coatings	37
              Waterborne Maskant	35
              Low-VOC  Organic Coatings for Commercial Aircraft Application  	4C

SESSION 10   AUXILIARY SYSTEMS	41
       Papers Presented:
              Low Volatility Surface Preparation: A Hybrid Approach   	41
              Transfer Efficiency and VOC Emissions of
               Spray Gun and Coating Technologies in Wood Finishing   	4;
              You Can't Always Judge a Paint Spray Gun Cleaning System by Its Cover	44
                                               IV

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                                   TABLE OF CONTENTS
                                           (Contd)
                                                                                       PAGE
SESSION 11  APPLICATIONS 2  	461
       Papers Presented:
             Priority Manufacturing and Environmental Issues at Military Industrial Facilities	463
             Low-VOC Dual-Cure Aerospace Topcoat	467
             UV Pollution Prevention Technology in Can Manufacturing	475
             Pollution Prevention Opportunities in the Manufacture of Paint and Coatings	489

Appendix A   REGISTRANTS	  A-l

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                                  INTRODUCTION

        Surface coating operations release approximately 19 percent of stationary area source
 volatile organic compound (VOC) emissions1.  Many of these sources cannot be impacted by
 add-on controls at a reasonable cost due to their small size and/or the difficulty of capturing
 emissions. The reduction of solvent emissions from architectural and other coatings continues
 to rely on prevention technologies, such as the replacement of VOC with water or
 nonphotochemically reactive solvents, the use of high solids coatings, or improvement of the
 efficiency of transfer of the coating to the coated surface.  In current practice, reformulation
 with nonphotochemically reactive solvents may lead to other environmental problems,  such as
 increased toxicity, greater stratospheric  ozone depletion potential, and worsened multimedia
 effects.

        A conference tided, "Pollution Prevention Conference on Low- and No-VOC Coating
 Technologies," was held on May 25 through 27, 1993 in San Diego,  California. The
 conference was sponsored by the U.S. Environmental Protection Agency (EPA), Research
 Triangle Institute (RTT), and the American Institute for Pollution Prevention (AIPP). The
 primary purpose of the conference was  to provide a forum for the exchange of technical
 information on coating technologies.  Specifically, the conference was designed to focus on
 improved and emerging technologies  that result in fewer VOC and toxic air emissions  than
 traditional coating systems.

       Approximately 230 people attended the conference.  Of these  attendees, about 50
 percent were from industry, 40 percent  from  government, and 10 percent from  consulting
 firms and universities.  There were nine foreign registrants:  three each from Taiwan and the
 United Kingdom; and one each  from  Sri Lanka, Norway, and the Philippines.  Conference
 registrants are listed in  Appendix A.

       Technical papers presented at the conference were divided into 11 sessions focusing
 on different topical areas including  coating technologies, specific coating applications and
 case studies, application equipment, and pollution prevention concepts.  Several papers
 focused on  new products and improvements in these areas, such as an electrophoretic urethane
 coating from Great Britain, a zero-VOC house paint from Glidden, and developments
 involving inorganic polymers such as zinc silicates and silicones. Coatings for substrates,
 such as metal  (aerospace),  wood (furniture),  plastic, foil, and concrete, were also discussed.
    'U.S. Environmental Protection Agency.  1993. Regional Interim Emission Inventories (1987-1991),
Volumes I and II. EPA-454-R-93-021a and EPA-454-R-93-021b. U.S. Environmental Protection Agency,
Office  of  Air Quality Planning and Standards, Research  Triangle Park,  North Carolina.  May.
                                           VI

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                          SESSION 1
                            OPENING
                       WELCOME ADDRESS
                                 by
                        Richard J. Sommerville
                      Air Pollution Control Officer
                San Diego County Air Pollution District
                         San Diego, California
                             KEYNOTE
         "A Manufacturing Company's View of Low VOC Coatings"
                                 by
                             Paul Eisele
            Director of Health, Safety & Environmental Affairs
                         Masco Corporation
                           Taylor, Michigan
                       PAPERS PRESENTED:

       "Coatings Research in the U.S. EPA's Organics Control Branch"
                                by
                           Michael Kosusko
                 U.S. Environmental Protection Agency
            Air and Energy Engineering Research Laboratory
                 Research Triangle Park, North Carolina

'Using Life Cycle Analytical Techniques to Assess Alternative Coating Systems"
                                by
                           Keith A. Weitz
                       John L. Warren (Speaker)
                      Research Triangle Institute
                    Center for Economics Research
                 Research Triangle Park, North Carolina

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                             WELCOME ADDRESS

                                          by

                                    R. J. Sommerville
 As the air pollution control officer for San Diego County, I'm gratified to see an entire
 conference devoted to pollution prevention. It's in all of our best interests to eliminate
 pollution  at the source.

 Effective  prevention measures can reduce the need for stricter regulations in the future.

 We've all heard a lot of talk lately about how the  cost of regulations in California are chasing
 businesses away. The simple fact is that California is a leader in air pollution regulations—
 because it's a leader in producing smog. California is home to 3 of the 10 smoggiest cities in
 the country.  Environmental regulations are one of the compromises we make in order to
 continue living and working in one of the best  climates in the world.

 But that doesn't mean we can't do things better.  At the San Diego Air Pollution Control
 District, my staff has literally spent hundreds of hours with business owners and the military
 to gather  their input on everything from  rule development to permit program streamlining.

 Fortunately, California has become a pioneer in producing low-volatile organic  compound
 (VOC) and VOC-free coatings. Also, coating manufacturers are currently marketing products
 that exceed regulations in anticipation  of stricter rules in the future.

 Individual companies are also taking the initiative  to reduce or eliminate the use of coatings
 that contain VOCs.  For example, BASF has developed a new VOC-free, water-based
 adhesive bonding primer for the aerospace  industry. The company is also developing VOC-
 free, air-dried primers which could possibly be used in conventional metal shops.  Another
 company has begun using powder coatings as a substitute for high-VOC,  high-performance
 architectural coatings.

 Southern California Edison of Irvindale,  California has created a Customer Technology
 Application Center.  The center features  a demonstration facility and educates industry about
 low-VOC coatings, new spray equipment, and new curing methods including ultraviolet,
 radio-frequency, and infrared materials.  Its staff works with painters to assist them in
 converting to water-based and high-solid coatings.

The center has also made a lot of progress in finding  solutions to meet the needs of individual
companies, particularly in the area of water-based  wood product coatings. The low-VOC,
water-based coating now produces a more durable finish than standard lacquer.  One user
accidentally spilled his coke over a piece of furniture  he was working on. The  soda was left
on the wood overnight and didn't even make a mark.
                                           3

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Throughout the conference today and tomorrow, you will have the opportunity to leam about
other developments in VOC-free and low-VOC coating technologies and products, as well as
new applications for them.  Please keep in mind that your air quality district is there to help
you adapt to these new coating methods. Don't hesitate to use our expertise to help make
your lives easier and your businesses more successful.  We're on the same team.  Thank you
very much.

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 (The woik described in this paper was not funded by the U.S. Environmental Protection
 Agency.  The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)
                      A MANUFACTURING COMPANY'S VIEW
                              OF LOW VOC COATINGS

                                     Paul J. Eisele
                     Director Health, Safety & Environmental Affairs
                                  Masco Corporation
 Introduction
       Any discussion of low VOC coatings must have a ground  work laid to determine the
 perspective of the presenter.  Masco Corporation and its sister company MascoTech (formerly
 Masco Industries) are manufacturers of consumer products and industrial products respectively.
 Masco Corporation is the largest manufacturer in the U.S. of furniture and kitchen cabinets, thus
 wood products.  Masco is also the largest manufacturer of plumbing products, faucets, tubs and
 spas. MascoTech is a leading manufacturer of automobile parts and architectural products like
 windows and doors.  I stress that Masco is a manufacturer concentrating on manufacturing
 processes for simple products.  Forbes Magazine called Masco "Masters of the Mundane".  I
 say all this to preface the fact that we focus on making simple products better.  Coatings are an
 important component of many of our products.  Finishing in the  Masco "mind" varies from
 electroplating of brass, coating metal doors, painting plastic auto parts to finishing wood. Masco
 is not a finish supplier but rather a coating user.  The Company expects most coating R & D
 to be done by its suppliers not in our R & D labs.  We do however invest considerable time in
 testing application, durability and performance of coatings within the divisions like Delta Faucet
 and Drexel Heritage  Furniture.  The Company does strive to reduce emissions of VOC and air
 toxics through a  fairly standard  mix of pollution prevention, control equipment and coating
 application.

 Pollution Prevention

      The Company has approached pollution prevention as both  a cost saver and regulatory
 initiative.   From a regulatory standpoint the Pollution Prevention Act fit into our existing
 programs in media specific regulatory initiatives in the Clean Air Act and CERCLA for example
 (Figure  1).  In addition the Company was asked by the USEPA to participate in the voluntary
 Industrial Toxics Program also known as 33/50. The Program calls for voluntary reductions in
 emissions of some seventeen toxic compounds by 33% in 1992 and  50% by 1995.  Many of the
 target compounds are also VOC's including xylene, toluene, methyl ethyl  ketone and methyl
 isobutyl ketone which are also common solvents in coatings.  Both Masco companies achieved
greater than  33% reductions through  1992  (Figure 2).  The greatest reduction in Masco
 Corporation was made by the Home Furnishing divisions which  include -furniture and  fabric
 manufacturing (Figure 3).  The  reductions  result from such  factors as use of higher transfer
coating application technologies such as high volume low pressure (HVLP) spray guns, limited
 use of water borne coatings, and improved manufacturing process resulting in lower rework and
cleaning. The greatest reduction in MascoTech was made by the Architectural Product  group

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  which include door and window manufacturing (Figure 4).   Most  of the reductions were
  achieved by use of waterborne coatings and glues or powder coating on metal parts, as well as
  purchase of precoated steel.  The Companies have found greater applicability of waterborne
  coatings to metal because the substrate can be made more uniform for water coatings than can
  other substrates like wood or plastic.

  Low VOC Coatings

        Masco generally relies on the marketplace for new coating technologies, that  is,  we do
  not attempt to develop our own coatings.  Advances are a result of collaborative efforts between
  the Company and finishing suppliers.  This is very typical of manufacturers.  In some instances
  the product may dictate extensive R & D to use lower VOC coatings.  One such example is
  automotive headlight manufacturing done by MascoTech Coatings.  Industry demands for light
  weight vehicles without sacrificing safety have led to utilization of composite materials in  autos.
  The coating demands  are  great  since in  some instances they play an important role  in the
  function.   MascoTech  uses silicon  to  coat poly carbonate  lenses  as well as UV inhibitor to
  prevent cracking to give the plastic the properties of glass. The plastic light housing is vacuum
  metalized and then conventionally topcoated to give the reflective properties. The resulting head
  or tail lamp assembly is much lighter than the old assembly made of glass and metal with no loss
 of quality.  Vacuum application is  very efficient, as low to no VOC  materials can  be used.
 MascoTech coating is now experimenting with a high solids base and top coat applied  in the
 vacuum chambers. There have been numerous problems in the fouling of the vacuum chambers
 to date but when perfected  this will  drastically reduce VOC emissions.

       The use of low VOC materials for wood coating has also been challenging. Lexington
 Furniture, a Masco Corporation company began attempting to use waterborne coatings in the late
 1980's in production.   To date its success  has been on particular wood species,  and finishes
 which do not require smooth, rich finishes, for example wicker, rattan and one oak suite.  Since
 that time  more lower VOC coatings  are being used in production but still limited  to particular
 woods and particular fashion looks.   Wood is a difficult substrate because of its porosity, non
 uniformity of substrate, swelling when moist, and inability  to apply high temperature drying.
 Henredon Furniture has had some success with a couple of suites.  Universal Furniture  is testing
 a reverse  hybrid system,  that is where waterborne stains  or color coats are used  followed  by
 coating with traditional nitrocellulose lacquers sealer and topcoats.  This means changes to
 conventional finishing in that extensive wiping and sanding must be done making it more labor
 intensive manufacturing.  It does  have the advantage of achieving VOC reductions without the
 disadvantage of difficult repair or rework.  Most waterborne coating approaches had utilized
 conventional stains on wood followed by waterborne sealers and topcoats.  A major problem has
 been  rework or repair because  waterborne topcoats are not as amenable as conventional
 nitrocellulose which is very forgiving and easy to remove or rework with VOC solvents.   This
 is especially frustrating for a wood furniture piece with extensive value added prior to finishing.

Summary

      Masco like many other manufacturers has found it easier to utilize low VOC coatings on
metal products rather than plastic or  wood.  Both plastic and wood are not uniform substrates

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for finishing materials and are susceptible to damage with high temperature drying or setting.
The Companies, both Masco Corporation and MascoTech, have had far greater success to date
in reducing VOC's  by  a combination of better solvent management, improved application
technologies and some use of conventional controls rather than by low VOC coatings for non
metal materials.  With more research on finishing material chemistry and application, low VOC
coatings will become a bigger share or "piece" of the VOC reduction "pie". Activities like this
workshop are necessary  to insure that recent advances are known and understood so that they
can be assimilated into  the mainstream of manufacturing.   Some of us wish that low VOC
coatings were available and usable for all of products now. The Company and its suppliers are
committed however to continuous improvement  in its products and manufacturing processes  to
utilize the complete mix of technologies to reduce VOC and toxic emissions, which in the future
will be achieved through greater reliance on  low VOC coatings.

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                 FIGURE 1
      CERCLA
               INDUSTRIAL
                 TOXICS
00
RCRA
              Pollution
            Prevention
CWA
 STORM WATER
                          NPDES
                   SARA

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                    MUURE 2
     MASCO TOXICS PROGRAM
CO
CO
CO
CD
D)
c8
O
CO

Q
CO
T3
C
D
O
CL
   5000
4000
   3000
   2000
1000 -
     0 -
     1988
                               Masco Corporation

                            • • • • • MascoTech, Inc.
        1989
1990
1991
1992

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                           FIGURE 3
           MASCO CORPORATION
            TOXICS REDUCTION PROGRAM
CO
T3
C
cd
CO
13
O
    3000
b,
 Q)
 D)

 (5
 O
 CO
b
 CO
 C
 Z3
 O
 CL
2000 -
1000
                                  Home Furnishings

                               • • • • • Building Products - Wood

                               *• ••• • Building Products - Plumbing
       1988   1989   1990   1991   1992

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              MASCOTECH, INC.
            TOXICS REDUCTION PROGRAM
CO
T3

03
CO
ID
0)

E>
03

O
CO

Q

CO
13
O
0.
    1500
    1000
500
 0
                                     Architectural Products

                                     Transportation

                                     Miscellaneous
       1988
         1989
1990
1991
1992

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12

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   COATINGS RESEARCH IN THE U.S. ERA'S
       ORGANICS CONTROL BRANCH
             Michael Kosusko
     U.S. Environmental Protection Agency
Air and Energy Engineering Research Laboratory
          Organics Control Branch
    Research Triangle Park, North Carolina
                     13

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ABSTRACT

      This paper provides a brief overview of research and development
projects in the Organics Control Branch of  the U.S.  Environmental
Protection Agency's  Air  and Energy Engineering Research Laboratory
that  impact on surface coating processes.   Projects  can be
characterized as:  (1) scoping studies,  in which an industry or process
is characterized and pollution prevention  (P2) opportunities are
identified;  (2)  technology  assessment  and development projects, in
which the feasibility of specific coating technologies or P2
techniques is evaluated;  (3)  demonstration  projects, in which methods
of reducing emissions are tested in cooperation with industrial
partners;  or (4)  technology transfer projects, such  as this
conference.   Scoping projects are ongoing for paper  and other webs
(surface coating) , furniture restoration and repair, printing,
architectural and industrial maintenance coatings, consumer/commercial
adhesives,  and roofing.   Technology assessment and development
projects are ongoing to  evaluate very  low-VOC, non-waterborne coatings
and a  2-component  epoxy  topcoat for wood furniture manufacturing,  to
identify technical barriers to the  use  of radiation-cured and
waterborne coatings, and to assess  innovative ink-feed systems for
printing.   Demonstration projects are planned for auto body
refinishing,  for  coated  and laminated substrate manufacturing (i.e.,
the use  of aqueous adhesives  and of alternative equipment cleaning
methods),  and for  the design of recirculating spray booths
incorporating VOC  concentration gradient phenomena.
                                   14

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 (This  paper has been reviewed in accordance with the U.S.
 Environmental Protection Agency's peer and administrative  review
 policies and approved for presentation and publication.)


 INTRODUCTION

       •For more than two decades, the U.S. Environmental Protection
 Agency's (EPA)  Air and Energy Engineering Research  Laboratory  (AEERL),
 located in Research Triangle Park, North Carolina,  has  been  exploring
 control approaches for the pollutants  and sources that  contribute  to
 air quality problems.   AEERL has successfully developed and
 demonstrated cost-effective sulfur dioxide,  nitrogen oxides, and
 particulate control technologies for fossil  fuel combustion  sources.
 More recently,  it  has  expanded its interest  to areas that  include
 indoor air quality,  radon,  organic control,  stratospheric  ozone
 depletion,  and global  warming.   The AEERL also develops inventories of
 many types of air  emissions.   Over the past  several  years, AEERL has
 made a substantial effort  to expand pollution prevention as  the
 preferred choice to reduce air emissions.   Its goal  is  to  conduct
 research that will result  in the greatest  possible reduction of  air
 pollution for the  lowest  cost.'1

      The Organics Control Branch (OCB) of AEERL  is  charged with
 developing and assessing pollution prevention (P2) techniques and add-
 on  control technologies for reducing organic air emissions;  i.e.,
 organic air toxics (hazardous air pollutants [HAPs]) and volatile
 organic compounds  (VOCs).   OCB's P2 research is focused in three
 technical areas:  (1) Surface Coating,  such as wood furniture
 finishing,  printing, and the use of adhesives and radiation-cured
 coatings;  (2)  Solvent  Cleaning,  such as vapor degreasing,  process
 equipment cleaning,  and in-process precision cleaning; and (3)
 Consumer/Commercial  Products  (C/CP), including traditional consumer
 products  (e.g., hair spray  and  household  cleaners) and non-process
 solvent use in  commercial operations such  as textile manufacturing,
 roofing,  and furniture refinishing.  Each  of the industries  with which
 OCB  is working  has concerns about emissions  from each of OCB's
 technical areas.   Most of these industries use surface coatings, use
 solvents  (to prepare surfaces for coating  or to clean equipment), and
 use a wide variety of  prepackaged commercial products in their
 facilities.   This  paper will  discuss OCB's projects  that impact
 surface coating operations.   Projects  and project contacts are
provided Appendix  I.

     Generally,  projects  in the Organics Control  Branch can  be  divided
 into four categories:

 (1)   Scoping Studies characterize an industry or  process and its
     emissions and identify P2  opportunities to  reduce  those
     emissions.  Scoping projects are  ongoing for  furniture
     restoration and repair,  paper and other webs coating, printing,
     roofing, architectural and industrial maintenance  (AIM) coatings,
     and consumer/commercial adhesives.

 (2)   Technology Assessment  and Development Projects evaluate the
     technical  and economic feasibility of specific coating
     technologies  or P2 techniques.  Technology assessment and
     development projects  are ongoing  to evaluate very  low-VOC,  non-
     waterborne coatings and a two-component epoxy  topcoat for wood

                                  15

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       furniture manufacturing, to identify technical  barriers to the
       use of radiation-cured and waterborne coatings,  and to assess
       innovative ink-feed systems for printing.

  (3)   Demonstration Projects investigate methods  of reducing emissions
       in cooperation with industrial partners.  Demonstration projects
       are in the works for coated and laminated substrate
       manufacturing, for the design of recirculating  spray booths
       incorporating VOC concentration gradient phenomena,  and for auto
       body refinishing.

  (4)   Technology Transfer Projects:  Such as this  conference,  The
       Pollution Prevention Conference on Low- and No-VOC Coating
       Technologies,  or the development of information manuals or
       software evaluating prevention alternatives.

 SCOPING STUDIES

 Consumer/Commercial Products  (C/CP) Report to Congress (RTC) Support

       Information on non-process  solvent  use was  evaluated  for 15
 industrial and commercial source categories to characterize VOC
 emissions and identify P2 opportunities.  Non-process solvents are^
 used by industry, commercial operations, and/or individual consumers;
 they are not incorporated into a product or chemically modified  as
 part of the manufacturing process.  Project results will support a
 Report to Congress, required by §183 (e) of the Clean  Air Act
 Amendments of 1990  (CAAA), which addresses emissions  of VOCs from
 consumer or commercial products.   Successful P2 approaches will
 support regulatory efforts resulting from the  Report  to Congress.

      As a result of this evaluation,  five categories were selected for
 further study.  These categories  are:
      1)    Textile Manufacturing
      2)    Furniture Repair and Refinishing
      3)    Roofing
      4)    Hold Release Agents, and
      5)    Heating,  Ventilation and Air-Conditioning  (HVAC)  Coil and
            Parts Cleaning.
 For  each category,  a more detailed evaluation of  emissions,  emission
 sources,  and P2  opportunities is  being completed.  Three of these
 categories—Furniture Repair and  Refinishing; Roofing;  and Textile
 Manufacturing (e.g., screen printing)—use surface coatings.   Reports
 detailing emissions  and P2  opportunities for the  five categories are
 expected during  Fall 1993.

Assessment of Pollution Prevention (P2)  Opportunities in Five
 Industries

      In this small cooperative project with the  South Coast Air
Quality Management District  (SCAQMD),  emissions and P2  opportunities
have been assessed for  five  industries,  all of which use surface
coatings:  (1) Architectural  and Industrial  Maintenance  (AIM)  Coatings;
 (2) Consumer/Commercial Adhesives;  (3)  Rotogravure Printing;  (4)
Flexographic  Printing;  and  (5) Graphic Arts.  The final  report for
this project  is  expected  during Fall 1993.
                                   16

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 Source Reduction Review Program (SRRP)  Focus Groups

      The objective  of  the  Source Reduction Review  Program  (SRRP) is to
 ensure the consideration of P2 options  during the development of air
 toxic (also known as Maximum Achievable Control Technology [MACT])
 regulations for 17 of the many source categories to be regulated under
 Title III  of the CAAA by the year 2000.  The purpose of this project
 is to identify P2 opportunities via focus group input for five of
 these categories.  Of the five, only one is  a surface coating category
 (i.e.,  Paper and Other Webs).  The other categories are:  (1)
 Reinforced Plastics (Boat Building);  (2)  Integrated Iron and Steel
 Manufacturing; (3) Plywood/Particle Board Manufacturing;  and (4)
 Acrylic/Modacrylic Fiber Production.  Focus  groups  will include the
 participation of industrial, governmental, and academic experts in
 order to get as broad a perspective as  possible.  The Paper and Other
 Webs  focus group is scheduled to meet before September 30,  1993,  as
 are the Reinforced Plastics and Iron and Steel focus groups.

 TECHNOLOGY ASSESSMENT AND DEVELOPMENT PROJECTS

 Wood  Furniture Finishing

      Status and Future Developments in Very Lov-VOC Coatings.  The
 objective  of this project is to establish the status of research and
 development (R&D)  and market development  for very low-VOC coatings
 used  for wood furniture finishing.   Information will be gathered
 through contacts with resin suppliers,  paint  manufacturers, wood
 furniture  manufacturers,  and their trade  associations.   The question,
 •What  is really available in terms of low-VOC coatings?"  will  be
 addressed  as will the status of ongoing development projects.   The
 technical  barriers and concerns of industry  about these coatings will
 be identified and addressed.  Opportunities  for demonstrating  very
 low-VOC coatings for wood furniture finishing will  be identified.  The
 final report for this project should become  available during the Fall
 of 1993.

      Waterborne Two-Component Epoxy Topcoats.  Details of this project
 will be presented on Wednesday afternoon.  May 26, 1993,  at  this
 conference.   The paper will be available  in  the conference  proceedings
 (pages  357-365) .   This project is  cooperatively funded with SCAQMD.  A
 two-component  water-based epoxy resin coating system containing less
 than 0.08  Ib/gal  (10 g/1) VOC has  been  developed as both clear and
 white-pigmented topcoats.   These topcoats  have met  most performance
 criteria including:  (1)  a VOC content of  less than  0.08 Ib/gal;  (2)
 high gloss;  (3)  dry  to touch in 10  minutes or less,  dry to  handle in
 15 minutes  or  less;  and (4)  a 2H pencil hardness.

 Technical Barriers to the Use of Radiation-Cured and Waterborne
 Coatings

      This  project is part of SRRP and is just underway.  The use of
 radiation-cured (e.g.,  ultraviolet  [UV]-cured and electron  beam [EB]-
 cured) or water borne coatings is a  P2 option  for several  SRRP  source
 categories.  However,  technical barriers  to  their broadened usage such
 as concerns  about  toxicity  and the  difficulty of  coating  complex parts
using radiation-cured coatings exist.   The objective of this project
 is to identify and characterize these technical barriers  and to
 identify and complete  critical research to overcome them.
                                   17

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  Innovative Ink Feed Systems

       This project is also part of SRRP and is just underway.  The
  systems  (e.g.,  piping,  tanks,  and mixers)  used to feed ink  to printing
  presses  and their subsequent  cleaning requirements are the  source of
  substantial volatile organic  HAP  emissions.   Substitute infc feed
  systems  could  substantially reduce these  emissions.

  DEMONSTRATION  PROJECTS

  Auto Body  Refiniehing

       This project is being completed cooperatively with SCAQMD.   Its
  objective  is to demonstrate a  P2  technique or  techniques to  reduce
  volatile organic  emissions  from auto  body  refinishing  operations.
  Although project  details have  not yet been finalized,  we will probably
  work with  a university-based paint research center to  field- or pilot-
  test innovative,  low- or no-VOC coatings that  have been proven at the
  bench-scale.  Work is expected to be  underway  during 1993.

  Retrofit of Existing Solvent-based Flexible Substrate  Coating
  Equipment  to Use  Water-based Coating  Systems

      The coated and laminated substrate manufacturing  industry makes a
 wide variety of pressure sensitive products such as masking, cloth
  (duct), and cellophane tapes,   tags, labels, and a number of exotic
  laminated products.  It was selected  for study because of significant
 air emissions of methyl ethyl  ketone  (MEK) and toluene reported in the
 1990 Toxics Release  Inventory  System  (TRIS)2;  i.e.,  it  is the #1 source
 for MEK  (8,050 tons[7,300 Mg]) and the #3 source for toluene (13,000
 tons[11,800 Mg]).   A focus group,  including members of the Pressure
 Sensitive Tape Council (PSTC)  and the Tag and Label Manufacturers
 Institute  (TLMI),  and academic and state environmental experts,  helped
 OCB identify opportunities for significant reductions of organic HAP
 emissions in this  industry.

      The use of solvent-borne  coatings (e.g.,  adhesives) was
 identified as the  primary source of the industry's toluene and  MEK
 emissions.   The key barriers to the use of waterborne coatings  by
 small  firms in this industry are:  (1)  The capital cost of purchasing
 new equipment which could use  waterborne adhesives and (2)  The  lack of
 readily available  technical  information which would allow the
 retrofitting of existing solvent-based equipment to use waterborne
 coatings.   PSTC representatives from large companies indicated  that
 they would work with OCB to  document successful applications of
 retrofit  technology so that  a  descriptive  "how to" manual could  be
 developed for use  by small businesses  in the industry.   Once the use
 of waterborne coatings is  implemented  by small businesses,  significant
 toluene and MEK emission reductions would  be achieved.

     A report documenting background  issues for retrofitting equipment
 to use  waterborne  coatings should  become available during the Fall  of
 1993.   The  high level of industry  participation through the  PSTC will
 allow demonstration and documentation  efforts  to be initiated during
 1993.

Partitioned,  Recirculating Spray Booth

     Recirculation in paint  spray booths has been recognized for many


                                    18

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years as  a means  of  increasing  the concentration and reducing  the
volume of spray booth exhaust.  This allows the use of a  smaller add-
on  control device, hence  reducing air pollution control costs.  A
partitioned,  recirculating paint spray booth  is shown in  Figure 1.
Partitioning  of the  spray booth exhaust  stream takes advantage of the
VOC concentration gradient that exists vertically across  the booth
exit.  VOCs stratify in the booth, and their  concentration  is  greatest
closer to the floor.   By  pulling the booth exhaust stream from the
bottom portion of the booth and the recirculating stream  from  the top
portion of the booth,  the concentration  of the exhaust stream  can be
enhanced, perhaps reducing the  exhaust volume to be controlled below
that of a simple  recirculating  booth.  Preliminary field  tests have
shown the feasibility of  reducing controlled  air volumes  by 50-75%
below those of non-recirculating booths.

      A demonstration of the stratified recirculation  concept  is
planned at the U.S.  Marine Corps  (USMC)  Maintenance Depot near
Barstow,  California.   The demonstration  will  be completed
cooperatively with the Marine Corps and  Penn  State University.  During
the demonstration, an existing  spray booth will be modified to use
both recirculation and partitioning.  A  movable plenum will be used to
evaluate  the  optimum height for flow partitioning.  An additional
control technology will be evaluated during the demonstration.  Spray
booth exhaust will feed to an add-on control  device supplied by Terr-
Aqua which uses UV light  to destroy organics  absorbed on  a catalytic
substrate, scrubbing with ozonated water, and a final activated carbon
polishing step.

Paint Application Technology

      Evaluation of  Ultra Low Volume  (ULV)  Spray Gun System.   The
objective of  this project is to evaluate an ULV spray gun system.
Tests have been completed cooperatively  with  the U.S.  Air Force at
Warner-Robins Air Force Base, Georgia.   Qualitative results of the
test are  promising.   A large improvement of paint utilization
efficiency was attributed to the enhanced paint lay down  or flow out
provided  by the gun.   This and  the ability to spray high  viscosity
paints (which contain fewer solvents) have led to a 50 to 75%
reduction in  VOC  emissions.  The final project report is  expected
during Fall 1993.
                                   19

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                  FRESH MAKEUP
                  AIR INTAKE
 BOOTH INTAKE
     DUCT
RECIRCULATION
    DUCT
                                                          SPLIT Fl
                                                            DUC
                                                    TO EXHAUST
1. The Partitioned,  Recirculating Spray Booth Concept
                            20

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      Spray Qun Cleaning.  The purpose of this project is to compare
 emissions from two types of paint spray  gun cleaning equipment (i.e.,
 open and closed systems) to each other and to those from current
 cleaning practices.  In the open system,  cleaning solvent is  sprayed
 from the gun, with its spray tip removed,  into an open container that
 is shaped to minimize solvent bounce-back and that has air flow into
 the bottom of the container.  The closed system consists of spraying
 cleaning solvent through the gun while it  is enclosed in a capture
 device.   This project, which should be completed during Fall  1993,  is
 being done in support of EPA's Control Technology Center (CTC).   The
 CTC provides technical support to local,  state,  and EPA Regional
 environmental personnel, small businesses,  and international  clients.
 It is co-sponsored by AEERL and EPA's  Office of  Air Quality Planning
 and Standards.

 TECHNOLOGY TRANSFER

      Technology transfer  (T2) is the final  and,  perhaps,  the  most
 important type of project activity in  the Organics Control  Branch.
 Through  T2, the results  of OCB's  research are provided to the people
 who can  use it,  hopefully in a format  that  they  can easily  use.   T2
 also provides OCB an opportunity to interact  with its potential
 clients  (i.e.,  through workshops and conferences)  to better understand
 their needs and the status of technology in many industries.  The most
 straightforward means of providing information to potential users are
 project  reports and presentations at large  professional  conferences.
 However,  these mechanisms are not necessarily targeted at  the user
 community.   Some of the difficulty of  reaching the right audience can
 be overcome by providing report  copies to local,  state,  and regional
 P2 and small  business assistance providers,  the  Control  Technology
 Center,  and industry trade associations.  Information can  also be
 distributed through P2 data bases and  electronic bulletin boards  such
 as the Pollution Prevention Information Clearinghouse (PPIC)  which,  as
 part of  the Pollution Prevention Information  Exchange System  (PPIES),
 is managed by EPA's Office of Environmental Engineering  and Technology
 Demonstration.

      EPA-sponsored workshops and conferences provide an opportunity
 for interacting directly with a  targeted audience.   OCB  has completed
 two conferences  for surface coatings.  The  Surface-Coating-Free
 Materials Workshop was held in July 1991, to  explore the potential  for
 development and use of materials that  would not  need to  be  coated
 during manufacture or recoated during  use.  If such materials were  to
 come into widespread use,  VOC and air  toxic emissions associated with
 surface preparation (cleaning),  coating, and  paint stripping  before
 recoating could be avoided.   A summary of this workshop  is  available
 from the National  Technical  Information Service  (NTIS)3.  This is the
 second conference.   The Pollution Prevention  Conference on  Low-  and
 No-VOC Coating Technologies is being held to  provide a forum  for
 exchanging technical information on innovative coating technology and
 to  allow EPA  to interact with industry, academia,  and others
 interested in surface coating technology.

      A third coatings conference has been proposed for March  1995,
with much the same objective as  this conference.   It would  probably be
 held  on the East Coast,  in the Raleigh-Durham, North Carolina, area.
A series of technology transfer  workshops may  also be proposed for
completion during  1994 to allow  OCB personnel  to present  the  results
of  their research  to,  and to interact  with, the  user community.


                                    21

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SUMMARY AHP CONCLUSIONS

      The Organics Control Branch has a broad program in pollution
prevention which  impacts  many  industries ranging from wood furniture
manufacturing to  coated and  laminated substrate manufacturing to
printing  ajid publishing.  Each of these industries has common
concerns.  They all  use surface coatings; most use solvents for
preparing surfaces for  coating or for cleaning equipment;  and all use
an abundance of prepackaged  commercial products.  This  paper
summarizes surface coating activities in OCB.  Although many of its
initial research  products are  nearing completion,  OCB  expects that  its
surface coatings  program  will  continue to grow and develop.   The input
of a broad spectrum  of  industry, academic, and other surface coating
experts,  such as  the attendees at this conference,  is needed to
continue  to enhance  the focus, quality, and content of  OCB's current
and future research  activities.

REFERENCES
1.    Shaver, E.M.,  "Pollution  Prevention for Cleaner Air:  EPA's Air and
      Energy  Engineering  Research  Laboratory, •  Pollution   Prevention
      Review, Winter  1992-93, pp.41-50.

2.    Toxic Chemical Release Inventory, National  Library of Medicine
      Toxnet System, U.S. Environmental Protection  Agency,  1990.

3.   Northeim, C.M., M.W. Moore,  and J.L. Warren,  Surface-Coating-Free
     Materials Workshop - Summary Report, EPA-600/R-92-159  (NTIS PB93-
      101160), August 1992.
                                   22

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 APPENDIX  I;   SUMMARY OP OCB PROJECTS AND PROJECT  CONTACTS
 I.    SCOPING
      A.    Consumer/Commercial Products Report to Congress
            1.    Furniture Repair & Refinishing
            2.    Roofing
            3.    Textile Manufacturing

      B.    Assessment of P2 Opportunities in Five Industries

      C.    Source Reduction Review Program (SRRP) Focus Groups

 n.    TECHNOLOGY ASSESSMENT AND DEVELOPMENT
      A.    Wood Furniture Finishing
            1.    Status and Future Developments in Very Low-VOC Coatings
            2.    Waterbome Two-component Epoxy Topcoats

      B.    Technical Barriers to the Use of Radiation-cured and Waterbome Coatings

      C.    Innovative Ink-feed Systems

 III.   DEMONSTRATIONS
      A.    Auto Body Refinishing

      B.    Retrofit of Existing Solvent-based Flexible Substrate Coating Equipment
            to Use Water-based Coating Systems

      C.    Partitioned, Recirculating Spray Booth

      D.    Paint Application Technology
            1.    Evaluation of Ultra Low Volume (ULV) Spray Gun System
            2.    Spray Gun Cleaning

 W.   TECHNOLOGY TRANSFER
      A.    Surface-coating-free Materials Workshop

      B.    P2 Conference on Low- and No-VOC Coating Technologies - San Diego

      C.    P2 Conference on Low- and No-VOC Coating Technologies - East Coast
                          R. McCrillis
                           J.Whitfield
                           M.Kosusko

                           M.Kosusko

                            C-Nunez


                          RMcCrillis



                            C.Nunez

                            CJMunez


                           G. Ramsey

                            C.Vogel


                            CDarvin

                            C.Darvin
                          M.Kosusko

                          M.Kosusko

                          M.Kosusko
TELEPHONE NUMBERS

      Chuck Damn
      Mike Kosusko
      Bob McCrillis
      Carlos Nunez
      Geddes Ramsey
      Chet Vogel
      Jamie Whitfield
      Control Technology Center HOTLINE
919/541-7633
919/541-2734
919/541-2733
919/541-1156
919/541-7963
919/541-2827
919/541-2509
919/541-0800
                                             23

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24

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)
         USING LIFE CYCLE ANALYTICAL TECHNIQUES TO ASSESS
                       ALTERNATIVE COATING SYSTEMS
 Keith A. Weitz
 John L. Warren
 Environmental Management Systems
 Center for Economics Research
 Research Triangle Institute
 Research Triangle Park, NC  27709
 INTRODUCTION

       Life cycle assessment (LCA) is a holistic approach to assessing the environmental and
 human health burdens associated with  a  given  product system.   It seeks to reconcile
 technology and ecology at each stage of the life cycle of products, processes, and activities
 from  acquiring raw materials to recycling or disposal by identifying system  inputs  and
 outputs;  assessing the potential  impacts  of those  inputs and  outputs on  the  natural
 environment, human health,  and natural resources;  and  implementing  opportunities for
 achieving improvements. Life cycle thinking starts before the cradle (R&D, design) and goes
 beyond the grave (recycling, re-use).1

      This paper describes the LCA process, which can be used to assess alternative low-
 and no-volatile organic compound (VOC) coating systems with the objective of minimizing
 potential  impacts to the environment and human health. In this context, LCA is useful for
 recognizing trade-offs between alternative coating systems that may not have eliminated
 environmental and human health impacts but merely transferred them to other life cycle
 stages.

      Currently, no  protocol exists for conducting an LCA.  However,  LCA generally
consists of the following components:

      Goal  Definition and Scoping:  Identifies the purpose and objectives of the LCA, as
      well as study boundaries, data  needs,  comprehensiveness, users of the  results,  and
      potential applications.
                                       25

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        Inventory Analysis:  Identifies and quantifies—to the extent possible—resource and
        energy inputs, air emissions, waterborne effluents, solid waste, and other inputs and
        outputs associated with a product system.  This information is compiled into a life
        cycle inventory.

        Impact Assessment: Identifies, characterizes, and values potential impacts of concern
        to the natural environment, human health, and natural resources associated with the
        inputs and outputs of a product system.

        Improvement Assessment:  Identifies, evaluates, and implements opportunities for
        environmental and human health improvements. Opportunities for improvements may
        be realized at any stage  of the LCA process.

        LCA is not necessarily a linear or stepwise process. Rather, as suggested by Figure 1,
 information from any component  can complement information from the other components.
 For instance, opportunities for environmental improvements do not necessarily stem from the
 life cycle improvement assessment but can be realized at any stage of the LCA process.  The
 inventory component alone may be used to identify opportunities for reducing inputs from
 or outputs to the environment.

                                    Improvement
                                    Assessment
                                     Goa/
                                    Definition
                                  and Scoping
                 Impact  *	•—•	       '             Inventory
               Assessment                                  Analysis

                           Figure 1. LCA Framework

APPLYING LCA TO EVALUATE LOW- AND NO-VOC COATING SYSTEMS

       Government legislation, such  as the 1977 and 1990 Gean Air Act Amendments, is
the major force behind the conversion from conventional to low-  and no-VOC coating
systems. Another motivation for this  conversion is to reduce or eliminate environmental and
human health  concerns associated with VOCs, such as photochemical smog and human
respiratory damage.

       However,  switching from conventional  to  alternative coating systems  may  be
exchanging one problem for another.  For example, an alternative coating system may replace
VOCs with other hazardous materials, or the alternative coating system may require special

                                        26

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 drying and curing equipment that significantly increases energy usage.  When switching to
 alternative coating systems, trade-offs besides reducing VOCs need to be evaluated. LCA
 may  be  an effective  approach for assessing such trade-offs.  We elaborate on  the LCA
 process summarized in the introduction of this paper by comparing a conventional coating
 system with a no-VOC powder coating system.  The characteristics of the two systems are
 as follows:

       •   Conventional coating system:  30 percent solids, 70 percent solvents
       •   No-VOC powder coating system: 100 percent solids, 0 percent solvents

 Table 1 provides a comparison of the basic components of conventional and no-VOC powder
 coating systems.

 Goal Definition and Scoping

       Goal  definition  and scoping forms  the basis of interrelationships between  the
 inventory, impact, and improvement assessment components.  As suggested in Figure 1, goal
 definition and scoping are both discrete activities and the basis of the  life cycle inventory,
 impact, and improvement assessment components.

       The goal definition activity clearly identifies and defines the purpose and objectives
 of the LCA at the beginning, as well as maintains consistency with the  goals and objectives
 of the study throughout the LCA process. An example of goal definition, which will also be
 used as the guiding goal  for purposes of this paper, is to assess alternative coating systems
 to choose the coating system that generates minimal environmental and/or human health
 impacts.

       The breadth and  depth of the LCA, or  scope, is governed by the defined study
 boundaries,  comprehensiveness,  data needs,  impact  areas  included  and  excluded,
 methodologies employed, users of results, and potential applications of the LCA (e.g., LCA
 as a baseline vs. comparative study).  The  scope of the LCA will undoubtedly be bounded
 by resource (i.e., money, time, technical expertise) constraints that limit  the practitioner from
 gathering and analyzing data for each and every possible component of  a system's life cycle.
 Thus the  primary goal of scoping in this case may be to match the level  of detail of the LCA
 with available resources while allowing the practitioner to achieve the  goal of the LCA.

       Because scoping may be both a discrete and integral component in LCA, it may occur
 at the beginning of the LCA and may be reevaluated when beginning or during the  inventory
 analysis  and the impact and improvement  assessment components.   For example, data
required to conduct an impact assessment may be missing from the inventory component or
may be of insufficient quality. In this case, the scope of the impact assessment, and thus the
overall LCA, may have to be constricted.
                                        27

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  TABLE 1. COMPARISON OF BASIC COMPONENTS OF CONVENTIONAL
                  VERSUS POWDER COATING SYSTEMS23
      Component
       Conventional Coating
Powder Coating
 Basic coating inputs:

   Pigment

   Binder (resins)

   Carrier (solvents)

 Materials pretreatment



 Application equipment

 Drying


 Utilization rate

 Output waste

   Air pollution

   Water effluent


   Solid waste



Hazardous waste



Overhead costs
Finish quality
 10-20%

 10-20%

 60-80%

 Solvent-based primer tank(s), air
 dried


 Spray booth

 400" oven, 40-45 minutes


 60-70%


 VOCs

 Waste water from equipment
 cleaning

 More packaging materials needed to
 protect finish


Liquid overspray
Paint sludge


More labor
More equipment to meet
VOC regulations
More energy costs
40-60%

40-60%

0%

Anodic electrocoat tank,
oven dried (475°, 5
minutes)

Spray booth

400° oven, 10-15
minutes

95-98%


No VOCs

Waste water from
equipment cleaning

Less packaging materials
needed because finish is
more durable

Powder overspray can
be easily
recycled/reused.
                                  Higher gloss
                                  Higher coatage
                                  Higher durability
                                  Higher corrosion
                                  resistance
                                     28

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 Inventory Analysis

    Life cycle inventory analysis is a technical, data-based process of quantifying energy and
 raw material requirements, atmospheric emissions, waterborne effluents, solid wastes, and
 other inputs or outputs throughout the entire life cycle of a system.  Life cycle stages include
 raw  materials  acquisition,  manufacturing,  use/reuse/maintenance,   and  recycle/waste
 management.  Figure 2 illustrates a simplified representation of the full  product life cycle.
                 Input*
                           SyMm Boundary
                  Raw
               Materials
                Energy
Materials manufacture
Product fabrication
HtoMrtMckagincyaiatribution
                             Output*

                             Atmospheric
                             Emissions
                             Waterborne
                             Wastes
                                                                Solid
                                                                Wastes
                                                                Coproducts
                                                                Other
                                                                Releases
                           Syctwn Boundaiy

                   Figure 2.  Simplified Full Product Life Cycle4
    Life cycle inventory analysis is a static representation of a dynamic system, as is the
entire LCA process.  That is, the life cycle inventory is a "snapshot" of inputs and outputs
of a given product system.  In light of this limitation, some general applications of the life
cycle inventory are the following:

       •   Establish a baseline of information on a system's overall resource and energy
           consumption and environmental loadings;

       •   Identify stages within the life cycle of a product or process where inputs and
           outputs might be reduced;

       •   Compare the system's inputs and outputs associated with alternative products,
           processes, or activities;

       •   Help guide the development of new products, processes, or activities toward a
           net reduction of resource and energy requirements and environmental
           emissions; and

       •   Help identify areas to be addressed during life cycle impact assessment.4
                                          29

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        Because its methodology has been evolving over a 20-year period, life cycle
 inventory analysis is relatively well developed.  We describe the steps involved in
 conducting the inventory analysis using the two coating systems—A (conventional) and B
 (powder coating)—as an example. EPA developed these eight steps for conducting an
 inventory analysis.4

        1.) Define the Purpose and Scope of the Life Cycle Inventory Analysis.   The
 purpose of the life cycle inventory analysis when evaluating two coating systems may be
 to provide baseline information for comparing the environmental and human health
 impacts of system A (conventional) versus system B (powder coating).  The scope of the
 inventory analysis should, at a minimum, clearly define the following study components:

        •   product, process, or activity to be studied;

        •   reasons for conducting the inventory analysis, including the needs of and
            potential applications for pertinent user groups;

        •   use of the results of the inventory  analysis by the practitioner;

        •   elements of the inventory analysis, such as energy and raw material inputs and
            waste or coproduct outputs; and

        •   elements not addressed hi the inventory analysis, such as socioeconomic and
           aesthetic issues, for example.4

        2.) Define the System Boundaries.   Once the goals and objectives for preparing
 the life cycle inventory have been determined and the intended scope identified, the
 practitioner can define the system boundaries. Whereas determining the scope of the
 inventory analysis defines both the issues and physical system to be addressed,
 determining the system boundaries defines  the portions of the physical system that will be
 included in the  inventory analysis.  A complete life cycle inventory analysis will establish
 boundaries that represent the system broadly, over the entire life cycle as shown in Figure
 2.

       Some helpful questions for setting and describing specific system boundaries might
 include the following:

       •   Does the system need to cover the entire life cycle?

       •   What will the product be used for, or is the study intended to compare
           systems?

       •   What ancillary materials or chemicals are used to make or package this
           product or run the processes?

       •   In a comparative analysis, are any  extra products required to allow one product
           to deliver equivalent or similar performance to another?

Figure 3 shows an example of the basic system boundaries for the two coating systems.


                                          30

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       3.)  Devise an Inventory Checklist   After defining the purpose, scope, and
boundaries of the inventory analysis, the practitioner can prepare a checklist to guide data
collection and to develop an inventory model.  The practitioner should address eight
general decision areas on the generic checklist shown in Table 2. This checklist is not
definitive; the practitioner may want to tailor the checklist to meet specific needs.

       4.)  Institute a Peer Review Process.  Because LCA is a fairly new concept and
its methodology is not widely accepted and well-understood, LCA reviewers have
recommended using a peer review process.  In the  context of LCA, peer review is not just
a post-study activity but  an integral component that is implemented early in the LCA
process. In the context of inventory analysis, a peer review process may help to validate
the following components:

       •   scope and boundary definitions;

       •   data collection and compilation plan;

       •   key assumptions and value judgments, if any;

       •   validity of results; and

       •   interpretation and communication of results.

Checklists such as the one presented in Table 2 are useful for organizing information on
these components to aid  in the peer review process.

       5.)  Gather Data.  Data gathered in the inventory analysis may come from a
number of different sources and may be categorized in different ways. Some example
data categories include the  following:

       •   Individual Process- and Facility-Specific:  data gathered from a particular
           operation within a given facility

       •   Composite: data from the same operation or activity combined across
           locations

       •   Aggregated:  data combining more than one process operation

       •   Industry-Average:  data derived from a representative sample of locations  and
           believed to statistically  describe the typical operation across technologies

       •   Generic:  data whose representativeness may be unknown but that are
           qualitatively descriptive of a process or technology
                                          31

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M*n*g«irM
^5
Figure 3. Basic Life Cycle System Boundaries for Coating Systems
                             32

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TABLE 2.  A TYPICAL CHECKLIST OF CRITERIA WITH WORKSHEET FOR
                       PERFORMING A LIFE-CYCLE INVENTORY4



  LIFE-CYCLE INVENTORY CHECKLIST
  INVENTORY OF:

 Purpose of Inventory:  (check all that apply)
   Private Sector Use                                    Public Sector Use
    Internal Evaluation and Decision Making                     Evaluation and Policy Making
    Q   Comparison of Materials, Products, or Activities            D Support Information for Policy and Regulatory Evaluation
    D   Resource Use and Release Comparison with Other         D Information Gap Identification
    Manufacturer's Data                                      D Help Evaluate Statements of Reductions In Resource Use
    D   Personal Training for Product and Process Design             and Releases
    O   Baseline Information for Full LCA                       Public Education
    External Evaluation and Decision Making                     D Develop Support Materials for Public Education
    Q   Provide Information on Resource Use and Releases        D Assist in Curriculum Design
    D   Substantiate Statements of Reductions in Resource
        Use and Releases

 Systems Analyzed
   List the product/process systems analyzed in this inventory: ^___^_^____^____^^^_^^__^__^___^_^^_^__
 Key Assumptions:  (Hst and describe)
 Define the Boundaries
    For each system analyzed, define the boundaries by life-cycle stage, geographic scope, primary processes, and ancillary inputs included in
 the system boundaries.

 Postconsumer Solid Waste Management Options: Mark and describe the options analyzed for each system.
  D    Landfill	   O Open-loop Recyc*ng_
  D    Combustion	   D  Closed-loop Recycling
        Composting                                        D  Other	'
 Befit for Comparison
  D This is not a comparative study.                         D This Is a comparative study.
 State basis for comparison between systems: (Example: 1,000 units, 1,000 uses)	
 If products or processes are not normally used on a one-to-one basis, state how equivalent function was established.


 Computational Model Construction
  D System calculations are made using computer spreadsheets that relate each system component to me total system.
  Q System calculations are made using another technique. Describe:	
Describe how inputs to and outputs from postconsumer solid waste management are handled.
Quality Assurance: (state specific activities and initials of reviewer)
  Review performed on:
  D  Data Gathering Techniques	 Q  Input Data	
  D  Coproduct Allocation	 D  Model Calculations and Formulas_
                                                       O  Results and Reporting	~
Peer Review: (state specific activities and initials of reviewer)
  Review performed on:
  D Scope and Boundary	 D Input Date	
  D Data Gathering Techniques	 D Model Calculations and Formulas
  D Coproduct Allocation	 O Results and Reporting 	
Results Presentation                                    D  Report may need more detail for additional use beyond
  D Methodology Is fully described.                            defined purpose.
  D Individual pollutants are reported.                       a  Sensitivity analyses are included in the report
  D Emissions are reported as aggregated totals only.             Ust,
    Explain why: 	D  Sensitivity analyses have been performed but are not included
                                                         in the report. Ust	
    in the report. List:
  D Report is sufficiently detailed for its defined purpose.
                                                      33

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  The type of data and level of specificity required is teased on the previously defined goals,
  scope, boundary, and intended application of the inventory data.

        One method to simplify the data gathering process is to break down the system at
  hand into a set of distinct subsystems.  A "subsystem" is defined as an individual step or
  process that  is part of the defined system.  Each subsystem will have a distinct set of
  inputs and outputs that can be  described in the inventory analysis.  For example, although
  several components make up the life cycle of coating systems, the manufacturing stage of
  a particular coating might occur within a single facility.  This single facility can be
  viewed as a subsystem (see Figure 4), so data can be gathered on all the manufacturing
  steps together. This example draws the subsystem boundary around the entire group of
  manufacturing steps within a given facility and not around each individual manufacturing
  step.

        After identifying  subsystem boundaries, the practitioner can  collect the raw input
  and output data.  To help manage potentially large amounts of data, the practitioner can
 organize the data into a chart or table like Table 3.
                              Energy
          Raw Materials/
            Resources
          Materials
Subsystem X
                           Air
                        Emissions
                                  Water
                                 Effluents
         Solid
         Waste
 Co-products


• Products
                  Other
                 Outputs
                           Figure 4.  Generic Subsystem*

       6.) Develop Stand-Alone Subsystem Data.   To represent the inputs and outputs
of the entire system, the practitioner must aggregate the individual subsystem data.  Stand-
alone subsystem data refers to standardized or normalized data that is amenable to
aggregation with other subsystem data. The primary goals of developing stand alone data
are the following:

       •  To present data for each subsystem consistently by reporting the same product
          inputs and outputs from each subsystem.
                                          34

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TABLE 3. SUBSYSTEM WORKSHEET FOR MANAGING DATA4
LIFE-CYCLE INVENTORY CHECKLIST PART II - SUBSYSTEM WORKSHEET
Inventory of:
Life-Cycle Stage Description:
Date:
Quality
SUBSYSTEM DESCRIPTION:



Data Value*
Type-
Assurance Approve
Data' Age/Scope
:

Quality Measures"
SUBSYSTEM INPUTS
Materials
Process
Other"
Energy
Process
Pre combustion
Water Usage
Process
Fuel-related




































SUBSYSTEM OUTPUTS
Product
Coproducts'
Air Emissions
Process
Fuel-related
Water Effluents
Process
Fuel-related
Solid Waste
Process
Fuel-related
Capital Repl.
Transportation
Personnel
• Include units.
• Indicate whether data are ad
a specific manufacturer or ta
Atlanta facility wastewater p«
and indicate the period covet
* Ust measures of data quality
* Include nontraditional Inputs
' If coproduct allocation metho
























































tual measurements, engineering estimates, or theoretical or published values and whether the numbers are from
Eflity, or whether they represent industry-average values. Ust a specific source If pertinent (e.g., 'obtained from
nmtt monitoring data").
re al available, regulated only, or selected. Designate data as to geographic specificity, e.g., North America.
«d (e.g.. average of monthly for 1991).
available for the data item (e.g., accuracy, precision, representativeness, consistency-checked, other, or none).
[e.g., land use) when appropriate and necessary.
d was applied, indicate basis in quality measures column (e.g.. weight).
                    35

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        •  To develop the data in terms of the life cycle of only the product examined in
           the inventory analysis.

        Two main activities need to be undertaken to achieve these goals. First, the
 practitioner must translate the input and  output data from each subsystem to the same
 unit of production or time, as well as to the same unit of measure (e.g., pounds, tons,
 gallons).  Second, the practitioner must identify and distinguish inputs and outputs
 attributable to the product in question from inputs and outputs  attributable to the
 production of coproducts. Commonly called coproduct allocation, this process is usually
 based on relative weight.

        7.)  Construct a Computational  Model.  A computational model is needed that
 incorporates the normalized  data and material flows into a computational framework using
 a computer spreadsheet or other accounting technique.  The systems data that result from
 the model's computations will yield the total result for the inputs  and  outputs of the
 system in question.

        The computational model uses "proportionality factors," which are quantitative
 relationships that reflect the  relative contributions of the subsystems to the total system.
 For example, data gathered for manufacturing conventional coatings may have been based
 on 1,000 gallons of solvent.  If the total system is based on 1,000 gallons of conventional
 coating (which is 70 percent solvents, 30  percent solids), the contribution of solvent to the
 total system is 0.70 times 1,000, or 700 gallons.

       8.)  Present the Results in a Transparent Manner.  Transparency in this context
 refers to clearly communicating such aspects as the scope, system boundaries, data
 sources, methodologies used, limitations,  and assumptions of the analysis. A tabular
 presentation format may best communicate results; however, the tables' format will vary
 between studies.  Summary tables such as Tables 2 and 3 may  be appropriate for
 illustrating results. In any case, the format for communicating  life cycle inventory
 analysis results should be consistent with  both the purpose of the inventory analysis and
 the goals and scope of the LCA in general.

 Impact Assessment

       Life cycle impact assessment is a systematic process, quantitative and/or
 qualitative, that  identifies and describes potential environmental and human health impacts
 associated with the inputs and outputs of a given system.  Although life cycle inventory
 analysis is well developed, life cycle impact assessment is in its infancy, so methodologies
 are either undeveloped or untried. Therefore, we only briefly describe this component.

       To date,  most LCAs have been strictly life cycle inventory analyses with no
explicit impact assessment.  These studies often implicitly interpret life cycle inventory
results in a context that implies impacts.  Failing to consider the methods  used to evaluate
and weight or rank the life cycle inventory items may convey that all  inventory items
have relatively similar impact potentials.  Life cycle impact assessment makes explicit the
methods used to assess the potential impacts resulting from a given system.

                                         36

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       Life cycle impact assessment is fairly well developed on a conceptual level. A
 three-phase conceptual framework, developed by the Society of Environmental Toxicology
 and Chemistry (SETAC)5, has been used as a basis for developing life cycle impact
 assessment.  A variation of these three phases contains the following activities:

       •   Classification:  The process of assigning and initially aggregating life cycle
           inventory data to relatively homogeneous groupings of potential impacts of
           concern (e.g., photochemical smog, lung disease, fossil fuel depletion)—called
           assessment endpoints—within primary impact categories (natural environment,
           human health,  and natural resources impacts).

       •   Characterization:  Analyzing and possibly estimating the magnitude of
           potential impacts—called measurement endpoints—as actual or surrogate
           measures of assessment endpoints that were  identified in the classification
           phase.  Characterization involves using specific impact assessment tools known
           as conversion models and impact descriptors.

       •   Valuation:  The explicit and collective process of assigning relative values
           and/or weights to potential impacts of concern (assessment endpoints) using
           formal valuation methods.

       Figure 5 provides a conceptual schematic of these three stages.  As illustrated in
Figure 5, the sequence from the life cycle  inventory to the improvement component is not
necessarily linear, which is consistent with the three-component LCA triangle in Figure 1.
The sequence involves interrelationships and feedback loops among the major
components. For example, opportunities for environmental improvement can be realized
at any phase of the  LCA, but unplanned modifications may entail revisiting previously
completed components.

       Unlike other forms of impact assessment, life cycle impact assessment does not
necessarily attempt  to quantify actual impacts associated with a system. Instead, life cycle
impact assessment attempts to establish a link between the inputs and outputs of a  system
and potential impacts.  The ability  to establish this link  depends on the availability and
use of specific impact assessment tools—called conversion models—to estimate the
magnitude of the contribution of specific life cycle inventory items to potential impacts of
concern (assessment endpoints).
                                         37

-------
                              Identify Potential
                                  Impacts
                               Select Assessment
                                  Endpoints
                            Classify Inventory Items
                           by Assessment Endpoint
                              Select Measurement
                                  Endpoints
Apply Conversion Models
                           Develop Impact Descriptors
                                                                   CO
                                                                   CO
                                                                   UJ
                                                                   u
                            Apply Weighting/Ranking
                                  Methods
                            Life Cycle Improvement
                                Assessment
Figure 5.  Life Cycle Impact Assessment Conceptual Framework
                                    38

-------
         Recent forums (SETAC Life Cycle Impact Analysis Workshop in February 1992
 and the SETAC Life Cycle Data Quality Workshop in October 1992) have identified a
 five-level tiered hierarchy of conversion models, shown  in Figure 6.
                            ThKS: Site-Specific Exposure/Effects
                                                          sment
                              Models determine the actual impact* of Ma cycle
                             inventory data based on sle-speclic fate, transport.
                             and impact Information lor the relevant impact area.
                              Tier 4: Generic Exposure/Effects Aa*aaamant
                           Models estimate potential ImpacU on the back of generic
                       environmental and human health Mormatioa Generic environmental
                       information may consist at generic lata, transport, and impact data lor
                            potential individual, population, or ecosystem knpacts.
                            Her 3: Inherent Chemical Properties Aiienment
                        Modafc aggregate He cycle invenlory data on the back of inheranl
                      chemical properties, such as loricity, persistence, and bioaccumulation.
                         Categories of inherent chemical properties may then be used to
                                 determine relative impact potentials.
                                Tier 2: Impact Equivalency Assessment
                     Models use derived equivalency (actors as a basis on which to aggregate We
                      cycle inventory data. Aggregated equivalency (actors may then be used to
                         estimate relatively homogeneous measures ol potential impacts.
                                   Tierl: Loading Assessment
                   Models 1st and possbry group lie cyde inventory data in terms ol potential impacts.
                   LJe cycle invenlory data may also be aggregated into stressor groups that can be
                                    linked to potential impacts.
           Figure 6.  Five-Level Tiered Hierarchy of Conversion Models
        One major constraint currently limits the applicability of conversion models—the
 lack of data on many environmental and human health effects.  The general consensus is
 that the lack of this data limits practitioners to Tier 1- and Tier 2-type conversion models
 where  impacts are not measured per se.  Tiers 3 to 5  conversion models require more site-
 specific data as well as additional computational models.  Gathering site-specific data and
 developing computational models are long-term goals.

 Improvement Assessment

        The improvement assessment component of LCA is a systematic process that
 identifies, evaluates, and implements opportunities for environmental improvements.
 Because the improvement component has not yet  been developed or even discussed in a
 formal public forum, we do not discuss it in this paper. Preliminary discussions on
 improvement assessment have recognized that both quantitative and qualitative evaluations
 of improvement options may occur  in this component.    In assessing the two alternative
 coating systems, the improvement assessment component might recognize that the  powder
coating system not only eliminates VOC emissions but it also uses less energy and labor
 and produces less waste products.  On  a "less is better" basis, the powder coating system
uses less inputs and generates less outputs; therefore,  this  system may be considered more
                                             39

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 environmentally benign than the conventional coating system.  In addition, the
 improvement assessment might also identify and implement opportunities to further reduce
 input use and output production within the powder coating system.

 CONCLUSION

        In an era of heightened awareness of environmental and human health effects
 resulting from products and processes, LCA represents an emerging tool for  incorporating
 such concerns into decisionmaking processes. This paper outlines the LCA process,
 including goal definition and scoping, inventory analysis, impact assessment, and
 improvement assessment.  Techniques used in this process could be applied to assess
 alternative coating systems to minimize potential impacts to the environment and/or
 human health.

        Although much of LCA methodology remains to be developed, LCA  currently may
 be used as both a  screening tool for assessing potential environmental and human health
 impacts and a tool for making explicit those methods used to evaluate alternative coating
 systems that  may have relatively similar or largely different components and/or effects.
 REFERENCES

 1.  Henn, Carl L. The New Economics of Life Cycle Thinking.  Unpublished paper.
    Society of Logistics Engineers, New Brunswick, New Jersey.

 2.  Pojasek, Robert B. Spray Painting: The Search for the Right Answer.  Pollution
    Prevention, (Spring):243-248,  1992.

 3.  Rauch Associates, Inc.  The Rauch Guide to the U.S. Paint Industry.  Bridgewater,
    New Jersey, 1990.

4.  U.S. Environmental Protection Agency.  Life-Cycle Assessment: Inventory Guidelines
    and Principles.  EPA/600/R-92/245. Washington, DC, 1993.

5.  Fava, James A., Richard Denison, Bruce Jones, Mary Ann Curran, Bruce Vigon,
    Susan Selke, and James Barnem.  A Technical Framework for Life-Cycle
    Assessments. Society of Environmental Toxicology and Chemistry, Pensacola,
    Florida, January 1991.

6.   Canadian Standards Association. Environmental Life Cycle Assessment.  Draft report.
    Canadian Standards Association, Ontario (Toronto), Canada, 1992.
                                        40

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                              SESSION 2
                           TECHNOLOGIES
                           PAPERS PRESENTED:

  "Radiation Curing Technology:  Ultraviolet (UV) and Electron Beam (EB) Processing"
                                    by
                              Richard W. Stowe
                          Fusion UV Curing Systems
                             Rockville, Maryland

             "Environmental Compliant Thermoplastic Powder Coating"
                                    by
                               David F. Ellicks
                         Department of the Air Force
                      Air Force Corrosion Program Office
                             Robins AFB, Georgia

 "Supercritical Fluid Spray Application of Low-Pollution Coatings for Plastic Substrates"
                                    by
                             Wayne Paul Miller
                             Kenneth A. Nielsen
                         Union Carbide Corporation
                        South Charleston, West Virginia
                                   and
                               Tom Morrison
                   Red Spot Paint & Varnish Company, Inc.
                             Evansville, Indiana

'Utilizing Dispersion Resins with Inorganic  Solids in a New Formulary Blending Process
                  to Achieve Synergistic Results of Performance"
                 (Expanded abstract; paper not available.)
                                    by
                              Philip W. Coscia
                     Resources Conservatory International
                             Gustine, California
                                    41

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)


               RADIATION CURING TECHNOLOGY
           Ultraviolet (UV) and Electron Beam (EB) Processing
                         Richard W. Stowe
                     Fusion UV Curing Systems
                        7600 Standish Place
                       Rockville, MD  20855
      Radiation curing of polymeric materials is an efficient and
relatively low temperature electricity-based technology with many
applications in coating, printing,  adhesives,  electronics, and
communication material.    Radiation curing,  which includes
Ultraviolet Curing and Electron Beam technologies, can improve
the  overall physical  or chemical properties  of polymeric
materials and produce superior results  in bonding, surface
finish,  and durability to those of other technologies.   Speed
and  controllability in these applications, suggest an increasing
market for this electrotechnology in manufacturing worldwide.


BENEFITS

      Both UV or EB Curing are highly desirable for processing,
owing to benefits  of  productivity as well as advantages of being
"clean"  technologies.   These radiation  processes have a number of
key  attributes;  they  are:
      •   a  solventless  process —  cure  is  by polymerization
           rather than  by evaporation,  so  VOC emissions are
           eliminated;
      •   a  lov  temperature process — heat is not required;
      •   a  high speed process  — cure is nearly instantaneous;
      •   an energy-efficient process — energy is invested only in
           the  curing reaction, not in  heating;
      •   easily controlled —  inks and  coatings do not "dry," so
           do not set up in printing/coating equipment.

APPLICATIONS

      Radiation-processing technologies offer several major
advantages over other  production  methods.   These benefits include
rapid curing,  low process temperatures, the absence of pollution,
and substantially lower energy costs,  as  well as high-quality and
specialized products.   Typical product lines involve coatings (on
wood, metal, paper, and plastic),  inks (for letterpress,
lithographic,  gravure,  and screen printing),  and adhesives (for
film, foil, or paper substrates).  The industries using these
technologies are diverse and  varied; they include electronics,
fiber optics,  flooring,  packaging, plastics,  and printing.

                               43

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 MATERIALS

      The essential ingredients of a radiation-curable material
 are:

 (1)   Oligomers —  30-90% concentration; completely reacted upon
      cure; primarily provide film properties such as flexibility,
      hardness, and chemical resistance; (equivalent to "resins"
      of conventional coatings)  There are a number of choices of
      types which provide a variety of features and properties of
      the uncured and cured material, such as viscosity,  cure
      speed, hardness, toughness,  flexibility, weathering,  etc.

 (2)   Monomers — 10-70% concentration; completely reacted  upon
      cure; controls viscosity and polymer chain formation;
      (equivalent to "solvent" in  conventional materials  EXCEPT
      that it is completely reacted)

 (3)   Photoinitiator (UV curing only) — 1-5% concentration;  a
      photo-active material which  responds to (UV)  light  and
      initiates chain formation.

 (4)   Additives and pigments — conventional materials to alter
      stability,  adhesion,  tack, or appearance.


 TECHNOLOGY:  UV CURING

      UV lamps are generally of two types:  (1) Medium pressure
 mercury vapor arc lamps (usually  called "arc lamps"),  or (2)
 Medium  pressure  mercury vapor microwave-powered lamps (called
 "microwave powered lamps"  or "electrodeless lamps").

      The UV energy produced by the lamp bulb is focussed by  a
 reflector onto a (moving)  surface.   The UV energy  striking the
 surface causes the photoinitiator to trigger the polymerization
 reaction.   The material is usually solidified ("dry")  when it
 exits the cure zone.

     Lamps  are characterized by the  UV light intensity at  the
 work surface  (irradiance),  measured  in Watts per square
 centimeter  (W/cm2).   Cure  dose is a  function of time (or process
 speed) and  is  measured  in  Joules  per square centimeter (J/cm2).
 By using  multiple  lamps, the process width can  be  extended
without  limit.

     A  light enclosure  is  required to eliminate stray UV light
 and to provide protection  to personnel from exposure  to  UV.
                                44

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TECHNOLOGY:  BB  CURING

      Electrons  generated by a hot  filament  and cathode are
accelerated  by  a  high voltage to produce  a  flood  of  high energy
electrons  which are  concentrated into  a beam onto a  (moving)
surface.   The energy of the electrons  is  a  function  of the
accelerating voltage.  Electron beam accelerators are
characterized by  their accelerating voltage:  300  kV  or less  is
referred to  as  "low  energy."  Most curing accelerators are in
this  range.  Process width is usually  130 inches  or  less.

      Electrons  striking and penetrating the uncured  material
cause a direct  initiation of the cross-linking reaction in the
material,  and the material is immediately polymerized.

      The dose (D), in megarads, received  by a  material is
characterized by  the electron current  (I),  the velocity of the
process (S), and  a factor (k) which is a  function of the
accelerator  voltage,  geometry, width and  distance:

                        D(Mrad) =


      The curing zone is surrounded by an  enclosure to  contain an
inert (nitrogen)  atmosphere.  It is necessary  to  displace  oxygen,
which interferes  with the curing reaction at the  surface of high
speed materials.  Electrons striking oxygen molecules  would also
produce ozone.  The  enclosure is also shielded to prevent  escape
of radiation produced by the high  energy  electrons.


PRODUCT APPLICATIONS FOR DV PROCESSING

      •    Printing and Publishing
                Book  and magazine covers
                Brochures and promotional  materials
                Compact disc boxes  and album covers
          -    Menus

      •    Consumer Products
                Eyeglass lenses
               Trophies and plagues
          -    Tape measures

     •    Wide web converting
               Silicone release films
               Vinyl flooring no-wax finish
               Solar reflective films
               Vinyl woodgrain laminating films
                              45

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PRODUCT APPLICATIONS FOR 0V PROCESSING (continued)

     •    Business Forms
               Direct nail
               Catalogs
               Business forms
               Sweepstakes mailings

     •    Narrow web converting
               Labels and tags
               Bar code printing
               Lottery tickets
               Stickers and decals

     •    Plastics
               Headlamp lenses and bodies
               Decorative caps and containers
               Auto body moldings

     •    Medical  devices
               disposable syringes
               Transdermal patches
               Catheters

     •    Plastic  container decoration
               Shampoo and toiletry bottles
               Toothpaste tubes
               Styrofoam cups  and containers

     •    Wood
               Fillers and sealers for plywood and particle board
               High gloss finishes on case goods
               Wood flooring strips and parquet

     •     Electronics
               Component  marking
              Conductive inks
              Conformal  coatings

     •    Metal Containers
              Two piece  (aluminum)  beer and beverage cans
              Three-piece  (steel)  cans and containers
              Metal boxes

     •    Telecommunications
              Optical fiber coatings
              Printing on wire and cable insulation
              Optical ribbons, cables and fiber coloring
                              46

-------
 PRODUCT APPLICATIONS 70R ELECTRON BEAM PROCESSING

      Curing ("drying"!

      •    Inks and coatings in offset lithography (e.g.,  printing
           folding cartons and flexible packaging)

      •    coatings on wood,  Masonite or particle board to produce
           decorative panels

      •    Adhesives in laminating operations

      •    Silicone coatings on controlled- release  products
           (e.g.,  label stock)  and magnetic coatings on recording
           tapes and discs

      Crosslinking

      •    Plastic films for high strength and temperature
           packaging materials (e.g., shrink wrap)

      •    Heat shrink tubing for electronic applications

      •    Wire/cable insulation to increase chemical  resistance
           and allowable operating temperature

      Sterilization

      •    Medical products


      Electron beam (EB)  and Ultraviolet (UV)  processing are
sometimes  considered to be competitive technologies,  but  in most
cases,  specific manufacturing requirements provide  a  clear
differentiation between the two approaches,  and  they  tend to be
complementary.  In some instances they may both  be  required.


RECYCLING  OF  RADIATION-CURED PRINTED MATERIAL

      A study  recently conducted by the Beloit Corporation,
sponsored  by  RadTech International,  found that all  of the (UV/EB)
ink/coating combinations were recyclable into board grades.

      Furthermore,  the study  proved that for recycling into tissue
grades, all materials require a system containing flotation while
most  also  require centrifugal  cleaners.

      In addition,  UV inks and sheetfed litho inks with water-
based coating  also require dispersion,  a common  component in
today's recycling mills,  for recycling into tissue  grades.


                                47

-------
      For recycling into  fine  paper grades,  most ink/coating
 combinations require dispersion and additional flotation.

      Hence the Beloit study's conclusion:   UV/EB printed and
 coated paper can be recycled  into  tissue and/or paper grades
 using commercially available  equipment.  In fact,  UV/EB cured
 paper is just as recyclable as other materials.
UV and EB MARKETS
            U.S. Market for Radiation Curable  Coatings^
              Inks  and  Adhesives.  by End-user Industry
                            (Value  $mm)
Industry
Electrical / Electronics
Packaging
Graphic Arts
Wood furniture & Construction
Automotive
1991
74
67
31
49
8.4
1996
140
103
49
69
12.7
% Change
90%
54%
58%
41%
51%
                               Source: Frost and Sullivan, Inc. -  1992
RECENT TREND AND SHARE
                  Annual Coatings  Market  Survey
                     (percent of total volume)
TYPE OF COATING USED
Convent i ona 1
High-solids
Two-component
Powder
Haterborne
Vapor-cure
Radiation-cure
other
1989
47.8
14.9
12.2
11.1
9.1
1.6
1.4
1.9
1990
46.0
16.5
12.9
11.5
11.2
.7
.9
3.3
1991
41.6
16.4
11.6
12.8
11.8
1.4
2.0
2.5
1992
32.5
16.3
11.5
16.7
16.9
1.1
2.3
2.5
                           Source: Industrial Finishing - January 1992
                                 48

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     "Radcure  coatings today comprise  about 3% ($300 million)  of
the U.S. industrial  coating market  ($10  billion).   Indeed,  (TV and
EB coatings that  cure instantly, rapidly and with  minimal VOC
certainly have a  bright  future.  The share could reach 10%  ($1
billion) by 2000".
                             Source: Industrial Finishing - May,  1992

CONCLUSION

     Radiation-processing technologies offer several major
advantages over other production methods.   These benefits include
rapid curing,  low process temperatures,  the absence of pollution,
and substantially lower  energy costs,  as well as high-quality  and
specialized products.  Typical product lines involve coatings  (on
wood, metal, paper,  and  plastic), inks (for letterpress,
lithographic,  gravure, and screen printing),  and adhesives  (for
film, foil, or paper substrates).  The industries  using these
technologies are  diverse and varied; they include  electronics,
fiber optics,  flooring,  packaging, plastics,  and printing.  While
still minor manufacturing techniques,  their industrial use  is
expected to expand greatly, with a continued annual growth  of  15
to 20%.
                               49

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50

-------
(The work described in this paper was not funded by the U.S. Environmental Protection
Agency.  The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
                    ENVIRONMENTAL COMPLIANT
                THERMOPLASTIC POWDER COATING
                               David F. Ellicks
                                   USAF
                        Air Force Corrosion Program Office
                               WR-ALC/CNC
                               215 Page Road
                                  Suite 232
                          Robins AFB.GA 31098-1662
                                     51

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 INTRODUCTION

      In the early 1970s,  inhibited epoxy primer and aliphatic polyurethane
 paint systems were applied to a majority of Air Force weapon systems.  This
 coating effectively reduced the level of corrosion on the exterior surfaces of
 aircraft.   This  resulted  from "built-in" corrosion inhibitors and the
 coating's  capacity to  bend without cracking as the surfaces of the aircraft
 flexed during flight.   The Air Force recognized the 1980's as the decade  of
 environmental awareness.   The 1990's, on the other hand,  will introduce the
 new technologies required to fully address all the environmental  considera-
 tions.  The current painting operations generate carcinogenic substances
 (methylene diisocyanates),  air pollution (volatile organic compounds from
 solvent-borne coatings),  and hazardous wastes (paint waste containing
 strontium,  barium,  or  zinc chromates and cadmium) .  Historically,  the Air
 Force has  used primers and topcoats because of the excellent  corrosion
 protection they  provide.   The Air Force,  in general,  and Warner Robins  Air
 Logistics  Center,  in particular,  have been striving toward the elimination  of
 isocynates,  volatile organic compounds,  and heavy  metals.   The goal  is  for  the
 paint operation  to conform to the increasingly stricter environmental and
 health requirements.   The painting operation requires very expensive
 facilities (explosion  proof lighting and fixtures,  drainage system, and one
 pass heating/cooling ventilation systems),  hazardous  waste disposal
 facilities,  air  supplied  respirator devices,  medical  examinations, and
 extensive  training.  In addition,  special  high volume/low  pressure paint
 spraying equipment  and high solids solvent-borne coating systems are being
 used to help reduce volatile organic compounds.

      In order  to reduce the environmental/health hazards and  the cost of
 disposing  of the hazardous  waste,  the Air  Force  Corrosion  Program Office
 continually  evaluates  potential  new coatings  and application  techniques.  One
 new and promising  coating and application  technique is Thermoplastic Powder
 Coating (TPC)  applied  through flame  spraying  equipment.  This  paper describes
 the Air Force  Corrosion Program Office's initial evaluation,  economic
 analysis,  environmental analysis,  and the  preliminary  results  from
 applications testing done at Warner  Robins  Air Logistics Center, Robins
 Air Force  Base,  Georgia.

 BACKGROUND

      There has been a  long-term problem at  many  Air Force bases with the use
 of  hazardous coatings/coatings removal materials and the lack of adequate
 facilities for performing corrosion  prevention and control  processes on
 nonpowered aerospace ground equipment, munitions handling equipment, nonfueled
 industrial vehicles, trailers, containers,  components, and  civil engineering
 real  property  facilities/structures.   Standard coatings are not meeting the
durability and maintainability requirements of the units and pose a hazard
both  to the health of personnel and  the environment.  Lack of authorized and
available corrosion facilities in  the munitions  or aerospace ground support
equipment organizational units for depainting/repainting of the end items  and
parts  is a problem at many  bases.  Keeping  this  in mind,  the Air Force
Corrosion Program Office is  always looking  for new technologies to protect Air
Force  assets from corrosion  damage.  We are also mindful that the life cycle
environmental considerations must  be integrated  into product/process
engineering design procedures.
                                    52

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THERMOPLASTIC PONDER COATING AND APPLICATION EQUIPMENT SYSTEM DEFINITION AND
EVALUATION

System Definition

     Currently, there are three common  techniques  for  applying powder
coatings:  electrostatic deposition,  fluidized bed dipping and flame spraying.
Electrostatic deposition is accomplished by  immersing  an electrically grounded
part in  a fog of powder sprayed from  an application gun which transfers a
static charge to the powder.  The powder is  attracted  to the  part and clings
to the surface.  The coated part is then heated (oven  or infrared lamps)  to
bake and fuse the coating to the part.   Fluidized  bed  coating involves dipping
preheated parts into a column of powder which has  been fluidized (agitated)  by
passing  air up through the column.  The heat retained  by the  part serves to
melt and fuse the coating.  In flame  spraying,  powder  is blown through a
flame, melted, and directed onto the  material being coated.

     The TPC and application equipment  system is similar to metal flame
spraying equipment with thermoplastic or thermoset  powder replacing the metal
powder.  Some of this equipment is expensive and too complicated to use at
field-level bases.  The coating process is simple.  In general, the bare  metal
surface  to be coated is first inspected for  cleaniness (oils,  hydraulic
fluids,  etc.) and then preheated to approximately  175  degrees  Fahrenheit  with
the application flame gun or nozzle to  drive off moisture and  to ensure that
the applied plastic will flow smoothly.   The preheating step is followed by
application of the finely ground, pigmented  polymer to the desired thickness
either as solid or molten powder.  The  final step  is the continued heating  of
the applied polymer to insure proper  flow-out to the optimum coating
temperature range of 320 to 425 degrees Fahrenheit, as monitored by a
hand-held infrared pyrometer.  After  the coating cools, the painting operation
is complete.  For the thermoplastic powders,  no chemical reaction or change in
the molecular structure occurs during the coating  process.  Therefore,  these
coatings have the potential for easy  repair  if damaged by simply reheating  or
re-applying additional powder.  The coating  is soft, one coat, glossy,  thick
(10-12 mils), durable, easy to apply, repairable,  safe for workers,  and
environmentally compliant.

     The thermoplastic powder is generated by grinding polymer pellets  at
cryogenic temperatures using liquid nitrogen as a  refrigerant.  Originally,
Envelon  powder was supplied directly  by Dow  Chemical Corporation; however,  Dow
has now  licensed that process to Morton,  International, a major commercial
supplier of industrial powder coating materials.   Plastic Flamecoat Systems
(PFS) of Houston, Texas (an alternate TPC equipment manufacturer) grinds
DuPont Nucrel and is currently the only source for  this powder.  The
Dow/Morton product is a "melt blend"  material in which pigments,  UV
stabilizers, and other additives are  blended with melted polymer before
grinding.  The DuPont/PFS powder is "dry blended"  by mixing additives with  the
powder after grinding.  Both powders  cost relatively more than the convential
solvent-borne coating systems.  Both  materials are  considered  "environmentally
compliant" by current EPA federal and state  regulations.

     Both the Dow and DuPont powders  may be  obtained in a range of "melt
index" values.  Low melt index polymers are  more viscous at any given

                                        53

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 temperature than are high melt index polymers.  In general, the low melt index
 powders yield tougher coatings but are more difficult to apply because they
 require higher temperatures to achieve flow-out during application.  Both
 polymers melt at about 300 degrees Fahrenheit and flow over a substrate that
 has been preheated to a temperature of 150 to 175 degrees Fahrenheit.   If
 coating temperature exceeds 425 degrees Fahrenheit for extended periods of
 time (minutes), significant polymer chain cross- linking occurs,  and the
 coating effectively converts from a thermoplastic to a thermoaet  material.
 When this happens,  field repairability of the coating by reheating is  lost.
 If coating temperatures exceed 650 degrees Fahrenheit during application, the
 polymer is permanently damaged and the coating is destroyed.  To  avoid
 overheating, the coating temperature is carefully monitored by the applicator
 with a hand-held infrared pyrometer.

 System Evaluation

      A TPC application system was selected by the Air Force for a  field-level
 test program.  This system was chosen as the most suitable for evaluating the
 current state of flame coating technology and its potential for an alternate
 to conventional solvent-borne paint systems.   The simplest and most commonly
 used TPC flame spray application systems are entirely pneumatic.   These
 systems require only clean,  dry compressed air and fuel  (typically liquid
 propane)  for operation.   Powder is stored in a hopper and delivered by hose to
 the gun in a stream of compressed air that transports powder from  the hopper
 with a venturi.  Propane is  delivered to the gun through  a separate hose and
 mixed with air at the gun exit where it  is ignited.   The  equipment operator
 sets the air, powder,  and fuel flow rates with controls located on or near the
 gun.   The powder/air mixture blows through the flame,  melts and flows onto the
 surface to be coated.

      Dow and DuPont are  the  two major domestic suppliers  of thermoplastic
 polymer resins developed for flame spray application.  Each manufactures a
 similar commercial  thermoplastic resin.   Dow  "Envelon" is an Ethylene Acrylic
 Acid (EAA)  copolymer.  DuPont  "Nucrel" is an  Ethylene Methacrylic Acid  (EMAA)
 copolymer.   These copolymer  formulations  were developed to enhance
 polyethylene coating adhesion.   Dow and  DuPont have  worked closely with
 application equipment  manufacturers to develop effective  TPC flame spraying
 systems.   Some equipment  suppliers restrict  the use  of their hardware to
 specific  polymers.   The  flame  spraying equipment manufactured by American
 Thermoplastics,  Inc.  (AT)  of Mesa,  Arizona,  has been selected  for field-level
 evaluation at several  Air Force bases.  AT allows  the use of all commercially
 available TPC materials;  however,  the use  of  Dow Envelon  is  recommended.  Dow
materials were used in this  test  program.

 System  Characteristics and Modifications

      Of the three flame  spraying  systems evaluated,  the UTP  system had the
most  sophisticated  flame  application hardware.   UTP  uses  an electro-pneumatic
 system  requiring  oxygen as well as  compressed air  and  propane.  This method
provides  a  smaller,  hotter flame  yielding  better temperature control and
better  flowout  of thermoplastic powder.  This  has  lead to the current
development effort  focused upon improving  flow-out temperature and the spray
pattern.   The Air Force is looking  at modifying the  nozzle to use  a premixed
 combustion  instead  of  a diffusion flame for better heating control.  In
                                        54

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addition,  we are seeking  modification of the nozzle to change  from a  circular
to a tapered oval spray pattern  to  widen the pattern and to  improve the
coating  uniformity (thickness  variations).
Further  nozzle development  may also be necessary for coating hard-to-reach
areas, e.g., angles,  tubing, and grating,  found on maintenance stands or other
complex  equipment residing  in  the Air Force inventory.

     Thermoplastic powder coatings  have notable performance  properties that
address  the environmental/health problems  inherent with standard Air Force
polyurethane coating systems.  For  example, these coatings exhibit  excellent
resistance to various chemicals,  solvents,  and reagents.  This coating should
not  be  used in contact with chlorinated solvents, fuming or strong oxidizing
acids, aromatic alcohols, or heterocyclic  aldehydes.   These  coatings have
shown  excellent abrasion  resistance and good barrier  qualities to prevent
corrosion, and they are environmentally compliant.  These coatings  have the
ability  to be applied in  almost  all types  of weather  in any area, inside or
outside,  where it is safe to use a  flame.   The thermal  spray coatings are
proving  useful in many Air  Force applications.     They  are not appropriate for
every  application.  This  process does have  drawbacks  such as incompatibility
with live munitions or combustibles,  problems with thin metal and composites,
slow application rate (50 to 100 square feet per hour), high substrate
temperature effecting the heat treatment of alloys, and high material cost.
This information is based on the preliminary laboratory testing using the test
requirements in MIL-C-83286 as a comparison and guide to base our above
conclusions.

Continuing Efforts

     Warner Robins Air Logistics Center is  pursuing an  aggressive program to
test and evaluate thermoplastic  powder coating flame  spray application methods
with the desire to implement this technology as one of  the new alternatives  to
solvent-borne coatings.   Current efforts involve optimizing the spray nozzle
for better coating applications  and developing flameless techniques for
coating  with thermoplastic/thermoset  powders.   The Air  Force Corrosion Program
Office will continue  to strive to identify  a coating  system that will provide
corrosion protection  while  eliminating environmental/health problems
throughout the Air Force.

Conclusions

     Thermoplastic powder coating flame spray application methods produce a
simple,  highly reliable,  safe, environmentally compliant, single coat
capability to augment  the standard  Air Force epoxy-polyurethane coating
systems.   TPC will also eliminate some requirements for several current
maintenance operations, e.g.,  chemical conversion coatings,  long paint drying
times, air supply respirators, and  expensive facilities.  The need to convert
from standard coating to  thermoplastic/thermoset powder coatings is being
driven  by the requirement  to  reduce  hazardous wastes,  enhance personnel
safety,  provide a cleaner environment,  and  minimize coating facilities.
                                    55

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f AIR FORCE
 CORROSION PROGRAM
                 THERMOPLASTIC

                POWDER COATINGS

                         (TPC)
                           Briefer:

                           DAVID F. ELLICKS

                           Materials/Mechanical Engineer
                           Air Force Corrosion Program Office
   AFCWIe
AFCorr Data Disk 2
Briefing rn: afcorr

-------
     FORCE
in
CORROSION PROGRAM
                          OBJECTIVE
    OBJECTIVE
        EVALUATE THE FLAME SPRAYED TPC
        TECHNOLOGY AS AN ALTERNATIVE
        TO STANDARD AIR FORCE EPOXY/
        POLYURETHANE COATING SYSTEM
          POLYETHYLENE PLASTIC
             •ETHYLENE ACRYLIC ACID COPOLYMER (DOW) (MORTON)
             -ETHYLENE METHACRYLIC ACID COPOLYMER (DUPONT)
 fn: blank
          AFCORR Data Disk 2
As Of:

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f.AIR FORCE
 CORROSION PROGRAM
APPROACH
     APPROACH
        ENGINEERING STUDY--STARTED 1 OCT 91
        CONTRACTOR: SCIENCE APPLICATIONS
        INTERNATIONAL CORPORATION (SAIC)
        THREE PHASES:
               * PHASE I - INDUSTRY SURVEY/SITE VISITS
               * PHASE II - EQUIPMENT/COATINGS EVALUATION
               * PHASE III - EQUIPMENT/COATINGS FIELD TESTS
tm blonk	AfCORR Data Disk 2	As Of

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 f AR FORCE
                        APPLICATION
tn
VO
CORROSION PROGRAM
    EQUIPMENT APPLICATION
       NONPOWERED AEROSPACE GROUND EQUIPMENT
       MUNITIONS HANDLING EQUIPMENT
       NONFUELED INDUSTRIAL VEHICLES
       TRAILERS
       COMPONENTS
 fn: blank    AFCORR 6afa Disk JAs 01:

-------
f AIR FORCE
 	             BENEFITS
CORROSION PROGRAM
    POTENTIAL  BENEFITS
       ONE COAT
       NO/LOW VOLATILE ORGANIC COMPOUNDS (VOCs)
       NO TOXIC FUMES
       NO HAZARDOUS WASTE
       FIELD APPLIED/REPAIRABLE COATING
       EXTENDED SHELF LIFE
       REDUCE VENTILATION/FACILITIES REQUIRED
       NO CURE TIME - COOLING TIME
rn7 blank	AFCORR Data Bisk 2	 As 01:

-------
( AIR FORCE
                       DRAWBACKS
CORROSION PROGRAM
    DRAWBACKS
       NO CORROSION INHIBITORS
       THICK
       ORANGE PEEL APPEARANCE
       SLOW COATING RATE
       LIMITED USE
       HIGH TEMPERATURE DEGRADATION
       ROUND SPRAY PATTERN (NOT OVAL)
frn blank	AfCORR Data bisk 2                   As

-------
 f AR FORCE
 	                PROCEDURE
N)
CORROSION PROGRAM
       TPC APPLICATION PROCEDURES

          PREPARE SURFACE TO BARE METAL
          INSPECT FOR CLEANINESS
          PREHEAT SURFACE TO 150 - 170 DEGREES F
          START APPLYING TPC
          INSURE PROPER FLOW-OUT TEMPERTURE (350-400 DEGREES F)
             - USING HAND-HELD INFRARED PYROMETER
          AFTER COATING COOLS, ITEM READY TO USE
 fn: blank	AFCOftft Data Disk 2                      As Of:

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[ AIR FORCE
 	^           TEST  SITES
CORROSION PROGRAM
     FIELD EVALUATION SITES
        EGLIN AFB FLORIDA
        ANDERSEN AFB GUAM
        KADENA AFB JAPAN
        ELEMENDORF AFB AK
tn: blank    AFCORR Data Disk 2As Of:

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[ AR FORCE
        O
CORROSION PROGRAM
PRESENT STATUS
     STATUS
         PHASE II       MID AUG 93
         PHASE III       DEC 93
         PHASE IV       DEC 94
fn: blank	AFCOftft Data Disk 2	As Of:

-------
(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

                    SUPERCRITICAL FLUID SPRAY APPLICATION
                            OF LOW-POLLUTION COATINGS
                               FOR PLASTIC SUBSTRATES


Wayne Paul Miller
Kenneth A. Nielsen
Union Carbide Corporation
P.O. Box 8361
South Charleston, WV  25303

Tom Morrison
Red Spot Paint & Varnish Co., Inc.
P.O. Box 418
Evansville, IN 47703
INTRODUCTION

       Increasing pressure from groups concerned about the fate of the environment have helped
spawn a new generation of heightened governmental regulation designed to significantly reduce the
amounts of volatile organic compounds (VOC) emitted. The coatings industry has been the target of
many of these regulations. As a result, coatings formulators and applicators have had to develop new
methods or products to remain compliant. Very often the resulting coatings have been dramatically
inferior to their conventional organic solvent-borne precursors in terms of economics, appearance,
performance, and convenience.

       Two strategies are prevalent today in reducing the amount of organic solvent emissions from
coatings. The first, removing the organic solvent from the coating prior to the application, is the most
widely practiced. The second, removing the solvent from the air handling system after it has been
released from the coating and prior to release to the outside atmosphere, is less widely  practiced
because of the high capital and operating costs  involved, and the intimidating level of sophistication. It
is also inappropriate in those states that regulate emissions based on die applied VOC level.
Additionally, with the fuel tax strategy proposed by the current administration, fuel-intensive systems,
such as incinerators, are less attractive.

       Removing the solvents prior to the application typically results in viscosity increases in the
coating. The increased viscosity of the coating has dramatically detrimental effects on  the
processability, sprayability, and appearance of the coating.  To overcome this, formulators have
frequently resorted to reducing the molecular weight of the base resin(s) in the coating  in order to keep
the viscosity of the coating low enough to handle. This approach has typically been referred to as high-
solids coatings.

       Typically, reactive coatings have suffered less from the high-solids approach than have
conventional lacquer coatings. This has been because the reactive functionality of the base resin
                                ©1993 Union Carbide Corporation
                              (Reproduced with Permission)
                                            65

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 lime required, are costly, and therefore unattractive to many applicators and formulators.

        In spite of the many advantages that solvent-borne coatings have, they are typically
 characterized by high emissions of volatile organic compounds, and consequently are under increasing
 regulatory scrutiny.  The development and introduction of the supercritical fluid spray process has not
 only allowed this challenge to be overcome, but also allowed for further performance and economical
 improvements in solvent-borne coatings for plastics.

 SUPERCRITICAL CARBON DIOXIDE AS A  COATING SOLVENT

        Supercritical fluids are interesting and useful because they  have properties that are intermediate
 to both gasses and liquids. Because of the high temperatures required to drive normal liquids into the
 supercritical regime, compressed gasses are the most widely utilized supercritical fluids.  Supercritical
 fluids  have become increasingly more widely used in a variety of industrial applications within the last
 dozen years.  Thorough treatments of the properties and uses of supercritical fluids are provided by
 Johnston (1) and McHugh and Krukonis (2).

        Perhaps the most important property of supercritical fluids  is the relationship between density,
 and hence solubility, and pressure, and not just temperature.  Because supercritical fluids are highly
 compressible in nature, significant changes in density (and solubility) can be initiated with relatively
 small changes in pressure. Supercritical fluids  have lower densities, higher rate of diffusion, lower
 viscosities, and higher penetration ability when compared to normal liquid organic solvents.  These
 properties permit supercritical fluids to penetrate polymer systems and then mix and equilibrate faster
 than normal solvents.

        Supercritical carbon dioxide is the primary, but not only, supercritical fluid utilized in the
supercritical fluid spray process.  Along with the attributes that supercritical carbon dioxide shares with
other supercritical fluids, it has many other significant attributes for use in coatings applications.

        1)      The critical conditions of carbon dioxide (31  degrees Celsius/88 degrees Fahrenheit,
               1070 psi) are easy to obtain. The critical temperature is only slightly above room
               temperature,  and the critical pressure is well within the designed containment pressure
               of typical airless spray equipment.

        2)      Carbon dioxide is much less toxic than  normal organic solvents. It has a high threshold
               limit value (TLV) of 5000 parts per million (0.5%).  The health effects of carbon
               dioxide are slight, when compared to other liquid organic solvents.  The concentration
               of carbon dioxide observed in the spray booth has been observed to be innocuous in the
               range of normal spray operation.

        3)      Carbon dioxide is non-flammable and mostly inert.  Also, the supercritical fluid
               compatible coating has a much higher flash point because it has less solvent.  This
               helps reduce the overall flammability in and around the spray booth and spray line.
               Along with the safety benefits of a less flammable area, it can also be less expensive for
               insurance purposes.

       4)      Supercritical carbon dioxide, because of its small molecular size and high solubility,
               can easily penetrate most polymer systems to significantly improve the viscosity of
               most coating formulations.

                                              68

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        S)      Carbon dioxide is a low cost commodity chemical that is readily available throughout
                the world.  It is available in a number of packaging configurations designed to meet the
                supply needs of both large- and small-volume coating applicators. Bulk prices of
                carbon dioxide are currently less than ten cents per pound in most parts of the country.

        6)      Carbon dioxide is not considered to be a volatile organic compound by any of the state
                or federal regulatory agencies.

 REDUCTION OF THE "GREEN HOUSE" EFFECT

        The release of carbon dioxide from coatings formulated for spraying with supercritical fluids,
 when considered by itself, has little or no effect on local or global  environments. For example, an
 automotive plant that sprays a top coat on 250,000 automobiles per year would emit less carbon dioxide
 than is emitted by soft drinks in the United States in just eight hours. In fact, utilizing carbon dioxide
 as a coating solvent actually reduces the amount of "green house* carbon dioxide that is generated
 during coating operations.

        1)      The supercritical fluid spray process uses  carbon dioxide created as a byproduct from
                natural gas wells, fermentation plants, ammonia plants, and other industrial
                applications, which would be released anyway. Therefore, no nevy carbon dioxide is
                created by the process.

        2)      In general, one pound of carbon dioxide is used to  replace one pound (or more) of
                normal organic solvents in the supercritical fluid spray process.  When that one pound
                of normal organic solvent is  emitted to the atmosphere, it eventually oxidizes to
                produce 2.3 to 3.3 pounds of new. carbon  dioxide.  The one pound of byproduct carbon
                dioxide from the supercritical fluid compatible coating system can not further oxidize to
                produce any additional carbon dioxide.

        3)      The high volumes of air from the booths produce a low solvent concentration in the
                conventional application. Therefore, thermal oxidation abatement requires the burning
                of substantial amounts of fuel.  In one automotive paint operation studied, thermal
                oxidation abatement produces 18 pounds of new carbon dioxide per pound of organic
                solvent.

        The amount of recycled carbon dioxide, if used to apply coatings, would certainly be dwarfed
by emissions from other sources. In fact, the total amount of recycled carbon dioxide utilized
industrially in the United States is less than one-third of one percent of the carbon dioxide generated
from coal burning for power plants; oil and natural gas for home heating; automotive fuels; and from
the food industry.

SPRAY GENERATION AND CONDITIONS

        The supercritical fluid spray process  uses commercial spray equipment specifically designed
and manufactured by the Nordson Corporation, of Amherst, OH, to be compatible with the coating
materials and the properties of supercritical fluids.  The supercritical pressures are well within the


                                               69

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 standard regime of airless spray, allowing the use of airless spray guns, spray nozzles, hoses, and
 pumps.  The supercritical temperatures are well within the regime of conventional heated paint
 systems. Because there is not a need for any exotic spray equipment, a wide selection of previously
 developed accessories for other paint systems can be utilized.

         In order for the carbon dioxide, which is a gas under normal conditions, to be mixed with the
 coating formulation, it is necessary to pressurize the mixture to maintain the supercritical conditions
 necessary to achieve the optimum benefits.

         The amount of dissolved supercritical carbon dioxide used to spray any given coating
 formulation is a complex function of the solids level, solubility, viscosity characteristics, pigment
 loading, and the desired spray pressures and temperatures. Another unique feature of the supercritical
 fluid spray  process is that the carbon dioxide level in the coating can be used to regulate the film build,
 and, to some extent, the dry time of a coating.  When spraying at constant pressure through any given
 nozzle of fixed flow, as the amount of carbon dioxide increases, the amount of coating material
 decreases.  Thus, increasing the concentration of carbon dioxide reduces the deposited film thickness.
 As the film thickness decreases, so does its dry time. When the film thickness is held constant, usually
 by reducing the application rate (traverse speed), the dry time is also decreased somewhat from the
 increased loss of solvent in the spray fan.  The typical application range is from 10 to SO weight
 percent carbon dioxide, and the mixture of carbon dioxide and  coating material is usually sprayed as a
 single-phase solution.

         In order to make the carbon dioxide supercritical, and offset the cooling that occurs as the
 carbon dioxide diffuses from the solution and expands as a free gas in the spray, the solution is heated.
 Because carbon dioxide solubility is inversely proportional to temperature, and viscosity is directly
 proportional to temperature, an optimum spray temperature can exist. The typical range is from 40 to
 70 degrees Celsius (100 to 160 degrees Fahrenheit).

         The dissolved carbon dioxide usually reduces the spray  viscosity to less than SO centipoise.
 The coating material usually has a formulated viscosity of from 500 to 3000 centipoise, but materials
 with much higher viscosities have been successfully sprayed.  The amount of viscosity reduction is a
 function of the polymer system, carbon dioxide concentration, temperature, pressure,  and solubility.
 The viscosity reduction is important because it allows the spray  solution to be readily atomized into a
 series of fine droplets necessary to deposit a high quality, uniform, film of coating material.

 SPRAY CHARACTERISTICS

        Supercritical carbon dioxide functions both as a viscosity reducer and a generator of vigorous
 atomization.  This vigorous atomization  is produced by a new mechanism that remedies the defects of
airless spraying and produces a high quality, uniform, film.

        Conventional airless spray techniques are often characterized by coarse atomization and
defective spray fans that limit their usefulness to the application  of low-quality films. The atomization
mechanism employs a high pressure drop across the spray orifice to generate a high velocity liquid
film. The film typically becomes unstable when the induced shear generated from the high velocity
differential from the film to the surrounding air exceeds the surface tension and cohesive forces in the
film. When the shear is high enough, the film disintegrates in a series of filaments and droplets.
Because the  surface tension and cohesive forces in the film are not completely overcome, the resulting
spray consists of non-uniform size droplets and filaments.  The spray fans resulting from this

                                                70

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 mechanism of atomization tend to contain jets that limit the ability to deposit a high quality, uniform
 film.

        Supercritical fluid sprays using carbon dioxide have a significantly different atomization
 mechanism. The resulting spray is airless in nature, but has all of the desirable traits of the air spray.
 but without the high air volumes. A feathered spray, with the spatial uniformity of fine droplet sizes
 necessary for obtaining high quality films and high transfer efficiencies, is produced from the vigorous
 decompressive atomization provided by the supercritical carbon dioxide.

        The vigorous decompressive atomization is believed to be produced when the dissolved
 supercritical carbon dioxide in the spray solution suddenly becomes exceedingly supersaturated as the
 spray exits the nozzle and undergoes a rapid and large pressure drop.  The dissolved carbon dioxide is
 driven forcefully to the gaseous state. The rapid gasification of the carbon dioxide overwhelms the
 surface tension and cohesive forces of the spray solution before an extensive liquid film can form at the
 nozzle.  By disrupting  the formation of the liquid film,  the defects of the airless film are avoided.
 Because the fan is no longer constrained by the surface tension and cohesive forces of the airless fan, a
 wider fan can  be generated at  the nozzle exit.  This permits the formation of a rounded parabolic-
 shaped spray fan with high uniformity of droplet sizes.  The fan is characterized by tapered edges
 similar to those of conventional air spray fans. The tapered edges permit the coating material to be
 deposited uniformly in a wide central region, with progressively less coating deposited towards the
 edges of the fan. This is particularly desirable when there is a need to overlap adjacent layers of
 sprayed  coating  to produce a uniform film thickness. Fan widths of the spray are regulated by nozzle
 selection, as is done with conventional airless spray.

        Laser  light scattering analysis has shown that the typical supercritical fluid spray fan has
 atomized droplets that range in size from 20 to SO microns.  This is dramatically smaller than the
 coarser atomization (70 to ISO microns) measured  for normal airless spray fans.

        Additionally, the decompressively atomized droplets decelerate rapidly after exiting the spray
 nozzle to provide a soft spray with low deposition velocities. The shear induced by the decompressive
 atomization, which causes the  droplets to leave the nozzle at wide angles to make the parabolic fan,
 creates a large braking force to the droplet. Additionally, much of the droplets momentum is dissipated
 by the diffusion of carbon dioxide. One acrylic coating was  measured to have a superficial spray
 velocity  of 82  meters per second (266 feet per second) at the nozzle.  At typical spray distances of 30
 to 40 centimeters (11.75 to 1S.7S inches), the average velocity had dropped  to seven meters per second
 (23 feet per second). The maximum droplet velocity is only  10 meters per second (33 feet per second).

       Additional evidence of the rapid release of the carbon dioxide can be found by observing the
 rapid cooling of the heated spray that occurs at very short distances from the spray nozzle.  The
cooling of the decompressively atomized spray occurs much faster than the cooling of conventional
heated sprays.  A conventional airless spray, heated to 60 degree Celsius (140 degrees Fahrenheit),
does not cool back to ambient temperature until it is almost eight inches from the nozzle.  The
decompressively atomized spray, heated to the same temperature, reaches ambient temperature within
less than one inch of the nozzle.  This rapid cooling is important because it reduces the amount of
solvent that evaporates from the spray, permits more efficient solvent use, and reduces exposure of
workers  in the spray area to solvent vapors.
                                                 71

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 TRANSFER EFFICIENCY

         In order for the full benefits of VOC reduction to be realized, it is also necessary to achieve
 high transfer efficiencies.  Because transfer efficiency depends on a large number of variables relevant
 to the application for which it is measured, it is not possible to compare the efficiencies of one
 application to those of another.  In order to obtain meaningful values, it is necessary to measure
 efficiencies in situ.  It is also easy to be mislead if maximum values of one application method are
 compared to those of another if the quality of the applied film on the pan is disregarded. For example,
 larger droplet sizes are easier to deposit than smaller droplet sizes, but typically provide a lower quality
 film.

         Both independent laboratory testing and commercial production performance measurements
 have demonstrated that the supercritical fluid spray process can provide improved coating appearance
 and performance without sacrificing material utilization, which has been the traditional trait of previous
 spray processes designed to reduce volatile emission.

         One of the major spray equipment companies made a thorough examination of the transfer
 efficiencies of the supercritical fluid spray process.  The test procedure that they utilized involved
 spraying spaced panel targets on a conveyor line. The results showed that the supercritical spray
 process provided significantly superior transfer efficiency when compared to air spray systems.  The
 transfer efficiencies of the air-assisted airless  spray system and the supercritical fluid spray process, at
 spray pressures of 1200 to 1500 psi, were not dramatically different.  In another test, the transfer
 efficiency of the decompressive spray was measured by foiling an entire automobile body and spraying
 it using the supercritical fluid spray process.  The overall transfer efficiency measured in the test was
 eighty percent.

         In addition to measuring transfer efficiencies, it is useful to consider the amount of coating
 solids used per part sprayed.  In another study, the supercritical fluid spray process was compared to a
 high-volume, low pressure (HVLP) spray system.  The conventional formulation was sprayed at
 nineteen weight percent solids.  The coating formulated for use with the supercritical fluid spray
 process  contained forty-two weight percent solids, which yielded a sixty-seven percent solvent
 reduction from the conventional formulation.  Transfer efficiencies were measured by spraying a series
 of flat parts 20 x 16 inches in size. The transfer efficiency of the supercritical fluid spray process  was
 measured to be five to eight percentage points lower than for the HVLP spray because of the smaller
 droplet size.  However, comparison of the production sprays showed that the parts sprayed with the
 supercritical fluid spray process demonstrated an improved coating appearance with thinner film builds.
 This resulted in an overall twenty-seven percent reduction in coating solids usage, and a realized
 solvent usage reduction of seventy-six percent when compared to the HVLP spray system.

        At one commercial installation of the supercritical fluid spray process, the amount of solvent
 used per part sprayed is sixty percent less than was experienced prior to conversion of the spray line
 from the air-assisted airless spray process.  This solvent reduction is only slightly less than the solvent
 reduction in the reformulated coating. However, the parts sprayed by the supercritical fluid spray
process have a superior appearance to those sprayed by air-assisted airless spray.  Additionally, higher
 film builds, without runs or sags, are possible on vertical surfaces using the supercritical fluid spray
process. The higher achievable film builds contribute to the improved appearance in this application,
and, combined with the improved appearance, permit a reduction in number of production steps
necessary.
                                               72

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        At another commercial installation of the supercritical fluid spray process, the reformulated
coating has sixty-seven percent less solvent than the conventional formulation applied by air-assisted
airless spray guns. In this application, the supercritical fluid spray process enables the same coating
appearance to be achieved at lower film builds.  Overall coating solids usage has been reduced by forty
percent, allowing an overall solvent usage reduction of eighty percent.

COMPARATIVE VOC, COVERAGE, AND COST DATA  FOR PLASTIC COATING

        Red Spot  Paint, a licensee of the supercritical fluid spray process, has developed several
coatings for use with the process.  In doing so, it was important for them, and ultimately their
customers, to understand both the technical and economic aspects of the technology.  Extensive
comparative data, in terms of VOC, coverage, and cost, has been generated and compiled.

        In comparing a conventional automotive-quality exterior acrylic lacquer to the version of the
coating reformulated  for use in the supercritical fluid spray process, it was immediately apparent that a
VOC reduction, to the compliant level, was achieved.  Michigan Rule 632, the applicable regulation
determining compliance, requires that the coating be applied at less than 5.0 pounds per gallon of
VOC. In addition to the VOC reduction obtained, all of the air  toxics, as  regulated by the Clean Air
Act, were eliminated from supercritical fluid  spray coating formulation.

WEIGHT SOLIDS (supplied)
WEIGHT per GALLON (coating)
VOC (supplied)
SOLVENT REDUCTION
WEIGHT per GALLON (reducer)
VOC (applied)
MI Rule 632 COMPLIANT?
CONVENTIONAL
FORMULATION
25%
7. SO pounds
5.62 Ib/gal
100%
6.68 Ib/gal
6.24 Ib/gal
NO
SUPERCRITICAL FLUID
FORMULATION
36%
7.77 pounds
4.97 Ib/gal
NONE
NONE
4.97 Ib/gal
YES
       Initial comparison of the VOC data does not make the supercritical fluid spray formulation
seem too impressive. Relatively, speaking, 4.97 pounds per gallon of VOC does not seem to be a large
improvement over 6.24 pounds per gallon of VOC. However, when the coverages (calculated for 1.0
mil dry film thickness with 100% transfer efficiency) of the two coating formulations are compared, the
advantages of the supercritical fluid spray formulation become much more dramatic.
~~-
VOLUME SOLIDS (supplied)
Theoretical COVERAGE (supplied)
SOLVENT REDUCTION
VOLUME SOLIDS (applied)
Theoretical COVERAGE (applied)
CONVENTIONAL
FORMULATION
18.9%
303 ft2/gal
100%
9.45%
152 ft2/gal
SUPERCRITICAL FLUID
FORMULATION
28.0%
449 ft2/gal
NONE
28.0%
449 ft2/gal
                                            73

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         The parameter that stands out the most in the above data is the theoretical coverage data of the
 conventional solvent-reduced coating.  The applied coverage of the supercritical fluid formulation is
 almost three times that of the conventional formulation.  The seemingly small difference in the VOC
 belies the fact that there is actually a huge difference in the coverages of the two formulations.

         While improvements in VOC and coverage are important, it has long been understood that the
 best way to improve a paint is to reduce its cost. Without a financial payback, many applicators are
 unwilling to implement VOC reducing technologies unless forced to by federal, state, or local,
 regulations.

PRICE PER GALLON (coating)
PRICE PER GALLON (reducer)
SOLVENT REDUCTION
'PRICE PER GALLON (CO2)
PRICE PER GALLON (applied)
Theoretical COVERAGE (applied)
COST/FT2 (® 100% Transfer efficiency)
COST/FT2 (9 30% Transfer Efficiency)
CONVENTIONAL
FORMULATION
$18.23
$4.28
100%
NONE
$11.26
152 ft2/gal
$0.074
$0.247
SUPERCRITICAL FLUID
FORMULATION
$26.63
$0.00
NONE
$0.58
$17.21
449 ft2/gal
$0.061
$0.183
 * - PRICE PER GALLON (C02) is based on a 30 weight percent reduction of the coating with CO2
 with the cost of $0.25/pound of
        The significance of the comparative data can be better understood with the realization that the
 supercritical fluid spray process has repeated demonstrated superior transfer efficiencies to the air spray
 process for which the conventional coating was formulated.  It is not unreasonable to expect, in light of
 the transfer efficiency studies done, efficiencies in the range  of at 50% for the supercritical fluid spray
 process.  Given that, the economics are even more dramatic.

VOC (applied)
Theoretical COVERAGE (applied)
TRANSFER EFFICIENCY (probable)
COST/FT2
CONVENTIONAL
FORMULATION
6.24 Ib/gal
152 ft2/gal
30%
$0.247 .
SUPERCRITICAL FLUID
FORMULATION
4.97 Ib/gal
449 ft2/gal
50%
$0 122
        The data shows that for this particular coating, a mere twenty percent reduction in VOC
realized by utilizing the supercritical fluid spray process translates to a fifty percent reduction in cost
per square foot of coverage for the applied coating. Applying the aforementioned principle regarding
cost reduction and coating improvement - it is clear that the supercritical fluid spray coating is twice as
good as its conventional precursor.
                                                74

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COATING SYSTEMS

        The supercritical fluid spray technology has been used to apply a variety of high-quality clear,
pigmented. and metallic coatings using thermosetting, thermoplastic, air-dry, and two-pack polymer
systems.  Polymers that have been successfully demonstrated include acrylics, polyesters, air-dry
alkyds, urethanes, melamines, phenolics, vinyls, epoxies, ureas, nitrocellulose, and cellulose acetate
butyrate.  A wide variety of pigments and filler materials have been used, including many colored
organic and inorganic pigments, titanium dioxide, carbon black, aluminum flake, calcium carbonate.
silica, and clay.  Most polymers and pigments used in conventional solvent-borne coating systems are
believed to be applicable to the supercritical fluid spray process. For many applications, little or no
adjustment will be needed in the polymer system; only the solvent-blend will need reformulated.

CONCLUSION

        Commercial production experience has clearly demonstrated that significant reductions of VOC
emissions can be made in coatings using the supercritical fluid spray process. Contrary to conventional
wisdom, the results also clearly show that, when using the supercritical fluid spray process, these
reductions in pollutant emissions are also characterized by significant improvement in the quality of the
coating and dramatic material and operating cost savings to the coating applicator.

        The supercritical fluid spray technology has been shown to be an effective  pollution prevention
technology that is applicable to most types of solvent-borne coating systems. Volatile organic
emissions have been reduced up to eighty percent and air toxic solvent emissions have been eliminated
in most coatings reformulated for use with the technology. It is expected that solvent emissions will
continue to be reduced as new coating systems are developed that have improved carbon dioxide
solubility.  Eventually, the technology is expected to become the liquid analog to powder coatings but
to have better coating performance and significant application advantages.

        Commercial use is expected to continue to expand because the process can be an effective
replacement for conventional high-solids coating  applications that use air, HVLP, air-assisted airless,
airless, and rotary spray systems.  Besides plastic coating applications, the technology is currently in
place in the market areas of wood furniture, automotive topcoats and components, general industrial,
adhesives, and  release coatings. Continued expansion in the  existing market segments, and penetration
into the areas of aircraft, metal office furniture, marine, drum, appliance, and specialty applications, is
expected in the near future.
                                               75

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                                        REFERENCES

 1.     Johnston, K.  Supercritical Fluids. Kirk-Othmcr Encyclopedia of Chemical Technology.
        3rd Edition. Supplemental Volume.  Wiley-Interscience, New York. 1984.

 2.     McHugh, M. A. and Krukonis, V. Supercritical Fluid Spray Extraction. Butterworths,
        Boston. 1986.

 3.     Nielsen, K  . A. et al.  Supercritical Fluid Spray application Technology:  A Pollution Prevention
        Technology for the Future. Journal of Oil & Color Chemists Association 74(10): 362-368
        (October 1991).

 4.     Nielsen, K. A. et al.  Advances in Supercritical Fluid Spray Application of Low-Pollution
        Coatings. Presented at the Air & Waste Management Association 84th Annual Meeting &
        Exposition.  Publication 91-104.5. Vancouver, British Columbia (June.  1991).

 5.     Anonymous.  First Carbon Dioxide Solvent Production System. Industrial Finishing 67(11):
        34-36(1991).

 6.     Nielsen, K.  A. et al.  A New Atomization Mechanism for Airless Spraying: The Supercritical
        Fluid Spray Process.  Pages 367-374 in Semerjian, H. G. Editor. Proceedings of the Fifth
        International Conference on Liquid Atomization and Spray Systems. NIST Publication 813,
        Gaithersburg, Maryland (July 1991).

 7.      Anonymous. Pennsylvania House Expands UNICARB Use.  Industrial Finishing 92(11):
        46-49(1991).

 8.      Nielsen, K.  A. et al.  Spray Application of Low-VOC Coatings Using Supercritical Fluids.
        SAE 1991 Transactions, Journal of Materials & Manufacturing, Sec. 5, Vol. 100: 9-16 (1992).

9.      Nielsen, K.  A.  et al.  Supercritical Fluid Spray Coating: Technical Development of a New
        Pollution Prevention Technology.  Presented at the  20th Water-Borne & Higher-Solids,
        and Powder Coating Symposium.  New Orleans (February, 1993).

ACKNOWLEDGEMENTS

        We acknowledge  the valuable contributions of J. N. Argyropolous. R.H.  Bailey, D. C. Busby,
R. S. Cesaretti. R. C. Clark, L. J.  Craft, D. J. Dickson, R. A. Engleman, C. W. Clancy, J. D. Goad,
B. L. Hilker, K. L. Hoy,  A. C. Kuo, J. J. Lear, C. Lee, M. A. Lutterbach, K. M. Perry. M. A.
Perry, N.  R. Ramsey, D. C. Ross, G. C. Ross. P. D. Samuel. S. P. Seiler, J. D. Wines, and P. R.
Zitzelsberger.  We thank Professor M. D. Donahue of Johns Hopkins University  and J. D. Colwell and
Professor D. W. Senser of Purdue  University for their assistance.
                                               76

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 (The work described in this abstract was not funded by the U.S. Environmental Protection
 Agency.  The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

                    (Expanded Abstract; Paper Not Available)
   UTILIZING DISPERSION RESINS WITH INORGANIC SOLIDS IN A
         NEW FORMULARY BLENDING PROCESS TO ACHIEVE
                SYNERGISTIC RESULTS OF PERFORMANCE

                                   Philip W. Coscia
                                    881 Ash Avenue
                                  Gustine, CA  95322
 In attempting to assess the dispersion performance of water-borne acrylic, urethane, and vinyl
 resins, certain liquid compounds and graded solids regarded commonly as pigments and fillers
 were employed. Dispersing these materials without adding to the volatile content, various
 surfactant/detergents were used. Microscopic investigation yielded what we considered
 unsatisfactory results.  As a comparative standard, we then employed textbook formulae in
 conjunction with these materials.  Investigation of dispersion effectiveness was less complete
 than what had been done prior without the use of added volatiles.  Because of experience in
 other areas of study, it was decided to utilize a blending technique as a developmental
 endeavor. It is this method which will be discussed.  We have come to realize the far
 reaching effect this can have for the asset protection market; complete blending adds to the
 life of an applied coating exponentially. There is much to yet be done in this field as  the
 extensive patentability is still underway and as is the perusal of the technical aspects for the
 explanation  of the forces at work.

 As conventional blending requires the use of additional compounds, which are undesirable as
 impactors to the quality of life as air and water contaminators, a blending sequence was
 laboratory instituted which demonstrated that highly effective mixing could be achieved in
 much less time than required conventionally.  Not only was it found that particle size was
 reduced without the need  for grinding, but compounds could be alloyed  that expressed no
 affinity for one another.  Moreover, minimum amounts of active materials suffice for
 performance when functionally dispersed.

 Through  a hydraulic extrusion in excess of 12,000 psi, a polyether dispersion, in conjunction
 with calcium, was driven across an orifice of novel design. This orifice was housed at the
 front of a tube which acted as a pressure reducing respository. The construction of the tube
 allowed calibration of a harmonic resonance.  We found that resonances are particularly
 unique to each compound. It was not until explanations for the especially fine compounds
 produced defied logic that it was deduced that synergism between the shear at the orifice and
the staged resonance was acting molecularly to set the ingredients at proper limits to their
ionic charges.  The visible effects of dispersion and the reduction of particle size achieved a
finished material with exceptional layout and physical performance properties.  The time
                                          77

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savings to produce the finished article appears to be in the range of 60 to 80 percent
Exotherming, common to paint manufacturing and which limits the total blending
completeness of finish, is no longer an issue.

Further calculation relative to orifice/resonance configurations achieved dramatic conclusions.
It was at this time that various compounds, which we knew to be immiscible, were applied to
the process.  Alloys were achieved  which performed in extended form as their concentrated
counterpart did.

We reviewed the findings of our results and formed conclusions pertinent to physical and
social qualifications:

       •     Conventional blending by shear blades in open tanks can be replaced by closed
             tanks moving materials by centrifugal pump across  a shear orifice, reducing
             manufacturing air and personnel impact

       •     Logistics of manufacturing efficiency can be further improved by the
             introduction of fluidized ingredients immediately downstream of the orifice.

       •     A superior finished product with the reudction of undersirable chemicals can be
             produced in less time with less energy and manpower.

       •      Alloys of dissimilar materials known to have no affinity can be produced
             which achieve superior performance of asset protection with  economy and ease
             of application (i.e.,  hand-rubbed, true perfluorinated wax).

      •      The where-with-all  to realistically bring these findings of fruition for scale
             production  will require concentrated effort and assets.

      •      Product yielded by this sequence achieves a balance of components which has
             yet to be explained  from a molecular standpoint  After the initial protections
             are in place to allow a request for funds from standard sources, we plan to
             develop our discovery further.
                                          78

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                             SESSION 3
                       POWDER COATINGS
                          PAPERS PRESENTED:

                       "Advantages of Powder Coating"
                                   by
                               Albert Holder
                       Naval Surface Warfare Center
                            Annapolis, Maryland

      "Aerospace Applications for Powder Coating at Hughes Aircraft Company"
                                   by
                              Larry W. Brown
                      Hughes Missile Systems Company
                              Tucson, Arizona

"Fluoropolymer Coatings for Architectural, Automotive & General Industrial Applications"
                                   by
                             David M. Grafflin
                         Market Manager - Coatings
                          Evodex Powder Coatings
                     Dexter Automotive Materials Division
                           Birmingham, Alabama
                                    79

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

                   ADVANTAGES OF POWDER COATING
                           ALBERT HOLDER
                   NAVAL SURFACE WARFARE CENTER
                        ANNAPOLIS, MARYLAND
 ABSTRACT

    Powder coating, a curiosity only a short while  ago,  has

turned, into a 17% per annum growth  item in  the United  States.

How did this happen?  The equipment manufacturers improved the

efficiency and equipment was custom made  on request, the  powder

manufacturers themselves invested in significant research and

development, but it would be fair to say  that  the EPA

 (Environmental Protection Agency) inadvertently did the most to

advance this technology by reducing allowable  volatile organic

compound (VOC).

      The Federal Government, while slow to  change, has invested

substantial time and money, and is using  the products.  For

example,  the Navy coating maintenance  facilities on the east and

west  coasts are increasing their usage.   Why this sudden

interest?  One hundred percent solids,  no waste on over spray,

dry film thickness from 0.8 mil to 300+ mils,  pencil hardness  of

6H, are good enough reasons.  But most  of all, when we recognize

that  near zero VOC is definately coming.  A  survey of the  options

indicates that for those components where fusion of the coating

is  feasible, powder coating is a good way to go.
INTRODUCTION


     Thermoplastic powder coating has been commercially available

since  the  50's,  but not in a refined form.  Particle sizes were

                               81

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 never consistent, the equipment was adapted to powder coating or
 was very expensive.  Re-tooling of paint shops was never required
 in the budget.
      Then in the 60's, thermoset powder coatings came into the
 market with better control of particle size.  The finished
 product looked like liquid paint and in most instances,  their
 properties were superior.
      Still progress was extremely slow in introducing the
 technology into paint shops,  because of the initial high expense.
 There  was no necessity to change,  as liquid paints were being
 made to their specifications  or custom made for  the old
 equipment.
      Then came environmental  regulations,  as administered through
 the EPA.   The agency's primary function is to control, monitor,
 advise and even fine if necessary,  any organization or person
 violating the federal laws on exceeding the limits  for pollution
 of  the air and water.   In our coating  industry VOC, toxic
 chemicals,  and pigments are of concern.  As important is the
 disposal  of waste created during manufacture and application.
 Disposal  sites are diminishing in numbers,  therefore supply and
 demand is  inflating the cost  of disposal.   Waste created is the
 responsibility of its  creator to the very end.  With this in mind
management  was making  an effort to  adjust or shutdown.  Paints
and coatings  with lower  VOC's like  high  solids, waterbased
coatings,  and powders  were all  potential replacements.  High
solids and waterbased  coatings  still produced overspray and
higher loss than  powder  coating, which has a 96-99% transfer
efficiency.   Waste  and pollutants are  minute in  comparison  to
                                82

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conventional paints.

      Equipment manufacturers have done their homework and

introduced new spray  guns,  spray booths,  extruders, mixers,  etc.,

by  improving efficiency and custom-building of units.  Many  paint

shops are required at this  point in time  to replace old

equipment, and those  who went with powder are very encouraged.


ECONOMIC ASPECTS

        Powder coating is a  proven compliance technology,  with

negligible overspray  loss,  no waste,  because it can be  recycled.

      Is it difficult  to formulate?  No!   Liquid coatings  can be

much more time consuming, with a great variety of  ingredients.

The composition of powder coating versus  conventional

paints are compared below:

                POWDER COATING     LIQUID  COATING

                PIGMENT(S)          PIGMENT(S)
                POLYMER(S)          POLYMER(S)
                CATALYST(S)         CATALYST(S)
                ADDITIVE(S)         ADDITIVES
                                   SOLVENTS

      For powder coatings the polymer  and  catalyst  can be

purchased as one resin.   Liquid coatings  for baking generally

contain more than one polymer,  two or more solvents and usually

more than one additive.

MANUFACTURE

                POWDER COATING         LIQUID COATING

                COLLECT INGREDIENTS    COLLECT INGREDIENTS
                PREMIX                 DISPERSE
                EXTRUDER               LET DOWN
                CHIPPING               ADJUST VISCOSITY
                GRINDING               PACKAGE
                PACKAGE

                                83

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      Without a doubt, raw material collection for manufacture of

 liquid paints or coatings is more labor intensive due to the

 greater number of ingredients and the fact that additions can

 only be made at certain intervals during manufacture.

 APPLICATION

      There are two common methods:
                     FLUIDIZE BED
                     ELECTROSTATIC SPRAY


 TYPES OF RESINS

                 THERMOPLASTIC
                 THERMOSET

      The thermoset resins or polymers in the future  will  be  used

 in place of non-compliance VOC coatings such as  epoxy polyamides.

 REACTION OF POLYMER TO HEAT

           THERMOPLASTIC              THERMOSET

              MELT                      MELT
              FLOW                      FLOW
              GEL                       GEL
                                        CURE  (NO  REMELT)

 COMMON THERMOPLASTIC      AND       THERMOSET POLYMERS

         POLYPROPYLENE                 EPOXY
         POLYETHYLENE                  POLYURETHANE
         NYLON                         ACRYLIC
         PVC                           POLYESTER  (LOW  MOLECULAR
         POLYESTER (HIGH MOLECULAR                   WEIGHT)
                      WEIGHT)

      Liquid coatings have  alkyd  resins as  the workhorse, powder

coatings have epoxy  resins.   Epoxies  can give thin or thick

films  and  therefore,  can be used for  decorative  or functional

purposes.   They  are  chemical  resistant and FDA approved.

     Polyester polymer  modified  with  epoxy resin, polyurethane,

or triglycidyl isocyanurate gives properties not achievable by

the individual polymers.
                               o4

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     Acrylic resins are  usually used in combination with blocked

urethanes and have excellent  gloss,  thin film appearance,  and

hardness with only fair  impact resistance.

PROPERTIES OF THERMO SET  POWDER COATINGS

POLYMER    HARDNESS   IMPACT    SALT-FOG    EXTERIOR    CUR I
*EPOXY
PENCIL
HB-5H
HB-2H
HB-3H
HB-3H
riNCH-LB)
60-160
60-160
60-160
60-160
( HOURS)
1000
1000
1000
1000
DURABILITY
POOR
FAIR
POOR
GOOD
VERY GOOD
GOOD
GOOD
(DEGREES F7MINS)
450/3
250/30
450/3
325/25
400/7
310/20
400/10
360/25
HYBRID


POLYESTER


ACRYLIC


      *Re-bar epoxies are cured  450/25 seconds.

THE ADVANTAGES OF POWDER COATING ARE CONVINCING.

      Powder coating shows both  technical and economic

advantages in comparison to other  processes, while lowering

coating costs,  quite considerably,  reducing production risks and

are

—economical—thanks to powder  recovery
—harmless to the environment—no  solvents
—more durable against mechanical  influences
—cleaner to work with—no solvents
—easily automated thanks to wrap  around
—high build films—achieved in one operation

WHAT  ARE THE PROCESS REQUIREMENTS  FOR POWDER COATING?

1.  Suspension of blank parts
2.  Pre-treatment (i.e. de-greasing, phosphating, chromating)
3.  Drying
4.  Powder coating
5.  Baking 275-450 F
6.  Removal of cured parts

MARKET SECTORS
                                85

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 TRANSPORT
-AUTOMOTIVE
-TRUCK & BUS
 DOMESTIC
 APPLIANCE
 BUILDING
 ELECTRICAL
 GENERAL
 INDUSTRIAL
 PUBLIC
 SERVICE

 HEAVY
 DUTY
-WHITE GOODS
-HEATING
-FIRES
-LIGHTNING

-ALUMINUM EXTRUSIONS
-CONSTRUCTION PARTS
-STRUCTURAL STEEL/ALUMINUM

-LIGHT/ELECTRONICS
-SWITCHGEAR

-TRADE COATERS
-OFFICE FURNITURE
-BUSINESS MACHINES
-SHELVING AND RACKING
-GARDEN FURNITURE

-STREET LIGHTNING
-FURNITURE

-REBAR
-GENERAL HEAVY DUTY
-PIPELINES
NAVY AND POWDER COATINGS

     The Navy has Naval shipyards and Shore Intermediate

Maintenance Activities at various locations on the east and west

coasts that apply powder coatings.  In these activities, shops

are set  aside for corrosion control and it is here that powder

coatings  are being used or seriously considered for production

purposes.

     Parts and components are received daily from ships and are

immediately:

     —Logged
     —Tagged for identification
     —Degreased with trisodium phosphate
     —Blasted  with  abrasive,  usually  aluminum oxide, to  near
       white metal
     —Preheated
     —Powder coated 10(+ or - 2) mils thick
     —Post heated
                              B6

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Surface    profiles for  steel  and  aluminum  are  two to  three

mils and one  to  two mils respectively.


     Epoxy powder  coatings have proved very efficient for Navy

use.  The Naval  Sea Systems Command (NAVSEA) has designated

powder coatings  for shipboard corrosion prevention and control

and is currently conducting testing and evaluation on the

feasibility of using powder coating as sealer and top coating for

thermal spray aluminum.  With the longer service life of  the

coatings, Naval  personnel will have more time for the ship

essentials like  training and vital operations.

     Powder coatings are less permeable, which is very important

in our case,  have  short baking times and produce almost no  pollutants or

hazards, since no  solvents are involved.

     Five years  of use in corrosion control application has

proved substantially positive.  Some of the areas now employing

powder coatings  are:

—Vent Screens
—Telephone Boxes
—Electrical  Boxes
—Light Fixtures
—Lockers
—Bunk Beds
—Search Light Fixtures
—New Construction
—Battle Helmets
—Or Any Portable  Housing
—Valve Bodies

     The Navy sees a  substantial  increase in  the  use of these

coatings in  the  never  ending battle  to  prevent  or  retard

corrosion.
                                87

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88

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 (The workdescribed in this paper was not funded by the U.S. Environmental Protection
 Agency.  The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

               AEROSPACE APPLICATIONS for POWDER  COATING
                          at HUGHES AIRCRAFT COMPANY
 Larry W.  Brown
 Hughes  Missile  Systems Company
 P O  Box 11337 801  N18
 Tucson, AZ. 85734
 INTRODUCTION

       Regulations restricting Volatile Organic Compound (VOC) emission and hazardous waste
 generation and disposal  are beginning to seriously impact the painting of aerospace hardware.
 Continued use of many of the traditional aerospace paint systems such as the Mil-P-23377 Epoxy
 Primer / Mil-C-83286 Urethane Topcoat has been prohibited in many areas  of the country since
 they exceed 420 gm/liter VOC content   Some users of the new compliant paint systems have
 experienced significant paint related cost increases due to  additional rework, more stringent
 record keeping, and increasing hazardous waste disposal costs

       Hughes  Missile  Systems  Company  (formally the Missile Systems  Group  of Hughes
 Aircraft Company) began working with powder painting in  1983 while searching for improved
 painting processes  Since the powder painting  process produces essentially no VOC's and reduces
 hazardous waste generation, it offers significant environmental advantages over competing paint
 systems including   compliant systems that reduce the level of emissions   The Navy approved
 powder paint for use on the interior of the Phoenix missile fuselage in 1986 and these have been
 successfully powder coated  since that date.   Additional development work has led  to several
 more  powder  paint  applications and successful implementations  on both  the  Phoenix  and
 Maverick missile programs

       Organic  coatings (paints) serve  a wide variety  of  functions in the missile  industry
 Exterior surfaces as well as some interior areas of missiles normally receive some type of organic
 finish  The customer specifies  the  required  finish system based on the  requirements of each
 service branch or application. The primary function of an organic finish system is for protection
 from environmental influences  Other associated .functions include visibility characteristics and
 missile identification for tactical or  training  purposes    Thus an organic  finish  system is an
 important aspect of missile manufacturing

       Conventional liquid  paints use solvents  to transport  the  pigments and resins over the
 surface to be painted.  After the volatiles evaporate, only the pigments and resins that form the
final painted surface remain.  Since these volatiles comprise a significant portion (30% to 80%) of
the applied paint film, only a fraction of the applied material forms the dry paint film.

                                        89

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        Powder paint, by comparison, consists of blended resins and pigments ground into a very
 fine powder  During application this powder is fluidized and usually electro-statically sprayed on
 the part being painted  The cure process uses an oven at temperatures ranging from 250°F to 400
 °F to fuse the  paint  particles to  each other and bond them to the substrate   Since there are
 essentially no volatile components (significantly less than  1%), all of the applied paint material
 becomes pan of the dry paint film

        Since the early 1980's powder painting has experienced tremendous growth averaging
 almost 20% growth per year in terms of quantities of powder sold1  Powder painting  is used in
 many commercial applications including appliances, automobiles, office furniture, architectural
 applications and sporting equipment.  The paint performance requirements for many of these
 applications are similar in many respects to the performance required of aerospace coating
 systems.

 POWDER PAINT MATERIALS

        There are two major classifications of powder paint, thermosetting and thermoplastic
 Thermosetting powder paints cross-link chemically to produce  higher molecular weight materials
 during the thermal cure process2  As the material cures, it chemically cross-links and will not
 reflow upon re-heating  A thermoplastic powder however will melt and flow upon application of
 heat, but  is chemically unchanged,  thus when reheated it will re-flow

 Thermoplastic Powder Coatings

       Thermoplastic coating materials include polyethylene, polypropylene, nylon,
 polyvinylchloride, and thermoplastic polyester  Thermoplastic powders are generally used for
 special applications requiring thick films and  they do not normally compete for the same
 applications as liquid paints. The high molecular weight resins used in thermoplastic powder
 paints are difficult to grind to the small panicle size necessary for the spray application and fusing
 of thin (less than 5 mils) films   These coatings are selected for their chemical resistance,
 electrical  insulation, weather ability, abrasion resistance, or low coefficient of friction

 Thermosetting  Powder Coatings

       Since thermosetting powder paints  chemically cross-link during the curing process to form
 higher molecular weight products, the cured coating has a different structure and properties than the
basic resin  Thermosetting powders can be ground into fine particle (25 - 40 microns average) and
can form thin paint coatings in the 1 to 3 mil range. These powder paints compete for the same
market with available liquid paints since they produce surface coatings with properties equivalent
and sometimes superior to the coatings produced by the liquid compliant technologies   A
technological expansion has occurred in the area of thermosetting powder paints in the last few
years   The major types of thermosetting powder paints are: epoxy, epoxy polyester hybrid,
urethane polyester,  and acrylics

                                         90

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 Epoxy Resin Powders

        Epoxy resins are utilized by most thermosetting powder paints in use today.   This class
 of powders offers excellent chemical  resistance, toughness, flexibility,  adhesion, and corrosion
 characteristics  Advances in epoxy formulations have enabled epoxy based powders to be tailored
 to a wide range of desired film characteristics  Additionally, epoxy powders can be formulated to
 cure over a wide range of bake temperatures some with cure temperatures  as low as 250° F
 Epoxy powders cost less than other available powder formulations

        Unfortunately, epoxy powder paints share liquid epoxy paint's limited ultra-violet ( UV )
 resistance and thus chalking of the paint surface is the result of extended exterior exposure.  An
 epoxy powder paint will chalk within a few months of exterior exposure.  This chalking does not
 significantly affect the paints excellent physical, chemical resistance, or corrosion protection
 properties Chalking  is a surface phenomena and inhibits further degradation.  Cleaning will
 restore much  of the original paint finish but will allow additional chalking to occur  Chalking is
 most noticeable on high gloss dark colored paints, while it is least noticeable on light colored low
 gloss paints   In addition to having equivalent or superior properties, epoxy powders generally
 cost less and can be formulated to cure at lower temperatures than other powder materials.

 Epoxy Polyester Hybrid Powders

       These hybrid coatings were developed in Europe as an attempt to improve the weather
 ability  of epoxy  powders  They  are closely related to epoxy powders and have similar properties
 Hybrid powders have improved over-bake and weather ability characteristics.  They still chalk but
 the rate of chalking  is slower and results in less discoloration than  standard  epoxy powders
 Hybrid powders provide corrosion protection similar to epoxy powders, although they have softer
 films and generally demonstrate a reduced resistance  to solvents and alkali.  These powders have
 excellent  electrostatic  spray characteristics and  demonstrate  improved penetration into corners
 and recesses relative to other powder coatings

 Urethnne Polyester Powders

       Urethane polyester  powders are comparable  chemically to  the exterior  quality urethane
paints  which have been used on aircraft, buses, and other vehicles for a number  of years.  These
films combine toughness with  excellent weathering characteristics.  These  coatings must  be
applied in thin films (less than 2  mils) or the mechanical properties,  such as impact resistance and
flexibility, tend to be degraded   These coatings  are good candidates where exterior durability is
required.
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 Acrylic Powders

        The final group of thermosetting powder coatings is the acrylics, which exhibit excellent
 exterior durability.  The acrylics generally exhibit excellent  hardness and good impact resistance
 along with excellent alkali  resistance.   However,  acrylics generally exhibit  inferior adhesion
 characteristics as compared to other powders  Acrylic powders are usually more expensive than
 other powder coating formulations

 APPLICATION CONSIDERATIONS

        Unlike liquid painting technologies, powder painting may not be applicable to every pan
 or assembly.   Since  powder paint is usually applied by electrostatic spraying, the surface being
 coated needs to be conductive or have a conductive  layer a few mils under the surface. This
 conductive layer is grounded during the application process and the charged paint panicles are
 electro-statically attracted.  A conductive wash may be applied to  non-conductive pans, such as
 composite materials, to provide a temporary conductive layer sufficient to provide electrostatic
 attraction of the paint panicles  After the paint particles have been electro-statically applied,  the
 ground may be removed and the powder panicles will maintain adhesion during normal handling

       Powder painted pans or assemblies must be capable  of being baked at the powder paint's
 cure temperature.  Cure temperatures range from about 250°F for a low temperature  epoxy
 powder paint to over 400°F  for some  other powder formulations.  Although powder cure times
 are  shon,  5 minutes  to approximately 45  minutes, they are at peak  temperature, therefore a
 massive pan must also be allowed the time necessary to reach temperature in addition to the cure
 time. Required cure  duration is generally inversely proportional  to cure  temperature   Since
 powder paints usually have excellent abrasion resistance, powder painted parts usually require
 little or  no touch-up after typical  assembly processes.   These  abrasion characteristics  allov
 components to be powder painted prior to  assembly, thus avoiding thermal damage to sensitive
 components or assemblies

       The pan geometry should also be evaluated to identify areas which  may be difficult to
 paint due to Faraday cage effect3   These  areas can usually be painted successfully,  but  some
 experimenting  with  application  process parameters (  atomizing pressure,  powder flow rate,
 voltage, etc.  )  and  spray application geometry may be necessary  Some substrate materials or
 surface treatments may also require experimentation to insure acceptable paint film characteristics.

       Due to the chemical resistance of some powder coatings, they usually cannot be effectively
 removed using  solvents or paint removers.  Removal usually requires some form of media blast to
 eliminate the paint economically.  Media  blast must be  carefully evaluated  before using it in
applications where  non-destructive testing  techniques  are used, since it may  obscure cracks,
corrosion or signs of metal fatigue.
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ECONOMIC CONSIDERATIONS

       Powder painting offers several  potential economic advantages when compared to liquid
painting technologies4.  Savings can be realized in the areas of labor, energy, material, hazardous
waste disposal, and safety.  The  savings in several of these  areas are sometimes difficult to
quantify; however,  when  analyzed and  added together,  the  powder system  usually offers a
significant cost advantage  over liquid  coating systems.   Table 1 summarizes  the approximate
costs per square foot for  a traditional manual liquid painting  operation and a manual powder
painting facility.  These costs are very sensitive to part complexity, painted area and lot size and
the data in Table 1 assumes a complex geometry totaling a few square feet of painted area flowing
through the painting operation in lot sizes of approximately 10.
1

I
3 COAT LIQUID
SYSTEMS
LABOR
MATERIAL
ENERGY
WASTE DISPOSAL
TOTAL COST
S/SQUARE
FOOT
2.00
.30
.05
.15
2.50

/

POWDER PAINT
LABOR
MATERIAL
ENERGY
WASTE
DISPOSAL
TOTAL COST

SQUARE FOOT
.50
.15
.05
.05
.75



7
f
Table 1.    Cost  Comparison - 3 Coat  Liquid Paint System vs Powder Paint
                                      93

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 Labor Savings

        Labor savings associated with powder painting result from several factors.  First, powder
 paints are delivered ready to use and require no mixing with solvents or catalysts This eliminates
 an  entire operation  usually associated  with  liquid coatings    Additionally, monitoring  and
 maintaining many process parameters associated  with liquid painting  (  viscosity, pH, solvent
 content,  percent solids, etc. ) is unnecessary. Powder painting is usually a one coat application,
 and significant labor savings result from eliminating the application of primer  and multiple top
 coat applications    Powder  painting requires  less operator skill and training  than  normally
 required  for  liquid painting   Since the  powder particles  can be removed from the part with
 compressed air prior to baking, it is very easy to rework parts prior to cure.  After the parts are
 cured, any required touch-up can be performed using a compatible liquid paint.  Clean-up of the
 paint gun and booth is much easier with powder paints and require only a broom and compressed
 air, and vacuum cleaner instead of the solvents and wipe cloths required to clean-up after solvent
 based liquid painting  In some applications powder painting may eliminate up to 75% of the labor
 required  for liquid painting

 Energy

       Significant energy  savings can be realized from  the implementation of powder  painting
 Since the quantity of volatiles in powder paints are minimal and no room temperature volatiles are
 present, the makeup air requirements can be dramatically reduced. No makeup air is required for
 the powder paint  booth and only small amounts are required to vent the ovens used  for curing.
 This translates  into  a significant savings in air  conditioning  or heating.   While the  oven
 temperatures  required for powder painting are significantly higher than normally used  to cure
 liquid coatings,  the cure  time is significantly shorter   Thus  there is usually  an energy savings
 resulting from implementing powder coating

 Material Costs

       The increased material utilization advantages possible using powder coatings usually result
in material cost savings when compared to liquid coating systems  An electro-statically applied
powder paint  will achieve approximately 70  percent first pass material utilization   The over-
sprayed powder particles can be collected, screened and then mixed with virgin powder for reuse
Since less than  1  percent of the  applied  material" is volatile, powders  easily achieve  material
utilization rates of about 95 percent  Liquid systems usually  achieve overall material utilization
rates of between  20 to 60  percent since the over-spray cannot be recycled and the  sprayed
material contains large quantities of volatiles
                                          94

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        There are fewer materials to store since powder coatings usually replace both the primer
 and topcoat   Most powder paints can be stored in room temperature environments (65° to 85°
 F, < 50% Relative Humidity) however low  temperature cure powders (< 300 ° F) may require
 refrigerated conditions Shelf life for properly stored material may vary from 6 to 12 months for
 low temperature powders to several years for other formulations

        Since drips and runs are almost nonexistent with powder painting, the reject rate typically
 declines,  resulting in  higher yields.  The cured  powder  paint film usually  has  better abrasion
 characteristics than  liquid paints. This enables powder painted  pans  to withstand handling and
 assembly with less paint damage, thus resulting in  reduced rework. Additionally, cleanup of spray
 guns and  paint booths used  for powder painting  requires no  solvents and is  therefore safer,
 cheaper and easier.

 Environmental Costs

        Significant quantities of flammable hazardous materials, including cleaning  solvents, mixed
 paint, catalysts, etc., are associated with liquid painting systems  These require special handling,
 storage, and disposal.   The need for these solvents and other flammable hazardous materials is
 eliminated when using powder coatings.   The quantity and type of hazardous waste generated
 from a powder coating operation is dependent on  the type of powder, resin formulation  and
 pigmentation  (metallic) constituents  Powder paint formulation sources  indicate that modern
 powder paints should  pass the Toxicity Characteristic Leaching Procedure (TCLP) testing  and
 alternatives to disposal as hazardous waste of excess or used powder may be  available depending
 on  local regulations.    Therefore, to ensure proper disposal,  the waste classification or listing
 should be determined  on a case  by case basis.  Powders have several  environmental advantages
 when compared to solvent  based  liquid coating  systems.   These advantages,  including  greatly
 reduced solvent use,  lower fire  hazard, and  greater operator safety,  provide a cost advantage
 when comparing powder painting to other painting systems.  The cost and liability associated with
 waste generated from a powder coating  process may  be  considerably less than  a solvent  base
 painting system.

       In  many areas, the  use  of certain  liquid coatings is either prohibited or requires  the
 installation and operation of expensive adsorption  devices to remove VOCs from paint booth  and
oven exhausts    The  lack of volatiles  in  powder paints eliminates this  problem  and  may
significantly reduce the fire risk   Powder paints  also result in a much cleaner environment for
paint shop employees,  and may lower labor costs by reducing the  overhead associated with safety
equipment and allowing a lower job class employee to perform the task.
                                         95

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 HUGHES MISSILE SYSTEMS COMPANY  (IIMSQ

        The standard liquid paint system used at the HMSC Tucson plant site is the Mil-P-23377
 epoxy primer and the Mil-C-83286 Urethane topcoat.  A Mil-C-8514 wash primer is also used
 on some alloys including inconnel.  Prior to 1986 ail production hardware was painted using
 these or similar high-solvent liquid paints.  HMSC  began evaluating powder paint in 1983 and
 implemented  several epoxy powder painting applications on both the Phoenix and Maverick
 missile systems between 1986 and January 1991. These powder paint applications accounted for
 approximately 60% of the  facilities production painting volume after January 1991.

        The typical  conventional wet paint process flow chart is presented in Figure 1 with  all
 VOC emission points and hazardous material generation points are identified. On substrates
 where a wash primer is required several additional operations are required which add additional
 VOC emission points and hazardous waste generation points to the flow chart.  Thus our
 conventional painting process consists of at least thirteen operations, twelve of which produce
 VOC emissions and eight of which produce hazardous waste.
        F.I THIRTEEN STEPS

        |   | TWELVE VCX; EMISSION ACTIVITIES

        HI EIGHT HAZMAT (PAINT, PAINT COMPONENTS. AND SOLVENTS) GENERATION ACTIVITIES
Figure 1:    Typical Liquid Paint System Process Flow

       Figure 2 shows the  epoxy powder painting process which has been used to replace
conventional wet painting on several applications at the HMSC Tucson facility.  This process
consists of only six operations with only one VOC emission point, one hazardous material
generation operation and two possible hazardous material (HAZMAT) generation operations.
                                        96

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                                                              f~%
                                                            HAZMAT?
                 SIX STEPS

                 1 VOC EMISSION ACTIVITY

                 1 HAZMAT GENERATION ACTIVITY

                 2 POSSIBLE HAZMAT GENERATION ACTIVITIES
Figure 2:    Powder Paint Process Flow

       The Toxicity Characteristic Leaching Procedure (TCLP) test data for the powder we use
indicates that it can be disposed of as ordinary waste instead of hazardous waste however this
needs to be evaluated for each powder paint and regulatory environment.  Thus the only VOC  and
HAZMAT generation point is the cleaning operation prior to painting. By implementing a high
pressure aqueous cleaning system this VOC and HAZMAT generation point was eliminated for
the powder painting of the Maverick airframe resulting in a paint process with  no VOC emissions
or hazardous material generation points.

       Comprehensive testing has been required to qualify powder paint for all current
applications since no Military Specifications cover the application or material performance of
powder paint on airborne systems.  A portion of the many tests procedures  included salt fog,
humidity,  dry and wet tape adhesion, abrasion resistance, impact, and resistance to various
solvents. The selected epoxy powder paint system was typically equivalent or  superior to the Mil-
P-23377 / Mil-C-83286 paint system which was used as the benchmark.  Since no appropriate
powder paint Mil-Specs exist, internal specification control drawings are developed and
engineering changes specifying powder painting are processed and evaluated on a case by case
basis. Although this is a lengthy process, environmental and cost benefits following
implementation make the effort worthwhile.
                                         97

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 POWDER COATING  INDUSTRY

        Powder painting systems suitable for most applications are currently available from several
 suppliers. Most low and medium volume applications can be handled using booths with manual
 electrostatic powder application guns and no powder re-claim capability5  For most applications
 these systems would use existing batch ovens for curing and could be integrated into existing
 paint shops  Systems for high volume applications is considerably more expensive since they
 usually incorporate capability for quick color change, powder re-claim, and monorail conveyor
 systems feeding the  pre-treatment equipment, powder paint booth, and cure oven.

        There are over ten major powder paint manufacturers supplying the US market  While
 most of these have worked with the aerospace industry they primarily supply powders for the
 automotive, appliance, and industrial markets. AJ1 of these manufacturers have powder
 development laboratories and can formulate small quantities of custom powders for testing.
 Minimum lot size for custom formulations may range from about 250 to 1500 pounds
 Purchasing small quantities of custom powders for low  rate applications can be challenging
 although the situation seems to be improving and one powder manufacturer is specifically
 targeting aerospace applications. Another powder manufacturer has  recently added the capability
 to supply from stock the full range of Fed Std 595a colors in a polyester powder formulation.

 Powder  Paint  Specifications

       The only Military Specification for powder painting is Mil-C-24712 "Coatings, Powdered
 Epoxy" issued by the Naval Sea Systems Command in February 1989. This specification was
 intended for interior  steel and aluminum  equipment, furniture, electrical box surfaces and exterior
 steel and aluminum surfaces exposed to marine environments. The first revision of this
 specification is scheduled to be issued in the near future and will add polyester powder paints for
 improved exterior UV resistance  Paints  meeting Mil-C-24712 are available from  several sources.

       Other specifications such as WS 22351 for the Mark 48 torpedo cover powder painting
 for specific weapon systems  This particular specification was issued by the Naval Underwater
 Systems Center  and covers the powder materials,  application processes and test requirements for
 the ADCAP torpedo.

 CONCLUSIONS

       Experience at the HMSC Tucson  plant site has demonstrated that powder painting
 consistently reduces the cost associated with painting while essentially eliminating  paint related
 VOC emissions and HAZMAT generation.   Although powder painting is not currently suitable
 for all aerospace applications it is both cost effective and appropriate for many applications
Increasingly stringent environmental  regulations tend to  favor the long term development and
 implementation of powder painting since it eliminates both VOC emissions and hazardous waste
generation
                                        98

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       The cost savings and quality improvements associated with powder painting has enabled
HMSC to be proactive in developing and implementing this environmentally friendly process even
in today's competitive environment  Efforts to implement new powder paint applications at
HMSC are expected to continue especially since previous powder painting applications have
demonstrated cost reductions, quality improvements in addition to eliminating paint related  VOC
emissions and hazardous waste generation
                                    REFERENCES

1      Bocchi, G J  Powder Coatings  A World Market Overview,  Conference Proceedings,
       Powder Coating'88, Sponsored by the Powder Coating Institute. Nov 1-3, 1988  p 1-3

2      Hester, Charles I  ,  Nicholson, Rebecca L. "Powder Coatings Technology Update",
       Environmetnal Protection Agency, Control Technology Center, EPA-450/3-89-33,
       October  1989, p 5-10.

3      Lehr, William D  Powder Coating Systems, McGraw-Hill, Inc  1991, p 104-106

4      Miller, Emery ed. User's Guide to Powder Coating, 2nd edition, SME, 1987, p. 21-28.

5      Serio, Earl, Powder Coating Application Equipment for the Small End User,  Conference
       Proceedings,  Powder Coating '92.  Sponsored by the Powder Coating Institute,
       Oct 6-8,  1992, p 207-220
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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
                FLUOROPOLYMER COATINGS FOR
           ARCHITECTURAL, AUTOMOTIVE & GENERAL
                    INDUSTRIAL APPLICATIONS
                            David M. Grafflin
                         Market Manager - Coatings
                     Dexter Automotive Materials Division
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       The primary focus of this paper  is an exciting, environmentally-compliant
 full-strength fluoropolymer powder coatings technology which combines all of the
 traditional  performance of the low solids solvent-borne PVDF  (polyvinylidene
 difluoride)  coatings used primarily in exterior architectural applications and
 specialty automotive critical fluids tubing requirements in a 100% solids powder
 coating system.   The development of a commercially viable PVDF powder coating for
 these applications is the direct result of successfully addressing the  somewhat
 unique issues relating to the efficient processing of the raw materials,  rather
 than a modification of the basic chemistry which has been utilized in a liquid,
 solvent-borne format since the mid-1960's.  The high level of performance which
 this chemistry has demonstrated in terms of the recognized aggressive architec-
 tural  specifications  and  its  resistance  to ultraviolet  light  degradation,
 chemical and mechanical  attack and  automotive  fluid resistance requirements, was
 initially evaluated with great care to determine the percentage of  the weight
 solids of the formulation which needed to be composed of the PVDF component.  In
 an evaluation array which spanned PVDF composition at everything from ten percent
 (by  weight  solids)  to  ninety percent of the formulation,  with a  variety of co-
 polymer chemistries  as the associated vehicle, it was  convincingly  demonstrated
 that  the PVDF material  (effectively dispersed in  a solvent  vehicle)  at a fifty
 percent  level, began to have a positive impact on the performance of the applied
 film, and that at a seventy percent  level, the optimum balance of performance and
 ease of application was accomplished, and this  quickly became the standard of the
 industry.
      At the time that  this technology was commercially introduced in its liquid
 form  (through a  series  of coatings companies  who were licensed  to utilize the
PVDF resin in this marketplace), the fact that this chemistry was self-limited
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 to a maximum of 35% volume solids, by virtue of the difficulties in dispersing
 the  resin,  was  a  non-issue,   as  the  entire discussion  of  VOCs and  their
 environmental impact had not  surfaced.  During the decade of the 1970's and into
 the early  1980's,  the  effectiveness of  this solvent-borne  liquid  chemistry
 continued and  flourished,  and  there were very few efforts directed at  moving
 toward a compliant vehicle.  The work which was done was directed initially  at
 a water-borne  dispersion of the  resin,  which proved extremely  difficult and
 ineffective in  sprayable formulations,  resulting in  films which demonstrated
 inconsistent performance,  and  which  were more  difficult  to  apply due to a
 tendency of the resin to agglomerate within the coating itself.   At the same
 time,  in those applications which were  being performed on conventional coil
 coating lines  (the  high volume users of this chemistry), the  installation of
 incinerators during  the early  energy  crisis to  capture  the relatively high
 solvent levels in these formulations in order to  recover the  fuel potential in
 these low volume solids formulations further reduced  the interest in a move to
 compliant chemistries.  The remaining segment of  the  market which was going to
 have to address this problem was in the spray application end,  typically handled
 by entrepreneurial independent  applicators who were, at least  at that time, not
 getting  extensive  attention from the regulatory agencies.
       Against  this  backdrop  of a  protected channel  of  distribution  and the
 limited  scope  of enforcement  activity,  there was  no driving compulsion for the
 primary  resin suppliers  to develop a compliant  material.   In the automotive
 tubing market, virtually all of  the initial applications for this technology were
 developed and utilized  in  Japan with no associated environmental pressure to
bring  these materials  into compliance.  The applications  were primarily via dip
application  and were able to coat  relatively large quantities of tubing with
 fairly small quantities  of  coating which  further  reduced the visibility of the
process as a source  of potential environmental liabilities.
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       In the American architectural metals marketplace, essentially none of the
 applicators  were involved  in or  particularly  aware of powder  coatings  as a
 technology, nor  were they equipped to apply the material.  In Europe, however,
 the situation was functionally quite  different.  The architectural marketplace
 was successfully being supplied with polyester powder coatings, both due to the
 lower levels of UV exposure present in their environment, and the significantly
 different infra-structure which had never fostered the growth of a viable PVDF
 liquid coatings market.  The applicators and the coatings manufacturers supplying
 this market were very comfortable with powder coatings as a technology, and with
 the somewhat different  cosmetic appearance which  powder coatings provide  (the
 slight "orange peel" evident in the cured film).   For them, the question was
 whether or not they  needed a  PVDF powder coating product,  as they had never seen
 their market  significantly  impacted  by  the  liquid  material,  nor were their
 customers demanding a significant upgrade in product  quality.   The marketplace
 had grown accustomed to the solid but reduced performance of polyester films  when
 compared to  full-strength PVDF films, and  they were  already  environmentally
 compliant by virtue of functioning in a powder  system.   They certainly had no
 desire to make a move  to PVDF  in  any liquid  format, either solvent or water
 borne, as this would be a complete transition in their coatings lines,  and their
 potential  interest in a  PVDF  powder coating was driven by the desire to be  able
 to  compete  in  an  increasing global  market  with  a  product  which met  the
 requirements  of the two  most environmentally  aggressive and growing markets,
 North  America  and the Pacific Rim.
       It  is  worth  noting  that  the   bulk  of  the  European  higher  quality
 requirements were initially being met with TGIC polyester powder coatings.  The
TGIC  crosslinker  (triglyceridyl isocyanurate) has  become the subject of  much
discussion in the past two years concerning its potential as a mutagen, based on
both inhalation and  ingest ion studies  in  Europe and the United States.   After
extensive testing and great public debate which  was leading the coating suppliers
                                      104

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 to evaluate and to commercialize non-TGIC polyester systems,  a re-evaluation of
 the test data has  led to a minimization of the concerns, and  in  fact,  in  many
 markets, the pressure has essentially disappeared concerning  the elimination of
 this material.   The  alternative  crosslinkers which  have been evaluated  are
 competitive in performance at essentially equivalent  cost, but given the lack of
 extended exposure and test data with them in formulated coatings, there has  been
 reluctance to move forward with a wholesale change given the  reduced  pressure
 from a hazardous materials  perspective.
       Sigma Coatings, B.V.,  in the Netherlands, who  had significant commercial
 activity in  PVDF liquid coil coatings and polyester  powder coatings for  the
 architectural marketplace,  became seriously interested in the potential for a
 PVDF powder  coating  in  the early  1980's,  and  undertook  a research project  in
 their facility in Zeist which  quickly arrived at the same functional hurdle which
 the preliminary efforts  in the USA had identified in  similar  attempts earlier -
 the complexity of this issue  was not  in  its chemistry  (the formulas of the two
 versions of this technology are identical), but in the efficient processing of
 this material, given the thermoplastic nature of the resin, in order to make its
 application  economical,  and  competitive to  the  liquid formulations  well-
 established in the marketplace.
       Traditional  thermosetting  powder  coatings  are  manufactured  in a  dry
 blending process in which the  ingredients are measured,  and blended together
 prior to being introduced into a modestly heated extruder  from which they emerge
 in a viscous  condition, are  rolled  out into a ribbon which  is  cooled and cracked
 into chips  or flakes, and subsequently introduced into a conventional grinder
which  reduces the  material  to the  fine  particle size distribution  which is
typical  of powder  coatings.   If  this  same procedure is utilized  with  PVDF
chemistries,  their thermoplastic  nature  survives  in  traditional processing up
until the material emerges  from the extruder.  At that point,  the material is
thoroughly  incompatible with room temperature grinding  as  it rapidly melts into
a taffy-like  mass which  resists further processing.
                                       105

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       The technical approach taken by Sigma Coatings was directed at simplifying
 the processing of this material  in light of its  thermoplasticity,  and toward
 developing a mechanical sequence which resulted  in  a high percentage through-put
 of a  viable material.  The  first significant  change  came at the exit  of the
 extruder, where rather than extruding the blended powder  coating out through
 chilled rolls in a ribbon-like format, the extrudate is forced through a water-
 chilled die  so  that  it resembles  uncooked spaghetti strands  which can then  be
 chopped into small semi-rigid pellets for further  processing.
       After a  series  of empirical evaluations,  it was rapidly determined  that
 conventional water cooling was not sufficient for  effective processing of  this
 material into  a usable product,  and  work  was  begun on  identifying the  most
 appropriate  cryogenic temperatures  at  which  a   workable  material  could  be
 manufactured.  The results of this work  (now well-documented  in two US patents
 issued in 1986 and 1989) demonstrated  that pre-cooling the  pellets produced  in
 the extruder  by  immersion  in  liquid nitrogen at approximately  -50°C.,  and
 introducing them into a grinder charged  with liquid nitrogen  at a volume which
 maintains the pellets at approximately -125CC. throughout  the  grinding process,
 yielding in  excess of ninety-seven percent usable product.   The powder which  is
 produced is  predominantly  in the 40-55 micron particle size  distribution  range,
 and once applied,  demonstrates superior  film flow and leveling, resulting  in a
 cosmetically attractive  film which provides all  of the  performance  of  the
 traditional  solvent-borne  materials, and reduces their approximately 6.5  pounds
 per gallon of  VOC's  to almost  nothing.   In addition, by the nature  of  the
 chemistry,  the  finished  PVDF powder coating  is  extremely  compatible with
 electrostatic application  (either  corona or tribo), and applies effectively at
extremely low voltage and air settings on any available powder coating equipment.
                                     106

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       No conversion of technology euch as this happens easily, or  with  direct
 translation of all of the benefits of the former system into the new one.  Powder
 coatings,  by  virtue  of their  composition  and format, will never  be able  to
 replicate the blending systems readily available in their liquid counterparts
 which make possible the combination of base colors into custom colors in  very
 small batches. In addition, the liquid clear coats which are  produced in  liquid
 fluoropolymer chemistry as an adjunct coating to the color coats are not possible
 in powder, as the exposure to liquid nitrogen hazes the material  irreversibly and
 imparts a cloudiness to the applied film which is cosmetically and functionally
 unacceptable.  In addition,  it is more difficult to produce brilliant metallic
 colors in this technology through the typical  powder coating bonding process as
 it tends to fuse the thermoplastic material unacceptably,  while dry-blended PVDF
 metallics are certainly viable.  Beyond these  few limitations, it is important
 to  repeat that the color space of  PVDF coatings, either powder  or  liquid, is
 EXACTLY the same by virtue of the  fact  that the pigmentation utilized to deliver
 the performance mandated by the architectural specifications which typically call
 for this material (American Architectural Manufacturers Association 605.2, etc.)
 is identical.  These ceramic pigments, which demonstrate tremendous stability in
 extended UV exposure,  and deliver the  high  levels of color and gloss retention
 demonstrated by PVDF films,  are identical in the liquid and powder formulations,
 assuring that  the colors are the same in the final films.  The  resin which  is the
 backbone of  these PVDF coatings, traditionally known  by  the tradename of its
 producer (Kynar 500*  as produced originally by the  Pennwalt  Corporation, more
 recently acquired by  Elf  Atochem North America, Inc.),  is  different  in its
particle size depending on whether the  vehicle  is to  be powder or liquid.  Kynar
 500*, when provided for powder coating  use, is provided in a finer particle size
under the tradename Kynar 500PC*.  The  chemical composition of the resin  is un-
changed, as is the  performance of the  applied film, as measured  in  all of the
traditional measures of architectural performance.
                                        107

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       The longest term measure of performance, and the single criterion which
 most  specifically  separates  full-strength  PVDF  films  from  their  lesser
 counterparts,  is  the stability of these coatings in  extended exterior exposure.
 The  traditional  measurement  in the  architectural  market  is color  and gloss
 retention after five years of exposure  in  South Florida at a 45°  angle.   The
 first panels of liquid PVDF films went on exposure in  early 1964, and there are
 literally thousands and  thousands of  such panels  still  on exposure,  amply
 demonstrating  the performance properties of this material.  The first panels of
 powder  PVDF films went on similar  exposure in April  of 1986, and as of  this
 meeting  are  now  over  seven  years  old,  and  are  demonstrating all  of  the
 performance characteristics of their liquid counterparts in terms of  exposure.
 In accelerated testing,  the  powder films meet and exceed all of the physical
 testing standards, with the superior performance most  associated  with the  fact
 that the  powder  coatings  tend to  develop  a  thicker  film  than their  liquid
 counterparts (1.6-1.8 mils total film versus 1.0-1.2 mils total film), with  the
 advantages seen most  often in  falling  sand resistance,  transit abrasion  and
 handling  damage  improvement,  preferable pencil  hardness,  and  more uniform
 deposition on formed radii and shapes.
      The thermoplastic systems described in this paper are applied as the last
 step of  a total  finishing process  for  architectural substrates.    From  the
 pretreatment perspective,  the  requirements for proper  cleaning and  either
 chromate or chrome-phosphate  conversion coatings, remain the same in powder as
 they are in liquid.  There is a requirement for a traditional primer chemistry,
 available in either a liquid flash version or a powder  cured vehicle, under  the
 PVDF  powder coatings.   The specific  gravity of the  PVDF  powder coatings is
 relatively high, typically 1.7, which sees applications  efficiencies on line with
 proper voltage  and air controls, at the level of 60 square feet of coverage  per
 pound  of  powder  applied  or  more,  with extremely  high  first pass  transfer
efficiency given the  electrostatic affinity  of this  material to which we have
already  referred.
                                      108

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       With the demonstration of a viable thermoplastic PVDF powder coating for

 monumental architectural applications,  the industry now  has  a full range  of

 environmentally  compliant  technologies  with  which  to address  the emerging

 enforcement of the 1990 Clean Air Act and its amendments.  From the conventional

 TGIC polyesters  on which this market  segment  was founded  in Europe,  to the

 emergence of the functionally equivalent non-TGIC  polyesters which resolve the

 potential for any mutagenic concerns during application, to the presence of the

 PVDF films, there is now a  range of  product qualities  available which meet and

 exceed the requirements  for commercial/light industrial/low-rise architectural

 specifications (AAHA 603.8 typically), right through monumental architectural

 specifications as discussed (AAMA 605.2 typically).  It is worth re-stating that

 the  performance of these materials and the differences between  them is the same

 in powder as it is in liquid, as the chemistries neither gain nor lose properties

 by virtue of their physical state.  The greatest differences in gloss and color

 retention between polyesters and f luoropolymers relate both  to the base resin and

 the  pigmentation (polyester versus PVDF and organic versus ceramic), and in a

 study  which spans a wide  color  space, with  both  systems  formulated  to the same

 colors at  roughly equal  low gloss  levels,  performance in  45° South  Florida

 exposure is as follows:

                                                      RETAINED
                                    ORIGINAL            GLOSS
   COLOR         RESIN SYSTEM          GLOSS             (3 YEARS)          AE

White           Polyester             30.0              11.7             1.60
White           Kynar 500* PVDF       37.0              44.7            1.09
Yellow         Polyester             28.0               9.2           15.43
Yellow         Kynar 500* PVDF       15.0              20.7            3.06
Dark Blue      Polyester             29.0               2.7            9.48
Dark Blue      Kynar 500* PVDF        4.0               5.5            1.20
Black           Polyester             32.0               2.8           10.30
Black           Kynar 500* PVDF       17.0              16.9            1.26
Dark Brown     Polyester             38.0               1.7           11.52
Dark Brown     Kynar 500* PVDF       43.0              39.5            1.14

     The two systems utilized to  perform this  study  are currently commercial

systems  which  are in wide distribution for architectural applications of  the
                                       109

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 typical variety  (everything from window systems to entryways to spandrel panels
 to full curtain-wall configurations).   rive year exposures in Florida in full
 strength fluoropolymer powder and liquid systems are virtually indistinguishable
 in  their  performance against  the  requirements  for  color  stability,  gloss
 retention, film integrity and other barometers of performance.   In the automotive
 marketplace,  interest  has  now  expanded  from   the  critical  fluids  tubing
 application to utilizing PVDF cabling compounds for fuel hoses (both in vehicle
 and in fuel  pumping applications)  and to the use  of PVDF  films  for  fuel  tank
 lining applications  and for body-color-matched side molding applications where
 the exceptionally strong  weathering  resistance can support the cost  of  a  more
 expensive material.   There are numerous evaluations underway at the domestic Big
 Three and  the transplants to expand the use of  this  technology in  its  more
 compliant forms (film, powder, water-borne,  etc.)  as well as in the traditional
 solvent systems,  with  the obvious  advantages  for  environmental compliance
 favoring the non-solvent borne materials.
      Before  closing, it  is appropriate  to review other  characteristics of
 f luoropolymer powder coatings technologies which must be kept in mind during its
 application.   As with other powder coatings, this material is melt-processable,
 and recommended peak  metal temperatures must be reached in order to achieve  full
 "cure" of the  applied film.  The recommended time at temperature is the same as
 it is for its liquid counterpart (5 minutes above  450°F.).  In order to optimize
 the  flow and  leveling of the topcoat,  the powder primer must  be  at least
 partially cured prior to application of the topcoat.  This preliminary  cure  also
 serves to assure  that there  will be none  of the powder primer which is knocked
down into the  reclaim of the topcoat, thereby diminishing its integrity.  The
 liquid  flash primer  requires  a  minimum of  5 minutes  of flash  time  prior to
application of the topcoat to assure that all residual solvents  are removed  from
the primer film and do not blow through the topcoat during the curing cycle.  In
addition, the liquid flash  primer is formulated without the traditional  strontium
chromate component, making it the most environmentally compliant  liquid material
currently available.

                                       110

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      In  the  other segments  of  this  conference,  many other  aspect* of  the
 handling and application of thermoplastic powder coatings have been covered.  For
 both the automotive and architectural communities which are still coming to grips
 with this technology,  the opportunity this material presents to set aside all of
 the  potential environmental  complications which  the  traditional  technology
 entails (the need to incinerate at considerable expense, and the calculated risk
 of chasing federal and local air quality regulations which will be ratcheted down
 in increments over the next several years during the enforcement of the Clean Air
 Act) is  significant.   Given the  extremely high level of vocs existing in  the
 traditional  formulations (higher on a per unit  basis than  almost  any other
 conventional coating), the liquid fluoropolymer coatings will be among the first
 to be targeted by the  probable increase in regulatory enforcement over the next
 few months  and years.   The  availability  of  a proven technology in a fully
 compliant  form which exceeds the demands  and expectations of the material
 specifiers, the regulators,  and the architectural and automotive customers is a
 tribute  to  those  who  had   the  foresight  to tackle  the  unique  processing
 characteristics of a performance-capable thermoplastic material, and to develop
 the appropriate procedures to make it viable.
David M. Grafflin
Market Manager - Coatings
DEXTER AUTOMOTIVE MATERIALS DIV.
psb/5-6-93
NOTE:     Kynar 500* and Kynar 500PC* are  registered trademarks of Elf
          Atochem   North  America,   Inc.  (formerly  the   Pennwalt
          Corporation), for their architectural  f luoropolymer resins.
                                       Ill

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                                    BIOGRAPHY

                               DAVID N. GRAFFLIN
                           MARKET MANAGER - COATINGS
                             THE DEXTER CORPORATION
                      DEXTER AUTOMOTIVE MATERIALS  DIVISION
                             1-7 EAST WATER STREET
                              WAUKEGAN, IL  60085
Currently  serving  as Market Manager-Coatings for the Coatings Group of Dexter
Automotive  Materials Division,  encompassing the activities  of  EVODEX Powder
Coatings (a  joint  venture of The Dexter Corporation and Evode Group pic), Mr.
Grafflin has spent the last eight  years  in domestic and international market
development  of a  variety  of  fluoropolymer  technologies,  with  a  particular
emphasis in  full strength  PVDF powder  coatings.

Since the commercial introduction of this material in the North American market
in 1991 (when it reached five years Florida exposure), EVODEX has provided a full
spectrum of  powder coatings  for interior  and exterior residential, commercial,
industrial and monumental  architectural applications.
                                       112

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                             SESSION 4
                      FEDERAL PROGRAMS
                          PAPERS PRESENTED:

 "U.S. Navy Compliance to Shipbuilding and Ship Repair Environmental Regulations"
                                   by
                               Alex Kaznoff
                       Naval Sea Systems Command
                            Arlington, Virginia

"Low-VOC Coatings Developed by DOE for Environmentally Conscious Manufacturers"
                                   by
                              Mark D. Smith
                            Allied Signal, Inc.
                           Kansas City, Missouri

      The Precedent-Setting Use of a Pollution Prevention Project in an EPA
         Enforcement Settlement: The First Dollar-for-Dollar Penalty Offset"
                                   by
                              David Nelson
                        EnviroSearch International
                            Salt Lake City, Utah
                                   and
                            James J. Periconi
                     Donovan Leisure Newton & Irvine
                           New York, New York

                  "Array Pollution Prevention Success Stories"
                                   by
                                Jack Hurd
            Army Acquisition Pollution Prevention Support Office
                            Alexandria, Virginia
                                  and
                             Mark W. Ingle
                     Ocean City Research Corporation
                            Arlington, Virginia

                                  113

-------
    (The work described in this paper was not funded by the U.S. Environmental Protection
    Agency. The contents do not necessarily reflect the views of the Agency and no official
    endorsement should be Inferred.)
US NAVY COMPLIANCE TO SHIPBUILDING AND SHIP REPAIR
              ENVIRONMENTAL REGULATIONS
              NAVAL SEA SYSTEMS COMMAND
                         CODE05M
                         ALEXKAZNOFF

-------
                             OVERVIEW


           O  CLEAN AIR ACT AMENDMENT (CAAA)


           O  CONTROL TECHNIQUES GUIDELINES (CTG)


           O  NATIONAL EMISSION STANDARD FOR HAZARDOUS AIR POLLUTANTS
              (NESHAP)


           O  CALIFORNIA REGULATIONS


           O  CURRENT DoD COMPLIANCE EFFORTS
                                           i


           O  DoD TR1-SERVICE RAD COATINGS PROGRAMS
DUMB

-------
  CLEAN AIR ACT AMENDMENT 
-------
                           CAAA TTTUES 1 & 3

    O   MAAQS (TITUE 1)

        o   OZONE:  ESTABLISH AND ISSUE COMT1ROL TECHNIQUES GUIDEUNES
                   (CTGs)  TO REDUCE AGGREGATE EMISSIONS  OF VOLATILE
                   ORGANIC COMPOUNDS (VOCs)

                > > VOCs:   MANY SOLVENTS USED IN PAINTS CHEMICALLY REACT
                           WITH NQx AND SUNLIGHT IN THE ATMOSPHERE TO
                           FORM OZONE

        o   PM-10:  ESTABLISH AND ISSUE CONTROL TECHNIQUES GUIDELINES
«                  (CTGs) TO REDUCE AGGREGATE EMISSIONS OF PM-10

               » PM-10;   PART1CULATE MATTER WITH A DIAMETER OF LESS
                           THAN OR EQUAL TO TEN MICRONS
    O  HAPs(TITLE3)

        o   HAPs:   ESTABLISH AND ISSUE NATIONAL EMISSION STANDARD FOR
                   HAZARDOUS AIR POLLUTANTS (NESHAP)

                > > HAPs:   HAZARDOUS AIR POLUJTANTS WHICH POSE ADVERSE
                           ENVIRONMENTAL AND/OR HUMAN HEALTH AND SAFETY
                           EFFECTS (APPROX.189 HAPs)
 DM. MB
 BIMTM

-------
         CONTROL TECHNIQUES GUIDEUNES (CTGs) FOR VOC SOURCES

    O  FEDERAL OZONE MEASURES (CAAA - TITLE I)

       o   ISSUE CTGs FOR STATIONARY SOURCES OF VOC EMISSIONS FROM
           PAINTING IN THE FOLLOWING INDUSTRIES:

               AUTOMOBILE/LJGHT TRUCK     -   METAL FURNITURE
               METAL COO.                 •   LARGE APPLIANCES
               FABRICS                   -   PAPER
               MAGNETIC WIRE INSULATION    -   CANS
               MISCELLANEOUS METAL PARTS  -   FLATWOOD PANNELJNG
           -   AEROSPACE

           *   SHIPBUILDING OPERATIONS AND SHIP  REPAIR  COATINGS AND
               SOLVENTS- COVERS VOC AND PM-10 EMISSIONS

    O  HAZARDOUS AIR POLLUTANTS (CAAA - TITLE 3)

       o   ISSUE NESHAPs FOR ALL STATIONARY SOURCES THAT EMITS HAPs
OR.MEXRUMUV

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              SHIPBUILDING OPERATIONS AND SHIP REPAIR CTG
       FEDERAL REGULATORY DEADLINES

               ISSUANCE:  BEFORE NOVEMBER 15,1993
               EFFEC7TVTTY: TO BE DETERMINED, FED & STATE IMPLEMENTATION
                          MAY BE DIFFERENT

       IMPACTS

       o   EXISTING  SHIPBUILDING AND  SHIP REPAIR EMISSIONS SOURCES IN
           NONATTAINMENT AREAS

       O   VOC AND  PM-10 EMISSIONS FROM THE APPLICATION AND REMOVAL OF
           PAINTS, COATINGS, AND SOLVENTS ABOARD MARINE VESSELS (EXCLUDING
           PLEASURE CRAFT)

       o   VOC AND PM-10 OMISSIONS STANDARDS BASED ON BEST AVAILABLE
           CONTROL MEASURES (BACM)

               BACM:   AN EMISSION LIMITATION THAT WILL ACHIEVE THE LOWEST
                       ACHIEVEABLE EMISSION RATE FOR THE SOURCE TO WHICH
                       HT IS APPLIED
CODECOM

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         SHIPBUILDING OPERATIONS AND SHIP REPAIR NESHAP

O   FEDERAL REGULATORY DEADUNES - NESHAP

           ISSUANCE: NOVEMBER 15,1993 (ORG. NOV *94)
           EFFECnVfTY: TO BE DETERMINED

O   IMPACTS

    O   NEW  AND  EXISTING SHIPBUILDING AND  SHIP REPAIR FACILITIES
        CONSIDERED MAJOR AND AREA EMISSIONS SOURCES (189 HAPs)

           MAJOR SOURCE: 10 TONS/YR OR MORE OF ANY HAP OR 25 TONS/YR
           OR MORE OF ANY COMBINATION OF HAPs

    O   PHASE I -  DEVELOP HAPs EMISSIONS STANDARDS BASED ON MAXIMUM
        ACHIEVEABLE CONTROL TECHNOLOGY (MACT)

           MACT:  NEW-  AS STRINGENT AS THE AVG. ACHIEVED BY THE
                           BEST CONTROLLED SIMILAR SOURCE
                   EXISTING -    AS STRINGENT AS THE AVG. ACHIEVED BY
                               THE  BEST   12  PERCENT  OF  EXISTING
                               SOURCES

    o   PHASE II - DEVELOP RISK-BASED EMISSION REDUCTIONS

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                          STATE REGULATIONS


   O  STATES REQUIRED TO DEVELOP •STATE IMPLEMENTATION PLAN' (SIP) WHICH
       ADOPTS FEDERALRECHJIREMaiTSASAMINlMUM TO ACHIEVEMENT ATTAINMENT
       OFCAA

       o   CALIFORNIA

               14 AIR QUALITY MANAGEMBTT DISTRICTS (AQMDs)

               -BAY AREA AQMD
               .SOUTH COAST AQMD
               -SAN DIEGO APCD

    O  CALIFORNIA REGULATIONS IMPACTING DoD ACTWITTES

       o   ARCHITECTURAL & INDUSTRIAL MAINTENANCE (AIM) REGULATIONS
               PAINTS APPLIED TO SHOREBASED FACILITY STRUCTURES

       o   MISCELLANEOUS METAL PARTS AND PRODUCTS
               PAINTS APPLIED TO SMALL METAL PARTS (USUAULY LIMITED TO SHOP
               APPLICATIONS
•IMYB

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U)
  CALIFORNIA REGULATIONS IMPACTING DoD ACTIVITIES (cont'd)

o   AEROSPACE COATINGS
        PAINTS APPLIED TO AIRCRAFT OR EQUIPMENT/ORDNANCE INSTALLED
        ON AIRCRAFT

o   MARINE COATINGS
        PAINTS APPLIED TO MARINE VESSELS OR EQUIPMENT/ORDNANCE
        INSTALLED ABOARD MARINE VESSELS

CALIFORNIA REGULATION REQUIREMENTS

o   GENERAL LIMITS FOR VOC CONTENT

        AIR DRIED COATINGS (CURE AT TEMPERATURES BELOW 194T)
        BAKED COATINGS (CURE AT TEMPERATURES ABOVE 194T)

o   SPECIALCOAT1NGAPPLICAT1ONIJMITSFORVOCCONTENT(ESSEiniALFOR
    CONTINUED MARINE COATINGS OPERATIONS

        VOC CONTENT LIMITS BASED ON IN-SERVICE ENVIRONMENT AND
        PERFORMANCE REQUIREMENTS
        .JUmFOULJNG (AF) PAINTS - NAVY APPLICATION
        ..CHEMlCALAGEtfTRESISTAffTCOATINGS (CARC) -ARMY APPLICATION
        -AIRCRAFT WING COATINGS - AIR FORCE APPLICATION
core O

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               HAVY RESPONSE TO CALIFORNIA VOC REGULATIONS




      O  REFORMULATED PAINTS AND COATINGS TO COMPLY WITH MARINE COATINGS

         REGULATIONS


         o   REDUCED SOLVENT (VOC) CONTENT FOR ENVIRONMBiTAL COMPLIANCE


         o   ENSURE CONTINUED OPB1A11ONAL AND SERVICE LIFE PERFORMANCE


         o   SUBSTHimON/CANCELLATlON OF PAINTS
M

*     O  PURSUE NEW TECHNOLOGIES FOR VOC REDUCTION


         o   HIGH SOLIDS PAINTS AND COATINGS


         o   WATH1 BASED PAINTS


         o   POWDER COATINGS (THERMAL PLASTIC)


      O  CALIFORNIA COMPLIANCE PROGRAM


         o   THREE YEAR PROGRAM  ($3M> TO  DEVELOP, TEST, AND  QUALIFY
                         NAVY MARINE COMPLIANT PAINTS

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N>
cn
          NAVY "CALIFORNIA COMPLIANCE- LESSONS LEARNED

O   LEAD TIMES - (BEST & WORST CASE: 24 VS 45 MONTHS)

    O   TEST & EVALUATION (T&E):  TECHNICAL DIFFICULTIES IN R&D IMPACTS
                               COMPLIANCE SCHEDULE
            LABORATORY REFORMULATION
            PERFORMANCE VALIDATION
            TOXICOLOGICAL/HAZMAT REVIEW-ATMOSPHERIC CONTROL TESTING
            SPECIAL APPLICATION TESTING (Lc. FIRE AND/OR HEAT RESISTANCE)

    O   DOCUMENTATION/SPECIFICATION UPDATE

            QUALIFICATION OF VENDOR PRODUCTS
            TECHNICAL GUIDANCE FOR END USER (FLEET)
            REVISION OF SPECIFICATIONS TO INCLUDE APPROVED PRODUCTS

    O   IMPLEMENTATION OF COMPLIANT MATERIAL TO FLEET

        < < EXPERIENCED SIGNIFICANT LOGISTICS PROBLEMS AND DELAYS > >
            NEW PROCUREMENT OF COMPLIANT MATERIAL (CONTRACT BUYS &
            NATIONAL STOCK NUMBERS (NSNs)
            COMPETITIVE BUYS - SHIPMENT/DISTRIBUTION
            STOCKING AND SUPPLY TRANSIT! ON OF COMPLIANT MATERIAL TO THE
            SUPPLY SYSTEM
 CR.MJEX

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                        NAVY LESSONS LEARNED (coifd)


      O   INTERIMVARIANCESNEG011ATH>INAIl.TT1REEDISmflIC1S
          AND SUPPLY


      O   NAVY STILL COMPLETING UPDATE TO NAVAL SHIPS TECH MANUAL (NSTM
          CHAPTER 631) AND SPECIFICATIONS TO REFLECT CHANGES


S     O   NAVY NOW Di COMPLIANCE WTTH SEPTEMBER 1991 RULE AND SEPTEMBER 1994
          PENDING RULE


      O   SPECIALTY CATEGORIES MUST BE SPECIFIED TO ENSURE THE CONTINUED USE
          OF CURRENT NAVY COATINGS
    A'Bt

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to
-J
            CURRENT NAVY COATINGS PROGRAM EFFORTS

O   REFORMULATE SHIPBOARD PAINTS AND COATINGS TO REDUCE VOC CONTENT
    LJMTTS TO 1HE LOWEST PRACTICAL LEVELS

    o   SUPERCRITICAL CO2 TECHNOLOGY

O   SHIPBOARD PAINTS AND COATINGS HAZARDOUS MATERIALS DATABASE

    o   ENVIRONMENTAL ISSUES

           IDENTIFY HAPS LEVELS IN  ALL NAVY SHIPBOARDS  PAINTS AND
           COATINGS

           _   REFORMULATE PAINTS TO SUBSTITUTE/ELIMINATE HAPs  TO
               COMPLY WITH STATE AND PENDING EPA LEGISLATION

    o   HEALTH AND SAFETY ISSUES

           IDEN11FY HEAVY METALS CONTENT IN PAINTS IN EXCESS  OF
           PERMISSIBLE LIMITS

           IDENTIFY IMPROVED PAINT REMOVAL EQUIPMENT AND TECHNOLOGY
           TO MINIMIZE POTENTIAL  HEALTH HAZARDOUS DURING COATING
           OPERATIONS

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                        ARMY COATINGS PROGRAM


     O   REFORMULATED PAINTS AND TOPCOATS TO MEET CALIFORNIA VOC LIMITS

         o   PRIMERS

         o   TOPCOATS

         o   CARC COATINGS

M
«    O   CURRENT RftD ACTIONS

         o   REFORMULATION OF LAOUERS

         O   AMMUNITION ENAMEL

         o   HEAT RESISTANT COATINGS

     O   EXPANDING USE OF POWDER COATINGS

     O   EXPANDING USE OF ELECTROSTATIC COATINGS
  DR. Mat!

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                 AIR FORCE COATINGS PROGRAM


O   CURRENTLY IN COMPLIANCE  WITH  CALIFORNIA AEROSPACE  COATINGS
    REGULATION - PRIMERS AND TOPCOATS

    O  AIRCRAFT

    o  WEAPON SYSTEMS

    o  GROUND SUPPORT EQUIPMENT

O   AIR FORCE DEPENDS HEAVILY ON AEROSPACE INDUSTRY FOR R&D  OF
    AEROSPACE PAINTS AND COATINGS FOR ENVIRONMENTAL COMPLIANCE

O   REQUIRES R&D COATINGS DEVELOPMENT

    o  FUEL TANK COATINGS

    o  ADHESIVE STRUCTURAL BONDING PRIMER

O   NO REPLACEMENT FOR CHROMIUM (VI) FOR USE IN ANT1CORROSIVE PRIMERS

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                ANALYSIS OF PROPOSED CTG FOR MARINE COATINGS
                   /
       O   PROPOSED EPA CTG VASTLY DIFFERENT FROM CALIFORNIA MARINE COATING
           REGULATIONS

           O   ALL MARINE COATINGS APPEAR TO BE GROUPED INTO FOUR CATEGORIES
               BASED UPON CHEMISTRY AS OPPOSED TO APPLICATION

                   ALKYD PAINT SYSTEMS
                   EPOXY PAINT SYSTEMS
                   INORGANIC ZINC PAINTS
                   ANTT-FOUUNG PAINTS
O
               "NOTE: THIS MEANS OF CLASSIFICATION DOES NOT CONSIDER MEANS OF
                      APPLICATION OR INTENDED SERVICE OF THE PAINT WHICH
                      DICTATES VOC CONTENT AND MAY VARY GREATLY

           EPA PROPOSED CTG IS NOT CLEAR AS TO WHAT DISPENSATION WILL BE GIVEN
           TO SPECIAL APPLICATION COATINGS (I.e., POLYURETHANES,  HIGH  SOUDS
           ALUMINUM HEAT RESISTANT PAINTS, etc...)

           EPA PROPOSED CTG IS LIKELY TO ADOPT CALIFORNIA *94 VOC LIMITS

           O   GENERAL COATING VOC CONTENT LIMIT - 340g/l (AIR DRIED COATINGS)
    an MAY n

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           ANALYSIS OF PROPOSED NESHAP FOR MARINE COATINGS

       EPA NESHAP

       o   REGULATES 189 HAP* EMITTED DURING SHIPBUILDING OPERATIONS AND
           SHIP REPAIR

               HAPS LIMITS AND TECHNICAL APPROACH ARE UNKNOWN AT THIS TIME

           *   NAVY CONCERN THAT EPA WILL REGULATE LOW HAPs AND LOW VOC
               WHICH MAY NOT BE TECHNICALLY FEASIBLE FROM AN APPLICATION
               AND PERFORMANCE STANDPOINT

       CALIFORNIA HAPs REGULATIONS

       o   AIR TOXICS "HOT SPOTS' INFORMATION AND ASSESSMENT ACT OF 1987

               REGULATES APPROXIMATELY 740 HAPs (INCLUDING 189 EPA HAPs)

               HAPs ARE GROUPED FOR INVENTORY REPORTING

               ..QUANTIFY EMISSIONS OF APPROXIMATELY 400 HAPs

               ..DOCUMENT PRESENCE OF APPROXIMATELY 340 HAPs
OM.MJEX1

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                 DoD TRI-SERVICE R&D COATINGS PROGRAMS

0   TRI-SERVICE ENVIRONMENTAL QUALITY STRATEGIC PLAN PROGRAM (GREEN BOOK)

    O   DoD PILLAR 3:  POLLUTION PREVENTION
        RELIANCE SUBAREA: COATINGS APPLICATION AND REMOVAL
        REQUIREMENT THRUST 3B: PAINT STRIPPING AND COATINGS

O   GOAL:

        o   PRESERVE THE ENVIRONMENT
        o   MINIMIZE TOXIC OR HAZARDOUS MATERIALS USED AND/OR GENERATED
        o   ELIMINATE POTENTIAL FINES
        o   IMPROVE HUMAN HEALTH AND SAFETY
        o   REDUCE REGULATORY REPORTING BURDEN
        o   REDUCE DISPOSAL, EQUIPMENT, AND CONTROL COSTS

O   PROVIDES R&D TECHNOLOGIES IN THE AREAS OF:

           ALTERNATIVE PAINTING AND STRIPPING METHODS
           REFORMULATION OF PAINTS AND STRIPPERS
           IMPROVED APPLICATION, CLEANING, AND STRIPPING EQUIPMENT
           IMPROVED  ABRASIVE  BLASTING  EQUIPMENT AND
           RECOVERY/RECYCUNG/TREATMENT EQUIPMENT
MMM.M
oooceoi
CRMB

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U)
UJ
               DoD COATINGS RESEARCH PROGRAMS


0   NON-HAZARDOUS CORROSION PROTECTION PAINTS AND COATINGS - NAVY

O   NON-HAZARDOUS ANT1FOUUNG/FOUUNG RELEASE HULL COATINGS - NAVY

O   ELIMINATE CHROMATE WASTE GENERATION FROM CORROSION PROTECTION
    PROCESSES - ARMY, NAVY, AIR FORCE

O   REDUCE HAZARDOUS WASTE FROM PAINT CONTAINER DISPOSAL - ARMY, NAVY

O   NON-HAZARDOUS CHEMICAL AGENT RESISTANT COATINGS - ARMY

O   REUSE/RECYCLE PAINT SLUDGE AND FILTERS - ARMY

O   COST-EFFECTIVE NON-POLLUTING PAINT STRIPPING METHODS - ARMY, NAVY, AIR
    FORCE

O   NON-POLLUTING, LQW-VOC CHEMICAL STRIPPERS - ARMY, NAVY, AIR FORCE

O   IMPROVED BLAST GRIT RECYCLJNG TECHNOLOGY - NAVY, AIR FORCE
 oi Mat

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                DoD COATINGS RESEARCH PROGRAMS (conf d)


   O  REDUCE HAZARDOUS WASTE GENERATION FROM PLASTIC MEDIA BLASTING - AIR
       FORCE

   O  ELIMINATE CHROMATE WASTE GENERATION FORM PAINT STRIPPING PROCESS -
        ARMY, AIR FORCE

   0  REDUCE HAZARDOUS WASTE GENERATION FROM CHEMICAL PAINT STRIPPING
       OPERATIONS - ARMY, AIR FORCE

   O  DEVELOP ENVIRONMENTALLY SAFE PAINT STRIPPING OPERATION FOR SMALL
       PARTS - AIR FORCE

   O  TECHNOLOGY TO RECYCLE/REUSE PAINT-REMOVAL MEDIA - ARMY, AIR FORCE

   O  MINIMIZATION OF WASTE FROM LEAD BASED PAINT (LBP) DEBRIS - ARMY, AIR
       FORCE

   O  MODELS/THEORIES FOR IMPROVED CORROSION CONTROL - NAVY, AIR FORCE
on. Met
aurar*

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                      R&D COST AND FUNDING ESTIMATES
     O   COST ESTIMATES: TECH. BASE  TECH. DEMO  IMPLEMENTATION  TOTAL
                         $6,670K     $40,769K     $OK              $47,439K
     O  FUNDING PRORLE:
U)

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               NAVAL SEA SYSTEMS COMMAND (CODE 05M1) PAINTS
          (per NAVAL SHIPS' TECHNICAL MANUAL • CHAPTER 631 OF 11/01/92)
Ul
ON
                  TT-E-490
                  MlLrP-24441—
                  MILrP-15930, F120,
                      .MIUE-24365
                  DOD-E-1115C, F30.
DOD-E-18210
DOD-E-1821
                      JWHL-P-24441C, P150
                                      VTION:
                                         DOD-E-1115C, F30

                                         DOD-C44596 OR NAVY F25A
                                        JDOIMX24596 OR NAVY F25A
X)D-O24596 OR NAVY F25A
                  DOD-P-15146.
                  DOD-P-15183.
                                    	DOD-024596 OR NAVY F25A
                                        MILr&24635
                                         MIL-E-15090, F111
                       DOD-C-24596 OR NAVY F25A
                      JMlLrE-24635
                      JIIILr&24635
                  MIL4E-15090, F111-.
                  MILrB5556.
                                         MIL-E-15090, P111
                       DOD-C-24596 OR NAVY F25A
                        IIUE-24635
                      JX)D-P-24631B

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         NAVAL SEA SYSTEMS COMMAND (CODE 05M1) PAINTS (cortTd)
       (per NAVAL SHIPS' TECHNICAL MANUAL - CHAPTER 631 OF 11/01/92)
               DOD-P-23236-.
               MILrP-24647.
               MILrP-15931.
               MILrD-23003.
               DOD-P-24648	
UJ
               TT-B489...
               TT-V-51—
               DOD-P-15328.
               TT-P-1757.
               TT-V-119.
                                     .DOD-E-24607B
                                     JDOD-C-24667
     .1T-P-28(LOWVOC)
     ,TT-P-645B
     .MlLrP-24647
---- MIL-P-15931
                                     M1L-IV24483
            PURCHACE OF
      LOW VOC MATERIAL
     TT-P-645B, F84 OR
      MIL-P-24441C, F150
     .TT-P-645B, F84 OR
      MILrP-24441C, F150
     ."n^-645B, F84 OR
      MHrP-24441C» F150
     .LOCAL PURCHACE OF
      LOW VOC MATERIAL
     JJOCAL PURCHACE OF
                                      LOW VOC MATERIAL

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          NAVAL SEA SYSTEMS COMMAND (CODE 05M1) PAINTS (conTd)
        (per NAVAL SHIPS9 TECHNICAL MANUAL - CHAPTER 631 OF 11/01/92)
                MILC46081
                MILrP-24555_.
                DOD-C-24596-
.JIHIXM6081
 .TT-P-28 (LOW VOC)
                MILC-24380.
.JtflLrC-24380
OJ
00

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 U)
         Low-VOC  Coatings for ECM
                            Mark D. Smith

                       Staff Materials Engineer


                           AlliedSignal Inc.

                        Kansas City Division *
              (The work described in this paper was not funded by the U.S. Environmental Protection
              Agency. The contents do not necessarily reflect the views of the Agency and no official
              endorsement should be inferred.)
 * Prepared Under Contract Number DE-AC04-76-DP00613 United States Department of Energy.
All data prepared, analyzed and presented has been developed in the context of work authorized
                         under the Prime Contract.
 IliedSignal
  AEROSPACE

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                  AGENDA
           PAINTS
             •  Environmental concerns
             •  Compliance actions
             •  Current paint status
             •  Anticipated future work
             •  UV coatings
           DRY FILM LUBRICANTS
             •  Environmental concerns
             •  Replacement actions
^IliedSignal
  AEROSPACE

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   AIR POLLUTION REGULATION

  Missouri Air Pollution Rule 10 CSR 10-2.230, Control
  of Emissions from Industrial Surface Coating
  Operations
  Applies to locations emitting more than 6.8
  kilograms per day or 2.7 tons per year
  KCP regulated under the provisions for painting
  "Miscellaneous Metal Parts"
  Emission Limit of 3.5 pounds of VOC's per gallon of
  coating as applied
  Effective date of Compliance; December 31,1982
IliedSignal
AEROSPACE

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       COMPLIANCE ACTIONS:
N)
Spray painting operations voluntarily halted
Began process of developing "site plan" and
obtaining state and local EPA approval
Started VOC survey of currently used paints and
began search for "compliant" replacement paints
 IliedSignal
 AEROSPACE

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VOC's of Selected High VOC Paints
    Urethane  Epoxy
         Enamel
Acrylic
Alkyd   Epoxy  Lacquer ZincChr.
     Primer       Primer
Teflon
                    Paint Systems
IliedSignal
AEROSPACE
Wash
Primer

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 COMPLIANCE ACTIONS: (continued)
   Started survey of painting industry contacts to
   determine possible alternate sources of production
   painting
   Obtained and installed activated carbon filtering
   systems for production painting area
   Began obtaining and VOC-testing replacement paints
.AlliedSignal
  AEROSPACE

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   VOC's of Selected Low VOC Paints
       UV Cured
       Epoxy
Alkyd *  Waterborne Zinc Chrm.
     Epoxy Primer  Primer *
Epoxy
Primer *
Epoxy *   Urethane
                      Paint Systems
^AlliedSignal
  AEROSPACE

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AREAS OF CONCERN IN SWITCHING

     TO REPLACEMENT PAINTS
•  Customer requirements for color, corrosion
   protection and durability
•  Maintaining Military Specifications as basis for
   production paints
•  Compliant paints using "exempt" chlorinated
5  solvents
•  Coatings for which there were no direct
   replacements, (lacquers, Teflon® paints, wash
   primers, dry film lubricants)
•  New paint techniques and equipment that might be
   necessary
 AEROSPACE

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    PRESENT PAINTING STATUS

   Almost all applications using low VOC paints
   Limited use of high VOC materials within special
   booth, stack emissions routed through activated
   carbon filters until alternates found
   Significantly reduced number of routinely used
   different paint systems (from 25 down to
   approximately 5)
   Larger percentage of paints based on Military
   Specifications and Federal Standard Color
   numbers
   Significantly reduced VOC emissions
IliedSignal
AEROSPACE

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 ANTICIPATED FUTURE PAINT WORK

 •  Continued emphasis on high-solids, low VOC
    polyurethane and alkyd enamel paints
 •  Reduction or elimination of chlorinated
    solvent-based coatings
 •  Investigation of new lead and chromate-free Military
 5  Specification primers
 •  Elimination of special booth and/or filtration of all
    booths
 •  Evaluation of alternative coating methods
^IliedSignal
  AEROSPACE

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        ALTERNATIVE METHODS

             INVESTIGATIONS

   A study on powder coating is underway.
   New powder coating booth and two new powder
   coating guns are installed and operational.
   Electrophoretic coatings are being studied. New
   equipment is being obtained and set-up.
   Alternate cleaning and pretreatment methods are
   being studied, (alternate solvents, aqueous cleaning,
   dry plasma cleaning, chromate  conversion
   replacements).
^IliedSignal
  AEROSPACE

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         UV CURABLE COATINGS

 »  The materials are essentially 100% solids and
    therefore have a very low VOC content.
 •  The materials are very quick curing thus increasing
    through-put and decreasing chances for surface
    defects.
  -  Special curing equipment is required; curing of the
    material is line-of-sight from the UV lamps.
 •  Clear or translucent materials work best;
    opaque/pigmented materials are limited in curing by
    their ability to absorb UV within the bulk of the
    coating.
^AlliedSignal
  AEROSPACE

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        DRY FILM LUBRICANTS
          i
  Under current Missouri regulations regarding
  emissions from "surface coating operations", dry
  film lubricants are not included
  Most of the presently used materials are high VOC,
  from 6.42 to 8.12 pounds per gallon applied
  Division goal of reducing emissions to "as low as
  reasonably attainable" is driving substantial
  investigation into low VOC dry film lubricant
  technologies
IliedSignal
AEROSPACE

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 VOC's of Selected E/M Lubricants
      EL-9000
Type A   EL-620    99-A   4396-S
    Dry Film Lubricants
AEROSPACE
4396-BX

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 AREAS OF CONCERN IN SWITCHING

    TO REPLACEMENT DRY FILMS

 •  Application techniques and equipment will most
   likely require substantial changes. (Licensing of
   some technologies may be required.)
 •  Performance requirements of the present materials
   are not well defined, therefore proper replacements
   will be hard to define.
   New low VOC versions of existing dry film lubricants
   are relatively unproven in actual use which causes
   some trepidation in adopting their use.
Ln
ui
^AlliedSignal
  AEROSPACE

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     LOW VOC DRY FILM ACTIONS

   A group is studying dry film lubricants, surveying the
   dry film market and attempting to define
   performance requirements for their use.
   Possible alternatives include: Dicronite®, Microseal®,
   sputtering, sputter/ion treatment, electrophoretic
   coatings, increased hardness coatings, and E/M's
   new low VOC materials
   Study will determine objective inspection techniques
   for dry films
   Several other small short term tests are being made
   on individual parts or assemblies
^IliedSignal
tn
  AEROSPACE

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                  SUMMARY
    Environmental concerns about surface coating
    operations prompted an analysis of coatings
    materials and other compliance actions.
    The painting operations equipment underwent some
    modifications within the approved site plan.
    The switch to low VOC paints was made as soon and
    as completely as possible within certain constraints.
^IliedSignal
  AEROSPACE

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Ul
       SUMMARY (continued)


Changes in the type of dry film lubricants used are
anticipated.
Other low VOC painting techniques such as dry
powder, electrophoresis and UV coatings are being
investigated.
Investigations continue regarding other
environmental concerns such as chlorinated solvent
and hexavalent chrome reduction.
 AEROSPACE

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
      The Precedent-Setting Use of a Pollution Prevention Project in an EPA

        Enforcement Settlement:  The First DoIIar-for-Dollar Penalty Offset
                                    Presented by:

                                    David Nelson

                               EnviroSearch International

                                 Salt Lake City, Utah
                                  James J. Periconi

                           Donovan Leisure Newton & Irvine

                                New York, New York
                                      157

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  ABSTRACT
        Prior to the case described in this paper, the U.S. Environmental Protection
  Agency had not allowed an environmental project dollar-for-dollar setoff against a
  proposed fine in an enforcement action. Typical penalty offsets were historically in the
  range of 15 to 25% at the time of this settlement, although dollar-for-dollar setoffs
  were theoretically available. Relatively few projects of this nature had been negotiated
  with regulatory agencies, and virtually none in a RCRA enforcement action. This
 pollution prevention Supplemental Environmental Project (SEP) is one of five types of
 projects allowed by the new  EPA policy on the use of SEPs in enforcement actions.
 This paper describes the development of the legal and technical strategy utilized by the
 authors to aid the  client in its settlement approach to Region IX EPA.  Finally, the
 results of the implementation of the project to the company are discussed and the
 conclusion is made that this multi-media pollution prevention project foreshadows a
 significant developing state and federal regulatory trend.

 DESCRIPTION OF THE FACILITY AND PROCESSES
       The described  facility, located in an industrialized area  of San Leandro,
 California, is an office furniture manufacturing company employing 65 full-time
 workers in two shifts.  As was  true in early 1991, when the enforcement inspection
 discussed in this paper took place, the business utilizes bulk materials such  as sheet and
 coil metals which are in turn  bent, welded, assembled and painted to specifications.
 Primary products are storage cabinets, bookcases, and shelving.
       After metal forming occurs, the steel parts are attached  to an overhead conveyor
 line which runs through a chemical spray rinse system.  These  rinses remove cutting
oils from the parts as well as  coat the semi-finished steel with rust inhibitors. The final
rinse consists of a water bath, the effluent of which is discharged via a permit to a
Publicly Owned Treatment Works (POTW). The parts, still conveyed via the overhead
                                       158

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 line, pass through a large drying oven just prior to entry into the Ransburg automatic
 spraying mechanism which utilizes an electrostatic application to maximize adherence
 of the paint to the steel parts.  Overspray is collected in air filters which mostly
 surround the circular paint booths.  Remaining overspray adheres to walls, floors and
 various equipment surrounding the spray system.
        While the Ransburg coats a large percentage of the steel parts, they must be
 finished via hand-held spray guns, operated only by the night shift.  Custom furniture
 not handled by the automatic conveyor system is hand painted in  dedicated, three-
 walled paint booths, the overspray of which is handled via filters. The facility  uses
 Thermal Setting  Resin (TSR) paint which requires that painted parts, unlike evaporative
 formulas,  be returned to the drying oven for curing at 350 degrees Fahrenheit.  Oven
 air emissions from the curing process are regulated via a permit.
       To understand fully the pollution prevention opportunities this company  could
 and did realize, it is important to note that the company offers custom colors on its
 products to retail customers at no additional charge and with rapid turnaround. This
 will be discussed later with regard  to its implications in the facility's waste management
 practices.

 DESCRIPTION OF THE ENFORCEMENT ACTION
       The facility had a joint enforcement inspection  in 1991 by the California
 Department of Health Services (now  California Environmental Protection Agency) as
 well as by  EPA, with the federal government  eventually exerting jurisdiction (In Matter
of Harbor Universal. Inc.. Docket  No. RCRA-09-92-0001. U.S.  Environmental
 Protection  Agency. Region IX). The EPA found that the facility  had baked paint and
solvent wastes in  its drying ovens,  which, according to EPA, made the facility an
unpermitted Treatment,  Storage or Disposal (TSD) facility subject to regulation under
the Resource Conservation and Recovery Act  (RCRA). Region IX issued a
                                       159

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 Compliance Order requiring the facility to submit a RCRA Closure Plan for the oven,
 to submit a plan for immediate compliance with all applicable regulations and to pay
 penalties of $341,000.

 BACKGROUND ON SUPPLEMENTAL ENVIRONMENTAL PROJECTS (SEPS)
       The encouragement by EPA to use SEPs in enforcement proceedings is a natural
 outgrowth of the overall importance of the pollution prevention emphasis the agency
 began to apply  in the early 1990's following the enactment of the Pollution Prevention
 Act of 1990.  See EPA's Pollution Prevention Strategy, 56 Fed. Reg. 7849 (2/25/91).
 This new emphasis represented a shift away from "end of the pipe" control strategies
 which, in EPA's judgment, merely shifted contaminants from one medium (e.g.,
 hazardous waste storage drums on site) to another (e.g., a landfill where the wastes
 were disposed,  or the atmosphere to which incinerated wastes were discharged).
       Much of industry, particularly larger companies, had begun, by the mid-80's, to
 realize the limited value of "end of the pipe" control strategies as the costs of hazardous
 waste disposal began to skyrocket. Early source reduction strategies in the organic
chemical industry, for example, are described in the prescient 1985 study  by INFORM,
a non-profit, New York-based research organization, entitled Cutting Chemical Wastes.
which has recently been updated in a work (Environmental Dividends: Cutting More
Chemical  Wastes  1992) that demonstrates that enormous progress has been made in
corporate attitudes to pollution prevention as well as in actual source reduction.  Also
fueling this attention and focus was the then new annual rite of Toxic Release  Inventory
(TRI) data, which showed in 1988, for example, that reporting facilities released 4.57
billion pounds of contaminants directly into the  environment.
       Under Carol Browner's leadership, the agency is likely to increase the  use of
SEPS, especially pollution prevention-based SEPs.  In fact, the Clinton Administration
                                   160

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 early on announced its intention to increase their use and although already found in as
 many as one in ten negotiated settlements,  growth in their use is expected to continue.
        In the second of EPA's 1991 Enforcement Policies discussed below,  EPA
 targeted the reduction of 17 high risk chemicals, choosing those offering the best
 opportunities for source reduction (applicability to the referenced facility discussed
 later). The overall goal of EPA as of early 1991 was to reduce the total releases of
 these chemicals by 33% by the end of 1992.  (The authors are unaware as to whether
 EPA believes it has met this goal; however, reductions are believed to have been
 significant.)
        EPA's Regions and program branches are to "investigate flexible, cost-effective
 regulatory approaches that avoid prescriptive approaches and that rely on market-based
 incentives...", (EPA Pollution Prevention Strategy, pg.10).  EPA is also to "ensure
 that its  enforcement program seeks pollution prevention opportunities as part of
 ensuring compliance" with environmental laws.  "EPA will encourage the inclusion of
 pollution prevention conditions in Agency enforcement settlements." As noted, the
 SEPs are, in fact, increasingly employed in negotiated settlements, with pollution
 prevention SEPs in the lead. The strategy is to "incorporate prevention  into every
 aspect of the Agency's operations in program and regional offices/
       The enforcement-related side of this policy is developed in two EPA guidances:
        1.      "EPA's Policy on the Use of Supplemental Environmental Projects
 (SEPs)  in Enforcement Agreements" (2/12/91) defines those projects, other than those
 required to correct the underlying violation, which a defendant or respondent in
administrative proceedings "may  undertake in exchange for a reduction in the amount
of the assessed civil  penalty".  Acceptable projects include:
       i.      Pollution Prevention Project: one that "substantially reduces or  prevents
the generation or creation of pollutants through use reduction (i.e., by changing
                                       161

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 industrial processes, or by substituting different fuels or materials) or through
 application of closed-loop processes";
        ii.     Pollution Reduction Project: one that "goes substantially beyond
 compliance with discharge limitations to further reduce the amount of pollution that
 would otherwise be discharged into the environment...[e.g.] that reduces the discharge
 of pollutants through more effective end-of-pipe or stack removal technologies; through
 improved operation and maintenance; or recycling of residuals at the end of the pipe."
        iii.    Environmental Restoration Project: one that remediates adverse public
 health or environmental consequences, "to enhance the environment in the vicinity of
 the violating facility."
        iv.     Environmental Auditing Project:  not one "that represents general good
 business practices," though it may be considered by EPA "if the defendant/respondent
 undertakes additional auditing practices designed to seek corrections to existing
 management and/or environmental practices whose deficiencies appear to be
 contributing to recurring or potential violations."
        v.     Public Awareness Project: one that includes publications, broadcasts, or
 seminars or "which underscore^] for the regulated community the importance of
 complying with environmental laws  or disseminate[s] technical  information about the
 means of complying with environmental laws," including sponsoring industry-wide
 seminars.  For those considering this SEP option,  it is important to note that the project
 must be publicly advertised as being part of a consent agreement with the EPA in
satisfaction of an environmental violation.
       Importantly, there must also be a "nexus" or relationship between the original
violation and the supplemental project._A vertical nexus exists when the project
reduces pollutant loadings to a given environmental medium to offset earlier excess
loadings of the same pollutant to the same medium. A horizontal nexus is described as
when the project either gives 1) relief for different media at a given facility or 2) relief
                                      162

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 for the same medium at different facilities.  All SEPs must significantly reduce the total
 risk posed to public health or the environment by violations.  Additionally, all SEPs
 must be "directly related to addressing compliance problems within the industry within
 which the violation took place."
        While EPA will not generally allow a SEP to be merely a sound business
 practice that a facility should do anyway (e.g. a basic environmental auditing program),
 the agency makes an exception in the case of pollution prevention projects alone. The
 reason  is the pollution prevention projects in particular among SEPs have the
 "advantage of potentially providing significant  long-term environmental and health
 benefits to the public," as well as also being a sound business practice.
        Similarly, pollution prevention SEPs can also (unlike other SEPs) include
 studies  which "will be eligible for a penalty offset when they are pan of an Agency-
 approved set of pollution prevention activities at a facility and are designed to correct
 the violation..."  The goal  is to encourage pollution prevention studies needed to
 determine appropriate measures.  The "size of the penalty offset may include the costs
 of the study." Finally, the amount the fine is lowered can reflect the actual dollar
 expenditures for SEPs, but by no "more than the after-tax amount the violator spends
 on the project."   However, new equipment may be depreciated as a business expense.
       2.     The second importance guidance, issued the same month as the first
 guidance and the same day as EPA's  Pollution  Prevention Strategy, is EPA's "Interim
 Policy on the Inclusion of Pollution Prevention and Recycling Provisions in
 Enforcement Settlements" (2/25/91).  This policy is intended to be used specifically for
 those cases where a pollution prevention program will be part of an enforcement
 settlement.  It is this document that contains the list of 17 chemical  wastes which EPA
 has targeted for reduction.  Additionally,  the policy describes "good faith" as a factor
 in the settlement: "(t)he willingness of a respondent to correct the violation via a
pollution prevention project can be one  of the assessment factors used to adjust the
                                      163

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 'gravity1 component of the penalty." "Voluntary" and "timely" disclosure of the
 offense  may also be taken into account in the final settlement.
       At the time of the agency negotiations regarding this enforcement action, in late
 1991, SEPs had been used sparingly, and in fact, EPA's (new at the time)  Pollution
 Prevention Information Clearinghouse (PPIC), tasked with recording all SEPs from the
 various  EPA Regional offices, headquarters and states, knew about only four SEP
 settlements.  Used mostly in TSCA, EPCRA, and FIFRA cases up to that point, the
 reduction in fines were on the order of only 10 to 25% of the amount spent on the
 pollution prevention project.
       Since that time, SEPs have seen widespread use, and are currently estimated by
 EPA, as noted earlier,  to be used in one in  ten enforcement cases and growing.  EPA's
 1992 National Penalty  Report, released in the late spring of 1993, indicates there were
 409 SEPs negotiated in all programs during 1992.  The agency estimated their dollar
 value at  $50.1 million (though the figure has met with considerable controversy as
 being too high or too low), with EPA Regions reporting 222 SEPs. The mobile
 sources air program added 187 SEPs, of which 183 were public awareness  projects.
 More than half of the regional SEPs  were pollution prevention projects with TSCA or
 EPCRA cases comprising 40% of the total.  The authors believe many of these
 settlements arose from "paperwork"  reviews such as failures to file Pre-manufacture
 Notices (PMNs), or Form Rs, respectively, and not the result of investigation-intensive
 inspections (especially RCRA inspections) conducted by state or federal agencies.
 According to EPA, programs other than mobile sources, TSCA and EPCRA - e.g.,
 RCRA -  each generated no more than 5% of such cases.

DEVELOPMENT OF LEGAL/TECHNICAL STRATEGY
       The attorney/consultant team  was  led by the authors, whose backgrounds were
 ideally suited for this particular case.  Prior to entering private practice, Mr. Periconi
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 had been an Assistant Attorney General in the Environmental Protection Bureau of the
 New York Attorney General's office for five years in the early to mid-1980's
 prosecuting early criminal as well as civil hazardous  waste, air, water and wetlands
 violations; subsequently, he was Chief of the Hazardous Waste Enforcement Bureau for
 the New York State Department of Environmental Conservation.  Prior to starting his
 consulting firm in 1985, Mr. Nelson was a former multi-program enforcement officer
 for several regulatory agencies in the State of Utah and served on several EPA
 oversight committees tasked with reviewing the implementation of RCRA and
 CERCLA in the early 1980's. While with the agencies, Mr. Nelson was involved with
 several high profile enforcement cases.
       This background allowed the team to realize immediately the severity of the
 enforcement action both on the face of the allegations and in early conversations with
 agency personnel, but also the opportunities the company could realize by a substantial
 program aimed at not only addressing EPA's  immediate concerns, but also going far
 beyond the enforcement action.  Our ultimate goal was not only to keep penalties low
 while satisfying satisfy the agencies, but to  help the company turn its overall
 environmental management program into a  cutting-edge business advantage by reducing
 its production costs.
       The initial step was to evaluate the operational as well as strictly environmental
aspects of the facility in a broad, unrestricted sense, without emphasizing the
enforcement action.  In  other words, the team was not focused on the hazardous waste
paint-baking episodes, as the correction of this problem was obvious, namely, stop the
practice and undertake RCRA closure; rather  it looked at the facility as a whole, all the
time seeking pollution prevention opportunities that would be incorporated eventually
into the plan as well as the day-today business activities of the facility.
       While facility personnel had a basic  understanding of the regulations, and was
striving to meet regulatory requirements, it  was apparent that the waste handling
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 practices were grossly inefficient to the point that it was a clear financial burden,
 enforcement and penalty issues aside. Major waste streams consisted of a great deal of
 paint overspray over large portions of the painting rooms and surrounding environs,
 necessitating the use of large quantities of thinner for cleanup.  Additionally, paint and
 solvent contaminated rags were overly abundant as were discardable paint filters, often
 used well beyond their effective use to the point of over-saturation. To attempt to
 control the large amount of paint overspray on the floor, large quantities of cardboard
 were placed on the floor, sometimes layers deep, typically well saturated with paint and
 therefore quite heavy. This waste material was shipped off to a TSD in pallets, priced
 by its weight, as an expensive hazardous waste.
        Additionally, large quantities of waste paint thinner were generated from
 cleaning of guns, lines and other miscellaneous chores.  While much of this was
 reclaimed by the company to which the facility sent these wastes,  those wastes with a
 higher proportion of waste paint to solvent could not be reclaimed.  Interestingly, the
 facility also generated enormous amounts of thinner waste  due to its marketing success
 in offering custom colors to clients. The result of this successful marketing effort was,
 however, the very frequent changing of colors, including the entire flushing of long
 lines thick with paint. This created,  of course, an externality not charged to customers
 in higher prices for custom  lines of products.
        Additional potential  environmental pollutants, which were reviewed as pan of
 the waste minimization audit, were rinse bath chemical additives from the wastewater
 stream discharged to the POTW, via permit, as well as the paint solvent emissions in
 stack gases from the drying ovens, also regulated by a permit. Both permits were
 current for both emissions; however, the team looked at pollution prevention
opportunities with these wastes as well.
       Readers familiar with the pioneering work of eminent pollution prevention
researchers Joel Hirschhorn, Ph.D. (Hirschhorn & Assoc., Washington D.C.) and
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 Robert Pojasek Ph.D. (GE1 Consultants, Boston, Mass.) know that non-technical
 barriers, sometimes called "soft" or behavioral barriers, predominantly exist within a
 facility, the result of which is the typical creation of substantial disincentives for
 pollution prevention opportunities.  In other words, the greatest gains for pollution
 prevention opportunities are not necessarily or even typically found in  high-tech,
 capital-intensive, R&D solutions; rather they exist in recognizing, modifying,
 empowering and rewarding facility personnel behavior that precludes the generation of
 unnecessary amounts of waste.  The employees are closest to the problems,  and
 therefore, closest to the most cost-effective, low-tech solutions.  It often requires,
 however, an independent review by outside expert consultants, to identify these
 industrially dysfunctional, competetively-disadvantaged behaviors.  This facility was no
 different than most others we have consulted  to and in  this regard, we noted the
 following during our review:
       - Communication barriers were significant between management and workers
 and were further hampered to a significant degree by language barriers;
       - Employees were not empowered  nor rewarded to bring forth solutions to the
 facility's daunting environmental problems;
       - Plant engineers and senior managers were convinced  that they had investigated
every possibility for waste minimization and that no possibilities existed to realize
further benefits;
       - The night shift posed the greatest threats to the environmental health and
safety (EHS) programs.  This was due to the  fact that no programs existed to sensitize,
empower, train and reward (particularly) night shift personnel (nor did they exist to a
large degree  for the day shift) in solving these problems.  Thus, they festered, and
ironically presented each new day shift with an ever-increasing, downward spiral ing
environmental, health and safety headache. The day shift, almost entirely out of touch

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 with the night shift regarding EHS matters, inherited on a daily basis problems
 seemingly with no end.
        - Pollution prevention opportunities were so apparent and numerous that the
 prevailing attitudes by all personnel virtually precluded them from seeing them.
        These barriers were by far the biggest hurdle to overcome in developing an
 entirely different environmental, health and safety corporate ethic.  Once this was
 accomplished, with the direct and sincere involvement of the company CEO,
 sometimes on a daily basis, the facility began its journey to turning the facilty around.
        It is important to note that management was understandably jaded by the
 regulatory process insofar as they had received incorrect information from a variety of
 sources as to proper management of paint wastes.  The company had a plant engineer
 trying to "keep up" with changes in regulations on a "part-time" basis in a state known
 for its aggressive environmental agenda (California). Thus, he felt he  had to rely on
 two seemingly credible sources which, in fact, caused problems.  The paint salesman,
 whose incentive was to sell more paint, indicated that the baking of paint wastes was
 the "industry standard" and that it met regulatory restrictions on VOC content. (Of
 course, these standards have become ever more stringent in states like California or
 New York, so that what was an "industry standard" in one year would no longer be so
 a year or two later).
       Perhaps more troubling was literature from its main competitor, which we
 presented to EPA during the negotiation phase, virtually showcasing its baking of paint
 waste in its ovens to reduce volume!  The article was professionally produced,
complete with a photograph of the proud facility operator holding a dry bucket of paint
 in front of a drying oven almost identical to our client's. Contributing to this problem
was the fact that the competitor is a very large player in the office furniture business,
and our client had to (and continues to have to) compete with far less resources, not the
least of which were, and are, environmental.
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        After it completed the environmental and waste minimization audit, the team



 exhaustively researched all uses of pollution prevention settlements in administrative



 consent agreements.  As stated above, only four cases had at the time been registered



 with the PPIC, which at the time was just getting underway. Additionally, we checked



 numerous state and Regional EPA sources for SEP-like agreements, only to be



 dismayed by the lack of a centrally-organized source.  Not surprisingly, each Region



 had its own "style" or writing  and disseminating such orders, resulting in difficulty in



 making comparisons and compiling a real profile, based on scant details of the



 application of the SEPs policy in  many Regions' consent agreements.  (The reader is



 cautioned that the authors believe EPA still lacks a centrally-organized, easily



 retrievable source of detailed SEP information. We attempted to update this paper at



 the time of publication only to find that although there are some gross numbers



 available regarding SEP settlements, see  17 Chemical Regulation Reporter 545 (BNA)



 6/4/93, useful information is not easily obtainable. Neither LEXIS nor Westlaw, in



 addition, keep such information in particular or non-adjudicatory administrative



 settlements in general on line).



       We were well  armed when we first met with Region IX and were fluent in what



 we believed were the  cases negotiated to that date as well  as a pollution prevention plan



 and a number of reasons why a SEPs approach was appropriate. To our client's  delight



 and EPA's credit, the agency recognized  the effort and relied on us as a source of



 expert information.



       We presented to EPA a very comprehensive, detailed waste management  study



performed at the described facility, which included raw material use, a water "budget"



 for all  uses and processes, solid as well as hazardous waste outputs, and a



comprehensive materials budgets, among other measures.



       Additionally, we proposed nine  administrative measures, aimed at correcting,



 influencing or empowering employee behavior.  These included:




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        - Issuing a Pollution Prevention Policy from management to employees;
        - Assigning a person or team within the plant to manage and direct the program;
        - Having this person or team report progress routinely to the company president;
        - Conducting employee training on pollution prevention technologies in the
 fabricated metal industries;
        - Monitoring of pollutant volumes more closely to observe changes and  trends;
        - Implementing inventory control in the paint storage room, and recycling of
 unused paint after six months or less;
        - Minimization of overpurchases of special colors;
        - Purchasing frequently-used colors in bulk to minimize empty containers.
        We proposed nine operational changes fixed on hands-on solutions to direct
 reduction of hazardous waste/material generation. These included:
        - Elimination of the unnecessary use of cardboard on the floors;
        - The use of collection troughs to reduce overspray falling to the floor;
       - The use of metal grating to create a better floor drainage and collection system
 in painting and storage areas;
       - Improving paint transfer techniques  in storage room using dedicated barrel
 pumps, funnels, spigots, or other devices;
       - Installation of dedicated distribution systems for the most commonly used
 paint colors to minimize line flushing;
       - Exploration of the possibilities of running lots of one color per week or one
color per night;
       - Exploration of the business pros and cons of offering a more limited choice of
colors;
       - Reviewing adequacy of equipment maintenance practices;
       - Reviewing adequacy of operator training and feedback for process
improvement.
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       We made one product reformulation suggestion that the facility manufacture
 furniture of pre-coated stock (recognizing that this may be a type of "generator shift" of
 hazardous waste generation in that some facility would need to paint the steel).
       The  nine production process changes were the:
       - Investigation of newer spray guns and centrifugal spray systems to reduce
 overspray;
       - Reduction of open space between parts on  the conveyor system (this greatly
 reduces amount of overspray);
       - Consideration of painting some parts only by the Ransburg or only by the
 spray gun rather than by both;
       - Measurement of the Ransburg's efficiency and comparison to the design
 specifications;
       - Reduction of the pressure in the  spray guns;
       - Installation of a baffle system for the collection of overspray;
       - Modification of the filter systems so as to collect less overspray (this allows
 more paint to go to the part);
       - Review of the efficiency of the cleaning and rinsing system to reduce water
 use and load on the POTW.
       - Installation of a dedicated in-plant paint thinner recycling system.
       Finally, we wanted to study six raw material changes, some of which were
 R&D based, in the sense that the realization of immediate benefits were less tangible,
and would require some investment in time and follow-up to investigate.  These
changes were:
       - Powder coatings;
       - Water-based coatings;
       - Radiation-curable coatings;
       - Dip tank system innovation;
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        - Alternative thinners and solvents;
        - Alternative cleaning and pre-coating chemicals.

        As the facility implemented the Pollution Prevention Plan, we learned that
 certain changes worked while others did not, a situation not unexpected.  For example,
 the total elimination of cardboard to collect overspray on the floor seemed to be a
 highly desirable goal because it became quite saturated and heavy and was therefore
 very expensive to dispose of as a hazardous waste.  Several alternatives to this were
 explored; however, the facility returned to its use, but currently uses this procedure
 quite sparingly.  It is not placed several layers thick, is strategically placed so as to
 provide maximum benefit and is removed prior to saturation.  Importantly, however,
 its use has been curtailed by overall better housekeeping practices, advances  in the use
 and maintenance of the spray paint systems and other behavioral changes on the pan of
 employees, the overall result of which is continued waste minimization. This is
 precisely the desired effect of a rigorous pollution prevention plan in that it constantly
 provides the facility with feedback of its successes and failures in order to maximize
 beneficial alternatives.
       It is important to note that the facility had, from time-to-time, investigated
alternative coatings in the past; however, the company had no system or mechanism to
rigorously follow new trends in the coatings industry. Again, the company was in a
sense "trapped" by its small size, and was unable to participate in a program to keep it
on the cutting-edge of coatings technologies which would not only help cuts  its
production costs but greatly benefit the environment as well.
       While we discussed the SEP policies and this  facility's proposed Pollution
Prevention Plan as a SEP at the December 1991 meeting with EPA, we did not think it
prudent to make the case for the Pollution Prevention Plan meriting a dollar-for-dollar
SEP setoff at that initial meeting.  Our goal at that point was to get EPA interested in
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 how implementation of the Plan would mean long-term compliance and pollution
 prevention for this facility. EPA's lawyers and technical staff were cautiously
 enthusiastic about the possibilities of the  Plan for achieving these long term compliance
 and source reduction goals.
        At the end of the meeting, we were asked to and did prepare a detailed, written
 proposal integrating the Plan into the SEPs policy as applicable to this particular
 enforcement action, and to make clear just exactly what kind of a monetary setoff
 against the fine we were seeking.  In preparing the written proposal, we did so because
 we believed  in the case for such a setoff, where the proposed fine represented a
 substantial penalty for such a small company, where  the company was sincere in
 eliminating the problem, and EPA staff was  thoughtful and sophisticated about the
 issues, and seemed eager to participate in a new, developing, and promising pollution
 prevention program recently outlined by the  Agency.
       The agency responded  favorably to the detailed proposal, the legal and technical
 personnel going out on a limb somewhat in granting what they knew would be the very
 first dollar-for-dollar setoff against a proposed penalty.  We attached the Pollution
 Prevention Plan to the Consent Agreement and Final Order (CAFO) which required
 four quarterly reports to be made, with the consultant acting as  the "third party" auditor
 in order to certify to EPA that the expenses and changes had been made as proposed.
 It is important to note that  money not actually expended on implementation of the
pollution prevention plan would have to be paid to EPA as an additional penalty; thus
the facility owner had to fully  implement the Plan as agreed. The dollar-for-dollar
setoff was for the full $218,000 for implementation of the Pollution Prevention Plan,
and that after other penalty reductions, the company only paid a $93,000 fine.
       We believe EPA's policy to allow study and analysis of  pollution prevention
projects (unlike other SEPs) to qualify for a  penalty offset is a wise one.  There is

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 typically a series of trials and errors before the right combination of projects can be
 determined, and the project here was no exception to this rule.

 SUCCESS OF THE STRATEGY
        The attorney/consultant team's success in persuading EPA relied substantially
 on the fact that we helped EPA understand how full implementation of this facility's
 Pollution Prevention Plan would aid the agency's own goals of 1) incorporating such
 plans into enforcement settlements with  a strong  financial incentive to do so and; 2)
 reducing pollutant loadings to the environment, thus lowering  risk to human health and
 the environment in the short and medium runs and; 3) improving overall environmental
 compliance in the  long run, thus avoiding  the need to expend scarce agency
 enforcement resources repeatedly on the same  "problem" facility. We got EPA very
 interested at the December 1991 first enforcement negotiation  meeting in having the
 facility implement the Plan and, more importantly, take numerous steps to ensure long-
 term, overall facility compliance with all environmental regulations.
       Additionally, the plan was a success because
       1.     We  supported the legal and  policy  argument that this case was ideally
 suited for a pollution prevention project through a highly technical evaluation of sound,
 implementable pollution prevention measures;
       2.     We  found that sophisticated technical and legal staff at EPA understood
 that the facility's problems went far beyond the immediate RCRA violations that
 resulted from the inspection, and that therefore, the solution had to be comprehensive;
 we knew that ultimately these regulators  were beyond a "let's hit 'em  for everything
 they're good for" approach of maximizing the fine, and truly wanted to see the facility
 become compliant  in an overall sense. Indeed, we found EPA staffers working on this
project eager to be involved with a cutting-edge, comprehensive pollution prevention
plan.
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        3.     We had full support from senior company management after careful



 education about the benefits of pollution prevention projects, and informing them that



 enforcement actions could possibly recur unless attitudes genuinely changed and the



 level of training and professional assistance were  increased; this change began with the



 development by the President of the  company of a comprehensive policy that we did



 not write for him, but which we insisted that he develop based upon our discussions;



 based upon these developments, EPA viewed management's active "willingness...to



 correct a violation via a pollution prevention project" as "one of the assessment factors



 used  to adjust the 'gravity' component of the penalty." Interim Policy at p.6.



        4.     Our plan met both the horizontal and vertical nexus requirements of the



 SEPs policy.  It met the horizontal nexus test because decreasing the amount of



 hazardous wastes generated in the paint spray process would automatically reduce air



 pollutants generated,  i.e., "relief for different media at a given facility." SEPs Policy at



 p.6.  It met the vertical nexus test because the project would reduce the amount of



 paint waste created by overspray, and reduce spray paint line flushing with solvents, or



 entirely eliminate the use of solvents by materials substitution.  Thus,  this facility's



 SEP had a vertical nexus with the violation because the SEP "follow[ed] a violation



 back  into the manufacturing process  to address  the root cause of the pollution." SEPs



 Policy at p. 6.



       5.     Three of the 17 targeted chemicals in the SEPs policy for reduction were



used and generated as waste at the facility; these are methyl ethyl ketone, methyl



isobutyl ketone, and xylene.  Reduction in their use thus directly met EPA's goals to



reduce the overall pollutant burden on the atmosphere;



       6.     While it was not our (or the facility's) intention to do so initially, our



plan reflected a true "multi-media" approach, foreshadowing federal and state programs



that were then proposed and are now underway. These  initiatives represent EPA's and



the states' desire to undo the historical fragmentation of environmental regulation on a



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 program by program basis, and to replace the patchwork system we all currently labor
 under with a "holistic" approach that deals with all programs and the systemic problems
 in management and operation that lead to environmental violations.
        The company's success, on the other hand, began with the reduction in penalties
 assessed, of course, the relief that while an enormous amount of money would have to
 be expended, $218,000 of what had been a pure penalty would at least go toward
 improvement of facility operations. Thus, the company's success and reward was the
 longer-lasting one of lower operational costs, less of the heavy, solvent and paint-
 saturated cardboard having to be hauled away as hazardous waste, at great expense,
 thus contributing to a larger bottom line. In addition, the company benefited as greater
 sensitization of management and employees to opportunities for greater corporate
 environmental citizenship took hold.
        Perhaps the truly satisfying reward, however, were the results of a recent
 agency inspection of the facility wherein the  findings reported that "all waste
 manifesting and profiles were accounted for" and, reflecting the long-term commitment
 the company made to its employees, that "training programs were in place for
 employees handling hazardous wastes and that training logs were signed by each
 employee." Additionally, all waste storage containers were properly covered, stored,
 labeled and were  in fact detailed as "excellent."  The facility is subject to California's
 famously rigorous SB 14 waste minimization program, and the inspection found it to be
 implemented "with reductions in waste production." Finally, the agency wrote:
 "Significant improvements in all areas of hazardous waste management.  Positive
attitude of [the facility] has created an environment of reinforcing values for hazardous
waste reduction and management."

LIMITATIONS OF SEPS
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        This paper does not discuss in detail the limitations and criticisms to SEPs, yet
 it would be  incomplete without at least briefly listing them.  Some criticisms that have
 been leveled are:
        1.      Pollution Prevention SEPs may provide a disincentive for voluntary
 pollution prevention projects.
        2.      EPA is reluctant to grant additional dollar-for-dollar settlements, and the
 agency has been criticized for the generosity of this particular settlement.  However,
 the authors strongly believe that given the appropriate circumstances, potential violators
 should nevertheless attempt to secure a similar settlement.
        3.      The Government Accounting Office (GAO) has suggested in a July 1992
 report that EPA is without authority to "divert" to corporate violators dollars that
 should go into the Federal Treasury.  EPA intends to continue to use SEPs in settling
 enforcement cases until this is worked out.
       4.      Projects consistent with EPCRA and  other federal and state statutes
 mandating pollution prevention or source reduction  will not qualify for offsets because
 they are already required.
       5.      Once a particular company has effectively  been "put on notice" by
agreeing to implement a SEP, particularly a pollution prevention SEP, it will  be
difficult for other  facilities under the same parent corporation to ignore implementation
of similar programs.

CONCLUSIONS  AND RECOMMENDATIONS
       Pollution prevention has early on received a high profile under the Clinton
Administration, and is likely to receive ever greater attention.  As states turn up their
environmental  agendas, they will also increasingly utilize pollution prevention
techniques to abate environmental penalties. Already, several successful citizen groups
are using SEPs in  public enforcement actions.
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        It is important to note the skyrocketing use of SEPs; however, equally important
 is the realization that these are likely used in "paperwork violations" of EPCRA and
 TSCA.  Opportunities exist, therefore, for creative use of SEPs in more investigation-
 intensive enforcement actions such as RCRA violations.  Should you embark on such a
 venture, it  is our hope that you or your clients realize the overall benefits that our client
 gained in fully implementing a realistic and rigorous pollution prevention program.
        But based on our experience in this case, and in discussing  Pollution Prevention
 Plans with a number of clients, we believe there are certain changes that can and should
 be made in implementation of the SEPs program.
        First, EPA  must  figure out a way  to resolve an inherent tension between the
 time needed to examine  and  experiment with numerous possible pollution prevention
 projects and restrictions  occasioned by certain agency requirements.  These are, in
 particular, the apparent need to quantify  project costs precisely up front in the
 administrative settlement, at  a time when  the facilty in an enforcement action wants to
 maximize the amount of penalty settoff, rather than defer any decision to make
 substantial capital expenditures pending further study of their utility to the particular
 facility.  As the INFORM studies of 1985 and  1992 and researchers Hirschhorn and
 Pojasek have shown, so many pollution prevention projects do not  require large capital
 investments so much as changes in facility attitudes and procedures.  (This paper
describes this very occurrence with our client). Yet EPA requires in the administrative
order a fixed dollar amount of pollution prevention projects "up to  which" amount an
offset will be made. Thus, there is an overemphasis on both sides on selecting big-
ticket items  (e.g., large capital expenditures for equipment replacement, which may or
may not contribute  to pollution prevention) in costs terms.  This is  an unfortunate
emphasis.
       The second agency requirement that is inconsistent with the trial and error
nature of maximizing pollution prevention opportunities is the insistence that all
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 projects be completed within an artificially short time-frame, namely, in our case, only
 six months.  It may have been a RCRA program requirement or a function of personnel
 caseloads and workplans, but our only disagreement with EPA after it had accepted our
 basic proposal was its insistence that we compress a one-year program into six months,
 for purposes of signing off on the Consent Agreement and Final Order.  We were told
 informally that if things were going well, technical staff would have the discretion to
 extend beyond six months the time in which we had to spend the full $218,000 that was
 the maximum setoff allowed in the settlement for implementation of the Plan.  It  is not
 easy to spend $218.000 wisely  in six months at a small facility when study of various
 alternatives,  to determine the right combination of projects, itself could take six or
 more months.  Why force facilities to spend money (failing which, the unexpended
 portion would be added to the penalty amount) before a thoughtful examination of what
 a facility needs has been completed? Pollution prevention engineering is increasingly
 receiving R&D investments, yet many solutions are just "out of reach" of the
 manufacturing sector  within perhaps a dictated regulatory time frame.  The SEP system
 should allow for such cases  where a violator who genuinely wishes to participate  in the
 "cutting-edge" of pollution prevention technology is allowed to make the proper
 investment over an agreed-upon time frame.
       Our third  conclusion and suggestion for improvement is that it is a mistake to
 link penalty offsets solely to the dollars expended on the pollution prevention project
 rather than on the amount of reduction of pollution produced by the project.  Again, if
 the low-tech, relatively  inexpensive solution results in a significant source reduction or
pollution prevention,  why not reward the regulated entity for its ingenuity in finding
 inexpensive solutions?
       Our final suggestion  is that the agency complete and carry  out its "two percent
project", between its Office  of Enforcement and  Compliance Monitoring, the
prerequisite to finalizing the  1991 Interim Policy discussed above.  Regions have  in
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 theory been encouraged to continue to expand the use of pollution prevention
 conditions in enforcement settlements, as part of long-term strategic planning for multi-
 media enforcement, according to EPA guidances. The authors believe that this
 initiative must move forward expeditiously, despite the lag in EPA efforts that we are
 now experiencing, typical when there is a change of administrations in Washington.
 The concern is that as leading states like New York and California move forward with
 their own multi-media and pollution prevention efforts, absent a coherent and "final,"
 not "interim" policy on such efforts, they will adopt only those pieces of EPA's
 program, if any at all, that seem suitable rather than the entire package.  Already
 California,  for example, has despite the leadership of California EPA Administrator
 Jim Strock, the author of  the two 1991 U.S. EPA guidances that are the foundation of
 SEPs and the use of pollution prevention projects in enforcement actions,  adopted a
 restrictive form of the SEPs program - one in which most of the elements are in place,
 except that the  maximum  amount of setoff is only 25%  of the penalty. Worse, in New
 York,  which has begun an aggressive multi-media enforcement program, pollution
 prevention requirements are essential in settlements,  but without any penalty setoff
 whatever (except for government entities for certain  "environmentally beneficial"
projects). Thus, there is a real potential for the States to adopt the stick without the
carrot (as in New York), or without a very big carrot (as in California).  We believe
that restricted State budgets and the need to fund agency budgets has taken precedence
over good public policy - one that recognizes that the benefits to the society at large
from pollution prevention  programs are so enormous that industry deserves the
maximum amount of incentive to undertake such programs.
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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

              ARMY POLLUTION PREVENTION SUCCESS STORIES

Jack Hurd
Army Acquisition Pollution Prevention Support  Office
5001 Eisenhower Ave.
Alexandria, VA 22333

Mark W. Ingle
Ocean City Research Corporation
1745 Jefferson Davis Highway, Suite 702
Arlington, VA 22202
INTRODUCTION

       The United Stales Array Materiel Command purchases over $95 billion worth of
equipment and supplies every year.1  To ensure that the acquisition programs purchasing these
items address the life-cycle pollution prevention concept, the Army Acquisition Pollution
Prevention  Support Office (AAPPSO) was established in 1989.  The  overall AAPPSO
program goal is to prevent as much pollution as possible by designing environmentally
friendly equipment and support systems from the start and not simply treating whatever toxic
by-products happen to be generated.

       Since  1989, the AAPPSO has had a number of pollution prevention successes related
to Volatile  Organic Compound (VOC) and hazardous air pollutant reductions. The programs
and the key success areas are listed below:

Program         	Success	

Implementation of Low VOC                   Verified system performance.
Electrodeposiied Epoxy                        Implemented new military
Coating on Array equipment                   specification.
                                             Started reducing VOC
                                             emissions from Army
                                             procurement activities.

Implementation of Non-VOC                   Verified systems performance.
based Cleaning Compounds                    Conducted performance tests.
on Army Equipment                          Implemented use of new products.


Replacement  of Ozone Depleting                Developed technically valid
Compounds (ODCs) in Array                   substitution plan.
Equipment                                  Started eliminating ODC based
                                             systems through redesign.

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Program	Success	

Elimination of Spray                           Verified elimination process.
Chromate Conversion                           Conducted site implementation.
Coating Applications.
       The technical efforts described above will be discussed in detail.  However, these
successes represent only a few of the many AAPPSO project areas. Some of the other
important programs being managed by the AAPPSO include; elimination of chromic acid
plating rinses; development of powder coatings for Army applications, development of a
technically  valid, comprehensive plan  for eliminating cadmium plating from Army equipment;
training of  Army acquisition personnel at all levels regarding the need for effective acquisition
pollution prevention; development and distribution of over 6000 copies of the "Materiel
Developer's Guide for Pollution Prevention;" and generation of the contractual support
documents  the Army requires to task contractors to implement pollution prevention.
BACKGROUND

       Army industrial manufacturing processes are an essential part of the military
equipment rework/overhaul process.  Army manufacturing processes are quite similar to those
in private industry and must comply with the same Federal, state, and local environmental
regulations.  Any operating or overhead costs associated with the procurement, use, or
disposal of hazardous materials  adversely impacts facility costs and does not contribute to an
improved final product. In the past, expenses related to hazardous materials were considered
a "cost of doing business." Today, through pollution prevention implementation, the Army
does not have to pay for pollutants that do not add value to the product.

       In addition to having to fund the normal "cost of doing business" associated with the
use of hazardous materials, excessive pollutant discharges can  lead to permit violations.
During the 1991 - 1992, both Red River and Letterkenney Army Depots violated their air
quality permits. These violations were related directly to excessive Volatile Organic
Compound (VOC) emissions from painting and finishing. These permit violations have lead
to significant changes in depot operating procedures.

       The most effective means of saving money and preventing permit violations is
pollution prevention.  Pollution prevention has  also been mandated as Federal and state law.
The Federal Pollution Prevention Act of 1990 established an overall policy that twenty-eight
states have adopted as part of their environmental regulations.  Army VOC pollution
prevention programs are designed to ensure compliance with these laws and to simultaneously
improve product quality.  Thus,  pollution prevention programs help to minimize operating
costs, avoid NOVs, and comply  with  pertinent environmental regulations.
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DISCUSSION

       The following discussion sections highlight the key success stories. Each discussion is
roughly divided into sections describing the program background, technical results, and
conclusions.

Implementation of Low VOC Electrodeposited Epoxy Coatings on Army Equipment

       In 1989, the Army Acquisition Pollution Prevention Support Office (AAPPSO),
Armaments Research. Development, and Engineering Command (ARDEC), Tank and
Automotive Command (TACOM), and Belvoir Research Development and Engineering Center
(BRDEC) initiated a program to include the electrodeposisted epoxy (E-coat) coatings used by
the automobile industry in the Army Chemical Agent Resistant Coating (CARC) family of
materials. The program was designed to effectively leverage the existing knowledge within
the automotive industry and thus minimize the required Army  investment.

       E-coat systems utilize a low Volatile Organic Compound (VOC) epoxy paint emulsion
in a completely recyclable water bath.  Vehicle bodies or other complex parts are electrically
charged and lowered into the E-coat bath.  The electric current flowing through the bath
causes the epoxy paint to "plate-out" on all conductive surfaces. Because the epoxy coatings
are non-conductive, current densities increase  around defects or difficult to coat areas.  The
increased current densities cause additional coating  deposition.  Thus, the coating application
process causes epoxy to be deposited uniformly on  virtually all conductive surfaces.2

       Ocean City Research Corporation (OCRC) worked with ARDEC and TACOM  staff to
evaluate the corrosion control performance of an environmentally  acceptable, low-lead, low-
VOC, E-coat formulations.  OCRC prepared test panels with the proposed E-coat material and
with conventional spray applied epoxy primers. Simultaneously, TACOM coated tactical
vehicle bodies with the proposed materials. The panels and vehicles were then exposed to the
natural marine environment for a period of one-year.  Data were collected tracking the
substrate corrosion allowed by the various corroding systems.  Test results indicated that the
proposed E-coat material provided superior substrate corrosion control performance relative to
the currently applied spray epoxy primers.

       Upon completion of the technical corrosion control performance evaluations, the
proposed E-coat material was evaluated by BRDEC for compliance with the rigorous CARC
requirements. The CARC system must resist absorption of chemical warfare agents, prevent
substrate corrosion, withstand normal wear, and provide effective camouflage within the
visible light and IR range.  BRDEC tests indicated  that the proposed E-coat material was an
effective primer that satisfied all CARC performance requirements.

       A new military specification, MIL-P-53084, for the electrodeposited epoxy was
generated. This specification allowed Army acquisition activities to "call-out" E-coat in
procurement projects.  This new specification  has already been invoked on the Family of
Medium Tactical Vehicles (FMTV) program and will reduce VOC emissions, improve product
quality, and cut costs in the near future.
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       The major TACOM FMTV procurement project for medium duty trucks was one of
 the first to require E-coat  Because the E-coat system is inherently low in VOCs and has a
 near 100 percent transfer efficiency, primer coating VOC emissions arc minimized. Assuming
 that 10,000 trucks will be procured by the Army over the life of the contract, E-coat
 implementation could reduce primer VOC emissions by approximately 3900 tons.

       In addition to VOC emission reductions. E-coat is a far more effective corrosion
 control primer than the older spray primer systems. Data is not yet available regarding how
 much corrosion control maintenance can be avoided by using E-coaL However, it has
 primarily been the use of cathodic E-coat over a zinc-phosphate prelreatment that has allowed
 the commercial automotive industry to  give 7-year or 70.000 mile corrosion warranties.2

       Finally, E-coat implementation will save the Army an enormous amount of money
 over the life-cycle of it's new vehicles.  The savings will come from reduced maintenance
 costs, reduced coating consumption, and from being able to comply with the latest Clean Air
 Act Amendments. Because state air quality regulatory agencies can require Army facilities to
 install expensive pollution control equipment if they continue to use the older, higher VOC
 materials, the use of E-coat can save money through cost avoidance. At one Army depot
 alone, the use of E-coat could save over $3.5 million in one time cost avoidance and over
 $196,000/year in subsequent maintenance expenses.
Implementation Low VOC Cleaners at Army Depots.

       Corpus Christi Army Depot (CCAD) repairs and reworks Array helicopters. CCAD
had been using a wide range of VOC-based cleaning compounds in the bearing shop and
airframe coating facility.  AAPPSO staff worked with CCAD to identify the cleaning process
parameters and develop effective measures of cleanliness for the VOC cleaning operations.
Existing private industry experience was leveraged during the cleaning parameter assessment
The key cleaning parameters were then compared against the performance of currently
available aqueous cleaners.  Bases on this analysis, AAPPSO staff identified a non-VOC
based, aqueous cleaner that could satisfy the important cleaning process parameters.

       Depot staff developed a performance test program to verify aqueous cleaner system
performance. Two performance test programs were initiated.  The first program was designed
to verify that the aqueous cleaning process could be used on high-value bearings without
causing corrosion.  The second program was designed to verify that the aqueous cleaner could
remove soils from  airframe before final coating application.

       Both performance tests program were conducted at the depot using production
personnel.  The use of depot personnel and equipment ensured that the aqueous cleaners could
not only satisfy operational requirements, but could also be  implemented.  Trials were
conducted using the aqueous materials to clean components and airframes.  The trials
demonstrated that the aqueous cleaner was an effective substitute for the VOC based
materials.

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       The aqueous cleaner based systems have been installed at the depot  Although VOC
emission reductions are difficult to quantify, use of the aqueous cleaners has reduced depot
operating costs. Depot personnel estimate that $75,000 is saved every year by avoiding the
costs of purchasing, handling, and treating the hazardous VOC  based cleaning materials.
Replacement of Ozone Depleting Compounds

       The Army uses a wide range of chlorofluorocarbons (CFCs) in fire suppression,
refrigeration, and solvent cleaning systems. CFCs are considered Ozone Depleting
Compounds (ODCs) because they rise to stratosphere and catalytically destroy ozone
molecules.  In 1988, the United States Congress ratified the Montreal Protocol which is
intended to protect the ozone layer by eliminating ODC production. Broadly speaking, the
Montreal Protocol increases taxes on some compounds and eliminates production of all ODCs
in accordance with a fixed time-table. Because the United States, the Department of Defense,
and the Army have accepted the Protocol guidelines, ODCs will have to be removed from
fielded equipment and designed-out of subsequent systems.

       Considering that ODCs are mentioned in over 9500 military specifications, reducing or
eliminating the uses for these materials is a technically complex task.1  To manage this task.
AAPPSO consulted with technical experts, industry, and the Chairman of the United Nation's
"Halons  Technical Options Committee." Based on these consultations, AAPPSO developed a
"Strategic Plan for Replacing Ozone Depleting Chemicals in U.S. Army Tactical Weapons
Systems." This plan presents solutions for the problems caused by ODCs used as fire fighting
materials, refrigerants, and cleaning solvents.

       The ODC plan suggests overall system replacement and existing stock conservation as
the most effective means of addressing the fire fighting issues.  Current Array tactical
equipment typically includes hand-held fire extinguishers and an automatic fire suppression
system based on the halon family of chemicals.  Hand-held units are used to fight small
electrical or equipment fires.  Automatic units are used to extinguish fires caused by
catastrophic accidents or combat damage.

       The plan describes a logical process for replacing the halon filled hand-held units with
similar carbon dioxide extinguishers. AAPPSO data reviews and fire analysis calculations
showed that slightly larger capacity, but similar rating, hand-held carbon dioxide filled
extinguishers could  effectively fight the same size fires as the current Halon 1301 units.  The
AAPPSO intends to remove all Halon 1301 hand-held fire extinguishers from Army tactical
vehicles  by the end  of 1995 and install the more environmentally friendly carbon dioxide
based units. The Halon 1301 units will then be drained and the fire suppression chemicals
collected in the ODC  Reserve.

       The Reserve concept is intended to ensure that the Army has enough Halon 1301 to
satisfy its wartime and operational fire suppression requirements. Main battle tanks, armored
personnel carriers, and most other armored vehicles have an automatic Halon 1301 fire
suppression system. These systems trigger automatically when the armor is breached and
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 within 250 milliseconds discharge Halon 1301 to extinguish any resulting fires.  What makes
these systems Mission Critical is that Halon 1301 is the only material known that can
extinguish the fire and not smother or poison the crew. Israeli data collected during the 1982
invasion of Lebanon showed that their halon system equipped tanks were 50%  less likely to
burn after being hit than non-halon equipped vehicles.4 Because fires destroy tanks and kill
crews far more than armor penetrations alone. Halon 1301 systems are considered vital.  The
Army plans to stockpile Halon  1301  from hand-held units and from decommissioned  systems
to meet operational needs.  This Halon 1301 Reserve will only be  used during future
conflicts. The stockpile approach minimizes the amount of halon that will have to be
produced and eventually released  into the environment while simultaneously  providing enough
material to keep these vital systems operational during combat

       The strategic plan addresses the refrigeration issue in a similar manner.  Refrigeration
systems are used on many modern tactical vehicles to cool electronics, food,  medical supplies.
and crews.  Because these military cooling requirements are similar to those of the
private/commercial sector, the plan suggests purchasing commercially developed non-ODC
cooling systems in the future.  The ODCs from current Array refrigeration systems will be
collected  and a one-year operational reserve kept in supply. The reserve materials will then
be  used on an as-needed basis to maintain and repair older ODC based cooling  systems.

       The strategic plan describes the use of alternative technologies to eliminate the need
for ODC  based solvent cleaning systems.  ODC based cleaning systems are used to remove
soils from delicate parts, flux residues from  printed circuit boards, and as "blow-off cleaners
for precision machinery.  AAPPSO determined that the ODC applications were  not unique
and that there are many currently  available alternative cleaning technologies that could be
used to replace ODCs. These cleaning technologies include aqueous washers, supercritical
carbon dioxide systems, sodium bicarbonate blasting, and vacuum degreasing. The AAPPSO
has communicated the need to eliminate ODC based cleaning systems to the Army acquisition
managers. These managers will use AAPPSO supplied contractual documents to prohibit
contractors from using ODC based cleaning systems.  In addition, Army depots are
conducting on-site evaluation programs for the new cleaning systems.

       Considering that the ODC  program is fundamentally administering the recycling of a
material that will no longer be produced, the economic savings (due to the unknown nature of
the future supply/demand interactions for the materials) are difficult to quantify. However.
the plan is not designed to produce economic benefits, it is intended to reduce the threat to
the ozone layer while simultaneously allowing the Array to satisfy vital wartime operational
requirements.

Elimination of Chromate Conversion Coating Applications.

       Many of the armored personnel carriers, self propelled howitzers, and transport
systems used by the Army are fabricated from 5000 series aluminum.  The Army has been
applying chrornate conversion coatings to this armor grade aluminum as a CARC system
pretreatraem. The chrornate conversion coating uses carcinogenic hexavalent chromium to
produce a pretreatment film that reportedly improves adhesion and reduces underfUm
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corrosion.  Red River Army Depot personnel initially thought chromate conversion coatings
could be eliminated from the aluminum armored vehicles they reworked without resulting in
any performance degradation.  Depot staff investigated the best commercial practices and the
pretreatmcnt systems used by other services on similar grades of aluminum.  This
investigation revealed that commercial industry and the Navy were using more
environmentally acceptable pretreatments - only the Army still required chromates on armor
grade aluminum.  Based on this finding, depot staff contacted AAPPSO and requested
assistance with the elimination of this hazardous pretreatment

       The AAPPSO tasked OCRC to conduct a detailed technical evaluation of armor grade
aluminum operational performance both with and without the chromate pretreatment.  The
technical evaluation was to focus on the "real-world" armored vehicle operating conditions.
The test program included:

1.     Long-term natural marine atmosphere exposure testing of CARC coated armor grade
       aluminum test panels.

2.     Evaluation of both wet  and  dry coaling adhesion.

3.     Examination of how the alternative surface pretreatments affect resistance to Army
       alkaline cleaning solutions.

       After completing the long-term exposure and laboratory  tests, results were summarized
in a final report.  The report concluded that the 5000 series aluminum was so  inherently
corrosion resistant that the chromate conversion coating did not inhibit underfilm corrosion.
In addition, laboratory testing demonstrated that primer to aluminum adhesion could be
improved by using environmentally acceptable mechanical pretreatments instead of the
chromate materials.  Finally, the alkaline cleaner exposure tests indicated that  any number of
the alternative pretreatments improved overall system  performance relative to the chromated
test panels. These favorable results indicated that chromate conversion coatings could be
eliminated  from armor grade aluminum coating processes without degrading in-service
performance.

       The favorable technical evaluation program results led to chromate elimination trials at
Red River  Army Depot  Depot personnel provided a  trial vehicle body and assisted with a
non-chromate conversion coating implementation test  The on-site implementation test
confirmed  that  vehicles could be coated by the depot without the chromate material. Figure 1
shows the trial  vehicle coated with the standard Army three color camouflage system.

       Based on technical data collected during the on-site implementation program, a
specific process control document,  tailored to meet the depot's operational needs, was
developed.  The document provides the depot staff with the process requirements and quality
control tests that are needed to eliminate the chromate conversion coatings.
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       Elimination of chromate conversion coalings from Red River Army Depot will reduce
hazardous waste generation, eliminate a worker health threat, and cut costs. Currently.
chromate conversion coating rinse waters are processed by an industrial waste treatment plant,
generating hazardous sludge wastes. Elimination of the chromate conversion coating will
significantly reduce the waste treatment plant hexavalent  chrome burden.  The elimination of
chromate conversion coatings from plant operations will alleviate a threat to worker health.
Currently, the chromic acid based material is sprayed by  a "moon-suited" worker in a booth.
By eliminating this hazardous pretrcatment, workers in and around the booth will not be
exposed to hexavalent chromium.  Finally, eliminating the chromate conversion coatings will
allow the depot to avoid having to upgrade their pollution control equipment  This one Army
depot alone could avoid having to spend $4 million on new pollution control equipment and
save an additional $195,000/year  in maintenance costs.  Upon receipt of Command approval
for the final changes, chromate conversion coatings at Red River Army Depot will be
eliminated.  The success of this project would then be exported to other Army production and
maintenance facilities.
CONCLUSIONS

       The following conclusions are based on the overall AAPPSO successes:

1.     Acquisition pollution prevention programs save money. Total savings and cost
       avoidance from the four programs discussed in this paper for the first year are
       close to $8,000,000.  Additional yearly savings would exceed $500,000.

2.     Acquisition pollution prevention programs reduce the need for hazardous
       materials and protect the environment

3.     Management of essential hazardous materials will prevent pollution and ensure
       Army activities continue to have an available supply of these vital materials to
       satisfy mission critical needs.
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                                BIBLIOGRAPHY

1.     Headquarters Army Materiel Command. Environmental Office, April 1993.

2.     BASF Corporation Technical Presentation, G. Lovell, April 1992.

3.     Materiel Developer's Guide for Pollution Prevention. AAPPSO Publication, 1992.

4.     The Illustrated History of Tanks, A. Lighlbody, J. Poyer, Publications International,
      1989.
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M577 Test Vehicle, Final Coating System
M577 Test Vehicle, Final Coating System
 Figure 1    M577 Test Vehicle Without Chromate Conversion Coating
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                         SESSION 5


      ENCOURAGING POLLUTION PREVENTION

                       PAPERS PRESENTED:

              "Pollution Prevention Opportunities in Coatings:
           Educating Those Who arc Responsible for This Task"
                                by
                         Robert B. Pojasek
                        GEI Consultants, Inc.
                      Winchester, Massachusetts

     "Economic Incentives to Stimulate the Development and Diffusion of
                Low- and No-VOC Coating Technologies"
                                by
                          Brian J. Morton
                     Research Triangle Institute
                    Center for Economics Research
                 Research Triangle Park, North Carolina
                               and
                          Bruce Madariaga
                U.S. Environmental Protection Agency
              Office of Air Quality Planning and Standards
                 Research Triangle Park, North Carolina

          "Pollution Prevention in the Wood Refinishing Industry"
                                by
                           Azita Yazdani
                Pollution Prevention International, Inc.
                          Brea, California
                               and
                          Donna Toy-Chen
                        City of Los Angeles
                            HTM Office
                       Los Angeles, California

"The Importance of Product Stewardship and Its Impact on Pollution Prevention"
                                by
                         Richard S. Sayad
                    The Dow Chemical Company
                         Midland, Michigan
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  (The wort: described in this paper was not funded by the U.S. Environmental Protection
  Agency.  The contents do not necessarily reflect the views of the Agency and no official
  endorsement should be inferred.)

           POLLUTION PREVENTION OPPORTUNITIES IN COATINGS:
          EDUCATING THOSE WHO ARE RESPONSIBLE FOR THIS TASK
 Robert B. Pojasek
 GEI Consultants, Inc.
 1021 Main Street
 Winchester, Massachusetts 01890
 INTRODUCTION

       Finding substitutes for regulated chemicals is an expensive proposition for the
 suppliers.  Millions of dollars are spent in researching and development costs to make
 compliant chemicals available to customers. On the other side, these chemical users must
 spend a large amount of money to qualify the substitute chemical for its intended applica-
 tion. It seems that whenever a chemical gets added to yet another regulated list, vendors
 and users begin the quest for substitutes. Regulation creates a rather uncertain future
 market because it is difficult to predict which chemicals will be added to which lists.
 With a new administration in Washington, D.C., there are already new initiatives to
 expand the listing of chemicals reportable on the Toxics Release Inventory's Form R.

       One way to provide some level of predictability is by the adoption of pollution
 prevention practices by a wide range of industrial chemical users.  By increasing process
 efficiency, users will require lower quantities of chemicals.  Perhaps they will be able to
 eliminate the use of certain chemicals altogether by finding new materials which do not
 need to be cleaned or coated. Chemical companies can then diversify into providing
 these new materials to industrial users.

       The expeditious move to pollution prevention has started with the formation of the
 American Institute for Pollution Prevention. This group,  initiated with funding  from the
 U.S. Environmental Protection Agency (EPA),  is an alliance of 27 trade and professional
 associations (see Table 1). All the information  generated by EPA's pollution prevention
programs is channeled into these associations to reach a broader constituency.  The EPA
can also tap the pollution prevention resources of these groups and  their membership as
new programs are initiated.

       Another means of expediting the adoption of pollution prevention is by making
sure that engineering students have the opportunity to learn about pollution prevention  in
a classroom setting.  The American Institute for Pollution Prevention has sponsored  an
initiative at UCLA to develop a set of pollution  prevention homework assignments that
can be utilized in traditional chemical engineering courses. With the assistance of the
American Institute of Chemical Engineers, a member association, these homework assign-
ments were distributed free of charge to any chemical engineering professor who wanted
them.  In a related effort, the author has developed a pollution prevention course that can
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 be offered at the graduate level in an environmental engineering curriculum.  A copy of
 the syllabus may be found in the Appendix to this article.

 DESCRIPTIVE METHOD FOR POLLUTION PREVENTION

       The descriptive method for pollution prevention has evolved over the four years
 that this course has been offered.  This approach does not use worksheets, questionnaires,
 checklists or case histories.  These are prescriptive tools.  Instead process flow diagrams
 are used to map out the  means for producing whatever product the facility is responsible
 for manufacturing.  Process mapping allows the pollution prevention team to determine
 the functionality of the operation.  It can be seen that one step initiates another which in
 turn initiates another until the process has completed its overall function with some type
 of product (result).  Materials accounting techniques are utilized to track all materials
 used and lost from each  unit operation.   Losses include those to the air, water, solid
 wastes, spills/leaks, and accidents (i.e., bad batches, damaged products, fires/explosions,
 etc.).  Activity-based costing (ABC) is utilized  to allocate environmental management
 costs to the individual production units from the overhead which is typically spread
 evenly across the entire production sequence.  In this manner, opportunities occurring in
 high ABC units will be explored first.  This will help lower the cost of the operation and
 the pollution prevention effort will make it more efficient.

       Every loss from the production units is an opportunity not to have that loss.  In
 any manufacturing operation, there  will be many opportunities for pollution prevention.
 In the  prescriptive method, someone must look for opportunities or read about them in
 the available case histories or industry-specific studies.  However, these approaches are
 not self-sustaining because the listing of opportunities is limited.  Because the list is large,
 it must be screened with  a set of criteria  specific to the facility under investigation.
 Emphasis will be placed  on the primary opportunities. Pollution prevention tools such as
 cause and effect diagrams, force field analysis,  and dendograms are utilized to determine
 the root cause of the loss. Brainstorming techniques are used to derive a large number of
 alternatives to eliminate the loss.  These alternatives are screened using effectiveness,
 implementability, and cost criteria derived by the pollution prevention team. If
 necessary, a formal feasibility study is performed on the most attractive alternatives.
 Some form of financial justification  may be necessary to implement the selected
 alternative.

       The Descriptive Approach is a logical, common-sense method which is nearly
 identical to the application of total quality management and just-in-time programs within
 the  same manufacturing facility.  Students with little knowledge of manufacturing tech-
nology can work with an industry to implement  such a program after about  seven weeks
of the course. They finish the project at the end of the 14 week semester and it counts
for 40 percent of their grade.
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APPLICATION OF APPROACH TO COATINGS

       When coatings become highly regulated, the single focus of the firm using them is
to find substitutes.  Certainly this is the approach that the chemical companies wish to
pursue themselves,  since they make and sell these coatings.  Some of the losses of
volatile organics from the application of coatings can be improved by increasing the
transfer efficiency and by other good operating practices  surrounding the storage and
handling of the coating medium. Efficiency translates to less coating that can be sold.

       Non-VOC coatings are another option but may have other drawbacks such as
poorer drying, use of flammable chemicals (i.e., alcohols), and a variety of other side
effects.

       The questions that the Descriptive Approach ask are:  Why are you coating in the
first place?  Is there a material that can be used that does not need to be coated?  Are
there coatings with high transfer efficiencies that use no liquids?  The whole idea is to
eliminate the loss from a coating operation, not to substitute one loss for another.  More
than likely there are no ready solutions for most coating problems.  However, through
continuous improvement, the pollution prevention team should work towards the non-wet
coating or the elimination of the need to coat by changing the base material.  Many
manufacturing firms end up reacting to regulations by switching to substitutes at the last
minute.  Sometimes these substitutes are more expensive to buy.  They are always
expensive to qualify.

       If manufacturers practiced pollution prevention, they would be creating a
predictable market for new materials and non-wet coatings.  The chemical companies
would diversify to capture this new market in order to cover  the decreased demand for
traditional coatings and low-VOC substitute coatings.  Manufacturers must train their
engineers to be skilled at pollution prevention techniques. Manufacturers need to see that
new engineers are being trained in pollution prevention technique application. Manufac-
turers must see to it that the chemical suppliers are provided with an incentive to spend
the money that it will take to revolutionize the way we coat materials today.  This is an
area where everyone can win.
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                   TABLE 1 - AIPP MEMBER ASSOCIATIONS

 Aerospace Industries Assoc. of America
 Air & Waste Management Assoc.
 American Petroleum Institute
 American Institute of Chemical Engineers
 American Academy of Environmental Engineers
 American Iron & Steel Institute
 American Paper Institute
 American Society of Civil Engineers
 American Electroplaters & Surface Finishers Society
 American Institute of Architects
 Chemical Manufacturers Assoc.
 Electric Power Research Institute
 Health Industries Manufacturers Association
 Industrial Designers Society of America
 National Agricultural Chemicals Association
 National Association of Corrosion Engineers
National Roundtable of State Waste Reduction Programs
Solid Waste Association of North America
U.S. Department of Defense
Water Environmental Federation
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          APPENDIX A



POLLUTION PREVENTION SYLLABUS
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                    Department of Civil/Environmental Engineering
                               TUFTS UNIVERSITY
 CE-194J Pollution Prevention                                            Spring 1993
 Instructor:  Dr. Robert B. Pojasek
                            COURSE DESCRIPTION
       This course focuses on the interface between manufacturing and the environment.
 By manufacturing a product more efficiently, there will be less losses to the environment.
 Pollution prevention examines how a manufacturing firm can move away from end-of-the-
 pipe pollution controls as the  only means of complying with stringent regulations. A
 process perspective is necessary to gain an understanding of chemicals use and process
 losses.  Information presented in the course will provide a basis for developing and
 implementing techniques to reduce these losses at the  source.

       This is a "hands on" course where the student will learn by actually working on a
 pollution prevention project.  In lieu of a final examination, the student will work in a
 small group  to evaluate a designated facility which manufacturers paints, adhesives, or
 coatings (i.e., the industry classification chosen as the focus for this semester's course).
 Together they will prepare process flow diagrams, materials accounting summaries,
 description of all of the opportunities for pollution prevention, and a rank ordering of
 these opportunities.  Each student in the group will then research one of the primary
 opportunities, conduct a feasibility study, and make recommendations for implementation.

       In order to learn how pollution prevention programs are planned and implemented,
 each student will work in another small group to evaluate a designated firm's actual
program.  A confidentiality agreement will be negotiated in each case before the work is
commenced.  Each program will be evaluated in terms of the culture of that firm and not
by comparing it to other firms' programs. The group will write a report describing the
program and making recommendations to improve  it.  Each student will prepare an
individual critical review of the program.
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                            COURSE SCHEDULE
  1.    January 25, 1993         INTRODUCTION TO POLLUTION PREVENTION

       Without dwelling extensively on the terminology and definitional problems that
 currently exist in this emerging field, some generic pollution prevention concepts will be
 presented.  These concepts will include chemical use cycles,  the waste management hier-
 archy, sustainable development and the theories of loss control.  Incentives and dis-
 incentives to the use of pollution prevention practices  in industry will be examined along
 with pressures that have been brought to bear to induce facilities to place these practices
 in place. No attempt will be made to examine specific pollution prevention legislation or
 regulations.

 2.    February 1, 1993         MANUFACTURING AND MANAGEMENT

       Emphasis in this course is placed on pollution prevention in manufacturing. All
 manufacturing categories have commonalities which, when recognized, allow the
 pollution prevention practioner to apply the concepts described in the previous section
 without regard to the type of firm. Besides examining manufacturing, the manner in
 which manufacturing is managed is a key to the successful implementation of pollution
 prevention.  Analogous management programs (such as total quality  management, just-in-
 time, and computer integrated manufacturing) will  be discussed along with a model for
 manufacturing for competitive advantage.

 3.   February 8, 1993     CORPORATE POLLUTION PREVENTION PROGRAMS

      One of the term papers will have the student explore how companies plan, operate,
 and sustain pollution prevention programs. An important key to a successful program is
 the recognition of the corporate culture.  At various levels  in the firm, this culture can
 vary somewhat depending on whether one looks at die corporate organization, business
 units/ divisions, facilities or departments in the facilities. There is also the issue of the
 impact of suppliers and customers in formulating a workable program to enhance
 competitiveness of the operation.  Analogous programs such as total  predictive
 maintenance will be examined to see how lessons learned will be applicable to pollution
prevention programs.
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  4.    Feb. 17, 1993 MAPPING A MANUFACTURING PROCESS OR OPERATION
        (Wednesday)

        Mapping is utilized to help develop a picture of the process or operation being
 examined.  Resolving the differences between the way different people see the process
 and what is actually happening is a valuable activity.  A variety of mapping and other
 visualization techniques will be evaluated along with analogies to road maps and electrical
 schematic diagrams.  Using process flow diagrams to help understand process
 functionality is at the heart of the descriptive approach to pollution prevention
 assessments.  A variety of exercises will be utilized to develop suitable map preparation
 skills.

  5.    February 22, 1993         CONDUCTING A FACILITY ASSESSMENT

        To conduct a successful pollution prevention assessment one must learn to become
 a good EXPLORER.  Utilizing prescriptive  tools (i.e., checklists, worksheets, and
 questionnaires) for conducting assessments have many problems associated with them.
 Process flow diagrams and materials accounting must be an important component of the
 assessment.  The difference between materials accounting and materials balances will be
 explained.  It is important that the facility assessment identify all the  losses from the
 operations or process steps. All ancillary and intermittent operations must be identified
 and incorporated into the assessment.

 6.    March 1, 1993            IDEA TOOL BOX

       Total quality management and other management programs employ a number of
 tools to define  and understand the problems as well as to gather information for the
 feasibility study.  Every loss identified in the assessment is an opportunity not to have the
 loss.  To describe  the opportunity and to qualify which opportunities are most important,
 a variety of tools can be utilized.  They include: brainstorming, storyboarding, mind
 mapping, cause and effect diagrams, Pareto process, root cause analysis and
 computerized simulation models.  Examples will be utilized from process equipment
 cleaning and chemical transfer/mixing operations.

 7.    March 8, 1993            ANALYZING INFORMATION

       An ARTIST takes information gathered  from the assessment and draws pictures with
it.  Graphical techniques will be utilized  to present the data from the above steps. If the
pollution prevention practitioner can utilize the tool box to discover trends and get at the
root cause of the problems, they can begin to derive alternatives for each  primary oppor-
tunity and develop  the information necessary for screening and evaluation which takes
place in the feasibility study. Above all, one must resist the search for the "right"
answer.

                                       200

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 8.    March 15, 1993           THE FEASIBILITY STUDY

       Conducting the feasibility study is like being a JUDGE.  Considering the specifics
 in each case is important.  Criteria for screening alternatives will include effectiveness,
 implementability and cost.  A more detailed analysis of the primary alternatives will
 consider engineering, economics and institutional considerations. The need for bench and
 pilot testing must be determined at this time.  Ail this activity will help establish a
 successful implementation program.
                                -SPRING BREAK	
 This break provides an opportunity to work on the term papers. Four lectures will be
 given over the next two weeks to familiarize the student with the major categories of
 alternatives that are often considered in a pollution prevention feasibility study.

 9.    March 29, 1993    OPERATING PRACTICES/MATERIALS SUBSTITUTION

       Good  operating practices are often referred to as the "low hanging fruit" of
 pollution prevention. These are the easiest alternatives to implement and may often lead
 to the largest increments of reduction. Materials  substitution is most frequently utilized
 by industry to move from listed regulated materials to unlisted materials.  There are many
 cases where the substitute has either shifted the media into which the loss was transferred
 or was later deemed toxic after more detailed tests were conducted. Dematerialization is
 another form or materials substitution that will be covered.  TERM PAPER ON COMPANY
 P2 PROGRAM DUE.

 10.    April 5, 1993            TECHNOLOGY/RECYCLE-REUSE-RECOVER

       Technology can range from equipment modification and process automation to
 quantum leaps in the manner in which an item is manufactured.  Industrial ecology is a
 term used to examine the concept of recycling.  There is often an overlap between
 recycling and treatment. Each of these considerations occupy a lower status on the waste
 management hierarchy covered in die first class.  Sham recycling and off-site operations
 will be examined along with the practice of waste exchange.

 11.    April 12, 1993            IMPLEMENTATION

      Implementing the primary alternative selected in the feasibility study is often like
being a good  WARRIOR.  Instead of fighting to get something implemented, teamwork,
program integration and a good feasibility study should help facilitate project and
program implementation.
                                     201

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 12.    April 19, 1993           No Class

        This break will provide an opportunity to complete the pollution prevention
 projects which are DUE at the next class.

 13.    April 26, 1993           DESIGN FOR X

        It is always preferable to design pollution prevention into new processes and
 products.  The X can stand for the following terms:  environment, recyclability,
 disassembly, remanufacturability,  reliability, durability, waste minimization, etc.  These
 terms have been in use for a long  time and are all related to one another.  Life cycle
 analysis of products  is also an old tool which has taken on new meaning by including
 environmental impacts of operations from the extraction of the raw materials to the
 ultimate disposition of the final product.  This analysis can utilize the descriptive
 approach developed  in this course and need not be prescriptive.  TERM PAPER ON
 POLLUTION PREVENTION PROJECTS DUE.

 14.   May 3, 1993              COURSE WRAP-UP

       Each of the important lessons learned about the manufacture of paints, adhesives
 and coatings will be  utilized to design the coatings manufacturing facility of the future.
                           COURSE INFORMATION
Textbooks.    There are four texts:  "A Kick in the Seat of the Pants" by Roger von
Oeck (ISBN 0-06-096024-8 pbk.); "21st Century Manufacturing" by Thomas G. Gunn
(ISBN 0-88730-546-6); "Faculty Pollution Prevention Guide", EPA/600/R-92/088, 1992;
and "Guides to Pollution Prevention-The Paint Manufacturing Industry,"  EPA/625/7-
90/005, 1990.

Additional reading materials will be handed out each week in class along  with the home-
work assignments.

Reserve Reading.  There will be materials placed each week in the reserve reading
location of the departmental library.  Usually these materials will provide supplementary
information.

Homework.  Homework must be completed by the start of each class. All homework
must be TYPED with adequate spacing to make written comments in the class and by the
instructor. It will be discussed in the class and collected with comments written by the
student as a result of the class discussion.

                                     202

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Grading.  Each student will receive a letter grade based on the following components:

              1.    Pollution Prevention Project-Term Paper =40%
                         Group Report = 25% of grade
                         Individual Report = 75% of grade

              2.    Critical Review of Corporate Program =  30%
                         Group Report = 33% of grade
                         Individual Report = 67% of grade

              3.    Homework:  Approx. six assignments = 20%

              4.    Classroom Participation = 10%

Class Schedule.  Each class will begin promptly at 6:30 p.m. on the dates indicated above
and will end at 9 p.m.

Office Hours.  Dr. Pojasek will be available one hour before every class, i.e., 5:30 to
6:30 p.m.  He is also available by appointment and by telephone during the normal
business day at the following location:  GEI Consultants, Inc.; 1021 Main Street;
Winchester, MA 01890 (617) 721-4097 (voice mail).  His fax number is (617) 721-4073.
                                      203

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204

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         ECONOMIC INCENTIVES TO STIMULATE THE DEVELOPMENT
       AND DIFFUSION OF LOW- AND NO-VOC COATING TECHNOLOGIES
Brian J. Morton
Center for Economics Research
Research Triangle Institute
3040 Comwallts Road
Research Triangle Park, NC 27709

Bruce Madariaga
Cost and  Economic Impact Section (MD-13)
Standards Development Branch
Emissions Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711


INTRODUCTION

       In 1970, the year of the first Earth Day, the nation's newspapers carried a powerful image
that symbolized the responsibility of everyone in a mass-consumption society for creating and
solving environmental problems. This icon is the famous Pogo cartoon: "We have met the
enemy and he is us."

       With the exception of the regulation of automobiles, national air pollution policy has only
recently addressed the environmental problems that are directly attributable to the use (as distinct
from manufacture) of mass-produced consumer goods.  In the Clean Air Act Amendments of
1990, the Congress directed the Environmental Protection Agency to regulate "consumer and
commercial products" to reduce emissions of volatile organic compounds, which are among the
precursors of ground level ozone. Section 183(e)(l)(B) of the Clean Air Act as amended (Clean
Air Act) defines a consumer or commercial product as "any substance, product (including paints,
consumer and commercial products, and solvents), or article (including any container or
packaging) held by any person, the use, consumption, storage, destruction, or decomposition of
which may result in the release of volatile organic compounds." The definition excludes fuels
and fuel additives.

       Thus, generally speaking, the environmental purpose of regulation of consumer and
commercial products under the Clean Air Act is to reduce the flow of volatile organic
compounds (VOCs) into the atmosphere from consumption (including storage) and disposal.
Figure 1 shows the dissipative and disposal emissions into the air that would be the target of
Federal regulation, distinguishing them from the production-related emissions that would be
beyond the scope of regulation under Section 183 of the Clean Air Act (as would emissions to
land and water).
Disclaimer This paper was written by Brian J. Morton and Bruce Madariaga in private capacity.
No official support or endorsement by the Environmental Protection Agency is intended or
should be inferred.                        ___

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 Note: Shaded area indicates consumption-related emissions.


  Figure 1.  Comprehensive Classification of Emissions From Production and Consumption

 Source: Adapted from Stigliani, William M. Chemical Emissions from the Processing and Use of Materials: the
 Need for an Integrated Emissions Accounting System. Ecological Economics, 2(4):325-341,1990 (Figure 2).
       Consumer and commercial products include literally thousands of specific commodities,
including especially paints and other coatings. "Architectural and industrial maintenance
coatings" are one subgroup of these products currently under consideration for regulation by the
Environmental Protection Agency.  These coatings are the source of approximately 3% of all
VOC emissions in the nation. A formal negotiation is underway now to develop a Federal rule to
address this important environmental problem. The rule may set a precedent for subsequent
regulations involving consumer and commercial products.

       Economic incentives could constitute the regulatory strategy, or one component thereof,
to be promulgated under Section 183(e) of the Clean Air Act "The regulations under this
subsection may include any system or systems of regulation as the Administrator may deem
appropriate, including...economic incentives (including marketable permits and auctions of
emissions rights) concerning the manufacture, processing, distribution, use, consumption, or
disposal of the product" [Section 183(e)(4)]. Regulations developed under Section 183(e) may
be imposed only with respect to manufacturers, processors, wholesale distributors, and importers
but not to retailers and users.
                                          206

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       Economic incentives are feasible for regulating VOC emissions from architectural and
industrial maintenance (AIM) coatings. Most important, economic incentives may be the most
desirable type of regulatory strategy because of their potential to achieve emission reductions at
lesser cost than less flexible strategies, and because of their greater potential to promote
environmentally beneficial technological change.

       As the nation redoubles its efforts to solve the nearly intractable problem of excessive and
unhealthy levels of ground level ozone, a broad survey of the potential of economic incentives to
reduce VOC emissions from AIM coatings and other coatings is especially timely. This paper
surveys different types of economic incentives and compares them against the following criteria:
environmental effectiveness, promotion of technological progress, economic impacts on coating
manufacturers, and implementation costs.

       A conclusion of this paper is that no single economic incentive will always be the best
because the best program depends on policy makers' objectives. Another general conclusion is
that the most helpful definition  of the problem of reducing VOC emissions from coatings focuses
not on reducing emissions from existing products but on providing "coating services" with fewer
adverse environmental effects.

SIGNIFICANT CHARACTERISTICS OF VOCS AND OF OZONE

       Volatile organic compounds and ozone have specific characteristics that influence the
design of an effective economic incentive.  In an airshed, VOCs mix uniformly with nitrogen
oxides to form ozone, one of the main components of urban smog. The characteristic of being
uniformly mixed implies that the concentration of ozone is independent of the location in an
airshed of sources emitting VOCs but dependent on the total amount of VOC emissions in the
airshed.  Another significant characteristic of the pollutants is that at current emission rates,
VOCs do not accumulate in the atmosphere from year to year, nor does ozone, and hence injury
to human health and ecosystem health is due not to the historical mass of emissions but from
current emissions.  Therefore, cost effective incentives do not need to differentiate among the
locations of sources and receptors in an airshed, and the incentives should target the rate of
current emissions of VOCs.1

BASIC MECHANICS OF ECONOMIC INCENTIVES TO REDUCE VOC EMISSIONS

       The  basic rationale for using economic incentives to reduce VOC emissions is to bring an
environmental service provided by the troposphere—its capacity to assimilate VOCs—into the
economic system.2 When people  release pollutants into the air, they use  an environmental
service without, in most cases, paying  for the use of this service. While there is no cost, or an
inadequate cost, to the polluter for releasing pollutants, there is a cost to all persons whose health
or well-being is diminished by the resulting decline in air quality. Economic incentives for
pollution control achieve their environmental purpose by increasing the cost of discarding
unwanted byproducts of production or consumption to the environment.

       Economic incentives directly or indirectly set the price of the environment's assimilative
capacity. Fee programs may directly set the price:  when the fee is charged per unit of emissions,
the fee is the price. Marketable emission permit programs indirectly set the price: the price is
determined by the permit market  After obtaining an initial allocation of permits from the
government, permit holders buy and sell permits. These transactions determine the price of a
permit.  Because the permit is an entitlement to emit a certain quantity of a pollutant in a given
time period, for example, one ton  of SO2 in one year, the permit price is equivalent to the price of
emissions.

                                         207

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        We know from observing ordinary markets that an increase in the price of a resource
 motivates users of the resource to use less. An increase in the price of gasoline, for example,
 motivates some people to reduce driving and others to buy more efficient automobiles. This
 example of the effect of a change in price and many similar examples justify the expectation that
 an increase in the price of using the environment to dispose of materials will lead polluters to
 reduce the emissions for which they are responsible.

        Implicit in using the market system for pollution control is another purpose of economic
 incentives and another operating principle: by maintaining polluters'  flexibility to respond to
 regulation, self-interest ensures that the amount of pollution control undertaken by a polluter is
 inversely proportional to the costs that the polluter incurs. Polluters will therefore be motivated
 to minimize the aggregate expenditure on pollution control.

        Figure 2 illustrates the cost-effectiveness of emission fee and transferable emission permit
 programs. Two sources initially emit a total of 30 units of pollution. The government intends to
 reduce pollution to a total of 15 units. The government may either charge a fee of $500 per unit
 of pollutant or allocate 15 permits (one  unit of emissions per permit) in some way to the sources.
 An emission fee or a permit price of $500 will induce Source  1 to reduce emissions from 15 units
 to 5 units. Source 2 reduces emissions from 15 units to 10 units. This allocation of
 responsibility for emission reduction  minimizes compliance costs.  Figure 2 shows that any other
 pattern of emission reductions increases total cost. For example, Source 2 would save the
 amount indicated by area A if it were to increase emissions by one unit, but Source 1 would
 spend A plus B.  Theoretically, economic incentives lead to the cost-minimizing pattern of
 emission reductions.
          Dollars/unit
         of emissions
           reduced
                                               MC2
MCi
                500
         Source no. 1
                    0123456789
                   15  14  13 12  11  10  9  8  7   6
                                                    10  11 12 13  14  15
                                                     543210
                                                                        Source no. 2

                                      Emissions reduced

       Figure 2. Cost-Effectiveness of Economic Incentives for Emission Reductions

Source: Adapted from T. H. Tictenberg, Emissions Trading: An Exercise in Reforming Pollution Policy, p. 20.

                                          208
Resources for the Future. Washington, D.C.. 1985.

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REGULATING VOC EMISSIONS VERSUS PROVIDING PRODUCT SERVICES WITH
LESS ENVIRONMENTAL DEGRADATION

       The purposes of any regulatory program influence the choice of specific options for the
many elements in the design of a program. A primary purpose of an economic incentive to
reduce VOC emissions from coatings would be to provide incentives for actions leading to the
achievement of a specific reduction in total VOC emissions from the regulated products. It is
important to observe that the achievement of the goal is not a one-time accomplishment but must
be met on a continuous basis, therefore requiring a permanent incentive.

       A significant subtlety affecting the objectives for the regulation of VOC emissions from
coatings is the distinction between aiming for reduced emissions from coatings per se and aiming
for reduced emissions from the means used by coating consumers to obtain the services that
coatings provide.  This distinction may have important implications for the design of the most
environmentally effective and least expensive regulatory strategy.

       The regulation of consumer and commercial products will illustrate.  Regulation of
consumer and commercial products under the Clean Air Act shall require "best available
controls" [Section 183(e)(3)(A)J. The Administrator of the EPA, on the basis of "technological
and economic feasibility, health, environmental,  and energy impacts," shall determine the desired
degree of emissions reduction that "is achievable through the application of the most effective
equipment, measures, processes, methods, systems or techniques, including chemical
reformulation, product or feedstock substitution,  repackaging, and directions for use,
consumption, storage, or disposal" [Section 183(e)( 1)].  Best available controls refer to the
emissions reduction that is determined by following the procedure specified in Section 183(e)(l).

       The requirement for best available controls not only establishes the general environmental
goal of regulation, it also establishes a framework for conceptualizing the thrust of regulation.
Specifically, the most important feature of this framework is a focus on each individual type of
consumer and commercial product: interior non-flat paint, exterior non-flat paint, clear wood
preservative, and others.

       A liability in the best-available-controls approach is that it encourages a tendency to
overlook the environmental gains that may be available from such indirect means of emission
reduction as substituting surface-coating-free materials for conventional materials. An analogy
to demand-side management in the electricity market is apposite.  Electricity itself is not
consumed because it directly provides things that people  value but because it is a source of
energy for lighting and heating, which are directly consumed. The distinction between electricity
and the services that electricity provides leads to  a recognition that society may be  better served
not by imposing high-cost emission control requirements on coal-burning power plants, but by
reducing electricity demand through, for example, policies that  increase the efficiency of using
electricity. For similar reasons, the design of regulations to reduce VOC emissions from coatings
should not overlook options for promoting substitute no-VOC technologies.

       Obviously, this argument in favor of pollution prevention is a familiar one. Yet the
combination of pollution prevention and economic incentives is a rather unexplored part of the
policy terrain. A survey of economic incentives to reduce VOC emissions and to promote low-
and no-VOC coating technologies will illustrate the pollution prevention opportunities that may
be seized with the use of economic incentives.
                                         209

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SURVEY AND COMPARISON OF ECONOMIC INCENTIVES TO REDUCE EMISSIONS
AND TO PROMOTE LOWER-VOC COATING TECHNOLOGIES

       Economic incentive strategies designed to achieve emission reductions typically work by
directly imposing a cost on the polluter, or the manufacturer of a polluting product, for the
emissions for which he or she is responsible. Policy-makers have many strategies from which to
choose.  Further, the choice is complex because multiple criteria are relevant to the choice of
regulatory strategies. The following criteria, although not exhaustive, are among the most
important for economic incentives to reduce VOC emissions from coatings:

       • certainty of air emissions reduction,

       • probable implementation cost,

       • potential for adverse economic impacts on coating manufacturers, and

       • potential to promote technological progress.

To facilitate the comparison of regulatory strategies, we use a system of qualitative rankings that
indicates relative performance on a criterion. Therefore, for example, the specific meaning of a
ranking of poor on a criterion may not be indicated precisely, but the difference in performance
between poor and fair is less than the difference between poor and excellent.

       A full comparison of regulatory strategies should account for both direct and indirect
effects. Any strategy that serves to increase the cost of employing VOC-containing coatings will
simultaneously stimulate development of lower-VOC technologies such as coating-free surfaces.
For example, coating-free surfaces are substitutes for surfaces that require coating. If the cost of
coatings is increased, the relative coi>i of coating-free surfaces will decrease, and demand and
prices for coating-free surfaces will increase. Higher selling prices for coating-free surfaces will
then stimulate technological developments.  Consequently, over time, the indirect effects of VOC
regulation include an increased demand for substitute products and an increased supply of new
substitute products.

       The rate of technological innovation is sensitive to the regulatory strategy. Though
command-and-control strategies that increase the cost of producing or consuming high-VOC
coatings will encourage development of low-VOC technologies, economic incentives may be
used to stimulate technological development in a more effective and sustained manner.3

       An economic incentive, such as VOC content fees or VOC allowance trading, provides a
continuous incentive for polluters to reduce emissions. Command-and-control strategies, for
example, VOC content limits and mandated technological requirements, provide a one-time
increase in the cost of using high-VOC coatings. After compliance, polluters do not have a
continuing incentive to reduce emissions further. However, polluters who must pay an emission
fee have a continuous incentive to develop technologies to reduce emissions and hence to reduce
fee payments. Similarly, when participating in an emission trading program, polluters have a
continuous incentive to develop emission-reducing technologies in order to sell more or buy
fewer allowances.
                                        210

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       Various fee-based strategies can be employed to increase the private cost of producing or
consuming VOC-containing coatings. Examples of such strategies include:

       (1)  simple emission fee—constant or variable fee rate per unit of VOC

       (2)  emission fee with rebates—fee revenues are rebated to manufacturers,

       (3)  emission fee over VOC threshold—fee is levied only on emissions from products
            of which the VOC content exceeds a threshold, and

       (4)  VOC reduction subsidy—fee paid by government for each unit reduced.

Table 1 summarizes our evaluation of each of the regulatory strategies discussed in this paper.

       In the group of strategies labeled as a "simple emission fee," a fee is levied on all
emissions, and, at any point in time, each source faces the same fee rate. A constant fee provides
a diminishing incentive for emission reduction and technological progress if inflation occurs.
Further, as the economy grows and the volume of coating sales increases, emissions will also
increase.

       Variable rate fees are essential to forestalling an eventual increase in aggregate emissions
from the regulated products, and even so the level of emissions will be uncertain.  A pre-
specified formula can be used to link the fee rate to the level of emissions reduction progress
from some baseline. Although advance notice of the conditions under which the fee will change
does enhance the formation of expectations, one potentially serious disadvantage of this strategy
is planning uncertainty for sources because emissions reduction progress is uncertain and hence
the fee rate will change unpredictably. Planning uncertainty increases the adverse economic
impact on coating manufacturers.

       The potential of a simple emission fee to promote technological progress is very goojd,
but the potential for adverse economic impacts on coating manufacturers is high. The certainty
of emissions reduction is fair even with a variable rate fee because of the difficulty of predicting
the short-term responses to a fee, although repeated adjustment of the fee rate will close the gap
between expected and actual reductions. The probable implementation cost is moderate,
reflecting the regulator's need for: product-by-product information on coating sales, VOC
content of each regulated product, laboratory testing of sampled products, and each regulated
source's remittance.

       Fee strategies with full or partial rebates  are attractive because rebates can  reduce
economic impacts on manufacturers. By rebating fee revenues based on market share or any
other criterion unrelated to emissions, incentives to reduce emissions and to develop lower-VOC
technologies can be maintained  Incentives for technological diffusion, however, may  be
reduced if revenues  are rebated  A manufacturer that develops a new technology will be more
reluctant to sell an innovation toother manufacturers, because to do so would reduce the latters'
fee payments, resulting in reduced rebates to the manufacturer selling the technology.  Because  a
manufacturer also could lose its competitive advantage by selling its technology to competitors,
the total incentive for technological diffusion is especially low in a fee program with rebates.
The total incentive for technological change is less in comparison to fee strategies without
rebates.  The record-keeping associated with rebates increases the regulator's implementation
costs.
                                         211

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TABLE 1. RANKING OF REGULATORY STRATEGIES TO REDUCE VOC EMISSIONS FROM SURFACE COATINGS
RELATIVE RANKING
Strategy
Simple Emission Fee
Emission Fee With Rebates
Emission Fee Over VOC Threshold
Emission Reduction Subsidy
^x 	 ' ' 	 ; •• •• 	 " ' 	
•> \"
Allowances
Marketable Allowances
Auctioned Allowances
Cross-Line Averaging
'
Substitute Product Subsidies
Substitute Product Research Grants

Combination Fee or Auction with
Substitute Product Subsidies

Command and Control
(Content Limits or
Technological Requirements)
Potential to
Promote
Technological
Progress
Very Good
Good
Limited
Very Good

Fair
Very Good
Excellent
Fair

Good
Very Good

Best

Poor
Potential for
Adverse Economic
Impacts on Coating
Manufacturers
High
Low
Low to Moderate
None
, ', , ' '
Low to Moderate
Low
High
Low to Moderate

Low
Low

Highest

Moderate to High
Probable
Implementation
Cost
Moderate
Moderate to High
Low to Moderate
Moderate
< 	 '.'. ';.' 	 '' '•/. '<'•;/:;:./ V^l*
Moderate
Moderate to High
High
Moderate
, ^
Moderate
Low

Moderate to High

Low
Certainty of Air
Emissions
Reduction
Fair
Fair
Fair
None
'/ / ' ', ,1
Excellent
Excellent
Excellent
Poor

Fair
Poor

Good or Excellent

Good

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       Another strategy to reduce the adverse economic impact on manufacturers from fees
combines an emission fee with a VOC content threshold. A fee would be levied only on
emissions from products of which the VOC content exceeds a specified threshold. Depending on
the threshold, this hybrid strategy is likely to reduce fee payments in comparison to a simple fee
strategy. It may also may reduce administrative costs because only sales and VOC content of
coatings exceeding the VOC threshold need to be monitored. A drawback with this strategy is
that incentives for technological innovation are limited because no incentive would exist for
reducing VOC content below the threshold.

       Another pricing strategy that can be employed to reduce emissions from coatings is a per
unit emission reduction subsidy or negative fee. Instead of manufacturers paying a fee for each
unit of VOC emitted, the regulator would pay manufacturers a subsidy for each unit of VOC
reduced  below some baseline. This strategy unambiguously benefits manufacturers while
preserving their incentive to reduce emissions.  The subsidy would create an opportunity cost of
using VOCs: forgone subsidy receipts. Provided that the rates are equal, an emission reduction
subsidy and an emission fee have the same potential to promote technological progress.

       Unfortunately, there are at least two major problems associated with the subsidy
approach.  The most obvious problem is one of funding such a program.  A less obvious problem
concerns the long run "entry/exit" impacts associated with subsidizing emission reductions.
Subsidies make the subsidized industry more profitable, thus discouraging exit from the industry
and encouraging entry into the industry. Though each manufacturer has an incentive to reduce
emissions, the number of manufacturers could increase.  It is entirely possible that aggregate
emissions could increase in the long run (after entry) with an emission reduction subsidy.

       Various emission trading strategies can also be employed to increase the private cost of
producing or consuming VOC-con tain ing coatings. Examples of such strategies include:

       (5)   simple allowances—VOC allowances for each source,

       (6)   marketable allowances—trading among sources is permitted,

       (7)   auctioned allowances—the initial allocation of allowances is made via auction, and

       (8)   cross-line averaging—sales weighted average limits.

As with fee strategies, different emission trading strategies perform differently on the evaluation
criteria.  For the group, the cost of implementation is unlikely to be low because the regulator
must keep track of allowance holdings as well as monitor emissions. With the exception of
cross-line averaging, the trading strategies in this list cap aggregate emissions from the regulated
sources.  The first three trading strategies offer unmatched certainty of air emissions reduction;
conversely, as explained below, cross-line averaging performs poorly on this criterion.

       The simplest trading strategy works by distributing VOC allowances to each source based
on historical emissions, product market share, or some other criterion.  Sources choose their own
least cost strategy to reduce VOCs under their "bubble."  If the emission constraint implied by
the distribution of allowances is binding, each source will have a fair incentive to develop or
adopt lower-VOC technologies. Lower-VOC technologies generate an internal  supply of excess
allowances that may be consumed by new  coatings or increased  sales of reformulated coatings.
A source's gain from excess allowances is limited because he or she may not sell allowances to
another company. The prohibition on interfirm trading severely limits  the incentive for
technological progress.

                                         213

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        Any particular source's incentive for technological innovation and aggregate (industry
 wide) control cost savings will be augmented, however, if sources are allowed to exchange (buy
 or sell) allowances with other sources. Intcrfirm trading increases flexibility for responding to
 the increased private cost of emissions. A source may find that external sources of emission
 reductions are cheaper than internal sources.  The prospect of selling excess allowances (or
 buying fewer allowances) provides a stronger, continuing motivation to invent lower-VOC
 technologies. The incentive for technological progress is very good, but not as high as possible
 because, as we explain next, the greatest benefit to an innovator occurs when allowances are
 auctioned.

        The regulator may sell allowances at an auction instead of giving them away.
 Theoretically, at an auction, sources immediately obtain the quantity of allowances that allows
 them to achieve the cost-minimizing configuration of emission reductions, given current
 conditions. Allowances are thus distributed predominantly to sources whose control costs are
 high.  Auctions avoid the time and transact ion costs associated with trading, and  they
 immediately establish  an obvious market price, which facilitates the evaluation of future
 investments in emission reduction.

        An auction allowance strategy could also increase the rate of technological progress.
 Although the incentive for each individual manufacturer to develop new technologies does not
 depend on the method  used to distribute allowances, the distribution  method does affect the
 private gains from diffusion. Under an auctioned allowance strategy, all participants would gain
 from the diffusion of low-VOC technologies in order to drive allowance prices down. This gain
 from diffusion is absent from allowance strategies in which the regulator gives allowances to
 sources. Therefore, the potential of an auction allowance strategy to promote technological
 progress is excellent.

        A potential problem with an allowance auction is a substantial adverse economic impact
 on sources because they must purchase allowances from the regulator. It is possible to devise
 revenue-neutral auctions that minimize these impacts.4  In a revenue neutral auction, all
 payments for allowances are kept within the industry; in effect, the regulator rebates payments
 for allowances.  However, these rebates lessen incentives for technological diffusion.

       In the context of this paper, cross-line averaging is another emissions trading strategy in
 which trades may only occur within a facility or company. ^  A single sales-weighted average
 VOC content limit is imposed on each source.  Thus each source's total rate of VOC usage or
 production is limited.  Unlike the emission trading strategies discussed above, cross-line
 averaging does not cap aggregate emissions. Each source is given flexibility to use or produce
 high-VOC coalings if it compensates with sufficient use or production of low-VOC coatings.  If
 a source's actual weighted average is binding, the source will have an incentive to develop low-
 VOC coatings or employ low-VOC technologies so that high-VOC coatings or technologies can
 also be used. Because  of the similarity of cross-line averaging and allowances without  interfirm
 trading, the-potential of averaging strategies to promote technological progress is  only fair.

       A potentially serious problem with cross-line averaging strategies is that sources may act
 opportunistically, defeating the environmental objective of the strategy.  For example, sources
 may sell inexpensive low-VOC coatings at reduced prices to reduce their sales-weighted average
 VOC content. If this were to occur, aggregate emissions could increase. The certainty  of
emissions reduction with this strategy is very low.
                                           214

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       All of the above emission fee and emission trading strategies work by increasing the cost
of producing or consuming VOC-containing coatings. Another approach to motivating VOC
reductions is to directly decrease the cost of developing or producing no- or low-VOC substitutes
for coatings. Two such strategies are:

       (9)  substitute product subsidies and

       (10) research grants.

       For example, subsidies could be employed to promote the development or sale of
substitutes such as coating-free surfaces. Ideally, the level of substitute product subsidies should
be directly related to expected VOC reductions.  Indirect product subsidies are also possible
through tax  credits. Lump-sum subsidies such as research grants may be easier to administer,
though they provide less certainty regarding emission reductions. Grants could directly promote
technological innovation and may also encourage technological diffusion if they  are made
contingent upon early public disclosure of new developments.

       Unlike per unit VOC reduction subsidies, subsidies to promote the development or sale of
coating substitutes (or no-VOC as opposed to low-VOC coatings) avoid entry-exit problems that
could result in long-run emission increases.  Increased profitability and entry could not result in
increased emissions if the substitute product emitted zero VOCs.  However, the problem of
funding such subsidy and grant strategies would still exist.

       Substitute product subsidies and research grants have a good to very good potential to
promote technological progress, but the certainty of emissions reduction  is very low because any
improvement occurs solely as a result of technological innovation and diffusion.  Any adverse
impact on coating manufacturers will occur as a result of the diffusion of products that reduce the
demand for coatings. Implementation costs are likely to be low to moderate;  linking subsidies to
expected VOC reductions is likely to require somewhat extensive economic and engineering
modeling.

       One way to fund substitute product subsidies and research grants  is to obtain revenues
from an emission fee or an auctioned allowance strategy [(1), (3), and (7)]. Therefore, a
combination strategy may be desirable:

       (11) combination emission fee or permit auction with no-VOC product subsidies

Such a combination VOC reduction strategy would provide the maximum incentive to develop
lower-VOC technologies. It may also encourage coating manufacturers to jointly develop and
share low-VOC technologies because technological diffusion would result in lower subsidy
payments to no-VOC competitors such as producers of surface-coating free materials.
Depending on whether the incentive is an emission fee or a marketable emission  permit, the
certainty of emissions reduction is good or excellent, respectively. The disadvantages of these
strategies are an especially great likelihood of adverse economic impacts on coating
manufacturers and high implementation costs.

       Authority for States to implement a combination strategy such as  (11) is granted by the
Clean Air Act Amendments of 1990. Section 182(g)(4)(B) explicitly states that revenues
generated by an economic incentive program may be used to provide incentives to achieve
additional emission reductions and, more specifically, may be used to encourage  the
development of lower-polluting solvents and surface coatings.

       The last strategy that we evaluate is a command-and-control strategy:

       (12) VOC content limit or technological requirement
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 Almost all the rewards that innovation and diffusion bring to sources under the other strategies
 are absent. Because these gains are minimal, a command-and-control strategy performs
 especially poorly in terms of the potential to promote technological progress.  Another
 disadvantage is the moderate to high economic impact on coating manufacturers; the impact is
 potentially substantial because sources do not have flexibility to find the least costly means of
 reducing emissions. Implementation costs are probably low because the regulator does not
 absolutely need to keep track of emissions for purposes of determining compliance. The
 emission reductions that this type of strategy can achieve are certain in the near term, but they
 will be eroded in a growing economy.

        Table 1 illustrates the numerous tradeoffs that need to be considered when selecting a
 regulatory strategy to reduce VOC emissions from surface coatings. The rankings are based on
 an "all else equal" principle and will obviously not apply in all cases. Other criteria that are
 important, such as consumer and taxpayer impacts and political feasibility, were not assessed for
 reasons of brevity.

 CONCLUSIONS

        Overall, economic incentives provide substantial advantages over command-and-control
 strategies to reduce VOC emissions from surface coatings. In general, economic incentives are
 superior with respect to minimizing aggregate expenditure on pollution control (i.e., cost-
 effectiveness) and promoting technological progress. The potential for adverse economic
 impacts on coating manufacturers tends to be lower with economic incentives. Allowance-based
 economic incentives are unique for their ability to cap emissions.

        Nevertheless, command-and-control strategies may still be preferable if monitoring,
 record-keeping, and other implementation activities are significantly less expensive than with
 economic incentives.  Hence the choice between strategies depends greatly on the size of the
 additional implementation costs associated with economic incentives.

        The "optimal" economic incentive strategy depends on the policy-makers' objectives.  If
 stimulating technological progress is considered of most importance, a combination incentive
 strategy such as (11) may work best, but this strategy could impose severe impacts on coating
 manufacturers. All of the economic incentive strategies examined in this paper lead to more
 rapid technological progress than would result from command-and-control strategies, but some
 provide more  stimulus than others. All of the economic incentive strategies lead to more cost-
 effective emission controls than would result from command-and-controi strategies, but some
 imply fees, allowance prices, or subsidies to competitors that could severely affect coating
 manufacturers. If certainty over reducing air emissions is of most importance, then emission
 trading strategies are best.  It is therefore essential that policy-makers determine objectives and
 priorities before selecting a regulatory strategy.

       Finally, in keeping with the pollution prevention approach, a full appraisal of the
 desirability of economic incentives includes an examination of the potential for unintended
 damages. The hypothetical programs examined in this paper have been narrowly focused on
 VOC emissions, but the environmental problems in manufacturing and using coatings are
 interdependent.  Narrowly defined solutions may be counterproductive when imposed on
complex problems. Intermedia transfers of pollutants could occur if reformulated products are
 more prone to off-specification manufacture or have a shorter shelf life.  Manufacturers may
reduce VOC content by substituting a noxious solvent or propellant, which could increase health
risks to workers and product users. A coating with reduced VOC content may produce a less
durable film than a higher-VOC formulation, potentially leading to increased emissions over the
life of the substrate. VOC content limits appear to be more prone to these problems than
economic incentives because limits are more likely to constrain manufacturers' product design
options. This may be another reason to prefer economic incentives over less flexible strategies.

                                           216

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                                   REFERENCES

1.  Bohm, Peter and Clifford Russell.  Comparative Analysis of Alternative Policy Instruments.
   In:  Handbook of Resource and Energy Economics, vol. 1, pp. 395-460. A. V. Kneesc and J.
   L. Sweeney, eds. Elsevier Science Publishers, Amsterdam,  1985.

2.  Freeman, A. Myrick III and Robert H. Haveman. Residuals Charges for Pollution Control:
   A Policy Evaluation. Science, 177:322-329, 1972.

3.  Milliman, Scott R. and Raymond Prince. Firm Incentives to Promote Technological Change
   in Pollution Control. Journal of Environmental Economics and Management, 17:247-265,
   1989.

4.  Hahn, Robert W. Designing Markets in Transferable Property Rights: A Practioner's Guide.
   In:  Buying a Better Environment:  Cost-Effective Regulation Through Permit Trading, pp.
   83-97. Erhard F. Joeres and Martin H. David, eds.  University of Wisconsin Press, Madison,
   Wisconsin, 1983.

5.  Carlin, Alan.  The United States Experience with Economic  Incentives to Control
   Environmental Pollution, p. 5-17. EPA-230-R-92-001, U. S. Environmental Protection
   Agency, Washington, D.C., 1992.
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218

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

            Pollution Prevention in the Wood Refinishing Industry

By:

Azita Yazdani                       &     Donna Toy-Chen
Pollution Prevention International, Inc.       HTM Office, City of Los Angeles
471 W. Lambert Road, Suite 105           City Hall, 3rd floor
Brea CA 92621                           Los Angeles CA 90012

Introduction

Pollution Prevention International, Inc. (PPI) under contract to the City of
Los Angeles conducted a pollution prevention study of the wood refinishing
industry.  PPI reviewed the common coatings processes and hazardous
material management practices utilized by this industry.  PPI evaluated
alternative water-based and low VOC coatings utilized at various facilities.
In addition, PPI conducted a workshop for the  City of Los Angeles
refinishing industry users to share the information about the alternative
technologies and new coatings systems application.

Industry Overview

The wood  refinishing industry  in Los Angeles consists of furniture and
cabinet refinishing, reupholster and repair shops.  These shops are engaged
in the repair and refinishing of household and office furniture  and fixtures
(both metal and wood), kitchen cabinets and particle boards.  Approximately
300 shops in this industry sector are licensed within the City.  The majority
of these shops are small companies with three to seven employees. In the
City of Los Angeles, only one shop employed about 60 employees and three
shops employed about 15 employees.

The industry is primarily focused in Los Angeles' furniture district, with most
shops engaged in refinishing and restoration of antiques. About ten percent
of the companies were contacted by PPI to set up site visits and review
operation and practices.

The basic refinishing steps that most of these shops followed are as
following:

1.  Remove old finish, using chemical stripping or sanding

2.  Sand, stain, (and bleach) the surface

3.  Fill the  pores
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 4. Apply sealer

 5. Add transparent or colored film coat

 A number of different chemicals are used in any of the above processes.
 These may include:

 Cleaning:   petroleum distillates, alcohol
 Stripping:   methylene chloride, acetone
 Staining:    mineral spirits, alcohol, pigments
 Painting:    toluene, glycol ethers, pigments
 Finishing:   resins, shellacs, toluene, diisocyanates
 Equipment Cleaning:      petroleum distillates, 1,1,1-trichloroethylene,
                         alcohols

 Regulatory Requirements

 There are a number of  regulatory requirements that impact this industry
 sector.  These are primarily hazardous waste and air quality requirements.

 The South Coast Air Quality Management District (SCAQMD) is responsible
 for controlling air pollution and attaining federal and state air quality
 standards in Southern California.  The regulations limit the content of
 Volatile Organic Content (VOC) of the coating or the solvents used by these
 shops.  All refinishers are required to have a permit, whether or not they
 operate a paint booth.  The annual emissions must also be reported by each
 facility.

 The SCAQMD Rule 1136 and  1171  are the two major rules that impact
 refinishing operations.   Rule 1136 limits a facility on the use of high VOC
 coatings that are used on wood products. A coating can  not be applied
 which exceeds the limits in Table 1.  The amount of coating used at the
 facility must be recorded to demonstrate  the quantity of emissions from the
 facility.

 Proper application equipment is required when applying coatings. SCAQMD
 allows for the following applications equipment:

 •     electrostatic
 •     flow coat
•     dip coat
•     high volume, low pressure (HVLP) spray
•     paint brush
•     hand roller
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 Rule 1171 regulates solvent cleaning of application equipment. The rule
 states that a cleaning solvent shall not have a VOC content greater than
 950 grams per liter of material and a VOC composite partial pressure of 35
 mm Hg or less at 20C (68F).  Common VOCs found in cleaners are methyl
 ethyl ketone and acetone. Cleaning processes allowed by Rule 1171
 includes systems that totally enclose cleaning equipment used to flush the
 part in a controlled manner.  Wipe cleaning and spray cleaning with a
 maximum container of 16 fluid ounces are also allowed.

 The refinishers have to also comply with the various regulatory requirements
 applicable to hazardous waste generators.  These requirements are not
 discussed in this paper.  It should be noted that in California there is no
 exemption for small quantity generators, thus  these facilities have to comply
 with the regulations without regard to all the  waste generated, such as
 clean-up solvents, contaminated rags and waste paint.

 Summary  of Site Tours

 Six facilities were toured  during this study to  explore the management
 practices and assess regulatory compliance status of each plant. Of these,
 four plants were actual refinishing plants. The other two were furniture
 manufacturers.

 Three of the refinishing plants visited were very small facilities.  The users
 at these facilities were for the most part not in compliance with the various
 regulatory requirements in place.  One plant utilized a spray booth without a
 permit. This plant, an antique furniture refinisher, was not willing to
 disclose many of the management practices it utilized.  For example, the
 plant generated no hazardous wastes although it engaged in stripping and
 coating of various wood,  iron, and cement parts.  Isopropyl alcohol or
 methylene chloride were used for stripping purposes.  For the most part, the
 chemical was applied on the part, then the coating was scraped off after
 some time.  The rags utilized by the workers were soaked in water after
 use. This  water is then illegally disposed down the sewer.  The rags were
 either reused or disposed  in trash. This refinisher had started experimenting
 with some water based lacquers.  He sealed the part with solvent based
 material and then sprayed water based top coatings. This plant also did not
 utilize the  required application equipment, such as HVLP guns.

The next refinisher engaged in refinishing and refurbishing of old pieces.  He
has switched to water based coating, primarily because of the look and
texture that  the water based materials gave his work. This facility did not
 restore pieces  that require the high polished lacquer look, therefore there
was no need to utilize these types of coatings. No chemical stripper was
 used at this  facility, only mechanical (hand) sanding was done.  This user.
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 had never managed any of his leftover chemicals or rags as hazardous
 waste.  He used water to clean application equipment.  The water was kept
 in a bucket then dumped on the floor to dry out. This refinisher complained
 about the SCAQMD requirements and how he did not have time to keep
 track of the paint usage records and prepare the reports required.

 The other small refinisher  visited used both water based and acrylic
 material. The facility had  a permitted spray booth and he  used conventional
 guns to coat.  He coated a mixture of old and new pieces, thus a variety of
 coating materials are used at this shop.  He did not manage any waste as
 hazardous waste although he generated  some thinner from gun cleaning and
 other cleanup operations.

 The last refinisher visited was a large job shop that engages in refinishing,
 painting, and upholstery of office and commercial clients.  This facility
 employs as many as 75 personnel at times, and  complies with the
 regulations from both air quality and hazardous wastes. This  facility had
 experimented with water based material  but found that the water based
 lacquer chips, causing problems for the customers. Also parts coated with
 this material can not be touched-up. The facility had two permitted spray
 paint booths which  utilized HVLP guns, and used gun cleaning stations to
 clean application equipment. Lacquer thinner was primarily used for this
 purpose, which is sent for disposal at a cement kiln for resources recovery.
 The filters in the booths is also disposed  as hazardous wastes. The facility
 spent as much as $15,000.00 annually to dispose of hazardous wastes.
 This facility also used stripping chemicals which  was hauled as hazardous
 waste when used and wash thinner (TCA-based) was used to clean
 equipment or dilute  coatings.  This material was  reused until no longer
 useful.

 Two finishers were  also visited,  one small and one large. The large facility
 mass produces furniture using 50 tons of coatings per year. The furniture
 was put together, sanded, and finished on an assembly line process.  The
 fastening and sanding was done by hand power tools. The finishing was
 completed on the assembly line, in the open air, with air assisted airless
 spray guns.  Two applications of clear coat solvent-based lacquer were
 applied in most cases, within ten minutes of each other. In one hour, the
 piece of furniture was boxed and ready to go.

The second finisher  visited produces high quality, custom furniture.  It
designs and formulates its  own coatings. All of the furniture is also
fabricated at the shop.  The furniture is put together, sanded, and then
finished.  The finish  is applied by HVLP spray guns in a spray booth.  The
finish is one thick coat application of an opaque solvent based coating.  The
coated piece is then cured  for several hours in a "clean room".  The results

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 are high quality flawless rock hard coatings.  This facility uses less than 4
 tons of coatings per year.

 Study Findings

 The majority of the facilities visited were small quantity hazardous materials
 users and waste generators and were in violation of basic regulatory
 requirements for air quality, hazardous waste, and hazardous materials
 management.

 Most users were not familiar with the regulatory requirements governing
 their industry, and did not have the necessary permits to  operate their
 business.  PPI also  found that most of the facilities had problems with
 record keeping and calculations that needed to be conducted on a daily
 basis to comply with the SCAQMD rules and regulations.

 The impact of air quality regulations on the industry is most significant.  The
 SCAQMD rules  are  primarily written for larger furniture manufacturing and
 coating facilities and the regulatory requirements for smaller users is
 cumbersome.

 All refinishers except the largest refinishing facility did not meet hazardous
 waste management requirements , including hazardous waste disposal,
 manifesting, and generator requirements.

 Pollution Prevention Techniques and Technologies

 As mentioned earlier, the majority of the users participated during the study
 had major problems with the application and implementation of the
 regulatory requirements. However, the various pollution prevention
 techniques were reviewed and discussed during facility visits, so users will
 become familiar with the requirements. The following is a summary of the
 various pollution prevention opportunities that were identified for this
 industry sector.

 EQUIPMENT MODIFICATIONS

There are a number of new equipment technologies that can be utilized by
 the paint and coating users to reduce paint usage and overspray.  One type
 of technology that has become widely utilized in recent years is the High
 Volume Low Pressure paint gun systems.  These systems  allow the use  of
 low pressure airstream at high pressure to propel coating at the transfer
 efficiency of 65-95  percent. This type of technology has  been widely used
 in the wood industry in the recent years.
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 ALTERNATIVE COATINGS

 There are a number of alternative materials and processes that are used
 throughout the wood  industry. These coatings are reviewed below:

 Waterborne Coatings - Waterborne coatings are used in some sectors of the
 wood industry with documented success. This type of coating contains low
 VOC so is favored by  the air regulatory agencies.  The slower drying time is
 sometimes a concern for users with high volume production. The water
 borne material may also raise some wood surfaces, requiring extra sanding
 and preparation steps. Some VOC solvents are normally used in these
 formulations, however, the low VOC concentrations is still an advantage
 over conventional coatings. Commonly, electrostatic application equipment
 is recommended for high volume spray application.

 High Solids Coatings - These coatings contain as much as 30 percent
 solvent and up to 55 percent solids by volume.  Although these coatings are
 low in VOC, they have high viscosity and applications with spray equipment
 is more difficult.  The high solids content of these  coatings require high
 drying time, resulting in shorter pot life.  The application equipment must be
 routinely maintained.  Paint "Orange" peeling and solvent popping are also
 some of the problems  of these coatings.  The use of these  types of coatings
 in wood industry is limited.

 UV and IR Curable Coatings • These coatings are used in less than 5 percent
 of the wood refinishing market due to the cost of the equipment and
 limitations for uses such as refinishing.  The transfer efficiency of these
 coatings is 95 to 98 percent, and they contain no solvent.  The
 conventional spray equipment can not be used for  the application of this
 technology.

 Study Conclusions

 PPI and the City of Los Angeles concluded that small facilities engaged in
 this industry sector have to comply with regulations that are too complex
 and time-consuming for a small facility. The industry will respond to a
 regulatory assistance program that does not prevent these small businesses
 from running their day-to-day operations and will assist them in complying
 with the maze of regulations. The City of Los Angeles has considered
 making the following recommendations to the SCAQMD to assist the
 refinishing industry to comply with the requirements:

«     Exempt this industry sector from all record keeping and reporting
      requirements for air  quality regulations;
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Increase transfer of information between industry and developers of
technologies; ar\d

Mobilize industry to interface with regulatory agencies and regulators.
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         TABLE 1
Current VOC Emissions Limit
   Rulell36 (August 1991)
VOC LIMITS
Grams Per Liter of Coating,
Less Water and Less Exempt Compounds
ON AND AFTER
7/1/94
COATING
Clear topcoats
Filler
High-Solid Stains
Non-glaze
Glaze
Inks
Mold-Seal Coating
Multi-Colored Coaling
Pigmented Coating
Sealer
Strippers
Low-Solids Stains
Toner, or Washcoat
(e/L)
550
500

700
700
500
750
685
600
550
350

480
(Ib/gal)
(4.6)
(4.2)

(5.8)
(5.8)
(4.2)
(6.3)
(5.7)
(5.0)
(4.6)
(2.9)

(4.0)
(g'D
275
500

700
700
500
750
275
275
550
350

480
flb/eal)
(2.3)
(4-2)

(5.8)
(5.8)
(4-2)
(6.3)
(2.3)
(2.3)
(4.6)
(2.9)

(4.0)
ON AND AFTER
7/196
(E/L)
275
275

240
240
500
750
275
275
240
350

120
(Ib'Eal)
(2.3)
(23)

(2.0)
(2.0)
(*-2)
(6.3)
(13)
(2.3)
C.Oj
12.9)

(1.0)
       226

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency.  The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)
            The Importance of Product Stewardship and
                   Its Impact on Pollution Prevention
Richard S. Sayad
The Dow Chemical Company
1320 Waldo Road. Suite 342
Midland, MI 43640


       Product Stewardship can be an important factor in helping businesses maintain that their products
are being used safely by workers who handle the products, from the time they are shipped to the time they
are disposed. Committing the time and effort now to a Product Stewardship Program is an essential invest-
ment in the future of our industry.

       Experience suggests that many organizations haven't had the opportunity to completely explore the
positive impact Product Stewardship — throughout the whole life cycle of the product — could have on its
business as well as its customers. And they haven't had the opportunity to develop programs with and for
customers. The following information will help explain Product Stewardship throughout the life cycle of the
product, how it works, the responsibilities involved and the benefits.
                                          227

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THE MEANING OF PRODUCT STEWARDSHIP

        Product Stewardship is more than just a program. Most programs have a beginning and an end.
Rather, Product Stewardship is an ongoing process — a continuous activity that is used to: (1) obtain the
proper health, environmental and safety data for our products: (2) evaluate uses and (3) take appropriate
steps to protect human health, safety and the environment. This last statement especially, take appropriate
steps to protect human health, safety and the environment is the correlation between Product
Stewardship and pollution prevention. Pollution is one of the causes leading to an unhealthy environment
and environmental concern. Preventing pollution is an element of Product Stewardship — a way to lake
action to keep the earth safe and healthy for future generations.

        Basically, Product Stewardship is an investment of resources, time, and capabilities. It's knowing
the full capability of our products and explaining those capabilities to the users. It's conducting the various
safety tests and providing notification through material safety data sheets and proper labeling. Product
Stewardship is more than a commitment to develop data for the safety of our products and our customers.
It's a commitment to help customers understand our products and how to use them. To work with them so
they can help themselves.


THE RESPONSIBILITY AND COMMITMENTTO PRODUCT STEWARDSHIP

       You  may be thinking to yourself right now. "I wish it were just a program, never-ending sounds
awfully time consuming — and expensive." Well, you may be right in one respect — it is a major commit-
ment. Should you choose to embark on the path to Product Stewardship, it will become a continuous
process. But over time, you are likely to stop thinking of it as a "never-ending program" and begin seeing
it as a belter way of doing business.
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 Who Is Responsible?
        The responsibility of Product Stewardship is covered throughout the whole product life-cycle as
 explained in the "Codes of Management Practices and Product Life Cycle" chart. This chart is part of a
 program called Responsible Care® — the CM A (Chemical Manufacturers Association) initiative developed
 to respond to the questions and concerns of the public surrounding our industry. The aim of Responsible
 Care is to respond to the public through improved performance in health, safety and environmental quality.
 It is not a public relations program, but rather a performance-based program that requires constant interac-
 tion with the public, the government, employees, and every other person affected by our industry. While
 Product Stewardship is a code in the Responsible Care Program, Product Stewardship is apparent in all the
 codes of management practices.

        You 11 notice in the chart below that Product Stewardship is considered in each area of the product
 life cycle, from design to disposal. That means Product Stewardship responsibility lies with each and every
 employee along the life cycle of the product

 Codes of Management Practices and Product Life Cycle
      CODES OF
    MANAGEMENT
      PRACTICES
f
                                                     INCEPTION
                            Design    Develop
 PRODUCT LIFE CYCLE
Manufacture Transport      Sell
                                               Use
                                                        DlS|K>>C
  Community Awareness &
    Emergency Response
       Process Safety
        Distribution
      Employee Health
         and Safety
     Pollution Prevention
    Product Stewardship
                                                         ii
       Product Stewardship requires a total team effort Marketing, Research and Development, Manufac-
turing. Quality Assurance and Distribution all must work together to provide the necessary commitment.
support and resources for the Product Stewardship activities of each product For example. Marketing
furnishes customers and distributors with appropriate information to promote proper handling, use and
storage of products. This information allows employees, customers and distributors to determine use
limitations that may involve human or environmental hazards and to work with producers to address these
issues through modifications to products and their uses.
                                               229

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         Research and Development is responsible for conducting needed tests at each stage of product
 development to look for potential hazards. They also develop applications that permit the handling, use and
 disposal of products without creating an unacceptable level of risk. By providing information to production.
 distribution and marketing—employees, distributors and customers can learn proper product usage. R&D
 also re-evaluates the need for additional health, environmental and safety information as technology and
 regulations change.

         Manufacturing reviews product specifications and assures that the work environment is considered
 when plants are designed, operating practices developed, processes changed and employees trained. They
 also inform employees about the product's physical make-up and consequences of overexposure. Manufac-
 turing is also responsible for obtaining health information on products from suppliers. They furnish contrac-
 tors with exposure guidelines, proper handling, use and disposal of products. It's also their job  to adhere to
 pollution control and industrial hygiene standards and respond to local health and environmental concerns.

         Quality Assurance is responsible for exactly that — assuring the quality of products and services
 and that the products are well documented and labeled in compliance with regulations. They also audit the
 performance of systems and processes to monitor conformance of policies and provide technical assistance
 in quality improvement programs.

         Distribution determines that appropriate steps are taken to protect persons, property and environ-
 ment while products are being transported and stored. They select the proper containers for distribution and
 the proper carriers, warehouses and terminals to perform distribution functions.

        It's crucial to a good Product Stewardship program that each function of the product  life cycle work
 together. It is a total team effort to pull together — and basically, it's a commitment among those functions to
 help develop the needed data and to work with customers to support the safe use of our products.

        Let me give you a good example of commitment to Product Stewardship in a Research & Develop-
 ment function. Well call the product steward in this example Carl. A major part of his job is Product Steward-
 ship for aJK/l chloride and epichlorohydrin. When Carl was introducing Product Stewardship procedures to
 his customers, he ran into an awkward situation. A medium-sized chemical company in the Midwest ordered
 its first shipment of alryl chloride and Carl insisted on visiting the customer and inspecting^he safety facili-
 ties before the shipment was delivered. Upon inspecting the facilities, it was discovered that the company
 didn't have safety showers within 25 feet of the delivery area. The customer promised the showers would be
 installed at a later date. But for safety's sake, the product steward insisted that the showers be installed
 before the delivery or the shipment would be stopped. Naturally, the customer was angry — at first. Then he
 realized that the product steward was putting the safety of his customers before the company's profit He saw
 Carl in a whole new light

        Let me give you another example of commitment to Product Stewardship and customers. A product
 steward introduced his customers to a new innovation called a dry disconnect valve designed  for the safe
 handling of altyl chloride and epichlorohydrin. When using this valve, only a few drops of the  chemical
would be lost from the hose during a tank truck unloading — as opposed to losing as much as a gallon with
some conventional unloading systems. Again, customers were skeptical. They didn't think the valve would
make a difference. After the first "dry run" testing of the valve at an unloading site, those skeptics became
believers — very appreciative believers. This is just one example of how Product Stewardship is a means to
prevent pollution.
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THE BENEFITS OF PRODUCT STEWARDSHIP

        Product Stewardship Programs can. if properly organized, protect people and the environment
through pollution prevention, waste reduction and safety procedures. If each employee is dedicated to the
Product Stewardship Program for their products, workers will be safer, chances of exposure and accidents
may decrease and emissions may decrease.

        Product Stewardship also helps protect products from misuse. As mentioned earlier, pan of the
program includes proper and specific labeling and handling instructions — and sometimes a trip to the
customer's location to review storage, safety and even disposal facilities. Al! of these are good methods for
preventing not only pollution, but misuse of the product. When products are being used accurately and
according to your Product Stewardship program, chances of liability and exposure to adverse publicity are
greatly reduced.


THE PROVISIONS OF PRODUCT STEWARDSHIP

        Product Stewardship can help show an increase in product safety and assessment It promotes
proper use of products and provides adequate and dear warnings that customers should be aware of. If your
company currently has a Product Stewardship program, but it's basically internal, perhaps you may want to
extend it to your customers. This means notifying customers of any new hazard findings either from the
environmental, TOX or use standpoint — and giving customers various forms of information  to help them
with product disposal problems. In some cases, it may even mean prohibiting the use of your products in
certain applications.


Customer Support

       After customers learn what we're trying to accomplish through Product Stewardship and that it
promotes their safety, we've found them to be overwhelmingly supportive. Customers do read and appreci-
ate the safety and handling information. And they're always looking for information about regulatory and
compliance issues. Regulatory information isn't always easy to understand and customers appreciate the
help in addressing its requirements. Understanding of the regulations allows customers to more easily
incorporate changes into their everyday processes — changes that keep them in regulatory compliance,
prevent pollution and control waste.
                                               231

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 PRODUCT STEWARDS

         Ideally, every product manufactured should have a product steward to follow the use and distribu-
 tion of that product Product stewards are expected to be experts on the chemicals they are responsible for.

 Responsibilities

   Product Stewards are also expected to:
 • teach others about chemicals
 • respond to emergencies
 • know and interpret material safety data sheets and labels
 • review customer facilities
 • give technical information
 • know the laws and regulations for their chemicals
 • help customers address product handling deficiencies
 • evaluate customer uses of the product and consider potential risk
 • participate in product safety reviews (PSRs), and
 • know and work with resource specialists — TOX, environmental, industrial hygiene
 Knowledge Required

        It's important that product stewards keep up with significant new information and communicate it to
 customers. It's also their responsibility to provide health and safety information on their product That may
 mean training internal employees or customers about the product Product stewards need to be aware of the
 ongoing evaluation of the use. storage and disposal of products: if there will be future stewardship require-
 ments or additions placed on that program. They also must communicate changes in brochures, literature or
 technical data sheets, help in the evaluation of the regulatory impact and initiate corrective actions.

        In addition, product stewards need to know about the chemical physical and biological properties of
 the product They must know the mode of distribution into commerce, whether direct or through a distribu-
 tor, and whether it's a mixed shipment Customer storage facilities must be adequate. Product stewards
 should know of other materials in storage and their location. It's also important that they know how the
 product will be used by the customer. Are the customers considered high- or tow-technology companies?
 And what will be needed to help mem use your products safely? What about disposal? How much of the
 material is unused? Is it localized or general? If they incinerate, which products? Are there any recycling or
 reclamation programs in effect? What programs are available for correct disposal? A product steward must
 know answers to aO of these questions to better help employees and the customer.
Customer Assistance

       The amount of assistance a product steward may give a customer depends on the sophistication of
the customers and the hazard properties of the product Some product stewards will devote 5% of their
stewardship responsibilities, some will give 25% of their time and some will give 100% of their time. It just
depends on the nature of their product the uses, and the customer base they support.
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        Product safety reviews should be an active part of your Product Stewardship program. Each product
 should go through a product safety review to ensure that appropriate steps are being taken to protect
 employees, public health and the environment The product steward would help organize and conduct the
 review process, which includes manufacturing, marketing, legal and toxicology. These reviews can be done
 in various stages of product development and, certainly, if an unexpected incident arises or if new data
 comes along that affects health and the environment.

        A Product Stewardship program can offer customer support and assistance in the form of industrial
 hygiene surveys; safety training using literature, posters, usage presentations arid videos; and discussions on
 material safety data sheets. You can also provide information on loading and unloading of the product, waste
 reduction, reclamation,  and disposal and regulatory assistance. All of this information will help your custom-
 ers learn to use your products safely and effectively.

        At Dow, we've had over 20 years to refine our procedures and support programs. Continuous
 improvement is a daily occurrence Your Product Stewardship program doesn't have to be this in-depth. It
 can and will develop as your needs grow and as your company sees the benefits from Product Stewardship.


 HOW TO ENCOURAGE EMPLOYEES TO COMMIT TO A PRODUCT
 STEWARDSHIP PROGRAM


        As mentioned, some companies may have Product Stewardship programs in different stages of
 development. That's great. The point is, everybody should have some type of a Product Stewardship pro-
 gram — for the good of your company, your customers and the environment.

        Incorporating a program into your company will help prevent pollution, reduce waste, assist in
 regulatory compliance and possibly increase business. But how do you get your employees to buy into it?
 After all, the success of a Product Stewardship program relies heavily on employee commitment and partici-
 pation. One method we used to get employees interested involves a new waste reduction program called
 WRAP — which is an acronym for Waste Reduction Always Pays. WRAP has five goals:

 1. reduce waste to the environment
 2. recognize excellence
 3. enhance waste reduction mentality
 4. measure and track progress, and
 5. reduce long-term cost.

        Each of our manufacturing divisions is responsible for the development and implementation of the
 WRAP program within its own operations. This allows each division the flexibility to tailor the program to
 specific needs. Each division is also responsible to encourage employees to take a proactive role in reducing
waste and committing to continuous improvement through Product Stewardship. Encouragement methods
used include idea-generating contests, utilization of quality performance techniques, plant waste reduction
reviews, recognition/reward programs and even the development and communication of top ten generator
lists for waste and emissions at a division.
                                              233

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         Waste data — which includes emissions — is collected across all media, by process, at a facility. A
 ratio of waste versus production is then calculated to account for production variances. The waste ratio or
 index can be tracked and evaluated by each facility. The program flow chart lists the steps taken in the
 WRAP process to achieve continuous improvement
                           I* R () (J R A -M     F I. O XV    CHAR T
                                   Communicate
                        i   Track IVogress
                        I   and Report
                          Implement
                          Actions
                                                            Inventory Losses
                                                                  Identify
                                                                  Sourcrs
                                          CONTINUOUS
                                         IMPROVEMENT /^/  Priori*»
                                                         Establish Goals
                                 Allocate Resources
        Each plant is asked to develop an inventory of its waste streams that may affect the air, water or
 land. Specific waste streams are identified and researched as to how they are produced by the process. They
 are then prioritized for further investigation and action based on volume and toxicity concerns. Tracking
 progress is fundamental in monitoring the impact of the plant's efforts. It also allows the facility to communi-
 cate its performance to employees and the community.

        S'nce 1974, our plants in the U.S. have cut air emissions by more than 85 percent And we continue
 to strive for further improvements. Although waste reduction sometimes requires capital improvements such
 as new equipment and upgraded facilities — many of the waste reduction projects have ended up saving us
 money. We've saved money on feedstock costs, waste treatment and on landfill costs. And in many cases,
 we've also increased productivity and improved product quality.
Examples of How WRAP Works

        Here are a few examples of how successful our WRAP program has been. In one department for
films, a waste reduction team identified ways to improve the manufacture of barrier films through source
reduction and improved quality control The team made equipment modifications including: modification to a
film winder for operation consistency, which reduced the amount of rejected material; new gauging equip-
ment to minimize thickness variation, which further reduced film rejection; new monitoring equipment to
ensure that the resin is not overheated and therefore unusable; and a new roU-and-trim grinding system was
installed to make pellets out of scrap material The recycled product can be sold to recycle customers. The
results yielded a 400,000 pound a year reduction in materials going to landfills, and a cost savings of $100,000
a year. The addition of the roll grinding system reduced landfill material by 100,000 pounds a year, at a
savings of $30,000 a year.
                                                234

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        At one of our plants, a waste reduction team identified an opportunity to reduce CFC emissions from
the manufacturing of membranes. These membranes are used in water purification systems and other
systems that remove water from substances such as cheese. The team implemented a number of changes
and modifications. Distillation equipment was installed to purify and recover unused liquid CFC from the
process and a carbon absorptive system was installed to collect the CFC vapors, which were then sent back
to the distillation equipment In addition, specialized equipment was installed to remove water from the
recovered CFC so it could be reused. Later, neutralizing and collection tanks were installed to reclaim more
CFC for reuse and existing equipment was upgraded to improve process controls.
CFC Emissions


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86 »7 88 89 90
       As a result of these waste reduction steps, the plant reduced the amount of CFC emissions by 87
percent since 1986, saving over $1.6 million. Also, membrane production more than tripled over that same
time period.
                                              235

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 CONCLUSION

        The examples I've given are part of our WRAP program, which is part of our Product Stewardship
 program. We've been working toward improving our operations for years—and that's basically how the
 Product Stewardship program evolved. Product Stewardship has also helped us comply with government
 and EPA regulations. For example, through our commitment to Product Stewardship, we were anxious to
 participate in the EPA's 33/50 program. The 33/50 program is the EPA's voluntary pollution prevention
 initiative to reduce national pollution releases and off-site transfers by 50% in 1995. The interim goal was to
 reduce releases by 33% in 1992. With a strong Product Stewardship Program in operation, sometimes we're
 in compliance before the regulations are even issued. That's just better for everyone.

        To dose, I'd like to emphasize the importance of Product Stewardship to your company, to your
 customers and to our earth. If we don't commit now to pollution prevention, waste reduction and recycling
 — all aspects of Product Stewardship — then we can expect a more expensive and harsh commitment in the
 future. Now is the time to make the investments needed to ensure that future generations will continue to
 use our products — safely and effectively.

        Experience has shown that customers want to do the right thing. They use safely information and
 want to comply with regulations. As suppliers of these products, it's our responsibility to help our customers
 understand the regulations and how to comply with them. That's Product Stewardship — an investment of
 our resources, our time, and our capabilities in the whole product  life cycle. It's knowing the full capability
 of our products and explaining those capabilities to the users.

        Conferences like the Pollution Prevention Conference give us the opportunity to cooperate, learn
 from and work with each other as an industry. We have the opportunity to discuss regulations and compli-
ance so we can take a proactive approach to making our businesses as safe as they can be — for our work-
ers, our customers, our communities and our Environment.
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                            SESSION 6
                     INORGANIC COATINGS
                         PAPERS PRESENTED:

    "Long-Term Corrosion Protection with Single-Coat, High-Ratio Zinc Silicate"
                                   by
                            Parke Schaffer, Jr.
                         Inorganic Coatings, Inc.
                           Malvern, Pennsylvania

            'Two Surprises from Inorganic Zinc-Rich Silicate Coating
            A reactive semiconductor approach to surface protection"
                                   by
                           C. William Anderson
                     Marine Environmental Research
                       Morehead City, North Carolina

"A New Inorganic Coating for Magnesium Alloys with Superior Corrosion Resistance"
                                   by
                              Alex J. Zozulin
                    Technology Applications Group, Inc.
                         Grand Forks, North Dakota
                                  and
                             Duane E. Bartak
                       University of Northern Iowa
                            Cedar Falls, Iowa

         "Inorganic Chemistry as  an Option for Formulating High Solids,
     Low- and Zero-VOC Architectural, and Industrial Maintenance Coatings"
                                   by
                            Christine Stanley
                           Raymond E. Foscante
                                Ameron
                        Protective Coatings Division
                             Brea, California
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 (The work described in this paper was not funded by the U.S. Environmental
 Protection Agency. The contents do not necessarily reflect the views of the Agency
 and no official endorsement should be inferred.)
 Lone Term Corrosion Protection with Single-Coat High-Ratio Zinc Silicate
                                            Parke Schaffer, Jr. (Inorganic Coating, Inc.)

   Today I will be talking about water-based zinc silicate, follow its evolution from the early
 1940's to the present; the evolution from post-cure and self-cure products to the no-cure high-
 ratio, NASA formula that is available today.

    Water-base zinc silicates were first developed back in the 1930's, but the first large
 commercial application was in 1942 on the Wyalla pipeline — a 250-mile pipeline stretching from
 Wyalla to Morgan in Australia. The pipeline runs through the desert, through salt marshes and
 along the coast within a few yards of the ocean. After 48 years of exposure, a single 3 mil coat of
 water-base zinc silicate is still protecting the pipe with no sign of breakdown.

    That first application of zinc silicate in 1942 had a unique curing process. The product was
 applied and then baked at about 450°F to cure out the alkali metal that is present in all silicates.
 In the early  1950's, the product was brought to this country and a post-cure acid wash was
developed to cure or neutralize the alkali.

    (The following slides detail long  term applications of post-cure and self-cure zinc silicates.)

    In order to understand how any coating could protect steel permanently, it is important to
understand the basic corrosion process on steel.

                          •
(The following is a discussion with slides, detailing the corrosion process on steel.)
    There are three basic ways to stop corrosion:
    1.  With organic barrier coatings such as epoxy, urethane, acrylic, vinyl, etc. Barrier coatings
       adhere by means of a mechanical bond (vs a chemical bond) and because they are
       organic, break down over  time.
    2.  By galvanizing or metalizing with pure zinc metal applied to the steel surface. A pure
      zinc coating protects by setting up a new anode/cathode relationship with the steel acting
      as the cathode and the zinc sacrificing as the anode. In mild environments this sacrificial
      method may last 40 years, however, in an extreme acid rain, road salt or marine environ-
      ment, the zinc will sacrifice rapidly. When the zinc is depleted, corrosion will begin.

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     3.  Or a third means of controlling corrosion is by applying a single coat of water-base zinc
        silicate. Both the above principles are at work with zinc silicate since it first acts galvani-
        cally or sacrifically and finally becomes a permanent barrier coating. Here's how it
        works:

         Zinc silicate is 90 percent zinc and 10 percent silicate or liquid glass with the active com-
         ponant being SiC^ or silicone dioxide.  SiC^ has the unique capability to chemically
         complex with metal.  The 90 percent zinc content initially sets up the same anode/
         cathode relationship as in galvanizing but with one major difference. The zinc oxides
         formed  by the sacrificing zinc continue to react with the SiC^ while filling the pores in
         the porous film. Over time, the oxides form an extremely dense hard coating  that ulti-
         mately seals off to become a permanent barrier coating. Why permanent?  Because the
         backbone of the coating is ceramic, or glass ,or SK^, that is chemically bonded
         to the iron on the surface (over 2000 PS I).  It does not break down over time.

    (Many slides — graphics and actual cross sections — will be shown to  illustrate all of the
 above; other slides will illustrate the self-healing properties of zinc silicates.)

    So far, we have seen how generic zinc silicates protect steel and while all zinc silicates work
 in the same way, there has been a definite evolution in silicate chemistry that has allowed quality
 and production advantages.

    In order to understand the evolution from low ratio post-cure and self-cure to high-ratio no-
cure, you must understand the basic chemistry of alkali metal silicates.  (Slides will aid in the
following discussion.) Water-base zinc silicates are, very simply, silicate  and zinc. And silicate
is liquid glass. The question has been asked many times, "How is it possible to make glass into a
liquid since glass is insoluble?" Chemically, SiC^ and water will not react and might  be
illustrated by:  SK^ II ^0. However, if you will recall, early in this discussion I mentioned that
SiO2 reacts chemically with metal - so if we can identify a metal that holds or reacts with water,
we could bridge the SiC^ and ^O. The alkali metals, sodium (Na) potassium (K) and lithuim
                                           240

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 (Li), do react with water and Si02.  So an alkali metal silicate looks like this, SiO^^O^O •-
 the potassium is holding the water and reacting with SiO2 to form a stable liquid glass. That is as
 long as the ratio of SiO2 to K2O does not go above 3.75:1.

     After application of a standard ratio (3.75:1) zinc silicate, it's the alkali that must be cured
 out of the zinc silicate film. The solublizing agent must be removed  by one of three curing
 methods: high temperature or baking, acid wash port-cure, or long term self-cure.  It is this
 curing requirement that has kept water-base zinc silicates in a small niche market. In the early
 1970's, NASA undertook a program to solve the curing problems and take advantage of the
 chemistry's permanent protection.

     NASA found a way to  raise the ratio from 3.75:1 up to 5.3:1 -- in other words, they found a
 way to remove the potassium metal before it goes in the pail, while maintaining the stability of
 the high-ratio liquid glass.  So the curing process for high-ratio zinc silicate is simply evaporation
 of the water. As the water evaporates, the high-ratio film becomes insoluble and extremely hard
 and adhesive reaching 1000 PSI pull strength in just two hours.

    The high-ratio chemistry now allows the easy application of a water-base zinc silicate
 without a post-cure or indeterminate, lengthy self-cure. Additional advantages include:
        recoatable with itself for additional millage or easy repair,
        self-inspecting over organic contamination;
        mudcrack and overspray resistant up to 6-8 mils DFT;
        topcoat with epoxy, acrylic, etc. in two hours or less;
        zero VOC's, no fire hazard, no toxic chemical waste;
        unbeatable economics, both short and long term.

    (Following will be slides detailing long term and application case histories which illustrate
the permanence and above advantages.)

    The high-ratio zinc silicate NASA formula provides permanent protection with just a single
coat.  Permanent protection, coupled with the advantages above, offer short and long term
economics that are beyond comparison with any coating chemistry  that has come before.  High-
ratio zinc  silicate chemistry is destined to become the world standard in corrosion protection for
steel.

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242

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  (The work described in this paper was not funded by the U.S. Environmental Protection
  Agency. The contents do not necessarily reflect the views of the Agency and no official
  endorsement should be inferred.)

TWO SURPRISES FROM INORGANIC ZINC-RICH SILICATE COATING
A reactive semiconductor approach to surface protection

C. William Anderson
Marine Environmental Research
P.O. Drawer 767
Morehead City, North Carolina 28557

Introduction

       Much of the information we are seeing at this symposium revolves around the utility of Zn rich
coatings.   Marine Environmental Research (MER) has been examining these coatings as the material
component in a surface protective system  applicable to both marine and land based needs.  The non-
material  component of this system is electrical.   The way these two  components interact and the
surprising results are addressed  in this paper.
       Pushing an object through a fluid seems a simple enough system to model.  It is simple until an
attempt is made to do so. Recent Americas Cup races have been decided on the basis of who has the best
modeling software.  Military and commercial operations spend a great deal of effort approaching this
problem.   In general, the resistance to pushing objects through water can be treated as having two
components: static and frictional.  Static resistance is predominantly a function of the shape of the vessel
and is most important at higher velocities (surprise).  Frictional resistance is determined largely by the
"roughness" of the vessel hull surfaces.  How important this can be is shown in figure 1.
       These diagrams show that is possible to quickly require increased fuel burning just to  keep the
same speed.  Since shipping is based on meeting timetables and not consumption tables, biofouling that
results in an  increased  roughness of vessel surfaces  is a major concern of marine traders.  Power
requirements rise, vessel ranges drop and the new limitations hinder commerce and defense. Over the
years, methods have been put forth to keep fouling to a minimum.
       Efforts at keeping the hulls clean  include scraping and antifouling coatings. The antifouling
coatings have included copper, tar/pitch, coatings with toxic components and coatings that are  ablative,
hard or slippery(l). Figure 2 shows this schematically. None of the existing systems are suitable for
large scale commercial applications for reasons of cost, environmental concern or longevity.

Body

         Since the interface between any  surface  and ion containing solution (like seawater) has an
inherently electrochemical character, it made sense to examine an antifouling approach that utilized both
electrical and chemical properties of this interface (see figure 3). William J. Riffe began a  series of field
and laboratory experiments  combining conducting or ionic coatings and impressed electrical signals.
After a decade of constant experimentation, he had found an incredibly effective antifouling system:
inorganic Zn rich paint and pulsed electrical signals.
       The MER antifouling system consists of two components: a Zn rich inorganic coating and an
electrical signal.  The Zn rich coating is applied to the surface utilizing common application technology.
A coating thickness of a few mils is sufficient and can be conveniently applied in one or two passes by
a single operator  with minimal time between coats.  The lack of volatile solvents or other transference
agents reduces the occupational and environmental impact of application. Low Zn leach rates both extend
the useful  life and  lower environmental concerns while the system is in use.  Several of the physical
properties of the inorganic Zn coating component of the MER system are those expected of the coating
itself.   The color,  hardness and  surface smoothness  of  the coating are just what is  expected for
comparable inorganic zinc coatings. The behavior of the coating changes substantially under the influence

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of electrical modulation, though.
        The electrochemical component of the MER antifouling system is the non-classical approach to
the antifouling problem.  Zn rich inorganic coatings have significant conductivity and can be thought of
as a complex  and heterogeneous electrode surface.  An applied potential of appropriate value is able to
allow  the  controlled release  of Zn2"1" ions  into the solution immediately in contact  with the  coated
substrate.  Milliseconds later, reversing the electrochemical perturbation results in the replating of the
Zn2+  ions as  Zn° back in the coating where it originated.  Replating efficiencies for metal  ions stripped
from 7 micron diameter electrodes (the diameter  of the  average dust particle  in our formulation) in
potential pulse experiments can rise over 99.95%   This  results  in  virtually no net loss  of Zn to  the
surrounding solution, yet allows some Zn ions to be present in the solution just at the surface at intervals
sufficiently frequent to deter barnacle larvae and other species from adhering to the underlying substrate.
This represents a major advance in antifouling  technology from cost,  application, environmental and
longevity standpoints.
        When evaluating the  electrical/electrochemical  component  of this system, several  questions
became evident.  While the first experiments were able to produce  a significant antifouling system, it
wasn't clear what the pertinent electrochemical variables were.  If you are trying to optimize a process,
it is reasonable to have a clue about what variables you wish to adjust.  A series of experiments were
undertaken to determine if current, charge, potential or frequency were the principal electrical parameters.
        The initial suspicion was that the charge placed on the surface of the coated  surface was the
principal antifouling action factor.  The understanding of the solution-electrode interface given by the
Gouy-Chapman-Stern etc. models revolves around  the capacitive and faradaic behavior of the interface
(2). Electrons present on the surface of a conductor with insufficient energy to be transferred to orbitals
on  solution species will still attract cations in the solution. These cations then form a layer of charge
adjacent to the conductor.  These two layers of charge form a capacitor.  Counterions extend further into
the solution.  This series of charges and ions is called the electrochemical double layer and gives the
electrode-solution interface many of its observed properties.
        The first  significant event in the process of attachment of biofoulants to a surface involves a
"glue" protein, a charged polymer produced by fouling organisms.  Macromolecular charges play a
significant role in their structure, migration and orientation with respect to other substances.Since ionic
interactions can be critical in the establishment of an attachment of biological species to surfaces, it made
sense  to attempt  to modulate the charged double-layer in hopes of  disrupting the "glue"  - surface
attraction,  thereby creating a  deterrent to biofoulants.  The first experiments  were conducted with a
current path directed between the vessel hull, through the Zn coating  to external anodes, cathodes or the
surrounding ocean.  Examination of the current-charge transients for potential pulses showed very small
current passage through the coating and a dominance of capacitive over faradaic charge transfer.  That
finding had two implications.  Any redox processes that resulted in mass transfer between phases were
minor  and the capacitive component of the interface was important.
        Upon examining the antifouling mechanism, it became clear that the Zn had profound effects on
larval  metabolism (especially  on the glue production) in  barnacles and that the nature of the applied
electrical pulse sequence changed both antifouling characteristics and the current time transients. Surfaces
coated with the inorganic Zn coating and subjected to a pulsed electrical signal remained largely free from
hard fouling and those few barnacles that were able  to attach to the surface were so loosely held that they
could be swept off with a wipe by a hand.   The inorganic Zn coating appeared to have some  "odd"
capacitive  behavior, as  well.
        By coupling the coating  (ca 90% Zn,ZnO and  10% silicate binder) with an  electrical  pulse,
significant antifouling capability is produced that can last for years in service. The current requirement
for antifouling action is minuscule: 100 foot long vessels require only standard car battery sized supplies,
for example.  Vessels, even stationary in the docks, remain largely free of hard fouling for years.  Those
few barnacles that do manage to stick are held so loosely that a swipe of the hand will dislodge them.

                                              244

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A Test

These findings were brought together and tested on a system where fouling was becoming a significant
problem: electrical power plants. Zebra mussels and other biofoulants were beginning to clog even the
huge heat exchanger water supply "pipes". Shut down and cleaning the heat exchangers can be incredibly
costly, upwards of $1 million per day, simply on the basis of lost generating capacity.  As a part of a
major study of potential antifouling coatings, Drs. Leitch and Puzzuoli at Ontario Hydro examined the
MER inorganic Zn system (3) and thirteen other coatings for their antifouling characteristics against zebra
mussels. When the MER inorganic Zn system was installed on a set of flags (coupons or panels) near
power plant heat exchanger intakes, protection against zebra mussel biofouling was provided. Two years
later, the remaining intact unit continues to provide protection.  MER's inorganic zinc coating  system
(both physical and electrical) was the only non-silicone coating demonstrated as effective against the zebra
mussel  fouling.  The MER system showed  only a  few percent  of the fouling present in the  control
experiments.  Identical units treated in the same  manner in the same study suffered the disconnection of
the electrical  signal source.  Those units are beginning to show  signs of fouling:  this is  in the field
confirmation that both the coating and the electrical signal are required to give the indicated antifouling
character.
        Subsequent experiments showed that it was not required to have the bulk of the current flow go
from inside the supporting structure into the surrounding solution.  Simply passing a current through the
underlying conductor structure imparted, antifouling protection to the surface. We believe the mechanism
of action is the same in this configuration, only that current leaked  across the interface gives the required
Zn ion.
        Tests on small stationary vessels, larger commercial tugs and industrial power plant installations
show the MER  inorganic zinc - electrical  system to provide effective antifouling for years in the rather
extreme marine environment.  But that's not what we want to address here.

        There are two competing aspects a new technology: performance and theory.  As we all develop
new technologies, we gain experience in the models and theories of that technology's operation. That
normally gives us the idea, based on some theoretical grounds that a particular behavior is possible within
a technology. As we approach the development  of the new idea, we have some theoretical basis for our
approach. Before others invest any time, effort or money, the following question is asked: "We see that
there is some theoretical evidence for this technology, but does it actually work in the field?"   On the
other hand,  and less frequently, we find some interesting technology that we actually observe in the field.
This time, when we try to develop the technology, we are asked:  "We see that it does actually work in
the field, but is there some theoretical evidence for this technology?"  This is the situation MER was in:
we had  an observable process, yet not a clear underlying theoretical basis for its operation. Experiments
were conducted to try to correct this situation.
        The nature of the specific experiments conducted is not entirely pertinent to this discussion, but
during the course of examining the antifouling mechanism, two critical observations were made:

        1) Zn was the active component in the  antifouling action and the electrical signal significantly
        prolonged the lifetime of the efficacy of the coating.

        2) In some installations, the  underlying support for the  coating showed substantial structural
        integrity, far beyond that expected under the circumstances.

A third piece of evidence came in at the same time: Zinc leach test results. Antifouling agents have been
notoriously harsh on the non-fouling biological systems living near places where marine vessels spent any
significant time.  In order to assess the localized potential environmental impact, zinc leach rate tests were

                                             245

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conducted (EPA test SW-846) and showed MER's inorganic zinc coating formulation has a sub-ppm
Zn/day/M2 covered surface leach rate.  While this is a thousand-fold lower than that found for the zinc
dust alone, the relatively impervious crosslinked silicate binder should effectively shut down much ion
and solvent movement so the lower zinc leach rate is expected.  The incredibly low Zn leach rate, the
structural integrity of the underlying steel matrix and the prolonged lifetime of the antifouling (due to Zn)
action suggested that the MER coating .system would have significant effect as an anticorrosive coating
system.  Again, The MER system relies on both a material component (the inorganic Zn coating) and an
electrical component (the electrical signal). Antifouling action was significantly enhanced and prolonged
with the application of the electrical component.  Since Zn ions are the active agent, the electrical signal
appears to help retain zinc in the coating.
        With some  simple calculations, it is  possible  to predict a useful lifetime for MER's coating
system: at a coverage of 60 microns, 0.5 microns of the Zn would leach into solution per year. That
extrapolates to greater than 100 years. The use of this coating system above the sea, on "dry" land would
only serve to reduce the rate of Zn leaching, stabilize the material part of the system and provide longer
than expected lifetime.   In fact, we know that the entire underlaying substructure is not protected until
the last bit of inorganic zinc coating is gone.  Localized deterioration may occur. Even so, at this point,
there is likelihood  that  this coating  system (both material and electrical) will provide anticorrosion
protection beyond the lifetime of those applying the coating on the structure. Considering leaching solely,
75-125 year effective lifetime is not out of the question at this point.

And now, the hard part: elucidation of a mechanism of action.

        Before continuing, it is useful to examine the current model of corrosion and some attacks that
have proven  successful  in the slowing of corrosion processes.  We will begin with considering the
electrochemical  cell and  then  the  corrosion  process cell  analog.   Figure  4  shows  a  standard
electrochemical cell.  The chemical half  reactions in the left  and right portions  of  the cell  transfer
electrons externally  to the solution through a conductor. The anode electrode is the corroding substance
of interest.  As metal atoms ionize, the ions are either dissolved in the solution or form ionic surface
compounds on the anode. Figure 5 focuses on the local cathodic  region of a metal protected by inorganic
Zn coating.  An oxidant, usually water or water related, is reduced at the cathode to  form gases (like
Hydrogen) and other charged species. Charge is carried between the two electrodes through the solution
by  ionic transport mechanisms to complete the electrical circuit.
        Virtually all anticorrosion strategies  focus on one area of this complete process.  Alloying
strategies address either conductivity within the metal or the electron transfer process at the electrode -
solution interface.  Prophylactic insulating coatings attempt to interrupt the interfacial  electron  transfer
by  providing a barrier to reactant approach.  Simply keeping the surroundings "dry" can impede the
charge transfer between anode region and cathode region through the  surroundings, as well  as lowering
the concentration of the reactant at the cathode. Cathodic protection by sacrificial anode "short-circuits"
the process by providing a better route for electrons that eventually show up  at the  cathode.  Every
electron (or two) that doesn't come from the original anode means there is one more substrate metal atom
that didn't oxidize.
        Since both antifouling and anticorrosion are within areas where Zn  has found some use, we
looked first to models of operation that zinc has  clearly exhibited in the past.  This lead us to amass a
list of what is NOT  going on in this system:
        First (and perhaps most important) is  that the MER system doesn't appear to function utilizing
zinc as a sacrificial anode.  The loss of zinc from the surface  matrix is minuscule, as shown by the
leaching tests. Field tests also support this position.  We will see more about this later.
        Secondly, this system isn't operating by cathodic protection. The magnitude of current - potential
- charge that is employed in this system is microscopic compared to the normal values found in cathodic
protection (4). Typically, tens of mA/square meter are used in cathodic protection of galvanized steel.

                                               246

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MER's system operates on tens of microamps per square meter. In fact, it was in the experimentation
related to assessing cathodic protection as a mechanism that we noticed that the capacitance associated
with the solution  -  coating interface was not even close to that expected.   Higher than  expected
capacitance jumped out to us as well as a dependence of capacitance on potential. Differential capacitance
is nothing new but we felt that the variation was larger than we expected.
       Thirdly, the system doesn't behave as a simple insulating impervious coating.  The measured
resistance through the inorganic zinc coating is too small. A typical 200 micron coating of MER's cured
coating shows a resistivity of around 2 x 103 kilohms-cm.  This is way too low to behave as an effective
insulative coating, yet not low enough to  be a "good" conductor.
       One more aspect of the MER inorganic zinc coating not yet mentioned is the rough physical
composition.
       As we examine the materials that comprise the coating, the several percent of the coating that is
NOT zinc metal looms large.  The few percent of the matrix that is silicate based will have substantial
network  silicate structure after the curing and crosslinking of the coating removes carrier and expelled
reaction product water. The remaining crosslinked network will have largely insulator characteristics (5).
The zinc metal, of course is a reasonable conductor or at least a very good p-type semiconductor and has
found  use in chip gate manufacture.  It  is reasonable  to imagine Zn  as a gate material  in these
applications, since it is viewed as a  "p-metal". "p-metals" are those having hole mobility larger than
electron  mobility, as measured  by the Hall effect. Thus, Zn can be thought of as having the character
of a p-semiconductor (6). Finally, we have the few percent of the "zinc" that is actually zinc oxide. Zinc
oxide in these films is at best, a heterogeneous phase,  coating  the zinc metal  particles.  During the
application of the coating, some of the coating will undoubtedly be pushed aside and allow direct Zn-Zn
contact between dust particles, but the particles will largely be coated with oxide of variable composition.
The electrical properties of ZnO are  interesting and complex.  ZnO will  act  as a semiconductor with
about  a  3.2 eV band  gap (7).   Dopants or other compositional variations  significantly alter the
conductivity of ZnO, allowing resistivities of relatively "pure" ZnO from 1015 to 10"^ ohm-cm (8).  This
range spans resistivities of insulator and semiconductor materials.     Assessing the electrical behavior
of the MER coating system becomes problematic when we look at the incredibly low currents / charge
needed for anticorrosive protection.  The standard models for anticorrosion protection don't do well. The
model we wish to present here is based on interruption of the electron transfer between metal substructure
and the surrounding species.  We believe  the Zn / ZnO / SiOx structure is behaving like a semiconductor
device, and perhaps more specifically, like a Field Effect Transistor (FET).  Perhaps more appropriately,
it behaves like many FETs connected ip several arrangements throughout the coating.

The FET structure

       If we look at the model for a FET, and we will use a Junction FET (JFET) to illustrate the point,
we can interpret portions of the coating structure in  semiconductor terms.  In the JFET case (figure 6),
the charge transfer from the source to the  drain must  pass through a narrow region of semiconductor near
the gate.  As  an appropriate potential/charge  is placed on the gate, the nearby majority charge carriers
in the channel semiconductor are depleted from the region  around the gate.  As the depletion region
grows, the crossectional area available for majority charge carriers to move from source to drain drops.
The source-drain current is lowered as the depleted region grows.  When enough charge is placed on the
gate, the conduction channel is finally "pinched off"  and current flow stops. This is the classic way that
JFETs can behave as switches, interrupting the flow of current from source to drain. Typical common-
source forward transconductance (the relationship between gate control voltage and source-drain current)
for a JFET is 10,000 micromhos. Small voltages control large currents.  This effect is at the center of
the use of FETs in amplifiers.
        If we view the corrosion current as the source-drain current, then we can imagine controlling the
magnitude of that current by the application of a small voltage/charge on the gate.  We can model much

                                             247

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of the JFET from the components of MER's inorganic Zn coating matrix (figures 7 and 8). The cathodic
portion of a corrosion cell would represent the source of electron flow.  The redox processes provide Vdi.
This voltage comes from a combination of submetal through coating to the surrounding oxidant or simply
within the coating itself as some Zn metal is sacrificed. These electrons pass through the coating. With
ZnO  behaving as the n-type semiconductor, it would be analogous to  the channel semiconductor in the
above illustration.  Since the typical ZnO layer is only a fraction of a micron thick, the interfacial region
between two "Zn" dust particles would be thin enough to pinch off readily, shutting down charge transfer
through the ZnO.  The field drives the charge carrier motion and with a thin ZnO layer, the field for
even  a small potential  drop will be large.
          Since the drain would be the interfacial region between ZnO surface and surrounding oxidant,
addressing the charge transfer through the ZnO layer and not the Zn dust. In fact,  the electron transfer
between surface  and oxidant will necessarily involve electron travel through the ZnO layer.
        Typical FET gate control voltages require 3-5 V to deplete the channel region. In the absence
of leak pathways, the structure can remain depleted for a long time. In a typical MER application, there
will be dozens to hundreds of particle-particle interfaces.  There will also be particles that have metal-
metal contact with other particles and base metal due to application force scraping away ZnO on impact.
This means that the overall structure would less be modelled  as a single FET, but as a series of FETs,
each connected through a network of other FETs. This type of structure will likely be "leaky", requiring
some redepletion in order to maintain the effect. The critical  junctions, though, are those at or near the
surroundings  / coating interface.  Interpreting the coating in terms of its semiconductor properties does
allow us to address some of the observed anticorrosive action of the MER coating system.

1) Small charges/currents/voltages can control corrosion currents.
2) Cathodic protection need not play a role in this mechanism, yet electrical control is required.
        -the oxidation of the Zn in the coating can be very slow, as long as  the gates pinch off the current
        through the ZnO channels.
            •**>•
        Up to now, we have not addressed the presence of the silicate binder.  The silicate binder need
play no role in this model,  but in fact it may contribute significantly.  For example, if we include the
(post-curing) silicate network insulating structures, a more appropriate model FET may be the Insulated
Gate FET (IGFET) or the Metal Oxide Semiconductor (MOSFET).  In these structures, the gates are
electronically insulated from the substructure channel semiconductor.  The depletion mechanism is similar
to that for  the JFET,  in that  a  pinch off region lowers the charge movement through  an underlying
semiconductor channel. By this model, reducing the corrosion current by a factor of only 5 would extend
the life of the coating by a factor of 5. This, would turn a 8-year inorganic Zn coating into a 40-year coat
lifetime, neglecting non-corrosion deterioration.
        Utilizing semiconductor technology as a means to control is not new (9,10), yet the principal
approaches have centered on modifying conduction band energies to inhibit electron transfer and not shut
down current through external depletion of charge carriers.  Some experimental evidence does support
a semiconductor model approach to the MER coating anticorrosion system. For example, the pn junction
has an inherent capacitance  and that capacitance depends on the potential of the signal impressed across
the junction.  In addition,  the  resistance through these coatings is  temperature dependent.  At the
temperature rises, the  resistivity drops by about  1 %  per Kelvin over a range of room temperature to
40°C.   Metallic  conductor  charge transport would show an increase in resistance with temperature.
Semiconductor charge transport  shows resistance drops  as temperature rises.  In fact, ionic charge
transport  shows resistance-temperature behavior similar to semiconductors in that respect and  we are
beginning experiments to discriminate between these potential mechanisms.
                                             248

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Conclusions

       Inorganic zinc coatings are noted for their ease of application, low toxicity and wide applicability
to substrates.  MER has found two areas where a combination of inorganic zinc coating and impressed
electrical signal results in significant prophylaxes.
       Marine and freshwater antifouling protection is afforded by the MER coating  system.   The
inorganic zinc coating and electrical signal are both required for optimum performance.
       In addition, the MER system can provide anticorrosion protection for an extended period of time.
The mode of action appears to involve the semiconductor nature of Zn/ZnO in the coating.


References:

1.     Costlow, J. and Tipper, R., "Marine Biodeterioration: an Interdisciplinary Study", Naval Institute
       Press, 1984.

2.     Bard, A.J.  and Faulkner, Chapter 12  in "Electrochemical Methods", Wiley,  1980.

3.     Leitch, E. G. and Puzzuoli, F. V., J. Protective Coatings & Linings, 9, no. 7,  2, 1992.

4.     Morgan, J., "Cathodic Protection", 2nd ed., NACE, 1993.

5.     Munger, C. G., J. Protective Coatings & Linings, 6, no. 6, 187, 1989.

6.     Dunlap, W. C.,  "Introduction to Semiconductors", p.56, Wiley, 1957.

7.     Brown, H. E., "Zinc Oxide Properties and  Applications", International Lead Zinc Research
       Organization, N.Y., 1986.

8.     Seitz.M. & Whitmore,D., Phys. Chem. Solids, 29,1033,1968.

9.     Jain, F. C., Technical Report to NADC #N62269/83-66-32008, 1985.

10.     Frommet, M., "Passivity of Metals and Semiconductors", Elsevier, 1983.
                                            249

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                      90
                      80-
                   8  IW
                   I  60-
                   I
                   a
                   o  40-
                   J*
                      30
                   -=-  -05
                      -1.5
                   n
                   B,
 -2
•2.5
 -3
                  w -4.5

                      -5
                      BO
                     70
                   - ^
                   e
                   s
                   S 30-
                      10
                             Factors  in Total Resistance
                                  Japanese Destroyer Yudachi
                                     Hull
shape]—
                            10   12   14   16   18   20   22   24   26
                                       Vessel Speed (Knots)
                                   Loss of Speed
                               Japanese Destroyer Yudachi
                                               (Initial Speed: 20 knots I
                                           \
                                                         x:
                             50   100   150   200   250   300    350   400
                                         Days out of dock

                                    Cost of Fouling
                             Increase in Shaft HP to Keep 15 Knots
                             50    100   150   200    250   300   350    400
                                        Days out of Dock
Figure 1.  a)  contributions of static and frictional resistance to the total resistance,  b) loss of
speed  for a vessel kept at constant power as a result of increased fouling  c) required power
increase to keep a vessel at a constant speed, rising due to effects of fouling.
                                         250

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                                                                                               larvae
ro
ui
                                                                                               larvae
                                                                               d
                Figure 2.  Four approaches to antifouling: a) toxic leaching  b) ablative coating  c) "hard1

                coating and d) the MER system.

-------
NJ
              J I I
          I 'l .»
               I  1 '
       I,,'Conductor,,,
                                    o
   o      o         o
      -       o          o
                                                                           o
                                        o
                                             o
                     Charged foulant "glue"

                  _     Macromolecule
                  °                      4
                                   o
o                      o
     Solution     +
                                                                             4-
              Figurc 3. A primary event in fouling is the approach of the charged "glue" molecule to the
              surface to be settled on.

-------
                             e-  —>
                          M
                        M
                                   R   O
                      Anode      Cathode
           b)
                       Corroding Substrate
                   A
e-  — >
                    M
                                       R   O
                  Local
                  Anode
                  Region
            Local
            Cathode
            Region
Figure 4.  The electrochemical cell model for corrosion,  a) a standard electrochemical cell
having separated half-cells  b) a segment of a corroding substrate showing localized cells, with
nearby anode and cathode on the same piece of metal.  The circuit is completed by the
movement of ions back to the region around the anode.
                                  253

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                                                             ;;1JL1 V^vCLJL : o Ll:Uo LI Ct LV->
N)
                       Products
                                                           Oxidant
                Figure 5.  A view of only the local cathode region of a substrate covered with a protective
                inorganic Zn  showing the path of -current from a nearby anode region and out through the
                coating to the oxidant in the surroundings.

-------
              JFET  Operation
    V
     SD
(O
tn
ui
GS
                             Source
                                e-
                                V
                              Drain
n-type
semiconductor
material
                                         Gate(s)
                        depletion
                        region
          Figure 6. A diagram of the common mode of operation for a junction field effect transistor
          (JFET). Depleting the channel region of charge carriers reduces the ability of current to flow
          between the source and the drain.

-------
                               Substrate
                               IVTetal
cn
                        Zn:85% by mass ZnO:7%by mass
                        Silicate binder:8% by mass
                      (ca.  25 micron coat indicated)
             Figure 7.  If you were 500 microns tall, what would the surface and coating look like? This
             shows the coating a bit more to scale, with oxide layers present on the Zn particles and binder
             present. This coating would be about 1 mil thick.

-------
                                  Substrate  metal
                                                        Source
N)
Ul
                                                                                    ZnO
                                                          Drain
                           Product(s)      Oxidaht
                   Figure 8. Focusing on a single pair of the dust particles in contact with the substrate metal, the
                   analogous structures to a JFGT appear: the source current comes from the reductant at the
                   anode, the drain is the oxiclant half reaction  and the ZnO forms the n-typc semiconductor
                   channel between the gates. The externally applied signal provides the field to shut off the
                   source-drain current.

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258

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

                    A New Inorganic Coating for Magnesium Alloys
                         with Superior Corrosion Resistance

Alex J. Zozulin
Technology Applications Group, Inc.
4957 10th Avenue South, Grand Forks, ND 58201
Duane E. Bartak
University of Northern Iowa, Department of Chemistry
Cedar Falls, IA 50614

INTRODUCTION

      Magnesium, the sixth most abundant element in the earth's crust, is the lightest of all
commonly used structural metals. Having a density of only  1.74 g/cm3, it is one and one-
half times lighter than aluminum, approximately four times lighter than zinc or steel and is
comparable in weight to perhalogenated or mica and asbestos filled plastics. Although pure
magnesium is too soft for structural use, the addition of other elements such as aluminum,
zinc, manganese and rare earths have produced alloys with enhanced chemical and physical
properties. Alloys of magnesium have found considerable use in applications where weight
saving is important. The automotive industry has been looking increasingly towards magne-
sium for reducing vehicle weight, thus improving fuel economy, and is currently the major
user of magnesium die cast parts. For example, a weight reduction of 125 Ib. will yield  a
fuel economy improvement of 0.2 to 0.5 miles per gallon in  the EPA Combined City-
Highway test.1  In a recent perspective of magnesium in automobiles more than forty pro-
duction applications of magnesium alloys on US  cars are listed.2  Other industries which
benefit from magnesium's low weight include power tools, computers, recreational equip-
ment and aerospace.  In addition to it's low weight other advantageous properties include a
hjgh-strength-to-weight ratio, excellent dimensional stability, high impact resistance, good
creep strength as well as high thermal and electrical conductivity. In addition, magnesium
and its alloys are recyclable and present no toxicity hazard.3

      Pure magnesium metal is a reactive metal and thus is easily oxidized. This oxidation
or corrosion, galvanic as well as surface, is often  the major obstacle against the use of mag-
nesium in aggressive corrosive environments. However, through the use of high purity
alloys with a low content of iron, nickel and copper, satisfactory performance may be
achieved with respect to surface corrosion.4-5 For example, the corrosion rate in salt spray
(ASTM B117) of high purity AZ91D6 and AM607, both die cast alloys, range from 1-12
mpy and less than 20 mpy, respectively, while two sand cast alloys, AZ91E and WE43,
exhibit similar rates of 5 mpy8 and 8-16 mpy9, respectively.  Other commonly used alloys,
such as ZE41 A, demonstrate considerably higher corrosion rates. The corrosion rate of
ZE41A  has been reported to be greater than 400 mpy.10 The utilization of these alloys, par-
ticularly in aggressive environments, will require the application of surface treatments to
provide additional protection against surface corrosion. In contrast, alloy composition will
have a limited influence on galvanic corrosion; however, in this case, the service perfor-
mance will depend on the proper design, assembly and surface treatments as well as the
metal purity.11                         25g

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       In terms of aerospace applications, magnesium alloys, including ZE41 A, QE22A
 and AZ91E, are currently used to fabricate main transmission housings and other gear boxes
 for several helicopters which are used for commercial and military purposes. Other parts,
 which are cast using these alloys, include intakes and intermediate casing for aircraft
 engines, housing for auxiliary power units, canopy frames and speed brakes. In many cases,
 extremely corrosive environments are encountered and, as a result, high performance coat-
 ings are required to produce maximum protection against surface and galvanic corrosion
 while minimizing maintenance.

       The surface treatment processes for magnesium alloys which serve as a paint base
 and a barrier towards corrosion can be grouped into two types. The first type is the chemical
 conversion coatings which are applied either by immersion, brush on or spray-type process-
 es while the second type involves an electrochemical anodic process. Table I provides a b'st
 of the more commonly employed surface treatments.12 Though many of the conversion
 coatings do produce a surface that provides some corrosion protection and can act as a paint
 base, they are limited in applications on the more reactive sand cast alloys.  In addition, the
 abrasion resistance of these coatings, including the anodic processes, are not particularly
 high. It is interesting to note that most of the treatments shown in Table I also utilize chro-
 mates in the primary coating or sealing bath. The utilization of chromates plus other materi-
 als such as cadmium, zinc, lead, copper and many volatile organic compounds (VOCs) has
 resulted in the EPA identifying the metal  finishing industry as one of the most significant
 contributors to environmental pollution.13 As a result, there is a critical need for new coating
 technologies which will reduce or eliminate chromate based systems yet provide adequate
 corrosion resistance, abrasion resistance and paint adhesion.
Table I. Common Inorganic Surface Treatments for Magnesium Alloys.
Chemical Treatment

       #1
       #7
       #17

       #19
       #21
       HAE
       Indite No. IS
       Bonderile 1000
Conversion
Conversion
Anodic

Conversion
Conversion
Anodic
Conversion
Conversion
 Solution Constituents

 Sodium dichromate, nitric acid
 Sodium dichromate. calcium or magnesium fluoride
 Ammonium bifluoride, sodium chromaie,
 phosphoric acid
 Chromic acid, calcium sulfate
 Chromic acid, ferric nitrate, potassium fluoride
 Potassium hydroxide, potassium fluoride.
 aluminum hydroxide, sodium phosphate.
. potassium manganate
 Chromic acid, chloride, nitrate solution
 Iron phosphate
       Recently, a new high performance coating for magnesium alloys has been developed
which exhibits improved corrosion protection and abrasion resistance as well as providing
an excellent paint base. The coating has been given the trademark, TAGNTTE™, and is pro-
duced by an electrochemical process that does not employ chromates. The process and coat-
ing characteristics arc described herein.
                                       260

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products which may be present on the alloys through the use of the mild alkaline etch. This
solution, commonly used to brighten die cast alloys, shows an insignificant metal loss after a
ten minute treatment. The coating process itself consists of two steps. The first step is a
simple chemical process in which the magnesium alloy is immersed into a heated solution
containing the fluoride ion. This solution applies a layer containing a mixture of magnesium
fluoride and oxofluorides and magnesium oxide and serves as a base for the step second.
The second step is an electrochemical process in which the magnesium alloy is made the
anode in an electrolytic cell.
       The electrolytic process is accomplished using a relatively high voltage rectifier
which supplies a combination AC/DC signal to the electrochemical cell. As in other
anodization processes, the magnesium alloy is the anode while the stainless coating tank
serves as the cathode. The electrolytic process involves the concurrent anodization or oxida-
tion of the metal substrate and deposition of inorganic species from the silicate containing
electrolyte. As a result of the relatively high voltages, greater than 150V, a spark process
develops during the deposition.  The sparking action is the result of the applied voltage being
greater than the dielectric breakdown voltage of the layer produced in the first chemical step
and the developing coating in the electrolytic step and produces temperatures which have
been estimated to be greater than 1000 C. These localized high temperatures result in the
fusion of silicate and oxide species onto the metal surface.  Although the heat generated
from the spark is localized on the surface, the resistive heating of the solution requires a
cooling system to maintain the electrolyte temperature between 10-20 C. Figure 2 is a pho-
tograph of a magnesium AZ91D panel during the deposition process with the sparks visible
on the panel surface.  The lifetime of these sparks is typically less than a millisecond.
           figure 2. A photograph of • 4" x 6" lest panel of magnesium alloy AZ91D during the Tagniie anodic tpaik
           deposition process.


      Surface and near surface elemental analysis of the coating by ESCA indicates the


                                          261

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 EXPERIMENTAL

       Evaluation of coating performances was conducted on two magnesium alloys,
 AZ91D, a die cast alloy, and ZE41 A, a sand cast alloy. All panels used to evaluate corrosion
 resistance were from the same melt so as to eliminate any variation in base corrosion rate for
 the bare metal due to variations in alloy composition. All coatings were applied as per speci-
 fications either in-house for the Tagnitc coating or by an aerospace approved metal coating
 facility. In addition, all panels were entered into the salt spray chamber together to eliminate
 variation in chamber conditions.

       Coating thicknesses were measured by an eddy current technique using an EMI
 International EM-2000E instrument which was calibrated with two plastic sheets of certified
 thickness on an alloy base of similar surface roughness as the panel tested. The arithmetic
 average roughness height, R,, was measured using a Sheffield type QE profilometer
 amplimeter which was calibrated using a precision reference specimen.  Five measurements
 were made across the surface of each panel using a 0.03" cut off width and 1.5" piloter
 stroke length. The five readings were averaged to yield the R, value. Abrasion resistance
 testing were conducted using a Taber Model 5130 abraser using two C-17 abrading wheels
 with 1000 grams of load (ASTM D4060). The C-17 wheels were refaced before each test
 and after every 1000 cycles using a S-l 1 refacing disk. Results are reported as a Taber Wear
 Index (TWI) and number of cycles achieved. Corrosion performance testing was performed
 using a Singleton Model 20 corrosion test chamber operating as per ASTM B117. Panel
 evaluation was conducted as specified in ASTM D1654, method A and B. Scanning elec-
 tron photomicrographs were obtained on a Hitachi S-800 scanning electron microscope.

 THE COATING PROCESS

       The application of the TAGNTTE coating, as is the case with other coating processes,
 requires good cleaning practices such as those specified in MEL-M-3171.14 Typically, the
 cleaning procedure shown in the process flow diagram of Figure 1 is sufficient to degrease
 and clean the surface. In addition, this method is capable of removing minor corrosion

 Figure 1. Process Flow Diagram for TAGNTTE Treatment of Magnesium Alloys.

                                 Dcgreaser, aqueous based
                                 40-50eC, 1-15 min., Rinse

                                     Alkaline Etch
                                 70-80°C, 1-10 min.. Rinse

                                   Fluoride Prcireatment
                                 70-95°C. 5-90 min., Rinse

                                    TAGNITE-8200
                                     10-15°C. Rinse

                                   Surface Neutralization
                                     Post-Treatment
	50°C. 30-120 seconds. Rinse	

                                         262

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major constituents include magnesium, silicon, oxygen and fluorine for the coating on both
the AZ91D and ZE41A alloys with a very minor quantity of potassium. For the ZE41A
alloy, a minor percentage of cerium was detected, a result of the 1% rare earth composition
of the alloy.  The measured bonding energies indicate that the silicon atom is present in the
form of silicate, not as silica, and the fluorine atom exists in its ionic form. This presence of
magnesium in the coating indicates the electrolytic process involve the oxidation of the mag-
nesium alloy substrate with the concurrent spark deposition of silicate and oxide species on
the surface of the magnesium alloy. The oxidation and deposition process also results in a
dimensional change for the magnesium alloy part. Cross-sections of panels which were par-
tially masked, then coated and subsequently examined by SEM indicate that a dimensional
increase of approximately 54% of the coating thickness occurs for the AZ91D alloy as com-
pared to 46% for the ZE41 A. These values are similar to those reported for the other two
anodic processes. For example, chemical treatment 17 and HAE show an increase of
approximately 65 to 75% and 50 to 75%, respectively.15

      The thickness of the coating can be varied from two to thirty micrometers by control-
ling the current density and the time of the coating process. Typically, the process is per-
formed at a constant current density in the range of 5 to 15 A/ft* with coating times  of 10 to
20 minutes for a five to ten micrometer (0.2 to 0.4 mil, type I) thickness and 45 to 75 min-
utes  for a 20 to 25 micrometer (0.8 to 1.0 mil, type H) thickness. The final voltage,  though
dependent upon the current density and bath composition, typically ranges from 280 to 320
volts for a type I and 320 to 340 volts for a type II with power requirements of approximate-
ly 0.4 and 1.6 kW hr/ft2, respectively.

COATING MORPHOLOGY

      The coating produced during the electrochemical process yields a surface with a
finite amount of porosity. The porosity is a result of the evolution of oxygen gas from the
oxidation of water or hydroxide ion with the concurrent generation of sparks at the surface.
Figure 3 A is a scanning electron photomicrograph representing the top view of a 5 microme-
ter thick Tagnite coating on a AZ91D test panel at a magnification of 2000 while Figure 4A
represents a 22 micrometer thick coating on a ZE41A test panel. The maximum size of the
pores is typically in the range of one to five micrometers for a type I thickness and one to ten
micrometers for a type II thickness  with the size dependent on the electrolyte composition,
concentration and the time of coating process. The increase in pore size with coating thick-
ness  may be attributed to a similar increase in spark size resulting from a greater dielectric
breakdown voltage as the deposition process proceeds. Though the surface is porous, the
surface texture as measured by profilometer indicates the arithmetic average roughness
height (RJ ranges from 25 to 85 microinches for coatings between 2 to 25 micrometers (0.1
to 1.0 mil) thick. The value of Rm is dependent on the time of deposition or the thickness,
only marginally dependent on the current density or the rate of deposition, and is essentially
independent of the substrate alloy. For example, a coating thickness of 12.5 micrometers
produces a surface with a value of R, from 48 to 53 microinches for current densities
between 3 and 15 A/ft?.

      Finally, it should be noted that although the coating has a porous microstrucrure,

                                        263

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 Figure 3. Scanning electron photomicrographs: A) top view of the Tagnile coating on AZ91D (200xX B) cross-section view of the Tignile coating on
 AZ91D(2000bi).
Figure 4. Scanning electron photomicrographs: A) lop view of (he Tagnhe coating on ZE41A (SOOx), B) crou-iectian view of the Ttgraie coating on
ZE41A(1000xX

                                                              264

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cross-sectional views of the coating indicate that the pores do not completely transverse the
coating. Figure 3B and 4B are SEM photomicrographs of cross-sections of the TAGNITE
coatings on the same alloys as shown in Figures 3A and 4A, respectively. As can be seen.
the coating interface with the metal is quite good with no passageways occurring between
the exterior and the base metal. Thus, the coating has the effect of preventing an aggressive
environment from contacting the reactive metal substrate which would result in extensive
corrosion.

CORROSION PROTECTION AND PAINT ADHESION

       With the advent of high purity magnesium alloys, the corrosion rate for the base
metal has been significantly reduced as compared to pure magnesium metal. In aggressive
environments, however, additional corrosion protection is required and provided by the
application of surface coatings. In addition, these coatings also serve as a base for painting.
To test for corrosion resistance and paint adhesion, accelerated testing is performed using a
salt spray chamber (ASTM B117). Table III illustrates some representative data for salt
spray testing on the AZ91D and ZE41A alloys which have been treated with the Tagnite,
HAE and chemical treatment 17 coatings. As can be seen, the Tagnite coating provides
increased corrosion protection as compared to HAE and chemical treatment 17. For exam-
ple, the Tagnite coating on  AZ91D with a thickness of 5 to 10 micrometers (Type I) yields
an ASTM D1654 (procedure B) rating of 8 after 28 days in salt spray while both HAE and
treatment 17 are rated at 5 after just 14 days. It should be noted that the rating is based on
the percentage of the total surface area that has failed due to corrosion pits, blisters or any
other type of failure present. A rating of 8 represents a 2 to 3% failed area and a 5 denotes
11 to 20% of the area has failed. The best rating is a 10 which corresponds to no failures.
The application of a thicker coating provides improved protection as indicated by a rating of
10 for a Type II Tagnite coating after 28 days in salt spray. The ZE41A alloy also benefits
from a Tagnite coating and» as shown in table m, a type II coating typically gives a rating of
9 on panels exposed to salt  spray for 14 days while treatment 17 affords only minor protec-
tion with over 75% of the area having failed (a rating of zero) after only 2 days. It should be
noted that the duration  of the corrosion test will be less for the ZE41A alloy than the AZ91D
alloy due to the difference in corrosion rates for the base alloys.


Table ID. ASTM D1654 Ratings en AZ91D Panels Subjected to Salt Spray.
Coatinp/Altov
Tagniiel/AZ91D
Tagniie'/AZ91D
Tagniie1/ZE41A
Dow 17/AZ91D
Dow 17/AZ91D
Dow 17/ZE41A
HAE2/AZ91D
Thickness
Typel
TypcH
TypeH
Type I
TypeD
TypeH
Typel
Time
28 days
28 days
14 days
14 days
14 days
2 days
14 days
Unscribed Area (Procedure B^
8
10
9
5
5
0
5
       1 Post-treated using sodium dihydrogen phosphate
       2 Post-treated using sodium dichromate and ammonium bifluoride


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       A comparison of the coating morphologies offers a possible explanation for the
 greater effectiveness of the Tagnite coating over HAE and treatment 17 towards corrosion.
 Cross-sections and surface examination of the coatings by SEM indicate the pores in the
 Tagnite coating are smaller and more uniform in size and distribution as compared to the
 other two anodic processes. Further, the Tagnite coating shows considerably fewer intercon-
 necting pores which completely transverse the coating to the base metal substrate. In con-
 trast, the coating from treatment 17 typically produces the deepest pores with a high degree
 of interconnectivity.  As a result, the Tagnite coating effectively isolates the magnesium
 metal substrate from the corrosive environment.

       The corrosion resistance of the magnesium alloys may be further improved by seal-
 ing the coatings with paints. In this case, test panels of the AZ91D alloy which were coated
 with 10 to 25 micrometers of the Tagnite coating were primed with a melamine polyester
 primer and then painted with a thermosetting acrylic enamel top coat. The panels after being
 scribed were placed into salt spray for 28 days, with an evaluation of each leg of the scribe
 being performed every seven days. The data, shown  in Table IV, indicate consistently high
 ratings with no corrosion migration under the scribe or corrosion in the unscribed areas.- The
 lack of corrosion creepage from scribe is indicative of the good paint adhesion characteris-
 tics of the coating and may be attributed to its surface morphology.

 Table IV. ASTM D1654 Ratings on AZ91D Panels wiih Tagnite, Painted and Scribed.1

                    Scribed Area (Procedure A>             Unscribed Area (Procedure B")
                    7 day   14 day  2|day.  28 day               28dav
       10-22-3        10     10     10     10                   10
       10-23-3        10     10     10     10                   10
       10-24-1         9     10     10     10                   10
       10-25-2         9     10     10     10                   10
       10-29-6        10     10     10     10                   9

1 Testing (ASTM) and evaluation (ASTM D1654) was carried out by R.W. Munay. The Dow Chemical Company,
Technical Service and Development, Lake Jackson Center. Texas.

      The effect of primer and top coat on the corrosion resistance and paint adhesion was
also examined on the ZE41 A alloy. When panels of this alloy, treated with the Tagnite and
treatment 17 coatings, are painted with one coat of primer (MIL-M-23377E) and subjected
to salt spray for 28 days, extensive corrosion occurs for the treatment 17 coated panels with
typical ratings of 3 (procedure B). In contrast, the Tagnite coated panels arc rated as 10 (pro-
cedure B). Additionally, panels were also coated with the Tagnite and treatment 17 coatings,
painted with one coat of primer (MIL-M-23377E) and a top coat (MEL-C-46168D). In this
case, the paint adhesion characteristics were tested by scribing the panels before placing
them together in salt spray for 28 days. Due to the higher corrosion rate of this alloy, corro-
sion pits  develop on the scribe for both coating systems; however, the extent of corrosion
migration under the scribe or the degree of paint adhesion to the  anodic coatings is consider-
ably better with the Tagnite coating than with treatment 17. Ratings (procedure A) of 5 A
and 9A (with a single low value of 7 A) are typically obtained for treatment 17 and Tagnite
coatings, respectively.

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ABRASION RESISTANCE
       Abrasion resistance has been determined on Tagnite, treatment 17 and HAE coatings
on AZ91D as well as the Tagnite coating on ZE41 A. Table V illustrates representative data
in the form of the number of cycles and a Taber Wear Index (TWI). As can been seen from
the data, the Tagnite coating on both AZ91D and ZE41A is considerably more wear resistant
than either HAE or treatment 17. Though the abrasion resistance will  largely be dependent
Table V. Abrasion Test Results.

Sample                     TWI-1-

AZ91D. TAGNITE, 0.3 mil        9
AZ91D. TAGNTTE, 0.6 mil        8
AZ91D, TAGNITE. 0.8 mil        7
AZ91D. TAGNITE, 0.9 mil        6

AZ91 D. HAE, Type I (0.2 mil)     142
AZ91D. HAE, Type II (2.6 mil)     142

TEA 1 A, TAGNITE. 02 mil        6
ZE41 A. TAGNITE. 0.5 mil        7
ZE41 A, TAGNITE. 0.6 mil        14
ZE41 A, TAGNITE. 0.8 mil        12
ZE41 A, TAGNTTE, 1.0 mil        14

AZ91 D. TAGNITE, 0.5 mil        14
AZ91 D. Treatment 17.1.0 mil      37
AZ91D.HAE. 1.0 mil            104
Cycle    Comments

5000     < 10% metal exposed
7000     < 10% metal exposed
5000     < 10% metal exposed
6000     < 10% metal exposed

75      10% metal exposed, coating gone after 200 cycles
1800     10% metal exposed; coating gone after 3000 cycles

1000     10% metal exposed
5000     10% metal exposed
5000     10% metal exposed
7000     10% metal exposed
9000     10% metal exposed

3000     bare metal starting to show2
1000     coating gone after 500 cycles2
1000     coating gone after 500 cycles2
1  Taber Wear Index (TWI) defined as TWl=(A-B)x 1OOCVC where A is the weight of the test specimen before abrasion in
milligrams, B is the weight of the test specimen after abrasion in milligram and C is the number of cycles of abrasion
recorded.
2  Data provided by R.W. Murray. The Dow Chemical Company, Lake Jackson Research Center, Freeport, Texas.

upon the chemical nature of the coating, the significant increase in resistance may be partial-
ly attributed to the coating process in which the localized high temperature, occurring during
the spark deposition, fuses the silicate and oxide species onto the metal substrate surface.

ENVIRONMENT

       Over the last several years, concern has been raised regarding the impact the metal
finishing industry has on the environment. When one considers that the commonly used
materials include chromium, cadmium, zinc, lead, copper, nickel, cyanides and VOCs, it is
not surprising that the EPA has listed the metal finishing industry as a major contributor to
environment pollution.13 Due to the demanding environment in which their products func-
tion, the aerospace industry has become a major user of metal finishing systems, and have
recently expressed concerns regarding VOC emissions, utilization of 1,1,1-trichloroethane,
hexavalent chromium emissions, the land ban and hazardous waste disposal costs, OSHA
                                          267

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 compliance and source reduction and recycling.  As a result of the increasing inevitable gov-
 ernment regulation of hazardous wastes, the industry will be required to become more envi-
 ronmentally responsible through the implementation of waste minimization programs and/or
 the utilization of less hazardous materials.

       Chromates are one of the principal chemicals used in metal finishing industry, partic-
 ularly those dealing with magnesium based alloys. The chromate ion is an excellent corro-
 sion inhibitor. It is used  as a paint pigment, employed in chromate conversion coatings, as
 well as in anodizing baths for aluminum based and magnesium based alloys and as a post-
 treatment for sealing anodized surfaces.  However, chromates are known to be highly toxic
 and carcinogenic.16 The oral ingestion of 1-2 grams of chromic acid or 6-8 grams of potassi-
 um dichromate is reported to cause kidney failure, liver damage, blood disorders and even
 death.17  In addition, exposure of chromates to the skin for prolong periods may cause rash-
 es, blisters and ulcers while inhalation  may cause lung cancer.  Due to these health risks,
 OSHA limits insoluble chromates in the air space to lmg/m3 per 8 hour day per 40 hour
 week and has specified that chromate containing paints must be labelled with a lung cancer
 warning.18

       There are several approaches to the chromium issue. One option is to improve the
 handling procedures in the work place so as to comply with the allowable chromate expo-
 sure limits. Since it is likely that the regulations will only become more restrictive, this alter-
 native will serve only as  a temporary basis. Another alternative is to reduce or eliminate
 chromate containing waste by the application of new technologies.  For example, a study by
 VanCleave19 has resulted in a significant chromium reduction in which chemical treatment
 21 was found to be a suitable replacement for treatment 1, both chromate containing  solu-
 tions, thus permitting the elimination of a planned 7600 gallon treatment 1 tank in their new
 finishing facility.

      Though the implementation of chromium reduction programs is clearly needed, the
 best alternative is the utilization of chromium free materials. Recently, Hinton20-21 has pre-
 sented several alternatives to chromate conversion coatings  and paint pigments for alu-
 minum based alloys.  For magnesium alloy users the elimination of chromate may be more
 difficult, partly due to the greater chemical reactivity of magnesium. Many of the commonly
 employed conversion coatings are chromate based (see Table I) while the common cleaning
 solution for removing corrosion products and old finishes is chromic acid. Further, current
 specifications such as MIL-M-3171 require the application of chemical treatment 1 to sand
 cast magnesium alloys for corrosion protection during shipment and storage.

      As discussed earlier chemical treatment 17 and HAE are routinely applied to magne-
 sium alloys when increased corrosion protection is required. Treatment 17 contains approxi-
 mately 8% by weight sodium dichromate and, although it is reported that the solution is only
 infrequently disposed, thus generating only small volumes of chromium containing waste
 water through dragout, the presence of large processing tanks still results in employee expo-
 sure and the potential for environmental damage should a spill occur. In addition, even
though disposal is infrequent, chromium is introduced directly into the environment from the
coating itself.  Based on the operational parameters for treatment 17 approximately 0.1 to 0.2

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oz of chromium would be introduced into the environment per square foot of metal coated.22
Although HAE is not a chromate containing solution, the coating requires a post-treatment
in ammonium bifluoride and sodium dichromate for all grades except grade 115 and thus uti-
lizes chromium compounds in the overall process.

      A significant chromate reduction may be made by first replacing chromate conver-
sion coatings which are used for temporary protection with oil. It has been reported that
magnesium components may be stored from 1 to 5 years if the alloy is oiled and sealed in a
polythene bag containing a desiccant.23 Furthermore, the use of oil instead of the conversion
coatings will allow the metal surface to be cleaned using alkaline cleaners without relying on
chromic acid. Finally, the application of a chromium free coating system such as the Tagnite
coating will eliminate chromates in the anodizing and/or post-treatment baths.

CONCLUSIONS

      Reduction and elimination of chromium based systems will be a major endeavor in
the metal finishing industry as the governmental regulation of chromium becomes more and
more restrictive.  For magnesium based alloys chromium reduction may be achieved by
replacing the conversion coating used for temporary storage with oil and by the application
of chromium free coating systems such as Tagnite. The Tagnite system provides greater cor-
rosion protection, enhanced paint adhesion and better abrasion resistance than either chemi-
cal treatment 17 or HAE.

ACKNOWLEDGEMENTS

      We wish to thank The Dow Chemical Company, Lake Jackson Research Center for
tests conducted on the Tagnite coating as well as Tom VanCleave and Gunter P. Barth of
Lockheed Missiles and Space Company for the ESCA data.  We also wish to thank Jim Suda
for performing the SEM work.

                                  REFERENCES

1.    Davis, J. The Potential for Vehicle Weight Reduction Using Magnesium, Society of
      Automatic Engineers, Paper 910551, 11991. pp. 71-85.

2.    Mezoff, J. G. Magnesium in Automobiles, in Perspective, Society of Automotive
      Engineers, Paper 800417,1980. pp. 1-14.

3.    Murray, R. W., and J.  E. Hillis. Magnesium Finishing: Chemical Treatment and
      Coating Practices, SAE, Paper 900791,1990. pp. 1-10.

4.    Aume, T.K. Minimizing Base Metal Corrosion on Magnesium Products. The Effect
      of Element Distribution (Structures) on Corrosion Behavior, Proceedings of the 40th
      World Magnesium Conference, Toronto, 1983.

5.    Hillis, J.E. The Effects of Heavy Metal Contamination on Magnesium Corrosion
                                      269

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       Performance, SAE, Paper 830523,1983. pp. 1-7.

 6.     Reichek, K.N., KJ. Clark, and I.E. Hillis. Controlling the Salt Water Corrosion
       Performance of Magnesium AZ91 Alloy, SAE, Paper 850417,1985.

 7.     Hillis, J.E. and Reichek, K.N. High Purity Magnesium AM60 Alloy: The Critical
       Containment Limits and the Salt Water Corrosion Performance, SAE, Paper 860288,
       1986, pp. 1-8.

 8.     The Dow Chemical Company. Heat Treating Sand and Permanent Mold Magnesium
       Castings. No. 141-552-87. Midland, Michigan, 1987. 10pp.

 9.     Magnesium Elektron, Inc. WE43 A Corrosion Resistant Magnesium Casting Alloy
       for Use up to 570°F. No. 467A. Lakehurst, New Jersey, 1991. 4 pp.

 10.    Stevenson, A. Metals J., 39 (5): 16-19, 1987.

 11.    Hawke, D.L., J.E. Hillis, and W. Unsworth. Preventive Practices for Controlling the
       Galvanic Corrosion of Magnesium Alloys, IMA Technical Committee Report, 1988.

 12.    The Dow Chemical Company. Magnesium : Operations in Magnesium Finishing.
       No. 141-479-86R. Midland. Michigan, 1990. 56pp.

 13.    Holmes, J. Metal Finishing, 87 (11): 65,1989.

 14.    Military Specification. MIL-M-3171C. Magnesium Alloy, Processes for
       Pretreatment and Prevention of Corrosion on, U.S. Government Printing Office, No.
       713-153/4659, March 1974. 44 pp.

 15.     Military Specification. MIL-M-45202C.  Magnesium Alloys, Anodic Treatment of,
       U.S. Government Printing Office, No. 703-023/2048, April 1981. 31 pp.

 16.     McCoy, DJ. Proc. Second AESF/EPA Chromium Colloquium. Miami, Florida,
       1990.

 17.     Toxicological Profile for Chromium, Agency for Toxic Substances. U.S. Public
       Health Services. Report No. ATSDR/TP-88/10, July, 1989.

 18.     Bittner, A. Surface Coatings Australia, 27 (5): 6, 1990.

 19.     VanCleave, T.E. Evaluation of Dow 21 to Replace Dow 1: Chromium Reduction
       Using Process Consolidation.  7th Annual Aerospace Hazardous Waste Minimization
       Conference, St. Louis, Missouri, 1992.

20.     Hinton, B.R.W.  Metal Finishing, 89 (9): 55,1991.
                                    270

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21.   Hinton, B.R.W. Metal Finishing, 89 (10): 15, 1991.

22.   Treatment 17 typically requires revivification after 20 fWgal have been treated with
      the recommended concentration of 6.7 to 16 oz/gal of sodium dichromate (the pre-
      ferred concentration being 13.3 oz/gal). If one assumes the bath contains 6.7 oz/gal
      of sodium dichromate after 20 frugal have been processed and that all the loss chro-
      mate occurs in the coating,  then 6.6 oz/gal of sodium dichromate will be needed to
      return the solution to the preferred concentration or 0.1 oz of chromium per square
      foot of metal treated would be loss to the coating.

23.   Magnesium Elektron Ltd. Surface Treatments for Magnesium Alloys in Aerospace
      and Defence. Twickenham, England. 14pp.
                                      271

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272

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  (The work described in this paper was not funded by the U.S. Environmental Protection
  Agency. The contents do not necessarily reflect the views of the Agency and no official
  endorsement should be inferred.)

                         Inorganic Chemistry as an Option for Formulating
                         High Solids, Low and Zero - VOC Architectural and
                                 Industrial Maintenance Coatings

 Christine Stanley
 Ameron Protective Coatings Division
 201 North Berry Street, Brea, CA 92622

 Raymond E. Foscante
 Ameron Protective Coatings Division
 201 North Berry Street, Brea, CA 92622

 INTRODUCTION

     Architectural and Industrial Maintenance (AIM) Coatings are required to protect a wide range of
 substrates from degradation by a very wide range of environments. Coating systems presently used rely
 almost entirely on organic polymers. These chemistries are well established and give proven protection
 to stationary structures in many environments. Inorganic polymers have also been used in the form of
 inorganic zincs coatings, but these products have limitations in that they are used only on ferrous sub-
 strates, have poor aesthetic properties, are not very compatible with organic topcoats and do not give
 performance in acidic and caustic immersion service. However, their performance in these limited appli-
 cations exceed their organic counterparts. Further, the performance properties of silicone and silicate
 resin in baked coatings is well documented and they provide superior properties in heat, UV and chemi-
 cal resistance. Silicone resins have also been used to improve the performance of organic polymer coat-
 ings. They can improve such characteristics as heat and sunlight UV resistance. Until recently, with the
 exception of inorganic zincs and some organic/inorganic copolymers, inorganic polymers were not feasi-
 ble for stationary structures because they required baking. A breakthrough in curing technologies has
 led to polymers that will film form under ambient conditions to give inorganic backbones.  Further, these
 coatings can be formulated to very low VOC's either in solvent, 100% solids or water based options. The
 performance of these products, in general, exceeds those of organic based coatings.

 DISCUSSION

 Terminology

    For clarity. Table 1 gives definitions of the chemical terminology used in the following discussion. In
 coating compositions, the typical resins using the silicon-oxygen bond as the repeating unit in the back-
 bone are silicones and silicates. The term polysiloxane can include silicones, but it is used herein in its
 broadest sense, that is, any polymeric structure that contains repeating silicon-oxygen groups in the
 backbone, side chains, segments or cross links regardless of substitution on the silicon  atom. The pres-
 ence of certain organic groups bonded to the silicon atom in silicones and polysiloxanes moderates phys-
 ical, mechanical and chemical properties, typically in an advantageous fashion1. Oxysilane refers to a sili-
 con based structure in which the silicon is bonded to up to four alkoxide or hydroxyl groups thereby ren-
 dering that structure reactive to certain condensation reactions; the oxysilane may be monomeric, poly-
 meric or a pendant group of a larger molecule.

Comparison of Inorganic and Organic Binders

    To understand the performance difference of organic and inorganic products, we must first comment
on comparative chemical properties of the binders (See Table 2). The high bond strength of the Si-O
bond compared to a typical GC bond gives the inorganic structure strength making them more durable
 in comparison to carbon based structures. Further, this structure is more inherently heat stable leading
to heat resistance up to 2000°F. By comparison, epoxies and polyurethanes are limited to the 200-300°F

                                             273

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  range. Inorganic silicone-oxygen bonds are unaffected by sunlight and ultraviolet attack. By compari-
  son, organic binders such as epoxies and alkyds typically show early chalking and fading and
  polyurethanes and acrylics will show fading and gloss loss in a 3-5 year period. Since Si-O is already oxi-
  dized, polymers based on such a backbone are not affected by atmosphere oxygen and most oxidizing
  chemicals. In contrast, organic polymers will eventually oxidize and degrade. An inorganic structure is
  not combustible, organic polymers will burn and generate smoke and toxic fumes.

  Inorganic Binder Chemistry

     Traditional silicone and oxysilane curing involves a process called hydrolytic polycondensation in
  which an alkoxide silane is first hydrolyzed and the resulting silanols are condensed to a polymer net-
  work (See Figure 1). The innovations being described involve catalysis of this process or direct conden-
  sation and the selection of appropriate silicone and oxysilane precursors to produce binders of use in
  AIM coatings (See Table 3).

  Coating Formulation: Silicones

     Silicone copolymers (containing either alkyd, acrylic or polyester coresins) are well known. The
  amount of silicone resin  incorporated in the copolymer determines the properties of the coating.  The
  binders are manufactured by condensation at high temperatures. The AIM coatings curing and drying
  properties are dominated by those properties of the organic component. Their solids and VOC content
  are also dominated by the organic component'.

 Coating Formulation: Poiysiloxane

     The chemistry described above has been successfully applied to create pure polysiloxane network
 binders. These binders have been formulated into pure polysiloxane AIM coatings having maximized
 thermal, chemical and UV resistance9. Further, polysiloxane/organic "hybrids" AIM coatings have been
 formulated that significantly enhance the properties of the selected traditional organic resin based coat-
 ing.  As well as high performance properties, these formulations offer advantages in VOC content. This
 chemistry increases molecular weight of the binder during the curing of the film to produce solid poly-
 mer networks. The silicone and oxysilane precursors used are selected not only for performance but for
 their very low viscosity allowing for low VOC content formulations.  Pure solvent based polysiloxane
 formulas have been produced with volume solids contents of 80-95%. These precursors in hybrid sys-
 tems are also selected for their compatibility and diluting effect on  the organic components giving coat-
 ings a volume solids content of 80-100%. Water borne inorganic binders have also been formulated into
 coatings.  The pure inorganic versions use silane and silicates as precursors and these systems require no
 cosolvents and have 0 VOC. Water borne organic hybrids can also be formulated at low VOC, however,
 these do require some oo sol vent to form a film with acceptable performance.

 EXAMPLES

    The following examples are offered to demonstrate the unique properties provided by utilization of
 polysiloxane chemistry in AIM coatings.

 Polysiloxane Topcoats

    Topcoats have been formulated with both pure polysiloxane and polysiloxane/organic hybrid
binders. Table 4 describes the formulations that exploit the ultraviolet resistance of the siloxane bond.
These formulas have similar appearance to  polyurelhanes.  Table 5 outlines the formulas' characteristics.
The UV resistance of both these formulas has proved during accelerated weathering tests to be more
resistant than traditional organic based topcoats (See Figure 2). Another interesting property of these
polysiloxane coatings is their inherent compatibility with inorganic zinc silicate (IOZ) primers. As dis-

                                              274

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 cussed previously, IO2 primers have superior corrosion performance properties, but limited compatibili-
 ty with organic topcoats. Traditionally, a 3 coat system utilizing an 1OZ primer has been used as a high
 performance system in the protection of steel in aggressive industrial atmospheres (See Table 6). The
 epoxy midcoat is used to tie the IOZ primer to weatherable topcoats that cannot be applied directly to
 this primer. The compatibility of the polysiloxane topcoats with the IOZ primers allows a 2 coat system
 with obvious advantages (See Table 7).

 Water Based System

     The above system describes solvent borne topcoats.  An alternative to the 2 coat system above is a 0
 VOC water based system. IOZ primers are available for both systems that contain 0 VOC This technolo-
 gy has been used to formulate a 0 VOC pure polysiloxane, water based topcoat. As with the previous
 system, the topcoat is very compatible with the IOZ primer.  This system will provide corrosion protec-
 tion equivalent to the organic and solvent based polysiloxane system. The finish of this topcoat is flat
 and so is not usable where a gloss finish is requested. However, this product will maintain its finish and
 not chalk or discolor much longer than organic finishes.  Table 8 shows the coating characteristics of this
 product.

 Heat resistant Polysiloxane Coating

    Compositions that contain  pure polysiloxane binder networks have been formulated that provide
 maximum heat and/or chemical resistance Heat resistance in excess of 1100°C (2000°F) can be achieved.
 Typical formulations will contain micaceous iron oxide (MiOx) as the major filler component; the most
 successful formulations have the binder to filler ratio as near as possible to the CPVC Table 9 gives a
 description of this type of formulation. Figure 3 shows thermogravimetric anaylsis for this type of formu-
 lation and Table 10 gives the coatings' characteristics. The weight loss over the temperature range is
 around 10%; this accounts for the loss of the organic substituent groups, absorbed water and residual sol-
 vent. The remaining film maintains mechanical integrity and continues functioning as a barrier coat
 even after high temperature exposure. Table 11 is a summary of representative properties of this type of
 formulation*. Typical applications would include stacks, the exterior of reactors and on piping under
 insulation. There are no equivalent organic coatings with this level of performance. The closest heat
 resistant ambient cure products are silicone alkyds. Their temperature resistance can be as high as
 1000°F but their VOC content is generally above 400 grams/liter.

 Chemically Resistant Polysiloxane Coating

    The same binder system can be used with an optimized pigment package to achieve chemical resis-
 tance of a scope not given by organic systems (See Table 11). Indeed, because this type of formulation is
 essentially inorganic, it behaves like a zinc silicate without the acid exposure and chemical reactivity lim-
 itations. Table 12 describes the coatings characteristics. Polysiloxane tanklining prototypes are resistant
 to virtually all solvents, organic acids and mineral acids in certain concentration ranges.  However, pure
 polysiloxanes are not resistant to alkali.  Table 13 is a summary of the representative chemical resistance
 of this type of formulation. Tank linings based on organic binders are available. Ambient temperature
 cured organic systems generally have good alkali resistance, but only moderate to poor resistance to sol-
 vents and acids. These products are available in low VOC content formulations, however, to approach
 the resistance of the polysiloxane to solvents and acids, force cure of bake systems are necessary. These
 systems are generally higher in VOC content and often include aromatic amine hardners that present
 toxiciry problems during application.

    In ongoing formulation work, epoxy/polysiloxane hybrids have been developed that cure at room
 temperature and combine the resistance of polysiloxane to acids and solvents with epoxies resistance to
alkali. These coatings have shown the best combination of chemical resistance.

                                              275

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CONCLUSIONS

    In summary, it should be emphasized that a new formulation chemistry has been described. The
products used as examples typify the first generation of oxysilane and polysiloxane based systems. This
chemistry offers the opportunity for quantum improvements in such performance areas as heat, chemi-
cal, ultraviolet resistance and durability.  This chemistry allows the retention of desirable properties in
existing systems while enhancing those areas needing improvement.  The use of this chemistry is consis-
tent with the need for developing high performance AIM coating systems that offer reduced environ-
mental, health and safety hazards.
REFERENCES

1.   Brown, L.H.; 'Treatise on Coatings"; Myers, R.R.; Long, J.S., Ed.; Marcel Dekker, Inc.: New York,
    1972; Vol. I, Part III. Chapter 13.

2.   Finzel, W. A.; "Properties of High Temperature Silicone Coatings." Journal of Protective Coatings and
    Linings, 1987,4,38-43.

3   Law, G.H.; Gysegem, A.P.; US Patent 4113665,1978.

4   Gasmena, R.L.; Brea, Calif., Oct 1991, Ameron Technical Report 99/91.
                                             276

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                                          TABLE 1
                                         Terminology

 Silicon         The element (Si)

 Silane         Substituted silicon compounds

 Oxysilane      Silicon compounds with at least one substituent an alkoxide, hydroxide or aryloxide

 Silicate        Metal salt of silicon-oxygen anion

 Silica          Sand; silicon-oxygen compound

 Siloxane       Compounds with 2 or 4 oxygens bonded to silicon

 Polysiloxane   Polymer with silicon-oxygen backbone

 Silicone        Polysiloxane with organic substiruents on each silicon, typically 2

 Organic        Carbon based compounds; polymers with carbon-carbon units with backbone
                                           TABLE 2
                                    Comparative Properties
                                 Inorganic and Organic Binders

1.   Binder Backbone
 \   /
-C-C-  83Kcal/mole
 /  \
 \
-Si-O-  106Kcal/mole
 /

2.   Si-O is UV resistant

3.   Si-O is already oxidized

4.   Si-O is not combustible
                                             277

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                                            TABLES
                                      Advances in Siloxane
                                       Coating Chemistry
                       • Low/Ambient Temperature Curing

                       * Silicone Intermediates

                       * Oxysilane Prepolymers

                       * Formulation Technique

                       * Inorganic/Organic "Hybrids"
                                           TABLE 4
                                   Pure Polysiloxane Coating
                                        Topcoat Formula
                                          Description

 1.  Binder     Pure Polysiloxane Backbone
               Silicon Substiruents Selected /Balanced for UV Resistance and Film Properties
               Cross Link Density Balanced for Film Properties
 2.  Pigment   Selected for Appearance
               Full Gloss Range
                      High, Semi, Flat
 3.  Curing     Ambient Conditions
               Single Package
               Catalyzed Hydrolytic Polycondensation
                                  Hybrid Polysiloxane Coating
                                       Topcoat Formula
                                          Description

1.  Binder     Mixed Polysiloxane - Acrylic Backbone
               Silicon Substituents Selected /Balanced for UV Resistance and Film Properties
               Acrylic Selected for Appearance, Physical, Mechanical Properties
               Cross Link Density Balanced for Film Properties
2.  Pigment    Selected for Appearance
               Full Gloss Range
                     Full, Semi, Flat
3.  Curing     Ambient Conditions
               Catalyzed Polycondensation

                                             278

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                                           TABLES
 Characteristic
Pure Polysiloxane
Topcoat
Hybrid Polysiloxane
Topcoat
Number of Components
Volume Solids, %
VOC, grams/liter
Dry to Touch, hrs at 70°F
Dry Through, hrs at 70°F
Application
1
86
129
2
6
Spray, Brush
and Roller
1
85
122
2
8
Spray, Brush
and Roller
                                          TABLE 6
 A.  Inorganic Zinc
    Silicate Primer

    Corrosion
    Control
       Epoxy
       Midcoat

       Adhesion
       Promoter;
       Tie coat
       Polyurethane
       Topcoat

       Appearance
       Weatherability
    Three coats required to make the organic coatings, notably polyurethane, compatible with IOZ
B.  Inorganic Zinc
    Silicate Primer

    Corrosion Control
       Polysiloxane
       Topcoat

       Barrier
       Appearance
       Weatherability
• Two coats because polysiloxane is inherently compatible with IOZ
• No need for epoxy midcoat to make system compatible
• Epoxy film not needed for corrosion control; IOZ is sufficient
                                             279

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                           TABLE?
               lOZ/Polysiloxane System Advantages
Better weatherability

Same corrosion resistance as three coat

Less manufacturing touch-up/repair

Faster manufacturing turn-around

Lower VOC emissions

Reduced waste generation/disposal
                           TABLE 8
            Coating Characteristics of Pure Polysiloxane
                      Water Based Topcoat
       Components                 1

       Volume Solids, %             43

       VOC, grams/liter             0

       Dry to Touch, hrs at 70°F       0.25

       Dry Through, hrs at 70°F       12


       Application                   Spray
                            280

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                                          TABLE 9
                                     Polysiloxane Coatings
                             Heat and Chemically Resistant Example
                                         Description

1.  Binder     Pure Polysiloxane Background
               Phenyl and Mathyl Substituents to Balance Properties
               Oxysilane Cross Linking to Maximize Heat and Chemical Resistance
2.  Pigment    Micaceous from Oxice
               Level to Maximize Heat Resistance
                      or
               Silica/filler Blend to Maximize Chemical Reistance
3.  Curing     Ambient Conditions
               No Baking
               Hydrolytic Polycondensation
                                          TABLE 10
                                    Coating Characteristics
                                 for Heat Resistant Polysiloxane
                             Characteristic

                             Components                 2

                             Volume Solids, %             90

                             VOC, grams/liter             96

                             Pot Life, hrs                  6

                             Dry to Touch, hrs at 70°F      1

                             Dry Through, hrs at 70*F      24


                             Application                  Spray
                                             281

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                                      TABLE 11
                                 Polysiloxane Coatings
                                 Heat Resistant Formula
 1.  Salt Spray
           5000 Mrs
           Blistering (ASTM D714)
           Corrosion (ASTM D1654)
           Scribe (ASTM D1654)
           Adhesion
 2.  Heat Resistance
           TGA - Total Weight Loss, to 1000°C
                  10%
           Torch - 1510°C, Discoloration
 3.  Condensing Humidity
           4500+Hrs
           Blistering
           Corrosion
           Adhesion
4.  Atlas Cell (Salt and  Deionized Water)
           1000 Hrs
           Vapor Phase
           Liquid Phase
5.  Chemical Resistance (Representative)
           Immersion at 25°C, (Test time, hrs.)
                  Acetic Acid
                  50% Sulfunc Acid
                  19% Hydrochloric Acid
                  Acetone
                  Mathylene Chloride
                  JP-4
                  Xylene
10
9
10
Excellent
10
9
Excellent
Pass, No Blisters
Pass, No Blisters
(4000)
(4000)
(3000*)
(8000)
(8700)
(1200+)
(8700)
                                         282

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                    TABLE 12
             Coating Characteristics for
          Chemically Resistant Polysiloxane
 Characteristic

 Components                        2

 Volume Solids, %                    80

 VOC, grams/liter                    99

 Pot Life, hrs                        6

 Dry to Touch, hrs at 70°F             1

 Dry Through, hrs at 70°F             24


 Application                        Spray
                    TABLE 13
               Polysiloxane Coating
                Immersion Formula
         Representative Chemical Resistance
Acetone
       Ketones
Methanol
       Alcohols
Xylene
       Aromatics
Methylene Chloride
       Chlorinated Hydrocarbons
Fatty Acids
Acetic Acids
       Organic Acids
Triethanol Amine
50% Sulfuric Acid
83% Phosphoric Acid
10% Nitric Acid
10% Hydrochloric Acid
Not Resistant to Alkali
                       283

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                                   \
                                   -Si-OH + ROH
   \
2 -Si -OH
Figure 1.              Hydrolytic Polycondensation of Oxysilane
                                           284

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                     §§82811 8§f  §
                       Time (Hours)
•ipolysiloxane

*SiliconeAlkyd

^Epoxy
2 Acrylic Polysiloxane

5 SG Acrylic Latex
« Acrylic Polyurethane

Z Alkyd
              Figure 2. Comparison of the accelerated ultraviolet
             resistance (QUV) of various generic classes of coatings
                           285

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 101.0

 100.0
         T1 19.7
         T2 983.4
         Y1 100.0 Wt. %
         Y2 912 Wt %
         AY  -e.8 Wt %
 ti.o
    0.0  ttO.0 tOOjO MOJO 400.0 900.0 tOO.O 700.0 tOO* §00.0 10OO.O
                         Temperature (°C)

Figure 3. Thermogravimetric analysis of heat resistant Polysiloxane
                            286

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                     SESSION 7
HIGH SOOBS AND WATER-BASED COATINGS
                  PAPERS PRESENTED:

     "The Development of Practical Zero-VOC Decorative Paints"
                           by
                     Richard Tuckerman
                     David W. Maurer
                   The Glidden Company
                      Cleveland, Ohio

     "New Environmentally Acceptable Metal Coating Systems"
                           by
                       Peter C. Ryder
                     Technical Director
                Hawking International Limited
                      United Kingdom
                          and
                       Peter L Hope
                     Technical Director
                   LVH Coatings Limited
                      United Kingdom

 "Water-Reducible Polyurethane Coatings for Aerospace Applications"
                           by
                     Patricia B. Jacobs
                 David C. McCiurg (Speaker)
                        Miles, Inc.
                   Pittsburgh, Pennsylvania
                          287

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

     THE  DEVELOPMENT OF  PRACTICAL  ZERO VOC DECORATIVE PAINTS

Richard Tuckerman and David  W. Naurer
THE GLIDDEN COMPANY
925 Euclid Ave.
Cleveland, OH  44115


     The  objective of this paper is to paint a picture of some of
the technical  challenges associated with the development of a
zero VOC  decorative paint.   The development of practical, zero
VOC decorative paints presented The Glidden Company with a unique
opportunity to combine the resources of many groups toward a
common goal.   These included our internal technical teams working
with external  supplier technical groups;  Glidden's corporate
marketing, manufacturing,  and product  regulatory and safety
teams;  as well as the regulatory and  environmental communities
as a whole.

     The  paint industry  has  been in the legislative and
environmental  spotlight  for  several decades now;  Even a brief
review of the  regulatory climate would include the  following
legislation:

     The  Clean Air Act
     The  Clean Water Act (CWA)
     The  Toxic Substance Control Act (TSCA)
     The  Resource Conservation and Recovery Act (RCRA)
     The  Emergency Planning  and Community Right to  Know Act
     (RCRA)
     Solid Waste Disposal Regulations
     State Implementation Plans (SIP)
     State VOC Regulations
     "Regulatory-Negotiation" Process  (Reg/Neg)

     The  paint industry,  as  a whole, has been extremely
responsive and responsible in relation to these requirements.
Often, and more importantly, the paint industry has been pro-
active over an even longer time frame  in introducing products
that are  better, safer,  and  more convenient for the end user.
The introduction of latex paints, electrocoats, powder coatings
and waterborne can  liners are just a few examples.

     The  trend towards waterborne paints over the past three  or
four decades has lead to the present split  of 75% waterborne, 25%
solventborne in the decorative paints  market.   In some segments
of the decorative paints market, ie. wall paints, the percentage
for waterborne paints is even higher,  at least 90%.

     A typical solventborne  decorative coating contains about 45%
solvent,  while its  latex counterpart contains approximately 7%.
However,  when  weighted by the proportion of total decorative
products  made  up of waterborne paints  (at least 75%),  we see  that
the contribution of solvents by waterborne  paints is still
significant.   We estimate that 20% of  VOC emissions from
decorative paints are given  off by conventional latex paints.

                                289

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      It was from this perspective that The Glidden Company viewed
 the opportunities afforded by a joint project with a major latex
 supplier as an opportunity to take action on a significant
 contributor to VOC's.  This would be a first step, placing
 Glidden firmly in the lead in the inevitable drive to remove
 petroleum based solvents from decorative paints.

      The initial challenges of this project did not deal with
 technical issues, but with conceptual ones - the fundamental
 goals and definitions which describe both the project and the
 product.  Working together, Glidden's technical, marketing,
 product safety group, along with the latex supplier developed a
 primary goal that met the recognized needs for real
 accomplishment and commercial success in the marketplace.

      Our stated project goal was nto develop a practical,
 commercially viable zero VOC decorative paint with all of  the
 positive attributes of current solvent containing latex paints."

      The resultant product target became a high quality latex
 semi-gloss wall and trim paint with wet adhesion,  block
 resistance and durability.   We believed that these specific
 qualities were essential elements and would present the most
 rigorous challenge in formulating without solvents.

      To insure a true "break through" technology,  the  Glidden
 team also established rigorous criteria for solvent elimination.
 Not only must the product be free of functional solvents,
 containing none of the coalescing aids or glycols  used in  current
 latex paint technology,  but it roust contain no incidental
 solvents which could be carried into the end product (usually in
 small amounts)  via other paint components.

      The technical challenge could now be clearly  established
 from the goals and definitions reviewed above.   To summarize this
 challenge the target product a high quality latex  semi-gloss,
 must contain no solvents,  incidental or functional,  and roust have
 applied characteristics - e.g.  film build and open time, flow and
 leveling,  low temperature film formation,  adhesion to  hard glossy
 surfaces,  "block resistance," scrubbability and final  appearance
 of  high quality products based on standard latex technology.

      The following is a  discussion of paint  properties  directly
 affected by the two major types of functional  solvents  -
 coalescents and glycols.


      In standard latex paints,  a relatively hard polymer is used
 to  impart film toughness, durability and  lack  of thermal tack to
 the  applied paint film.   This polymer, however, may form only a
marginally  performing film  at normal  application temperatures (75
 degrees F)  and none at all  at lower  temperatures (40 to  60
degrees F) .   A coalescing solvent, which can partially solvate or
 soften the  outer portion of the discreet  latex particles, is
 added so that when those particles come  into  intimate contact
 during the  drying of the paint  film  they will deform and

                                 290

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coalesce,  forming a continuous  film.   These  solvents leave the
film during  the drying process,  thereby imparting no permanent
softening  to the film.

     Glycols,  such as ethylene  glycol  and propylene  glycol are
added to latex paints to modify the  free liquid  phase.  Their
primary  function is to moderate the  rate of  dry  of a paint film
and thereby  impart several  useful  properties to  the  paint.  These
properties are better application  through increased  open or
working  time,  better flow and leveling (both through slowed
evaporation  and modification of surface tension) ,  and improved
gloss.   They can also decrease  a paint's susceptibility to
freeze/thaw  instability during  Winter  transport  and  storage.

     The key to formulation without  these components begins with
the use  of a novel latex that can  form a film at low temperatures
without  solvents yet can be hard enough to promote toughness and
prevent  thermal tack.  Having established that the neat latex
could form a film at low temperatures  without the  use of
solvents,  an initial paint  could be  made.

     The positive properties of this initial  paint formulation
mirrored closely many of the performance characteristics outlined
above.   It exhibited low temperature film formation,  acceptable
gloss, acceptable open time, adhesion,  block resistance, and
durability (scrub) .  This was not  an unexpected  result,  as these
properties are dependant in large  measure on  the quality of the
latex designed.

     The goal, however, was to  produce a practical semi-gloss
wall and trim enamel and several properties were still
substandard.   Chief among these were flow and leveling and
application  characteristics, specifically film build (thickness)
and feel under the paint roller.

     Beyond  these "superficial1*  but critical  attributes were a
host of  other paint properties,  hopefully taken  for  granted by
the end  user,  but of major  importance  to the  paint formula tor.
These include in-can stability  (viscosity changes),  control of
syneresis  (separation in-can),  opacity efficiency  (TI02
utilization),  foam control, and in-can resistance  to
bacteriological contamination.   Each of these additional
properties were judged to be marginal  or deficient in the initial
paint, and it was here that the technical challenge  was most
tested against the zero VOC definition established for the
project.

     The properties mentioned above  are controlled by the
coatings formulator through the use of additives.  These
additives  make-up approximately 5% of  the final  liquid paint.   It
is an understatement to say that the formulation of  modern,
practical  waterborne paints would  be impossible  without these
materials.

     Paint additives which  are  of  primary interest in this
discussion are: rheology control agents including  thickeners  and

                                291

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thixotropes,  defoamers, dispersants, surfactants, and in-can
preservatives.   This list matches-up well with the list of
deficiencies  noted in the initial solvent free paint formulation.

      In many  instances these additives,  common to all latex
paints,  contain solvents themselves.  These are either carriers
for  the active  components, part of the active mixture,  or  merely
residual components from the product synthesis.  The key
formulating challenge was to identify specific additives that
were both effective and solvent free.  This work was a
cooperative effort with raw material suppliers, who  helped
identify or make zero VOC additives and the Glidden  technical
teams use of  several experimental design techniques,  including
full & fractional factorial designs, titration/concentration
studies, and  three & four component mixture response surface
designs.

      In concluding this section covering the challenges  faced in
the  development of the initial  solvent free paint, we can  cite a
specific unexpected consequence of formulating latex products
with no solvent components.   During the  development  work from an
initial paint to the final prototype, the formulating team
discovered a  large number of samples that exhibited  microcracking
upon drying.  This microcracking was followed and observed
throughout the  drying process.   It began as discreet, pinpoint
discontinuities in the wet film that gradually expanded and often
interconnected,  forming the  final cracks.   This manifestation of
destabilization was evaluated in dozens  of samples before a root
cause was found.   It was apparent that the removal of all
solvents and  solvent containing components from the  free liquid
phase of the  paint has a profound effect on the paint's ability
to accommodate  hydrophobic components.   This lack of  "bridging
solvents" in  the free liquid phase influences stability
properties from short-term  storage through to the final
application and dry of the paint film.

      The final  prototype and its matte sheen companion was
rigorously tested with consumers in "blind trials" comparing the
solvent  free  paints with their  conventional  latex counterparts.
Consumers showed a significant  preference  for the solvent free
paints.   An "eggshell" sheen version was created and tested with
professional  painters.   This product branded,  "Lifemaster 2000",
has  been aimed  at the institutional market - hospitals, schools,
etc...

      Beyond achieving the performance milestones which would
assure users  of  no compromises,  these new  Glidden products
"Spred 2000 and  Lifemaster 2000"  bring environmental benefits
leading  the way  for the decorative  paints  industry.  The absence
of solvent emissions is the  technical  underpinning for major
reductions in paint odor.  Of course,  no VOC's are released which
can  react with  nitrogen oxides  in the presence of sunlight to
contribute to urban smog.

      These environmental benefits have been  recognized by a
variety  of organizations including  regulatory, scientific

                                292

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testing, and environmental groups.  Examples include the South
Coast Air Quality Management District 1992 "Clean Air Award",
certification of Spred 2000 as containing "No Smog Producing
Chemicals" by Scientific Certification Systems (Green Cross), and
the National Audubon Society who used Lifemaster 2000 in their
new headquarters building in New York City - a showcase for
environmentally conscious architecture.

     In conclusion, The Glidden Company would like to emphasize
that the development of a practical zero VOC decorative paint,
although a technical challenge, was more importantly a multi-
disciplinary challenge requiring innovations of our technical,
marketing, manufacturing and product safety groups, as well as
outside suppliers, coatings specifiers, and end users.  It is the
recognition of those challenges and the ability to marshall an
organizations resources to create a viable solution, which is the
ultimate and lasting benefit.
                               293

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294

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(The work described in this paper was not funded by the U.S. Environmental
Protection Agency. The contents do not necessarily reflect the views of the Agency
and no official endorsement should be inferred.)
                  NEW ENVIRONMENTALLY ACCEPTABLE
                        METAL COATING SYSTEMS
                                   By:
                     Peter C. Ryder - Technical Director
                                     Hawking International Ltd
                      Peter I. Hope • Technical Director
                                    LVH Coatings Ltd
                                   295

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          NEW ENVIRONMENTALLY ACCEPTABLE METAL COATING SYSTEMS

 In  this paper we are describing a range of decorative  and protective polyurethane
 coating processes for metals which can replace decorative electroplating, anodizing,
 painting  and in  some cases powder coating.   Conventional plating, anodizing and
 painting  processes all produce  environmentally  unacceptable effluents which
 contaminate  local air, water, or both.  Although such effluents can be treated in
 order to minimise the impact on  the  environment, new regulations are making
 treatment costs prohibitive and even  when  compliance  is achieved there  is usually
 some form of waste to dispose of.

 Our processes marketed under  the name of Clearclad and  Anoclad are relatively new
 to  the USA.  Marketing only began here  about  12  months ago.  In spite of this they
 are already well tried and proven processes.   There  are now well over  300
 production lines operating  throughout the world.  A number have  now been in
 production for over  7 years.

 The processes are based on the technology known as Electrophoresis.  This process
 has been known for  well over one hundred  years.  The first extensive use of  the
 process was  in the 1960's  when an anodic  coating  method  for priming car bodies was
 developed by Brewer and the Ford Motor Company.   All the early processes were
 Anodic.  This is  because the chemistry available at the time favoured the production
 of  resins suitable for the electrophoretic deposition onto parts forming the anode in
 the electrical process.  The problem  with  anodic processes is  that, except in  the
 case of aluminium or very  inert metals, making the  part to be coated anodic  in an
 electrolyte causes dissolution and  attack pf the metal  resulting in discolouration of
 the applied  coating..  This may be acceptable for undercoats, but is completely
 unsatisfactory for one coat decorative systems.  These systems only became
 practicable with  the development of cathodic electrophoretic systems within the last
 12  years.  The new  cathodic materials are based on polyurethanes and will give
 clear or  opaque coatings on any metal in a variety  of  colours and effects.  They  are
 quite hard at 3-5H pencil  hardness, wear resistant and have excellent exterior
 durability.

 THE PROCESS
 Electrophoresis is the process which occurs when two electrodes  are  immersed in  a
 colloidal  solution and a voltage is applied  across them.  Current flows and one of
 the electrodes becomes coated  with a layer of the material in the disperse phase.
The electrode coated can be either the cathode or  the anode depending  on the
 charge on the dispersed particles.  Whilst the  process  is driven by the applied
voltage, transport and discharge of the dispersed particles is largely influenced by
other processes.  Transport of  particles is  mainly by thermal and mechanical
agitation and the maintenance of a sufficient concentration of the disperse phase  in
 the colloidal solution.   Discharge and coating formation are strongly  influenced by
discharge of  ions around the electrode,-causing a pH change which destabilizes the
emulsion.  The disperse phase particles around  the electrode lose their charge,
coagulate and stick to the surface of the  electrode.  At the same time, the
continuous phase material trapped in  the layer is squeezed out by electro-osmosis.
The result  is a quite 'dry' electrically insulating layer forming on the electrode.
Once the easily accessible areas  are  coated, the high resistance of the coating
                                     296

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causes the current to be diverted to uncoated areas until the entire surface of the
electrode is covered.  There are,  however, limits to this process.  The two processes
of electrophoresis and electrolysis are,  in  some respects, competing.   For this
reason, the continuous phase (water in  most cases) must have quite  a  high  resistance
or all  of  the applied voltage will  go to drive electrolysis instead of electrophoresis.
This in practice  means that the water, which is the continuous phase, must be of
high purity and relatively free from dissolved ions.  Because of  the  high  resistance
of the disperse phase, the  applied voltage can only.drive the deposition current over
a limited distance.  This can  be  increased by increasing the voltage, but again  there
is a limitation.  Any coating can only resist a limited voltage.   Once  this is
exceeded,.the  coating breaks  down,  the current  increases,  the  increased local current
causes local heating of  the solution and coating causing film rupture.
Electrophoretic coating  materials are carefully formulated  to give  maximum throwing
power, but this must  be consistent with the wet coating having  sufficient
conductivity to enable the required  film thickness to be built up.  The current  state
of the art enables thickness of 25 to 40  microns to be coated, whilst giving very
good throwing  and covering power;  much better than can be achieved with
electroplating.
The  two  subdivisions of electrophoretic coating  are  anodic and cathodic processes.
This refers to  whether  the article to be  coated is made the anode or the cathode.
The  chemistry  involved  in  one is in effect the mirror image-of  the other, but  is
easier in the'^case of anodics which accounts for their longer industrial history.
Each process 'has some  advantages over the other,  the main distinction being that  the
anodic version is limited to coating some  specific metals,  (e.g.  Aluminium, Gold
Plate), whereas  the  cathodic  version will  coat any metal.
PROCESS MECHANISM
The material is  supplied as a resin  concentrate  at 50-65% solids which contains all
necessary materials to make up a new  bath or replenish an  existing one.  The only
additional materials  needed are dyes, pigments,  matting agents,  etc., designed  to
modify the finish.
This concentrate contains:-

      The main resin  binder modified to render  it water dispersable
      A water  miscible solvent
      A blocked  cross linker
      Catalyst
      Water immiscible solvent
      Surface  active  agents, Emulsifiers
      A  material  to provide the counter ion and give the  water
      phase a  limited low  level conductivity

When  this material is mixed with water it separates into  two phases.  The
undyed or unpigmented material has a 'milk" like appearance due to the light
scattering properties of the disperse phase.

Our current processes employ blocked  isocyanates as cross-linkers.  These  materials
do not develop  isocyanate activity  until  elevated temperatures  are  reached and the
blocking agent is split  off by the action  of heat.   We have a  range of processes
employing different cross-linker/blocker systems.   The unblocking temperatures vary
from  120"C to 147'C.  At these temperatures,  the activated isocyanates react with
the co-resins  to form a polyurethane.  The inert nature of the blocked  isocyanate  at
room  temperature ensures long term stability of the  concentrated product  and the
                                            297

-------
made up solution.   In some cases the systems also employ a catalyst which  speeds up
the  rate of  reaction and  this enables good cures  to  be obtained at quite moderate
temperatures.  The coatings  cure in  the  range of 130-160*C, the cure times being
about  15 minutes at metal temperature.
The  resin system can be used alone  and  unmodified to give clear,  transparent,  almost
invisible coatings which can  be used to protect and  preserve  the  underlying metal,
e.g.  on polished  brass, electroplated  silver, etc.
The  transparent  resins can also be dyed  to  give a wide  range  of  transparent colours.
These  allow  the  metal to show  through but  modify its colour.   In  this way, silvery
white  basis  metals  such as Aluminium,  Zinc, Nickel,  etc. can be made to look like
gold, brass,  copper, pewter,  etc. or can  be  given  completely artificial colours e.g.
green, purple, orange etc.
The  resin can also  be modified  by adding opaque  pigments to produce a wide range
of solid  colours, and black and  white.  These coatings completely  hide the basis
metal.  They, and indeed  the transparent colours, can in  addition  be modified to
produce  varying  degrees of gloss.
The  process  can be used  in many ways.  It can be  applied  after silver plating  to
give a clear, invisible coating  which prevents tarnishing  and resists wear.  It means
that drying  stain problems are eliminated, and much  thinner durable coatings can  be
applied.   Cost savings are effected by reducing the  typical silver thickness over the
bright nickel plate  to 0.2 microns.  A  fully  automatic plant using  this process has
been in  operation for over 7 years.
It can also  be applied over polished brass.  The coating thicknesses applied have
varied from  about 8 microns on  items  like photoframes to 20  microns on brass  door
furniture where  it is required to  resist wear,  weather and sunlight.
A very interesting application is the use of dyed  coatings to simulate brass,  copper,
bronze and gold. These can be  applied directly over polished  zinc diecastings
completely eliminating plating operations. This then avoids the use of toxic  chemicals
like  cyanide, acids, alkalies and  metal  salts.  The problem of spotting out due  to
chemicals trapped in pores is also eliminated.  The speeding up, simplification,  and
reduction in  steps in the  process is shown in  figures  It  2 and  .3.
Steel can be either coated direct, or  where brightening  and levelling is required  it
can  be preplated with a bright  levelling  acid  zinc.   This  can  then be coated with
brass,  copper or gold coloured Clearclad to give  the  required finish.  If solid colours
are required, the steel is either coated direct or if  maximum corrosion resistance is
required then a  phosphate pretreatment is applied.   One current application is  on
steel outboard motor parts, which in service are  partly immersed  in sea water.
Coatings carried out on aluminium vary from  brass and gold colours to black, white,
brown  and bronze  colours.  25 micron  coatings  on aluminium extrusions meet all of
the requirements of British Standards,  BS 4842 and  the  relevant parts of BS 6496.

Environmental Considerations

Our  processes described in this paper  were  designed to be  environmentally friendly.
In this respect all  of the materials used in the process  were reviewed from two main
viewpoints:
1.  Do they  prevent a hazard  to the environment?
2.  Are they hazardous  to human beings  working  with them or using the product?
The  materials used  have been  constantly reviewed and already  some changes have
been made in formulations .in view of  later discoveries  about  the nature  of certain
materials.  We can confidently  say that  the materials currently used are all the
safest available  in both respects.
                                          298

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The  second aspect is efficient  usage  of  the materials  in the process.  This must be
considered in several ways.

1.  Losses from the coating evaporation  and oven  curing:
The  coating  solution is at least 84% pure water.   Of the remaining  16% just over
half  is resin solids and other non  volatiles  which coat out on  the  work and form  the
final coating.  Of the other  8% (maximum)  5% is  the water miscible solvent which
almost entirely remains in the  bath.  The  remaining  3% is  the  water immiscible
solvent which largely deposits  with the  resins onto the part (some passes into the
water phase due to the coupling effect  of  the  water miscible  solvent).  When all
solvents are extracted  from the coating we get a "worst case" measurement of 0.9
Ib/gal which renders the process compliant in all areas of all  states.  In practice
not  all of this material is evolved in oven  curing; some remains in the coating.  We
are  working  on improving on even this by using more  reactive diluents.
Losses from  the  bath by  evaporation  are negligible.   The vapour pressure of
materials used is very low - the most volatile material in the bath is water.
Extraction over  the bath is not generally  necessary.

2.   Losses from  the coating bath  by  drag-out
When work exits the coating bath some of the coating solution is dragged out with
it.   The amount  depends on the shape of the work.   The  drag-out tank immediately
following the Clearclad  tank employs a  spray rinse on entry and exit  to ensure
efficient removal of the  uncoated solids.  This material is returned to the coating
tank by ultrafiltration.   This is shown schematically  in Figs.   4,5  and 6.   Ultrafiltration
is a  membrane separation process which separates the disperse phase from the
continuous phase.  The Clearclad  solution is  continuously  circulated through the
ultrafiltration  tube.  Water plus water miscible and  soluble components permeate
through  the  membranes.   This  permeate is  fed  into  the drag-out tank which flows
back into  the  coating tank  thus recovering the dragged out solids.  Long term audits
on  industrial plants have shown that better than 98%  of the material  added to the
tank is coated onto  the  work.   The  application efficiency of  the  process is clearly
illustrated by the fact that no rinses running to drain are used after coating.

The  ultrafiltration process is also used  to  continuously purify the coating solution.
Without this water soluble contaminants dragged in  by the work,  on jigs,
contaminants in  the water,  dissolution of  fallen components etc will raise the
conductivity of the ultra pure  water used.   This will favour electrolysis  over
electrophoresis causing gas  production and disrupting  the  coating.  This is prevented
by passing the permeate through  a special ion exchange  trap  which continuosly
removes impurities.

The  final  rinse in the  rinse  aid tank which  contains a special wetting agent  removes
much of the water and prevents dewetting.  This final rinse  aid  bath needs  changing
only every few  months.   Alternatively it can be slowly bled to drain with the
composition  maintained by constant top-up.

A standard Ultrafiltration unit suitable  for process  tanks up to 1200  litres produces
50-60 litres of permeate per hour.   To maintain the  balance  of the bath it is still
necessary to dump a little  permeate but this is  never normally more  than 5% of  the
total permeate production.
If all of the permeate were dumped the maximum possible contaminants  in it would
be  dissolved impurities  (anions & cations)  20 ppm,  pH 4.2 (mainly due to lactic  acid
                                           299

-------
- a by-product of the anodic reaction), disperse phase  solvent 0.4%, continuous phase
solvent 4.0% i.e.  total solvents 4.4%.  The maximum  rate  of  effluent production  will
be 60  L/Hour.  In a typical factory doing even minimal finishing operations one
would  expect an absolute minimum  of  3000/L of water per hour to be continuously
discharged from the plant.
This would give effluent water  'contaminated'  with  a maximum possible of:-

Total solvents 4.4 X 60 = 2.64L in  3000L of water = 0.88  mls/L  :
              100
Resin solids  :- zero.

Dissolved  ions (anions & cations) 20 = 0.33  ppm
                                 60

In normal operations not more than 5% of permeate  is  dumped.  This reduces  the
above  figures to 0.044 mls/L solvents  and 0.016 ppm dissolved ions.  The  total
dissolved ions figure is.  well below  all effluent limits we  have encountered. The
solvents are all easily biodegradable.
With further improvements we  hope to eliminate the dumping of permeate.  This will
almost  practically eliminate water pollution.

We commissioned  a  study of EPA VOC Regulations by an  Environmental Consultant at
the University of Illinois.  This has reviewed  the process against regulations in
detail  in 10 States  (including  California  and the San Fransisco and L.A. Bubbles).
The study has revealed  that "In all cases,  in all States investigated, in all areas of
the State, at all  levels  of production, for new and  existing  sources, Clearclad was
found  to be compliant with all  air  pollution regulations, with a very comfortable
margin".

In addition to this experience has shown that not only can the process meet  effluent
water  regulations, but that it can do  so  without any effluent water treatment.

Applications of Clearclad  Coatings

Some advantages  of Electrophoretic coating systems are given  be tow.
1.       No  runs, tear drops,  sags, or windows in the cured film.
2.       Superior adhesion.
3.       Precise  thickness control.
4.       More uniform product therefore more accurate prediction of corrosion
       .  life of coated components.
5.       Excellent coverage with  good  penetration  on to recesses and blind
         holes.
6.       Low concentration  of solvents in a water  based application system thus

         * No fire hazard
         * No need for flame proof equipment
         * Low toxicity
         * Environmentally friendly
                                        300

-------
7.        Low  curing  temgerature

          *Saves on heating  costs
          * Plated parts can be cured  on same jigs  without damage to jig
           coatings
          *No drying is necessary therefore the major problems  of drying
           stains is eliminated

8.        With  the  ultrafiltration recovery  system the ultra high
          efficiency of the process  means that 97-98% of  the material
          purchased  is coated on  to the  components.

9.        High  efficiency means  that  the process is virtually a closed
          loop system and is  non polluting.

 10.       Use of ultrafiltration means that dragged in impurities are
          easily removed.

 11.       Coating baths are  extremely stable and have very long life.
CLEARCLAD APPLICATIONS

 A list of current Ciearclad Industrial  Applications by Industrial  Sector, process and function
 are as follows:

          1.1.  L/oor «t winaow furniture i.e.  Door  & Window
                handles, locks, fasteners,  hinges, etc.
          1.2. Tableware  & holloware
          1.3. Bathroom fittings
          1.4. Car alloy wheel
          1.5. Bicycle parts
          1.6. Other  car  parts - exterior - interior underbonnet
          1.7. Giftware  & fancy goods
          1.8. Buttons (mettalic  only)
          1.9. Trophies (cups.shields,  metals  etc.)
          1.10.Spectacle  frames
          1.11.Metal parts for leather goods industry (shoe buckles,
               comers, etc.)
          1.12. Metal furniture & metallic parts for non metal
                furniture
          1.13. Kitchenware
           1.14. Household goods
           l.lS.Electrical  goods
           1.16. Architectural extrusions
           1.17. Architectural metal cladding
           L18. Display stands
           1.19. Costume  jewellery
           1.20. Toys

 2.   BY  PROCESS

          Ciearclad is frequently used over  the  following plating processes:

          2.1. Nickel plating
           2.2.  Brass  plating


                                        301

-------
         2.3.   Silver platiifg
         2.4.   Cold plating
         2.5.   Copper plating
         2.6.   Bronze plating
         2.7.   Bright tin plating
         2.8.   Nickel-chromium  plating
         2.9.   Zinc plating

         It is  also used directly on the following basis metals which
         have  been prepared by  -  polishing,  electro  or chemical
         polishing vibratory or barrel finishing

         2.10.  Brass
         2.11.  Silver
         2.12.  Bronze
         2.13.  Copper
         2.14.  Aluminium
         2.15.  Zinc Diecast (Mazak - Zamac -  Etc.)
         2.16.  Stainless steel
         2.17.  Some  other ferrous  alloys

         These materials can  be forged,  extruded, sheet (rolled),
         cast etc.

3.  BY FUNCTION

         Clearclad can be  used  either clear, coloured  or pigmented to
         make it opaque.   It  can be used  indoors or outdoors.

*        It can be used to produce excellent imitations of  more
         materials  e.g. dyed to  simulate  gold or brass; clear over
         bright tin to simulate silver; flash silver (0.2 micron)  to
         simulate  high  quality silver plate  or solid silver  (no
         tarnishing)
*        It can be used to produce vivid metallic colours which cannot be
         equalled.
*        It can be dyed to simulate copper
*        It can be dyed or pigmented to simulate black wrought iron.  In
         all cases it gives excellent wear  and corrosion resistance

A  Comparison  of Brass plated and  Lacquered  Zinc Die castings with Brass Coloured
Clearclad Coated  Zinc Diecastings from  an environmental viewpoint

1.  Traditional Brass  Plate & Lacquer (See  Fig.  1)


2.  Brass Coloured Clearclad  Coating (See   Fig. 2)


Life of Product

The life of the product depends very much on  the  finish and  its ability to stand up
                                         302

-------
to its environment.   Many  factors come into      this but two important ones are
corrosion resistance and  wear resistance.  Realistic accelerated tests for these  and
other properties are  difficult to devise but two  generally accepteo ones are

1.  Salt Spray  for corrosion  resistance  ASTM  B117

2.  Falling  Sand for  abrasion resistance    ASTM D968

The  following are comparisons obtained on typical production brass finished zinc
diecast handles:

                          Brass  plated  & lacquered    Clearclad Coated

Salt Spray  ASTM          24 -  96  hours              250 - 500 hours
Abrasion Resistance         2-5 litres                 30 - 40 litres

We have customers who are proposing to give 5 and in some  cases 10 year
guarantees  on  Clearclad coated  parts.  We feel  it is very  safe  to say that the  life
expectancy  of  our coated handles will be at least three times that of brass plated
items.  It  therefore  follows that the requirement to meet  market demand is one third
when Clearclad is used.  This alone will reduce  pollution by two thirds before any
other considerations  are  made.

Reclamation of  Scrap parts

Re-melting  plated zinc diecastings results in contaminated  zinc  alloy  due to the
metals with which they have been  plated.  Re-melting Clearclad coated parts burns
off the organic coating leaving  the diecasting alloy uncontaminated.

Some figures from an actual manufacturer

The  following are some figures from  a  manufacturer of zinc diecast  hardward
(handles etc).   The thickness of Clearclad coated is 20  microns (0.8 mils)  plus/minus
2 microns.  This thickness  was chosen because on most substrates (including zinc
alloy diecastings) the corrosion  resistance improves with increasing thickness up  to
15 microns  (0.6 mils).  This thickness is also sufficient to give good enough abrasion
resistance to give a  long enough life to most  components.

this customer  consumes 1900 litres/Kgms (Density=l)  per year.   At 20  microns  (0.8
mils)  thickness  one litre  of concentrate  covers  250 square feet of  work.  A typical
handle is about 0.1  square feet  (14.4 sq.inches).

Practical experience over a one  year period during which  1900 litres of Clearclad
concentrate were used showed the follow ing:-

Handles coated 	4,750,000
Total solvent added to the tank  (all  water phase, very little of which  goes into the
air as VOC)	125 Kgms.
TRAP ion exchange cartridges used 	52  (Approx.one per working week).
Cost of solvent added plus trap  cartridges used  as a  proportion of total Clearclad
materials cost	4.6%
                                      303

-------
TOTAL  POLLUTION  PRODUCED BY  THIS  PLANT

1.  VOC evolved on oven curing : Meets strictest regulations.
2.  Evaporation from tank : Negligible
3.  Effluent water pollution:  Very little -  no effluent treatment necessary
4.  Scrap components :  Very few
5.  Disposal of  bath  material : Not  required bath life is indefinite.   (In the
  event of a catastrophe bath is easily treated for disposal).
6.  Remote pollution  e.g. as represented by electricity generation  is low.
    Coating power consumed  is very small.  Tank heating not necessary.
    Oven curing is at lower than usual temperatures.

i.e. Pollution in all respects is LOW!
                                       304

-------
1,   Traditional Brass Plate & Lacquer

    Polish &  Degrease
STEP

1.
2.
3.

4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.


PROCESS

Soak Clean
Electro Clean*
Running Rinse
.
Acid Dip
Running Rinse
Cyanide Copper Strike*
Running Rinse
Copper Plate*
Running Rinse
Acid Dip
Running Rinse
Nickel Plate*
Nickel Dragout
Running Rinse
Cyanide Dip
Brass Plate*
Running Rinse
Neutralize Dip
Running Rinse
Hot Rinse
Dry
Lacquer
Oven Cure
Total Process Time • 72
Mins.
PROCESS TIME

2.0
1.0
0.5

0.5
0.5
1.0
0.5
10.0
0.5
0.5
0.5
12.0
0.5
0.5
0.5
2.0
0.5
1.0
0.5
1.0
2.0
3.0
20.0
61.0 *

T/T

0.5
0.5
0.5

0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5

11.0

HEATING^;

60-70*C
60*C
-

-
-
-
-
-
-
-
-
50-60*C
-
-
-
?
-
-
-
70*C
Hot Air
-



POLLUTED AIR
EXTRACTED
Yes
Yes
-

-
'
Yes
-
Yes
-
-
-
Yes
-
-
Yes
. Yes
-
-
-
-
-
Yes

POLLUTED WATER
TO DRAIN (POLLUTANTS

-
Na.Alkali .Silicates, Phosphates,
Wetters!
-
• Zn.SO , F
T
CN'.Cu.Na.Alkalai
-
Cu, CN1 or SO. or Pyrophospha
-
Acid (SO )
"t
-
Ni,S04,Cl,Borates,Brighteners
-
-
Cu, Zn.CN.Na.Cl
-
-
-
-
-

T/T • Transfer Time

* 5 Rectifiers employed all  using electric power
There are seven water polluting steps, some alka\lne, some acid.   These have to be  treated separately.  This is expensive, consumes
more power,  and produces toxic sludges which have  to  be disposed of  usually in land fills  « more remote pollution

-------
      2.   Brass- Coloured Clearclad Coating

         Polish & Degrease  as  before
STE;P
1.
2.
3.
4.

PROCESS
Clearclad Coat
Dragout Rinse
Rinse Aid Rinse
Oven Core
Total Process Time «
24.5 Minutes
PROCESS
TIME
2.0
0.5
0.5
20.0
23.0
T/T
0.5
0.5
0.5
-
1.5
HEATING
20-25'C (1)
-
40*C (2)
160*C

POLLUTED AIR
EXTRACTED
_
-
-
Yes

POLLUTED WATEI
TO DRAIN
.
-
Absolutely minimal
-

(1)   Clearclad Tank may require  slight heating or cooling depending upon the ambient temperature.

(2)   Optional :  Heating is only to speed  up drying  and preheat for oven.

Note:  The  plating process require  7 times as many tanks.  This equals  approximately the  same ration  of  factory  floor
       space.  This in turn  reduces requirement for heating or cooling and other associated  costs.  This also  reduces
       power consumption and  remote pollution.

-------
                                                 Fig., JL
                           EXAMPLES OF SIMPLIFXING  SEQUENCE  BY USING  "CLEAHCL.AD'
Substrate
Zinc Dlecastlng
Zinc Dlecastlng
Steel
Dr aaa
Steel
Aluminium
Aluminium
Surface Finishing
Required
Drass Plating
Antique Draas
brass Plating
Gold Plating
Gold Plating
Dras*a Plating
Gdld Plating
Electroplating
Sequence
Pretreatment - Cyanide Copper -
Acid Copper - Nickel - Grass -
Spray Lacquer
Pretreatment - Cyanide Copper -
Acid Copper - Nickel - Drass -
Black Nickel - Polishing -
Spray Lacquer
Pretreatment - Cyanide Copper -
Acid Copper - Nickel - Brass -
Spray Lacquer
Pretreatment - Cyanldo Copper -
Nickel - Gold
Pretreatment - Cyanide copper -
Acid Copper - Nickel - Gold
Not usually done.
Not usually done.
Tlmo
45 Mln.
45 Mln.
35 Mln.
25 Hln.
30 Mln.


Clearclad Coating
Sequence
Pretreatment - Brass
Colour Clearclad
Pretreatment - Blackening -
Polishing - Drasa Colour
Clearclad
Pretreatment - Zinc - Brass
Colour Clearclad
Pre treatment - Red Colour
Clearclad
Pretreatment - tllckel -
Silver Strlko - Gold Colour
Clearclad
Pretreatment - Brass Colour
Clearcl ad
Pretreatment - Gold Colour
Clearclad
Time
< 6 Hln.
0 Hln.
IS Hln.
6 Mln.
10 Mln.
6 Hln.
6 Mln.
Note :  1.  Pretreatment for electroplating la more complicated and time conauming.
       2.  Stoving time la nob Included In both cases.

-------
                                           Ills,  ii
                    SCHEMATIC DIAGRAM OF  CLOSED-LOOP  ELECTROPHORETIC  SYSTEM  INCORPORATING  "TRAP"
U)
o
00
                                     1. BATH MATERIAL IS PUMPED THROUGH THE
                                        ULTRAFILTRATION UNIT.

                                     2. THE FILTRATE (PERMEATE) IS PASSED TO:

                                     3. ION EXCHANGE UNIT TO REMOVE METALS AND
                                        OTHER IONS.

                                     A. THE RETENTATE IS RETURNED TO THE BATH.

                                     5. SOME PORTION OF THE TREATED PERMEATE
                                        MAY BE DUMPED.

                                     6. THE MAJORITY OF PERMEATE MAKES UP THE
                                        DRAG-OUT BATH.

                                     7. THE INCOMING PERMEATE DISSOLVES AND
                                        COUNTER-FLOWS DRAGGED-OVER SOLIDS
                                        BACK INTO THE COATING BATH.

In this way the ultrafiltrate and its corresponding retentate are re-combined
in the coating bath. On the way the permeate has been purified of foreign
contaminants and has been used to reclaim dragged-out solids. In this way,
minimal permeate is dumped and the system retains its operating volume. The
combination of Ion Exchange and Ultrafiltration in this closed loop concept
is called TRAP - Total Reclaim And Purification.

-------
                             Fig.  5.
Concentrate
                                                          ~).  fed Solution
       Hollow Fiber principle shall geometry
       Exploded ineiv of membrane surface
                                309

-------
                ULTRAFILTRATICN  SYSTEM
        TRAP CARTRIDGE
  CUTLET TO
S==L
   DRAXLTT TANK
26.5-C5 CXH U/F TUBE.
                                  0
                              (LL
                  i—IN
                                 4
                                  'I
          f-
1
1
I
1
1
1
1
1
1
t
-1
—I**
1
1
1










                                              3/1- CONTROL
                                                   VALVES.
                       PUHP TYPE 70/5
      INLET.
 FRCM CLEARCLAD T/>NK
                                                   ^ SOLUTION OUTLET.
                                                         U/F TO WASTE.
                                               CONTROL YALYE.
                                 310

-------
                       £!&.*.

COATING SOLIDS/NON-VOLATILE MATTER VS. VOLATILE ORGANIC MATTER

                            AS SUPPLIED/ItTBATH        DEPOSIT

COATING SOLIDS                     1000                 1000

WATER MISCIBLE SOLVENT              700                   10

WATER IMMISCIBLE SOLVENT            300                  206
VOC IJAS SUPPLIED"
GM/KG - LB/GAL               500 -.4.16            108-0.9
The residual 690 water miscible + 84 water immiscible solvent
parts remain in the 'bath and are "converted" to COD through
removal by ultrafiltration.

Electrophoretic coating systems differ from conventional spray
and dip paints in that not all of the VOC "as supplied" is
volatilised during application or baking. The deposition
mechanism excludes the majority of the solvent from the applied
coating. This excluded portion of the VOC may be eliminated
by ultrafiltration.

-------
                              Fig. 8.
      TYPICAL BATH  CONSTITUENTS OF ELECTROPHORETIC COATING  SYSTEMS
U)
M
NJ
       "VEHICLE"  RESIN
       CROSS-LINKER
       WATER MISCIBLE SOLVENT
WATER IMMISCIBLE SOLVENT
       ADDITIVES/EMULSIFIERS ETC.

       PIGMENTS/EXTENDERS/DYES ETC.
       WATER
% WEIGHT

5-10

3-6

3-8

2-4

LESS THAN 2

LESS THAN 10

BALANCE
       Typical CLEARCLAD bath will contain up to 16% of such
       constituents + balance of water. Auto-body primers may
       be 30% + balance of water.

-------
(The work described in this paper was not funded by the U.S. Environmental Protection
Agency.  The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

                Water-Reducible Polyurethane Coatings for
                             Aerospace Applications
                          Patricia B. Jacobs and David C. McClurg
                                       Miles Inc.
                                      Mobay Road
                                   Pittsburgh, PA 15205
     Solvent-borne polyurethane coatings traditionally have been the high performance coating of
     choice for aerospace and military vehicles.  State-of-the-art  high solids coatings for these
     platforms typically have a volatile organic compound content of 420 g/l (3.5 Ibs/gal).  (BMS
     1060H, MU-C-85285B, MU-C-46168D). The efforts to further reduce VOC have taken
     many forms. For polyurethane coatings, two-component water reducible polyurethane
     systems make significant reductions in VOC while maintaining the level of performance
     expected of traditional polyurethane topcoats.
                                        313

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  Introduction
         The extreme environments aircraft are subjected to dictates the use of high
  performance coatings for corrosion protection and camouflage.  Aliphatic polyurethane
  topcoats have long been the coating of choice for aerospace, because they provide excellent
  flexibility, chemical resistance and exterior durability. Traditionally, this high performance
  polyurethane coating has been a solvent borne conventional solids system.  Aircraft coatings
  like all other coatings are being required by new government and local regulations to reduce
  vobtiie organic emissions.  Raw material manufacturers and coatings suppliers have
  developed high solids and waterborne technology to meet these regulations. This paper will
  address a new chemistry for low VOC coatings which may have great potential in the
  commercial and military aerospace markers in particular.

         State-of-the an aircraft coatings for military and commercial aircraft are formulated
  at 420 g/1 VOC. These include MU-C-85285B (Type I). TT-P-2756, Mil-C-83286C
  (proposed revision) and BMS 1060H. The binder system (which is the largest factor in
  determining VOC) for these types of coatings make use of a hydroxyl-functional polyester
  polyol crosslinked with a hexamethyiene diisocyanate (HDI) based polyisocyanate to form a
  urethane linkage. The polyester polyol is a solid at room temperature, requiring a high level
 of organic solvent to reach practical application viscosities, especially when filled with
 primary and extender pigments. The polyisocyanate, on the other hand,  is a liquid typically
  1000 - 4000 cps at 100% solids. It is obvious that modification of the polyol component
 will have the greatest impact on the level of organic solvent used in the current coating
 system.
 Theory of Waterborne Polyurethane Resins
 One Component Polyurethane Dispersions
        One approach to reduce organic solvent levels in coatings has been to use water as a
 carrier. This concept has already been applied in one-component aqueous polyurethane
 dispersions. These are binary colloidal systems made from fully reacted, predominately linear
 polymers.  See Figure 1. Like most organic polymers, polyurethanes are not compatible with
 water. In order to disperse them in an aqueous media they are modified ionically and
 nonionically with hydrophilic groups.

       A coating made from a one-component polyurethane dispersion would contain
 pigments, cosolvents and surfactants typically used in waterborne coatings. The VOC of
 such systems generally ranges from 240-340 g/1. As water and cosolvent evaporate, a film is
 formed via coalescence.  For ambient cure systems, however, commercially available, fully
 reacted dispersions do not provide the same level of chemical resistance as that of a highly
 crosslinked solventborne polyurethane.

       Considerable work has been done to crosslink the ionic groups of the dispersion with
 polyaziridines and carbodiimides. A Boeing study formulated a series of polyurethane
 dispersions and crosslinkers in an attempt to meet the properties of MH-C-83286B1. They
 found that this type of crosslinker made a small improvement in the performance of a one
 component polyurethane dispersion, but did not meet Mil-C-83286B. Their results showed
acceptable corrosion resistance and flexibility, but failures in chemical resistance and high
gloss.
                                      314

-------
                                      Figure 1.
                     Preparation of a Polyurethane Dispersion
                              OCN-R-NCO «• HO-
                          • OH
                                    0    T    O
                           OCN-R-NHC1© ~~~~- OCNH-R-NCO
                                        CM,    O        O
                                       I, C CH, OCNH-R-NH
-------
                                      Figure 2.
                          Hydroxy-functionaJ Dispersion
                                        CH,

                 2n HO	OH  »  n HOCH,-C-CH,OH  *  4n OCN-fl-fCO

                                        COOH
                     0      0    O      CH,     0    O      0
                     II      H    II      I       I    II      |
              OCN-R-NCO	OCN-R-NCCCH,-C -CHjOCN-R-NCO—» OCN -R-NCO
                    H        HH     *  I        H   H        H
                                        COOH
                     O     O    O     CH,     0    O      O
                     n     «     «      i       H    u      n
              OCN-R-NCC—* OCN.R-NCOCH,-C -CHjOCN-R-NCO	OCN -R-NCO
                    H        H  H       I        MM        H
                                       COO'NHR,'
                                          1.

                                          2. OH-tunettonal Chain T«nnin«tor
Water Dispersible Polyisocyanates
       As in the case of polyurethane prepolymers, polyisocya nates are not compatible with
water. Additionally, the concept of mixing a polyisocyanate with water is unconventional
due to its reaction with water.  See Figure 3.
                                    Figure 3.
                          Isocyanate - Water Reaction
     R-NCO  *   HO-H   	^   R-NH2    +

     Isocyanate     Water             Amifte       Carbon Dioxide
    R'—NCO  *   R-NHj  	>-  U—jj-C-jj-H

    Isocyanate     Amine               H     H
                                           Urea

                                     316

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       These two potential concerns have been resolved through the development of
hydrophillically modified aliphatic polyisocyanates.  Depending on the modifying agent, the
water dispersability. functionality, and viscosity of the polyisocyanate can be influenced.
Although less desirable, reducing the polyisocyanate in an appropriate solvent can, in some
cases, improve the dispersion into water.

       We know that the uncatalyzed reaction between aliphatic polyisocyanates and water
is very slow2. We theorize that the polyisocyanate reacts preferentially with the hydroxyl
groups of the dispersion over water. Jacobs and Yu3 have monitored the consumption of
isocyanate by "polyol" and water over time, noting a trend for the polyisocyanate to react
preferentially widi the polyol. See Figure 4. As water evaporates from an applied coating,
the polyisocyanare particles coalesce with the hydroxy-functional dispersion. We believe that
after this coalescence takes place, the isocyanate group comes in dose enough proximity widi
the hydroxyl group tp react.

       We recognize that some of the polyisocyanate is sacrificed to the water carrier, and as
a consequence, we formulate with a large excess of polyisocyanate to insure complete reaction
of the hydroxyl groups. We have found optimal property development at NCO/OH ratios
of 2.0 and higher. The resultant polymer matrix can be considered a polyurea modified
polyurc thane.
                                     Figure 4.
                        Isocyanate Consumption vs. Time


c
o
"5
CL.
V)
e
o
u
O
O
£



60-

50-
40-


30-

20-
10-

• OH-ninctional PUD •

• water


9

_


0
w T 1 1 1 1 1 1
01234567
                                     Time Elapsed (hours)
                                      317

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  Properties
  Clear Film Comparisons
        To demonstrate the performance range of a two-component water-reducible system,
  dear films from a conventional solvent borne polyurethane and conventional one-
  component dispersion  were compared to films from a two-component waterborne coating
  in a common screening test.
                                      Table 1.
                             Clear Binder Comparisons

MEK2X
Pendulum Hardness (sec)
Reverse Impact (in-lbs)
Tensile Strength(psi)
% Elongation
2K Solventborne1
200+
170
160
4900
<5
2K Solventborne2
200+
23
160
6200
150
2K Waterborne3
200+
134
160
5755
10
IK PUD4
20
70
160
5700
160
 'Soventborne HDI polyisocyanate and a highly functional polyester
 ^Sovcntborne HOI polyisocyanate and a tri-functional polyester
 ^Reactive two-component waterbome system
 4Aqueous polyurethane dispersion
        The results from Table I show the increase in chemical resistance (MEK double
 rubs) of a reactive two-component water-reducible system over a one-component fully
 reacted dispersion. In fact, this screening experiment suggests the two-component water-
 reducible polyurethane demonstrates physical and chemical resistance properties of the same
 order as conventional solvent borne systems.
Pigmtnted Ccatingi
Camouflage Topcoats
       Our development efforts have suggested that this reactive water-reducible technology
would have potential for nearly all high performance topcoat applications.  Of particular
interest has been military and commercial aircraft topcoats.  Commercially viable coreactants
were formulated in a series of camouflage and gloss coatings, and tested toward the critical
requirements of Mil-C-852858, Type I, MU-C-83286B, and commercial BMS-1060H.
Factors such as NCO:OH ratio, OH-functionality, coreactam molecular weight,
polyisocyanate modifiers, surfactants, and manufacturing procedures were varied in early
formulation development.  The results of experimental designs and confirmatory
experiments were used to design formulations for aerospace applications. Responses
measured for these experiments include impact flexibility, low temperature flexibility.
Skydrol resistance, water resistance, adhesion, hydraulic and fuel oil resistance and gloss.

                                      318

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Table 2 is a portion of a screening experiment used to determine appropriate NCO/OH
ratios for a camouflage military aircraft topcoats.
                                      Table 2.
                       Water-reducible Camouflage Coating
NCO/OH
GE Impact
Low Temp Flex1
Mil-L-23699
Skydrol2 Fluid
Resistance
1.5
20
pass
fail
blistered
2.0
20
pass
pass
blistered
2.5
20
pass
pass
3 A pencil
3.0
20
pass
pass
1 A pencil
3.5
10
pass
pass
1 A pencil
* Bend over 1" mandrel at -65°F
* Slcydrol is a registered trademark of Monsanto. A pencil is the drop in pencil hardness after 7 days immersion
in Slcydrol 500B fluid.  2 A pencil with no blistering is considered acceptable.
       Several coatings formulations designed to meet the different requirements for Air
Force, Navy and commercial specifications were developed based upon this type of
characterization.  The following is an example of a camouflage aircraft topcoat formulation
and test results according to Mil-C-85285B, Type I.  Bayhydrol XP-7044 is the OH-
functional polyurethane dispersion and Desmodur XP-7007 is the water dispersible HDI-
based polyisocyanate. An NCO:OH ratio of 3.0 was taken from Table 2 and used in the
following initial formulation because it met the chemical resistance and impact flexibility
requirements for military aircraft.  The VOC of the final system is 211 g/1 (1.76 Ibs/gal).
                                      319

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                  Two-Component Waterborne Aircraft Topcoat

                                    f 191 -53
                                                          VOLUME
                                                          SOLIDS
                                                            3.51
                                                            0.00
                                                            0.28
                                                            0.35
                                                            0.29
                                                            0.60
                                                            1.73
                                                            3.24
                                                          14.49
                                                           0.60

RAW MATERIAL
COMPONENT I

WEIGHT


VOLUME

Predispcrsc on Cowles Mixer:
Bayhydrol XP-7044 84.67 9.61
DC ionized Water 162.18 19.47
Byk321
Tinuvin 292
Tinuvin 1130
10% Black Tint Paste
TiO2 R-960
Syloid 234
Letdown:
Bayhydrol XP-7044
FC-430 (20% in H2O)
4.32
2.89
2.89
11.30
57.74
54.06

350.18
28.50
Sand Mill entire Component I ro at
COMPONENT 11
Desmodur XP-7007
Exxate600
Total

111.36
37.12
907.21
0.56
0.35
0.29
1.24
1.73
3.24

39.75
3.34
least 5 Hegman

15.31
_SJfl
100.00
WEIGHT
SOLIDS

33.87
0.00
2.17
2.89
2.89
5.92
57.74
54.06

140.07
5.70


111.36
0.00
416.67
                      WEIGHT
                      WATER   SUPPLIER
                       40.64
                      162.18
                        0.00
                        0.00
                        0.00
                        5.24
                        0.00
                        0.00
                      168.08
                      22.80
MILES

Byk-Chemie
Ciba Geigy
Ciba Geigy

DuPont
Grace
MILES
3M
111.36
0.00
416.67
15.31
0.00
40.40
0.00
0.00
398.94
MILES
Exxon
Test Results
                    Formulation f 191-53
Initial Viscosity #4 Ford      25"
4 Hour Viscosity            33"
VOC                      211g/l
60° Gloss                  6.0
Scrape Adhesion to Primer    6 kg
7 Day Immersion in:
Mil-H-83282*              AE-1.3
MU-L-23699*               AE-3.1
GE Impact                 20%
Low Temp Flex 1"           Pass
1 Year  Florida Weathering    AE - 0.63
Mil-C-85285B, Type I  Control

             28"
             32"
             420 g/1
             4.5
             5kg

             AE-0.7
             AE = 2.4
             40%
             Pass
             N/A
*AE is the measure of color change in CIEIAB. Illumunant C color space. It is used as a comparative measure
of fluid resistance.

                                    320

-------
        When compared to the solvent borne control at 420 g/l, the two component water
 borne system gives comparable performance at less than half the VOC. We are currently
 pursuing field trails of this material on operational aircraft.


 Gloss Topcoats
        One of the drawbacks to some waterborne systems is the ability to achieve high gloss.
 A  binder system containing Bayhydrol XP-7044 polyurethane dispersion and Desmodur
 XP-7007 polyisocyanate performs well in camouflage systems, but it is difficult to achieve a
 60° gloss greater than 80.  Similar formulations utilizing experimental resins designed for
 higher gloss, however, demonstrate encouraging preliminary results for military gloss topcoat
 and commercial topcoat applications at VOC's as low as 120 g/l (1.0 Ib/gal).

        In the first system, an experimental polyisocyanate (EX-P) has been modified to be
 even more water dispersible than Desmodur XP-7007. This new polyisocyanate does not
 require reduction in cosolvent for incorporation  in water, and when reacted with XP-7044,
 films are higher in gloss  and more flexible.  A third system has made use of a new water
 dispersible allcyd (WRA) designed for high gloss.  Films made from the WRA/EX-P
 demonstrate  high gloss, good DOI, and excellent chemical resistance. Initial coatings systems
 have been tested for gloss, flexibility and Skydrol fluid resistance as well.  See Table 3.
                                       Table 3.
                         New Resins for Aircraft Topcoats1

VOC
60°/20° Gloss
DOI
7 Day Skydrol Fluid
Resistance2
30 Day Skydrol Fluid
Resistance3
GE Impact4
XP-7044-7007
211
71/33
60
pass
&U
20%
XP-7044/EX-P
128
85/58
82
fail
rail
40%
WRA/EX-P
127
88/78
90
pass
pass
20%
' All coatings tested were pigmented with TiO2 at a pigment to binder ratio of 0.7.
2 Tested over cpoxy primer Mil-P-23377. Failure is defined as a decrease in hardness of greater thane 2 pencils.
' Tested over epory primer BMS 10-79.
4 Tested direct to bare anodized 2024-TO aluminum as in Mil-C-852858.
Summary
Today's aircraft perform very different missions subjecting diem to a wide range of
environments. A military fighter for instance, requires a coating that is very flexible, usually
low gloss, and of moderate chemical resistance.  A commercial airliner, on the other hand,
requires a coating which provides excellent chemical resistance to such fluids as Skydrol, high
gloss, and moderate flexibility.

                                       321

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The common requirements these types of coatings share are light stability and low VOC.
The performance data described in this paper demonstrate a level of performance of the same
order as traditional aircraft topcoats of all types while reducing VOC by more than 50%.
Products such as the OH-functional polyurethane dispersions demonstrate the excellent
flexibility needed for military aircraft, while we believe the newer generations of modified
polyisocyanates and WRA's provide high gloss and excellent chemical resistance demanded
by commercial aircraft applications.


Our future efforts will be directed at formulating and testing this technology in all markets
including the aircraft industry.  Future development will be 1) to continue researching resin
compositions and manufacturing techniques to attain Miles' goal of very low and zero VOC
coatings 2) to more fully characterize weather resistance through accelerated methods and in-
progress outdoor exposures and 3) to pursue field trials of laboratory-proven coatings in
cooperation with coatings manufacturers to ultimately determine coating performance in a
real-life exposure.
                                      322

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                                 REFERENCES
1.     Swanbcrg, D. Water Reducible Polyurethane Enamel, D180-30690, Boeing 1990,
       pp. 49-61.

2.     Scnekcr, S.D., and T.A.. Potter, Solvent and Catalyst Effects in the Reaction of
       Aliphatic Isocyanates with Alcohols and Water. In: Proceedings of the Water-Borne
       & Higher Solids Coatings Symposium, New Orleans, LA, 1989.

3.     Jacobs, P.B., Yu, P.C.,  Two-Component Waterbornc Polyurethane Coatings, In:
       Proceedings of the Water-Borne and Higher-Solids, and Powder Coatings
       Symposium, New Orleans, LA, 1992.
                                    323

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324

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                          SESSION 8
                       APPOCA11ONS I
                       PAPERS PRESENTED:

             "Water Based and UV-Cured Coatings for Plastics"
                                 by
                           Edwin C. Laird
                    Coatings Resource Corporation
                      Huntington Beach, California

                "Water-Borne Lacquers for Aluminum Foil"
                                 by
                         William  F. Marwick
                      Alcan International Limited
                         Banbury Laboratories
                          Banbury, England

"Lower-VOC Coating System Conversion Costs for the Wood Furniture Industry"
                                 by
                         Mary-Jo  L. Caldwell
                      Midwest Research Institute
                         Gary, North Carolina

        "Development of Ultra-Low VOC Wood Furniture Coatings"
                                 by
                           Eddy W. Huang
              Center for Emissions Research and Analysis
                       City of Industry, California
                                and
                           Larry Watkins
             South Coast Air Quality Management District
                       Diamond Bar, California
                                and
                         Robert C. McCrillis
                 U.S. Environmental Protection Agency
            Air and Energy Engineering Research Laboratory
                 Research Triangle Park, North Carolina
                               325

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
            Water Based and UV-Cured Coatings for Plastics
              By Edwin C. Laird, President - Coatings Resource Corp.
                                     327

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 I.    HISTORY


 The  evaporation   of  solvents  from  coatings   has  long  been
 determined to be a cause of smog.  The formation of smog has been
 directly  attributed,  in  part,  to  the  reaction  of   organic
 hydrocarbons with  NOx and sunlight  to form  ozone in the  lower
 strata.     Solvents   were  segregated  by   their  photochemical
 reactivity.     Until  recently,   these  solvents  were limited  to
 allowable prescribed  levels in  coatings.  Recently,   regulations
 have indicated that  all solvents are smog precursors.   Thus,  all
 solvent  usage  has been regulated,  and  consequently,  their usage
 has decreased.

 Prior to 1966,  coatings for plastics  consisted of extremely high
 levels of aromatic solvents,  branched  ketones,  and  chlorinated
 solvents.   These solvent rich coatings  yielded volatile organic
 contents (VOC's) in excess of  700 g/1.    As a result of the above
 cited regulations,  the average VOC  levels of most  coatings  for
 plastics have decreased by over 60% to a level of 275  g/1.

 It   should be noted that although  some industries have been able
 to  reduce VOC levels  to this extent,  others have not been able to
 achieve  the   same results.   To a great extent, due to  the lack of
 polymer  technology advancement,  some coatings for  plastics,  such
 as  thin  film applications used in vacuum metalizing, still emit a
 high level of VOC.


 The quest for  lower  VOC emitting  coatings has progressed  along
 two major lines   of technology.   These  two lines are   waterbased
 systems  and  ultraviolet radiation cured (UV cured)  systems.  Both
 of  these lines of coatings  technology,   although in their infancy
 when  compared   to  the   old-style  solvent  based coatings,  have
 yielded  replacements  to the conventional solvent based coatings.
 In   some  instances,  these   products  have not  only  matched  the
 solvent   based coatings  in performance  and economics,   but have
 actually exceeded them.

 II.  WATERBASED  SYSTEMS

 The  trend  to waterbased vehicles constitutes  perhaps  the single
 most   important  development in  the  field of  plastics finishing
 during the last  decade.   As of  1970,  this market had   been, with
 very few exceptions,  almost solely  restricted to  polymer vehicles


 Ed Laird, Coatings  Resource Corp.
Waterbased and UV-Cured Coatings for  Plastic
                            328

-------
 supplied in solvent.   Now,  less  than two decades  later,
 waterbased polymers  comprise  20%   of  the  vehicles   used by   the
 plastics finishing industry.

 Waterbased  polymers   have  developed  along   three   major lines:
 styrene-acrylic  emulsions, acrylic  emulsions,   and  polyurethane
 dispersions.   These   systems  have   been shown to  be   substrate
 dependant.  A  coating that adheres to  styrene may  not  adhere to
 ABS.   Thus,  a careful evaluation of polymer  systems  is  necessary
 to  determine the optimum performance properties that  are desired.

 Based upon  extensive  testing  in   the  plastics industry,  the
 styrene-acrylic emulsions demonstrate the best overall  stability
 and  adhesion to a multitude of  plastics.   This  is due,  in part,
 to  the  styrene  component of  the  polymer.   However,   if film
 clarity  and whiteness is of concern, this  same styrene  component
 may  be  detrimental   to the   overall  finish.    When exposed to
 ultraviolet  light,    the styrene   component   yellows,   thereby
 detracting from the film clarity.   If mar resistance  is  a desired
 characteristic,  then   styrene-acrylic resins   would be   a logical
 choice due to the hard film produced by the resin.

 Acrylic  emulsions furnish  coatings manufacturers  with  a broad
 array of  performance properties including  high   gloss,  color and
 gloss  retention,   and the  ability  to  withstand the   degrading
 effects of water  and harsh industrial  chemicals.   Best of  all,
 the coatings manufacturer and  user  obtains  these  properties while
 avoiding highly toxic and flammable petrochemical solvents.

 Polyurethane  dispersions  provide  unique qualities    normally
 associated with  solvent based  two  component urethanes,  while
 avoiding highly toxic and flammable petrochemical solvents, much
 like   acrylic emulsions.  Some of   the  properties associated with
 polyurethane  dispersions include   superior chemical resistance,
 light fastness,   and  adhesion  to various plastics.   Polyurethane
 dispersions  are  currently used in automotive,  aerospace, and
 business  machine  finishes.     Although the  dry times  of  the
 polyurethane  dispersion products rivals those of  other polymer
 families,  the polyurethane dispersion  coatings required a little
more  time to  achieve their properties.   In order to accelerate
 the attainment of these properties,  chemical crosslinkers can  be
used.

Each  of  the above  cited systems  require coalescing solvent in
order  to  achieve  their optimum  performance.   As a general rule,

Ed  Laird,  Coatings Resource Corp.
Waterbased and UV-Cured Coatings for Plastic
                             329

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 the harder  the  polymer,  measured  by its  minimum film  forming
 temperature (MFFT)  and glass transition temperature Tg,  the  more
 coalescent that is  needed.  Additionally,  the evaporation rate of
 these  coalescing solvents  must be  slower than  that of  water.
 This is  of vital importance in order  to  mitigate the effects of
 humidity.    If  the  relative  ambient humidity  is   high,   the
 evaporation rate of the water in  the coating is retarded.    This
 creates a  condition in which the  water is the  last  volatile to
 evaporate from the  coating.   As a result,  improper film formation
 is  likely  to  occur.   Thus,   the coalescing  solvent   serves a
 critical  purposes.    It softens  the polymer matrix  so  that it
 fuses the polymer particles  to each other  and to the substrate.

 The transition from solvent  to water systems has not gone without
 complications.   Most industrial coatings  manufacturers  and users
 learned  to work with solvent-borne  vehicles  and are   far  more
 familiar  with them than with  waterbased  emulsion polymers.   The
 natural tendency is  for the  formulator and user  to handle and
 formulate these  polymers  in  the  same manner  as  solvent-borne
 vehicles.    This approach  may  not produce  optimal  coating on
 plastic  parts.   Consequently,  the  manufacturer and  users  were
 forced  to adapt their processes in  order to accommodate the new
 technology   in  coatings.      But,    as   a  result    of  these
 accommodations,    new  coatings    have    emerged   that   are
 environmentally friendlier and simultaneous yield  substitute,  if
 not superior coatings  for  the plastics industry.

 III.  ULTRAVIOLET RADIATION CURED (UV CURED)

 Ultraviolet  Radiation   (UV)   cured  coatings are  comprised  of
 monomers (a single polymeric unit),  oligimers (very short chained
 polymers),  and   photoinitiators.     These   coatings need  to  be
 exposed to light energy with wavelengths  between 240  and 400 nm.
 These   coatings  cure   extremely  fast    at   relatively   low
 temperatures.   The entire  surface  of the  part must be exposed to
 the  light source in  order  for the reaction to occur.   Coatings of
 high   gloss,  high solids,  zero  VOC,   with  lower  energy costs  than
 thermal  cured systems are  readily available.

 Monomers are  used as reactive  diluents  since they are inherently
 low   in   viscosity.      Their  degree  of   functionality    imparts
 different  properties to the final  film.    The greater the  degree
 of  functional groups that  a monomer has,   the  more crosslinking
 that  occurs.  This translates to  increased hardness and  decreased
 flexibility.  Monofunctional  monomers,  those  with  one functional

Ed Laird,  Coatings Resource  Corp.
Waterbased and UV-Cured Coatings  for Plastic
                             330

-------
group, provide  the greatest viscosity reduction.

These  materials  are the basis for  health concerns related  to  UV
curable materials.   Using standard hygienic  practices that are
employed when using  any coating  is sufficient  to mitigate any
sensitization that may occur as a result of monomer exposure.

Oligimers  are the main polymeric materials used today.  They have
a small degree  of functionality that allows  them to react  with
each  other  and the  monomer.   Generally, they  are difunctional
(two functional  groups) low  molecular  weight polymers  with  a
backbone   comprised  of  either  acrylic,  urethane,  epoxy,    or
polyester.   The  choice of  polymer is  dependent on the  desired
end-use.     All of  these  resin types  impart  greater strength,
hardness,  solvent resistance,  and gloss  than their  solvent  or
waterbased counterparts.

Photoinitiators are, as the name implies, chemicals that initiate
the curing  reaction  upon  absorption  of the  UV  light.    The
selection  of the  photoinitiator is crucial.  This minor component
will dictate whether the coating  cures and at  what wavelength.
The   entire UV  spectrum  can  be   covered  by  a  variety   of
photoinitiators.  A curing  package is developed by  coupling the
wavelength  of  the  light  emitted  by  the  UV  lamp  with the
wavelength absorption characteristics of the photoinitiator.


Pigmented  coatings are more complex than clear coatings.  This  is
due, in part, to  the reflection of non-absorbed light.  Pigments,
as well as   other fillers, absorb radiated light.    Each pigment
has its own  pattern of UV absorption that needs a photoinitiator
package and  lamp  designed for it.  White UV  curable coatings are
extremely  difficult to cure, as white  is the reflectance of all
light, and   the photoinitiators  used have a  tendency to  yellow
with time.   UV  coatings are  intrinsically higher in  viscosity
and, in many cases, need to be reduced with  solvent in order  to
be applied,  thus  increasing their VOC emissions.
IV.  CONCLUSION


Low  VOC coatings for plastics have improved exponentially  in the
past decade.  For many industries, these have proven to be  the


Ed Laird, Coatings Resource Corp.
Waterbased and UV-Cured Coatings for Plastic
                              331

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 salvation in light  of the ever  increasing regulatory  controls.
 Waterbased  coatings  have  become,  in  roost  cases,  a   direct
 replacement for solvent based  lacquer systems.  Research on  new
 polymers continues,  looking to produce hard durable materials  at
 even lower VOC levels.  Additives are constantly being created to
 enhance  properties   of coatings  on  exotic  substrates such  as
 polysulphone,  PEEK,  and high temperature composites.  The  future
 for waterbased  coatings indicates  that  it will  experience  an
 ever-increasing  demand, as  more and  more  production processes
 substitute waterbased for solvent based coatings.

 Ultraviolet curing technology work will continue on the curing of
 three dimensional parts, lowering of the expense associated  with
 the light sources, increasing  the power of these  light sources,
 and  developing  pigmented   coatings.     Resin  companies   have
 developed  waterbased UV resins  that use water,   rather than VOC
 emitting  solvents,  to reduce the viscosity  of the system.   This
 necessitates some heat  to evaporate the  water,  but  application
 becomes  much  easier.   Simultaneously,   this   would reduce   the
 amount of monomer that is needed in the system.

 Even with  these advancements,  some coatings for plastics cannot
 be   reformulated to  achieve these same   results.   In these cases,
 the manufacturer must look towards emission control equipment  in
 order to comply  with the current emissions regulations.   If  this
 approach  is  taken,   the  capital  costs  of  installation   and
 operation  must   be   given  serious  consideration   along  with
 maintenance costs required  to  keep  the  equipment  in  proper
 working condition.

 In  conclusion,  it must be noted that although great advances  have
 been  attained  in low VOC and  zero VOC coatings  for plastics,  it
 is  still a  technology that is  in its infancy.    It is hoped  that
 the  tremendous  growth  in this  technology will  continue  to where
 all  plastics can and will be  coating  with low VOC  and zero VOC
 coatings.
Ed Laird, Coatings Resource Corp.
Waterbased and UV-Cured Coatings for Plastic
                            332

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 Effect of Relative Humidity on the

     Evaporation Rate of Water

      from Waterbase Coatings
Ol

I
o
o
3

0
   100
                 Time
                        •• Coatings
                         A  H L > •• II I t V' **
                        _ ^^ .  C <• i |; o i a 111. M
                 333

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         Film Formation of Waterborae
                        Coatings
w
w
Waterborne coating
    on surface
                     Water evaporation yields
                      close-packed spheres
                     with solvent filled voids
                                         Further evaporation and
                                          polymer deformation
                                         yields continuou
                                                Coatings
                                                   '

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency.  The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
              Water-borne Lacquers for Aluminum  Foil
William  F Marwick
Alcan International Ltd., Banbury Laboratories, Banbury OX16 7SP, England
 1. INTRODUCTION

       Alcan rolls and converts aluminum foil in many countries worldwide. Facilities are in
 Louisville, Kentucky and in Australia, Brazil, Germany,  Japan, Scotland and Switzerland.
 Particular attention is being paid to VOC emissions from these plants. Low gauges of aluminum
 are coated with lacquers, and thus the quantities of organic solvent used are  comparatively great
 when compared to painting operations carried out on other aluminum semifabricates such as
 building siding or extrusions, if the calculation is on the basis of solvent use per tonne of metal.
 Water-borne lacquers offer an environmentally beneficial alternative  to the use of conventional
 solvents, and environmental legislation in several countries (e.g. U.K., Australia) is following
 the example of the United States in encouraging the use of water-borne lacquers.
       Not  all converted foil products can be successfully lacquered with water-borne lacquers.
 In particular, food packaging products for which a  sterilisation step in required, and where an
 interior-lacquered aluminum surface is sterilised after filling with the food contents, need a
 combination of chemical resistance and lacquer toughness which is very hard to achieve.
 Similarly, packaging products for which the lacquer has to provide both a heat-seal action and
 then resist a pasteurisation step, need a combination of properties which are  mutually conflicting
 for water-borne resins. For these sorts of products,  thermosetting vinyls and  epoxies will be very
 hard to replace.
       Some products, however, are relatively easy to lacquer with water-borne lacquers; one of
 these is cigarette bundling foil, the interior packaging of cigarettes. Alcan makes this product in
 four of the above countries, and this paper discusses technical issues arising in the changeover
 to water-borne lacquer for this product, both in terms of the coating  formulation and the coating
 process.
                                           335

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 2. PROPERTY REQUIREMENTS FOR CIGARETTE BUNDLING FOIL

        Cigarette bundling foil is a laminate of 22 g/m2 paper and 7 micron aluminum foil,
 gummed together with a silicate adhesive. The function of bundling foil is primarily to assist in
 the high-speed packaging operation, the cigarettes being first "bundled" in the foil and the carton
 being folded and glued around the bundle. The product is particularly suitable for this operation
 because of the "dead-fold" characteristic of the foil-paper laminate,  and the chief function of the
 lacquer is to impart the correct frictional characteristic to the foil surface, to enable the
 machinery to handle it properly.  There is a minimal requirement for water resistance, and of
 course an absolute requirement for an absence of off-taste from the lacquer. Tobacco companies
 in the U.K..  mostly use a gold lacquered foil, while in the U.S.A. most lacquer is clear. Color
 and gloss are therefore properties which often need to be closely controlled.
 3. CONVENTIONAL LACQUER:  PRODUCT & PROCESS CONSIDERATIONS

 3.1   Product considerations

       The conventional lacquer which has been used for many years for cigarette bundling
 foil is based on nitrocellulose resin, dissolved in ethanol with some ethyl acetate added, and
 containing plasticiser and solvent-soluble dyes.
       Gloss and transparency of the nitrocellulose lacquers are very good. Water resistance
 is also very good, indeed this property is far higher than the cigarette companies actually need.
 Retained odor is potentially a problem for these lacquers, because if there  are any high boiling-
 point solvents presert, they are difficult to remove completely from the coating. Historically,
 this occurs very rarely.

 3.2  Process considerations

       Gravure-applied lacquers need to have an on-machine viscosity of 20 to 30 seconds
(zahn 2 cup). With a nitrocellulose lacquer this is achieved at about 15% solids  in ethyl
acetate/alcohol. The dry coatweight applied is approximately  1 -  1.2 g/m2,  so that between
7 and 8 ml/m2 of wet coating need to be applied. This implies a  relatively coarse gravure roll,
perhaps 100 lines/inch with 50 micron cell depth. Coating with these parameters is  easy from
a production point-of-view; control of color intensity is  not difficult, coating machines can run
faster than 400 metres/minute, and coating heads are easy to clean because of the ready
dissolution of the lacquer in solvents. Nitrocellulose lacquers dry readily, but 6 - 7 ml solvent is
given off per square metre of foil.. The high flammability of the  solvent mixture means that a
large airflow is needed in the driers; the Lower Explosion Limit  for the solvents  is  2%,  so that
a large amount of air has to pass through and be heated up. Some of Alcan's plants have been
obliged by local legislation to install incinerators to burn these solvent vapors, and this means
both high capital and running costs.
                                            336

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4. WATER-BORNE LACQUER:  PROCESS & PRODUCT CONSIDERATIONS

4.1  Product considerations

4.1.1 Resins.   Water-borne lacquers can be based on acrylic, sulphonated polyester or
polyurethane resins; there are also some oxidizable alkyds and epoxy-esters for use where alkali
resistance is important. The polyurethanes and sulfonated polyesters both have properties which
make them preferable  to acrylics in some applications, but the work reported here focuses
exclusively on acrylics; they will remain the cost-effective choice for many applications.
The essence of formulating a lacquer with water-borne acrylic resins is to build in a mechanism
whereby drying is irreversible. In this way a stable solution  or dispersion becomes a water-
resistant film on drying. The mechanisms employed are as follows:
                     *  loss of neutralising ammonia or amine on drying
                     *  coalescence of dispersed droplets.
Acrylic solution resins have enough acid groups to dissolve completely in alkaline water, giving
a clear, viscous solution; they dry only by the  first mechanism. Acrylic dispersion resins, which
are polymerised from sub-micron dispersed droplets of monomer, have a higher molecular
weight and only enough acid groups to stabilise the dispersion. They dry by both mechanisms.
These two classes of resin impart both desirable and undesirable properties to the lacquer:
For cigarette bundling foil, the lacquer needs to be coatable  at quite high solids, so that the
quantity of water to be dried off is minimised and the coating machine speed is not
compromised. The dried film needs to have  some water-resistance. Dispersion resins are thus the
obvious choice for the resin vehicle. However,  some degree  of redispersibility at the coaler tray
is also important, otherwise the gravure roll cells will fill with coalesced or dried lacquer,
especially if the gravure roll  stops momentarily whilst it has lacquer on it. For this reason, a
blend of dispersion resin with some solution resin is best.
                                SOLUTION RESINS
   DESIRABLE

   redispersibility at coaler
                   UNDESIRABLE
                    high  viscosity
                       slow to dry
poor alcohol & water resistance when dry
                               DISPERSION RESINS
   DESIRABLE
   low viscosity
   fast drying
   water resistant, sometimes alcohol resistant, when dry
                   UNDESIRABLE

        limited redispersibility at coaler
                                           337

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4.1.2  Amine neutraliser.  Choice of neutraliser also influences the film-forming process and the
drying rate. Clearly, a volatile base such as ammonia or morpholinc will give the fastest drying
but also the greatest risk of cell-blocking on the gravure roll. An alkanolamine with a lower
volatility reverses this balance. Correct selection depends on machine conditions.

4.1.3  Coloration.   Conventional nitrocellulose lacquers for "gold" foil brands predominate in
the U.K.  They contain dissolved dyes and are transparent when dry. Replicating these gold
colors with water-borne lacquers is difficult; one can use pigment dispersions designed for
aqueous systems (e.g. Microlith WA series, Ciba-Geigy Pigments Ltd.) but the transparency of
the dried lacquer is reduced, especially if the foil is viewed at a glancing angle. Alternatively, it
is possible to incorporate some dyes (e.g. Savinyl,  Sandoz Chemicals  Ltd.) in stable dispersions,
and this gives excellent  transparent shades. The Savinyl dyes  need first to be dissolved in
cosolvents which can  then be let down with  acrylic solution resins, with water and finally with
emulsion resins; many of the latter are only marginally compatible with the dye-cosolvent
mixtures. Useful cosolvents for the Savinyl dyes include diacetone alcohol, acetylenic alcohols
and isopropanol.

4.1.4  Cosolvent.   A  small amount of an alcohol or glycol ether cosolvent has a pronounced
effect  on  the wetting action of water-borne lacquers. Inevitably, the surface tension of these is
higher than for the corresponding alcohol-based nitrocellulose lacquer. This makes water-borne
lacquers more sensitive to the substrate surface. Good coating quality is obtained from an
annealed  foil surface.  At Alcan, conventional practice is to anneal the coils for 34 hours at
300"C; this removes organic contaminants effectively. Figure  1  shows the effect of some
formulation changes on lacquer surface tension.
                  Figure 1: Surface Tension of Lacquers
             45	
                     Boytiydrait   BoytwdroiN
             40	•   •	
          O                  N«aayfl
          c  30
          •C  25
          •>     '
             20
             15


             10-
                                 1                 10                100
                                   solvent content (%)
                                           338

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This was measured on a Cahn Microbalancc using the Wilhelmy plate method; glass slides
of dimensions 24mm x 32mm x 0.15mm were lowered into lacquer samples at 40 microns
per second.

Key to Figure I:
"Bayhydrol I":   Bayhydrol LS2884 aqueous polyurethane resin (Bayer AC. D5090 Leverkusen. Germany)
               Microlith yellow 2RWA pigment (Ciba-Ceigy Pigments, Manchester, U.K.}
               Microlith scarlet RWA pigment (Ciba-Geigy Pigments, Manchester, U.K.)
             f Surfynol TG surfactant (Air Products d Chemichemicals , Inc.. Allentown. PA)
       042%^ Isopropanol
               water

"Bayhydrol //".  Bayhydrol LS2884 aqueous polyurethane resin
               Microlith yellow 2RWA pigment
               Microlith scarlet RWA pigment
       0.77%   Isopropanol
               water

"Neocryl I":     Neocryl BT67 acrylic resin emulsion (1CI resins b.v..  Waalnijk, Holland)
               Microlith yellow 2RWA pigment
               Microlith scarlet RWA pigment
       0.77%   Isopropanol
               water

Neocryl II: as Neocryl I but with more isopropanol.

The general pattern is that, for any water-borne resin system, the addition of a few percent of
solvent improves the wetting. Fair comparisons between one resin and  another are difficult,
because  some  are supplied  with small amounts of solvent already present.

4.2 Process Considerations

We have found that  efficient coating with water-borne lacquers requires a number of changes to
the process.  Firstly, the higher solids content (approx. 30%) of water-borne lacquers at
viscosities suitable for gravure coating (20 - 30 seconds, Zahn 2  cup) makes a lower wet film-
thickness desirable for both economy of lacquer and drying speed.  Secondly, the irreversible
film-forming characteristic  of the acrylic dispersions makes coating head control very important;
drying of the lacquer in the gravure cells has to be prevented by keeping the roll  turning in the
tray even during a machine stop.  These and other process considerations relating to water-borne
lacquers have been widely  recognised'.  Perhaps less well known is the use of fine ceramic
gravure rolls to deposit uniform wet films at very low coatweights. These have been utilised
with very encouraging results. The sequence involved in ensuring that the required dry
coatweight (0.6 g/m2) is applied is shown in figure 2. In this sequence  it may be seen that  the
desired color shade requires a pigment coatweight of 0.06 g/m2 dry coatweight,  which for the
candidate formulation requires 0.6 g/m2 dry coatweight of the complete lacquer. The lacquer
reaches the correct viscosity for coating at 25% solids, and has a specific gravity  of  1,  so 2.4
ml/m2 wet coatweight needs to be applied. The fine ceramic gravure  roll has a transfer factor of
about 40% when coating onto bare aluminum foil; that is to say, the wettability and  surface
roughness of the foil in relation to the wettability of the chrome  oxide  ceramic  result in about
40% of the contents of a cell full of lacquer being transferred to the  foil.
                                              339

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 It is not widely known that the transfer rate of water-borne lacquers from these rolls to
 aluminum foil  is so low; correct  knowledge of this parameter is of course essential if the
 correct roll engraving  is to be selected.
        Thus a gravure roll with a cell volume of 6 cubic centimetres per square  metre is
 needed; this implies an engraving of the order of 17 microns cell depth and 360 lines/square
 inch. This very fine gravure roll gives a welcome benefit in that the spread or lay of the lacquer
 coating has been found to be excellent, indeed better than that achieved routinely from the
 nitrocellulose lacquer.  The laser-engraved ceramic material ("Ucarlox", Praxair Surface
 Technologies Ltd., Swindon, U.K.) combines wear resistance with an accurate consistency of cell
 dimension across the web; this is of course essential for a colored lacquer, if shade is to be kept
 within specification at such a low coatweight.
                Figure 2: Gravure roll selection
                                Lacquer shad* requirement 0.06 tfm2 ptynar*
                                                            io 0.1
                                        Dry Coatweight
                                                  ttfets contort 25X
                                      wet ooatweigru applied:
                                          eel volume 6 mVm2
                          enwmlegtf¥unnH,3tOHn9»pfrlneh, 17 mtcnn erf top*
A comparison with the process parameters required for the nitrocellulose lacquers (see 3.2
above) shows that  a wet coatweight of 2.4 ml/m2 is applied in the case of these water-borne
lacquers, as opposed to 7 - 8 ml/m2 for the solvent-borne nitrocellulose. This low wet film
thickness overcomes the drying problem, and it also minimises the environmental effect of the
few percent of cosolvent which are included in the formulation to ensure good wetting of the
substrate. Finally, a cost reduction vis-a-vis the standard nitrocellulose lacquer is clearly
obtainable, at least in terms of material costs, since the dry coatweight has been halved and the
two lacquer types are broadly comparable in cost on a dry solid cost basis. Long-term
production experience will be needed before a reliable calculation can be made, which also
includes cost  changes arising from the process changes.
                                              340

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The excellent spread of the water-borne lacquer - referred to above - deserves further analysis; it
relates to the ease with which the dots of lacquer transferred to the foil surface can enlarge and
merge before they become immobilised through loss of solvent. To demonstrate the difference
between the standard nitrocellulose lacquer and a typical  water-borne acrylic, the two
formulations were made  at a number of higher solids contents than the actual on-machine
formulations, and the viscosities were measured on a Bohlin "Visco 88" viscometer. The results
are expressed in Figure 3 as viscosity against the percentage of solvent lost from the initial
concentration. Expressing the results  in this way removes any consideration of relative
evaporation rate, since for any lacquered foil passing through a drying oven, the solvent loss
must progress from 0% to essentially 100% from coating head to coil-up, and this is the  time
during which dot-enlargement has to take place.  It is clear that the rise in viscosity for the
nitrocellulose  lacquer is very sharp; that is why such lacquers can so easily give a mottled
appearance.
                    Figure 3: Viscosity rise through drying:
                              nitrocellulose (NC) and aqueous acrylic (aa) lacquers
            0.6 . -------------- -
           0.5
           0 4	   • aa
        CO
        £
        2? 0.3
           0.2-
           0.1	
              •               i
                                       6        8       10      12
                                        solvent tost
                                            341

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4.2.1 Ultrasonic Cleaning.  A process consideration which was mentioned in 3.2 above
was the easy cleanability of the gravure roll when solvent-home lacquer is used. The
water-borne lacquers can give problems in this respect, the drying being much less
reversible than is the case with nitrocellulose lacquers, even when the formulation contains
carefully chosen combinations of resin types, amine and cosolvent. With this in mind, an
on-machine ultrasonic cleaner has been installed. The resonator (Telsonic AG,
Bronschhofen, Switzerland) is in the form of a tube which extends the full length of the
gravure roll, and is located in the lacquer tray underneath the bottom of the roll. The tray
bottom is semicircular in profile, such that ultrasonic waves are  reflected  upwards onto the
roll  surface. The tray can be drained of lacquer and refilled with a mild alkaline cleaner
prior to switching on the ultrasonic resonator. The installation eliminates the need to
remove cylinders from the machine for cleaning; this was felt to be important, because the
brittle nature of the ceramic gravure roll makes it vulnerable to mechanical damage during
handling. Long-term experience of the use of the ultrasonic cleaner has yet to be gained,
but it is certainly effective.
5.  CONCLUSIONS

       The change from solvented to water-borne lacquers requires some changes to the
coating process, and does not give a cigarette bundling foil with identical properties to the
original product. However, this development work at Alcan has convinced us that there are
as many positive as negative property changes; in addition there is not only an
environmental benefit but also a potential cost saving. Water-borne lacquers are most
useful where local regulations permit small quantities of cosolvents (alcohols or glycol
ethers) to be included.
                                    REFERENCES

1.      Podhajny, R. M.   Surface Tension Effects on the Adhesion and Drying of Water-
       Based Inks and Coatings.    In: Proceedings  of Fine Particle Society Symposium on
       Surface Phenomena and Fine Particles in Water-based Coatings and Printing
       Technology, Boston, Mass.,  1989.  pp 41-58.
                                           342

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   LOWER-VOC COATING SYSTEM CONVERSION COSTS FOR THE WOOD FURNITURE INDUSTRY

Mary-Jo L. Caldwell
Midwest Research Institute
401 Harrisoo Oaks Blvd
Suite 350
Gary, North Carolina 27513

NOTE:  Although the research described in this technical paper has been funded wholly or in part by the U. S.
Environmental Protection Agency contract 68-D1-0115 to Midwest Research Institute, it has not been subject to
the Agency's review and therefore does not necessarily reflect the views of the Agency, and no official
endorsement should be inferred.

BACKGROUND
        During the manufacture of furniture, volatile organic compounds (VOCs) are emitted from the coating
operation.  These VOCs can contribute to the formation of ozone and exceedances of the National Ambient Air
Quality Standard for ozone.  In order to attain the ozone standard in many parts of the nation, emissions of
VOCs must be reduced.

        The U.S. Environmental Protection Agency (EPA) is currently developing a control techniques
guideline document  (CTG) for VOC emissions from wood furniture coating operations.  The CTG will be used
by States to develop wood furniture coating regulations.  The EPA  is also developing a national emission
standard for hazardous air pollutants (NESHAP) for wood furniture manufacturing. Midwest Research Institute
is helping the EPA develop both the wood furniture CTG and the NESHAP.  The use of regulatory negotiation,
a type of consensus-building process, has been initiated for both the wood furniture CFG and the NESHAP.

        As part of the CTG project, a cost analysis of VOC reduction alternatives was performed.  This paper
describes the analysis used to examine the cost to the wood furniture industry associated with adopting coatings
which release less VOC.
                                               343

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 INTRODUCTION
         The purpose of this paper is to demonstrate the methodology that can be used to estimate the costs and
 emission reduction associated with using lower-VOC coatings.  The costs of switching to lower-VOC coatings
 are site-specific, and the costs presented here should be viewed accordingly.  This paper discusses the initial
 cost analysis that was performed for the wood furniture CTG project.  The CTG project and the cost analysis
 are described in the draft CTG.    The original analysis has since been expanded and revised based on
 comments and information received from the industry. These revisions have not been finalized and therefore
 are not discussed quantitatively here.  Because the CTG is currently the subject of a regulatory negotiation
 process, the methodology  may change before the CTG is complete.

         The cost analysis performed for the CTG evaluated two primary VOC control strategies - the use of
 add-on controls (with and  without exhaust-flow reduction techniques) and the use of lower-VOC coatings.  Only
 the lower-VOC coatings cost analysis is discussed in this paper.

         The control techniques guideline will define reasonably available control technology (RACT). RACT
 applies to existing facilities. Therefore, the cost analysis discussed in this paper evaluated the costs of
 retrofitting an existing facility to switch from conventional solventborne coatings to  lower-VOC coatings.

         The objective of the analysis discussed here was  to develop the costs and VOC emission reductions
 associated with a variety of VOC control strategies. These costs and emission reductions were then used to
 calculate the "cost effectiveness* of the various control strategies, i.e., the cost per  unit of VOC reduced (S/ton
 VOC reduced).  The calculated cost effectiveness data were used in conjunction with other information to
 evaluate the various control strategies during development of the draft CTG. This paper focuses only on the
 development of the cost effectiveness data.

 INDUSTRY AND COATING INFORMATION
         The wood furniture industry was characterized, and the feasibility of a variety of lower-VOC coatings
 was evaluated.  In this section, the finishing process is described, the characterization of the industry by model
 plants is discussed, and the lower-VOC coatings evaluated are presented.

 Finishing Process
         The finishing process varies with the industry segment and the facility.  Residential furniture
 manufacturers generally  assemble their pieces and then finish them.  The remainder  of the industry also
 prefinishes some unassembled pieces. The coatings used in the wood furniture industry include but are not
 limited to stains,  sealers, and topcoats.  Coatings are usually spray-applied, although flatline coating methods
 such as curtain coating and rollcoating are used as well. The residential furniture manufacturing industry
 generally uses manual spraying, whereas the rest of the industry uses both manual and automatic spraying.

        The finishing process may be a single step or multistep operation. The coating may be manually or
automatically spray-applied in the spray booth. The piece then leaves the booth and may  be wiped before
entering the flash area, where the faster solvents are allowed to evaporate.  Depending on the number of steps
in the finishing sequence, the piece may then enter an oven and, after cooling, may be sanded, after which
subsequent coatings may be applied.

Model Plants
        A cost analysis for an individual facility would use facility-specific information that presumably would
be readily available.  The cost analysis described here was performed for the entire wood furniture coating
industry. Therefore,  "model plants" were developed to represent the wood furniture coating industry. The
model plants were developed based on information supplied by wood furniture manufacturers, coating suppliers,
application equipment suppliers, and industry representatives.

        In developing model plants, the industry was broken down into two main groups:  residential  furniture
manufacturers and "other."  Included in the "other" category are cabinet manufacturers, office and institutional
furniture manufacturers, and store fixture manufacturers.
                                                 344

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         The "other" category uses « finishing sequence that consists basically of applications of stain, sealer,
 and topcoat. Residential furniture manufacturers using a short finishing sequence use essentially the same
 sequence, except they also apply a washcoat after the stain, before the sealer. Residential furniture
 manufacturers using a long finishing sequence use the same coatings as manufacturer! using a short sequence,
 but the coatings are applied more frequently and additional coatings, including filler, wiping stain, and highlight,
 may also be used.

         For purposes of the analysis, the size of the model plants was based on total annual VOC emissions.
 Total VOC emissions of 225 tons per year (tons/yr) corresponds to the medium model plant, and 500 tons/yr
 corresponds to the large model plant. The smaller  model plants were subdivided into three categories with the
 following emission cutoffs: extremely small - 10 tons/yr, very small - 35 tons/yr. and small - SO tons/yr.  The
 very small model plant cutoff has since been revised from 35 to 25  tons/year.

         The subdivision of model plants is shown in Figure 1.  For model plant  purposes, the residential
 furniture manufacturing segment,  which primarily uses solventborne nitrocellulose lacquer coatings, was further
 segregated by short and long finishing sequence, and then by size.  The majority  of the "other" category
 primarily uses acid-catalyzed solventborne coatings and generally one basic finishing sequence. The "other*
 industry segment was broken  down by manual and automatic spraying, and then by size. Due to the capital
 investment required for an automatic spray application system,  it was assumed that small facilities would not use
 automatic spraying.

 Lower-VOC Coatings Evaluated
         The first step of the life cycle analysis involved determining which lower-VOC coatings are technically
 feasible for the wood furniture coating industry.  A detailed description of the lower-VOC coatings available to
 the wood furniture industry is not provided here but can be found in the draft CTG.' Initially three primary
 lower-VOC coating types were identified as technically feasible for  at least some  segments of the wood furniture
 coating industry:  waterborne, polyester, and polyurethane.  (The UNICARB* coating system was  evaluated
 later and this analysis is discussed under the section titled "Additional Costs Evaluated").  Polyester and
 polyurethane coatings are similar in terms of VOC content, solids content, and price.  Therefore, in the cost
 analysis, polyester and polyurethane coatings were treated as a single category, referred to as
 polyester/polyurethane (pe/pu) coatings.  Waterborne coatings can be used exclusively or in conjunction with
 conventional solventborne coatings.  Similarly, pe/pu coatings can be used in conjunction with either
 conventional solventborne or waterborne coatings, or some combination thereof.

        A total of five lower-VOC coating control strategies were originally evaluated:  full waterborne, hybrid
 waterborne, pe/pu, hybrid pe/pu, and hybrid waterborne  in conjunction with add-on controls.  A full waterborne
 coating system, consisting of all waterborne coatings, was evaluated.  A full waterborne coating system was
 considered technically feasible for all the model  plants except the residential furniture manufacturers using a
 long finishing sequence.  A hybrid-waterbome coating system,  consisting basically of waterborne sealer and
 topcoat in conjunction with other conventional solventborne coatings, was considered technically feasible for all
of the model plants.  A pe/pu system, consisting of pe/pu sealer and topcoat, in conjunction with conventional
solventborne coatings, was evaluated. A hybrid pe/pu coating system, basically consisting of pe/pu sealer and
topcoat in conjunction with both waterborne and conventional solventborne coatings, was also evaluated.  The
pe/pu and hybrid pe/pu coating systems were considered  technically feasible for all of the model plants.  The
use of a hybrid waterborne coating system in conjunction with add-on controls controlling VOC emissions from
the solventborne coating steps was evaluated but like the other add-on control analyses,  will not be discussed
here.

REDUCTION IN  VOC EMISSIONS
        The thickness of a coating, once applied, is referred to as the coating "build."  The build  is a function
of the amount of solids applied. For all of the coating steps except stains, washcoats, and highlights, it was
assumed  that the amount of coating used is a function of the final coating thickness the user wants  to apply to
the piece. Thus, it was assumed that the total amount of solids applied would be independent of the coating
used. The solids content of lower-VOC coatings is generally higher than that of conventional  coatings.  For the
coatings for which build is important, this translates into decreased coating usage.  The amount of lower-VOC

                                                   345

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             Residential
               furniture
                                   Small 50 tons/yr
                                 Medium 225 tons/yr
                                   Large 500 tons/yr
      Short
    sequence
  Long
sequence
Small j j Medium] J  Large { | Small |  {Medium|  j Large }
                          Small] [Medium] [  Large |      |Medium|   [ Large |
                            Figure I. Model plants for the wood furniture CTG.

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 coating required wu calculated by multiplying the amount of convention*! coating required by toe ratio of the
 solids content of the lower-VOC coating to that of the conventional coating.

         For some very low-solids coatings such as stains, washcoats. and  "highlights, * color penetration, rather
 than build, is of primary importance.  Waterborae stains, washcoats. and highlights are formulated such that the
 coverage on a per-gallon basis is the same as their solventbome counterparts.  Therefore, it was assumed that
 the same quantity of these reformulated materials is required as of their solventborne counterparts.

         The VOC content of the reformulated coatings evaluated is generally lower than that of conventional
 solventborne coatings. Thus, for every gallon of reformulated coating used, less VOC is emitted. Using the
 VOC content and the quantity of conventional coating used and the VOC content and usage of the reformulated
 coating, the emission reduction was calculated for each reformulated coating step.  The approximate VOC
 emission reductions associated with each of the reformulated coating systems that were evaluated are shown in
 Table 1.  In calculating VOC emissions from all coatings, it was assumed that all of the VOC contained in the
 coating is emitted.

         TABLE 1. REFORMULATED COATING SYSTEMS, REDUCTIONS IN EMISSIONS BY
                                   INDUSTRY SEGMENT. PERCENT
Model plants
Waterborae system
Hybrid waterborne system
Polyester/polyurethane
system
Hybrid polyester/
polyurethane system
Residential furniture
short finishing
sequence
88
59
55
84
Residential furniture
long finishing
sequence
N/A*
54
50
51
"Other* industry
80
55
50
75
   *Not applicable.

COSTS ASSOCIATED WITH LOWER-VOC COATING SYSTEMS
        The variety of costs that may be associated with switching from a conventional solventborne coating
system to a lower-VOC coating system are shown in Figure 2.  These costs may include incremental coating
costs, the cost of increased material storage requirements, the need for additional drying capability,
modifications to the existing coating supply and application system, and the need for a clean room environment.
The costs that will be incurred when switching from a conventional to a lower-VOC coating system depend on
the existing facility and the type of lower-VOC coating system used.  Each of these costs is discussed below,
and the methodology used to estimate the costs is described.

Coating Cost
        Lower-VOC coatings are usually more expensive on a per-galion basis than conventional solventborne
coatings.  However, as discussed above, fewer gallons of many of the lower-VOC coatings are used, due to the
increased  solids content.  Therefore, there may be an incremental coating cost or savings associated with using
lower VQC coatings.  The cost of using both conventional and lower-VOC coatings is calculated by multiplying
the per-gallon cost by the total number of gallons of coating used. The difference between these costs
represents the incremental coating cost. The incremental coating cost of waterborne and hybrid waterborne
coating systems represents from approximately 65 to 90 percent of the total annualized costs of switching.
Incremental coating costs only represent from  1 to 36 percent of the total annualized costs for pe/pu coating
systems, and from 1 to 60 percent for hybrid pe/pu system*.
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     COSTS OF SWITCHING
   Coating cost

   Material storage

   Additional drying capability

   Coating circulation/application system
   modifications

   Clean room

   Operating costs

   Other costs
Figure 2. Potential costs of switching to lower-VOC coating systems.

                  348

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 Material Storage
         In medium and large wood furniture coating facilities, conventional solventborne sealers and topcoats
 are usually stored in large bulk tanks located outside the building. The other coatings are usually stored in
 SS-gallon drums or other containers inside the building in heated storage areas.  In small plants, all coatings are
 usually stored inside in containers in heated storage areas.  If a facility were to switch to waterbome or pe/pu
 sealers and topcoats, the reformulated sealers and topcoats would have to be stored indoors, so increased  indoor
 heated storage would be required.

         The amount of indoor storage required was calculated assuming all coatings are supplied in 55-gallon
 drums.  It was assumed that due to land constraints, the coating storage building would  be beside the existing
 building.  Waterbome coatings usually contain some solvent, and pe/pu coatings may contain solvent that
 becomes part of the final film.  Coatings that contain solvent may have to be stored in a 2-hour fire-rated
 building if the building is beside the main facility.  Therefore, assuming  the new storage area would be right
 next to the existing building is a conservative assumption.  In calculating the amount of storage space needed,
 the reformulated sealer and topcoat coating usage was first calculated.  Then using the calculated reformulated
 coating usage, the turnover rate was increased from once every 3 months to once per month. The  storage space
 requirements were calculated based on 20 percent excess capacity to provide for increased production.  The
 installed capital cost  of a 2-hour fire-rated  building averaged around  $380 per SS-gallon drum stored, based on
 4 square feet per drum.  It was assumed that the  existing bulk material storage tanks would be left  in place with
 no additional expense.

 Additional Drying Capability
         Some of the reformulated coating  systems may require additional drying capability. How this need is
 addressed depends on the existing facility,  the configuration and speed of the finishing line, the substrate being
 finished, and potentially many other factors.  In some facilities, the need for increased drying capability may be
 addressed by simply  slowing down the line (or increasing the amount of time allowed for drying in  a facility
 without a finishing line). In other facilities, upgrading existing ovens may be sufficient, whereas in still other
 facilities additional ovens may be needed.  For purposes  of our analysis,  it was assumed that the additional
 drying capability requirement would be provided  by adding high-airflow convection ovens to the existing line.
 It was assumed that space for the new ovens was available or could be made available at minimal expense.

         The number of ovens needed  varies depending on the size of the model plant, the type of reformulated
 coating system being used, and the number of existing conventional ovens.  For the waterborne coating systems,
 it was assumed that a preheater oven is needed before any coatings are applied and that  an oven  is required after
 each waterbome  coating is applied.  It was assumed that the pe/pu coatings cure via a catalytic reaction with the
 curing time reduced by means of an oven.  Therefore, an oven is needed after each pe/pu coating is applied.

         Based on information provided by oven suppliers, it was conservatively estimated that a new 20-foot
 long high-airflow convection oven would cost $48,600 installed. In  addition to the cost of the ovens, there are
 increased electrical and fuel requirements associated with operating the new ovens.  These costs  are discussed
 later with other additional operating costs associated with the use of  lower-VOC coatings.

 Coating  Circulation/Application System Modification
         If a facility switches from conventional solventborne coatings to waterborne coatings,  some
 modifications to  the coating circulation and application system will be required.  Modifications may have to be
 made to the coating circulation system as well as  to the supply lines  from the mix room to the spray booths and
the application system.  The cost to retrofit a facility with an appropriate paint circulation  system so that
waterbome coatings can be used is a function of the location of the central mix room relative to  the spray
booths (if a central mix room exists), the number of spray booths, and the number of mix tanks feeding the
spray booths.

         It was awumcd  that in a small facility there is no central mix room and that the coating materials are
pumped  directly  from a drum. located at the spray booth, to the spray gun. For small model plants a modular
paint delivery system is used to transfer coatings  from the drum to the spray gun.  A modular system consists of
a coating storage drum, the drum cover and assembly, fluid regulators, valves, pumps, hoses, and a spray  gun.

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 If waterbome coatings are used, all components of the modular system would have to be made of tUinlcti steel.
 Based on vendor information, a cost of $9,100 per modular spray unit was estimated.

          For medium and large facilities, it was assumed that a new stainless steel paint circulation system
 would be needed if waterborne coatings were used.  Modifications to the material transfer lines would be
 needed, as well as changes in the mix room and the spray booths.  The replacement stainless steel systems were
 assumed to be constantly recirculating systems.  The constant circulation of waterborne coatings is necessary to
 avoid agglomeration of the coating material in the supply lines.  The material transfer lines circulating coatings
 between the mix room and the spray booths would have to be  made of stainless steel.  It was assumed for the
 purposes of the  analysts that new stainless steel transfer lines would be needed at all facilities.  Based on
 information supplied by wood furniture industry representatives, 200 feet of coating transfer line is needed for
 each spray booth.  The 200 feet includes 100  feet from the mix room to the booth plus 100 feet of return line.
 Based on vendor information, stainless steel pipe (304 grade or better) suitable for the transfer of coatings costs
 $20 per foot of  pipe,  installed.

          For waterborne coatings, changes in the mix room will be required to accommodate coating storage, to
 agitate the coating material, and to pump and  regulate the coating materials. Based on vendor information, the
 installed capital  cost of a mix tank was estimated as $25,600.  The total installed capital cost of the mix tank
 assembly (pumps, agitator, valves, regulator, and hoses) was estimated as $8,800.

         Modifications would also be needed at the spray booths in medium and large facilities that switch to
 wmterborne  coatings.  The  spray booth equipment would have to be stainless steel capable of handling
 waterborne coatings; the required new equipment at each booth would  include fluid valves, a regulator, a fluid
 hose to the gun, an air hose, a paint heater, a  spray gun, and an oil/water separator for the air supply.  Based
 on vendor information,  it was estimated that the equipment described above would cost $1.400, not including
 the cost of the paint beater.  The paint heater would be supplied separately at a cost of $1,850. The above
 equipment would be needed at each spray booth.

 Clean Room
         According to coating suppliers, polyester and polyurethane coatings are very difficult to repair after
 curing.  If dirt gets on the  coated piece before it is fully cured, it cannot be removed by conventional means
 such as rubbing  and polishing.  Therefore, to minimirr the number of rejects that cannot be repaired, the pe/pu
 coatings should not be exposed to dirt and should be applied in a clean room environment. A clean room is
 maintained at a positive pressure to prevent dirt from entering, and all air entering the room is filtered.  The
 entire  finishing room may  function as a clean room, or the clean room may be a tunnel encompassing the
 booth/flash/oven area.  For the purposes of this analysis, it was assumed that the clean room would be in the
 form of a tunnel  encompassing die sealer and topcoat spray booth/flash/oven areas.

        The size of a clean room is a function of the dimensions of the finishing line and the total exhaust rate
 from the clean room tunnel.  The cost of a clean room tunnel is very facility-specific and difficult to assess for
 each of the broad model plant categories.  Two clean room vendors were contacted, but only one supplied the
estimated cost of installing  a clean room in an  existing furniture coating facility.  An approximate cost of $1
 million per clean room was provided by one vendor. It was assumed that if pe/pu coatings are used, one clean
 room tunnel would be required for each finishing line within the facility.  Due to the facility-specific nature of
clean rooms and  the single  cost estimate, there is less confidence in this estimate than in those associated with
other costs for switching to lower-VOC coatings.

Additional Costs  Evaluated
        Estimates of several additional costs have been made since the publication of the draft CTG.
Additional operating costs,  the cost of using a UNICARB* coating  system, and the costs of a flatline coating
operation switching to lower-VOC coatings were estimated and are  described below.

Operating Costs.   Additional operating costs associated with switching to lower-VOC coatings include the cost
of fuel and electricity required for the new ovens, the incremental waste coating disposal cost, and taxes,
insurance, and administrative expenses.
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         Increased fuel tnd electricity costs associated with the additional ovens are operating costs associated
 with the use of some lower-VOC coatings.  The fuel provides the heat, and the electricity is needed for the
 fans.  Based on information obtained from furniture and oven manufacturers, the per-oven natural gas
 requirements were estimated to be 700 million British thermal units per year.^'3 Oven manufacturers indicated
 that a typical oven used in the wood furniture industry requires about 12 kilowatts of electricity to operate.^4
 These fuel and electricity requirements translate into an operating cost of approximately $3.470 per oven
 annually.

         Based on information supplied by wood furniture manufacturing industry representatives, it was
 assumed that the volume of waste coating produced is about 5 percent of total coating use.  Because the heating
-value of conventional solventborne coatings is relatively high, the disposal cost is relatively low (about
 $0.70/gallon of waste coating) .  Because the heating value of waterborne coatings is relatively low, the
 disposal cost is relatively high (about $3.50/gallon of waste coating).   Therefore, when a facility switches to
 waterborne coatings, though the total volume of waste coating is less because fewer gallons of coatings are
 used, the overall waste coating disposal cost may increase.  It was assumed that there is no  incremental waste
 coating disposal cost associated with the  use of pe/pu coatings.

         Indirect annual costs are an operating cost associated with the purchase of any equipment.
 Administrative expenses were estimated as 2 percent of the total capital investment, and insurance and property
 taxes were both estimated to be 1  percent of the total capital  investment.

 Cost of the UNICARB* Coating System.  When the original cost analysis was performed, the UNICARB*
 coating system was not being used in production in any wood furniture manufacturing facility.  Because it has
 since been used in production in several wood furniture coating operations, the costs and VOC emission
 reduction associated with the UNICARB* system have been estimated. The UNICARB* system evaluated
 consists of reformulated sealer and topcoat being used with conventional coatings. The UNICARB* system can
 also be used in conjunction with waterborne coatings, although this option was not evaluated.

        The UNICARB* system uses CC<2 to replace some of the solvent in the coatings.  UNICARB* coatings
 are formulated only with coalescing solvents, diluent solvents are left out.  Coalescing solvents are slow
 evaporating, fluent solvents are fast evaporating.  The highly viscous coating and supercritical CC*2 are mixed in
 a chamber and released as atomized paint through a spray gun. The CC^ evaporates from the paint particles
 before they contact the product being coated.  The deposited paint containing the coalescing solvents cures in the
 conventional way.

        There is a reduction of VOC emissions associated with the use of UNICARB* coatings. The reduction
 in VOC emissions results from the lower VOC content of the UNICARB* coatings and the higher solids
contents of the coatings, similar to the waterborne coatings. The major costs  associated with switching from
conventional solventborne coatings to a UNICARB* coating system include the incremental cost of the coatings,
royalty  costs, the need for additional drying capability, the  UNICARB* spray system, COj and tank rental, and
CO2 storage.  The methodologies used to estimate these costs are described below.

        Because acid-catalyzed UNICARB* coatings have not been developed and UNICARB* spray equipment
as presently designed cannot spray two-component coatings, it was assumed that UNICARB* coatings are not
presently feasible for the "other* industry segment using acid-catalyzed coatings.  For residential furniture
manufacturers, the UNICARB* coating system consists of UNICARB* sealer and topcoat with conventional
nitrocellulose coatings for the remaining coating steps.

        The incremental coating cost associated with using UNICARB* coatings was calculated in the same
way as that for waterborne coatings.  Generally less of the UNICARB* coatings are required because of the
higher solids content; however, they are generally more expensive on a dollar-per-gallon basis. Incremental
coating  costs represent from  13 to 50 percent of the annualized costs of switching to the UNICARB* system.
The reduction  in VOC emissions for UNICARB* coatings was also calculated as it was for the waterborne
coatings, as previously described.  The emission reduction associated with the use of UNICARB* coatings
varies from about 35 to 40 percent.
                                                   351

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         There is a $2/gallon royalty charged by Union Carbide, the developer of the UNICARB* system.  The
 user must pay Union Carbide $2 for every gallon of UNICARB* coating sprayed.

         In reformulating conventional nitrocellulose coatings to make UNICARB* coatings, the faster solvents
 are replaced with supercritical  CC^.  Although UNICARB* coating manufacturers have attempted to minimize
 the drying time required with UNICARB* coalings, additional drying time and/or airflow is still required in
 some instances.  Therefore, it was assumed that an oven is needed  after each UNICARB* coating is applied.
 The capital and operating costs associated  with the additional ovens were estimated as described previously  for
 waterbome coatings.

         The UNICARB* coatings require a specialized spray application system to apply the coatings.  At
 present, Nordson Corporation is the only application equipment vendor that is manufacturing the UNICARB*
 spray application systems. According to information supplied by Nordson in 1992, a typical 0.4-gallon-per-
 minute unit designed for the wood furniture industry costs $35,000. This cost applies to a predesigned unit,
 with one spray gun. Each additional gun costs about $625.  Installation costs depend on the distance to the
 CO2 source and the coating material  supply source but typically costs around $4,500.7>8

         A single UNICARB* spray application system can supply multiple spray guns.  The number of guns is
 theoretically limited only by the maximum possible flowrate of the unit; Nordson Corporation has found that
 about four guns is the  practical limit.  Sealer and topcoat cannot be sprayed  from the same unit.  The furniture
 industry often uses multiple sheens of topcoat, and Nordson Corporation has designed and tested a unit that can
 spray multiple sheens of topcoat.  The additional manifolds and reservoirs needed to spray four different sheens
 adds $10,950 to the cost of the unit; each additional sheen costs $2,000.8

         In developing the costs for the model plants, it was assumed that regular UNICARB* units are used to
 spray sealer, and multisheen units are used to apply topcoat. The number of units required was determined by
 the finishing sequence  and the number of finishing lines.  For each  model plant, it was estimated that one
 additional  multisheen unit would be purchased as backup.

         As previously mentioned. CC«2 is  required when using UNICARB* coatings.  Based on information
 provided by the UNICARB* equipment manufacturer, the cost of CQ^ tank rental plus the cost of the CCU was
 $1.17/gallon of coating sprayed.'  In most instances, the CC^ is stored in bulk storage tanks.7-8 It was
 assumed that a storage building would be required for CC^ storage  and that the storage building would cost
 $15,000.5

         Operating costs associated with the purchase and use of a UNICARB* coating system include the  cost
 of fuel and electricity for the new  ovens, and taxes, insurance, and administrative costs.  These operating costs
 were estimated for the  UNICARB* system using the same methodology as that described earlier for the
 waterbome and pe/pu coating systems.  It was assumed that there is no incremental waste coating disposal cost
 associated with UNICARB* coatings.

 Flatline Coating  Operations.  Some percentage of the furniture manufacturing facilities presently use flatline
 coating operations to apply some or all of the coatings.  Some additional percentage of the industry spray-
 finishes flat components and then assembles the components. In many instances, these operations could also use
 flatline finishing methods.  The methodology that could be used to estimate the costs is presented, but due  to the
 preliminary nature of the estimates, the results are not presented.

        If an existing flatline coating operation were to switch from conventional solventborne coatings to
 lower-VOC coatings, the VOC  emission reduction would be associated with the decrease in usage associated
with the higher solids content and the lower-VOC content of the lower-VOC coatings. The costs associated
with such a switch would include the incremental cost of the coatings and other operating costs (oven electricity
and fuel requirements,  incremental waste disposal costs, and taxes, insurance, and administrative expenses).

        If an existing spray operation using conventional solventborne coatings was to become a flatline coating
operation using lower-VOC coatings,  the total coating usage would decrease  for two reasons: the increased
 solids content of the lower-VOC coatings and the increased transfer efficiency associated with flatline

                                                 352

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 application compared to that of spray application.  The costs of such a changeover would include the
 incremental coating cost (or savings), the cost of the flatline coaler, the cost of removing the old line, the capital
 and operating costs of additional ovens, the incremental cost of waste coating disposal, and taxes, insurance, and
 administrative expenses.

 OTHER CONSIDERATIONS

         There are other factors to consider in converting a facility from a conventional solventborne system to
 pe/pu coating system, a waterbome coating system, or a UNICARB* coating system.  These factors are
 discussed here,  but costs associated with these factors have not been assessed in this cost analysis because of
 their facility-specific nature.

         The  first factor regards physical modifications that a plant must undergo to accommodate pe/pu coating
 systems.  If a facility were to convert some or all of its coating steps to a pe/pu coating system, the facility
 would probably remove the existing finishing line (or a portion of it) and replace it with a new line housed in a
 clean room environment' This differs from the conversion to a waterbome coating system  in which the facility
 would most likely retrofit the existing line(s).  The cost for a facility to remove an existing finishing line may
 be significant but is not incorporated into the total installed cost of $1 million for a clean  room runnel.  Also, it
 was assumed  that the pe/pu coatings are two-component catalyzed coatings. *"•''  Catalyzed pe/pu coatings
 must be applied using two-pack spray application equipment. The catalyst must be measured (weighed) prior to
 mixing and an exact amount of catalyst is required.'2  The cost analysis in this chapter does not account for the
 replacement of existing spray equipment with the two-pack spray equipment, neither does it incorporate the cost
 of scales for weighing the catalyst and the cost to train workers to perform such a task.  Also, the short pot-life
 of the pe/pu coatings may result in a cost to the plant in terms of more waste, but this cost is not accounted for
 in this analysis.

         Another factor to consider in converting from conventional solventborne coatings to a reformulated
 coating system is costs associated with downtime.  Whenever a new coating system is installed, there is
 downtime associated with the installation and training of the workers. These costs have not been assessed.  One
 final consideration in implementing a pe/pu coating system is the toxicity of the coating materials. Air purifying
 respirators and, in some ins^ry^*, supplied air respirators are required when applying pe/pu coatings.   The
 cost analysis in this chapter does not account for the cost of this equipment, the cost to train workers to operate
 while wearing this equipment, or the cost of lost production, if any, due to the decreased  mobility of the
 worker.

         Several potential savings were also not quantified due to their facility-specific nature and the difficulty
 of quantifying the monetary value of reduced employee exposure.  Savings may result from switching from
 solventborne to lower-VOC coatings due to decreased worker exposure. The reduced exposure to solvents may
 result in • health benefit to the workers, which could conceivably result in decreased  worker absenteeism.
 However, it is difficult to accurately quantify the monetary value of decreased worker exposure or any decrease
 in absenteeism that may result.

         Savings may result from decreased insurance premiums if a facility switches from solventborne
coatings.  However, a Factory Mutual representative said that insurance premiums would not automatically
 reduce if a facility switched to waterborne coatings.  The representative indicated that decisions regarding
premiums are site-specific, and an analysis of an entire facility would be required.

 CONCLUSIONS - COMPARISON OF REFORMULATED COATING SYSTEM TOTAL COSTS
         Bw-amf the final wood furniture CTG is currently involved in a regulatory negotiation process, and the
 model plants and associated costs may change as a result of that process, the individual model plant  costs that
were developed as a result of the first cost analysis will not  be discussed specifically.  Instead, the relative cost
effectiveness of the various lower-VOC-coating alternatives evaluated are discussed.

        The cost effectiveness of the five lower-VOC coating systems evaluated is presented  in Figure 3.
 Generally, the analysis indicated that for the model plants evaluated, hybrid waterborae is the most cost-
 effective lower-VOC coating system alternative, with cost effectivenesses ranging from around $l,300/ton to

                                                  353

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                UNICARB
    HYBRID WATERBORNE
u>
Ul
           WATERBORNE
                   PE/PU
            PE/PU HYBRID
                                    2,000         4,000         6,000         8,000

                                      COST EFFECTIVENESS ($/TON VOC REDUCED)

                              Figure 3. Cost effectiveness of lower-VOC coaling systems.
10,000

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$2,800/ton of VOC reduced.  The UNICARB* coating system's cost effectiveaen ranges from around
$l,200/ton to S4,300/ton of VOC reduced.  The cost effectiveness of waterborne coating systems ranged from
about $2,200/too to $3,SOO/ton of VOC reduced. The cost effectiveness of pe/pu and hybrid-pe/pu coating
systems is considerably higher in most instances (up to around $9,600/ton).

        Caution should be used in evaluating the cost  effectiveness of the pe/pu and hybrid pe/pu systems.  The
lower cost effectiveness estimates for these systems correspond to the residential furniture (long finishing
sequence) and "other* (automatic spraying) model plants.  Uncertainty in the estimate of clean room costs and
the flowrates associated with automatic spraying operations results in uncertainty in the cost effectiveness
estimates for these model plants.  The actual cost effectiveness estimates for these model plants may  be higher.

        The UNICARB* coating system is presently not feasible for the 'other* category, which generally uses
acid-catalyzed coatings.  The cost effectiveness of the other four lower-VOC coating systems evaluated is
generally higher for the 'other* industry than for the residential furniture industry.  That is, it is generally more
expensive to reduce a ton of VOCs emitted for the 'other* industry than it is to reduce  a ton of VOCs for the
residential furniture industry.  The coatings used today by the 'other* industry segment are higher in solids than
those used by the residential furniture industry.  Therefore, the decrease in coating usage associated with
switching to a lower-VOC coating is less for the 'other* industry than for the residential furniture industry.
This relatively small decrease in coating usage for the  "other* industry translates into a higher cost per ton of
VOC reduced.

        The costs and emission reductions presented in this paper were developed based on the best  information
available at  the time.  The purpose of the paper is to demonstrate the methodologies that can be used to estimate
the costs and emission reductions associated with using lower-VOC coatings. As the regulatory negotiation
process progresses, and more information becomes available, the estimated costs may change.
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                                             REFERENCES

  1.  Guideline Series - Control of Volatile Organic Compound Emissions from Wood Furniture Coating
     Operations.  Draft Chapters 1-5, Appendices A and C.  U. S. Environmental Protection Agency, Office of
     Air Quality Planning and Standards, Research Triangle Park, North Carolina.  October 1991.

  2.  Telephone Conversation. Christie, S., Midwest Research Institute (MRI). with Miller. D.. George Koch &
     Sons, Inc. October 21, 1991. Propeller oven fuel consumption.

  3.  Telephone Conversation. Caldwell, M., MRI, with Sale, W., Broyhill Furniture Industries.  September 17,
     1990.  Clarification of survey response.

  4.  Telephone Conversation, Caldwell. M., MRI. with Carl, D., George Koch & Sons.  March  11, 1992.
     Information regarding turbulator ovens.

  S.  ENSR Consulting and Engineering.  An Evaluation of VOC Emission Control Technologies for the Wood
     Furniture and Cabinet Industries.  Volume I of D, Technical Feasibility and Costs.  Sponsored by the
     American Furniture Manufacturers Association, Business and Institutional Furniture Manufacturers
     Association, and National Paint and Coatings Association, 1992.  200 pp.

 6.  Telephone Conversation, Caldwell, M., MRI, with Morgan, R., Union Carbide Chemicals and Plastics
     Company, Inc. May 7, 1991. The use of UNICARB* with acid-catalyzed coatings.

 7.  Telephone Conversation. Caldwell, M., MRI. with West, T.. Union Carbide Chemicals and Plastics
     Company. Inc. April 2. 1992. The UNICARB* system.

 8.  Telephone Conversation. Caldwell, M., MRI, with Daignault, C., Nordson Corporation.  April 6.  1992.
     The UNICARB* spray system.

 9.  Miller. S.  High Solids Coatings.  Products Finishing 1990 Directory,  pp. 32-37.

10.  Telephone Conversation. Caldwell, M.. MRI. with Riberi, B., Mobay Corporation.  August 27,  1990.
     Clarification of survey response.

11.  Dombey, S.  Woodworker's Guide to Conventional Finishes. Furniture Design & Manufacturing.
    January 1988. pp. 54-57.

12. Schrantz, J. Regs Could Severely Impact  Agricultural/Heavy Construction Equipment Finishes.  Industrial
    Finishing.  May 1991.  pp.  21-26.

13. Telephone Conversation. Beall, C., MRI, with O'Block, S., Miles, Inc. January 22, 1992.  Toxicity and
    safe handling of isocyanatea.

14. Telephone Conversation.  Beall. C., MRI. with Febo, F., Allendale Insurance Company.  January 2 and 3,
     1992. Impact of various control options on insurance premiums for the wood furniture industry.
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DEVELOPMENT OF ULTRA-LOW VOC WOOD FURNITURE COATINGS
                            Prepared By:
                          Eddy W. Huang
                Center for Emissions Research &. Analysis
                   dry of Industry, California 91748

                           Larry Watkins
              South Coast Air Quality Management District
                    Diamond Bar, California 91765

                        Robert C. McCrillis
                 17.5. Environmental Protection Agency
             Air and Energy Engineering Research Laboratory
              Research Triangle Park, North Carolina 27711
                               357

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 ABSTRACT

 It is estimated that the annual U.S. market for wood coatings is approximately 240,000 mj (63
 million gallons). On this basis, between 57 and 91 million kilograms (125-200 million
 pounds) of volatile organic compounds (VOCs) are emitted into the air each year from the
 use of presently used water-borne and solvent-borne systems. The use of  "VOC-free"
 formulations where possible would reduce such air pollution while providing new markets for
 industries.

 Adhesive Coatings Company (ADCO), a small firm specializing in low VOC, two-component,
 water-based epoxy coatings, holds patents on some of these formulations.  Polymer
 composition variations of the basic epoxy polymer in combination with each of several curing
 agents were prepared.  The resulting emulsions were analyzed through laboratory tests to
 measure gloss value, drying time, hardness/flexibility, level of solvents, and chemical and
 stain resistance.

 The new formulations contain < 10 g/1 (0.1 Ib/gal) VOCs which means that these coatings
 emit practically no VOCs.  The physical properties in the can, as applied, and as the cured
 finish are  discussed.

       DISCLAIMER:   The  work  represented by  this  document  has
       been funded  in part  by the  U.S. Environmental
       Protection Agency.  The  document  has  been  subjected to
       the  Agency's peer  and  administrative  reviews and has
       been approved  for  publication.  Mention of  trade names
       or commercial  products does not constitute  endorsement
       or recommendation  for  use.

 1.0 INTRODUCTION

 It  is estimated that the annual U.S. market for wood coatings is approximately 240,000 m3 (63
 million gallons). On this basis, between 57 and 91 million kilograms (125-200 million
 pounds) of volatile organic compounds (VOCs) are emitted into the air each year from the
 use of presently used water-borne and solvent-borne systems.  The use of  "VOC-free"
 formulations  where possible would reduce such air pollution while providing new markets for
 industries.

 The South  Coast Air Quality Management District (SCAQMD) Rules 1104 and  1136 - Wood
 Products Coatings require reduction of VOCs from such sources.  It is estimated that
 SCAQMD-wide compliance with these rules would reduce VOC emissions by about 18 Mg
 (20 tons) per day through a gradual  shift from high to low VOC coatings.  By phasing in low
 VOC coatings, instead of requiring installation of add-on controls, SCAQMD believes that
 furniture manufacturers will be able to comply with SCAQMD's rules without increased
costs.  To remain competitive in the regulated South Coast Air Basin, coatings formulators
and furniture  manufacturers have expressed interest in seeing further developments in low
                                      358

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 VOC coatings technology.

 Adhesive Coatings Co. (ADCO), a small firm specializing in development and
 commercialization of low VOC, two-component, water-based epoxy coatings, is currently
 developing coatings which will comply and/or exceed the emissions standards set forth in
 Rules 1104 and 1136.  ADCO currently holds patents on some of these formulations. It is
 estimated that new formulations of these two component water-based epoxy coatings have the
 potential to achieve a significant share or complete replacement of the current organic
 solvent-based coatings.  The new formulations contain < 10 g/1  (0.1 Ib/gal) VOCs which
 means that these coatings emit practically no VOCs.

 Several  large companies that manufacture and supply products used in the wood coatings
 industry have been contacted. The product marketing discussions have centered on how best
 to commercialize specific ultra-low VOC finished coating applications.  Discussions already
 are underway with two major corporations, both of which are worldwide suppliers of
 industrial products and services to the coatings, adhesives, and polymer  industry and
 recognized as leaders in providing coatings and ancillary products for the wood industry.

 Project Participants:

 ORGANIZATION                    CONTACT               PHONE NO.

 Center for Emissions                  Eddy W. Huang           (818) 854-5868
 Research & Analysis

 U.S. Environmental                   Robert C. McCrillis       (919)541-2733
 Protection  Agency

 Adhesive Coatings Co.                 James Shannon            (415) 571-7947

 South Coast Air Quality               Larry Watkins             (909) 396-3246
 Management District
2.0 OBJECTIVES

The objective of this project is to develop new low/no VOC wood coatings through
continuing research, formulation adjustments, and application testing.  In addition to the basic
development of the coatings, a marketing plan will be developed to get the products of this
project into the public's use.

Efforts are dedicated to conduct joint research into new promising technologies that are
sufficiently mature for demonstration to wood product manufacturers.  The high value added
coating products are developed utilizing existing technical know-how, data, and patents
                                        359

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  related to the new technologies.


  3.0  PROJECT DESCRIPTION

  This new wood coating system consists of an epoxy component (Part A) and an amine curing
  component (Part B). The complete absence of organic solvents means that this new coating
  system is not only less hazardous to use but emits practically no VOCs and therefore does not
  significantly contribute to air pollution. The ultra low VOC content of these new wood
  coatings  was confirmed by tests at the Center for Emissions Research & Analysis (the Center)
  (see Table A). This new two component water-based epoxy wood coating system has the
  potential to set a new  standard and therefore replace a very significant share of current
  organic solvent systems in use.


  3.1 Coating Characteristics:

  This new ultra-low VOC wood coating system is a high performance, two-pan, chemically
  cured,  water reducible, fast drying, epoxy product used as a wood coating.  It is a hard,
  durable primer coating that can be applied to a variety of wood surfaces. The coating system,
  as it now stands, has the following performance properties:

     (a) Less than  10 g/1 (0.1 Ib/gal) VOCs,

     (b) Liquid with rapid initial drying characteristics upon application,

     (c) Hardness,

     (d) Flexibility,

    (e) Chemical resistance,

    (0  Effort still required to improve sandability, and

    (g) Effort still required to lessen wood discolorization.


3.2 Technical Approach:

The coating development steps are to make the necessary formulation adjustments, continue
with application testing to improve the product characteristics, and overcome the
shortcomings.  The goal of the project is to develop a wood coating system that will set new
industry standards for VOC levels.
                                        360

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 The results of the research procedures and laboratory tests are documented and written status
 reports are prepared detailing the work completed to date along with the identification of
 areas that may require further investigation.

 The technical approach has centered around the following activities:

 1.  Work towards reformulating ADCO's patented epoxy polymer in combination with
     different curing agents.

 2.  Identify those compositions that yield the best overall coating performance in terms
     of gloss value, drying time, hardness/flexibility, and chemical and stain resistance.

 3.  Conduct the emission tests required to determine whether the compositions selected
     have less than 10 g/1 VOCs.

 4.  Formulate emulsions with white pigment for those compositions that meet the
     performance criteria and emissions limits.

 5.  Identify those pigmentations that yield the best overall coating performance in terms
     of gloss value, drying time, hardness/flexibility, and chemical and stain resistance.

 6.  Conduct the emission tests required to determine whether the pigmentations selected
     have less than 20 g/1 VOCs.

 7.  Prepare different finished wood panel coupons, both clear and pigmented, to
     demonstrate finished coatings that meet the performance criteria and emissions limits.

 8.   Assess the market acceptance by a written survey and develop two annual marketing
     reports to summarize the survey results, manufacturer acceptance, cost  benefits, and
     any application limitations.
33  Task Description:

The program for making formulation adjustments and undertaking the necessary application
testing to meet the desired product characteristic goals are outlined in the following tasks:

Task 1 - Formulation variations

Polymer composition variations of the basic epoxy polymer in combination with each of
several curing agents were conducted. The resulting emulsion was analyzed through
laboratory tests to measure gloss value, drying time, hardness/flexibility, level of solvents, and
chemical and stain resistance. All test results were documented.
                                        361

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 Product coating characteristic criteria used in this project included but are not limited to:

     1.     The product will contain VOCs < 20 g/1.

     2.     The product will have a gloss value in the 90-100 range as measured on an 80
            degree gloss meter.

     3.     The product will "dry to the touch" in  10 minutes or less and "dry to handle" in
            IS minutes or less for temperatures in the range of 45 to 60°C with a relative
            humidity not to exceed 80%.

     4.     The product will have a demonstrated pencil hardness of at least 2H.

     5.     The product will have a demonstrated chemical, water stain, and chip resistance
            comparable to other products for the same general use.


 Task 2 - Variations in pigmentation

 An emulsion was formulated with white pigment for the best epoxy polymer/curing agent
 ratios  selected in Task 1.  Laboratory tests were conducted to measure gloss value, drying
 time, hardness/flexibility, level of solvents, and chemical and stain resistance. All test results
 were documented.


 Task 3 - Preparation of finished coating samples

 The existing two-component spray application system developed by Binks Manufacturing Inc.
 was modified  and the application of the coatings was evaluated to determine if it meets the
 production requirements of wood furniture manufacturers. The results are shown in Table B.


 Task 4 - Market development

 Several wood  furniture manufacturers and coating suppliers were contacted to identify wood
 coating concerns, current application methods, costs, and critical areas for product
 improvements. Marketing information related to the wood coatings market was collected.
 The market segments in turn are subsegmented into wood furniture, kitchen cabinets,  new
 case goods, plywood (hardboard), regenerated wood products, flat stock finishes, and  specialty
 finishes. This information was reviewed to establish what specific data still need to be
 collected and how they should be used in structuring the planned market survey of wood
 coating suppliers.

Two market development reports will be prepared to summarize  how the new wood coatings
                                         362

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 address the concerns of the marketplace, potential cost benefits, and limitations.
 4.0 RESULTS AND FUTURE DEVELOPMENT

 Work on variations of the patented epoxy polymer in combination with different curing agents
 was finalized (see Table C).  The synthesis of the resin into a new resin was completed and
 was followed by the emulsification of the product in water. Analysis was expended by
 selecting those additional curing agents not previously evaluated but were known to be
 sufficiently reactive to achieve proper film formation and acceptable properties.  Each
 resulting film is characterized as to its properties (see Table D).

 Various formulations of curing agents in combination with the various epoxy polymers were
 evaluated to precisely identify those combinations that yield the best overall coating
 performance  and meet the desired coating characteristic criteria (see Table D).
Table A. VOC content of wood coatings
SAMPLE DESCRIBED AS:
SOURCE:
ANALYTICAL
Volatile content
3792 (GC), and
ADHESIVE COATINGS CO.
PART B 65-99 (CLEAR)
PART A 76-64 (WHITE)
2755 Campus Drive, Suite 125
San Mateo, CA 94403
WORK PERFORMED, METHOD OF ANALYSIS, AND RESULTS:
by ASTM-D-2369-811, density by ASTM-D- 1475-60, water by ASTM-D-
calculations by ASTM-D-3960-81 Section 8.2.4.
VOCs content2
VOCs, g/1 (of coating) = <10
VOCs, g/I (of material) = <10
The Center will also develop a low/no VOC "sanding sealer" wood coating so that a complete
1   The detection limit for VOCs is 10 g/1.

2   The two products (76-64 and 65-99) were mixed 5 :  1 prior to actual analysis.
                                       363

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  low/no VOC wood coating system will be available for public use. The extra developmental
  work will be focused on reformulating wood base coatings, determining performance
  characteristics and conducting application and emission testing for a new fast drying, solvent
  free wood sanding sealer.
                     Table B.  Physical properties of applied finish
        COLOR
Clear or pigmented white
        SERVICE
        TEMPERATURE LIMITS
-18 to 120° C (0 to 250° F).
May discolor over 60° C (140° F) after a long
period of baking
        GLOSS
Clear coating - 90 @ 80° meter
Pigmented coating - 75 @ 80° meter
        HARDNESS
Pass 2H pencil
        FLEXIBILITY
Pass 3 mm (1/8 in.) mandrel bend on steel
        IMPACT RESISTANCE
Direct -        Pass 3 m/kg (60 in./lb)
Indirect •       Pass 1.5 m/kg (30 injlb)
        ADHESION
Pass Crosshatch 100%
        STAIN RESISTANCE '
        (After 1 hour of exposure)
Coating is resistant to:
  Coffee
  Grape juice
  Mustard
  Ketchup
  Carbonated cola beverage
  100 proof vodka
  Shoe polish
  Laundry spot cleaner
  Detergent
  1,1,1 trichloroethane
  Acetone
  Petroleum solvents
  Ethyl alcohol
Cure conditions including curing rate, extended pot-life, and rheology modifications to include
use of thickeners in the formulation for adjusting the flow of coatings will be evaluated.
Both "clear" and "white" finished wet samples for emission testing will be prepared utilizing
a two-component variable ratio spray application gun.
                                       364

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Table C. Physical properties (in the can)
APPEARANCE
VISCOSITY
PH
TYPE
DENSITY
SOLIDS
FLASH POINT
SHELF LIFE
VOC CONTENT
Milky white, single-phase, creamy liquid
Part A: 0.9 Pa.s (900 centipoise)
Part B: 0.9 Pa.s
5.5 to 7.5
Two components:
Part A - Epoxy emulsion
Pan B - Curing agent
Clear: 1030 g/1 (8.60 Ib/gal)
White: 1500 g/1 (12.5 Ib/gal)
50% by volume
over 150° C (300° F)
> 6 months
< 10.0 g/1 (0.1 Ib/gal)
Table D. Application properties
MIX RATIO
THINNING SOLVENT
CLEANUP
FILM THICKNESS
THEORETICAL COVERAGE
DRYING TIME @ 50° C
RECOATABILITY
Pan A - 5 parts
Pan B - 1 pan
Water
Warm soapy water
75-125 urn (3.0-5.0 mils) wet
40-65 urn (1.5-2.5 mils) dry
9 mVl (360 frVgal) @ 50 pm (2 mils)
To touch: 10 rnin
To recoat: 20 min
Tack free: 15 min
Full cure: 60 min
Very good
365

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366

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                         SESSION 9
              AEROSPACE APPLICATIONS
                      PAPERS PRESENTED:

        "Replacement of Chromated Epoxy Primers/Wash Primers for
       Ground Support Equipment and Space-Related Flight Hardware"
                               by
                         Mark E. Lindsay
              Lockheed Missies & Space Company, Inc.
                       Sunnyvale, California

'An Investigation of flexibility Test Methods for Low-VOC Aerospace Coatings"
                               by
                         Angela M. Brown
                  Boeing Defense & Space Group
                        Seattle, Washington

                       "Waterborne Maskant"
                               by
                          Mark D. Jaffari
                           Malek, Inc.
                       San Diego, California

     "Low-VOC Organic Coatings for Commercial Aircraft Application"
                               by
                           T. D. Leland
                           C. M. Wong
                Boeing Commercial Airplane Group
                Materials and Processes Engineering
                        Seattle, Washington
                              367

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

      Replacement of  Chromated  Epoxy Primers/Wash Primers  for
    Ground  Support Equipment and Space Related Flight Hardware

  Mark E. Lindsay
  Lockheed Missiles & Space Company, Inc.
  P.O. Box 3504
  O/78-30, B/564
  Sunnyvale, CA 94089-3504

  INTRODUCTION
        Hexavalent chromium is listed as a hazardous air pollutant (HAP) under
  Section  112 of the Clean Air Acv of 1990.  In 1990, Lockheed Missiles and
  Space Co. (LMSC) took a proactive approach to eliminate/reduce the use of
  chromate containing compounds. Compounds containing hexavalent
  chromium are used as corrosion inhibiting pigments in paint primers such as
  epoxy primers and wash primers.

        LMSC uses several epoxy primers and wash primers that contain up to
  50% by weight chromated compounds as pigments. The primers primarily
  serve three functions. They (1) increase the compatibility between the substrate
  and the topcoat, (2) improve adhesion, and/or (3) improve the corrosion
  resistance of the substrate. Wash primers are used as a pretreatment for bare
  steel, copper, nickel, titanium, and aluminum surfaces to promote adhesion
  prior to priming where an immersion chemical treatment is not feasible. When
  this study began, eight chromated epoxy primers/wash primers were identified
  in use at LMSC (see Table I).

             TABLE I - LMSC  CHROMATED  PRIMERS
SPECIFICATION
MIL-P-23377
LAC 37-4467
MIL-C-8514
DOD-P-15328
LAC 37-4850
MIL-P-85582
TT-P-1757
LAC 37-4698
DESCRIPTION
Epoxy primer
Chemglaze primer
Wash primer
Wash primer
Zinc chromate primer
Water reducible primer
Zinc chromate primer
Wash primer
CHROMATE CMPD.
Strontium chromate
Zinc chromate
Zinc chromate
Zinc chromate
Tine chromate
Barium/strontium
Zinc chromate
Zinc chromate
USAGE 1989-90
75 gal/year
48 gal/year
8 gal/year
Not used in 1990
Not used in 1990
6 gal/year
2 gal/year
2 gal/year
  APPROACH
  Epoxy Primers
        The approach for replacing epoxy primers is illustrated in Figure I.
  Chromate free epoxy primers were evaluated for the two major applications in
  LMSC's Space Systems Division (SSD); ground support equipment (GSE) and
  space related flight hardware (SRFH). The approach consists of identifying
  candidates, screening the candidates and performing additional tests
  depending on the application (GSE or SRFH). The requirements for the
  screening tests are presented in Table II and the specific requirements for GSE
  and SRFH are presented in Tables III and IV, respectively.

                                  369

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                       Rgurel
            Approach to Replace Epoxy Primers
                        PHASE I
                  IDENTIFY CHROMATE-FREE
                        PRIMERS
                             • VOC <340 g/1
                             • Chromate-free
                             • Non-toxic pigment
                             •Commercially Available
                          PHASE II
                     SCREENING PROCESS
TESTS
• See Table II
MATERIALS
• MIL-C-65285 polyurethane
• MIL-C-22750 epoxy topcoat
• TT-L-32 lacquer
                                 I
                              PHASE HI
                         APPUCATION TESTS
SUBSTRATES
•2024 Al bare
•2024 Aldad bare
•2024 Al chem filmed
•6061 Al bare
•6061 Al chem filmed
•Cold relied steel bare
        GSE Requirements
        •See Table III
                         SRFH Requirements
                         •See Table IV
   GSE = ground support equipment
   SRFH = space related flight hardware
                                 370

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TABLE II - SCREENING TEST REQUIREMENTS AND METHODS
TEST
Viscosity-initial
Viscosity-spray
Outgassing
Dry time
Appearance
Adhesion
Lifting
Knife test
Impact resistance
Water resistance
Salt spray
resistance
Filiform corrosion
resistance
Fluid resistance
Gloss
Volatile organic
content
REQUIREMENTS
Info only
Info only
Collected volatile condensable
material: 0.1% max.
Total mass loss: 1 .0% max.
Tack-free: Info only
Dry hard: Info only
Smooth and uniform. No runs,
sags, orange peel, wrinkling.
bumps, fisheyes, pinholes. craters,
blisters, grit, or seeds.
No lifting, peeling, or coating
separation
No lifting or film irregularity after 5
hours
No flake, chip, or powder
10% min. impact elongation
No softening, wrinkling, or
blistering
No blistering, lifting, or corrosion
0.25" corrosion max. from scribes
lines
Lubricating oil: No softening,
blistering, or adhesion losf
Hydraulic oil: No softening,
blistering, or adhesion loss
30 max.
340 g/I max.
METHODS
#4 Ford cup
#4 Ford cup
ASTM E 595
ASTM E 595
Visual
Visual
Visual
FTMS141,
Method 6301
Visual
FTMS141.
Method 6304
GE Impact tester
4 days in Ol water
at120F
Scribed, 1000 hours
in 5% salt fog
Scribed, 1000 hours
in 80% RH at 40C
Immersed for 24
hours at 250F
Immersed for 24
hours at 150F
60 degree gloss
meter
BAAQMD method
           Table III - REQUIREMENTS FOR GSE
Test
5% salt spray resistance
Filiform corrosion resistance
Wet tape adhesion
Intercoat adhesion
(topcoats: MIL-C-85285, Am-E-Pox
Enamel and MIL-C-22750)
Requirement
1000 hours
1000 hours, 0.25 in max.
scribe line
lifting on
No lifting
No separation
                        371

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              Table IV - REQUIREMENTS  FOR  SRFH
Test
Dry tape adhesion
Intercoat adhesion
(topcoats for flight hardware}
Outgassing
Coefficient of thermal expansion
(CTE)
Requirement
No lifting
No separation
TML:1.0%max.
CVCM:0.1%max.
similar to current primer
(LAC 37-4467 Che mg laze primer)
Wash Primers
      Bay Area Air Quality Management District (BAAQMD) regulation changes
for wash primer VOC (780 g/l to 420 g/l) in 1991 prompted LMSC to investigate
replacement wash primers for GSE. A similar approach to the approach
described in Figure 1 for epoxy primers was used to replace wash primers. The
requirements for wash primers are listed in Table V.

            TABLE  V -  WASH  PRIMER  REQUIREMENTS
Test
Dry time
Appearance
Wet tape adhesion
bare steel and aluminum
Compatibility with
primers (MIL-P-23377,
MIL-P-53030 and MIL-
P85382)
VOC
Requirement
Info only
Smooth, uniform no runs
No lifting, peeling or
separation
No intercoat adhesion
loss
420 g/l max.
Method
Visual
Visual
FTMS 141, Method 6301
Visual
»
BAAQMD Method 22 or
23
RESULTS
Epoxy Primers
Phase I. An industry search and literature review identified six potential
replacement primers which are chromate-free, have VOCs less than 340 g/l,
and are commercially available. The six epoxy primer candidates identified are
listed in Table VI.

            TABLE VI -  EPOXY PRIMER  CANDIDATES
Manufacturer
Deft
DeSoto
Akzo
Lord Chemical
Savannah
Gavlon
Product Identification
44-R-8A/44-W-7 (MIL-P-53030)
PR-330/ACT-330
41407B534
K3803A
D-213 Industrial Red
9815-8509
Description
Water reducible
High solids
Ultra-guard high solids
Urethane, high solids
High solids
High solids
                               372

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 Phase II.  During the initial screening tests, it was found that the Lord Chemical
 primer (K3803A) only had a pot life of 10 to 15 minutes. This candidate was
 eliminated. The screening test results for the remaining 5 candidates are
 presented in Table VII.

 Phase III. The tests for GSE application were all included in the Phase II
 testing, thus no additional tests were needed for this application. The test
 results for the SRFH are presented in Table VIII.

     TABLE VIII* - MIL-P-53030 PRIMER RESULTS FOR SRFH
Test

Dry tape
adhesion
Intercoat
adhesion
Outgassing
CTE,
um/m°C
•Testl
CTE,
um/m°C
•Test 2
Coating

primer
primer & A276
white PU topcoat
primer & Z306
black PU topcoat
pnmer
primer & A276
white PU topcoat
primer & Z306
black PU topcoat
pnmer
pnmer
Result
Deft primer
(MIL-P-53030)
Pass
Pass
Pass
TML: 2.5 - 2.9%
CVCM:0.15-0.35%
TML: 4.0 - 5.5%
CVCM: 0.01 - 0.08%
TML: 1.4 -4.9%
CVCM: 0.04 - 0.14%
ai = 29.2
«2 = 73.8
ai = 23.8
«2 = 675
9922 primer
(control)
Pass
Pass
Pass
TML: 2.0 -2.1%
CVCM: 0.04 - 0.05%
TML: 3.8 - 4.8%
CVCM: 0.02 - 0.03%
TML: 1.4 -2.7%
CVCM: 0.01 - 0.04%
ai = 40.7

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TABLE VII - SCREENING PROCESS TEST RESULTS
TEST
Viscosity-initial
Viscosity-spray
Oulgassing: CVCM
TML
Dry Time: Tack-free
Dryhard
Appearance
Lilting
Knife test
Impact resistance
Water resistance
Salt spray resistance
Filiform corrosion resistance
Fluid Resistance: Lube oil
Hydraulic oil
Gloss
Volatile organic content
Adhesion: (Wet Tape)
2024 A1 with MIL-C-5541, Cl. 1A
2024 Alclad. solvent cleaned
2024 Alclad, with TT-L-32 topcoat
6061 Al, solvent cleaned
6061 Al with MIL-C-5541, Cl. 1A
Steel, solvent cleaned
Steel, sandblasted
Adhesion: (DryTqpe)
2024 Al with MIL-C-5541, Cl. 1A
2024 Alclad, solvent cleaned
2024 Alclad, with TT-L-32 topcoat
6061 Al, solvent cleaned
6061 Al with MIL-C-5541, CM A
DEFT
26 seconds
26 seconds
0.073%
.92%
30 minutes
1.0 hours
Pass
Pass
Pass
30%
Pass
Pass
Pass
Pass
Fails
3 units
2800/1

Pass
Fails
Pass
Fails
Pass
Pass
Pass

Pass
Pass
Pass
Pass
Pass
DE SOTO
25 seconds
25 seconds
0.002%
3.86%
2.5 hours
3.5 hours
Pass
Pass
Fails
4%
Pass
Fails
Fails
Pass
Pass
15 units
339oyi

Fails
Fails
Fails
Fails
Pass
Pass
Pass

Fails
Pass
Pass
Fails
Fails
SAVANNAH
Too thick
19 seconds
0.07%
3.07%
60 minutes
2.5 hours
Pass
Pass
Pass
30%
Pass
Fails
Pass
Pass
Pass
0.9 units
471 g/l

Pass
Fails
Pass
Fails
Pass
Fails
Fails

Pass
Pass
Pass
Pass
Pass
GAVLON
Too thick
18 seconds
0.40%
2.73%
30 minutes
2.0 hours
Pass
Pass
Pass
20%
Pass
Pass
Pass
Pass
Pass
1.5 units
4010/1

Pass
Fails
Fails
Fails
Pass
Fails
Fails

Pass
Pass
Pass
Pass
Pass
AKZO
15 seconds
15 seconds
0.26%
5.10%
14 hours
22 hours
Pass
Pass
Pass
30%
Pass
Pass
Pass
Pass
Pass
29 units
287 o/t

Pass
Pass
Pass
Pass
Pass
Pass
Pass

Pass
Pass
Pass
Pass
Pass

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TABLE IX - WASH PHIMER WET TAPE ADHESION TEST RESULTS
Coating
Wash Primer
Den 46-W-4
MIL-C-8514
Primer
MIL-P-53030
MIL-P-23377
MIL-P-85582
MIL-P-53030
MIL-P-23377
MIL-P-85582
Topcoat
MIL-R-85285
MIL-R-85285
MIL-R-85285
MIL-R-85285
MIL-R-85285
MIL-R-85285
Substrate
Bare Steel
Pass
Fails
Pass
Pass
Fails
Pass
6061 Al
Pass
Pass
Fail
Fail
Pass
Fail
         TABLE X - WASH PRIMER TEST RESULTS
Coating
Deft 46-W-4
Deft 46-W-4
Deft 46-W-4
Deft 46-W-4
MIL-P-53030
MIL-R-85285
Substrate
N/A
N/A
Steel
Steel
Test
Dry time
VOC
Appearance
Adhesion, FTMS
141, Method
6301 w/o cuts
Result
Tack Free: 30 min.
Dry hard: 1 hour
183g/L
Pass
Pass
                      375

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 DISCUSSION
 Epoxy Primers
       The primary function of epoxy primers is to (1) increase its compatibility
 between the substrate and the topcoat, (2) improve adhesion, and/or (3)
 improve the corrosion resistance of the substrate. The process screening tests
 include tests to verify that the primers will function as required, evaluate the
 application characteristics (i.e. dry time, appearance) of the coating, and verify
 BAAQMD VOC requirements are met.  The process screening tests (see Table
 II) were derived from MIL spec requirements for paint primers (i.e. MIL-P-23377
 - Primer Coatings: Epoxy, Chemical and Solvent Resistant).

       A major concern in using chromate-free primers is the potential toss of
 corrosion resistance.  Filiform corrosion resistance and salt spray resistance are
 two tests that evaluate corrosion resistance. In filiform corrosion resistance,
 primed and topcoated panels are "X" scribed, placed in concentrated
 hydrochloric acid for an hour, and then placed in a chamber at 104F and 85%
 relative humidity for 1000 hours. Filiform corrosion appears as threadlike
 filaments initiating from the exposed substrate and spreading underneath the
 coating. The test simulates damage to the surface of a piece of hardware and
 how well the primer prevents further coating damage. In salt spray resistance,
 primed panels are "X" scribed and placed in a 5% salt fog chamber.  Salt spray
 is intended to reproduce corrosion that occurs in salt spray conditions.  MIL-P-
 53030, Gavlon, and Akzo all passed both filiform and salt spray corrosion
 resistance. Savannah passed filiform but failed salt spray resistance. The
 DeSoto primer failed both of the corrosion resistance tests.

       MIL-P-53030 had good wet tape adhesion on alodined aluminum and
 bare and sandblasted steel.  Akzo passed all the wet tape adhesion tests. Both
 Savannah and Gavlon passed wet tape adhesion on alodined surfaces but
 struggled on bare surfaces and sandblasted steel. DeSoto failed most of the
 wet tape adhesions on both bare and alodined aluminum.  All but DeSoto
 passed all the dry tape adhesion testing.

       MIL-P-53030's ease of application and one hour dry time help make it
 practical for manufacturing to use. Akzo was also easy to apply but has a long
 tack-free time (14 hours) and dry hard time (22 hours) which can be
 inconvenient for manufacturing to use.  The DeSoto primer was easy to handle
 but was brittle, contributing to the aforementioned failures in adhesion. Both
 Gavlon and Savannah handled adequately and had acceptable dry times but
 both required significant solvent thinning to reach spray viscosity.  The Lord
 primer had a pot life of 10-15 minutes.  Lord indicated that their K3803A primer
 was designed for a two-component spray gun.  Two feed lines separately pump
 the two components together into a constantly agitated pot, and then feed the
 mix to the spray gun to be applied to the surface of the part. This application is
 not practical for LMSC so testing was halted.

      The VOC was tested using BAAQMD Method 22 (Solvent based, less
than 2% by weight water) or Method 23 (Water based). MIL-P-53030. DeSoto,
 and Akzo all were VOC compliant at application viscosity. Both the Gavlon and
                                  376

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Savannah primers were designed as high solids but their vendors did not test
their VOC's according to the BAAQMD methods. For example, in Gavton's
case, they used theoretical solids instead of actual in calculating their VOC.

Ground Support Equipment.  The MIL-P-53030 primer met all engineering
requirements needed for a GSE paint primer. MIL-P-53030 was compatible
with MiL-C-22750 epoxy topcoat, MIL-C-85285  high solids polyurethane, and
epoxy enamel used on GSE at LMSC. That makes it an excellent choice to
replace MIL-P-23377 high solids chromated paint primer and MIL-P-85582
water reducible chromated paint primer. Further testing of Akzo is warranted
but not a high priority due to its long dry time and the success of finding MIL-P-
53030. It is still being considered as a second chromate-free primer for GSE.
No further study was deemed necessary on Savannah, DeSoto, or Gavion
primers.

Space Related Flight Hardware.   In Phase II testing, the MIL-P-53030 primer
results were encouraging, so it was evaluated for possible use on space related
flight hardware (SRFH). MIL-P-53030 was compared to the current high VOC,
chromated primer for SRFH, Chemglaze 9922.

      Outgassing is one of the key requirements for a coating used in space
environments.  When a coating is exposed to space vacuum environments,
some volatiles can condense on critical surfaces and interfere with performance
of optical or thermal control surfaces. ASTM E 595 is the standard method for
measuring outgassing in a vacuum environment. ASTM E 595 requirements for
Total Mass Loss (TML) and Collectible Volatile  Condensable Material (CVCM)
are 1.0% max and 0.1% max, respectively. MIL-P-53030 by itself has CVCMs
ranging from 0.15% to 0.35%. When MIL-P-53030 is topcoated with A276 gloss
white polyurethane or Z306 flat black polyurethane the CVCM of the composite
films is consistently under 0.1% and the TMLs compare favorably with the
current Chemglaze 9922 system (see Table VIII).

      Intercoat adhesion with the two different SRFH topcoats, A276 gloss
white polyurethane and Z306 flat black polyurethane, is important and MIL-P-
53030 has been found to be compatible with both.

      Substrate adhesion to several different SRFH surfaces is also important.
Only dry tape adhesion is necessary as water and other weather considerations
are non-existent in space environments. MIL-P-53030 has demonstrated good
adhesion to alodined 6061 aluminum, bare 6061 aluminum, Dow 17 coated
magnesium, and abraded epoxy graphite.

      The CTE of the two primers were compared in order to identify any gross
differences in thermal characteristics between the two materials.  The CTE for
MIL-P-53030 primer compares favorably with that of the Chemglaze 9922
primer.

      Further work includes outgassing rate studies and thermal cycling (-250F
to +250F).
                                 377

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 Wash Primers
      After comparing the wet tape adhesion of the Deft wash primer and MIL-
 C-8514 wash primer with different primers on different substrates (see Table IX),
 it was noted that both the control (MIL-C-8514) and the Deft wash primer
 performed erratically and did not meet the requirement consistently.  Neither
 MIL-C-8514 (Metal Pretreatment Coating Compound) nor DOD-P-15328
 (Pretreatment Wash Primer - Formula No. 117 for Metals) specifications have
 any wet tape adhesion or weathering test requirements. It was decided that the
 wet tape adhesion requirement was not necessary.

      It should be noted that all the wet tape adhesion failures for both MIL-C-
 8514 and Deft were between the wash primer and the substrate. The Deft wash
 primer demonstrated acceptable intercoat adhesion with three different primers.
 Two of the primers, MIL-P-85582 water reducible, epoxy primer and MIL-P-
 23377 high solids, epoxy primer, are chromated and have been  replaced in the
 SSD GSE paint processes specification by the third primer, MIL-P-53030 epoxy
 primer.

      The subsequent tests for the Deft wash primer (Table X) indicated that it
 is an acceptable chromate-free replacement. The Deft wash primer passed
 VOC, appearance, and adhesion tests. This adhesion test was a wet tape
 adhesion with no cuts. The Deft wash primer is easy to apply and convenient to
 use since a subsequent primer can be applied after an hour. Since it is VOC
 compliant and performs very well with the GSE MIL-P-53030 primer, it was
 implemented as the GSE wash primer for SSD.

 CONCLUSION
 Ground  Support Equipment
      Two epoxy primers, MIL-P-53030 and Akzo, were found that meet GSE
 requirements. MIL-P-53030 primer has the advantage of a short dry time which
 makes it convenient for manufacturing to use and it has been implemented.
 Akzo is still under consideration but due to its long dry time and the success of
 finding another successful candidate, there is not urgency to test further at this
 time.

 Space Related Flight Hardware
      MIL-P-53030 has shown much promise as an eventual replacement for
 use on SRFH. Further work includes outgassing rate studies, thermal cycling (-
250Fto+250F).

Wash Primers
      The Deft wash primer met all the requirements of GSE wash primer.
Since it is VOC compliant and performs very well with the GSE MIL-P-53030
primer, it was implemented as the GSE wash primer for SSD.
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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency.  The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

                AN INVESTIGATION OF FLEXIBILITY TEST METHODS
                        FOR LOW VOC AEROSPACE COATINGS

Angela M. Brown
Boeing Defense & Space Group
P.O. Box 3999  MS 82-32
Seattle, WA 98124

INTRODUCTION

      Throughout industry, development work is currently underway to find low volatile organic
compound (VOC) containing alternatives to high performance aerospace coatings.  Chemical
resistance and flexibility are two performance characteristics required of aircraft coatings.
Unfortunately, these two requirements trade off with each other - increasing one decreases the
other. Impact and mandrel bend tests are defined for the flexibility requirements in current
aerospace coating specifications. As low VOC alternatives are being formulated and evaluated, the
suitability of these test methods to represent the actual functional requirements of an aircraft in
service has been questioned. The relationship of the results of current flexibility test methods to
each other and to actual functional performance will be studied using a test set-up representative of
service conditions.
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  ENVIRONMENTAL SIGNIFICANCE

        In the course of developing environmentally compliant coatings, chemists and engineers are
  forced to look to new binder technologies. Among the more promising new technologies at this
  time are water-borne, high solids, ultraviolet (UV) curable and powder coatings. Mechanical test
  methods are often used in aerospace specifications to assess coating performance. In this paper, a
  mechanical test is a test that measures the performance of a coating, as compared to a test that
  measures the physical properties of the material, such as the glass transition temperature.
  Adhesion, abrasion resistance, flexibility, and hardness are examples of requirements where
  mechanical tests are used. These test methods can be successfully used when measuring relative
  performance of similar coating formulations. When used to assess the properties of a new
  formulation, these mechanical test methods may not provide definitive results.  If these mechanical
  tests are used without good judgement, viable candidate formulations may be discarded as
  unusable.  During the course of developing environmentally compliant coatings, unnecessarily
  limiting the number of viable alternatives would be unfortunate. A study of flexibility test methods
  and their relationship to functional requirements in aerospace applications will provide data to
  support engineering judgement


  AEROSPACE REQUIREMENTS

        Coatings used in the aerospace industry have a unique set of requirements. They must
 withstand a variety of environmental conditions during flight, ground handling, storage, and sortie
 and mission situations. They must also withstand extreme combinations of these environmental
 conditions, such as high temperature and chemical exposure. Table I summarizes the common
 environments and their potential detrimental effects l.
Environmental Condition
High Temperature
Low Temperature
Thermal Shock
Humidity Extremes
Low Pressure
Vibration
Liquids (fuel, water, hydraulic fluid,
solvents, lubricants)
Polluted Atmosphere
Ice, Hail, Snow
Fungi
Ozone
Sand, Dust
Solar Radiation
Effect
expansion of substrate
contraction of substrate,
embrittlement
physical stress
moisture absorption, embrittlement
outgassing
physical stress
chemical attack, softening,
swelling, blistering
degradation
erosion, moisture absorption
degradation
chemical attack, degradation
erosion
physical degradation, embrittlement,
discoloration
       Table I - Environmental Conditions for Aerospace Coatings

       The typical finish configuration on aluminum aircraft structure is an inorganic surface
treatment, one coat of corrosion inhibiting epoxy primer, and two coats of a polyurethane topcoat.
                                          380

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 Flexibility verses Chemical Resistance
        In the course of the development of new, environmentally compliant coating materials for
 use in the aerospace industry, the issue of flexibility requirements combined with chemical
 resistance requirements is mentioned time and time again as a roadblock.  Current coating
 technology relies on controlling the extent of cross-linking that exists in the coating to achieve the
 required flexibility and chemical resistance. However, increasing the cross-link density to enhance
 chemical resistance is detrimental to the flexibility of a coating, while decreasing the cross-link
 density to improve flexibility compromises the chemical resistance properties.

        When the flexibility of a coating is considered independently as a mechanical property, the
 actual relevant requirement in aerospace applications is that the coating not crack in service around
 fastener heads, and at laps and at gaps in the structure.  Flexibility is required to withstand the
 relative motion between two separate but continuously coated pieces, such as structure and
 fastener, due to vibrational and thermal stresses. One of the primary functions of aerospace
 coatings is corrosion protection, and a break in the coating reduces its ability to protect the
 substrate on which it is applied. Both requirements are vital to the successful high performance
 aerospace coating formulation.

        Resistance to a variety of different chemicals is also a fundamental requirement of these
 coatings. These chemicals include fuel, hydraulic fluid and solvents.They may be encountered
 during the assembly of aerospace hardware as well as in service.  In service, coated surfaces will
 be literally bathed in these substances. The chemical resistance of a coating can be tested directly
 by immersing coated panels, by taping a saturated cloth onto coated hardware, or by rubbing a
 saturated cloth back and form across the coating surface.

 CURRENT TEST METHODS

        Material specifications for coatings used in the aerospace industry typically require one or
 more  of four different types of tests to evaluate a coatings "flexibility". These four types of
 mechanical tests are forward impact resistance, reverse impact resistance, room temperature
 mandrel bend and low temperature mandrel bend.  Other types, which are used occasionally and
 will not be discussed in this paper, include free-film elongation and tensile strength.

 Impact Resistance Test

       The impact resistance test measures the ability of an applied coating to resist the effects of
 an impact that occurs at a rapid rate. The forward impact resistance test places a coated panel into a
 fixture. A known weight is dropped from various heights onto a rounded indenter resting on the
 surface of the coated face of the test panel A reading of the highest value of inch-pounds (in-lbs)
 at which the coating does not crack is obtained.  The reverse impact test is similar, except the panel
 is placed coating side down.

 Mandrel Bend Test

       Bend tests measure the size  of the radius around which a coated panel can be bent before
 cracking.  The coated panel is placed into a fixture and is bent with a roller around either a
 cylindrical or a conical mandrel. When a cylindrical mandrel is specified, the test
 usually has a pass/fail criteria around a given mandrel radius. A conical mandrel has a radius that
goes from approximately two inches to one-eighth inch. In the conical mandrel bend test, a percent
elongation value is obtained by measuring the length of the crack from the small radius end. This
test is also performed at low temperature, typically at -65 °F.

                                             381

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  Problems

         These typical test types are used both interchangeably and as measures of the separate
  properties of flexibility and impact resistance.  How the requirements are defined varies from one
  specification to the next. For example, the forward and reverse impact resistance test appears in
  various coating specifications under the name impact resistance, impact durability, impact
  flexibility, and ambient flexibility, to name a few. This generates confusion as to what property is
  actually being measured. The mandrel bend  test does not evaluate the coating performance in a
  situation similar to service; aerospace coatings  in service do not undergo bending around tight
  radii.

        Mechanical tests that are used in specifications are typically quick, inexpensive and simple
  to run. Often these tests are either pass/fall or have qualitative rather than quantitative results.
  These mechanical tests are valuable as receiving and inspection, and quality control tools. These
  types of tests can be  successfully used when comparing, a set of similar materials. However, when
  the test is expanded to compare two different types of materials, direct comparisons can no longer
  be made.

        Qualified coatings must maintain their properties while being subjected to extremes of
  temperature and humidity, as well as chemical attack and solar radiation. Typically, the mechanical
  tests are performed on freshly applied coatings. When qualifying new materials,however,some
  specimens for the various flexibility tests are  exposed to either accelerated or natural weathering
  prior to testing. Allowing the test specimens to undergo weathering prior to testing is one way to
  increase the severity  and realism of these tests.  However, it does not duplicate service conditions.
 The problems with relying on these simple mechanical tests are compounded by the fact that the
 material that is being worked with is viscoelastic in nature.  That is, the coating's behavior changes
 with temperature as well as with the rate of applied stress. All of these factors contribute to the
 complexity of understanding how to properly use mechanical test data.

        If new coating formulations perform marginally when subjected to these tests and are
 compared to established coating technologies, they may be discarded as unusable. If these
 formulations have greater stability of physical properties under service conditions, or have better
 adhesion, they may in fact be viable for use in aerospace applications. Obtaining data will support
 scientific judgement in these areas.

 TEST PLAN

 Objectives

       The dilemma of chemical resistance verses flexibility and the question of proper application
 of current test methods has been highlighted during the course of developing new coating
 technology in the search for low VOC coatings. This has caused many coatings vendors to
 question the requirements and the use of current flexibility test methods. While many of the
 problems associated with the use of these test  methods are intuitively apparent, no actual data was
 found to address the vendors concerns. To begin to address the questions of the proper application
of existing flexibility test methods, a study of these methods was planned. In order to keep the
scope of the study manageable, it was decided that only a small set of variables would be
incorporated. The affects of conditions such as thermal shock or erosion will not be considered.

       The following is a list of objectives around which this test was planned:

              1) Obtain data comparing each of the four typical test methods to each other, using
              rank correlation as the evaluation criteria.

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              2) Develop and perform a test method that represents aerospace service conditions,
              and compare the results to current test method results.

              3) Use a designed experiment in order to minimize expense of test and to obtain
              data on impact of components of coating system on test results.

              4) Determine if further, detailed study of this issue is warranted.
 Development of Representative Service Life Test. Coatings on aircraft are applied in a continuous
 layer over an assembly of parts. These coatings must have the flexibility to withstand the relative
 motion of these parts due to vibrational and thermal stresses.  A test that would simulate this type
 of service environment would require a stress be applied to a specimen configured such that there
 would be relative motion between two parts. It was determine that a tension-tension fatigue test
 performed on a fastened lap joint would provide this test scenario. Table n summarizes the test
 set-up.  The tension-tension fatigue test is a common test in the aerospace industry for evaluating
 the mechanical properties of materials. For the purposes of this study, it provides the relative
 motion and repetitive stress environment that is representative of the service conditions faced by
 aerospace coatings. The test specimen, which is described in Figure 1, is made of 2024-T3
 aluminum sheet fastened with fifteen  countersunk-head hex-drive fasteners. The aluminum sheet
 was surface treated in accordance with Mil-C-5541 - "Chemical Conversion Coatings for
 Aluminum Alloys" - or Mil-C-8625 - "Anodic Coatings for Aluminum and Aluminum Alloys".
 The specimens were assembled with fay surface sealant and the fasteners were wet-installed with
 the same sealant.  One coat of primer and two coats of topcoat were applied after assembly.
Test type
Max load
Max stress
Min stress/Max stress Ratio
Temp ./Humidity
tension-tension fatigue
15,000 and 18,500 Ib
13 and 15.9 ksi
.019
ambient
              Table n - Summary of Test Set-up

       In this structural fatigue test, each end of the specimen is clamped into the fixture and a load
is applied that places the specimen into tension. As the cycles of the test progress, the samples is
repeatedly placed into more and less tension. The load is never completely removed. Because the
sample is not symmetrical, the outside three rows of fasteners are placed into greater tension than
the center row.
                                   o o o
                                   o o o
                                   o o o
                                   o o o
                                   000
              Figure 1 • Representative Service Life Test Specimen Configuration
                                           383

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  Detailed Test Plan

        The variables chosen for this designed experiment were (1) surface treatment, (2) primer
  flexibility, (3) topcoat flexibility, and (4) weathering. Varying these four factors provides
  information on the variety of different test configurations that may appear in aerospace coating
  specifications.  The addition of replicate specimens without primer completes the coverage of
  potential specification configurations. While the test was designed around these four variables and
  their interactions, the data presented in this paper examines only the first three. An analysis of a
  three-factor subset of this test design will not yield information concerning interactions between the
  factors. The complete analysis, incorporating data with all four of the variables, will provide
  information on all of the possible interactions.

        Design of experiments was used to develop the test matrix. The matrix describing the panel
  configurations comprising a set is shown in Table III.
Run
1
2
3
4
5
6
7
8
Surface
Treatment
Mil-C-5541
Mil-C-5541
Mil-C-5541
Mil-C-5541
Mil-C-8625
Mil-C-8625
Mil-C-8625
Mil-C-8625
Primer
Flexibih'ty
high
high
low
low
high
high
low
low
Topcoat
Flexibih'ty
low
high
low
high
low
high
low
high
Weathered
no
yes
yes
no
yes
no
no
yes
        Table m.  Flexibility Requirement Test Matrix

        The test begins with an evaluation of the test methods themselves and yields data on how
 well the test results for each test method correlate with each other. Seven sets of runs were
 performed using 4 x 6 x 0.020 inch aluminum panels, with four replicates of each.  These seven
 sets include configurations with and without primer. The four flexibility test methods chosen for
 this study are forward impact, reverse impact, room temperature conical mandrel bend and low
 temperature conical mandrel bend.

        The coatings selected for this study of flexibility test methods are shown in Table IV.
 Both of the high flexibility choices claim to have sixty percent elongation when tested with a G.E.
 impact tester and both of the low flexibility coatings claim twenty percent elongation.
Coating
Primer
Topcoat
High Flexibility
Koroflex
Gloss MIL-C-83286
Low Flexibih'ty
MIL-P-23377 Class 1
Flat MIL-C-83286
       Table IV. Coatings Selected for Flexibih'ty Test Study

       A tension-tension fatigue test of a fastened lap joint was chosen to represent service
conditions. The finish configurations defined in the test matrix (see Table HI) were applied to this
lap-splice fatigue specimen. The mechanical  test resulted in data on the number of cycles to onset
of cracking. The data generated in this study will be analyzed statistically, looking at the finish
configuration as a system as well as at the individual finish components.
                                            384

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 DATA AND RESULTS

 Analysis Methods

        Based on the use of a designed experiment, the individual contribution of each of the three
 factors - surface treatment, primer flexibility and topcoat flexibility -  on the performance of the
 tested panels can be determined statistically. The results of this analysis can be seen graphically in
 figures 2 through 6. Table V provides information about the codes used on the x-axis of these
 charts.
Code Letter
A
B
C
D
E
F
Finish Used
Mil-C-5541
Mil-C-8625
Low Flexibility Primer
High Flexibility Primer
Low Flexibility Topcoat
High Flexibility Topcoat
               Table V - Explanation of Codes Used in Figures 2 Through 7.

 Impact Resistance Test Results

        Figures 2 through 5 show the results of a statistical analysis of the results of impact testing.
 This analysis shows the contribution of each of the three factors to the results obtained during the
 test It does not account for interactions. The analysis of the topcoat used is confounded with the
 interaction between the surface treatment and the primer. Once the entire test matrix, as shown in
 Table HI, is complete and analyzed, the information about the contribution of all interactions will
 be obtained.

        The forward impact test results shown in Figure 2 show that either the topcoat  or the
 surface treatment/primer interaction has the most significant contribution to the test results.
 Because the effects of the surface treatment and the primer do not appear to be significant, it may
 be assumed that this contribution is in fact attributed to the topcoat The reverse impact test results
 shown in Figure 3 show a significant contribution to the test results by both the primer and the
 topcoat Therefore, the possibility of a strong surface treatment/primer interaction cannot be
discounted.

       Test panel configurations without primer were also tested. Figure 4 shows the results of
the forward impact test Neither the topcoat nor the surface treatment had a significant contribution
to the test results.  The results of the reverse impact resistance test on panels without primer is
shown in Figure 5. These results clearly show that the topcoat properties had the more significant
contribution to the test outcome.
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          Forward Impact Resistance
 Figure 2 - Forward Impact Resistance Tests Results - Factor Effects
 (see Table V)
         Reverse Impact Resistance
       A  B
Figure 3 - Reverse Impact Resistance Test Results - Factor Effects
(see Table V)
                            386

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          Forward Impact Resistance
          (without primer)
 T  45
        A   B                             E   F

 Figure 4 - Forward Impact Resistance Test Results - Factor Effects WITHOUT
 Primer (see Table V)

          Reverse Impact Resistance
          (without primer)
 9>  35
       A   B
Figure 5 - Reverse Impact Resistance Test Results - Factor Effects WITHOUT
Primer (see Table V)
                            387

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  Conical Mandrel Bend Test Results
         All of the panels tested in the room temperature conical mandrel bend tests passed without
  any cracking. Those tested at the low temperature of-65 °F did have some failures, to which a
  percent elongation value could be assigned No quantitative values could be assigned to those that
  passed.  Because of this, the same type of analysis that was done on the impact resistance tests and
  the service life test could not be done on the mandrel bend data. Additionally, the two
  configurations that experienced failures both had inorganic surface treatments in accordance with
  Mil-C-5541 and were primed with the low flexibility primer. In all of the failures, the cracks were
  accompanied by significant loss of adhesion of the surrounding coating. The disbond, in every
  case, occurred between the conversion coating and the substrate. This may be due to inadequacies
  in the applied surface treatment

  Representative Service Life Test Results

        Two replicates of each of the four configurations were fabricated for fatigue testing in this
  study. A steep learning curve was experienced during the testing of the first set of replicates,
  which was performed at a maximum load of 18,500 pounds. Because this type of test had not
  been performed before, no experience was available concerning when to expect the first cracks.
  An estimate was made that the first cracks would appear around one thousand cycles. This was a
  poor estimate.  Actual first cracks appeared before five hundred cycles.  Consequently, inspections
  for cracks were not made at the necessary cycle intervals to obtain differentiation in the data on the
  first four specimens. Additionally, it was determined that decreasing the load on the parts would
  create greater spread in the data.  The second set of replicates was run at a lower load of 15,000
  pounds and inspections for cracks were taken every ten cycles during the beginning of the test
  Data points were taken at the number of cycles when cracks around three fastener heads were
 observed. This data is shown in Table VI and Figure 6.  This data  is based on only one replicate,
 so little confidence may be placed on the statistical analysis.  Additionally, one of the
 configurations performed much better than the other three, so that single data point distorts that
 data shown in Figure 6. The data did, however, illustrate a significant difference between the
 performance of each of the four different test configurations.
Run
Configuration
(see Table ffl)
1
4
6
7
Cycles to Onset
of Cracking
50
10
500
30
              Table VI - Raw Data for Representative Service Life Test

       In all cases the cracks began around the tops of the fastener edges in the top row of
fasteners. Once the cracks were initiated at the top of each of the fifteen fastener heads, crack size
did not change significantly over the next several thousand cycles. In some cases, bubbles in the
coating appeared and grew at the edge of the fastener heads.  These bubbles were due to loss of
adhesion without a break in the film.  In other cases, the fastener rotated significantly in the hole
while cycling, causing a twisting and stretching effect around the edges of the'fastener heads. In
these cases, the coating eventually tore with jagged edges.  While testing the specimen with the
configuration of low flexibility topcoat over high flexibility primer, it was observed that only the
topcoat cracked. After ten thousand cycles, all but a few of these cracks continued to show primer,
intact, under the topcoat crack. All of the other test configurations cracked through the topcoat and
primer from the outset
                                             Joo

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                       Cycles to Onset of Cracking
                       A   B
C   D
E   F
              Figure 6 - Representative Service Life Test Results - Factor Effects
              (see Table V)

Comparison of Test Methods

       Due to the small number of test configurations, an absolute correlation analysis was not
performed at this time. This type of correlation will be performed after data is obtained for the
entire test matrix (see Table El). Instead, the data has been analyzed by ranking the results of each
test and comparing these rankings. This ranked data is shown in Table VTJ.
Run*
1
4
6
7
RANK
Forward
Impact
With
3
2
1
4
Reverse
Impact
3rimer
3
2
1
4
Forward
Impact
Reverse
Impact
Without Primer
2
4
1
2
4
2
1
4
Low Temp
Bend

3
4
1
1
Service
Life Test

2
4
1
3
              Table VII - Ranked Data Comparison Between Test Types

       The averaged raw data is shown in Table VTA. Each entry in this table is the arithmetic
mean of four replicates.
                                           389

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Run*
1
4
6
7
AVERAGED RAW DATA
Forward"
Impact
With!
46 in-lb
54 in-lb
56 in-lb
40 in-lb
Reverse
Impact
^rimer
32 in-lb
40 in-lb
46 in-lb
17 in-lb
Forward
Impact
Reverse
Impact
Without Primer
51 in-lb
50 in-lb
61 in-lb
51 in-lb
28 in-lb
46 in-lb
57 in-lb
28 in-lb
Low Temp
Bend

5% elong
>17%
>17%
4% elong
Service
Life Test

50 cycles
10 cycles
500 cycles
30 cycles
               Table Vm - Averaged Raw Data for All Tests

 FUTURE WORK

        The effort to complete the gathering of data in accordance with the test matrix shown in
 Table in is ongoing. Replicates of all of the test configurations for this test plan are currently
 undergoing accelerated weathering. The one exception is the lap-splice fatigue specimens. These
 specimens are large and bulky and will be difficult to handle in existing accelerated weathering
 equipment. Due to lack of available funds, no additional replicates of the tension-tension fatigue
 test configurations already tested will be evaluated. Once the entire data set is gathered, a more
 rigorous statistical analysis, examining main factor effects as well as interactions, will be
 performed. The results of this analysis will provide a more substantial comparison of the results of
 the different test methods and will indicate whether additional testing, incorporating more
 complexity of variables, is warranted.

 DISCUSSION AND RECOMMENDATIONS

 Impact Resistance Test

        An examination of the averaged raw data in Table Vin shows a greater data spread in the
 reverse impact resistance test than in the forward impact resistance test  It also demonstrates that
 the reverse impact test is a more severe test than the forward impact resistance test  This indicates
 that the reverse impact resistance test is the better choice when comparing different finish
 configurations. This is particularly true when comparing adjustments of the same basic coating
 formulation. The possible existence of a strong surface treatment/ primer interaction suggests that
 adhesion plays a role in the performance of a coating configuration in the reverse impact resistance
 test.

       The topcoat flexibility had the most significant impact on the test results obtained in the
 forward impact resistance test on the configurations used in this study.

 Conical Mandrel Bend Test

       The type of failure observed on those configurations that cracked during the low
 temperature mandrel bend test suggests adhesion problems resulting from poorly treated
 substrates. Each of these panels were treated with a chemical conversion coating. However, all of
 the panels that received this treatment did not fail.  Those that failed were the ones that were coated
 with the low flexibility primer. This suggests both a surface treatrnentfrrimer interaction and
 process problems with the chemical conversion coating.  Additional replicates of this test will be
run on freshly treated panels in order to further evaluate this finding and ensure that adequately
processed panels have been used.  Completion of data gathering for the entire test matrix will also
provide information on the significance of a surface treatment^>rimer interaction.

                                             390

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        The fact that there were so few failures in this test suggests that the conical mandrel bend
 test can be successfully used as an indicator of gross problems, but will not provide sound data on
 which to base fine comparisons. The low temperature mandrel bend test will be useful when
 screening prototype coatings. Performing the mandrel bend test at room temperature does not
 appear to be a useful test on the type of coatings that are typical in the aerospace industry.

 Representative Service Life Test

        Data on the number of tension-tension fatigue cycles to the onset of cracking of the coating
 around the fastener heads of a lap-splice specimen can be successfully obtained The results,
 shown  in Table Vffl, show differentiation in the test results from one test configuration to another.
 It is recommended that future tests of this type be run at lower loads in order to further spread that
 data. The tests should be stopped and inspections made every ten cycles during the beginning of
 the test until greater experience is obtained to predict failure points. Multiple replicates, if they do
 not indicate significant variability, will also provide greater statistical confidence in the test results.
 A reliability-based analysis, examining the fraction failed as a function of the number of cycles,
 may also provide useful information.2

 Comparison of Test Methods

        The six tests that illustrated a difference between the performance of each of the different
 test configurations consistently ranked the same high flexibility primer/high flexibility topcoat
 configuration as the highest performer. Unexpectedly, the low temperature mandrel bend test
 revealed the low flexibility primer/low flexibility topcoat configuration as a high performer as
 well. All of the other five tests ranked this configuration low, with the exception of the forward
 impact  test without primer, which is discussed below.  It appears that adhesion may play a
 significant role in the performance of panels during this type of test Completion of the entire test
 matrix and the performance of confirmation runs may shed more light on this phenomenon.

        It appears that the forward impact resistance test performed on panels without primer yields
 data whose ranking is inconsistent with the test on panels with primer. A closer examination  of the
 averaged raw data shows that three of the configurations actually yielded essentially the same
 results.  Therefore, there is no inconsistency.

       A meaningful comparison of ranked results shown in Table Vm for each of the three
 mechanical tests to the results obtained in the representative service life test cannot be made
 because the fatigue test data includes no replication.  It appears, however, that the test does provide
 data that will differentiate between the performance of different coating  configurations. Performing
 repeats of the test runs will provide a data set that could be statistically analyzed, resulting in more
 definitive results.

 SUMMARY

       Properly utilized, the mechanical test methods discussed in this paper can be valuable when
comparing the performance of similar coating formulations.  In the course of developing new
coating technologies for environmental compliance, these tests will be relied upon as well.
Evaluation of mechanical test results, when comparing different coatings, should not be done
literally but should incorporate sound scientific judgement. The data presented in this paper and
that will be obtained during this study will provide additional basis for informed coating selections.
                                            391

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ACKNOWLEDGEMENTS

      The author wishes to acknowledge the valuable contributions of the following persons:

      Marie Jorgensen                 Mark Foster
      Kenny Downs                   Jim Gertis
      Mark Parsons                   Mike Wagoner
                                     392

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                                      References

1.     The Boeing Company. Environments/Environmental Protection. Boeing Design Manual
       - 7180 Revision A.  Seattle, Washington, 1990. 15 pp.

2.     Martin, J.W.  Service Life Prediction for Coating Systems.  In: Proceedings of Short
       Course in Accelerated and Natural Weathering Techniques for Coatings and Polymers, The
       Kent State University Chemistry Department and Portage Technical Consultants, Inc.
       Kent, Ohio, 1992.
                                          393

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394

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
                         WATERBORNE MASKANT
                                  Mark D. Jaffari
                                Malek, Incorporated
                                 4951 Ruffin Road
                               San Diego, CA 92123
                                      395

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  INTRODUCTION


      Temporary  protective coatings  or  maskants  are heavily
  utilized  in aerospace chemical processing operations.  The
  purpose of a roaskant is to provide  protection to aerospace parts
  and assemblies  during chemical and  mechanical fabrication
  operations.  Operations such as chemical  milling, anodizing,
  painting, routing and bonding all reguire use of maskants to
  protect either  the whole part or selected portions of the part
  from the  chemical attack or mechanical damage.


      These naskants can be of a solid form like tapes or rubber
  plugs, but they are more generally  applied as liguids (like
  paints) which,  when dry, conform to the contour of the part and
  are manually peelable after the processing is completed.


      Traditional maskants have been rubber-based and require the
  use of chlorinated or aromatic solvents as the liquid diluent.
 Although successful in performance, these  traditional
  solventborne maskants are highly toxic and have been the major
 source of air pollution from aerospace chemical processing
 factories.  To  combat this problem  various approaches have been
 taken to either put pollution control devices onto the liquid
 maskant application equipment or to replace the solventborne
 maskants with less toxic and minimally polluting waterborne
 alternatives.


      This paper discusses the chemical nature and challenges of
 successfully developed waterborne maskants.  Current products
 produced by Malek,  Incorporated which are on the approved
 specification lists of major aerospace companies are described.
 Details of the environmental benefits and manufacturing process
 advantages which result from the implementation of waterborne
 maskants are given.   The economic considerations and pollution
 savings are described for two major aerospace processing
 factories located in the San Diego area.


 ENVIRONMENTAL CONCERNS


     Solventborne maskants  are formulated in such a way as to
 dissolve water insoluble polymers.   Solvents such as
 perchloroethylene, toluene  and 1,1,1 trichloroethane are  the  most
 commonly used for this  purpose.   Although these  solvents  do
 dissolve the  polymers,  they must be used  in a weight ratio of
 solvent to polymer of  much  greater than 1 to get proper  flow
 characteristics. Therefore,  solventborne maskants  contain from
.50 to  80 percent solvent which evaporates upon drying.  All of
 these  solvents  are toxic to  humans  and the ecosystem in terms of

                               396

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 toxic  air contamination,  ground/soil poisoning,  inhalation and
 transdernal absorption.


     There are several local and federal regulatory  agencies
 which  control the of use  and emission limits from maskant
 operations. Local air pollution control districts have  rules
 which  specifically call out the allowable solvent content and/or
 emission control efficiencies for aerospace maskant  operations.
 The  Environmental Protection Agency has also classified all of
 the  above mentioned solvents as Hazardous Air Pollutants (HAPs).
 The  Occupational Safety and Health Agency has set ever  decreasing
 exposure limits for workers using these products.  Public
 awareness of this has increased community concerns over companies
 involved with solventborne maskants.  Companies may be required to
 do assessments of the health effects to the surrounding community
 resulting from their use  of solventborne maskants. Finally,
 federal  excise taxes are  also being charged to consumers of these
 toxic  solvents.


     With all of this pressure being brought to bear on the usage
 of solventborne maskants,  the industry is actively seeking
 alternative products.


 SOLVENTBORNE AND WATERBORNE CHEMISTRY


     The preferred alternative to minimize the many difficulties
 associated with the use of solventborne maskants  has been to find
 low toxic air contaminant alternatives.   In order  to retain the
 good performance characteristics of the solventborne maskants,
 waterborne latices have been developed which are  lower  molecular
 weight,  water dispersible counterparts of solvent-dilutable
 polymers.   However,  the emergence of these latices being
 commercially available only partially solves the  problem, leaving
 many challenges  to formulate a useful maskant.


     Chemically,  solventborne maskants are simple  to understand
 and forgiving in nature.   Large molecular weight polymers are
 used which generally are  soluble in a variety of  solvents.  These
 large molecular  weight polymers have sufficient chemical
 resistance "as is"  so no  chemical curing is required when the
 film dries.   This contrasts with waterborne latex  polymers which
 are of a  smaller molecular weight and need to be cured  or cross-
 linked with heat and/or additional  chemical additives to  achieve
the desired chemical  resistance and strength.


     The  other challenges  have to do with the inherent
differences between  solvents and water.   Solvents  have  generally
low surface tension  compared with water,  therefore more care in
handling  must  be  taken to  avoid bubbles  or foam in the waterborne

                                397

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 maskant formulation.  If the waterborne maskant formulation is
 frozen, it cannot be reconstituted by thawing out as can be done
 with solventborne maskants.  This is due to the fact that latices
 are emulsions and the emulsion will generally not survive the
 shock of freezing.  Water also supports bacterial growth and
 corrosion reactions on metal, so additives must be introduced to
 eliminate or control these phenomena.


      Successful waterborne maskant formulators must consider
 these effects and have them addressed in their products.
 MALEK'S WATERBORNE MASKANT LINE
      Since 1988, Malek, Incorporated has successfully formulated
 waterborne maskants for aerospace chemical processing industries.
 An overview of Malek's current products are listed below.
 PRODUCT
EMISSIONS*   MAIN INDUSTRIAL
 CONTENT          USE
                    AEROSPACE
                    COMPANIES
 CAX-100-LA




 CAX-177

 CAX-200+



 MBP-100
   70




   70

   70


   20
Electroplating,
Chemical Milling
Boeing, Pratt & Whitney
McDonnell Douglas,
Kelly AFB, Caspian  Inc.
Chemical Milling    Boeing, Caspian Inc.
Chemical Milling,
Anodizing
Alenia, Italy,  McClellan
AFB, Caspian Inc.
Plating, Anodizing  General Dynamics Convair
                    (McDonnell Douglas),  Prat
                    & Whitney, Kelly AFB
     *In grams solvent per liter of coating
     Malek's  waterborne  maskants have been used on production
hardware since  1988 by Caspian Inc.  in San Diego where they were
pioneered for applications  in chemical milling.   Inherently low
in solvent content and high in solids content these products all
offer dramatic  reductions in air emissions created when compared
with their solventborne  counterparts.   As  an  example, the typical
solventborne  product contains 1200 grams of solvent per liter of
coating at 20%  by weight solids.  The CAX  products contain 70
grams of solvent per liter  at 48% by weight solids.  This results
in a 95% reduction in solvent emissions per unit area masked.
Malek's products are also applied in the same manner as with
solventborne  maskants, using conventional  spraying,  dipping and
pre-mask cleaning techniques.
                                398

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     As  you can see, Caspian  Inc.'s  early  success inspired many
other  aerospace chemical processing  companies to implement this
technology.  Although this  industry  is  traditionally very
conservative relative to changing  processing chemicals, these
products have proven themselves  to be capable of meeting the
strict requirements.


IMPLEMENTATION CASE STUDY:  CASPIAN  INC.


     Caspian Inc. has operated an  aluminum, titanium and steel
chemical milling plant for  over  25 years in San Diego,
California.  As a major subcontractor for  the aerospace industry,
Caspian  Inc.'s chemical milling  processes  are approved by over
twenty companies world wide,  including  Boeing, British Aerospace,
Fokker (Holland), Grumman,  Lockheed, Martin Marietta, McDonnell
Douglas, Northrop, Rockwell,  SAAB  (Sweden), Short Brothers
(Ireland), and Teledyne Ryan, to name a few.


     Caspian Inc. recognized  early on that the perchloroethylene-
based  maskant they were using would  have to be replaced or be
retro-fitted with a very expensive solvent capture system to
recover  greater than 90% of the  emissions.


     An  economic analysis showed that the  solvent capture system
would  cost greater than two million  dollars to install and carry
with it  high operating and  maintenance  costs.  Caspian Inc. also
realized that even with this  system, they  would still be exposing
the workers to perchloroethylene and the community would still
have the risk of fugitive emissions  as  well as a potential gross
emission if the recovery equipment were to fail, even
momentarily.  By working closely with Malek, Caspian Inc.
examined its chemical milling process and  current maskant
application requirements and  they  successfully replaced their
maskant  operations with CAX-100-LA.  They  maintained all of their
customer approvals and process profitability while reducing their
emissions from maskant operations  by over  95%.


     The transition from a  solventborne maskant process to the
CAX process was remarkably  straight  forward.  The main adjustment
made by  Caspian Inc. was to modify their maskant drying and
curing process.  Since solvents  are  much more volatile than
water, it was not previously  necessary  for Caspian Inc. to use
ovens  or forced drying equipment.  The  new waterborne process
requires that some provisions be made for  drying the water.
These  provisions involved the purchase  of  portable heaters, a
refurbishment of their existing  oven and a minor adjustment to
the normal process scheduling to allow  this drying to occur.
Although these changes cost Caspian  Inc. capital and operating
dollars  (approximately $30,000 for the  heating equipment and 8
KWH of power) they were nearly insignificant when compared with

                               399

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 over $2,000,000 in capital and at least 210 KWH operating cost
 for the solvent capture system.


      Additionally, Caspian Inc. has achieved pollution banking
 credits of over 106 tons of VOC per year, which were awarded to
 Caspian Inc. as they decreased their air emissions well in excess
 of their currently permitted amount.  These credits are a
 tangible financial asset for Caspian Inc. and they are valid as
 long as Caspian Inc. remains in business.  Caspian Inc.'s
 community image is improved and they are receiving a wealth of
 positive publicity from environmental groups as well as customers
 who prefer that their work be done in the most environmentally
 conscious manner.
 CASE STUDY:  GENERAL DYNAMICS CONVAIR


      General Dynamics Convair (GDC)  has been  in San Diego  for
 over twenty years performing a wide  variety of chemical
 processing, design and assembly of aerospace  vehicles.  In
 particular, GDC is a source of a section of fuselage of the
 McDonnell Douglas MD-11 aircraft.  In the processing of this
 fuselage, a large quantity of the  parts go through a chemical
 anodization process to promote paint adhesion to the interior's
 surface.   The exterior of  these polished aluminum skins are
 protected with maskant to  prevent  anodization of the exterior.
 San  Diego Air Pollution Control District Rule 67.9 requires that
 by July 1, 1993,  the maskant in this operation must have a VOC
 content of 250 grams per liter (less water and exempt compounds)
 or that an emissions control device  must be installed to capture
 at least 90% of the solvent.


      Similar to Caspian Inc.'s situation,  GDC had an existing
 facility which would have  been very  expensive and technically
 difficult to retro-fit with  solvent  capture equipment.  Their
 current spray booth was manually operated with airflow, humidity
 and  temperature control.   They did not normally oven cure  their
 solventborne maskant,  but  they normally did allow the parts to
 completely dry in the spray  booth  (taking about one hour after
 all  the spray coats are applied).  Beginning  in early 1992, GDC
 research  personnel began testing of  Malek's products for this
 process.   The key specification factors involved the ability to
 resist  all  process solutions,  no damage to the appearance  of the
 highly  polished aluminum,  and easy manual  peeling of the coating
 after anodization.   GDC identified MBP-100 as the best waterborne
 alternative.  Over thirty test pieces were  run in GDC's production
tanks to  choose the  coating  and to determine the parameters, such
as;  required thickness,  fluid viscosity,  drying and curing times
 for  optimum operations.  By  the middle of  1992, GDC had decided
to go with  a waterborne product in their current facility.  Their
 facility  engineers designed  a  simple oven  to dry and cure the
parts.  This oven was  placed  onto  existing floor space.  No

                               400

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 modifications to the spray  booth or spraying  equipment were
 required.   In late January  1993,  the oven  was installed and the
 first  production parts were successfully produced  at GDC using
 MBP-100.
      Since then, GDC has  stopped  all  purchases  of  solventborne
 maskant (1200 g/1  emissions)  and  is using MBP-100  in its  place,
 almost  six months  ahead of  the  required compliance date.


      MBP-100, having only 20  g/1  solvent content,  saves over 98%
 on the  emissions in every day use.  Their spraying equipment can
 be cleaned with water and they  do not need to add  pure
 perchloroethylene  to keep their maskant thinned.


      The  early reports from GDC are all positive.   They have the
 performance they require, a competitive flow time,  hugh pollution
 reductions and the workers  are  not exposed to highly toxic
 perchloroethylene.


 CONCLUSION
     Waterborne maskants for aerospace chemical processing do
currently exist.  These products cover the complete gambit of
maskant utilization requirements. The fact that alternative
technology does indeed exist is further verified by the fact that
the local air pollution control district has recommended Malek's
CAX waterborne maskant as best available control technology.


     The option of conducting a solventborne maskant operation
under the umbrella of a tightly-controlled solvent capture system
has many disadvantages.  These machines are very expensive to
purchase and operate.  They can contaminate the water which is
used in the recovery process and their very intense energy
requirements create increased pollution at the power plant.


     Process flexibility is also compromised with a solvent
recovery system in that the parts, when wet with solvent, must
remain inside the device (a large, tightly-controlled building
full of concentrated toxic vapors) until the solvent has
completely evaporated.  This requirement severely constrains
part-flow time.  All maskant operations must be halted if this
device has any mechanical problems.


     Waterborne maskants alleviate all of these problems while
introducing very few negative features, such as drying time,
which can be easily overcome with conventional technology.  In
general, aerospace processing companies using maskants have a

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large degree of flexibility as to what products are used in-
house.  Maskants do not fly-away with the airplane, and most
tines the individual companies themselves specify which products
are used.
     As can be seen by our wide ranging customers and processing
applications list, many key companies which have been faced with
the increasing environmental and health concerns have already
implemented these and other waterborne maskant products.   This
number of companies is increasing dramatically, and waterborne
maskants are now available from vendors of solventborne products.
We at Malek, Incorporated truly feel that this can be a case
where the industry acts with commitment and innovation to
economically operate in a less polluting fashion.
                               402

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)
              Low VOC Organic Coatings for Commercial Aircraft Application
 Authors:

 Address:
T.D. Leiand. C.M. Wong

Materials and Processes Engineering
Boeing Commercial Airplane Group
P.O. Box 3707, MS 73-40
Seattle, WA 98124-2207
ABSTRACT

      In response to the implementation of the 1970 Clean Air Act smog reduction
requirements by state and local environmental regulatory agencies, over 300 low
VOC (Volatile Organic Compound) paint formulations have been evaluated since
1985 by Boeing for use on commercial aircraft.  These formulations have been
state-of-the-art low VOC coatings based on (1) exempt solvent (methyl
chloroform), (2) high solids, (3) water reducible, (4) powder, and (5)
electrodeposition technologies.

      Working closely with aerospace coatings suppliers, Boeing has achieved
significant progress in the development and qualification of low VOC organic
finishes, including corrosion resistant primers and decorative enamels used on the
interior as well as on exterior components of our aircraft. Incorporating these new
paints into our manufacturing processes, and those of our subcontractors is
helping to reduce smog-forming emissions from aerospace facilities.  Development
efforts are continuing on low VOC coatings that can be used to replace  the current
(1) decorative paint system for interior plastic surfaces, (2) fuel tank primer, (3)
flexible corrosion inhibiting coatings for in-spar areas of the wings, and (4) low
VOC chromate-free primers for non-metallic composites and metallic surfaces.

                                    403

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 BACKGROUND

       The Clean Air Act of 1970 and implementation of its requirements by local
 environmental agencies such as the South Coast Air Quality Management District
 (SCAQMD) in the Los Angeles basin has posed a major challenge to both paint
 manufacturers and users.  The major impact on coating of commercial airplanes
 was not felt until SCAQMD Rule 1124 mandated use of 350 g/l max. VOC primers
 by January 1, 1988 and 420 g/l max. VOC topcoats by July 1. 1990 for
 aerospace manufacturers in its jurisdiction1. This had a very significant affect on
 Boeing commercial airplane manufacturing operations since hundreds of Boeing
 subcontractors are located in the Los Angeles area.

       Similar requirements were also soon adopted by other environmental
 agencies such as those located in San Diego, San Francisco, Houston, Philadelphia,
 Wichita and Seattle.  For the  Seattle area, Puget Sound Air Pollution Control
 Agency (PSAPCA) Regulation II is requiring use of low VOC primers and topcoats
 for coating the interior fuselage areas of airplanes by January 1, 1994.

       Significant investment  in alternative materials development began in the mid
 1980's, motivated by the company's desire to reduce use of VOC's in materials
 rather than relying solely on the use of control and capture technology. Use of
 control and capture technology requires very high capital investment as well as
 significant recurring maintenance costs including the cost of  disposal of collected
 hazardous materials. Working with coating suppliers to develop, wherever possible,
 low VOC coatings that would perform equal to or better than the conventional
 primers and topcoats for commercial airplane application was considered to be the
 most  environmentally sound and cost effective approach.

 STATE-OF-THE-ART LOW VOC TECHNOLOGY

      Several low VOC coating technologies were potential approaches to achieve
lower VOC coatings.  The following  is a list of the these technologies including
their advantages and disadvantages.

o 1,1.1 -TCA Exempt Solvent    1,1,1 -Trichloroethane (1,1,1 -TCA, also called
                              methyl chloroform) is considered to be non-
                              photochemically reactive and exempt from VOC
                             consideration by most regulatory districts.  Since
                              it is  an organic solvent, 1,1,1-TCA is easier than
                              water to use as a diluent in formulating coatings.
                             These coatings have drying and application
                             characteristics similar to conventional coatings.
                             However,  1,1,1-TCA has been identified as an
                             upper atmospheric ozone depleter and will  be
                             phased out of production by  1996.
                                   404

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o High Solids
o Water Reducible
o Waterborne
 o Powder
o Electrocoating
Use of lower molecular weight resin is often
necessary in order to maintain proper application
viscosity with large reduction of VOC's in the
coating formulation. Longer dry times, shorter
pot lives and thicker films per coat are usually
observed with high solids formulations.

One successful approach has been based on a
modified polyamine and epoxy resin system which
has been made water reducible with the addition
of a nitroparaffin as solvent2. This type of
dispersion has demonstrated drying and application
characteristics similar to conventional paint.
However, it does require  careful and gradual water
reduction after the base and catalyst are mixed to
secure a stable dispersion with proper viscosity.
It has shorter pot life and shelf lives than the
comparable conventional  coatings.

These coatings are water based dispersions that
include water in either the base or catalyst or
both and would usually require no further water
additions.  This is a relatively new development
and has the potential advantages of increased pot
life and easier mixing compared to water reducible
coatings.  Whether they can meet commercial
aircraft performance requirements has yet to be
verified.

These are nearly 100% solids coatings emitting
little or no VOC. The current state-of-
the-art powder technology typically requires a
minimum 250 F bake.  Exposing some aluminum
alloys to 250 F may have an adverse effect on
their mechanical properties.  In addition, this
technology is applicable only to detail parts and is
more difficult to get smooth aesthetically
acceptable coatings.

This primer technology can offer very low
VOC emissions, uniform film thickness and can
incorporate the coating operation into a tankline
surface preparation process. However, like
powder, these materials typically require a
minimum 250 F bake and are limited to detail parts
applications. To date, corrosion performance has
been lower than the current conventional primers
possibly due to lower levels of chromates.
        405

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 COMMERCIAL AIRPLANE LOW VOC PAfNT DEVELOPMENT

       Boeing has worked with aerospace coating suppliers to identify potential
 state-of-the-art low VOC coating technologies that can be used to replace the
 conventional high VOC coatings.  The most critical criterion is that they provide at
 least equivalent service performance.  Since 1985, over 300 primer and topcoat
 formulations have been evaluated (Table I).  As a result of close working
 relationship between Boeing and coating manufacturers, low VOC coatings have
 been added in several Boeing commercial airplane coating specifications as options
 to the conventional coatings. Use of these coatings is making significant
 contributions to the overall VOC emissions reduction in commercial airplane
 manufacturing and maintenance operations.

 A. Corrosion Inhibiting Primer For Interior Fuselage Boeing Material Standard (BMS)
   10-11, Type I

       From the 1970's to the mid 1980's, little progress was made in low VOC
 coatings development throughout the commercial airplane industry. By the mid to
 late 1980's, a major effort was undertaken by Boeing and aerospace paint
 manufacturers as technology advancements were emerging.  Also, technology
 driving regulations, such as South Coast Air Quality Management District
 (SCAQMD)  Rule 1124, were being promulgated establishing future dates for lower
 VOC primers.  All state-of-the-art low VOC primers such as water based, exempt
 solvent (1,1,1-TCA) based and high solids technologies from coating
 manufacturers were evaluated.  By late 1987, only exempt solvent based primers
 could meet the regulatory and stringent performance requirements in film
 thickness, drying time, adhesion, humidity, hydraulic fluid and corrosion resistance
 required by  BMS 10-11.  Two exempt solvent based primers were added to the
 Qualified Products List (QPL) as BMS10-11 Type I, Class A, Grade B primers.
 These exempt solvent based primers, while compliant  with Rule 1124, contain
 large amounts of non-photochemically reactive methyl chloroform. Methyl
 chloroform has been identified as an upper atmosphere ozone depletor and its
 production will be phased out prior to 1996 in accordance with the Montreal
 Protocol.  In light of this,  the implementation of the exempt solvent based primers
 was regarded as an interim solution.  Development work, in conjunction with Deft
 Chemical Coatings, continued toward development of  a hydraulic fluid resistant
 version of its Mil-P-85582 water reducible primer. After 5 years of extensive effort
 a product was qualified and added to the QPL as BMS 10-11, Type I, Class A,
 Grade E.

      Table II shows the  major property differences between the BMS10-11, Type
 I. Grade A (conventional), Grade B (exempt solvent) and Grade E (water reducible)
 primers.  Figure I shows the rapid viscosity increase of Grade E primer after 4
 hours at  75  F. Use of refrigeration to chill the mixed Grade E primer to below room
temperature (above 50 F) has been demonstated to be a viable way of obtaining
 longer pot life. Boeing controls allow for only 9 months shelf life as compared to
 24 months for Grade A primer demonstrating that these primers are less stable
dispersions than conventional primers.
                                     406

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              TABLE I,  LOW VOC  PRIMERS AND TOPCOATS EVALUATED SINCE 1985
                                                  LOW VOC TECHNOLOGY
1/SPEClfJCATlOM
  8MS 10-11,
  TYPE I

  BUS 10-79
  TYPES IltMI

  BMS 10-11.
  TYPE II

  •MS 10-60,
  TYPE 1

  BMS 10-60.
  TYPE II

  CHROMATE
  FREE

  •MS 10-66

  IMS 10-83

  BMS 10-20
JH_
PRIMER
PR 1 NCR
ENAMEL
ENAMEL
ENAMEL
PRIMER
ENAMEL
ENAMEL
PRIMER
KA
SO
7
1
0
0
2
0
0
0
Ml -SOL
33
19
62
5
40
13
5
6
3
WATER
37
12
1
0
0
4
0
2
4
E-COAT
2
0
0
0
0
0
0
0
0
POWDER
0
0
5
0
0
0
0
0
0
TOTAL
122
38
69
5
40
19
5
8
7
         DESCRIPTIONS  OF  SPECIFICATION DESIGNATIONS
         BMS10-11,  Type  I

         BMS10-79,  Types 11 I  III

         BMS10-11,  Type  II

         BMS10-60.  Type  1

         BMS10-60.  Type  II


         BMS10-86

         BMS10-83

         •MS10-20
Chemical and solvent resistant epoxy primer

Urethant compatible, corrosion resistant pri«er

Cheaical and solvent resistant epoxy enamel

Exterior protective eneael for general use
Exterior protective enamel possessing a high
degree of flexibility for specific use

Teflon filled coating

Interior decorative urethane paint system

Corrosion resistant finish for  integral fuel
tanks
                                  407

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                   Time, Hours
FIGURE 1.  DEFT 44GN11 VISCOSITY PROFILE at 75F
                      408

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Table II,    Differences Between Low VOC and Conventional Primers for Interior
            Fuselage Application
BMS1 0-11, Type I
Primer, Grade
% N.V., Admixed
VOC, g/liter
Viscosity, Sees.
No. 2 Zahn
Dry-to-dust,
Mins.
Pot Life, Hours
(At 75 F)
Shelf Life,
Months
A, (Typical)
38.0
Less than
650
15-17
5
16
24
B, (DeSoto)
39.9
Less than
350
(Excluding
1,1,1-TCA)
14-17
15
6
9
B. (Akzo)
32.7
Less than
350
(Excluding
1,1,1-TCA)
15-17
15
16
9
E, (Deft)
35.0
Less than
350
18-22
10
4
9
      One of the characteristics of the Deft water reducible primer is that it
requires consecutive additions of three separate and equal quantities of water to
the base/catalyst mix in order to obtain a proper dispersion. The so-called
"waterborne" primers now being  developed by other manufacturers include the
water in either the base or catalyst or both and are mixed similar to the
conventional primer. However, further development of this new waterborne primer
technology will be necessary to meet commercial airplane primer specifications.

      In addition to these technologies, efforts in high solids primer development
are continuing.  Recent submittals from suppliers  have shown significant
improvements in application, dry  film thickness, dry time and pot life.  Electrocoat
primer candidates from PPG and Sherwin-Williams have also been investigated.
Improvement in corrosion resistance and lower bake temperatures are needed to
make electrocoating a viable option for priming commercial airplane components.

B. Corrosion Inhibitive Primer For Exterior Fuselage And Wing Areas (BMS10-79)

      In conjunction with the SCAQMD Rule 1124 requirements, an exempt
solvent based primer was added to the QPL of BMS 10-79 as a Type II & III, Grade
B primer in early 1988. Table III  compares the major differences between the
Grade A (conventional) and Grade B primers.
                                     409

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      Table III.    Differences Between BMS10-79 Grade A and B Primers
BMS 10-79, Primer,
Grade
% N.V. Admixed
VOC, g/liter
Viscosity, No. 2 Zahn,
Sees.
Shelf Life, Months
Pot Life, Hours
Hydraulic Fluid, 30 days
Immersion at 75F
A, (Type III Typical)
35.7
Less than 650
15-17
12
8
HB I/
B, (DeSoto)
24.2
Less than 350
(Excluding 1.1.1-TCA)
12-16
9
6
4B I/
 I/   pencil hardness of coating following exposure
      While evaluation of other potential low VOC BMS 10-79 primers (waterborne
and high solids) is continuing, the only low VOC material currently available is the
Grade B primer.

C. Chemical Resistant Epoxy Enamels For Interior  Fuselage (BMS10-11, Type II)

      Boeing initiated efforts on both interior (BMS10-11, Type II) and exterior
(BMS 10-60) enamels for commercial airplanes since the mid 1988's.  Technology
driving regulations were being established.  SCAQMD Rule 1124 established a 420
g/l requirement effectivity of July 1,  1991. Since film thickness and dry time
parameter were not as stringent as with primers, the majority of the coatings from
suppliers were high solids enamels which involved less drastic formulation changes
as compared to other technologies.  Two qualified low VOC high solids epoxy (less
than 420 g/l) enamels were added to the QPL of BMS10-11 as Type II, Grade D
enamels. These materials have application characteristics similar to the
conventional Grade A coatings, however, they have shorter pot and shelf lives,
longer dry times, and higher application viscosities as shown in Table IV. The
Grade D enamels require only 15 minutes of induction time compared to the 1 hour
required by the conventional Grade A enamels. This is probably due to the use of
lower molecular weight (liquid) epoxy resins in high solids formulations, which
helps to reduce the time  for induction.

      Several powder coatings were evaluated for qualification as an option to
conventional BMS 10-11, Type II enamels. Appearance (too much orange peel) and
                                    410

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the tight tolerance of 250±.5 F in bake were the main constraints in using these
coatings. Efforts to improve appearance and lower the cure temperature by
suppliers are continuing.

D. Exterior Protective Enamels For Wing And Fuselage Areas (BMS10-60, Type II)

        High performance urethane enamels have been used as protective topcoats
for the exterior areas of airplanes such as the fuselage and wing areas because of
their superior weather and chemical resistance for many years. As in the case of
interior enamel (BMS10-11, Type II), essentially all the low VOC submittals from
suppliers were high solids (urethane) coatings (Table I).  Two high solids urethane
enamels have passed the qualification tests in specification  BMS10-60.  Table V
shows these qualified enamels perform similarly to conventional solvent based
DeSoto Series 1000 (BMS10-60, Type II, Grade A) .  Both DeSoto and Akzo low
VOC products are listed in BMS 10-60 as Type II, Class B, Grade 0 enamels.  Time
and temperature cure cycles for these coatings are similar to those for conventional
coatings. Work is continuing with suppliers on improved application  properties for
exterior fuselage applications and on lead-, cadmium-,  and chrome-free tint lines
for these low VOC enamels as well as  a more hydraulic fluid resistant version
(BMS10-60, Type I) of these topcoats  for general use.

E. Teflon Filled, Abrasion Resistant Urethane Enamel For Wing Areas (BMS 10-86)

      For protection of the high erosion areas of the wings  such as the leading
edge and some of the high rub areas (e.g. flap tracks areas  of the wings) of the
commercial airplanes, a teflon filled , abrasion resistant urethane  enamel (BMS 10-
86) is generally used.  Low VOC (less than 420 grams/liter) teflon filled abrasion
resistant urethane coatings from Crown Metro have been qualified to BMS 10-86
as Type  I (sprayable) and Type II (brushable) Grade 0 enamels. These high solids
urethane enamels have improved (significantly shorter) drying times compared to
conventional Grade A coatings.  With the high solids enamel, usually two coats will
be sufficient to provide 5 to 10 mils film thickness required  by BMS 10-86
whereas, with the conventional Grade  A enamel, 3 to 4 coats are required.

F. Additional Low VOC Paint Development Efforts For Commercial Airplanes

      During the past several years, Boeing has also been evaluating both
waterborne and high solids candidates  for a  variety of other coating types as
shown below:

o Corrosion resistant finish for integral fuel  tank (BMS 10-20)

o Interior decorative urethane paint system (BMS10-83)

o Nonchromate primer for nonmetallic composites (BMS10-103)

o Flexible corrosion inhibiting coatings  for in-spar areas of the wings  (BMS10-100)

o Nonchromate primer for metals
                                     411

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Table IV,   Differences between BMS10-11, Type II, Grade A and 0 Enamels
BMS1O-11, Type
It, Class B, Grade
%N.V.. Admixed
VOC, g/liter
Viscosity, Sees.
Zahn No. 2
Pot Life, Hours
Shelf Life,
Months
Induction Time,
Hours
Dry Time, Hours,
At 75 F
Dust Free
Tack Tree
Dry Through
Dry-to-stack
Appearance
Sag
A, (Typical)
49.6
Less than 600
20-25
16
24
1
1/2
3
6
8
Control
None
D, (Akzo 446-22
Series)
67.7
Less than 420
25
4
9
1/4
2
4
9
9
Slight Orange
Peel
None
D, (Crown Metro
14P21 Series)
61.8
Less than 420
28
4
9
1/4
2
4
6
7
Slight Orange
Peel
Slight
                                412

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Table V,  High solids exterior protective urethane enamels
BMS 10-60,
Type II, Class
B, Grade
%N.V.,
Admixed
VOC, g/liter
Viscosity,
sees., Zahn
No. 2
Shelf Life,
Months
A, (DeSoto
.-Series 1000
Control)
54.8
534
16-18
12
D, (DeSoto
Series 420)
65.95
417
17-19
9
D, (Akzo
646-88
Series)
64.71
418
20-24
9
    Table VI,    Dry time and shelf life for BMS 10-86 Grade D enamels
BMS10-86. Grade
%N.V., Admixed
VOC, g/liter
Dust Free, Hours
Tack Free, Hours
Dry Through, Hours
Shelf Life, Months
A, (Typical)
55.6
500-590
Type 1 2.0
Type II 2.0
Type 1 6.0
Type II 4.0
Type 1 12.0
Type II 6.0
12
D, (Crown Metro 23T3
&24T3 Series)
68.0
Less than 420
Type I 1.5
Type II 0.75
Type I 3.25
Type II 2.0
Type I 5.25
Type II 3.1
9
                                 413

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      Several low VOC technologies for BMS10-20, BMS10-83 and BMS10-103
are currently being evaluated.  For flexible corrosion inhibiting coatings for in-spar
wing areas (BMS 10-100), high solids vinyl technology may be available from
suppliers in the near future.  However, the availability of a low VOC nonchromate
primer for use on aluminum structures will at best, several years away. Current
state-of-the-art nonchromate corrosion inhibitive pigments do not perform as well
as chromate  pigments in  protecting adjacent scratched or damaged (uncoated)
areas. Corrosion pit depths of 1  to 10 mils have been observed in scribed areas on
2024-T3 bare aluminum panels coated with primers containing nonchromate
inhibitors after 3000 hours salt spray exposure3. This is quite large when
compared to  attack observed with conventional chromated primers, which ranges
from 0 to 0.1 mils depth.  Boeing is also evaluating potential corrosion inhibitors
using electrochemical polarographic and impedance techniques.  If a suitable
inhibitor is identified, cooperative efforts with coating suppliers to develop an
acceptable primer will follow.

CONCLUSION

      Significant progress has been  made by the joint efforts of the Boeing
Company and its coating  suppliers in development of low VOC primers and
enamels for commercial airplane paint operations. Since 1985, over 300 different
state-of-the-art low VOC  primer and enamel formulations have been tested.  As a
result of this  effort, several low VOC coatings have been developed and qualified.
This is allowing Boeing and its subcontractors to significantly reduce VOC.
emissions from painting operations.  Based on EPA paint usage and emissions
estimates for commercial  aerospace  painting operations, it is estimated that use of
the materials  developed to date will provide approximately a 40% reduction in
paint emissions by Boeing and its subcontractors.
                                  414

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                               REFERENCES
1.    Rules and Regulations, South Coast Air Quality Management District, Rule
      1124 - Aerospace Assembly and Component Coating Operations, Amended
      April 3, 1987, 9150 Flair Drive, El Monte, Calif. 91731.

2.    Alters, R. A., U.S. Patent 4,352,898, "Water-Reducible Epoxy Coating
      Compositions Without Emulsifier", October 5, 1982.

3.    "Salt Spray (fog) Testing", Boeing Specification Support Standard 6SS
      7249, Aug. 22, 1988.
                                  415

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416

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                       SESSION 10
                 AUXILIARY SYSTEMS
                     PAPERS PRESENTED:

       "Low Volatility Surface Preparation:  A Hybrid Approach"
                              by
                        Joseph A. Lucas
                     Inland Technology, Inc.
                      Tacoraa, Washington

             'Transfer Efficiency and VOC Emissions of
        Spray Gun and Coating Technologies in Wood Finishing"
                              by
                      Lesley Snowden-Swan
                  Pacific Northwest Laboratory
                      Richland, Washington
                             and
                        Pamela Worner
       Pacific Northwest Pollution Prevention Research Center
                       Seattle, Washington

"You Can't Always Judge a Paint Spray Gun Cleaning System by Its Cover"
                              by
                       Michael J. Callahan
                        Project Engineer
                         John P. Kusz
                 Manager of Product Development
                    Safety-Kleen Corporation
                         Elgin, Illinois
                            417

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)
            LOW VOLATILITY SURFACE PREPARATION:
                         A HYBRID APPROACH
                               Joseph A. Lucas
                         Inland Technology Incorporated
                          2612 Pacific Highway East
                                  Suite C
                             Tacoma, WA 98424
                                  ©1993

                     (Reproduced with Permission)
                                  419

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     In the past, industrial surface preparation practices have generally involved some variant
 of the following solvent usages:

          1. Manual wiping with MEK, MffiK, Lacquer Thinner, Acetone, 1,1,1 Trichloroethane,
            Freon 113, Methylene Chloride, Xylene, Toluene, or Mineral Spirits.

          2. Agitated dips or sprays using many of the above compounds.

          3. Vapor degreasing using Freon 113, 1,1,1 Trichloroethane, Trichloroethylene or
            Perchloroethylene.

     These materials and methods have worked well for industry as surface preparation
 techniques, primarily because they have grown up with industry during the last 50 or so years. As
 a new industrial cleaning need was identified, a selection of these solvents was empirically tested
 by the users; and, when one was determined to work effectively, it was adopted into the process.

     In fact these traditional solvents were so effective, in terms of cleaning efficiency and
 economy, they were nearly "no brainer solvents".  In other words one could literally specify
 "vapor degrease with 1,1,1 Trichloroethane" without knowing how clean that makes a surface,
 knowing how effective it was at removing specific contaminants, or knowing anything about the
 follow-on requirements, and still be fairly certain everything would work.  They could be certain
 that the weld would perform, the paint would adhere, and the adhesives would bond.

     Now, with the effects of The Clean Air Act, the Montreal Protocol phase out, the V.O.C.
 labeling requirements, and VOC limitations from a variety of sources looming imminent, these
 traditional industrial solvents are under major attack; and their continued use in industrial
 processes are becoming a major disadvantage for all industrial users.

     This has, in the last two years, created a major push to discover and develop alternative
 chemistries, and alternative processes,  to accomplish the same surface preparation tasks without
 incurring the same regulatory pressure and without causing the same risks to the environment and
 human health.

     Contrary to the "No Brainer"  characteristics of the traditional surface preparation techniques,
 alternate chemistries and  processes are by no means as universally effective. In fact they tend to
 be extremely application specific.  For  example, a major aircraft manufacturer used MEK to prep
 prior to painting, sealing, bonding, and welding. It also used MEK to remove adhesive, remove
 cured sealant, remove DyChem layout  dye to remove part marks, and for cleaning painting
 equipment.  The low VOC surface preparation that was developed to prep prior to painting,
bonding, sealing or welding works well for those applications but will not remove DyChem dye
part  marks, cured sealant or protective wing coatings.  A different substitute was developed that
removes DyChem dye, cleans paint equipment, and removes some adhesives, however it will not
prep surfaces, remove cured sealant, or remove protective wing coatings.  A third substitute that
will remove cured sealant and adhesives will not prep surfaces or remove protective wing
coatings.  Protective wing coatings must be removed by means of yet a fourth material.
                                           420

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    To add to this complexity there is very little existing information or data regarding the
cleanliness requirements for any of the typical industrial follow-on processes. This naturally
means that there is no way to effectively compare cleanliness results achieved via a potential
substitute against a known requirement. This lack of data within industry continually raises the
specter of the unknown. Will the weld hold as good, will the paint bond as well, will the circuit
board last 20 years, or will some unobserved or unknown difference in the process put the
company's product and reputation in jeopardy? This lack of good, replicable, comparable test
data is probably the primary impediment to the efficient design and adoption of low VOC
chemistries and processes, a more complete list of impediments is as follows:

     1. Research chic

     2. Research and design first, find application second

     3. Desire for quick fix that behaves like the old stuff

     A. We tried that before and it didn't work

     5. No involvement of line workers

     6. Unwilling to look at process changes and equipment changes

     7. Fear of unknown effects of new materials

     8. Lack of management courage

     9. Lack of  real data about processes.  Is this chemical really necessary?

    10. Failure to look upstream for changes that may make a chemical unnecessary

    11. Unwilling to make employees accept the need to change

    12. Desire for substitution of a product and/or process that is already validated, reluctance to
         do on site testing and adaptation.

    13. Establishing substitution criteria that pre-ordains failure. The substitute must:

            A. Be non-flammable

           B. Be non-toxic

            C. Be non-regulated

           D. Work with minimal process changes

            E. Be cheap/

                                            421

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     14. Lack of real technical knowledge about the current process

     IS. Lack of real technical data about the proposed alternative chemical/process.  How clean
         does this get and is that good enough?

     Some of these impediments can be ameliorated by shifting the attention away from the
 seductive tendency to focus on the solvent that is to be eliminated. Currently the cry is "I want a
 replacement for 1,1,1 Trichloroethane". This focus is usually of limited productivity because of
 the lack of process information. Was 1,1,1 Trichloroethane being used because it alone would
 remove the particular contaminants sufficiently for the follow-on process or was it being used
 because it worked? Was its use in essence the result of industrial habit?

     The most productive focus in designing or trying to identify a substitute is to focus on the
 application for which the current solvent is being used. What must be accomplished in order for
 the follow-on process to work?

     The following is a helpful diagnostic protocol that is designed to aid in deriving the necessary
 data from the industrial solvent usage process:

    1.  What is the solvent being substituted? Why is this particular solvent being used for this
        process?

    2.  What is the motivation for this substitution?

    3.  What is the process the solvent is being used in? Manual wipe, vapor degreaser, ultra
        sound, etc.

    4.   What is the substrate?

    5.   What are the contaminants that are being removed? What is their origin?

    6.   What are the follow-on processes?  Do they require this cleaning step?

    7.   How clean do you need the surface to be for the follow-on process?

    8.   Are there any centra-indications? (i.e. sulfur with aluminum at high temperatures)

    9.  Have you tried anything else as a substitute? What was it?  What were the reasons for its
       non-acceptance?

    Over the course of the last several years, we at Inland Technology have not only been
developing data on the performance of our products, but we have been collecting quality data on
the cleaning performance of many of the traditional solvents. Researchers have used a wide
variety of test methodologies and measuring equipment. Much of the test results are not
comparable in any meaningful way between methods, however this information, sketchy though it
may be, should be the beginning of a useful base line of performance data that will enable
industry, by using identical test methodologies, to begin comparing the performance of substitute
chemistries and processes.

-------
    The following is test data comparing the performance of traditional solvents with Inland
Technology alternatives:

                                    OSEE TEST
Traditional Solvent 1,1,1 Trichloroethane
Inland Technology Alternative Citra Safe®
Delta cV -135
Delta cV -32.2
On OSEE tests the smaller the Delta cV either positive or negative the cleaner the surface.

                                     NVR TEST
Traditional Solvent 1,1,1 Trichloroethane
Inland Technology Alternative Citra Safe®
MG/Plate8"xl2" 1.0-1.47
1.73
                              X-RAY FLUORESCENCE
Traditional Solvent Isopropyl Alcohol
Traditional Solvent Freon TE
Inland Technology Alternative Citra Safe®
Inland Technology Alternative Skysol 500
Control Uncleaned Aluminum
4 Counts/Second
ND (non detectable)
2 Counts/Second
ND (non detectable)
301 Counts/Second
                             OPTICAL SCANNING TEST
     Traditional Solvent  Freon T.E.
Inland Technology Alternatives
  Outperforming Freon T.E.
          EP921
        X-CALffiER
      CITRA SAFE®
    Expanding on this small beginning by developing on this base of test data should help take the
development and adoption of alternative surface preparation chemistries and processes out of the
frustrating, risky, labor intensive realm it currently occupies, and through the development and
use of scientific performance data, put this process firmly into the less stressful engineering realm
where it belongs.

    To date most of the chemical design work in the low VOC substitute arena has focused on
the following aqueous, semi-aqueous, and hydrocarbon cleaning chemistries. These approaches
have several inherent disadvantages that have impeded their universal adoption.

DISADVANTAGES OF AQUEOUS CLEANING

     1. Typically does not lend itself to manual surface cleaning

    2. Parts with blind holes and small crevices may be difficult to clean and require expensive
       process optimization
                                         423

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     3. Less effective on non-polar soils than polar

     4. Potential for galvanic corrosion to occur during process

     5. Some materials and processes are incompatible with water

     6. Higher energy consumption

     7. Rinsing difficulties-Some surfactants and other components can be difficult to rinse

     8. Sometimes high concentrations of organic coupling compounds contribute to organic
       emissions.

     9. Process equipment tends to be large and requires considerable space.

 DISADVANTAGES OF SEMI-AQUEOUS CLEANING

     1. Typically does not lend itself to manual surface cleaning

     2. Flammability - especially if sprayed

     3. Odors

     4. High hydrocarbon content (terpenes etc.) can auto-oxidize in the presence of heat, water,
       and air to increase non-volatile residue problems

     5. Sometimes the surfactants are difficult to rinse

     6. The chemistry of maintaining proper emulsion characteristics during the process can be
       difficult

     7. Higher organic concentrations can lead  to higher organic emissions.

DISADVANTAGES OF STRAIGHT HYDROCARBON CLEANING

     1. Flammability Problems

    2. Typically  100% VOC

    3. The need for low non-volatile residue tends to require the use of lower flash point lighter
      fractions that evaporate rapidly and contribute massively to organic emissions

    4. Low-volatility hydrocarbons typically leave objectionable residue unless extremely purified
      to include only one hydrocarbon chain

    5. Typically not effective on all soils
                                          424

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    6. Contaminate build-up in the cleaning tank can quickly cause a failure of the follow-on
       process

HYBRID CHEMISTRIES

    As a result of the difficulty experienced in attempting to replace the Ozone depleting
substances and other traditional highly volatile solvents, with more benign chemistries following
the approaches of aqueous, semi- aqueous, and hydrocarbon technologies, Inland Technology
Incorporated has developed a new hybrid approach, that from preliminary test data, promises to
solve many of the inherent problems associated with the other three approaches (Aqueous, Semi-
Aqueous and Hydrocarbon cleaning systems). This for lack of a better term is being referred to as
"Hybrid Chemistry".

    In many respects this Hybrid Chemistry incorporates many of the advantages of Aqueous,
Semi-Aqueous and Hydrocarbon cleaning systems while eliminating or markedly reducing many
of their inherent disadvantages.

    These modified hydrocarbon systems provide aggressive removal of a wide range of
contaminants. Components with large differences in inter-molecular forces of non-polar
dispersion, polarity, and hydrogen bonding are combined together to optimize contaminant
solubility. On the molecular level this means that components with the greatest affinity to the
contaminant tend to dominate the surface interface between the liquid and the contaminant; that
component is also most likely to solubilize the contaminant.  As a result, one blend might provide
the characteristics necessary to remove several very different contaminants. Hydrophobic
contaminants are attracted by the high dispersion, low polarity, and low hydrogen bonding
components of the system. Various "modified" hydrocarbons - oxygenated, nitrogenated, but not
halogenated - are used to attack polar, and hydrogen bound contaminants.  Coupling agents are
present to facilitate rinsing and solubilizing of all the materials including the contaminant.

ADVANTAGES  OF HYBRID CHEMISTRIES

    •  Can be designed to be nearly or essentially non-volatile.
       Even though they may be non-volatile, hybrids can be designed to be extremely free
       rinsing.

       Hybrids can have extremely high flash points.

       Hybrids can contain design components that exhibit strong polarity, strong dispersion
       forces and strong hydrogen bonding characteristics to enable one cleaning agent to be
       effective on a wide variety of contaminants.

       Hybrids exhibit a high capacity for contaminant loading while maintaining specified
       cleaning requirements.

       Hybrid chemistry is capable of delivering the exquisitely clean surfaces mandated by the
       most demanding of precision cleaning requirements.

                                          425

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     Several such hybrid systems have been designed by Inland. Most of the components of our
 hybrid systems originated from usage in industries such as the food industry and cosmetics
 industry. All have relatively high flash points, extremely low vapor pressures, and provide a major
 improvement in human and environmental safety.  Three of the products are CITREX, X-
 CALIBER,andEP921.

 X-CALIBER

     This product is designed to replace TCA, TCE and Methylene Chloride as a surface prep and
 stripper. It is used as an in-tank solution substitute for vapor degreasing with TCA, TCE or
 Freon.  It is also used for paint and coating stripping as a substitute for Methylene Chloride. X-
 CALIBER has the ability to aggressively remove and suspend both polar and non-polar
 contaminants.

     Highly polar at the same time with strong London forces of dispersion, X-CALIBER attacks
 a wide variety of contaminants.  Its hybrid nature tends to keep contaminants mobilized thereby
 reducing the effects of contaminant build-up in the tank. This characteristic is a major technical
 improvement over most straight hydrocarbon or aqueous/semi-aqueous cleaning chemistries.

 CITREX

     CITREX has many of the same characteristics as X-Caliber, but it is less aggressive and has a
 lower surface tension. It is another in-tank substitute for vapor degreasing and also stripping
 procedures. It  is slightly less aggressive than X-Caliber, but it does have a higher flash point (142
 °F), CITREX wets most surfaces better than X-Caliber and is more easily rinsed with water.
EP921

    EP-921 is a design effort to tame the hybrids sufficiently to allow for their use as hand
applied wipes for surface preparation prior to painting and other follow-on processes.  Like all of
the hybrids, a follow-up rinse or wipe is required as a standard process to achieve the low N. V.
R., of which they are capable.  In the case  of EP-921, a simple rewiping of the surface with a rag
dampened with water has proven sufficient for most follow-on processes.

    While  X-CALIBER and CITREX more nearly substitute for TCA & TCE, EP-921 was
designed chemically to more nearly mimic the behaviors and characteristics of Methyl Ethyl
Ketone.

    This led to the discovery of a new application for this extremely low volatility solvent
substitute.  Although 25 - 30% of solvent emissions in coating related activities come from
surface preparation, another, nearly equal, 25% is related to paint equipment clean up.

    EP-921  is a low volatility substitute for MEK and is effective at thinning and mobilizing
most of the paints and coatings it has been tested against.  Guns, pots, etc. clean up with the same
effort, the same equipment, and the same techniques as with using MEK.

                                         426

-------
    The major advantages are: a vapor pressure of <. 1 M M H G instead of 75 M M H G.

    This makes EP-921 750 times less volatile than M.E.K.

    EP-921 has a flash point of 146 °F - rather than the 20 °F flash point of M.E.K. and has a
much more benign toxicology for worker safety.
                                         427

-------
     12-T-
     104-
 A Hybrid Cleaning System's (X-CALIBER)
  Effectiveness Compared to the Cleaning
Effectiveness of 1,1,1 Trichloroethane (TCA)
     Non Volatile Residue Measured by EUipsometry
to
00
   S  8
                                                                           I TCA

                                                                           I X-CALIBER
                     10
          20             30             40
                Time (days)
     Plot of Elipsonteter Data For Solvents Tested

-------
                       SOLVENT SUBSTITUTION

                             CASE  STUDY


CLIENT:

      The Boeing Company


PROJECT:

      Eliminate or severely reduce the use of the Methyl Ethyl Ketone used for
      cleaning paint guns & painting equipment used in aerospace coating
      applications. A successful substitute must be less hazardous than MEK and
      must fit within the VOC regulations promulgated by PSAPCA and
      SCAQMD.

CONCERNS:

The project raised three major areas of concern:

1.    VOC regulations demand near non-volatility in paint gun cleaning materials.
     This lack of volatility raised possible contamination issues with regards to
     painting subsequent to  cleaning with substitutes.

2.    Most paint equipment is designed to be resistant to MEK.  There will be very
     little data available regarding component resistance to any substitutes.

3.    There are a great variety of coating systems in use today. The goal of the
     project was to create a  substitute with the near universal applicability of
     MEK.

SUBSTITUTION PROCESS:

1.    Try to create on a macro scale a material that mimics some of the electro
     chemical characteristics of MEK.

                                   429

-------
 2.    Keep the vapor pressure below .5 mmHg & the volatile content below 200
      grams per liter.

 3.    Test candidates on as many paint & coating systems as possible.

 4.    Devise & test purging techniques to eliminate paint contamination questions.

 METHODOLOGY:

       The final candidate was a cleaning formulation identified as EP921.  This
       material was constructed from mutually antagonistic materials that as a
       whole mimic, on a macro scale, the solubility parameters & the solubility
       vector enjoyed by Methyl Ethyl Ketone.

       Its near non-volatility would allow it to compete effectively, in terms of
       emissions, with MEK coupled with a vapor capture system of 99.7%
       efficiency.

       Cleaning effectiveness equal to MEK on 1011 Epoxy Primer,  1060 Series
       Topcoat, iron, alkyd enamels, varnish, polyeurothanes, & silicone coatings.

       Residue concerns have been eliminated by the successful use of a warm
       water final rinse of the paint gun.  This is then followed by an air blast  to
       dry the  gun prior to use.

       Testing on paint gun components  to date has not resulted in identifying any
       material adverse effects.

RESULTS:

       The client is continuing testing & initiating Boeing Material Technology
       materials testing prior to developing specifications for use. Northrop
       Aviation has also conducted tests  & has received preliminary approval  from
       SCAQMD and PSAPCA.  Evaluation regarding Aerospace VOC  regulations

                                     430

-------
is in process.  The original client is experimenting with other applications
for this mimic of MEK.

To date, good preliminary results have been obtained in the following
traditional MEK applications:

   •  Felt marker remover
   •  Removal of glues & adhesives
   •  Mild paint remover
   •  Grease & oil remover
   •  Machinists blue dye removal
                               431

-------
«<
             !w •    *ji5*n«<**t-  ^Tf«s»s^&fcv» v***  I*.:--     j; *f*
             InlaDdfTechnpl^pIncorporateJ
 Inland Technology Incorporated, is * privately owned corporation that is dedicated
 to the development and  production of advanced  solvents that are critical to all
 industries having to respond to the environmental  challenges of the 1990s.  Inland,
 operating from their facilities in Tacoma, Washington, is committed to customer
 satisfaction through quality - Total Quality Management  (TQM) is  an essential
 component of Inland's corporate commitments. During the past eight years, Inland
 has  become  a  preeminent  company  in the advancement of environmentally
 responsive solvents:

 •  Inland  is  a  member of the  Joint Association  for  the  Advancement  of
   Supercritical Technology (JAAST).  Inland was invited to participate as a full
   member amongst other technology  giants such  as  Los  Alamos National
   Laboratories, Battelle Northwest  Laboratories, IBM,  Boeing, Hughes and
   Autoclave Engineering.

 •  Inland is  an invited member of International  Air Transport Association and
   participated  in their subcommittee for non  chlorinated  paint  stripping
   alternatives.

 •  Inland is active in the ASTM G-4 subcommittee searching for new technologies
   for cleaning LOX lines.

 •  Inland is active in the SAEG-9 subcommittee on advanced methods for sealant
   applications

 •  Inland is an invited participant on U.S. Environmental Protection Agency's "Use
   Cluster"  committees  for development of printing and  aerospace industry
   regulations.

Inland actively supports many of the largest companies in the United States, as well
as federal government agencies, including: Westinghouse, Weyerhaeuser, Kodak,
McDonnell  Douglas,  Grumman,  Northrop,  Boeing,  Los  Alamos  National
Laboratories, Lawrence Livermore National Laboratory, U.S. Navy, and the U.S.
Air Force.
                                   432

-------
         TO DATE, THE SCIENTISTS AND ENGINEERS AT INLAND TECHNOLOGY INC.
 HAVE DEVELOPED SUCCESSFUL SUBSTITUTES FOR THE FOLLOWING PROBLEM SOLVENTS:
•Hi

fei^i^
Methylene
Chloride
1,M
Trichloroethane
Methyl Ethyl
Ketone (MEK)
Toluene / Xylene
Acetone
Stoddard Solvent /
Mineral Spirits
Trichloroethylene
Perchloroethylene
Methyl Ethyl
Ketone (MEK)
Freon 113
1,1,1
Trichloroethane
tiiiMHttsliBHlSnHalHn fflBIBBjP

lilt
Paint stripping; cold
tank soak; resin
removal
Electronic & electrical
cleaning. Also, metal
preparation
Surface preparation for
painting or welding
Surface preparation for
painting or welding
Cleaning of fiberglass
&. epoxy resins
Parts washing &. paint
cleanup
Degreasing & resin
removal
Degreasing
Paint Gun Cleanup
Vapor Degreasing;
Precision Cleaning
Vapor Degreasing;
Precision Cleaning



CITREX
X-CALffiER
CITRA SAFE®
TEKSOL EP
SAFETY PREP
CITRA SAFE
TEKSOL EP
SAFETY PREP
CITRA SAFE
TEKSOL EP
Z-STRJQ?
CITREX
CITRA SAFE
TEKSOL EP
BREAKTHROUGH
CITREX
TEKSOL EP
CITRA SAFE
CITRA SAFE
ISO-PREP
BREAKTHROUGH
EP921
CITRA SAFE OR
SKYSOL
WITH ULTRA
FILTRATION
CITRA SAFE OR
SKYSOL
WITH ULTRA
FILTRATION



Both products are biodegradable. CITREX is
not regulated by RCRA or SARA, Title III.
Both are low VOC.
CITRA SAFE is biodegradable; TEKSOL EP is
not regulated by SARA, Title III. Both are low
VOC and non chlorinated
SAFETY PREP. CITRA SAFE and TEKSOL
EP are biodegradable; all arelowVOCs
Same as above
Low VOCs & toxicity; High flash point;
CITREX is biodegradable
Low VOCs; CITRA SAFE is biodegradable.
BREAKTHROUGH is free from most
regulations TEKSOL EP is low toxicity
CITREX and CITRA SAFE are biodegradable,
low VOC. TEKSOL EP is non chlorinated with
low toxicity
Non-halogenated
Low VOCs, easier disposal; Low Toxicity
Biodegradable, High Flash Point, Low VOC.
not regulated by RCRA or SARA Title IB
CITRA SAFE biodegradable; SKYSOL is not
regulated by RCRA or SARA Title ID, Section
3 13. both are low VOCs
CITRA SAFE is biodegradable; SKYSOL is not
regulated by RCRA or SARA Title ITJ, Section
3 13, Both are low VOCs
It should be noted that performance needs vary from application to application and that none of these substitutes
should be expected to be 100% cross over for all applications.

Also, the chemical behaviors of these substitutes (vapor pressures, dry time, etc.) may differ from solvents being
replaced which may require changes in work practices in order for substitutes to be successful
Inland Technology, Inc.
1990  (Reproduced with Permission)
          433

-------
434

-------
   (The work described in this paper was not funded by the U.S. Environmental Protection
   Agency.  The contents do not necessarily reflect the views of the Agency and no official
   endorsement should be inferred.)

               TRANSFER EFFICIENCY AND VOC EMISSIONS
              OF SPRAY GUN AND COATING TECHNOLOGIES
                              IN WOOD FINISHING
 Lesley Snowden-Swan
 Pacific Northwest Laboratory
 Battelle Boulevard, P8-48
 Richland,WA  99352

 Pamela Womer
 Pacific Northwest Pollution Prevention Research Center
 1326 Fifth, Suite 650
 Seattle, WA  98101
SUMMARY
       This study was designed to determine which factors most strongly influence net volatile
organic compound (VOC) emissions and transfer efficiency (TE) of a spray coating operation in
a "real-life" wood finishing environment. Factors tested included spray equipment types and
coating types, as well as painter skill level and target size and shape.  Transfer efficiency and
coating usage were measured to rate the overall system performance (coating type plus
application method) in an operating wood finishing shop.  The equipment was designed to be
representative of small- to medium-sized businesses in the wood finishing industry.

       The study was not designed to determine the maximum achievable transfer efficiency for
the various spray guns, but rather to provide a non-biased test of "off-the-shelf" equipment not
optimized with variable tips.  Spray time was included in the data in order to aid in the analysis
of possible effects of the variables on production rate.  The study showed that a painting
operation must be viewed as a system, with gun type, coating composition, and especially
painter skill all affecting environmental performance.  The results also indicated that
water-borne coatings may hold significant long-term potential for VOC reductions in wood
finishing, and that painter skill level also exerts a strong influence on both transfer efficiency
and VOC emissions.
INTRODUCTION
             Improving transfer efficiency (TE) in spray coating operations would reduce
coating waste and VOC emissions, cut hazardous waste disposal fees and coating costs, and
lessen worker exposure to potentially hazardous materials.  Changing from 30 percent
transfer-efficient equipment to 65 percent transfer-efficient equipment would reduce materials
usage by approximately 50 percent1.  Many factors affect achievable TE, including spray
equipment type, size and geometry of the target, coating type, skill level of the spray operator,
air velocity, atomizing air pressure, fluid flow rate, and fan size.
                                          435

-------
        In this study, the impact of several factors which can affect achievable TE were
  investigated, including spray equipment type, size and geometry of the target, solids content of
  the coating, and skill level of the operator.  Transfer efficiency and VOC emissions were
  calculated for each of these factors. Other factors which may affect TE, such as air velocity,
  atomizing air pressure, and fluid flow were monitored and kept as stable as possible for the
  duration of the spraying procedures.  Environmental impact is clearly shown by the data on net
  VOC emissions, expressed in pounds of VOC per pound of solid applied, since those figures
  reflect both transfer efficiency and VOC content of the coating.
 METHODOLOGY
 Testing Environment
        Spraying was conducted inside a concrete dry filter spray booth of dimensions 14* x 43
 x 94' at a wood finishing facility in the Puget Sound area.  Fresh dry filters were installed in
 the booth prior to testing. The average temperature, percent humidity and air velocity in the
 booth for the duration of testing were 70F, 65 percent, and 180 ft/rain, respectively.

 Operator Skill Level
        To determine the importance of the human application factor on spray efficiency, the
 tests were performed with both a very experienced painter (over ten years spray painting
 experience) and a painter with limited  experience (less than one year).  The experienced sprayer
 had substantial experience with all of the spray guns tested. The novice sprayer had used all of
 the guns at least once; however, the bulk of his experience was with the HVLP air-assisted and
 HVLP equipment.

 Target Size and Geometry
        To investigate the effects of target configuration on  transfer efficiency, two types of
 targets (door panels and cabinet face frames) were sprayed  for each set of equipment and
 coating type used. The door panels provided a large flat target surface, while the frames
 offered a more complex shape. The door panels used were standard sized mahogany doors
 (dimensions 28" x 80", with a thickness of 1 3/8").  The simulated cabinet face frames were
 approximately 18" by 30", constructed from 2 1/4" x 1/2"  hemlock door casings.

 Coating Type
       The physical properties of each coating type are listed in Appendix A, Table A. 1. Each
 coating type consisted of a stain, a sealer, and a topcoat.  A single brand of stain was used for
 all tests. Stain usage was measured for the initial tests. However, because the weight of stain
 used was negligible compared to the weight of the sealer and topcoat, stain usage was found to
 have no measurable effect on the calculated TE of the total  coating system. Therefore,
although stain was applied in the remainder of the tests, stain usage was not included in the
transfer efficiency determination.

       The 25 percent solids and 30 percent solids alkyd modified nitrocellulose lacquer are
solvent-based coatings which are cured through the normal evaporative process to remove the
                                             436

-------
solvent. This type of coating is generally not available in a low-VOC material2.  Spraying was
also conducted with the 30 percent solids sealer combined with a 40 percent solids aikyd/urea
conversion varnish for the topcoat. This latter material contains a catalyst which promotes
curing through a polymer crosslinking process.  Though this type of coating is generally
available in high solids (low VOC) content, the shelf life of the final mixed material (catalyst
plus varnish) is less than  one day, and thus good planning and management is required to avoid
wasting material.

       The third type of coating investigated is a self-seal acrylic emulsion water-borne lacquer
(32 percent solids).  While the use of water-borne coatings substantially reduces  VOC
emissions, these coatings generally require longer drying times compared to solvent-reducible
materials, and generally require a heated environment, such as a curing oven.  Despite these
difficulties, water-borne coatings can be applicable to the wood finishing industry with some
procedural modifications.

Spray Equipment Type
       The spraying procedure used was modeled after regular production procedures used in
the shop.  Complete equipment specifications for the technologies chosen for testing is provided
in Appendix A, Table A-2. The equipment tested was selected by spray gun and coating
manufacturers' representatives participating in the study and are considered to be representative
of technology available to small- to mid-sized wood finishing businesses.

       The actual guns used in the study were newly purchased.  In addition, the guns were
used with the tips which were packaged with them, and no attempt to optimize gun performance
by using variable tips  was made.  The guns were intentionally used in this manner to provide a
flat comparison of "off-the-shelf1 equipment.

Volume and Mass Measurement
       Several measurements were necessary for the calculation of TE (see Appendix  B,
Equation B-l), including  volume  of coating used, mass of solids deposited on the target, weight
percent solids, and density of the coating.   The latter two measurements were also necessary for
calculation of VOC  content (see Appendix B, Equation B-4).  The volume of coating material
sprayed was measured using a fluid flow meter in conjunction with a pro-pulse receiver
module.  The mass of solids deposited on  each target was determined by weighing the target
before and after the coating system was applied using a Toledo SM30000 precision platform
scale (+/-0.1 gram).

Physical Properties Measurement
       Coating samples were taken at the  time of spraying and stored in sealed cans for later
analysis in the laboratory. Percent solids, density, and viscosity were measured  in a coatings
laboratory. Weight percent solids was determined by weighing a designated quantity of coating
specimen into an aluminum foil dish and heating at 200 degrees F to constant weight
(approximately two  hours). Density and viscosity measurements  were made at the coating
temperatures used for spraying using a weight-per-gallon cup and a Zahn #2 cup, respectively.
                                            437

-------
 RESULTS
 Transfer Efficiency
        The transfer efficiency results vary widely.  The maximum TE achieved in any of the
 tests approached 70 percent for the experienced sprayer and 60 percent for the novice sprayer,
 achieved both in spraying doors with the HVLP air-assisted gun and 30 percent solids coating
 system, and in spraying doors with the HVLP gun and water-borne system configurations (see
 Figure 1).  The minimum TE achieved was 23 percent for the experienced sprayer when
 spraying frames with the conventional gun and 30 percent solids system, and 18 percent for the
 novice spraying frames with the HVLP-1 gun and 25% solids system.  Due to the number of
 tests performed, it is difficult to determine immediately from these results the influence of
 individual factors such as gun type or coating on TE. It is most useful to consider each factor
 separately, as follows.

        There is much concern and controversy within industry and the regulatory community
 regarding which spray gun technology gives the highest transfer efficiency. The EPA assumes
 a TE of 25 percent for conventional airspray, 40 percent for air-assisted airless, and 40 percent
 for airless spray (for the coating of metal parts).  Although there is no universal TE assigned to
 HVLP, EPA region IX (San Francisco) assumes TE for HVLP to be greater than 65 percent
 (equivalent to electrostatic spray). Results from this study do not indicate a direct correlation
 between TE and spray gun type.  Although individual guns did vary in TE, no one gun
 consistently outperformed another with all of the coatings used. In addition, the TE achieved
 by one gun varied by as much as 50 percent depending on the specific test configuration.
 Again, it should be noted that the spray equipment was not set up to give the optimum TE (i.e.,
 with variable fluid tips and air caps), but rather were used off-the-shelf as received from the
 manufacturer. Pressures of fluid and air were, however, adjusted at the start of each test to
 ensure the best performance possible with the existing equipment.

        Although transfer efficiency does appear to be affected by coating type, there is no clear
 trend regarding the relationship between percent solids and TE. Perhaps the most consistent
 factor seen to exert an influence on transfer efficiency is painter skill level. In 90 percent of
 the combinations tested,  the expert sprayer achieved higher transfer efficiency than the novice.
 In fact, the differences in transfer efficiency due to painter skill level with a single gun type
 were often larger than differences between gun types. It is evident from these results that
 painter training and experience is a crucial factor in achieving optimal TE performance for
 spray coating operations.

 Volatile Organic Compound (VOC) Emissions
       A useful parameter for incorporating both the TE and VOC content of a coating
 application system is emissions (E). Emissions were calculated in this study as Ib VOC/lb
 solids applied to the target (see Appendix B, Equation B.4).  It is important to first notice the
 inverse relationship between TE and VOC emissions, i.e., with an  increase in TE comes a
decrease in VOC emissions.  For example, spraying frames  results in higher VOC emissions
and lower TE, and the experienced sprayer consistently achieved lower emissions and higher
TE than the novice.
                                            438

-------
       The most significant influence on emissions, however, appears to be the actual VOC
content of the coating material.  Emissions appear to consistently decrease from the lower solids
solvent-borne material to the higher solids material. In addition, tests run with water-borne
coating show significantly lower emissions than all of the solvent-borne coatings.

       Measurements of the amount of material of each coating type used to perform the spray
operation were also taken.  The results of these measurements demonstrate that, for each
equipment configuration, the amount of water-borne coating material used was consistently
lower than the solvent-based coating types. Obviously, reducing the amount of material used
reduces the environmental impact of that material.

Spray Time
       Although TE and VOC releases are perhaps the most important factors determining
environmental performance of a spray painting system, an equally important consideration from
an economics standpoint is production rate. If, for example, a particular spray gun technology
offers high TE but decreases production, material cost benefits due to increased TE may suffer.

       In order to provide insight into the possible effects of gun type on production rate, spray
times were measured for each combination of spray gun and coating system.  The average
results of these times are shown in Figure 3. With regard to gun performance, airless
application proved to be the quickest application method, while HVLP was the most time
consuming.  Once again, differences between the experienced and novice spray times clearly
show the advantages of using a trained painter.
CONCLUSIONS
       Strong conclusions regarding the effects of gun type on transfer efficiency or VOC
emissions are difficult to draw from the data. However, a few important points regarding
environmental effects in wood finishing operations are clear:

Painter skill level has a strong influence on achievable TE, VOC emissions, and spray
time. This element of the system is a direct and simple measure for improving environmental
performance.  Training, both introductory and on-going, should include  spray techniques,
coating content, equipment set-up, and optimization.

Several factors work as a system to affect environmental performance. These include
painter skill level, spray equipment type, and coating type, as well as uncontrollable factors,
such as the geometry and size of the target.  Solutions should be  situation-specific, and all of
the factors discussed above should be adjusted to optimize performance.

Waterborne coatings hold significant long-term potential for VOC reductions in wood
finishing.  As this study demonstrates, water-borne coatings provide significantly less VOC
emissions as well as reduced materials usage, irrespective of spray equipment used.  Operators
are urged to request information on the latest in water-based materials from their vendors.
                                           439

-------
    Figure 1. Transfer efficiency for all equipment types and coating systems
                (using data from expert painter spraying doors).
          Airless
 HVLP air-assisted
Air-assisted airless
            • 32% Solids Water-Bome

            • 40% Solids Conv Var

            D 30% Solids Nitrocel.

            DID 25% Solids Nitrocel.
    Conventional
                      10     20     30     40     SO
                               Transfer Efficiency (%)
60
70
                                            440

-------
      Figure 2.  VOC emissions for all equipment configurations and coating
                types (using data from expert painter spraying doors).
           Airless
 HVLP air-assisted
Air-assisted airless
          HVLP-2
          HVLP-1
     Conventional
                     miiiiimiiiiiiiiiiiiiiiiiiin	iiimmii	i	mi	m
                     """""""""	llllimiiiiiiiiiimmmiiiiii	iiiiiiiiiiiimi
                    lllllHlllllimiiiiiiiiiiimmiiimiiiiiimmiiiimiimiiiiimiiiiiimimiMiiiiim
                     iiiiiiiiiiiiiiiiiiiniiiiiiniiiiMiiiiiiiiiiiiiiiiiiiiiiiiM	iniiiiiiiiiiiiiiiiNiiiiiiiiiiiiiiiiiiiniiiiiiii
      • 32% Solids Water-Borne

      • 40% Solids Conv. Var.

      D 30% Solids Nitrocel.

      OH 25% Solids Nitrocel.
                              2468
                           VOC Emissions (Ib VOC/lb solids applied)
10
                                                      441

-------
           Figure 3. Spray time for expert and novice painters, with all equipment
             types (using average data from all coating systems, spraying doors).
         Airless

 HVLP air-assisted

Air-assisted airless

        HVLP-2

        HVLP-1

    Conventional
                                2345
                                     Spray Time (minutes)
                                          442

-------
 REFERENCES

 1.     Lee, Abigail C. "Compliance Guidance for Autobody Repair and Refmishing Industry
       Spray Coating Operations," Puget Sound Air Pollution Control Agency, 1991.

 2.     Joseph, Ron.  "Getting into Compliance with Environmental Regulations for Paints,
       Coatings, and Printing Facilities," International Coating Seminars, October, 1991,
       Session 3-180, p.4.
 BIBLIOGRAPHY

 Allison, Melissa, Teresa Summers, and Cathy Troutman.  Final Report for High Volume/Low
 pressure Spray Gun Evaluation.  Thomson Crown Wood Products, Mocksville, North
 Carolina, 1992.

 Baker Environmental, Inc. Current Potential Future Industrial Practices for Reducing and
 Controlling Volatile Organic Compounds. American Institute of Chemical Engineers, Center
 for Waste Reduction Technologies, New York, New York, 1992.

 Dambek, Paul J., Kevin D. Kelly, Joshua M. Heltzer, Maria L'Annunziata, and Thomas M.
 Smith.  A Guide to Pollution Prevention for Wood Furniture Finishing. Prepared for U.S.
 EPA Region  1, Capstone Project, Tufts University, Medford, Massachusetts, 1992.

 EPA Guides to Pollution Prevention:  The Paint Manufacturing Industry.  EPA/625/7-90/005
 (NTIS PB90-256405). U.S. EPA Risk Reduction Engineering Laboratory, Center for
 Environmental Research Information, Cincinnati, Ohio, June  1990. 67 pp.

 Hackney & Sons, Inc. Evaluation  of High Volume/Low Pressure Spray Coating Equipment
 Washington, North Carolina, 1990.

 Kennedy, K.C.  Transfer Efficiency of Improperly Maintained or Operated Spray Painting
 Equipment, Sensitivity Studies. U.S.  EPA Air and Energy Engineering Research Laboratory,
 EPA-600/2-85-107 (NTIS PB86-108271). Research Triangle Park, North Carolina, September
 1985.

Randall, Paul M. Pollution prevention methods in the surface coating industry. Journal of
Hazardous Materials, 29 (1992):  275-295, 1992.
                                        443

-------
                                              Appendix A
                              Material and Equipment Specifications
      Table A. 1.   Physical Properties of Coatings
Coating
Sealer (25%
solids)
Topcoat (25%
solids)
Sealer (30%
solids)
Topcoat (30%
solids)
Conv. Varnish
(40% solids)
Water-Bome
(32% solids)
Weight
(% solids)
26.07
29.72
25.81
28.07
35.79
30.86
VOC
(Ib/gaJ)
5.73
5.36
5.67
5.52
5.17
1.76
Density
(ib/gaJJ
7.74
7.62
7.62
7.67
8.06
8.24
Viscosity
(Zahn, #2)
33
45
37
28
33
30
      Table A.2.    Spray Equipment Specifications
Gun Type
Manufacturer
Model No.
Serial No.
Air Cap
Fluid Tip
Needle
Conventional
Airspray
Binks
2001
	
63PB
63B
563A
HVLP-1
Devilbiss
JGHV-530
	
*28
0.0425 inch
JGA402FX
HVLP-2
Accuspray
#10
3610155
fll
0.051 inch
0.051 inch
Air-Assisted
Airless
Grace
AA2000
	
(standard)
215/417*
(standard)
HVLP
Air-Assisted
Graco
AA2000
	
222608
215/417*
(standard)
Airless
Grace
Silver
	
	
415/417*
(standard)
     • First number represents fluid Up used for spraying face frames; second Dumber is the tip used for doors
In addition to the spray guns and coatings described above, other equipment was needed to perform the tests. Pumps were
used with the air-assisted airless and airless configurations (Graco, Model 10:1 Monark with 1/4 inch fluid and 3/8 inch
air hoses and Model 30:1 president with 1/4 inch fluid hose, respectively). The fluid flow meter (Graco, CS A AFMapproved;
Class 1. Division 1, Model 224-222, Series F91 A, Serial #C148) was used with a 200 mAmp power generator and a pro-
pulse receiver module. The fluid pressure pot (5 gallon ASME) included 1.4 inch fluid line and a 5/16 inch air line. Fluid
temperature was measured with a thermometer (VWR Scientific Inc.. 61014-020).
                                               444

-------
                                           Appendix B
                                           Calculations
 Transfer Efficiency  Transfer efficiency was determined on a mass basis using guidelines from ASTM
 Method D5009-89:

        Equation B.I          TE = (100 x P) x  100 / (F x d x S)
                                    where
                             TE = transfer efficiency (%)
                             P = mass of coating solids deposited on target (g)
                             F = volume of fluid delivered (ml)
                             d = density of coating (g/mi)
                             S = wt% solids of coating
 Volatile Organic Compound (VOC) Content.  VOC content was calculated using guidelines from ASTM
 Method D3 960-90:
                              For solvent-borne coatings,

        Equation B. 2:          V = (100 - (S + X)) x d x 10
                                    where
                              V§ = total VOC content (g/1) (organic volatiles)
                              S = wt% solids of coating
                              X = wt% exempt solvent of coating
                              d = density of coating (g/ml)

                              For water-borne coatings,

       Equation B.3:          VM =(V. x 100 x dj / (100 - (d x W))
                                    where
                              Vw = total VOC content  (g/l), based on coating excluding water
                              Vw = total VOC content (g/l), determined from calculation B.2
                              dw = 0.997 g/ml (density of water at 25°C)
                              d = density of coating (g/ml)
                              W = wt% \vater of coating

Coating density (d) and percent solids (S) were determined in the laboratory (see  Appendix A, Table A. 1).
while water content (W) was taken from manufacturers' coating specifications.

VOC Emissiors.  Emissions for each sealer + topcoat system were calculated with variables used in the above
equations (assumes 100% of VOC content in coating material is dispersed into air):

       Equation B 4:          E = [(V.  x VOL.) + (V, x VOL,)] / P
                                    where
                              E = VOC emissions for sealer + topcoat (g VOC/g solids applied)
                              V_ = VOC content of sealer (g/l)
                              VB = VOC content of topcoat (g/l)
                              VOL, = total volume of sealer used to finish target (1)
                              VOL, = total volume of topcoat used to finish target (!)
                              P = mass of coating solids deposited on target (g)

                                                 445

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446

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(The work described in this paper was not funded by the U.S. Environmental
Protection Agency. The contents do not necessarily reflect the views of the Agency
and no official endorsement should be inferred.)
             YOU CANT ALWAYS JUDGE A PAINT SPRAY GUN
                    CLEANING SYSTEM BY ITS COVER
                            Michael J. Callahan
                              Project Engineer
                          Safety-Kleen Corporation
                           777 Big Timber Road
                              Elgin, IL  60123
                                   and
                               John P. Kusz
                      Manager of Product Development
                          Safety-Kleen Corporation
                           777 Big Timber Road
                              Elgin, IL  60123
                                    447

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ACKNOWLEDGEMENTS

      The authors would like to gratefully acknowledge Ronald G.  Draftz of
IITRI for his guidance,  encouragement, and insight during this study.
                                     448

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TABLE OF CONTENTS
                                                                            Page



Introduction                                                                   450




Background                                                                   450




Test Plan                                                                     451



Test Equipment                                                               453




Measuring Equipment                                                          454




Active Test Procedures                                                         455




Passive Test Procedure                                                         457




Results                                                                       457




Conclusion                                                                   459




References                                                                    460
                                      449

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 INTRODUCTION

        The reduction of VOC enissions  from  surface coating  not only applies  to
 surface  preparation and application,  but to  application equipaent clean-up  as
 well.  Specifically,  most paint spray gun  cleaning systems use VOC's for
 cleaning and,  therefore,  are another  emission  source which must be evaluated.

        Many paint  spray gun cleaning systems  are  currently  in use throughout
 industry,  each with individual  emission characteristics.   The challenge
 becomes  selecting a system which cleans well,  yet minimizes VOC emissions.  A
 simple approach to emission reduction might  be to make sure the system uses a
 low vapor pressure solvent and  is closed during  operation.  However
 intuitive, this approach  may not always yield  the desired  results.

        This paper  -rill  discuss a  comparative  study of VOC emissions  between
 two paint spray gun cleaning systems.   One of  the  systems was defined as
 'closed'  (i.e. had a cover which remained closed during operation);  the other
 system was "open"  (i.e. had no cover).  A comparison was also made  using
 cleaning solvents  with different vapor pressures  to determine
 solvent/cleaning system interaction regarding emissions.

 BACKGROUND

       This comparative study was sponsored by Safety-Kleen Corporation,
 Elgin, Illinois,  and conducted by IIT  Research Institute  (IITRI), Chicago,
 Illinois, during June 1992.  Safety-Kleen Corporation provides parts  cleaning
 services with associated recycling to  the automotive aftermarket  industry.
 IITRI is a nationally recognized research and test institute which provides
 advanced research and testing to government and industry covering a diverse
 group of topics including environmental  issues.

       The comparative study was  performed to demonstrate equivalent
 compliance with California South Coast Air  Quality Management District
 (SCAQMD)  Rule 11711, effective July 1, 1992.  This rule requires that spray
 paint gun cleaners limit emissions of  volatile  organic compounds (VOC's) that
 are 'stratospheric ozone depleting or  global-warming compounds.'  The rule
 provides  specific  guidelines for the use  and disposal of solvents used for
 spray  paint gun cleaning systems (systems are defined as the cleaning unit
 and its solvent).

       The  principal aspects of the rule which deemed the study include:

 1.     The-cleaning equipment must be 'closed' during operation except when
       depositing and removing objects  to be cleaned, and is closed during
       nonoperation with the exception  of maintenance and repair to the
       cleaning  equipment itself.*

2.     The solvent  shall have a VOC content of '950 grams or less of VOC per
       liter of  material and a VOC composite partial pressure of 35 mmHg or
       less at 20»C  (68'F).'3

3.     Manufacturers, owners and operators may demonstrate equivalency (i.e.
      equivalent compliance)  for a spray paint  gun cleaning system in lieu of
      complying with these  rules.*
                                     450

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       Specifically, the Safety-Kleen Model 1107 Spray Paint Gun and Equipment
 Cleaner is considered by SCAQMD to be an open unit (i.e., does not have a
 cover); therefore, it does not comply with the specific provision of Rule
 1171.   Additionally, the solvent currently used with Model 1107 in California
 has a composite partial pressure of 96 mmHg,  which exceeds the "35 mmHg or
 lower" requirement of Rule 1171.

       However, the "equivalency provision" of Rule 1171 allows for a
 temporary exemption if it can be demonstrated that a "non-compliant" system
 does not lose more solvent than a currently accepted system.

       This study performed by IITRI was designed to determine  whether the
 Safety-Kleen Model 1107 had solvent losses comparable or less  than hose of
 closed systems using a low (less than 35 mmHg) vapor pressure  solvent.   A
 Herkules GWR spray paint gun cleaner with a low vapor pressure solvent was
 selected for this comparative compliance study.

 TEST PLAN

       A Safety-Kleen Model 1107 and a Herkules Model GWR were  tested for both
 active and passive solvent losses.   Active solvent losses were those which
 occurred from cleaning a spray paint gun according to the manufacturer' s
 recommended cleaning procedure for  each system.  Passive solvent losses were
 those  which occurred as each unit would normally be stored between active
 cleaning cycles.

       Solvent losses for active and passive tests were determined  separately
 to  permit total loss computation for any combination of active uses  per day
 with the corresponding times between use.

       Solvent losses were determined by precise weight difference
 measurements of each unit with its  solvent.   A highly sensitive precision
 platform scale was utilized for all weighing.   The test procedures used
 standard weights  to verify accuracy and sensitivity of the scale throughout
 the  testing.

      Active test weighing were made immediately prior to the  start  of an
 active  test and at the  completion of a cleaning cycle.   The active cleaning
 cycle for each unit will  be discussed in detail under "Active  Test
 Procedures."  Ten successive  cleaning cycles  comprised a single active test.

      Passive  test weighing were  made daily for each unit.  A  single  passive
 test lasted for five  contiguous days at ambient laboratory conditions.

      Environmental conditions  in the laboratory were not controlled;
however,  temperatures,  relative humidities  and air velocities  were
periodically recorded during  testing.   Each series of tests were conducted
virtually  simultaneously  in the same laboratory to minimize variations
resulting  from ambient  environmental variations.

      Two  primary  solvents  were tested:   Safety-Kleen 5820 West5 (vapor
pressure - 95  mmHg) and Grow  4231 P.N.C^  (vapor pressure  - 32  mmHg).  Both

                                       451

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  solvents  vere cross-tested in both units to verify representativeness and to
  preclude  test bias.

       A third solvent,  SK-East5,  produced by  Safety-Kleen,  was also used for
  cross-testing.   SK-East has  a vapor pressure  of  approximately 75 maHg.

       A fourth solvent,  cyclohexane (vapor pressure -  78  mnHg),  was used in
  one series  of active  tests  in the Safety-Kleen Model 1107 unit as a control
  solvent.  Cyclohexane was used to establish active losses for possible  future
  product developments.   This  solvent is available from  a number of sources as
  a high-purity organic of known vapor pressure.  Since  this  solvent is a
  single organic  chemical  with no isomers,  it provides a valuable  link between
  test results  from  this  study and  future  experiments.   It  may  also allow  for
  future comparative  losses from multicomponent solvents by simply comparing
 vapor pressures.

       All testing was performed solely by IITRI staff  at  its  principal
 laboratories  in Chicago, Illinois.  All units were operated in strict
 accordance with manufacturer's  instruction manuals.^-^  In addition, all
 active tests were conducted by  a  single operator to avoid inter-operator
 performance differences.

       The active test plan consisted of three test series (A  through C) .
 (See Table 1 below.)  Series  "A"  compared the Safety-Kleen and Herkules  units
 using S-K East and Grow 4213  solvents,  directly.   Series "B" and "C" provide
 similar cross comparison, but also permit comparison within a manufacturer's
 unit.
                                    TABLE I9
                               ACTIVE TEST MATRIX
 Series   Test
Cleaner Unit
Cycles
Test Function
Solvent
A
A
A
A
A
A
B
B
B
B
B
C
C
C
C
C
G
1
1A
2
3
4
5
6
7
8
9
10
11
12
13
14
15
26
Safety-Kleen(SKl)
Safety-Kleen(SKl)
Safety-Kleen(SK2)
Safety-Kleen(SK3)
Herkules (HI)
Herkules (2)
Safety-Kleen(SKl)
Safety-Kleen(SK2)
Safety-Kleen(SK3)
Herkules (HI)
Herkules (H2)
Safety-Kleen(SKl)
Safety-Kleen(SK2)
Safety-Kleen(SK3)
Herkules (HI)
Herkules (H2)
Safety-Kleen
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Standard Clean
Repeat of Test 1
Standard Clean
Standard Clean
Standard Clean
Standard Clean
Replicate of Test 1
Compare to Tests 3&4
Compare to Tests 2&11
Compare to Tests 5&15
Compare to Tests 4&14
Compare to Tests 268
Compare to Tests 1&6
Replicate of Test 3
Replicate of Test 4
Replicate of Test 5
Control
SK-East
SK-East
5820 Vest
Grow
Grow
SK-East
SK-East
Grow
5820 Vest
SK-East
Grow
5820 Vest
SK-East
Grow
Grow
SK-East
Cyclohexane
Note:  Test 1A repeated to correct procedural error.
                                      452

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       The passive test plan consisted of two test series,  "D"  and "E*  (See
 Table 2 below.)
                                   TABLE 29
                              PASSIVE TEST MATRIX
Series
D
D
D
D
D
E
E
E
E
E
Test
16
17
18
19
20
21
22
23
24
25
Cleaner Unit
Safety-Kleen(SKl)
Safety-Kleen(SK2)
Safety-Kleen(SK3)
Herkules(Hl)
Herkules(H2)
Safety-Kleen(SKl)
Safety-Kleen(SK2)
Safety-Kleen(SK3)
Herkules(Hl)
Herkules(H2)
Days
5
5
5
5
5
5
5
5
5
5
Test Function
Standard Passive
Standard Passive
Standard Passive
Standard Passive
Standard Passive
Compare to Test 17
Compare to Test 18
Compare to Test 16
Compare to Test 20
Compare to Test 19
Solvent
SK-East
5820 Vest
Grow
Grow
SK-East
5820 Vest
Grow
SK-East
SK-East
Grow
 TEST EQUIPMENT

 Safety-Kleen Model 1107

      Three  identical  new units,  identified  as SK-1, SK-2. and SK-3 were
 utilized  in  the  study.   The Safety-Kleen unit is an air-powered, dual-remote
 reservoir system consisting of  a  hemispherical cleaning/drain area with vapor
 collection collar and  vacuum operated final  rinse purge.  The dual remote
 closed reservoirs,  one for spent  solvent and one for clean final rinse,
 provide for  quick return of solvent to separate containers, minimizing
 potential for evaporation.  The two air-driven solvent transfer pumps are
 centrifugal  type to minimize solvent vapor evolution.  Solvent vapors in the
 hemispherical cleaning drain area are removed through a perimeter collar
 venturi system and ducted where deemed appropriate by the user.  This collar
 creates a slight negative pressure, keeping  vapors contained and away from
 the user.  In addition,  the collar vapor collector is interlocked with the
 solvent pumps to preclude solvent pumping in the event of collar vapor
 collector malfunction.   A vacuum  canister is also provided to capture solvent
 during the final rinse  purge stage.  This canister is fitted with a
 coalescing media that  gathers the solvent vapor, condenses it and returns it
 to the remote reservoir.

Herkules Model GVR

      Two virtually identical,  new units identified as H-l and H-2 were
utilized  in  the  study.   The Herkules unit is an air-powered, non-remote
 reservoir  system consisting of  a  rectangular solvent storage tank with
 integral  cleaning/drain area and  a closable  lid.  The rectangular solvent
storage tank is  nominally filled with five gallons of solvent.  The tank is
also equipped with an external  ball valve for draining during solvent change-
                                      453

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  out.   The unit is equipped vith four equipment cleaning nozzles to
  accommodate the cleaning of two spray paint guns vith paint cups
  simultaneously.  The solvent transfer pump is a positive displacement type
  interlocked with the lid opening/closure.

  Spray  Paint Gun

        Five identical,  new paint spray guns were used  for the  study.   One
  paint  spray gun was dedicated to each cleaner unit.   The paint spray  gun was
  manufactured by Sinks,  Model 98-1130.  This particular  paint  spray gun was
  selected because of its wide use throughout industry.

  MEASURING EQUIPMENT

  Platform Scale

       A  new,  high precision  Sartorius scale  (Model F150) with  a capacity of
  150 Kg was utilized for all  solvent weighing.  The published scale
  sensitivity was one gram over the  full range of 0 to 150 Kg.   The scale was
  set up and calibrated by a factory-trained  technician at IITRI prior to
  testing.   The sensitivity was verified subsequent to set-up and calibration.

       Sensitivity and accuracy tests at  load were performed using Class S-l
 weights  traceable to the National  Institute of Standards and Technology and
 six,  11.3  Kg  barbell weights  to provide  loads slightly greater than the paint
 spray gun  cleaner weights.  Additional standard (Class F) calibration weights
 borrowed from the factory technician were used to produce loads over the full
 range of the  scale.

       Weights were added  to the scale ranging from one gram to 150 Kg  noting
 the values.  A one-gram weight was added at each load to verify that  the
 scale could detect the one gram.  The scale responded precisely to the one-
 gram  addition at all loads.

 Scale Accuracy Verification

      Throughout active and passive  testing, the accuracy of the platform
 scale was verified prior to and immediately after each cleaning unit weight
 measurement.  This was  accomplished by placing the six 11.3 Kg weights in the
 marked  "footprint" and  recording the value.   Then a 50 g weight was added and
 the value verified to become  +50 g.  Finally,  all weights were removed; and
 the scale was checked for "zero tare."

Auxiliary Scale Platform

      The original platform of the  Sartorius scale was  too  small  to
accommodate the Safety-Kleen  cleaning system.   Therefore,  a larger, aluminum,
auxiliary platform was placed over  the existing platform and remained  for the
duration  of the testing.

      The  scale was sensitive to gross misplacement of the  load, which may
have led  to erroneous readings.  Therefore,  prior to testing,  the auxiliary
platform was marked with the  "footprint"  of  each cleaner and the barbell

                                       454

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 weights.  The loads throughout testing were placed in the marked location
 each time to preclude error.
 ACTIVE TEST PROCEDURES

       The following is a synopsis of the steps used to determine active
 solvent losses for each unit.

 Safety-Kleen Model 1107

  1.    Weigh the cleaner and components.   Record value and time.

  2.    Don gloves and safety goggles.   Disassemble the unused,  clean spray gun
       if it is not already apart, and place the parts in the cleaner bowl.
       Turn unit on.

  3.    Fill the paint cup from  the used solvent port for 7 seconds by counting
       7 beats starting when the solvent  begins flowing into the  cup.  Do not
       start counting when the  pump actuator switch is depressed, because
       there is a delay of several seconds before the solvent flows.  There
       will be a solvent afterflow of  several seconds when the  foot  actuator
       switches released.

  4.    Brush the spray gun cup  for 30  seconds as follows:  a) Brush the inside
       walls for eight seconds  using a sweeping rotary motion;  b) Continue
       brushing the inside walls using a  vertical stroke while  rotating the
       cup;  c)  Brush  the lip and outer, upper collar using rotary strokes for
       10 seconds.  Keep track  of time using the metronome beats.

  5.    Place the brush in the cleaner  bowl and assemble the spray head to the
       paint cup.

  6.    Shake the assembled spray gun containing the  solvent for 15 seconds
       using a  pendulum motion.

  7.    Place the spray tip against the suction canister spout and squeeze the
       trigger  while pushing the suction  canister up.

  8.   Maintain suction for 7 seconds.

  9.   Disassembly  the  spray gun.   Place  the  spray head in the  bowl  and pour
       the remaining solvent into  the  bowl.

10.   Add clean solvent to the  paint  cup  for 7  seconds.

11.   Rotate the paint cup on its  side 1  and 1/2  times slowly  for
      approximately 10 seconds  to wet  the  inside  paint cup surface,
      simulating the entrainment of residual  pigments/resins.

12.   Pour  the  solvent into  the bowl.

13.   Place the paint cup  into  the bowl upside  down  to promote drainage.

                                       455

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 14.    Invert the spray head and place its tube against the clean solvent
       delivery tube of the cleaner.   Squeeze the trigger while the solvent
       flows for 7 seconds.

 IS.    Turn the spray head upright and flush clean solvent from the cleaner
       onto the spray tip for 3 seconds while rubbing the tip with a gloved
       finger.

 16.    Place the spray head into the  bowl.

 17.    Remove and drape the gloves onto the  bowl  ledge  and turn the unit  off.

 18.    Disconnect the grounding clips and attach  them to  the  cleaner so they
       are part of the system weight.

 19.    Remove the exhaust hose from the hood and  place  it  so  the hood end
       rests in the bowl.

 20.    Weigh the cleaner and components at exactly 4  minutes  after  the unit
       was turned off.   (This 4-minute  wait  period is included  to permit  time
       for solvent evaporation from the bowl  and  components.)   Record the
       time.

 21.    Repeat steps 1-20 nine additional  times.

 22.    Record system operating pressure,  room temperature, relative humidity
       and air speed on  the  data form during the tenth cycle.

 23.   Remove  the  cleaner  and solvent cans after the tenth cycle of active
      cleaning.   Record the  tare weight.

Herkules Model GWR

 1.   Weigh the cleaner and components.  Record value and time.

 2.   Don respirator, gloves and safety goggles.   Disassemble the unused,
      clean spray gun, if it is not already apart.

 3.   Open the lid and invert the spray gun cup over the  short nozzle.

 4.   Remove the trigger lock from the cleaner chamber  and attach it so the
      trigger remains in an open position.

 5.    Place the tube of the spray head onto  a cleaner nozzle and close the
      lid.

 6.    Turn the cleaner on for 60 seconds, timing  the operation with a
      stopwatch.

 7.    Adjust the solvent pumping rate to 2 cycles/second  by matching the  pump
      beat to the metronome.

 8.    Turn off the cleaner and wait 5  seconds.

                                      456

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  9.   Open the lid and remove the trigger lock, returning it to the
       reservoir.

 10.   Shake excess solvent from the spray head into the reservoir.  Hang the
       spray head on the metal rod at the front of the cleaner.

 11.   Shake excess solvent from paint cup into the unit.

 12.   Close the lid,  placing the paint cup upright on top of the lid.

 13.   Remove gloves and place them on top of the lid,  and immediately  start
       timing a 4-minute wait period (to permit solvent evaporation from the
       components outside the reservoir).

 14.   Disconnect the  air compressor supply.

 15.   Weigh the cleaner and components in-place after  exactly 4 minutes using
       a stopwatch for time.

 16.   Repeat steps 1-15 nine more times.

 17.   Record system operating pressure,  room temperature,  relative  humidity
       and air speed on the data form during  the 4-minute wait period of the
       tenth cycle.

 18.   Remove the cleaner after the tenth  cycle of active cleaning.  Record
       the tare weight.

 19.   Repeat standard weighing to verify  scale precision and accuracy.   This
       completes a single active test consisting of ten data  points  for
       solvent loss per cycle.

 PASSIVE  TEST PROCEDURE

       The following is  a summary of the steps  used to  determine  the passive
 solvent  losses for each unit.   This procedure  was the  same for both units and
 consisted of the  following steps:

 1.     Connect  "fresh"  solvent  cans to the  Safety-Kleen unit.  Add  five
       gallons  of  test  solvent  to the Herkules  unit.

 2.     Perform  daily scale  calibration verifications.

 3.    Weigh  and record  each cleaner.   Record time of weighing.

4.    Repeat measurements  at approximately 24-hour intervals  for five
      additional days.

RESULTS

Active

      The comparative tests show that  the "closed* Herkules Model GWR with
      Grow 4213 (33 mmHg vapor pressure solvent)  lost  an average of
                                       457

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       18.2 g/cycle during active cleaning.  The Safety-Kleen Model 1107
       "open" unit with 5820 West solvent (95 mnHg vapor pressure) lost an
       average of 12.7 g/cycle during active cleaning.   The Herkules unit with
       Grow.solvent (32 mnHg vapor pressure) lost 1.4 times more solvent than
       the Safety-Kleen unit during active test.  (See  Table 3 below.)
                                   TABLE 39
                              ACTIVE LOSS RESULTS
Test
2
8
11
Test
4
10
14
Unit
SK-2
SK-3
SK-1
Unit
H-l
H-2
H-l
Solvent
5820 West
5820 West
5820 West
Average of
Solvent
Grow
Grow
Grow
Date
6-4-92
6-5-92
6-7-92
Safety-Kleen
Date
6-4-92
6-5-92
6-7-92
Average of Herkules
Cycles Total Loss.G
10
10
10
Units with
127
132
123
5820 Vest
Cycles Total Loss.G
10
10
10
Gun Units
202
162
182
with Grow
G-Loss/Cycle
12.7 +/-1-5
13.2 V-2.1
12.3 +/-1.1
12.7
G-Loss/Cycle
20.2 +/-1-9
16.2 V-0.9
18.2 +/-1-4
16.2
Passive

The tests showed that  the Herkules unit lost an average of 1.82 g/hour during
the passive (non-cleaning) mode.  The Safety-Kleen unit lost an average of
0.32 g/hr during the passive test period.  The Herkules unit lost 5.7 times
more solvent than the  Safety-Kleen unit during the passive period.   (See
Table 4 below.)
                                  TABLE  49
                             PASSIVE LOSS RESULTS
Test
17
21

19
25

Unit
SK-2
SK-1

H-l
H-2

Solvent Period Total Wt Loss
5820 West 9-14 Jun 92 32
5820 West 14-19 Jun 92 42
Average of Safety-Kleen Gun Cleaner Units
Grow 9-14 June 92 189
Grow 14-19 June 92 238
Average of Herkules Gun Cleaner Units
AVR G-Loss/Hr
0.27
0.37
0.32
1.57
2.07
1.82
                                      458

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CONCLUSION

      All of us recognize the importance of miniaizing VOC and toxic air
emissions in the coating industry -- not Just in the application of coatings
or surface preparation, but in cleanup operations as well.  The methods for
potential reductions are as diverse as the processes themselves.  For this
reason, simple rules and guidelines appear to be the most effective means of
reducing emissions.  However well intentioned, the desired result --
significant emission reduction -- may not always be achieved.

      As evidenced by the aforementioned comparative study results,
appropriate emissions reduction controls may already be in place,  but
misunderstood.  Just like a good book --a paint gun cleaner can't always be
Judged by its cover.
                                      459

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                                  REFERENCES


 1. South  Coast Air Quality Management District (California), Rule 1171,
   "Solvent Cleaning Operations," adopted August 2, 1991.

 2. Ibid,  subparagraph  (C)(2)(C), page 1171-8.

 3. Ibid,  subparagraph  (C)(1)(C), page 1171-6.

 4. Ibid,  paragraph (c)(7), page 1171-10.

 5. Safety-Kleen Material Safety Data Sheet No. 82343.

 6. Grow 4213 Material Safety Data Sheet.

 7. Safety-Kleen Model 1107 Instruction Manual.

8. Herkules Model GVR Instruction Manual.

9. Illinois Institute of Technology Research Institute (IITRI)  "Final
   Report--Compliance Study of the Safety-Kleen Model  1107  Spray  Paint  Gun
   Cleaner," dated 6-29-92.
                                      460

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                         SESSION 11
                      APPLICATIONS 2
                       PAPERS PRESENTED:

"Priority Manufacturing and Environmental Issues at Military Industrial Facilities"
                                by
                          John W. Adams
                         Richard S. Goldman
                          Jerry R. Hudson
          National Defense Center for Environmental Excellence
                 Concurrent Technologies Corporation
                       Johnstown, Pennsylvania

               "Low-V(X: Dual-Cure Aerospace Topcoat*'
                                by
                       Kevin E. Kinzer (Speaker)
                          Steven J. Keipert
                           3M Company
                   Corporate Research Laboratories
                         Si. Paul, Minnesota

        "UV Pollution Prevention Technology in Can Manufacturing"
                                by
                          Erik T. Donhowe
                      Coors Brewing Company
                         Can Manufacturing
                          Golden, Colorado

 "Pollution Prevention Opportunities in the Manufacture of Paint and Coatings"
                                by
                          Paul M. Randall
                U.S. Environmental Protection Agency
                Risk Reduction Engineering Laboratory
                          Cincinnati, Ohio
                               461

-------
(The work described in this paper was not funded by the U.S. Environmental Protection
Agency.  The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)


           PRIORITY MANUFACTURING AND ENVIRONMENTAL ISSUES
                      AT MILITARY INDUSTRIAL FACILITIES

John W. Adams. Richard S. Goldman, Jerry R. Hudson

National Defense Center for Environmental Excellence
Concurrent Technologies Corporation
1450 Scalp Avenue
Johnstown. PA 15904
1-800-CTC-4392

INTRODUCTION

       Concurrent Technologies Corporation (CTQ, a not-for-profit company, operates the
Department of Defense's (DoD) National Defense Center for Environmental Excellence
(NDCEE) which is located in Johnstown, PA. The NDCEE provides a means of testing.
evaluating, and applying new and "stale of the market" environmentally acceptable technologies
in a low-risk industrial setting.

       In 1990, Congress passed legislation that created the NDCEE.  Sponsored by DoD's
Office of the Deputy Assistant Secretary (Environment) and managed by the U. S. Army
Material Command, the NDCEE was given the broad charter to systematically address industrial
challenges and identify and implement environmentally acceptable solutions.

       The broad scope of our mission gives us the flexibility to lead government and industry
conversion to environmentally acceptable manufacturing technologies and to serve as a national
resource for environment-related technical and analytical support.  As the Center's infrastructure
is put in place, it will gradually address:
      •      waste minimization.
      •      hazardous waste management,
      •      management of RCRA-type wastes,
      •      municipal-type solid waste and incineration issues,
      •      air pollution management,
      •      medical waste management,
      •      contaminated site remediation,
      •      demilitarization,
      •      recycling and recovery,
      •      water pollution management,
      •      nuclear waste management, and
      •      mixed waste management.
      However, the initial thrust of the NDCEE will be that of Pollution Prevention —
specifically, demonstrating and exporting environmentally acceptable technologies to the DoD
and defense-related industries.

                                        463

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 HIGH PRIORITY ENVIRONMENTAL IMPACT REPORT

       To ensure that the NDCEE focuses its attention on the nation's most significant
 manufacturing and environmental problems first, the NDCEE has prepared a High Priority
 Environmental Impact Report. For this report, industrial manufacturing technologies were
 analyzed and ranked according to their potential for adverse environmental impact and relevance
 to DoD- and defense-related industrial operations.

       There is little information available that describes environmental discharges from DoD
 manufacturing facilities. Consequently, the NDCEE used the Toxic Release Inventory (TRI)
 industrial database, provided by the U. S. Environmental Protection Agency (EPA), for the
 analysis of potential adverse environmental impact. The TRI is the most comprehensive
 database available for industrial toxic air. water and solid waste discharges.

       From the TRI listing of more than 300 chemical and chemical compounds, the NDCEE
 defined "high priority chemicals" as those which are:

              currently regulated by EPA,
       •      proposed to be regulated by EPA,
       •      identified as ozone depleting substances, or
       •      identified as potential, probable or known human carcinogens.

       There were 68 chemicals in the TRI that met the criteria listed above.  These chemicals
 represent 71.4 percent of the total TRI-reported discharges in 1989.  Industries that discharge
 these "high priority chemicals" were classified according to three digit Standard Industrial
 Classification (SIC) codes and were ranked according to the total discharge of the chemicals.
 From the ranked listing of industries, those with operations similar or identical to manufacturing
 processes at DoD industrial facilities (e.g., electroplating) were selected as high priority.

       The five selected SIC Codes with their total TRI discharge are: 347 - Coaling, Engraving
 and Allied  Products; 367 - Electronic Components and Accessories; 371 - Motor Vehicles and
 Motor Vehicle Equipment; 372 - Aircraft and Parts; and 373 - Ship and Boat Building and
 Repairing.  The total TRI discharges and "high priority chemical" discharges from these
 industries are listed below. These industries will receive initial consideration by the NDCEE for
 environmentally acceptable replacement technology demonstrations.

   SIC             TRI Total Discharge               "High Priority Chemical" Discharge

   347               69.4 million pounds                     52.2 million pounds
   367               74.1 million pounds                     57.5 million pounds
   371              161.7 million pounds                    151.4 million pounds
   372               56.0 million pounds                     50.6 million pounds
   373               30.1 million pounds                     29.7 million pounds

      The NDCEE also conducted telephone  interviews with companies in each of the five
selected industries. Through these interviews,  we were able to identify the top manufacturing-

                                        464

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 related environmental issues, the associated manufacturing processes, technologies being
 considered to solve the environmental problems, and areas where the NDCEE could help.

 CROSS INDUSTRY ISSUES

       "High priority chemicals" discharges, which are common to three or more of the five
 selected industry segments, represent over 99.7 percent of the "high priority chemical"
 discharges.  This indicates a high level of similarity in manufacturing operations among the five
 selected discrete parts manufacturing industries. Based upon the "high priority chemical"
 discharges of these industries, the following discrete parts manufacturing process activities can
 be inferred for the five selected industry segments:

       •      painting             •       metal plating
       •      paint stripping       •       metal cleaning

       The sheer volume and breadth of the TRI discharge data gives the impression of
 fragmented and diffuse manufacturing-related environmental problems. The findings of this
 report suggest otherwise, since many industries face the same problems. In this High Priority
 Environmental Impact Report, the NDCEE has been able to distill  these problems into the
 following seven cross-industry manufacturing related environmental needs for the five selected
 industries:

       •     demonstrate acceptable alternatives for paint removal chemicals,
       •     demonstrate acceptable alternatives for chlorinated and volatile organic
             compounds used as metal cleaners and paint solvents.
       •     demonstrate pollution prevention strategies and technologies to reduce heavy
             metal wastes.
       •      demonstrate acceptable alternatives to solvent based paint systems,
       •      implement a broader, more diligent effort for technology transitioning,
       •      provide worker training  on pollution prevention practices and manufacturing
             technologies, and. finally,
       •      leverage scarce financial and human resources to solve common problems.

RECOMMENDATIONS

       Based upon the NDCEE's findings, eight preliminary recommendations are offered.
These recommendations are intended to stimulate discussion, upon reviewing this work effort,
among members of the NDCEE's Senior Board of Advisors and Executive Advisory Council, as
well as other interested individuals and organizations.  Conclusions and further
recommendations from those discussions will be incorporated into future considerations of the
NDCEE.

       The eight recommendations are specifically focused to action items for DoD and related
industrial facilities which, if taken, would enhance the overall quality standard of these industrial
facilities, as well as the overall environmental quality associated with the facilities and their
products.  The key features of these recommendations are:
                                         465

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1.      Compile environmental discharge data from industrial facilities in a manner
       which relates those discharges to the processes used at the industrial facility.

2.      Demonstrate alternative technologies which can resolve environmental discharge
       problems.

3.      Conduct training programs on pollution prevention and alternative manufacturing
       technologies.

4.      Link product and process specification requirements to environmental problems.

5.      Implement standard for environmental costs; such as disposal and treatment, as
       well as "hidden" environmental costs; such as compliance, reporting, and
       monitoring.

6.      Establish cost standards for "hidden" environmental costs; such as compliance,
       reporting, and monitoring.

7.      Establish financial incentive programs to encourage pollution prevention
       practices.

8.      Enhance the awareness of, and benefits from, pollution prevention alternatives
       through effective technology transitioning.
                                  466

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 (The work described in this paper was not funded by the U.S. Environmental Protection
 Agency. The contents do not necessarily reflect the views of the Agency and no official
 endorsement should be inferred.)

            LOW VOC DUAL-CURE AEROSPACE TOPCOAT1
 Kevin E. Kinzer
 and
 Steven J. Keipert
 Corporate Research Laboratories
 3M Company
 3M Center 201-2N-19
 St Paul, MN  55144
 INTRODUCTION

      The U.S. Environmental Protection Agency, as well as state
 and local regulatory agencies are in the process of implementing
 increasingly stringent controls on the emission of volatile
 organic compounds (VOCs).   These emissions are the primary cause
 of  photochemical smog and ozone pollution.  Approximately seven
 billion pounds per year of VOCs are currently released to the
 atmosphere.  A significant portion of this total is the result of
 industrial painting and coating operations.  Mandated reductions
 in  VOC emissions have led to the development of low or no VOC
 coating formulations by the coatings industry.  Unfortunately,
 the reduced VOC content in these new formulations has often
 required a sacrifice in performance,  appearance, or ease of
 application.

      This paper describes development of the 3M dual-cure process
 for photocured high-performance coatings.  Dual-cure involves the
 simultaneous polymerization of two monomer types to produce a
 material consisting of two independent but interpenetrating
 polymer networks (IPNs) .   The properties of these IPNs are often
 superior to either component separately.  This novel cure
 technology  may allow significant reductions in VOC content while
 maintaining the current performance characteristics of the cured
 coatings.   Demonstration of the commercial feasibility of this
 technology is in progress  in our laboratory with the support of
 the U.S.  Department of Energy Office of Industrial Technologies
 under a cost-share contract.  Performance testing is being done
 in  collaboration with the  Boeing Defense & Space Group.
Aerospace topcoats have been selected for initial development
 efforts.   These protective coatings have very high requirements
 for performance,  appearance and durability.  The materials
currently in use are two-part polyurethanes which are spray
applied.   High resin viscosity requires the addition of a large
     xThis paper  was  prepared for the  U.S.  Department of Energy,
Assistant  Secretary for Conservation and Renewable Energy,  under
DOE field  office,  Albuquerque,  Contract No. DE-AC04-88ID12692.


                                467

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 amount  of  solvent  to  reach  sprayable viscosity.  The aerospace
 industry is under  increasing  regulatory pressure to find low-VOC
 alternatives  for these  coatings.  To achieve substantial VOC
 reductions without a  performance sacrifice has proven
 challenging.  A dual-cure system consisting of a two-part
 polyurethane  (polyol  +  isocyanate), combined with monomeric
 acrylates  is  being evaluated  as a possible low-VOC replacement
 for urethane  topcoats.  The low viscosity acrylate component
 reduces the solvent required, while enhancing the performance of
 the cured  film.  Our  goal is  to produce a sprayable coating which
 meets the high-VOC performance specifications,  but at a VOC
 content substantially lower than currently available
 alternatives.

      California has established upper limits for VOC emissions by
 aerospace topcoats at 420 grams/liter (  SCAQMD rule 1124 ) .
 Previous to these regulations, high performance polyurethane
 topcoats typically had VOC levels of 650 grams/liter.   It  is
 likely that the regulations currently in force  in California will
 eventually be adopted nationwide.   To date,  VOC compliant
 aerospace coatings have required some relaxation of the
 performance specifications established by the 650 g/1 materials.
 Low-VOC coatings often have poorer appearance,  are more difficult
 to apply and cure more slowly, and lack  the  chemical resistance
 of their high-VOC predecessors.   Current low-VOC coatings are
 also at or near the maximum VOC levels allowed  by current
 regulations.   Traditional high-solids solventborne coatings
 technologies  are unlikely to allow reduction much below current
 levels without an unacceptable decrease  in performance.


 DESCRIPTION OF THE  3M DUAL-CURE  PROCESS

      The basis of  the 3M dual-cure process is a novel
 photocatalyst  system which allows  light  activated curing of  a
 variety of  reactive monomers,  including  acrylates  as well as
 polyols  and isocyanates  to give  urethanes.   The catalyst is  an
 iron  complex which  can be decomposed to  release catalytically
 active  iron species upon exposure to visible or ultraviolet
 light.   The photocatalyst structure  and  photodecomposition
 mechanism are  illustrated in Figure  1.

     Dual-cure catalysts are unique  in their ability to
photopolymerize polyols  and  isocyanates  to produce polyurethane
 resins.  Previously, all of  the  known polyurethane catalysts  have
been thermally activated.  Light activation allows a degree  of
control  of  the polymerization  process not  possible using thermal
catalysts.  This characteristic  can  be utilized to provide a
practical method for the preparation of  IPN polymers.
                                468

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                                Fe+
                    Fe*
                                              Fc1
    FIGURE 1.
Chemical structure of the dual-cure photocatalyst
and photo-decomposition mechanism.
     An interpenetrating polymer network is  formed when two
 polymerization reactions,  both which produce crosslinked
 networks,  occur within the same space,  but there  is no chemical
 interaction between the two polymerization reactions.  This
 produces two enmeshed polymer networks,  both continuous
 throughout the entire solid,  but with neither network connected
 to the  other by any chemical bonds.   For example, in the system
 chosen  for aerospace applications,  the two polymer systems are a
 polyurethane and a polyacrylate.   The polyurethane is formed by
 an addition mechanism,  while the polyacrylate is  formed by a
 radical  mechanism.   The two polymerizations  occur simultaneously,
 but independently of each other.   The result is a solid composed
 of two  interpenetrating networks,  both continuous throughout the
 entire  solid,  but with no interconnections between the
 polyurethane and polyacrylate networks.

     Materials having IPN morphologies often exhibit unusual
 mechanical  properties.   We have found in the polyurethane /
 polyacrylate IPN system that these materials exhibit the best
 properties  of  their constituent parts.   For  example, the tensile
 property data  shown in Figure 2 is for an IPN composed of a
 strong but  brittle polyacrylate,  combined with a  soft urethane
 with good elongation properties.   The tensile properties of each
 component alone are shown for comparison.  It can be seen that
 the tensile strength of the IPN approaches that of the pure
 acrylate, while at  the same time maintaining most of the
 elongation  of  the pure urethane.   The combined effect produces a
material which is much tougher than  either individual component.
This is  shown  in the chart for energy to break, which is the
 integrated  area under the  stress / strain curve.
                               469

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             Elongation at Break
£ i5o
• 100

}50
i  o
u
Urclhane
 Urclhan*/
  AcrylaU

Composition
                         Acrylat*
                                     Ultimate Tensile Strength
                                                 Ursthsne
 Ursthans/
  Acrylals
Composition
AcrylaU
             2.5
           ?  2

           j':
           " 0.5
              0
                                Energy to Break
                                Uralhano/AcrylaU
                                 Composition
                                  Acrylal*
      FIGURE  2.
    Tensile properties  (elongation at  break,  strength
    at break, and energy at break) of  a polyurethane /
    polyacrylate IPN material.
   DEVELOPMENT OF DUAL-CURE  AEROSPACE TOPCOATS

        This enhancement of  tensile  properties led to consideration
   of polyurethane / polyacrylate  IPNs for aerospace applications
   which have very demanding requirements  for durability under a
   wide  range of conditions.  Several other criteria were
   established relating to requirements in the curing process.  Cure
   of the coatings must be activated with  visible light exposure.
   Ultraviolet lamps were not an option because of the strong UV
   absorption exhibited by many common pigments.   Fortunately, the
   dual-cure catalysts absorb weakly in the blue portion of the
   spectrum,  which allows good cure  of fairly thick pigmented films.
  Cure  must also occur in air at  ambient  temperatures.   Nitrogen
   inerting something as large as  an airliner is not practical, and
  the number of potential users having heated hangers is limited.
  Normally,  acrylate monomers do  not cure well in air due to
  inhibition of radical cure by oxygen.   In an IPN system,  however,
  we have  found that once the urethane cure has  progressed
  sufficiently,  oxygen permeability is reduced to the point that
  acrylate cure can occur.   Cure  has been demonstrated at
                                  470

-------
 temperatures as  low as  60°F, with no detrimental effects.  As in
 conventional polyurethane coatings,  complete  cure  is determined
 by the slow cure of the polyurethane,  and development of  final
 physical properties is  obtained  in approximately one week.  Due
 to rapid acrylate cure,  and the  ability  to use  catalyst levels
 that would give  unacceptably short potlife with conventional 2-
 part urethanes,  very short tack-free times are  possible.  Current
 formulations require a  15 to 30 minute flash  time  for solvent
 evaporation,  followed by a 10 to 15  minute light exposure, at
 which point the  cured coatings are generally  dry to touch.

      A series of aerospace topcoat screening  tests were selected
 with the assistance of  Boeing personnel.   These were taken from
 the Boeing commercial specification  BMS  10-60,  as well as
 military specification  MIL-C-83286.  Tests were chosen which were
 most critical to performance, and most difficult to meet
 simultaneously.   These  included  VOC content, reverse impact,
 hydraulic fluid  resistance (7 & 30 day),  60 degree gloss, low
 temperature flexibility,  water resistance,  salt spray corrosion
 resistance and pencil hardness.  Accelerated  weathering (500 hr.
 Xenon Weatherometer)  was later added due  to questions about the
 weatherability of  non-urethane components.

      This test series was used for the routine  screening of
 experimental  formulations.   Formulations  were tested over a VOC
 compliant water-reduced chromated primer  (350 g/1 VOC),  on
 appropriately prepared  aluminum substrates as detailed in the
 specifications.  All  initial screening was performed on samples
 containing titanium dioxide pigment  at levels sufficient to
 achieve  good hiding power.  Cure has also been  demonstrated with
 a variety of  other  colors.  Reds appear  to be the most difficult
 to  cure  due to competitive light absorption at  catalyst
 absorption wavelengths,  and cure speeds  are slowed somewhat.
 Initial  samples were  knife coated and cured with 15 minutes light
 exposure.   Testing  was  performed after allowing the samples to
age  for  7  days at room  temperature.

     The optimum formulation at this point consists primarily of
polyurethane precursors,  with a lesser amount of acrylate
monomers.   The acrylate present appears  to  improve low
 temperature and  impact performance,  as well as  reducing the
viscosity of  the formulation.  Current performance and
specification requirements in the screening tests of several
formulations are shown  in the table  on the  following page.
                               471

-------

Pencil Hardness
7 day Skydrol
30 day Skydrol
Reverse Impact
60° Gloss
500 hr weathering
Pot-life
Dry -time
Reference
Specification
BMS 10-60
MIL-C-83286
BMS 10-60
BMS 10-60
BMS 10-60
BMS 10-60
BMS 10-60
MIL-C-83286
Criterion
>2B
<2 pencil loss
>2B
80 in.-lb.
>90%
>70%
>4 hours
<2 hours
Dual -Cure
Performance
H
H{-0)
HB(-2)
45 in.-lb.
89%
77%
>4 hours
<1 hour
      During optimization of the dual-cure formulation,  the most
 serious problems encountered were in achieving high initial
 gloss,  and satisfactory weathering performance.   Low initial
 gloss was found to result from incomplete acrylate  cure at the
 surface of the coating due to inhibition by oxygen.   Stained
 transmission electron micrographs of film cross-sections showed
 depleted acrylate to a depth of several microns.  This  resulted
 in post-cure film shrinkage,  and surface roughening if  pigment
 was present.   This problem was solved through the addition of co-
 catalysts which improved surface cure of the acrylate.
 Weathering improvements were achieved through reformulation of
 the urethane components to more weatherable types,  and  the
 addition of U.V.  absorbers and light stabilizers.   This improved
 weathering performance at the expense of impact flexibility,
 which fell to below specified levels.  We are currently
 investigating methods to improve coating flexibility without
 sacrificing other performance properties.

      Estimated VOC levels for initial dual-cure topcoat
 formulations  are  in the 300 gram per liter range.   We are in the
 process  of optimizing solvent composition and flow  control
 additives  for spray application with high-volume, low-pressure
 (HVLP) spray  equipment.   Final formulations will  be evaluated in
 a  full set of qualification tests at a Boeing facility.
CONCLUSIONS

     The dual-cure process shows promise  for protective coating
applications requiring high levels  of performance. . The IPN
polymer structure which is formed can provide enhanced
performance, often exhibiting the best properties of each
component.  VOC levels substantially below  those obtainable with
                               472

-------
 conventional high-solids technologies appear possible.
 Performance levels are approaching those required for aerospace
 applications,  and further optimization of formulations is in
 progress.


 RELATED PUBLICATIONS

 M.C.  Palazzotto,  et al. ,  "Dual Cure Photocatalyst  Systems",  ACS
 1990 National Meeting, Washington DC, High Solids Symposium,  Paper
 No. 206,  August 30,  1990.

 M.C. Palazzotto, et al.,  "Dual Curable Compositions for High Solids
 Coatings",  First   North  American Research  Conference on  Organic
 Coating Science  and  Technology,   Hilton Head,  South  Carolina,
 December 3-7,  1990.

 S.J.  Keipert,   "Dual  Cure Photocatalyst  Systems for  Solventless
 Coating",   First    Annual   International   Workshop   on   Solvent
 Substitution,  Phoenix, Arizona,  December  4-9,  1990.

 S.J. Keipert, et al.,  "Dual Cure Solventless Coating Process,  Phase
 I  Final  Report",  Contract  No.  DE-AC04-88ID12692,  Report No.
 DOE/ID/12692-1  (DE92013677),  February,  1992.

 S.J. Keipert, et al.,  "Dual Cure Solventless Coating Process,  Phase
 II  Final  Report",  Contract   No.  DE-AC04-88ID12692,  Report No.
 DOE/ID/12692-2  (DE93001351),  October,  1992.

 D.W.  Osten, "Dual  Cure Solventless  Coating  Process,  Phase III
 Semiannual  Technical  Progress  Report",   Contract  No.   DE-AC04-
 88ID12692,  Report  No.  DOE/ID/12692-3  (DE98001352), October,  1992.

 S.J.  Keipert,   "Low VOC Photocurable Topcoat  for  the  Aerospace
 Industry",   Third  Annual  International  Workshop  on   Solvent
Substitution, Phoenix, Arizona,  December  8-11,  1992.

R.J. DeVoe, D.C. Lynch,  "Energy Curable Polyurethane Precursors",
U.S. Patent 4,740,577, 1988.
                                473

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474

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(The work described in this paper was not funded by the U.S. Environmental Protection
Agency. The contents do not necessarily reflect the views of the Agency and no official
endorsement should be inferred.)

              UV Pollution Prevention Technology in Can Manufacturing
    Erik T. Donhowe
    Coors Brewing Company
    Can Manufacturing
    17755 W. 32nd Avenue
    Golden, CO  80401
    INTRODUCTION

      Conventional printing operations, including those in metal decorative printing, utilize solvent
    based, or solvent-containing, ink and varnishes. As a result, conventional printing technologies
    produce significant VOC (volatile organic compound) and HAP (hazardous air pollutant)
    emissions. One newer technology, ultraviolet (UV) light initiated curing of coatings, has the
    potential to provide significantly lower air emissions. The Coors Brewing Company Can
    Manufacturing Plant has been utilizing this technology in full scale aluminum can production since
    1975. This report details the significant pollution prevention provided by this technology, and
    additional associated significant benefits in cost savings, energy conservation and practical
    operation.
    HISTORY

      The Coors Brewing Company developed the country's first aluminum beverage can, a two-
    piece aluminum can, in 1959, and was instrumental in the transfer of aluminum can production
    technology throughout the beverage can industry. The Coors Can Manufacturing Plant, located in
    Golden, Colorado, is the largest aluminum can manufacturing plant in the world, producing
    approximately 4 billion cans a year. The plant currently produces aluminum cans exclusively for
    the beer beverage market.

      Coors Can Manufacturing worked in partnerships with several companies in developing the
    UV curing technology for decorating aluminum cans. The initial push to convert to UV operation
    was motivated by a desire to increase can printing speeds and to reduce energy consumption, in
    addition to a desire to lower air emissions. In 1974, Fusions Systems Corporation and Coors
    developed UV oven equipment which could rapidly cure UV inks. These UV ovens were installed
    in full scale can production in 1975. Coors has worked with several chemical companies over the
    years in developing practical UV inks and over varnishes. These chemical vendors have included
    Borden, General Printing Ink, Akzo and Martinez Ink Company. The Coors plant is currently the
    only plant in the country using the UV technology.
                                             475

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TECHNOLOGY

   The UV curing technology is used to apply the decorative exterior label on aluminum beverage
cans. The printing process is a "wet on wet" application, in which a clear protective over varnish
is directly applied on top of colored inks prior to UV curing. The UV chemicals are approximately
100% solids in content, with essentially zero solvent contents.

   In the can printing process (Figure 1), colored UV inks are applied to printing plates; one plate
for each image color. A rubberized blanket wheel rotates, contacting the printing plates, picking
up each color in sequence. The end result is a complete color image on the blanket wheel  Formed
"silver bullet" aluminum cans are carried on mandrels, rotate over the blanket wheel, and are
coated with the color image. The cans are then immediately carried over an over varnish wheel,
where the clear protective over varnish is applied over the ink. The cans are then carried on chains
to vacuum belts, where they are transported to the UV oven. The vacuum belt supports the cans
in proper geometry for curing through the UV oven. The entire process is very rapid: printing
speeds are approximately 1600 to  1800 cans per minute, and the UV oven cures the coatings in
approximately 0.7 seconds.
        mandrel wheel

                  can faad
     transfer unit
blanket
segment
                                                         Ink plate
                                              overcoat unit

                                       - o/o application roBar
                          FIGURE 1. UV Can Printer

                                       476

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   The alternative, conventional, technology used in other can manufacturing plants utilizes
thermal curing of inks and over varnishes. The thermal curing ovens are natural gas fired,
operating at 350 F or higher in order to achieve the ink and over varnish curing. Thermal ovens
are approximately 60 to 80 feet long, 8 feet wide and 25 feet high A long pin chain,
approximately 400 feet long, is used the transport the cans through the oven. The large
dimensions of the thermal oven, and the long transport chain,  are required to provide the thermal
contact time and still achieve production rates of 1500 cans per minute or higher (1).

   The UV ovens, in comparison, are approximately 9  feet long, 5 feet wide and  5 feet high. The
ovens operate at about  110 F, warmed slightly above ambient temperature due to the heat
evolution from the UV lamps. Cans are transported to  and through the oven on a vacuum belt.
The UV oven contains between six and eight 10 inch, 300 watt/inch, microwave  energized
mercury lamps. The lamps are positioned with parabolic reflectors in a geometry  to focus
maximum illumination on the exterior surface of the aluminum cans. After an approximately 0.7
second exposure time, the cans leave the UV oven dry.

   The print quality of the UV technology process is an important consideration.  All cans
produced at the Coors Can Manufacturing Plant are now made with the UV process, and print
quality is comparable to that obtained with thermal curing. Similarly, color and gloss quality is
equivalent to that obtained from the thermal process. The over varnish is applied  in order to
provide a protective coating over the decorative label,  currently  the abrasion resistance of the
over varnish is dependent on the film thickness of the over varnish. For a fully commercial can
market, with markets including all beverage categories in addition to the beer beverage, more
technical development is needed to formulate a higher abrasion resistance. This should be
achievable with newer formulations of UV over varnish (2).

   The Coors Can Manufacturing Plant has in the past utilized a thermal technology can line side
by side with the main UV technology can lines. As a result, production operators have had  the
opportunity to evaluate practical operations of the UV technology in comparison to the
conventional technology. The UV ovens can be started up much faster that thermal ovens (only a
5 minute start up time is required). The controls for the UV ovens are simpler. The newer UV
ovens utilize vacuum can conveyance belts, which  are simpler, more reliable, and easier to
maintain than the long 400 foot pin chains which transport cans through hot thermal ovens. The
low operating temperature of the UV oven is also beneficial for front  line production operation
and maintenance.  Maintenance and parts costs for UV technology have been estimated to  be
significantly lower than requirements for thermal technology (Table 1).
                                          477

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                TABLE 1.  OPERATIONAL EFFICIENCY
               Oven Size

               Downtime

               Maintenance

               Parts

               Process Control

               Energy Use
    10% of Thermal

    Significantly Less

    22% of Thermal

    28% of Thermal

    Simpler

    55% of Thermal
  In conjunction with the higher operational efficiency of the UV process, there are associated
financial savings. An estimated cost analysis has been performed for chemical usage, power
consumption, natural gas usage and equipment maintenance costs (Table 2). Chemical costs are
currently approximately 5% higher for UV inks and over varnishes. Natural gas is not required
for UV ovens, therefore the UV technology provides an estimated savings of $50,000 per billion
cans produced. As previously mentioned, thermal ovens require more maintenance. Therefore, an
estimated $90,000 per billion cans savings is provided with UV technology.
                      TABLE 2. OPERATING COSTS
                            (S1000/BILLION CANS)
                   CHEMICALS

                  ELECTRICAL

                 NATURAL GAS


                 MAINTENANCE
 UV

1,076

  60
  40
THERMAL

    1,025

      57

      50


     130
                                     478

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   The total energy consumption requirements have been compared for the UV and thermal
technologies (Table 3). Estimates in units of millions of BTUs per billion cans are provided. The
estimates include both BTU values obtained directly from natural gas (thermal ovens) and BTU
values for the electrical power consumption Since no natural gas is used with UV ovens,
approximately 15,400 million BTUs are saved per billion cans. Both types of ovens require similar
levels of electrical power. Electrical power consumption is slightly higher for UV than for
thermal, due to the energy demands of the UV lamps, however the thermal ovens also require
comparable electrical power to run blowers and can chain conveyors.The net energy savings with
UV technology is estimated to be 14,880 million BTUs per billion cans produced.
                      TABLES. ENERGY SAVINGS
                            (MMBTU/BILLION CANS)
                             UVOVEN
          THERMAL     ENERGY
            OVEN      REDUCTION
               NATURAL GAS
               ELECTRICAL
10.500
            15,400
9.960
            15.400
-520
                                         TOTAL
                        14.MO
ENVIRONMENTAL IMPACT

   Over the past two years, a series of procedures have been conducted at the Can Manufacturing
Plant to estimate the environmental impact of the UV printing technology. The procedures ranged
from the laboratory analysis of ink and over varnish VOC contents to full EPA protocol stack
testing  This analysis has provided a comparison of the UV to the thermal conventional
technology.

   An initial estimate was made utilizing ASTM method 24 testing of the thermal and UV inks
and over varnishes. Method 24 is the approved method for determining VOC content in paints
                                       479

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 and other surface coatings. The method was modified to add UV curing prior to the gravimetric
 analysis in the procedure, in order to accurately reflect the UV initiated cross-linking of the inks
 and overcoats. Results were expressed in tons of VOCs per billion cans. The data (Table 4)
 indicates that the current generation of UV coating, UV acrylate, contains 1.68 tons of VOC per
 billion cans, which is substantially lower in VOC content that the current water based thermal
 coating, which contains 28.9 tons per billion cans. A newer UV coating product with potential
 production application contains an even lower VOC content of 0.22 tons per billion cans.
                TABLE 4.  COATING VOC CONTENT
                          (MODIFIED METHOD 24)
                                                       TONS/BILLION CANS
                        WATERS ASED
                                       W ACRYLATE
                                                        UVEFOXY
   An initial estimate of actual stack emissions was conducted on the UV oven exhaust from a can
line running at full production rates. The method used was EPA Method 18, a general method
allowing the use of various procedures for sampling and instrumental analysis. The conditions
chosen were charcoal tube absorption followed by solvent desorption and GC/MS analysis. Based
on the UV chemical formulations, specific target compounds were selected. The results of this
screening test (Table 5) indicated that target compounds were not detectable to the detection
limits of I ppb (w/v).  Corresponding emission calculations in tons/year of VOCs indicated that
emissions were less than 0.3 tons/year for each target, and a total less that 1.5  tons/year.
                                         480

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                       TABLE 5. VOC EMISSIONS ESTIMATE
                                (EPA METHOD 18 SCREEN)

                   COMPOUND           ug/L           TONS/YR
n-butanol
ethoxyethanol
o-xylene
ethoxy ethoxyethanol
benzophenone

< 5
< 5
< 5
< 5
< 5
TOTAL =
< 0.3
< 0.3
< 0.3
< 0.3
< 0.3
< 1.5
   Additional estimates of VOC emissions were obtained from Material Safety Data Sheet
(MSDS) data for the VOC content of each coating product (Table 6). Comparisons were made
for the over varnish (overcoat), ink and bottom varnish (bottom coat) applications. The
application of a varnish on the bottom of the cans was estimated for the UV process as a
conservative comparison, even though bottom coat is not applied currently in the UV process.
Very significant differences are evident between the thermal and UV processes with this estimate.
The VOC emissions are again based on a tons/billion cans basis, as this is the index generally used
for regulatory control. A total of 28.5 tons of VOCs are estimated to be released as VOCs with
the thermal process in comparison to a conservative maximum emission of 1.6 tons/billion cans
for the UV process.

   A similar comparison (Table 7) was made for hazardous air pollutants (HAPs). Almost half of
the VOC content in current thermal coatings are glycol ethers, which are listed hazardous air
pollutants in the new Clean Air Act regulations. It is pertinent, therefore, that, with upcoming
higher scrutiny and tighter controls for HAPs, a technology with lower HAP emissions will be
highly preferred. Estimated HAP emissions from the thermal technology are 14.3 tons/billion
cans, and estimates from MSDS data indicate that there are no HAP emissions at all for the UV
technology.
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TABLE 6. ESTIMATED VOC EMISSIONS
     (MSDS DATA - TONS/BILLION CANS)
             THERMAL      UV
OVERCOAT
INK
BOTTOM COAT
TOTAL
26.5
0.8
1.3
28.5
1.3
0.2
0.1
1.6
TABLE 7. ESTIMATED HAP EMISSIONS
       (MSDS DATA-TONS/BILLION CANS)
             THERMAL       UV
OVERCOAT
INK
BOTTOM COAT
TOTAL
13.2
0.4
0.7
14.3
0.0
0.0
0.0
0.0
               482

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   Proposed HAP regulations at the federal regulatory level, and current HAP regulations at the
state regulatory level, require emissions reporting at very low reporting thresholds. Current
OSHA standards stipulate MSDS reporting thresholds for chemicals at  1% and 0.1%
concentrations. This data was judged to be too inaccurate for appropriate HAP regulatory
reporting needs. Therefore, protocol testing was conducted on the UV process at the Coors Can
Manufacturing Plant. This detailed stack testing was conducted in order to fully comply with our
current state HAP reporting thresholds at SO and 100 pound/year levels The data from the
protocol stack testing (Table 8) indicated that extremely small levels of HAPs are emitted  The
compounds detected were suspected to be present in the UV chemicals as trace constituents. It is
important to note that only 360 pounds are emitted for the entire facility per year. The UV
technology is therefore essentially a zero HAP process.
                       TABLES.  HAP EMISSIONS
                             (PROTOCOL TESTING)
HAPS
MEK
XYLENES
METHANOL
TOLUENE
FORMALDEHYDE
TOTAL
LB/YR*
67.3
429
72.1
124.7
53.4
360.4
                                               " Enbre F«c*»y
   The Coors Can Manufacturing Plant implemented the UV printing technology in 1975, and the
plant is the only can manufacturing plant using this technology. If the conversion had not taken
place in 1975, significant emissions of VOCs and HAPs would have occurred. The
implementation of the UV operation has thus had a very significant pollution prevention effect.
The magnitude of this is depicted in Figure 1. The upper part of the chart is the potential
emissions from a thermal process; the small lower area of the chart depicts the worst case
estimate for UV technology emissions.
                                        483

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    Approximately 80 to 100 tons of VOCs would have been emitted each year since 1975. The
 sum of these savings in potential emissions is 1,640 tons of VOCs. This comparison is
 conservative, since it is based on VOC contents of current UV and current thermal coatings, and
 earlier thermal coatings were much higher in solvent content.
          FIGURE 2.  CUMULATIVE VOC REDUCTIONS
              VOC* (TONS)
              140
              120

              100

              W

              60

              40

              20
               0
               1975
                     1977
                           1979   1961   1963   1965   1967   1969   1991
                                   IUV 0 THERMAL
   In addition to VOC and HAP emissions, CO2 emission estimates were compared for the two
technologies. The CO2 estimates are calculated from EPA conversion factors for natural gas
combustion, and also for CO2 emission factors for electrical power production. The CO2
estimates for the UV technology therefore include the CO2  emissions which occur at the power
plant generating the electrical power used for the UV process. The annual emissions savings at the
Coors Can Manufacturing Plant due to the UV technology are currently estimated to be 107.6
tons of VOCs, 57.0 tons of HAPs, and 4,216 tons of CO2

   If the UV technology were transferred nationally, there would be subsequent notable pollution
prevention impacts. Estimates for a national technology impact have been calculated by
comparing the annual production of approximately 4 billion  cans/year at the Coors Can
Manufacturing Plant to the national production rate. The national production of aluminum
beverage cans is approximately 100 billion cans/year (3).

   Pollution prevention estimates (Table 10) are 2,690 tons/year of VOCs,  1,425  tons/year of
HAPs, and 105,400 tons/year of CO2 emissions. These impacts are even more substantial taking
into account the regional clustering of can manufacturing plants in several states. The
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implementation of UV technology could therefore have a significant regional pollution prevention
impact.
                   TABLE 9. EMISSIONS SUMMARY
                            ENTIRE FACILITY - TONS/YR
                    VOC
                    HAP
                    CO2
                                                    ANNUAL
                            ACTUAL (UV>    THERMAL    REDUCTIONS
  6.4
  0.2
 4200
 114.0
 57.2
 8416
 107.1
                                                      17.0
 4210
                  TABLE 10.  EMISSIONS SUMMARY
                          NATIONAL POTENTIAL • TONS/YR
                                                    ANNUAL
                            ACTUAL (UV>    THERMAL    REDUCTIONS
                   VOC
                   HAP
                   CO2
 160
105,000
 2850
            1430
210.000
             1426
106,400
                                     485

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SUMMARY

   The UV curing technology in use at the Coors Can Manufacturing Plant has been a proven
technology for the past 18 years. Very substantial benefits are evident with this technology in very
low, or zero, VOC and HAP emissions, and much lower CC>2 emissions as compared to the
alternative thermal curing technology. Estimates also indicate that the UV technology consumes
less energy than the thermal technology, and that the UV technology is operationally more cost
effective than the alternative technology. The UV technology at the Coors plant is currently
dedicated  to a beer beverage market, and can product quality is fully acceptable for this market. A
higher abrasion resistance can coating is currently desired for other beverage markets. Therefore
newer generation UV over varnishes with higher abrasion resistance ratings may have to be
investigated or implemented in order to fully convert this technology. In light of the significant
pollution prevention effects from this technology, and more stringent upcoming air regulations, it
would seem to be desirable to overcome these remaining minor obstacles.
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                                 REFERENCES




1. Crabtrce, T.A. RadTech '88 North America, pp. 231-239. 1988.




2. Milton-Thompson, A. RadTech Report Vol 7 (2). pp. 18-23  1993.




3. Beverage World's Periscope. Vol 112(1538). p. 17. 1993
                                     487

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488

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POLLUTION PREVENTION OPPORTUNITIES
                IN THE
MANUFACTURE OF PAINT AND COATINGS
                  BY
             Paul M. Randall
    US. Environmental Protection Agency
     Office of Research & Development
    Risk Reduction Engineering Laboratory
    Pollution Prevention Research Branch
     26 West Martin Luther King Drive
          Cincinnati, Ohio 45268
             (513) 569-7673
           FAX: (513) 569-7549
                  489

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  Abstract

        The paints and coatings industry is rapidly changing to meet environmental and
  economic pressures.  Some of the changes include new coating formulations, higher
  performance finishes with improved properties, continued development of new technologies,
  and new application methods with improved transfer efficiencies.  In order to control costs,
  improve productivity and quality, and protect the environment, more paint companies are
  turning to pollution prevention as the cornerstone of their waste management programs.  Paint
  pollution prevention has been incorporated into many corporate total quality management
  (TQM) strategies.

        There are many pollution prevention methods for the paint manufacturing industry
  which vary  from very simple, inexpensive measures to new, expensive plant/equipment.  The
  methods, techniques or programs can generally be classified as either recycling or source
  reduction and may involve material substitution, process or equipment modification, revised
  operating practices, operating procedures (such as waste stream segregation), personnel
  practices (such  as operator training), loss prevention practices, or accounting practices. This
  paper will provide an overview of these practices in-place at particular manufacturing
  facilities to reduce wastes and associated costs, to be a more competitive industry that must
 still maintain quality and performance of its products.

        The information in this article has not been subjected to Agency review.  Therefore, it
 does not necessarily reflect the views of the Agency.

 Introduction

        The role of the paint and coatings industry in the U.S. economy is pervasive. Paint
 and coatings are essential not only for the decoration and  protection of the surfaces of many
 new industrial products but also for the maintenance of existing structures and products, such
 as homes, vehicles, machinery and equipment, buildings and factories. Without these paint
 and coatings, many of our durable and non-durable goods would have a decreased life-span.

       The manufacture of paints and coatings  is big business with shipments exceeding
 $115 billion (1989) in the U.S. alone. Americans consume approximately 1 billion gallons
 annually, of which, approximately 50 percent is represented by architectural coatings. The
 annual growth rate for the industry is expected  to be 1 percent (1991-1995).  The product
 coatings area accounts for about 36% of (1991) shipments and special  purpose coatings with
 16% of 1991 shipments. The nine industries  that are major consumers of paint and coatings
 include: (1) automotive;  (2) trucks/buses; (3) metal cans; (4) farm machinery/equipment; (5)
 construction machinery; (6) coil coating; (7) wood furniture/fixtures; (8) metal
 furniture/fixtures and; (9) household appliances.

       The driving forces behind the changes in paints and coatings continue to be product
performance improvements and environmental regulations  associated with new materials.

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 Paint and coating formulators as well as upstream raw material and resin suppliers are
 evaluating the components in their products and processes, changing the constituents to
 achieve desired performance of their coatings while also meeting new environmental rules.
 Paint producers undertake their own product research and development but also look to
 technological leaders to meet reformulation needs.

        In addition to addressing product reformulation impacts, paint and coatings
 manufacturers are also examining their production methods to look for ways to control costs.
 To achieve improved productivity and quality, as well as protect the  environment, more paint
 companies are turning to pollution prevention as the cornerstone of their waste management
 programs. Pollution prevention methods generally involve material substitution, process or
 equipment modification, modified operating practices and procedures (such as waste stream
 segregation), personnel practices (such as operator training), loss prevention practices or
 accounting practices. This paper will provide an overview of the paint industry's efforts to
 reduce wastes and reduce costs, while at the same time provide quality paint and coatings
 products which meet the performance requirements of a diverse customer base.

 Review of Raw Materials

        The primary raw materials used by the paint and coatings industry include resins,
 pigments, solvents and additives.  In the production of liquid paints (latex and solvent-based),
 production methods are primarily physical, that is, there are no chemical reactions or
 conversions of raw materials to other products and byproducts. Paint is typically a dispersion
 of a finely divided pigment in a liquid composed of a resin or binder and a liquid vehicle.

        There is a wide variety of synthetic resins used in coatings (i.e. acrylic, alkyd, vinyl,
 epoxy,  polyester, urethane, etc). The synthetic resins are long chain  polymers that may be
 linear, branched, or cross-linked or some combination of these forms depending on the
 functionality and reactivity of the monomers from thick they  are formed. Resins are selected
 based on many factors but primarily on application and performance.

       The liquid portion varies depending on whether the paint is solvent based or water-
 based.  Typical organic solvents include methyl ethyl ketone, methyl isobutyl ketone, toluene,
 and xylene.  Water based, water dispersed, or water soluble coating systems substitute water
 for some or all of the volatile organic solvent.

Manufacturing Process Wastes

       In the manufacture of paint and coatings, paint manufacturing facilities generate
different waste streams.  Typical wastes include:

e      Raw material packages, bags, containers from unloading materials into mixing vessels.

o      Pigment dusts from unloading of pigments into mixing vessels
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  o     Solvent emissions from storage tanks, leaks, and open process equipment

  o     Off-spec paints

  o     Spills

  «     Rinse water from equipment cleaning using water or caustic solutions

  o     Paint sludge from equipment cleaning operations

  o     Filter cartridges with uhdispersed pigment, paint and/or resins.

        Paint industries handle this waste by either on-site recycling, off-site recycling or
  treatment/disposal.  On-site recycling involves the selected reuse of raw materials or wash
  materials in new batches of paints and coatings.  Recycling of usable materials within the
  plant reduces the amount of new virgin raw materials needed per batch, resulting in
  significant reductions in operating aw well  as waste management costs. On-site recycling of
  solvents may include  distillations.  Many companies send their wastes to an off-site recycler,
  though more and more of these companies  are recycling their own wastes to reduce costs and
 improve operating efficiencies. Treatment/disposal operations available to paint
 manufacturers include incineration or land disposal.  Typically, many paint manufacturers
 send solvent-containing wastes off-site to a  cement kiln for inclusion in a fuels-blending
 program (for thermal  destruction).

       Of the wastes generated in a typical  paint manufacturing facility, equipment cleaning
 wastes are by far the largest in volume, collectively accounting for some 80% of the
 industry's wastes. Process equipment and tanks are routinely cleaned to prevent product
 contamination and/or restore operation efficiency.  Equipment that may need cleaning include
 high speed dispersion  mixers, sand mills, colloid mills, rotary batch mixers and blenders,
 drum mixers and roller,  grinding equipment, mixing vessels, pumps & motors, filters and
 strainers, filling and capping equipment and packaging equipment.  Many paint manufacturers
 are rinding pollution prevention provides significant opportunities for reducing wastes.

 Pollution Prevention Methods for the Paint Manufacturing Industry

       Pollution prevention, or the method of preventing polluting through source reduction
and recycling, is becoming a cornerstone of most progressive waste management programs.
Reducing wastes to remain competitive has  been an important ingredient for successful
business in the past and it will  be absolutely essential in the future. So controlling and
optimizing all parts of the manufacturing process is critical to reduce costs, improve processes
and continue to be competitive and profitable.


      Pollution prevention approaches can  be broken down into the following categories:

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        o     Source reduction • Good manufacturing practices, production process changes,
               and input material changes.

        o     Recycling - use and reuse of wastes, reclamation (on-site, off-site recovery).

        Good manufacturing practices generally means better procedural or institutional
 policies  and practices and can include waste segregation, personnel/employee practices,
 procedural measures, loss prevention practices, and accounting practices.  Personnel practices
 can include upper management initiatives, employee training, and/or employee incentives.
 Careful attention to production and maintenance operations is important to reduce spills and
 minimize off-spec products. Making employees more aware of the impact of waste on the
 company's costs as well as the impact on the environment.

        Procedural measures can include better documentation, better material and handling
 storage,  material tracking and inventory control and better production scheduling techniques.
 For example, since thousands of different paint formulations  require special production runs,
 more effective planning and production scheduling may be needed. Paint production,
 although a vital  phase, must intermesh smoothly with purchasing, formulation sales,
 accounting, inventory, personnel management etc. to make it profitable.  Production planning
 and scheduling may consist of a scheduling board listing the  batches to be run on each piece
 of equipment and the expected starting and finishing times.  It aids maintaining adequate
 inventory of active raw materials without overstocking and permits attainment of delivery of
 commitments to customers.  Also, if practiced effectively, it helps level peaks and slumps  in
 production during surges of short delivery orders or establish "downtime" of each piece of
 equipment while keeping check of overall efficiency and ensuring maximum equipment
 utilization.

        In loss prevention practices, better awareness of spill prevention and in house
 preventive maintenance programs may be required. Accounting practices should incorporated
 better apportionment of waste management costs to the departments that  generate wastes.

        Most off-spec paint is generated by small shops that produce specialty paints.  Since
 the production costs for specialty paints are typically high, most off-spec paints are reworked
 into marketable products. However, the cost of reworking off-spec paints are avoided if
 better trained and supervised operators as  well as quality control are reinforced so that
 generation of off-spec paints are avoided.

        Obsolete paint products and customer returns can be blended into new batches of
 paint.  Obsolete products result from changes in customer demands, new superior products,
 and expired shelf life. Careful production planning and inventory  control can reduce
obsolescence resulting from expired shelf life. Also marketing policies such as discounting
older paints can help reduce the amount of obsolete products.

       There are many  other ways of applying good manufacturing and operating practices.

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  For example, soliciting employee suggestions may uncover methods to make changes
  especially since the operators understand the process operations.  Quality improvement teams
  make significant improvements to the quality of the product, optimize the process, improve
  efficiency and productivity, and reduce the wastes in the process. Furthermore, incentives,
  rewards, and bonuses can be used to support pollution prevention programs and reduce
  wastes.

        Improving the efficiency of a process can significantly reduce waste generation.
  Available techniques range from eliminating leaks from process equipment to installing state
  of the art production equipment.  This  pollution prevention category includes improved
  operation and maintenance, procedural  changes, and equipment modifications.

        Equipment cleaning wastes represents the largest source of waste in a typcial paint
  plant. A method that reduces the need or frequency of tank cleaning or allow for reuse of the
  cleaning solutions is the most effective way to reduce wastes.

        The use of mechanical techniques, such as rubber wipers, reduces the amount of paint
  left on the tank walls of a mix tank.  Wipers are used to scrape the sides of a cylindrical mix
  tank (flat or conical).  Equipment cleaning is usually a manual operation so this process may
  be justified based on rescued labor costs as well as reduced usage of cleaning solution
  (another savings).  High pressure spray heads and limiting wash/rinse time systems can be
  used in place of regular hoses to clean water-based paint tanks. Studies show that high
 pressure wash systems can reduce water use by as much as 80 to 90 percent.

        Teflon  line tanks are sometimes used to reduce wall adhesion and improve drainage.
 This method is usually applicable to small batch tanks. A plastic or foam "pig" is used to
 clean pipes. This pig device is forced through the pipe from the mixing tanks to the filling
 locations, using nitrogen or some other  inert gas to propel the pig.

        Manufacturing procedures may be improved. For example, a paint facility's wash
 solvent from each solvent-based paint batch may-be separately collected and stored. When
 the same type of paint is to be made, waste solvent from the previous batch is recycled and
 used  in place of virgin solvent.

       Countercurrent rinsing processes can be applied to those plants with sufficient tanks
 space.  This technique is used to recycle "dirty" solution initially to clean tanks and then is
 followed by a "clean" solution to complete the rinse cycle.  The level of contamination builds
 up more slowly with the clean solution than the dirty reused solution  thus extending cleaning
 solution life.

       Spills due to accidental or inadvertent discharges usually occur during transfer
 operations or as a result of equipment failure. For example, during a loading operation, a
spill may occur from a leaking fill hose or fill line connection or leaking valves, piping, and
pumps. Sometimes spills occur from overfilling of tanks or due to improper or

                                          494

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 malfunctioning overflow alarms.  Improving regular equipment inspections and training
 programs prevent these spills from occurring as well as improved instrumentation and
 automation and efficient cleanup  methods if spills do occur.

        Small amount of dry materials used in paint may remain in bags.  Capturing the
 pigments for reuse through vapor traps helps reduce waste problems. The availability of
 these materials in slurry or paste  form eliminate problems of disposing of waste bags or
 packages.  Empty containers of liquid raw materials that contain  hazardous compounds are
 typically cleaned or recycled back to the original raw materials manufacturers or to a local
 drum recycler.  This avoids the costs of disposing of the containers.

        There are two major types of air emissions in paint manufacturing plants: VOCs and
 particuiates. VOCs may be emitted from the conservation vents on top of the bulk storage
 tanks of resins and solvents and from the use of open processing equipment such as mix
 tanks.  Since most process equipment is of open design, reducing VOCs from equipment
 could require substantial capital expenditure  in retrofit costs. Closed vessels with overhead
 refrigerated condensers will require considerable capital requirements which most paint
 manufacturers cannot afford. In fixed roof design, maintained  conservation vents, conversion
 to floating roof, use of nitrogen blanketing to suppress  emissions or the use of refrigerated
 condensers.  Implementing these options can result in cost savings to the paint and reduced
 raw material losses.

        Dusts generated during handling, grinding, and mixing of pigments may be hazardous
 and therefore dust collection equipment such as hoods,  exhaust fans, and bag houses are used.
 Use of pigments in paste form instead of dry will reduce or eliminate dust generated from
 pigments.  The drums can be recycled.
                                                           i
       Also, a major advance in paint manufacturing is the growing use of electronic control
 devices and batch automation.  The intent is to avoid operational accidents, improve quality,
 and  production efficiency, and the overall accuracy of the batch.  The effect should be less
 waste generated. Computer use is increasingly being used for materials allocation  and
 inventory control as well as preventive maintenance scheduling. As the costs associated with
 plant automation equipment decreases, the use of automation in paint manufacturing facilities
 will  increase.

 Case Studies

       Four companies that have  received special recognition for their pollution prevention
 programs by industry are Moline  Paint Manufacturing co. in Moline, IL, Vanex Color, Inc. in
 Mt. Vernon,  IL, Red Spot Paint & Varnish Co. in Evansville, IN, and Jamestown Paint
 Company in  Jamestown, PA. Moline reported a 50% reduction of hazardous wastes in less
than five years and reported savings of over  $140,000/yr in disposal and raw materials costs.
 Moline's program  included on site recovery for reuse, process modifications, statistical
process control techniques of waste generation, improved housekeeping, employee

                                         495

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  participation, and reuse of hazardous wastes off-site in a waste-to-energy recovery program.

         Vanex Co. used source reduction and recycling methods.  Ethylene glycol, a  free-
  thaw stabilizer in latex paints, has been replaced with propylene glycol which exhibits less
  health concerns.  Wash solvents generated from the production of solvent-based paints is
  recycled, when possible, into subsequent solvent-based paint batches. Unusable wash solvent
  was sent to a cement kiln. Approximately 80% of all wash solvent was recycled in-house
  resulting in savings of $15,000/yr.

         Red Spot Paint & Varnish Co. initiated a full waste-tracking system to identify the
  exact point of origin of each unit process waste, which was then sampled and analyzed to
  determine its potential for recycling and reuse. The program concentrated on motivating
  employees to  become more waste conscious  and to train them in waste reduction methods and
  procedures. Through their program, the company saved more than $1 million by incorporating
  a number of seemingly insignificant equipment additions and a few equipment and tool
  modifications, which represented over 60% savings.

        Jamestown Paint Company incorporated pollution prevention into their total quality
  management (TQM) program by focusing on waste minimization, quality control, customer
 satisfaction and increased profitability.  Employees drawn from various operational and
 administrative areas formed process improvement teams, and each team was given specific
 objectives and charged with clearly defined improvement goals.  Results a  year after
 implementation of the program showed a reduction in hazardous waste by more than 75% and
 savings  in excess of $100,000.

 Pollution Prevention Techniques Applicable to Paint Manufacturing

       The following summarizes some of the pollution prevention techniques paint
 manufacturers are using:

 Source Reduction

 o     Schedule compatible solvents in sequence to reduce truck loading and drum flushing
       need.

 o     Schedule like colors through equipment.

o     Install dedicated lines where feasible to reduce flushing.

0      Segregate line and pump flushings to produce low-grade thinners suitable for cleaning
       purposes.

0      Equip bulk storage tanks with vapor return lines.

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 0      Install collector to remove pigment dust from manufacturing area.

 «      Increase drum inventories of high volume products to reduce changing of products in
        the drumming line.

 o      Replace wastewater treatment lagoons with new system incorporating concrete cells
        covered by fiberglass dome, equipped with venting of off-gases to destruction by
        burning.

 °      Eliminate dry bags by converting to titanium dioxide slurry system pumped directly to
        mixer.

 °      Install closed filtration systems to reduce VOC emissions (losses); also closed filter
        systems can eliminate residues once left in filter bags.

 0      Install odor/vapor capture systems on bulk solvent storage tanks, resin tanks and
        manufacturing tanks.

 o      Eliminate all obsolete materials for possible rework.

 Reuse/Recycling in manufacturing process

 o      Recycle wash solvent whenever possible; to facilitate recycling, setup holding tanks
        for recovered washwater and wash solvent, segregate by color and/or product line;
        reuse wash  solvents from one batch in the grind state of the next batch of the same
        formula.

«      Collect pigment dust and recycle into batches.

o      Reuse in batch production solvents used for cleaning sand mills, manufacturing tanks,
       and tankwagons.

«      Reuse obsolete materials in present production.

o      Use virgin solvent for tankwagon cleaning and reuse in subsequent production.

o      Pass vapors  generated during filling and manufacturing through filters to remove as
       much VOCs as possible; collect solvent that would otherwise have gone to atmosphere
       and use as wash solvent

o      Where possible, mix obsolete  colors and sell as undercoat or primer.

o      Accumulate  all  skids not usable at plant and give to skid vendor.


                                          497

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  e     Recycle used motor oil from company vehicles.

  o     Reuse cardboard shipping cartons and plastic pails; return corner boards on can
        shipments to supplier.

  o     Unrecyclable wash solvents can be used as supplemental fuel in cement kilns for
        energy recovery; establish contracts with cement kilns for recycling of unusable wastes
        with high BTU value.

  o     Inspect, repair, and reuse shipping pallets received with the purchase of raw materials
        or return to vendor.

  o     Rinse and crush  metal containers and ship to scrap metal recycler.

  °     Recondition and recycle drums and five-gallon pails for use.

 Conclusions

        The paints and coatings industry will continue to seek Dew technologies to meet the
 growing needs and demands of our society.  While there has been significant progress in the
 industry to reduce or eliminate waste, manufacturers of all coatings recognize that new
 environmental regulations may seek to significantly reduce their wastes even further.  As a
 result, paint manufacturers will increasingly turn to pollution prevention techniques and
 methods to eliminate waste generation. Already, pollution prevention methods  are making
 significant contributions to reduce paint wastes/sludges  through source reduction,
 process/production techniques, good manufacturing practices, and material substitutions. The
 coatings industry's efforts  will be important towards improving environmental quality. Many
 of the pollution prevention techniques developed by the paint industry are relatively simple
 and inexpensive and may only require a conscious change in operating procedures. Some
 changes such  as new plant/equipment require greater monetary expenditures up front, but in
 the long run, may provide  the company with significant cost savings and improved
 environmental quality.

       Conclusions in this article are those of the author.  No official support for these
conclusions by the U.S. EPA is intended or should be inferred.
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For Further information

      There are many pollution prevention methods which have been published in various
literature or can be obtained through industry contacts. For further information, please
contact:

o     Paul Randall
      U.S. Environmental Protection Agency
      Office of Research & Development
      Risk Reduction Engineering Laboratory
      26 W. Martin Luther King Drive
      Cincinnati, Ohio  45268
      Ph. No. 513/569-7673
      FAX    513/569-7549
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                                  APPENDIX A

                                 REGISTRANTS
                   POLLUTION  PREVENTION CONFERENCE ON
                  LOW- AND NO-VOC COATING TECHNOLOGIES
            May 25  - 27,  1993          San Diego, California
 Kamal Abdelmissih
 Chemist
 Lockheed Advanced Development
 Company
 1011 Lockheed Way
 Palmdale, CA 93599-3731
 (805)572-4351
 Fax (805) 572-4315

 Carl Adams
 Logistics Management Specialist
 U.S. Navy
 Joint Depot Maintenance Analysis Group
 1080 Hamilton Street
 Dayton,  OH  45444-5370
 (513) 296-8295
 Fax (513) 296-8257

 Lorenzo Alejandria
Associate Air Pollution Control Engineer
 San Diego Air Pollution Control
 District
9150 Chesapeake Drive
 San Diego, CA 92123
(619) 694-3335
Fax (619) 694-2730

Rick Almen
Chemical Tech
Coors Brewing Company
 17555 West 32nd Avenue (CC290)
Golden, CO  80401
(303) 277-5024
Fax (303) 277-6670

Diane  Altsman
Environmental Scientist
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, GA  30365
(404) 347-2864
Fax (404) 347-2130
Dr. Padmini de Alwis
Director
National Aquatic Resources Agency
NARA, Crow Island, Colombo 15.
Sri Lanka
09 94 522009
Fax 09 94 1 522699

Dr. C. William Anderson
Director of Research
Marine Environmental Research
P. O. Box 2013
105 North 10th Street
Morehead City, NC 28557
(919) 726-4544
Fax (919) 726-9998

William F. Anspach
Materials Engineer
Wright Laboratory/Materials
Directorate
WL/MLBT
Building 654
2941 P Street
Suite 1
Wright-Patterson AFB, OH  45433-7750
(513)255-9035
Fax (513) 255-9019

Anne Arnold
Environmental Engineer
U.S. Environmental Protection Agency
JFK Federal Building
Boston, MA  02203
(617) 565-3254
Fax (617) 565-4939  .
                                   A-l

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 Jacqueline Ayer
 Manager, Engineering Operations
 Acurex Environmental Corporation
 Southwest Regional Offices
 4883 East La Palma
 Suite 505
 Anaheim, CA 92807
 (714) 970-5290
 Fax (714) 970-5396

 Brent A. Backus
 Air Quality Specialist
 Ventura County Air Pollution Control
 District
 702 County Square Drive
 Ventura, CA 93003
 (805)645-1428
 Fax (805) 645-1444

 Richard A. Benson (MS F643)
 Program Manager
 Los Alamos National Laboratory
 P. O. Box  1663
 Los Alamos, NM  87545
 (505) 665-3847
 Fax (505) 667-8873

 Dr. Elizabeth S. Herman
 Principal Paint Chemist
 Naval Aviation Depot/Aimed a CA
 Code 0542
 Building 7
 Port Hueneme, CA  94501
 (510) 263-7179
 Fax (510)  263-7180

 Kathie J. Beverly
Environmental Engineer
Naval Aviation Depot
Code 672
Naval Air  Station
North Island
San Diego, CA 92135-5112
(619) 545-4405
Fax Not Given
 Julia A. Billington
 Air Pollution Specialist
 California Air Resources Board
 2020 L Street
 Sacramento, C A  95814
 (916) 327-0650
 Fax  (916) 327-7212

 Tad  Bixler
 Air Quality Engineer
 Santa Barbara County Air Pollution
 Control District
 26 Castilian Drive, #B-23
 Goleta, CA 93117
 (805) 961-8800
 Fax (805) 961-8801

 Dennis Bollenbach
 Group Business Manager - Coatings
 SC Johnson Polymer
 1525 Howe Street
 Racine, WI 53403-5011
 (414) 631-4751
 Fax (414) 631-4079

 Gene Bossie
 SUPSHIP San Diego
 1385 Caliente Loop
 Chula Vista, CA  91910
 (619) 556-3367
 Fax not given

 Larry Breeding
 Manager, Environmental Affairs
 The Walt Disney Company
 500 South Buena  Vista Street
 Burbank,  CA 91521
 (818) 549-2330
 Fax (818) 549-2399

 Louis J. Brothers
 Product Manager
 Quaker Chemical Corporation
 Elm and Lee Streets
Conshohcken, PA 19428
 (215) 832-4223
 Fax (215) 832-4497
                                       A-2

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Angela M. Brown (MS 82-32)
Boeing Defense & Space Group
P. O. Box 3999
Seattle, WA  98124
(206) 773-2647
Fax (206) 773-4946

Larry W. Brown
Staff Engineer
Hughes Missile Systems Company
P.O. Box 11337
Building 801-18
Tucson, AZ  85734
(602) 794-7554
Fax (602) 794-7850

Richard H. Buchi
U.S. Air Force
Ogden Air Logistics Center
Science Engineering Laboratory
00-ALC/TIELM
7278 4th Street
HillAFB, UT  84056-5205
(801) 775-2992
Fax (801) 775-2628

Alan Buckley
Environmental Engineer
Massachusetts Office of Technical
Assistance
100 Cambridge Street
Room 2109
Boston,  MA  02202
(612) 727-3260, Ext 662
Fax (617) 727-2754

Dan Buell
Environmental Engineer
National Steel  & Shipbuilding Company
P. O. Box 85278
San Diego, CA  92186-5278
(619) 544-8764
Fax (619) 544-3542
Tom J. Burke
Manager, Paints and Coating Technology
FMC, Corporate Technology Center
1205 Coleman Avenue
Santa Clara, CA 95052
(408) 289-3820
Fax (408) 289-4429

Dr. Colin Butler
Alcan International Limited
Southam Road, Banbury
Oxon, England OX 167SP
Telephone (0295) 272626
Telex:  837601
Fax (0295) 274216

Mary-Jo Caldwell
Midwest Research Institute
401 Harrison Oaks Boulevard
Suite 350
Gary, NC  27513
(919)677-0249,  Ext 5141
Fax (919) 677-0065

Michael J. Callahan
Project Engineer
Safety-Kleen Corporation
777 Big Timber  Road
Elgin, IL 60123
(708) 697-8460
Fax (708) 697-4295

Gerald Ceasor
Research Associate
BP Research
4440 Warrensville Road
Cleveland, OH 44128
(216)581-5311
Fax (216) 581-5406

Carole Cenci
Permit Engineer
Minnesota Pollution Control Agency
520 Lafayette Road
StPaul, MN  55155
(612) 296-7554
Fax (612) 297-7709
                                       A-3

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 Paul Chad
 Associate Engineer
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA  92123-1095
 (619) 694-3606
 Fax (619) 694-2730

 David Chen, Project Engineer
 Berlin Company, Ltd.
 43 Ta -Yen South Road
 Koahctung, Taiwan
 886-7-871-1101
 Fax 886-7-871-6583

 Wen Yuan Chen
 Project Engineer
 Berlin Company, Ltd.
 43 Ta -Yeh South Road
 Koahctung, Taiwan
 886-7-871-1101
 Fax 886-7-871-6583

 Frank W. Childs
 Senior Program Specialist
 EG & G Idaho, Inc.
 P. O. Box 1625
 Idaho Falls, ID  83415
 (208) 526-9512
 Fax (208) 526-8883

 James A. Claar
 Senior Research Associate
 PPG Industries Research Center
 P. O. Box 9
 Rosanna  Drive
 Allison Park, PA  15101
 (412) 492-5310
 Fax (412) 492-5522

 Robert H. Colby, Director
 Chattanooga-Hamilton County
Air Pollution Control Bureau
 3511 Rossville Boulevard
Chattanooga, TN  37407
(615) 867-4321
Fax (615) 867-4348
 Gabriel A. Constantino
 Senior Environmental Specialist II
 Department of Environment & Natural
 Resources, National Capital Region
 100 EL-AL Building
 Quezon Avenue
 Quezon City, Philippines
 632-96-12-89 or 632-731-7731
 Fax 632-922-6991 or 632-731-7346

 Kevin Contreras
 Air Quality Inspector III
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA 92123-1095
 (619) 495-5515
 Fax (619) 694-2730

 John E. Cooper
 Customer Technology Representative
 Southern California Edison
 403 East 4th Street
 Perns, CA 92570
 (909) 940-8539
 Fax (909) 940-8527

 E. Rick Copeland, Market Manager
 Union Carbide Corporation
 Unicarb Group®
 3200-3300 Kanawha TPK
 Building 740, Room 5126
 Charleston, WV  25303
 (304) 747-5296
 Fax (304) 747-4886

 Philip Coscia
 RCI
 881 Ash Avenue
Gustine, CA  95322
Phone/Fax (209) 854-6352

Laura Costello
Product Manager
Porter  International
400 South 13th Street
Louisville, KY 40203
(502)588-9714
Fax (502) 588-9698
                                 A-4

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Stan Cowen  .
Air Pollution Control Engineer
Ventura County Air Pollution Control
District
702 County Square Drive
Ventura, CA 93003
(805) 645-1408
Fax (805) 645-1444

Kim Cresencia, Associate Engineer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123-1095
(619) 694-3990
Fax (619) 694-2730

Ella J. Darden
Technical Staff Assistant
Research Triangle Institute
3040 Comwallis Road
P. O. Box 12194
Research Triangle Park, NC  27709-2194
(919) 541-7026
Fax (919) 541-7155

Somnath Dasgupta
Waste Reduction Specialist
Iowa Waste Reduction Center
75 Biology Research Complex
Cedar Falls, IA 50613
(319) 273-2079
Fax (319) 273-2893

Paul S. Delaney
Engineering Supervisor
CTAC- SCE
6090 Irwindale
Irwindale, CA 91702
(818) 812-7549
Fax (818) 812-7381

Kevin Dick (MS 032)
Manager, Business Environmental Program
University of Nevada, Reno
Small Business Development Center
Reno, NV  89557-0100
(702) 784-1917
Fax (702) 784-4337
Erik Donhowc (MS CC284)
Environmental & Safety Services Manager
Coors Brewing Company
17755 West 32nd Avenue
Golden, CO  80401
(303) 277-3366
Fax (303) 277-6573

Peter Doty
Dow Chemical
Midland, Michigan
Small Business Development Center
MS 032
Reno, NV  89557-0100
(702)784-1917
Fax (702) 784-4337

Mark Dutcher
Sales and Market Development
Courtaulds Aerospace
409 Windjammer
Azle, TX 76020
None Given

Frank M. Ead
Materials and Processes Engineer
Lockheed Aeronautical Systems
Company
86 South Cobb Drive, #D173-B4
Marietta, GA  30062
(404)494-2818
Fax (404) 494-1610

Dr. Paul Eisele, Director
Health, Safety & Environmental Affairs
Masco Corporation
21001 Van Born
Taylor, MI  48180
(313) 374-6031
Fax (313) 374-6935
                                       A-5

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 Ensan El-ayoubi
 Environmental Engineer
 Missouri Department of Natural
 Resources Air Pollution Control
 Program
 P. O. Box 176
 Jefferson City, MO 65102
 (314) 751-4817
 Fax (314) 751-2706

 David F. Ellicks
 Department of the Air Force
 Air Force Corrosion Program Office
 WR-ALC/CNC
 215 Page Road
 Suite 232
 Robins AFB, GA  31098-1662
 (912) 926-3284
 Fax (912) 926-6619

 Doug Elliott
 Air Pollution Compliance Specialist
 State of Vermont Air Pollution Control
 Division
 103 South Main Street
 Building 3 South
 Waterbury, VT 05671-0402
 (802) 244-8731
 Fax (802) 241-2590

 Bill Elmquist
 Manager of Sales  & Marketing
 Technology Applications Group, Inc.
 4957 10th Avenue South
 Grand Forks, ND  58201
 (701)746-1818
 Fax (701) 746-1910

 Dave Esc am ilia
 Paint Manager
 Aerotest, Inc.
 16880 Laidlaw Street
 Building 210
Mojave,CA 93501
(805) 824-9331
Fax (805) 824-2208
 Caroline Espejel-Schutt
 Permit Supervisor
 Minnesota Pollution Control Agency
 520 Lafayette Road
 St. Paul, MN 55155
 (612)296-7711
 Fax (612) 297-7709

 John C. Evans
 Environmental Engineer
 North Carolina - Air Quality Section
 P. O. Box 29535
 Raleigh, NC 27626-0535
 (919) 733-3340
 Fax (919) 733-5317

 Al Fabiano
 Industrial Engineer
 U.S. Air Force
 SM-ALC/LAPH
 4342 Dudley Boulevard, Suite 1
 McClellan AFB, CA   95652-1407
 (916)643-1842
 Fax (916) 643-0428

 Terrel Ferreira
 Stationary Source Division
 Air Resources Board
 P.O. Box 2815
 Sacramento, CA  95812
 None Given

James Folck
 U.S. Air Force
Wright Patterson AFB, OH  45433-7750
None Given

Kristen Franklin (MS 032)
Pollution Prevention Technical Specialist
University of Nevada, Reno
Small Business Development Center
Reno, NY  89557-0100
(702)784-1917
Fax (702) 784-4337
                                   A-6

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 Pamela Franklin
 Engineer
 Acurex Environmental Corporation
 555 Clyde Avenue
 P. O. Box 7044
 Mountain View, CA 94039
 (415) 961-5700 Ext. 3399
 Fax (415) 964-6523

 Kevin Fulmer
 Environmental Engineer I
 State of Alabama
 Department of Environmental
 Management Air Division
 1751 Cong.  W. L. Dickinson Drive
 Montgomery, AL  36130
 (205) 271-7861
 Fax (205) 271-7950

 Ranji George
 Program Supervisor
 South Coast Air Quality Management
 District
 21865 East Copley Drive
 Diamond Bar, CA  91765
 (909) 396-3255
 Fax (909) 396-3252

 Mark T. Gholson
 Vice President
 Environment System International, Inc.
 8564 Katy Freeway
 Suite 132
 Houston, TX 77024
 (713) 984-9500
 Fax (713) 984-8815

 Michael Girosky (MS S302A)
 Materials Engineer
 Sikorsky Aircraft
Division of U.T.C.
 Main Street
 Stratford, CT 06601
 (203)386-4708
 Fax (203) 386-7523
Richard S. Goldman
Technical Manager
Concurrent Technologies Corporation
National Defense Center for
Environmental Excellence
1450 Scalp Avenue
Johnstown, PA 15904
(814) 269-2482
Fax (814) 269-2798

Marjorie Goldsmith
Quality Engineer
Aerojet Electronic Systems Division
1100 West Holly vale Street
Azusa,CA 91702
(818) 812-1787
Fax (818) 812-8077

David M. Grafflin
Evodex Powder Coatings
90 Carson Road
Birmingham, AL  35215
(205) 854-5486
Fax (205) 854-2566

Robert Grant
CA Air Resources Board
P.O. Box 2815
1100 W. Hollyvale Street
Sacramento, CA 95812
(916) 323-5774

Dr. Dan Grosse (MS 114)
Technology Development Manager
S. C. Johnson Polymer
1525 Howe Street
Racine, WI 53403-5011
(414) 631-2414
Fax (414) 631-3954

Madeline M. Grulich
Pacific Northwest Pollution Prevention
Research Center
1326 Fifth, Suite 650
Seattle, WA 98101
(206)223-1151
Fax (206) 223-1165
                                      A-7

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 Gary Gulka
 Director
 Vermont Agency of Natural Resources
 Pollution Prevention Division
 103 South Main Street
 Waterbury, VT  05614-0404
 (802) 244-8702
 Fax (802)244-5141

 Michael J. Halliwell
 Material Research Engineer
 U.S. Air Force
 WL/MLBT
 Building 653
 2941 P Street
 Suite 1
 Wright-Patterson AFB, 45433-7750
 (513) 255-3877
 Fax (513) 476-4728

 Steven A. Hamay
 Chemist
 PPG Industries, Inc.
 4325 Roseanna Drive
 Allison Park, PA 15101
 (412) 492-5454
 Fax (412) 492-5509. Oper. 492-5200

 Don Hammock
 Safety Manager
 Varco International
 P.O. Box 6626
 Orange, CA 02613-6626
 (714) 978-1900
 Fax (714) 937-5029

 Ole Jorgen Hanssen
Research Manager
Center for Applied Research
Box 276, N-1600
Fristad, Norway
4769 34 19 00
Fax 4769 34 24 94
 Lisa M. Harris (TS-779)
 Economist
 U.S. Environmental Protection Agency
 Office of Pollution Prevention &. Toxics
 401 M Street, S.W.
 Washington, DC  20460
 (202)260-1687
 Fax (202)260-0981

 Scott P. Harris
 Associate Hazardous Materials Specialist
 California Environmental Protection
 Agency
 Department of Toxic Substances Control
 1011 North Grand view Avenue
 Glendale, CA 91201
 (818)551-2831
 Fax (818) 551-2874

 Gary Hartnett
 Air Quality Inspector II
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego. CA 92123-1095
 (619) 694-3340
 Fax (619) 694-2730

 Henry Heck
 Development Associate
 Protective Coatings & Civil Engineering
 DOW USA
 2301 Brazosport Boulevard, #B1603
 FreeporuTX 77541
 (409) 238-1965
 Fax (409) 238-4530

 Paula Henry
• Senior Development Engineer
 British Airways - N210 TEA (S429)
 P. O. Box 10 - Heathrow Airport
 Hounslow - Middlesex TW6 2JA U.K.
 44 81 562-3104
 Fax 4481  562-5403
                                       A-8

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 Dave Hodges
 Environmental Scientist
 U.S. Environmental Protection Agency
 75 Hawthorne Street
 San Francisco, CA  94610
 (415)744-1197
 Fax (415) 747-1076

 Albert Holder (Code 2841)
 Naval Surface Warfare Center
 Annapolis, MD 21402-5067
 (410) 267-3659
 Fax (410) 267-2840

 Sandra Horn
 Senior Air Quality Chemist
 South Coast Air Quality Management
 District
 21865 East Copley Drive
 Diamond Bar, CA 91765-4182
 (909) 396-2169
 Fax (909) 396-2175

 Laurence L. Hornich
 Chemical Engineer
 U.S. Army/Letterkenny Army Depot
 Letterkenny Army Depot
 Chambersburg, PA  17201-4150
 (717) 267-9506
 Fax (717)  267-9299

 Ricke Hood
Air Pollution Control Engineer I
 Pennsylvania Environmental Resources
Air Quality Control
 P. O.  Box 8468 - 400
 Market Street - 12th Floor
Harrisburg, PA  17105-8468
(717)787-4310
Fax (717) 772-2303

Peter Hope, Technical Director
LVH  Coatings/Hawking Intl Ltd. U.K.
 1650 Union Avenue
Chicago Heights, IL  60411
(708)  754-0001
Fax (708) 754-0093
Paul Hoth (MS 350)
Engineer Environmental Services
Thiokol Corporation
P. O. Box 689
Brigham City, UT 84302-0689
(801) 863-8163
Fax (801) 863-5492

Glenn M. Howarth, Staff Engineer
GM Environmental and Energy Staff
30500 Mound Road, REB
P. O. Box 9055
Warren, MI 48090-9055
(313) 947-2408
Fax (313) 947-1422

Eddy W. Huang, Project Manager
The Center for Emissions Research &
Analysis
18559 East Gale Avenue
City of Industry, CA  91748
(818) 854-5868
Fax (818) 854-5869

Gene A. Huber
President
G. A. Huber Company
6407 El Pato Court
Carlsbad, CA  92009
(619) 438-1903
Fax (619) 438-4329

Martin W. Huszar
Military Sales Manager
Pro-Line Paint Company
2646 Main Street
San Diego, CA 92113
(619) 231-2813
Fax (619) 236-9681
Mark W. Ingle
Ocean City Research Corporation
1745 Jefferson Davis Highway
Suite 702
Arlington, VA 22202
(703) 212-9006
Fax (703) 212-9007
                                A-9

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 Cindy Ivey
 Environmental Coordinator
 Gieiger International
 7005 Fulton Industrial Boulevard
 Atlanta, GA 30336
 (404)344-1100
 Fax (404) 346-5203

 Munter T. Jabbur
 Environmental Engineer
 National Guard Bureau
 NGB/DEV
 Bldg. 3500, Stop 18
 AndrewsAFB.MD  20331-6008
 None Given

 Kirk Jackson
 Engineering Supervisor
 Kyowa America Corporation
 385 Clinton Street
 Costa Mesa, CA 92626
 (714)641-0411
 Fax (714) 540-5849

 Mark Jaffari
 Environmental Manager
 Malek, Inc.
 4951 Ruffin Road
 San Diego, CA 92123-1698
 (619) 279-0277 (Linda Collins)
 Fax (619) 279-9618

 Paul Jarman
 Air Quality Inspector II
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA  92123-1095
 (619) 694-3340
 Fax (619) 694-2730

 David H. Johnson (MS CC284)
 Senior Quality Systems Applications
Scientist
Coors Brewing Company
 17755 West 32nd Avenue
Golden, CO 80401
(303) 277-5935
Fax (303) 277-6573
 E. Dean Johnston
 Process Engineer Senior
 Hughes Aircraft Company
 1901 West Malvern Avenue
 Fullerton,CA  92634
 (714) 732-8286
 Fax (714) 732-6727

 Dr. Alex Kaznoff
 Naval Sea Systems Command
 2531 Jefferson Davis Highway
 Arlington, VA 22242-5160
 (703) 602-0135
 Fax (703) 602-0247

 Dr. Martin W.  Kendig
 Member of Technical Staff
 Rockwell International Science Center
 1049 Camino dos Rios
 Thousand Oaks, CA  91360
 (805) 373-4241
 Fax (805) 373-4383

 Daniel N. King
 Solvents and Functional Fluids Application
 Support Manager
 Exxon Chemical  Company
 5200 Bayway Drive
 Baytown,TX 77522-5200
 (713) 425-2462
 Fax (713) 425-5890

 Kevin Kinzer,
Research Specialist
3M
3M Center 201-2N-19
SL Paul, MN 55144-1000
(612) 733-6575
Fax (612) 737-2590

Doug Kirkpatrick  (MS 2-3-1)
Research Scientist
SAIC
 1710 Goodridge Drive
McLean, VA 22102
(703) 821-4587
Fax (703) 821-1134
                                 A-10

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 Marti Klein (Mail Code AE81)
 Environmental Engineering Specialist
 Rockwell International Space Systems
 Division
 12214 Lakewood Boulevard
 Downey, CA 90241
 (310)922-2116
 Fax (310) 922-2844

 Gig Korver
 Technical Support Manager
 Hexcel • Structural Products Group
 5794 West Las Positas Boulevard
 Pleasanton, CA 94588
 (510) 847-9500, Ext. 4301
 Fax (510) 734-9042

 Michael Kosusko (MD 61)
 Senior Project Engineer
 U.S. Environmental Protection Agency
 Air and Energy Engineering Research
 Laboratory
 Research Triangle Park, NC 27711
 (919) 541-2734
 Fax (919) 541-2157

 Jack Kowal
 Chemical Project Manager
 Coors Brewing Company
 17555 West 32nd Avenue
 Golden, CO 80401
 (303) 277-2038
 Fax (303) 277-6670

 Russ Krinker
 Customer Technology Specialist
 Southern California Edison
P. O. Box 4349
42060 10th Street, West
 Lancaster, CA  93539
(805) 945-7463
Fax (805) 945-7469
John P. Kusz
Manager, Product Development
Safety-Kleen Corporation
777 Big Timber Road
Elgin, IL 60123
(708) 468-2514
Fax (708) 697-8593

Edwin  Laird
Coatings Resource Corporation
15541 Commerce Lane
Huntington Beach, CA  92649
(714) 894-5252
Fax (714) 893-2322

William R. LaMarr, Program Manager
Southern California Edison Company
300 North Lone Hill
San Dimas, CA 91773
(909) 394-8859
Fax (909) 394-8922

Mark Lawless
Air Quality Inspector II
San Diego Air Pollution Control District
9150 Chesapeake  Drive
San Diego, CA 92123-1095
(619) 694-3340
Fax (619) 694-2730

Clayton Legrand
Environmental Engineer
Naval Aviation Depot
NAS, NADEP, Box 16
Jacksonville, FL  32212-0016
(904) 772-2200
Fax (904) 772-2229

Terry D. Leland (MS 73-40)
Manager
Boeing Commercial  Airplane Group
Organic Finishes and Environmental
Technology
P. O. Box 3707
Seattle, WA 98124-2207
(206) 234-3952
Fax (206) 237-0052
                                    A-ll

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  Bud Levine
  Vice President
  Deft Chemical Coatings
  17451 Von Karman Avenue
  Irvine, CA 92714
  (714) 474-0400
  Fax (714) 474-7269

  Karen Lewis
  Air Quality Inspector I
  San Diego Air Pollution Control District
  9150 Chesapeake Drive
  San Diego, CA  92123-1095
  (619) 694-3340
  Fax (619) 694-2730

  Mark E. Lindsay
  Lockheed Missiles & Space Company,
  Inc.
  Materials & Processes Engineering
  Space Systems Division
  1111 Lockheed Way
  Sunnyvale, CA 94989-3504
  (408)742-1115
 Fax (408) 742-7511

 Holly K. Lippert
 Hardware Engineer/Finishes
 Digital Equipment Corporation
 30 Forbes Road
 Northboro, MA 01532
 (508) 493-0491
 Fax (508) 351-5018

 Robert Little
 Head of Materials R&D Section
 Defense Research Laboratory
 Building El7, Royal Arsenal East
 Woolwich,  London SE186TD, England
 44 81-854-2044 ExL 4062
 Fax  4481-854-2937

 Ron Little, President
 R. W. Little Coatings Company
3923 Pacific Highway
San Diego, CA  92110
(619) 297-3705
Fax (619) 692-0418
 Joseph Lucas, President
 Inland Technology Incorporated
 2612 Pacific Highway East
 Suite C
 Tacoraa,WA  98424
 1-800-552-3100 or (206) 922-8932
 Fax (206) 926-0577

 Joan Lum (EQ/E1/F157)
 Senior Staff Engineer
 Hughes Aircraft Company
 2000 East El Segundo Boulevard
 ElSegundo, CA  90245
 (310) 616-1087
 Fax (310) 616-0106

 John Maclntyre (MS 521)
 Finish Shop Manager
 Dallas Manufacturing
 Texas Instruments Defense
 Goopd Lemroon Avenue
 P. O. Box 660246
 Dallas, TX 75266
 (214) 956-6256
 Fax Not Given

 Alexander Mart
 Project Manager
 Southern California Edison
 6070 North Irwindale Avenue, Suite I
 Irwindale, California
 (818) 812-7691
 Fax (818) 812 7646

 William Manvick
 Alcan International Limited
 Southaro Road, Banbury
 Oxon, England OX167SP
 44 295 272626
 Fax 44 295 274216

 David W. Maurer
Manager, Product Planning
 The Gildden Paint Company
925 Euclid Avenue
Cleveland, OH 44115
 (216) 344-8664
Fax (216) 344-8629
                                  A-12

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 Christopher A. Mayeux
 Environmental Chemical Specialist
 Louisiana Department of Environmental
 Quality
 11720 Airline Highway
 Baton Rouge, LA 70817
 (504) 295-8945
 Fax (504) 295-8573

 David C. McClurg
 Development Representative
 Miles, Inc.
 Mobay Road
 Pittsburgh,  PA  15205-9741
 (412) 777-4963
 Fax (412) 777-2132

 Robert C. McCrillis (MD 61)
 Project Manager
 U.S. Environmental Protection Agency
 Research Triangle Park, NC 27711
 (919) 541-2733
 Fax (919) 541-2157

 Jeanette McHaffey
 Engineer
 U.S. Air Force
 SA - ALC/PIESM
 450 Quentin Roosevelt Road
 Kelly AFB.TX 78241-6416
 (210)  925-8745
 Fax (210) 925-4916

 Jackie Sparrey  McHugh, Administrator
 Teledyne Ryan Electronics
 Health, Safety  & Environmental Affairs
 8650 Balboa Avenue
 San Diego, CA  92123
 (619)  560-6400, ext 310
 Fax (619) 560-1147

 Beth McMinn
Environmental Engineer
TRC Environmental  Corporation
 100 Europa Drive, Suite 150
Chapel Hill, NC  27514
 (919)  968-9900
Fax (919) 968-7557
Nick Melliadis
Eng. Physical Sciences Technician II
Colorado Department of Health/Air
Pollution Control District
4300 Cherry Creek Drive South
Denver, CO  80222
(303) 692-3175
Fax (303) 782-5493

Tony Mercer,  Plant Manager
Plastic Dress-Up Company
11077 East Rush Street
South El Monte, CA  91733-9985
(818)443-7711
Fax (818) 443-1814

Wayne Paul Miller
Union Carbide Corporation
P. O. Box 8361
South Charleston, WV 25303
(304) 747-5192
Fax (304) 747-4886

Anthony A. Mitchell
President
Pro-Line Paint Company
2646 Main Street
San Diego, C A 92113
(619) 231-2813
Fax (619) 236-9681

Dan Moe
Hazardous Materials Specialist III
Sacramento County Hazardous
Materials Division
8475 Jackson Road
Suite 230
Sacramento, CA 95826
(916) 386-6170
Fax (916) 386-7040

George Mogan
Advance Systems Technology
7675 Dagget St, Suite 350
San Diego, C A 92111
(619) 974-7667
                                  A-13

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 Michael S. Moke (MZ 2852)
 Consultant
 Lockheed Fort Worth Company
 P. O. Box 748
 Fort Worth, TX  76101
 (817) 777-2145
 Fax (817) 777-2115

 Brad Montgomery
 Pollution Prevention Engineer
 Lockheed Environmental Sciences and
 Technologies
 980 Kelly Johnson Drive
 Las Vegas, NV 89119
 (702) 897-3440
 Fax (702) 897-6645

 Mike Moran
 Air Quality Inspector I
 San Diego Air Pollution Control District
 9150 Chesapeake  Drive
 San Diego, CA 92123-1095
 (619) 694-3340
 Fax (619) 694-2730

 Teresa Morris
 Chief, Enforcement Division
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA  92123-1095
 (619) 694-3342
 Fax (619) 694-2730

 Tom Morrison, Assistant Manager
 Interior Automotive Department
 Red Spot Paint & Varnish Co., Inc.
 P. O. Box 418
 Evansville, IN 47703-0418
 (812)428-9129
 Fax (812) 428-9167

Brian Morton
Research Triangle Institute
P. O. Box 12194
Research Triangle  Park, NC 27709
(919) 541-7094
Fax (919) 541-5945
 Jeffery P. Mouser
 Customer Technology Representative
 Southern California Edison Energy
 Services
 25625 West Rye Canyon Road
 Valencia, CA 91355
 (805) 257-8219
 Fax (805) 257-8222

 Anne E. Murdoch
 Environmental Protection Specialist
 Naval Amphibious Base, Coronado
 SCE Code 84.1, Building 16
 Coronado, CA 92155
 (619)437-5114
 Fax (619) 437-0970

 Elsa Muyco
 Material  & Process Engineer Senior
 Teledyne Ryan  Aeronautical
 2701 Harbor Drive
 P.O.  Box 85311
 San Diego. CA  92186-5311
 (619)291-7311
 Fax (619) 260-5400

 Tom Naguy
 Chemical Engineer
 Wright Laboratory
 WL/MLSA
 2179 12th Street
 Suite  i
 Wright-Patterson AFB, OH  45433-7718
 (513)255-5117
 Fax (513) 476-4419

Jim Nale
Paint Shop Chief
 Municipal of  Metropolitan Seattle
Metro Transit
 12200 East Marginal Way South
Seattle, WA 98168-2598
(206) 684-2215
Fax (206) 684-2289
                                       A-14

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Joven Nazareno
Air Quality Engineer
San Joaquin Valley Unified Air Pollution
Control District
1999 Tuolumne Street
Suite 200
Fresno, CA  93721
(209)497-1000
Fax (209) 233-2057

Raivo Eerik Neggo
Project Manager
Southern California Edison - Research
P. O. Box 800 601/455
Rosemead, CA 91770
(818) 302-4361
Fax (818) 302-6250

David Nelson
EnviroSearch
844 South 200 East
Salt Lake City, UT 84111
(801) 532-1717
Fax (801) 532-1777
Home (801) 649-5562

Kim K. Nguyen
Air Resources Engineer
California Air Resources Board
2020 L Street
Sacramento, CA  95814
(916)327-1513
Fax (916) 327-7212

Jonezl A. Nixon
President
CCI Inspection Services, Inc.
2203 Tiraberlock Place
Suite 231
The Woodlands, TX 77380
(713) 367-6470
Fax (713) 364-7384
Coleen M. Northeim, Manager
Research Triangle Institute
Pollution Prevention Program
3040 CornwaJlis Road
P. O. Box 12194
Research Triangle Park, NC 27709-2194
(919)541-5816
Fax (919) 541-7155

Carlos M. Nunez (MD 61)
Chemical Engineer
U.S. Environmental Protection Agency
Air and Energy Engineering Research
Laboratory
Research Triangle Park, NC 27711
(919)541-1156
Fax (919) 541-2157

Joe Oliva, Jr.,
U.S. Air Force
Facilities/Equipment Engineering Section
SA/ALC/LAPSD
Kelly AFB.TX  78241-6334
(210) 925-8541
Fax Not Given

Randy Olms
Environmental Engineer
ChemTronics, Inc.
1150 West Bradley Avenue
ElCajon, CA 92020
(619) 258-5062
Fax (619) 258-5239

Sharon Orlando (MZ K3-7160)
Senior Environmental Engineer
General Dynamics
P. O. Box 85990
San Diego, CA  92186-5990
(619) 974-3386
Fax (619) 974-4000

Ron Orrell, Staff Engineer
Martin  Marietta Astronautics Group
P. O. Box  179
Denver, CO  80201
(303)971-8606
Fax (303) 971-9768
                                      A-15

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 Charles F. Outlaw
 Chief of Acquisition Logistics
 U.S. Air Force
 ASC/EML, Building 17
 2060 Third Street
 Wright-Patterson AFB, OH 45433-7203
 (513)255-5149
 Fax (513) 255-9985

 Richard Parks
 Naval Sea Systems Command
 Washington, DC  20362
 (703) 602-0213
 Susan Petersen
 Senior Staff Representative
 United Airlines - MOC - SFOSY
 Environmental Safety Department
 San Francisco International Airport
 San Francisco, CA 94128
 (415) 634-7209
 Fax (415) 634-7385
 Robert B. Pojasek, Ph.D.
 GEI Consultants, Inc.
 1021 Main Street
 Winchester, MA 01890
 (617) 721-4000
 Fax (617)721-4073

 Wade H. Ponder (MD 61)
 Chief, Organics Control Branch
 U.S. Environmental Protection Agency
 Air and Energy Engineering Research
 Laboratory
 Research Triangle Park, NC  27711
 (919) 541-2818
 Fax (919) 541-2157

 Donald Potenza (Code 706)
Supervisor,  Electronics Technician
Naval Weapons Station
800 Seal Beach Boulevard
Seal Beach, CA 90740-5000
(310)594-7178
Fax (310) 594-71798
 William J. Powell, Manager
 Southern California Edison
 300 North Lone Hill
 San Dimas, CA  91773
 (909) 394-8826
 Fax (909) 394-8922

 Robert Pryor
 Research Biologist
 TRA
 2257 South 1100 East
 Salt Lake  City, UT  84106
 (801) 485-4991
 Fax (801) 485-4997

 Karen Race
 Industrial  Safety & Environmental Control
 Lockheed Aircraft Service Ontario
 Department 1-533, P. O. Box 33
 Ontario, CA 91761-0033
 (909) 395-2804
 Fax (909)  395-2080
Paul Randall
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
Cincinnati, OH 45268
(513) 569-7418
Fax (513) 569-7549

Fred Raniere, Manager
Rockwell International
Material Processing & Chemistry
1049 Camino Dos Rios
Thousand Oaks, CA  91360
(805) 373-4619
Fax Not Given

Ron Reece
Environmental Engineer
Utah Division of Air  Quality
1950 West North  Temple
Salt Lake City, UT 84116
(801) 536-4000
Fax (801) 536-4099
                                  A-16

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Thomas Reeves
Occupational Safety & Health Specialist
U.S. Navy - Port Hueneme
4365 Missile Way
NSWC, PHD, Code 0009
Port Hueneme, CA 93043-4807
(805) 982-8120
Fax  (805) 982-6253

James Reimer
-Vice President
Plastic Flamecoat Systems, Inc.
1613 Highway 3
League City, TX 77573
(713) 332-8180
Fax  (713) 554-7434

Daniel R. Rhine
Naval Aviation Depot
Code 672
Naval Air Station
North Island
San  Diego,  CA 92135-5112
(619) 545-4405
Fax Not Given

Nolin C. Rhodehouse
Senior Technician
Babcock &  Wilcox Idaho - INEL
P. O. Box 1469
Idaho Falls, ID  83403
(208) 526-6533
Fax (208) 526-6361

William J. Riffe
Marine  Environmental Research, Inc.
105 North 10th Street
P. O. Box 2013
Morehead City, NC 28557
(919) 726-4544
Fax (919) 726-9998

Don  Robinson
Technical Evaluation Manager
Utah Division  of Air Quality
1950 West North Temple
Salt Lake City, UT 84116
(801) 536-4000, Fax (801) 536-4099
Dr. Alexander Ross
Senior Scientist
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-2617
Fax (202) 260-4524

David Ruiz
U.S. Air Force
SM-ALC/LAPRT
3028 Peacekeeper Way
Suite 3
McClellan AFB, CA 95652-1019
(916) 643-4712
Fax Not Given

Larry F. Runyan
Director of Manufacturing Services
American Furniture Manufacturers
Association
P. O. Box HP 7
High Point, NC  27261
(919) 884-5000
Fax (919) 884-5303

Carolyn Rushforth
Project Manager
Acurex Environmental
555 Clyde Avenue
Mountain View, CA 94089
(415) 961-5700, x 3610
Fax (415) 964-6253

Peter C. Ryder
Hawking International Ltd,
Surface Coating Technology
The Stenders
Mitcheldean
Gloucestershire GL17  OZB UK
44 05 94 544325
Fax:  440594543828
                                  A-17

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 James Sainsbury, Manager
 Product Regulation
 The Glidden Company
 925 Euclid Avenue
 Cleveland, OH 44115
 (216) 344-8818
 Fax (216) 344-8935

 Rosa Salcedo, Associate Engineer
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA  92123-1095
 (619) 694-3324
 Fax (619) 694-2730

 Chuck Sales
 Materials and Processes Engineer
 Rohr, Inc.
 P. O. Box 878
 Chula Vista, CA 9192-0878
 (619) 691-6718
 Fax (619) 691-2148

 Kenneth M. Sanders
 Naval Aviation Department
 Code 34200
 NAS Pensacola, FL 32508-5300
 (904) 452-3553
 Fax (904) 452-2961

 Richard Sayad
 Manager
 Health, Environmental & Regulatory
 DOW Plastics
 DOW Chemical  Company
 1320 Waldo Road
 Midland, MI  48642
 (517) 636-2867
 Fax (517) 638-2446

 Bruce Schwemmer
Director Regulatory Affiars
 CIBA-Geigy Coporation
CIBA Additives
Seven Skyline Dirve
Hawthorne, NY  10532
(974) 785-4477
Fax (974) 347-7086
 Mary Serra
 Waste Management Engineer
 California Department of Toxic
 Substances Control
 Office of Pollution Prevention and
 Technology Development
 301 Capitol Mall, First Floor
 P. O. Box 806
 Sacramento, CA  95812-0806
 (916) 445-0572
 Fax (916) 327-4494

 Michael Sfirri
 Inorganic Coatings, Inc.
 500 Lapp Road
 Malvern. PA  19355
 1-800-345-0531 or (215) 640-2880
 Fax (215) 640-1771

 Uve Sillat (MS G502)
 Head, Environmental Affairs
 Hughes Aircraft Company
 P. O. Box 92426
 Building R-30
 Los Angeles, CA  90009
 (310) 606-2044
 Fax (310) 606-2096

 Mark D. Smith
 Staff Materials Engineer
 Allied Signal, Inc.
 Kansas City Division
 P. O. Box 419159
 Kansas City, MO  64414-1659
 (816)997-2561
 Fax (816) 997-2049

 Randy Smith
Air Quality Inspector III
 San Diego Air Pollution Control District
 9150 Chesapeake Drive
 San Diego, CA 92123-1095
 (619) 495-5277
 Fax (619) 694-2730
                                       A-18

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Richard W. Sokol (SP-14J CCs)
Technical Assistant
U.S. Environmental Protection Agency
77 West Jackson Boulevard
Chicago, IL 60604
(312) 353-4347
Fax (312) 353-4342

Richard J. Sommerville
Air Pollution Control Officer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA  92123-1096
(619) 694-2730
Fax (619) 694-3303

Chris Stamos (ATD, A-5-3)
U.S. Environmental Protection Agency
Air and Toxics Division
75 Hawthorne Street
San Francisco, CA 94105
(415)744-1187
Fax (415) 744-1076

Christine Stanley
Ameron/Protective Coatings Division
210 North Berry Street
P. O. Box 1020
Brea, CA  92622-1020
(714) 529-1951
Fax (714) 990-0437

John R. Stone (9FT10)
Chemist
General Services Administration
Paints & Chemical Committee
400 15th Street, SW
Auburn, WA  98001-6599
(206)931-7929
Fax (206) 931-7039

Richard Stowe
Fusion UV Curing Systems
Fusions Systems Corporation
7600 Standish Place
Rockville, MD  20855-2798
(301) 251-0300
Fax (301) 279-0661
Charles E. Studer
Air Quality Engineer
Spokane County Air Pollution Control
Authority
West 1101 College
Spokane, WA 99201
(509) 456-4727 Ext. 107
Fax (509) 459-6828

Adeline Suson, Junior Engineer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123-1095
(619) 694-3214
Fax (619) 694-2730

Lucinda Swann
Air Quality Inspector II
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123-1095
(619) 694-3340
Fax (619) 694-2730

Jim Swartz
Manager, Health & Environment
Northwest Airlines
5101 Northwest Drive, Department C1510
StPaul, MN  55111-3034
(612) 727-4841
Fax (612) 727-4845

Bruce Tabak
Supervisor Paint Finishes
Sikorsky Aircraft
North Main Street
Stratford, CT  06497
(203) 386-6728
Fax (203) 386-7185

Rodger Talbert, Technical Director
Chemical Coaters Association
International
2088 Knapp Street, NE
Grand Rapids, MI 49505
Phone/Fax (616) 365-7602

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 Jack C. Taylor, VOC Unit Manager
 Georgia Environmental Protection
 Division/Air Protection Branch
 4244 International Parkway
 Atlanta, GA  30354
 (404)363-7114
 Fax (404) 363-7100

 Dennis Thurston
 Electrotechnology Specialist
 Southern California Edison
 1327 South Grand Avenue
 Santa Ana, CA 92705
 (714)458-4443
 Fax (714) 458-4472

 John Topalian
 Technical Staff Specialist
 Aerojet Electronic Systems Division
 1100 West Hollyvale Street
 P. O. Box 296
 Azusa,CA 91702
 (818) 812-1729
 Fax (818) 812-8077

 Larry Triplett (Mail Code 0341126)
 McDonnell Douglas
 P. O. Box 516
 SL Louis, MO 63166
 (314)232-2882
 Fax (314) 233-8578

 Lien Truong, Engineer Senior
 Lockheed Fort Worth Company
 P.O. Box 748
 Fort Worth, TX 76101
 (817) 777-0923
 Fax (817) 777-3533

Terence D. Turner, Research Engineer
Lockheed Advanced Development
Company
P. O. Box 250
Sunland, CA  91041
(818) 847-6883
Fax (818) 847-0598
 Joe Vail, Air Quality Chemist
 South Coast Air Quality Management
 District
 21865 East Copley Drive
 Diamond Bar, CA 91765
 (909)396-2190
 Fax (919)396-2175

 Patricia Valazquez
 Materials and Processes Engineer
 Rohr, Inc.
 P. O.  Box 878
 Chula Vista, CA  91912-0878
 (619)691-2780
 Fax (619) 691-2148

 Chester A. Vogel (MD 61)
 Chemical Engineer
 U.S. Environmental Protection Agency
Air and Energy Engineering Research
Laboratory
 Research Triangle Park, NC  27711
 (919)541-2827
 Fax (919)541-2157

Wilhelm Wang
Manager Product Safety
CIBA-Geigy Coporation
CIBA Additives
Seven Skyline Drive
Hawthorne,  NY  10532
(974)785-4311
Fax (974) 347-7086

Jeannie Warnock
Environmental Engineer
U.S. Air Force
5146 Arnold Avenue
Suite 1
McClellan AFB, CA  95652-1077
(916)643-2190
Fax (916) 643-2193
                                  A-20

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John Warren
Research Triangle Institute
P. O. Box  12194
Research Triangle Park, NC 27709
(919) 541-7308
Fax (919) 541-5945

Sheldon Weinstein
President
AC Products, Inc.
172 East La Jolla Street
Placentia, CA 92670
(714)630-7311
Fax (714) 777-8309

Chen Wen-Huei
Engineer-/Technical Supervisor
China Technical Consultants, Inc.
TFL, 97, Tun HWA S. RD. SEC. 2
Taipei, Taiwan (ROC)
886 2 7022831
Fax 886 2  7098825

Bob Whitfield
Safety Manager
Hearne Machining
325 West 30th Street
National City, CA  91950
(619) 474-6664
Fax (619) 474-1637

Richard Wire (MS 5T-09)
Chemical Engineer
Boeing Commercial Airplane Group
Operations Technology
P. O. Box 3707
Seattle, CA 98124-2207
(206)931-9820
Fax (206) 931-9884

Joe Yager
Senior Engineer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA  92123-1095
(619) 694-3324
Fax (619) 694-2730
Laura Yannayon
Assistant Engineer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123-1095
(619) 694-3326
Fax (619) 694-2730

Azita Yazdani
Pollution Prevention International
471 West Lambert Road
Suite 105
Brea, CA 92621
(714)255-1650
Fax (714) 255-9702

Tom Yee
Senior Vice President
Harbor Universal, Inc.
1900 Marina Boulevard
San Leandro, CA  94577
(510) 352-2100
Fax (510) 357-8704

Victor Young
Supervising Engineer
Waste Reduction Resource Center
3825 Barrett Drive
Suite 300
Raleigh, NC 27609
1-800-476-8686
Fax (919) 571-4135

Natalie Zlotin
Senior Air Pollution Control Engineer
San Diego Air Pollution Control District
9150 Chesapeake Drive
San Diego, CA 92123
(619) 694-3335
Fax (619) 694-2730

Alex Zozulin
Technology Applications Group, Inc.
4957 10th Avenue, South
Grand Forks, ND  58201
(701)746-1818
Fax (701) 746-1910
                                     A-21

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                                  TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
  1. REPORT NO.
   EPA-600/R-94-022
                                                         3. RECIPIENT'S ACCESSION-NO.
  4. TITLE AND SUBTITLE
   Proceedings: Pollution Prevention Conference on Low
    and No-VOC Coating Technologies
               5. REPORT DATE
                February 1994
               6. PERFORMING ORGANIZATION CODE
  7. AUTHOR(S)

   Coleen M. Northeim and Ella Darden,  Compilers
                                                         8. PERFORMING ORGANIZATION REPORT NO.
  9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Research Triangle Institute
  P. C. Box 12194
  Research Triangle Park, North Carolina  27709
                                                         10. PROGRAM ELEMENT NO.
               11. CONTRACT/GRANT NO.
                CR819541
  12. SPONSORING AGENCY NAME AND ADDRESS
  EPA, Office of Research and Development
  Air and Energy Engineering Research Laboratory
  Research Triangle Park, NC 27711
               13. TYPE OF REPORT AND PERIOD COVERED
                Proceedings:  5-10/93	
               14. SPONSORING AGENCY CODE
                 EPA/600/13
  is. SUPPLEMENTARY NOTES AEERL project officer is Michael Kososko, Mail Drop 61. 919/541-
  2734.
 16. ABSTRACT
           The report documents a conference that provided a forum for the exchange
  of technical information on coating technologies.  It focused on improved and emer-
  ging technologies that result in fewer volatile organic  compound (VOC) and toxic air
  emissions than traditional coating emissions.  Among the new products and improve-
  ments focused on were an electrophoretic urethane coating,  a zero-VOC house paint,
  and developments involving  such inorganic polymers as zinc silicates and silicones.
  Coatings for such substrates as metal (aerospace), wood (furniture),  plastic, foil,
  and concrete were also discussed.
17.
                              KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                            b. IDENTIFIERS/OPEN ENDED TERMS
                           c.  COSATI Field/Group
 Pollution
 Coatings
 Coating  Processes
 Emission
 Organic Compounds
 Volatility
   Pollution Prevention
   Stationary Sources
   Volatile Organic Com-
    pounds (VOCs)
13B
11C
13 H
14G
07C
20 M
13. DISTRIBUTION STATEMENT
 Release to Public
EPA Form 2220-1 (9-73)
  19. SECURITV CLASS (This Report)
   Unclassified
                                                                     21. NO. OF PAGES
                                                                       528
  20. SECURITY CLASS (Thispage)
   Unclassified
                            22. PRICE
A-22

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