EPA/600/R-07/025
                                              March 2007
Demonstration Evaluation of
   Biodegradable Degreaser
                   by

                 Battelle
            Columbus, Ohio 43201
            Contract No. 68-C-00-185
               Task Order 0026
             Task Order Manager

               David Ferguson
    National Risk Management Research Laboratory
        U.S. Environmental Protection Agency
             Cincinnati, Ohio 45268
 National Risk Management Research Laboratory
      Office of Research and Development
     U.S. Environmental Protection Agency
            Cincinnati, OH 45268

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                                       DISCLAIMER

The work reported in this document is funded by the U.S. Environmental Protection Agency (EPA) under
Task Order (TO) 0026 of Contract No. 68-C-00-185 to Battelle. It has been subjected to the Agency's peer
and administrative reviews and has been approved for publication as an EPA document.  Any opinions
expressed in this paper are those of the author(s) and do not, necessarily, reflect the official positions and
policies of the EPA. Any mention of products or trade names does not constitute recommendation for use by
the EPA.

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                                         FOREWORD

The U.S. Environmental Protection Agency (EPA is charged by Congress with protecting the Nation's land,
air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate
and implement actions leading to a compatible balance between human activities and the ability of natural
systems yto support and nurture life. To meet this mandate, EPA's research program is providing data and
technical support for solving environmental problems today and building a science knowledge base necessary
to manage our ecological resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency's center for investigation of
technological and management approaches for preventing and reducing risks from pollution that threaten
human health and the environment. The focus of the Laboratory's research program is on methods and their
cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface resources;
protection of water quality in public water systems; air pollution; and restoration of ecosystems. NRMRL
collaborates with both  public and private sector partners to foster technologies  that reduce the cost of
compliance and to anticipate emerging problems. NRMRL's research provides solutions to environmental
problems by developing and promoting technologies that protect and improve the environment; advancing
scientific and engineering information to support regulatory and policy decisions; and providing the technical
support and information transfer to ensure implementation of environmental regulations and strategies at the
national, state, and community levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan. It is
published  and made available by EPA's Office of Research and Development to assist the user community
and to link researchers with their clients.
                                         Sally Gutierrez, Director
                                         National Risk Management Research Laboratory
                                             in

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                                         ABSTRACT

The objective  of this project was to evaluate a bio-based parts-degreasing fluid called Eagle Kleen™
manufactured by Hydra-Tone Chemicals, Inc. (HTCI).  Performance tests of this methyl-ester/surfactant,
ready-to-use, micro-emulsion degreaser indicated that it was effective in removing oil and grease contami-
nation from bare metal and painted surfaces, and its degreasing power is similar to alkaline and solvent
cleaners. The project included the preparation of the Quality Assurance Project Plan (QAPP) and conducting
the following three Tasks: 1 - Laboratory Testing, 2 - Site Testing (conducted at the Vehicle Shop at Robins
Air Force Base [AFB], the Gas Turbine Engine [GTE] Shop at Hill AFB, and an equipment supplier), and 3 -
Engineering Cost Assessment.
                                             IV

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                                     CONTENTS

DISCLAIMER	ii
FOREWORD	iii
ABSTRACT	iv
FIGURES	vi
TABLES	vi
APPENDICES	v
ACRONYMS AND ABBREVIATIONS	viii
EXECUTIVE SUMMARY	ix

1.0   PROJECT DESCRIPTION	1
     1.1   General Overview	1
     1.2   Goals	1.
     1.3   Demonstration/Report Organization	2

2.0   TASK 1 - ANALYTICAL TESTING	3
     2.1   Initial Laboratory Evaluation	4
     2.2   Analytical Laboratory Testing - Eagle Kleen 1	7
     2.3   Analytical Laboratory Testing - Eagle Kleen II	9
     2.4   Analytical Laboratory Testing - Eagle Kleen III	9
     2.5   Analytical Laboratory Testing - Eagle Kleen III, Vapor Pressure	11
     2.6   Material Compatibility Evaluation	11
     2.7   Analytical Laboratory Toxicity Testing - Eagle Kleen III	13
     2.8   Conclusions	13

3.0   TASK 2 - SITE TESTING	15
     3.1   Background	15
     3.2   Robins AFB Testing	16
     3.3   Hill AFB Testing	19
     3.4   Ransohoff Testing	23

4.0   TASK 3 - ENGINEERING COST ASSESSMENT	29

5.0   CONCLUSIONS AND RECOMENDATIONS	32
     5.1   Conclusions	32
     5.2   Recommendations	32

6.0   REFERENCES	33

APPENDIX A MIL-PRF-87937D "Cleaning Compound, Aerospace Equipment"
APPENDIX B  SMI Results from  Eagle Kleen I Analytical Testing
APPENDIX C  SMI Results from  Eagle Kleen II Analytical Testing
APPENDIX D SMI Results from  Eagle Kleen III Analytical Testing
APPENDIX E  SMI Results from  Eagle Kleen III Vapor Pressure Testing
APPENDIX F  SMI Results from  Eagle Kleen III Toxicity Testing

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                                         FIGURES

Figure 1.   Bearing Inspection after Initial Immersion	6
Figure 2.   Bearing after Final Cleaning	7
Figure 3.   Handle Before Exposure to Eagle Kleen III	12
Figure 4.   Handle After Exposure to Eagle Kleen III	12
Figure 5.   Degreaser and Rinse Tanks for Eagle Kleen™ and Safety Kleen™ Bath	17
Figure 6.   Wheel Bearings Being Degreased with Eagle Kleen™	17
Figure 7.   Wheel Bearings Before (left) and After (right) Degreasing with Eagle Kleen™	18
Figure 8.   Cleaning Score for Equivalent Number of Parts Cleaned Using the Two Degreasers	19
Figure 9.   RAMCO Cleaning Line at Hill AFB GTE Shop	20
Figure 10.  Eagle Kleen™ Degreaser Bath	20
Figure 11.  Process Flow Diagram for Cleaning in the Hill AFB Gas Turbine Engine Shop	20
Figure 12.  Example of Air Inlet Housing Prior to Cleaning (left), After Degreasing with Turco 6849
           (center), and After Degreasing with Eagle Kleen™ (right)	21
Figure 13.  Overall Cleaning Score	22
Figure 14.  Parts Requiring Reprocessing	22
Figure 15.  "Grease Monkey" CLASSIC 3523 Blackstone~Ney Parts Washer	24
Figure 16.  Parts Washer After Eagle  Kleen™ Added	24
Figure 17.  Parts Partially Suspended in Cleaning Bath	25
Figure 18.  Top View of Fan Assembly After Cleaning	25
Figure 19.  Front View of Fan Assembly After Cleaning	26
Figure 20.  Rear View of Fan Assembly	26
Figure 21.  Agisonic AG-30 Shown from Front	27
Figure 22.  Agisonic AG-30 Looking Down into Basket	28


                                          TABLES

Table 1.    Subcontractor for MIL-PRF-87937D Testing	3
Table 2.    Analytical  Testing Per MIL-PRF-87937D	5
Table 3.    Eagle Kleen I Analytical Test Results per MIL-PRF-87937D	8
Table 4.    Eagle Kleen II Analytical Test Results per MIL-PRF-87937D	9
Table 5.    Eagle Kleen III Analytical Test Results per MIL-PRF-87937D	10
Table 6.    Reid Vapor Pressure Results for Eagle Kleen III	11
Table 7.    Material Compatibility Analysis  Results	13
Table 8.    96-Hour Pimephales promelas Bioassay	14
Table 9.    48-Hour Ceriodaphnia dubia Bioassay	14
Table 10.   Aquatic Toxicity as Measured by Lethal Concentrations	14
Table 11.   Cleaning Score Description	15
Table 12.   Critical Measurements for Site Testing	15
Table 13.   Aqueous Cleaning Tank Operating Conditions	27
Table 14.   ECA Assessment Factors	30
Table 15.   ECA Sensitivity Analysis	31
                                            VI

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Vll

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                           ACRONYMS AND ABBREVIATIONS

AFB          Air Force Base
ASTM        American Society for Testing and Materials

CPVC        chloropolyvinylchloride
CFR          Code of Federal Regulations

DOT          Department of Transportation

ECA          Engineering Cost Assessment
EPA          (United States) Environmental Protection Agency
ESOH        Environmental, Safety, and Occupational Health

HOPE        high-density polyethylene
HTCI         Hydra-Tone Chemicals, Inc.

IVD          Ion Vapor Deposited
IWTP         industrial wastewater treatment plant

LD50          lethal dose at which 50% of the species does not survive

MSDS        Material Safety Data Sheet(s)

NESHAP      National Emission Standards for Hazardous Air Pollutants
NRMRL      National Risk Management Research Laboratory
NPV          net present value

PPE          personal protective equipment
ppm          parts per million
PVC          polyvinylchloride

QAPP        Quality Assurance Project Plan
QA/QC       quality assurance/quality control
QPL          qualified product list

RTU          ready-to-use

SARA        Superfund Amendment and Reauthorization Act
SMI          Scientific Materials International, Inc.

TOM         Task Order Manager

USAF        United States Air Force
UN           United Nations

VOC          volatile organic compound
                                          Vlll

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                                   EXECUTIVE SUMMARY

The  objective of this project was to evaluate  a bio-based parts-degreasing fluid called Eagle Kleen™
manufactured by Hydra-Tone Chemicals, Inc. (HTCI). Performance tests of this methyl-ester/surfactant,
ready-to-use, micro-emulsion degreaser indicated that it was effective in removing oil and grease contami-
nation from bare metal and painted surfaces, and its degreasing power is similar to alkaline and solvent
cleaners. The project included the preparation of the Quality Assurance Project Plan (QAPP) and conducting
the following three Tasks: 1 - Laboratory Testing, 2 - Site Testing (conducted at the Vehicle Shop at Robins
Air Force Base [AFB], the Gas Turbine Engine [GTE] Shop at Hill AFB, and an equipment supplier), and 3 -
Engineering Cost Assessment.

Analytical Testing. In this task, the non-hazardous, non-flammable, non-corrosive degreaser was assessed
against a military specification (MIL-PRF-87937D) for water dilutable aerospace cleaning compounds. Itmet
biodegradable, flash point, cleaning performance, residue, and cold stability requirements, as well as a series
of metal and painted surface corrosion tests. It was found acceptable for sealants, rubber, and insulated wire,
as well  as  hydrogen embrittlement.  This ability to meet the hydrogen embrittlement requirement is a
significant achievement that sets it apart from most aqueous cleaners.  Unfortunately, it was found to craze
acrylics and polycarbonates.  It also  could not pass the heat stability tests designed for water dilutable
cleaners, which is a test not totally appropriate for a ready-to-use formulation such as Eagle Kleen™.  The
fluid was found suitable for full-scale demonstration trials where simple degreasing of metal and/or painted
surfaces was required. Independent material compatibility testing indicates that Eagle Kleen™ is a powerful
degreaser and, in some  cases, could dissolve polymeric materials used for gloves,  seals, gaskets, tank
construction plastics, and certain materials used for tubing and hoses.  However, acceptable alternatives for
these items are commonly available, such as neoprene gloves, Viton or Teflon gaskets and seals, and high-
density polyethylene (HDPE) tanks and containers.

HTCI describes Eagle Kleen™ as "non-toxic." However, limited aquatic toxicity testing, as part of the MIL-
PRF-87937D evaluation, indicated that Eagle Kleen™ was toxic to some aquatic life forms even at low
concentrations. Additional toxicity tests, where Eagle Kleen™ was evaluated against a typical solvent and a
typical alkaline cleaner, indicated that all three were toxic to aquatic life forms at typical use concentrations.

Site  Testing. Full-scale demonstration trials were held at Robins AFB and at Hill AFB.  Brief tests were also
conducted at Ransohoff, Inc., an immersion parts washer manufacturer. Details of those demonstrations are
summarized below.

Robins AFB.  The Robins AFB vehicle shop demonstration included side-by-side testing of 3-inch-diameter
steel wheel bearings cleaning with the shop's regular solvent, Safety Kleen PRF 680 Type II hydrocarbon
degreaser, and with Eagle Kleen III™ degreaser.  The initial assessment, using actual wheel bearings removed
from base vehicles for routine maintenance, showed that there was little or no difference in the appearance of
the cleaned parts, regardless of the degreaser used.  The following characteristics were noted for Eagle
Kleen™:

       •   In general, the level of cleaning was adequate, but on an individual part basis, the
           performance was either equal to or slightly inferior to the hydrocarbon degreaser.

       •   Cleaning times using Eagle Kleen™ were approximately 50% longer for a part of
           similar size, shape, and type of contamination than using  Safety Kleen.
                                             IX

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       •   The degreaser had an odor that was objectionable to some operators.

       •   Parts felt dramatically more slippery in gloved hands, until the parts were rinsed with
           water.

The Vehicle Shop manager indicated that Eagle Kleen™ may not be cost-effective due to the longer cleaning
time that was required. For Eagle Kleen™ to be economically attractive, its base cost, handling cost, and
disposal costs would have to be lower, and/or its lifetime would have to be much longer than that of a
traditional solvent.

HillAFB. The demonstration at the Hill AFB GTE shop included side-by-side testing of a variety of GTE
parts cleaned  in the shop's automated RAMCO system. The shop used hot alkaline cleaning (Turco 6849),
water rinsing, and drying operations.  Many of the parts that were degreased at the GTE shop had heavy
carbon contamination. All had some degree of oil and/or grease contamination too.  The  initial assessment
showed that Eagle Kleen™ was less effective than Turco 6849.  The following characteristics were noted for
Eagle Kleen™:

       •   The operators reported that Turco 6849 removed the oil, grease, and carbon deposits;
           in contrast, Eagle Kleen™ removed most of the oil and grease, but was not effective
           at removing heavy carbon contamination.

       •   Test results indicated that operating Eagle Kleen™ at an elevated temperature (90-
           120°F) did not significantly improve performance; however, the change in
           temperature dramatically increased complaints related to odor.

       •   The two-week testing schedule was stopped after three days due to these issues.

Ransohoff. Tests at the Ransohoff, Inc. company in Cincinnati, OH included testing of selected, condemned
GTE parts cleaned using the Ransohoff, Inc. ultrasonics-enhanced system. A few of the parts showed some
carbon contamination, and had some degree of oil contamination. The initial assessment showed that a 5%
solution of Eagle Kleen™ with ultrasonics was extremely effective at removing the carbon deposits. The
following characteristics were noted for Eagle Kleen™:

       •   A dilute solution of Eagle Kleen III can be used in an ultrasonically enhanced parts
           washer to remove a substantial portion of carbon deposited on typical GTE shop
           parts.

       •   Cleaning appeared good, but was not complete.  A longer immersion time or hand
           cleaning might be required for complete carbon removal.

       •   The solution was not effective at removing grease/heavy oils.

       .   The Eagle Kleen III odor was  detectable but not overpowering, even with the top off
           of the cleaning unit. It is anticipated that the odor problem would be reduced if the
           top is open for only a few minutes per hour. However, some type of ventilation
           would be required in most applications.

Engineering  Cost Assessment.  The assessment indicated that the installation of a new ultrasonic
cleaning bath and the use of Eagle Kleen III results in an attractive payback of <3.3 years depending
on the cost for handling, treatment and disposal of the spent alkaline cleaner and spent rinse.

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                                 1.0 PROJECT DESCRIPTION
1.1    General Overview
The purpose of this Task Order was to evaluate Hydra-Tone Chemicals, Inc.'s (HTCI's) Eagle Kleen™
biodegradable degreaser as a potential substitute for conventional alkaline cleaners and hydrocarbon
cleaning solvents. Battelle conducted the evaluation under contract agreement with the National Risk
Management Research Laboratory (NRMRL) of the United States Environmental Protection Agency
(EPA). The approach of the NRMRL is to work with industry to provide technical and economic infor-
mation about new technologies for potential users so that they can achieve voluntary reductions in the use
and release of hazardous substances. The intent of EPA's approach is to encourage the use of less-
polluting substances in industrial operations.

HTCI introduced Eagle Kleen™ as an environmentally friendly degreasing agent, designed to provide the
same degreasing effect as conventional alkaline cleaners and non-chlorinated cleaning solvents used in
immersion tanks and spray washers.  HTCI's product literature indicates that Eagle Kleen™ is completely
biodegradable, non-hazardous, non-flammable, non-toxic, non-corrosive, and safe-to-use. Eagle Kleen™
is a naturally derived product based on seed oil.  It is a ready-to-use (RTU) liquid degreaser designed with
a special methyl-ester micro-emulsion formulation. This unique solvent technology is intended to be used
for the removal of grease, cutting fluids, motor and transmission oils, hydraulic fluids, and other surface
contaminants.  Eagle Kleen™ has a flash point greater than 200°F (93°C) and is considered non-
flammable.  Eagle Kleen does not contain Superfund Amendment and Reauthorization Act (SARA) 313-
listed extremely hazardous substances or California Proposition 65 components. HTCI recommends that
Eagle Kleen™ should be used at temperatures above SOT (10°C) to provide adequate parts cleaning.

1.2    Goals
The goal of this NRMRL project is to validate the cleaning efficiency and economics of using HTCI's
Eagle Kleen™ biodegradable degreaser as an alternative to (and potential substitute for) hydrocarbon-
solvent degreasers and heated alkaline immersion cleaners. Such degreasers have been introduced in the
parts cleaning industry as replacements for organic solvents, most of which are ozone-depleting
substances and/or are targeted for reduced usage by EPA's 33/50 program (EPA, 1999).

Data were tracked on cleaning efficiency, bath performance, cleaning time, and working conditions when
using each fluid. By comparing these data, the suitability of Eagle Kleen™ as a replacement fluid in
these applications was assessed. The following three general issues were addressed:

       1.  The proposed new technology/methodology must be effective in performing the
           process function that it is intended to replace.

       2.  There must be a significant, measurable reduction in the quantity of waste hazard
           (pollutant) produced and in the level of hazard produced.

       3.  The economics of the alternative technology must be quantified and compared to the
           economics of the existing technology.

The consideration of each issue is critical to recommending the new technology as a feasible alternative to
the existing technology. The site testing task was designed to address items 1 and 2, and gather informa-
tion to evaluate item 3.

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1.3    Demonstration/Report Organization.
The Battelle Program Manager for this project was Dr. Bruce Alleman. Dr. Alleman was responsible for
all technical requirements and was supported by Dr. Bruce Sass who served as the Battelle Task Order
Leader. Dr. Sass maintained regular telephone communication with the U.S. EPA Task Order Manager
(TOM), Mr. David Ferguson. Ms. Sara Kuczek was responsible for preparing the QAPP, supervising the
laboratory effort (Task 1), and data reporting. Mr. Nick Conkle was responsible for Site Testing (Task 2)
and the Engineering Cost Assessment (Task 3).  The Field Evaluation Integration (Task 4)  was
eliminated. Ms. Betsy Cutie was the Battelle QA  Officer who monitored project performance with regard
to the QAPP.

This report is organized in the following sections:

       1.   Task 1: Analytical Testing
       2.   Task 2: Site Testing
       3.   Task 3: Economic Cost Assessment
       4.   Conclusions
       5.   References
       6.   Appendices.

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                            2.0 TASK 1 - ANALYTICAL TESTING

Prior to laboratory testing, Battelle consulted stakeholders at Robins Air Force Base (AFB) and Hill AFB
to discuss immersion and spray degreaser requirements for military parts cleaning. The purpose of these
discussions was to gain approval and learn about cleaning and materials compatibility requirements that
could be used as criteria with which to measure the performance of the different cleaning materials and
methods, and to form a direct way of comparing conventional cleaners with Eagle Kleen™.  The
appropriate cleaning and materials compatibility requirements are contained in MIL-PRF-87937D
("Performance Specification: Cleaning Compound, Aerospace Equipment").  It is attached as Appendix
A. The purpose of Task 1 was to demonstrate Eagle Kleen's™ ability to meet the criteria listed in MIL-
PRF-87937D.  Testing was to proceed at Hill AFB only if Eagle Kleen™ was comparable to or surpassed
the specification standards or requirements.  No specific prequalification testing was required at Robins
AFB's Vehicle Shop, but the corrosion testing results along with the other analytical tests provided by
this specification provided valuable information.

Degreasers used by the United States Air Force (USAF) must conform to MIL-PRF-87937D and, in some
cases, MIL-C-29602 or MIL-PRF-85570 to comply with the Process Orders and Technical Orders
dictating repair and maintenance of F-15, F-16, C-5, C-17, C-130, and C-141 aircraft component parts.
To facilitate the timely completion of this study, Battelle tested Eagle Kleen's™ performance on all
requirements outlined in MIL-PRF-87937D with the exception of long-term storage stability. Due to the
scheduling of the demonstration, this was not required because the material was not stored for longer than
a few months. To meet MIL-PRF-87937D, Battelle completed the material qualification requirements
tests listed for Type IV cleaners. Battelle managed the subcontracted analytical tests, performed quality
assurance (QA)/quality control (QC) assessments, and performed pre-testing (QA/QC of sample) in its
laboratories. Cleaning efficiency testing was part of the MIL-PRF-87937D series of tests, as described in
Section 4.5.21 in MIL-PRF-87937D. Some qualifying cleaning tests were performed by Battelle prior to
the on-site demonstration at Robins AFB in order to assess efficiency prior to final results being available
from the certification testing. Table 1 provides details on the MIL-PRF 87937D testing performed by
Scientific  Materials International, Inc. (SMI).

The  collection of test coupons/materials and conduct of laboratory testing required 2 months for each
formulation tested. Per SMI's instructions, 3 gallons, supplied in plastic containers meeting DOT UN
1H1  as required by 49 CFR 178, were required to test per MIL-PRF-87937D.  (Note: It is possible that
Eagle Kleen™ could qualify as a Type II degreaser, a Water Dilutable Cleaning Compound, but it was
felt that it would be appropriate to test it as a Type IV degreaser for these applications.)
                      Table 1. Subcontractor for MIL-PRF-87937D Testing
       Laboratory
         Address
                 Certifications
    Scientific Materials
    International, Inc.
    (SMI)
12219 SW 131 Avenue
Miami, Florida 33186-6401
Contact:  Pat Viani
(305) 971-7047
"Internationally recognized as an authorized facility by
airframe and engine manufacturers throughout the
world, including the U.S. Air Force and U.S. Navy."
www. smiinc .com

"We adhere to standard laboratory practices and utilize
certified standards for our meters and instruments where
applicable.  We have military inspections which
authorize our laboratory to perform testing of aerospace
maintenance chemicals in accordance with military
standards." Patricia Viani in an email to Sara Kuczek
dated 20 February 2004.

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The sample of material was to be collected from HTCFs readily available stock of Eagle Kleen™to
assure that a valid subset of the material was obtained and was not specialized for this test. Due to early
failures, HTCI was required to alter Eagle Kleen's™ formulation and specialized batches were tested.
This process of change is detailed later in the report. All material tested was sent to Battelle for quality
assurance/
quality control (QA/QC) prior to sending the material on to SMI for certification.

By performing QA/QC on the sample at Battelle prior to shipment to SMI, it was possible to ensure that
the product submitted for certification fell within the acceptable production ranges and appearances.
When the product failed these tests, an additional sample was requested from HTCI that met the
specifications prior to commencement of testing.

Per MIL-PRF-87937D, the tests described in performance specification were conducted (see Table 2).
HTCI supplied data on the  flash point, pH, toxicity, constituents, appearance, volatile organic compounds
(VOCs), drying point, and total immersion corrosion. These data were used for comparison when
evaluating the results from the SMI testing of MIL-PRF-87937D, but after the necessary formulation
adjustments, it was found that the data previously supplied by HTCI were not reflective of the current
formulation. HTCI certified that the composition of Eagle Kleen™ met the non-testable requirements
(i.e., workmanship) outlined in MIL-PRF-87937D.

2.1     Initial Laboratory Evaluation
A laboratory experiment was conducted to test the original formulation of Eagle Kleen™ (designated
Eagle Kleen I) for effectiveness as a degreasing agent.  Contaminated bearings that were to be discarded
were obtained through Robins AFB Vehicle Shop contacts.

Three contaminated wheel  bearings (two ~3 inches in diameter and one ~2.5 inches in diameter) were
obtained.  One was placed in a beaker and submersed in Eagle Kleen™ for approximately 25 minutes.
During that time there was little change to the solution color.  Some grease may have been loosened in the
inner  bearings, but no apparent degreasing was observed (see Figure 1).

Because the part was not satisfactorily degreased by immersion, it was sprayed with virgin Eagle Kleen™
for 5 minutes at a very low rate (130 mL/min); this had some minor cleaning effect. The part was me-
chanically agitated by hand in the solution, which resulted in additional cleaning. The part then was
sprayed with water and wiped with a paper towel, which left yellow to brown deposits on the towel.
There was evidence of heavy grease deposits on the back side of the wheel bearing. After cleaning, the
solution looked yellow.

The wheel bearing surface  remained slippery and the cleaning results did not look impressive. The dried
part was allowed to sit in a hood on a clean paper towel for later observation.  Upon returning, the part
had no rust, but was still very slippery due to either the residual grease or Eagle Kleen™ on the part.

A second wheel bearing initially was sprayed with virgin Eagle Kleen™ at a low flowrate, but this
activity showed little grease removal. The part still showed evidence of grease deposits on the back side
and the surface was slippery. It was determined that the part had not been cleaned adequately, so the
bearing was returned to the cleaning solution and re-inspected after 30 minutes of soaking. After
mechanically agitating the bearing in the bath, spraying with water, and drying with a paper towel, the
part looked significantly better and nearly all the grease deposits were gone (see Figure 2). The surface
was not slippery and in general the cleaning looked acceptable. The part was re-dipped in Eagle Kleen™,
rinsed in water, and allowed to sit on a paper towel for an  hour and then observed; there appeared to be
some  evidence of spot rusting.

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Table 2. Analytical Testing Per MIL-PRF-87937D
Specification
MIL-PRF-87937D,
Section 3. 4
MIL-PRF-87937D,
Section 3. 5
MIL-PRF-87937D,
Section 3. 6
MIL-PRF-87937D,
Section 3. 7
MIL-PRF-87937D,
Section 3. 8
MIL-PRF-87937D,
Section 3. 9
MIL-PRF-87937D,
Section 3. 10
MIL-PRF-87937D,
Section 3. ll(b)
MIL-PRF-87937D,
Section 3. 12
Title
Compositional
Assurance
Chemical
Properties
Physical
Properties
Effect on Metals
Non-volatile
Residue
pH
IR
Insoluble Matter
Flash Point
Emulsion
Wet Tape Adhesion
Cleaning Efficiency
Residue Rinsibility
Heat Stability
Cold Stability
Hydrogen
Embrittlement
(Cadmium and Ion
Vapor Deposited
[IVD] Plated Bars)
Total Immersion
Corrosion
Low-Embrittling
Cadmium
Effects on
Unpainted Metals
Sandwich Corrosion
Wet Tape Adhesion
Effect on Painted Surfaces
Stress crazing of MIL-PRF-5425 and
MIL-PRF-25690 (Type A and C) acrylic
plastics
Stress crazing of polycarbonate plastics
Long term storage
Hot dip galvanizing corrosion
Test Method
Test described in MIL-PRF-87937D,
Section 4. 5.1
Test described in MIL-PRF-87937D,
Section 4.5.3, ASTME 70
Test described in MIL-PRF-87937D,
Section 4.8.2
Test described in MIL-PRF-87937D,
Section 4. 5.2
Test described in MIL-PRF-87937D,
Section 4.5.7, ASTMD 56
Test described in MIL-PRF-87937D,
Section 4. 5. 8
Test described in MIL-PRF-87937D,
Section 4. 5.27
Test described in MIL-PRF-87937D,
Section 4. 5.21
Test described in MIL-PRF-87937D,
Section 4. 5. 4
Test described in MIL-PRF-87937D,
Section 4. 5. 5
Test described in MIL-PRF-87937D,
Section 4. 5. 6
Test described in MIL-PRF-87937D,
Section 4.5.9, ASTMF 5 19
Test described in MIL-PRF-87937D,
Section 4.5. 10, ASTMF 483
Test described in MIL-PRF-87937D,
Section 4.5.11, ASTMF 1111
Test described in MIL-PRF-87937D,
Section 4.5. 12, ASTMF 485
Test described in MIL-PRF-87937D,
Section 4.5. 16, ASTMF 1110
Test described in MIL-PRF-87937D,
Section 4. 5.27
Test described in MIL-PRF-87937D,
Section 4.5. 13, ASTMF 502
Test described in MIL-PRF-87937D,
Section 4.5. 14, ASTMF 484
Test described in MIL-PRF-87937D,
Section 4.5. 15, ASTMF 484
Test skipped. Test described in MIL-PRF-
87937D, Section 4.5. 17, ASTMF 1104
Test described in MIL-PRF-87937D,
Section 4.5. 18, ASTMF 483

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                   Table 2. Analytical Testing Per MIL-PRF-87937D (Continued)
Specification
MIL-PRF-87937D,
Section 3. 13
MIL-PRF-87937D,
Section 3. 14
MIL-PRF-87937D,
Section 3. 15
MIL-PRF-87937D,
Section 3. 16
MIL-PRF-87937D,
Section 3. 3
MIL-PRF-87937D,
Section 3. 3. 4
Title
Workmanship
Effect on polysulfide sealants
Rubber compatibility
Effect on polyimide insulated wire
Toxicity
Biodegradability
Test Method
Certified by manufacturer
Test described in MIL-PRF-87937D,
Section 4.5.19, ASTM D 2240
Test described in MIL-PRF-87937D,
Section 4.5.20, ASTM D 2240
Test described in MIL-PRF-87937D,
Section 4. 5.26
Percent survival will be recorded for
Pimephales promelas and Ceriodaphnia
dubia at 1, 10, 50, and 100 ppm
concentrations
Test described in MIL-PRF-87937D,
Section 4.5.22, 40 CFR, Part 796.3 100
(a)   All listed analytical tests must be passed in order for the on-site demonstration to proceed. Due to this, all tests
     are considered critical in this phase of the program.
(b)   Long-term storage was not tested.
                        Figure 1.  Bearing Inspection after Initial Immersion

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                              Figure 2. Bearing after Final Cleaning
At this stage, it appeared that Eagle Kleen™ would degrease a part effectively enough for a mechanic to
determine if it had a major defect that would require replacement. It also appeared that the part would be
clean enough for repacking with grease for reinstallation. It was determined that this cleaning ability was
suitable for site testing to commence at Robins AFB, but because spot rusting was observed, the
demonstration was delayed until corrosion data were obtained.

2.2     Analytical Laboratory Testing - Eagle Kleen I
After the initial laboratory evaluation, the original formulation (i.e., Eagle Kleen I) was submitted to SMI
for MIL-PRF-87937D testing.  However, there was not an exact category match for testing the fluid.
Eagle Kleen™ solution is intended to replace dilutable fluids, but is supplied as a "ready-to-use" fluid not
a water-dilutable concentrate. Therefore, it was determined to test it as a "Type IV - Heavy Duty Water-
Dilutable Cleaning Compound" but to test it as ready-to-use (non-diluted) fluid when certain tests called
for the dilution of the test material. The fluid was submitted on July 14, 2004 and test results were
reported on September 20, 2004.  Table 3  summarizes the results. The full results are included in
Appendix B.

Eagle Kleen I did not pass MIL-PRF-87937D requirements.  Specifically, it failed the heat stability and
several metal corrosion tests. Because the material is intended to be used at room temperature, the team
determined that failing the heat stability tests was not a reason to reformulate and retest alone, but that
without passing the corrosion tests, the demonstrations could not proceed at either proposed location.

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                Table 3. Eagle Kleen I Analytical Test Results per MIL-PRF-87937D
MIL-PRF-87937D
Section Number
3.3
3.3.4
3.4
3.5
3.5.1
3.5.2
3.6
3.6.1
3.6.2
3.6.3
3.6.3.1
3.6.3.2
3.7
3.7.1
3.7.2
3.7.3
3.7.4
3.7.5
3.7.6
3.8
3.9
3.10
3.11
3.12
3.13
3.14
3.15
3.16
Test Name
Toxicity
Biodegradability
Compositional assurance
Results
Informational^
Conforms
Informational
Chemical properties
Chemical Requirements
Insoluble matter
Flash point
Emulsion characteristics
Wet adhesion tape test
% Cleaning efficiency
Terpene hydrocarbons
Residue rinsibility
Conforms
Conforms
Conforms(b)
Conforms(b)
Conforms(b)
Not applicable
Conforms(b)
Physical properties
Heat stability
Cold stability
Does not conform
Conforms
Rheology
Consistency
Spray ability
Not applicable
Not applicable
Effect on metals
Hydrogen embrittlement
Total immersion corrosion
Low-embrittling cadmium plate
corrosion
Effects on unpainted metal surfaces
Sandwich corrosion
Wet adhesion tape test
Effect on painted surfaces
Stress crazing of MIL-PRF-5425 and MIL -
PRF-25690 (Type A and C) acrylic plastics
Stress crazing of polycarbonate plastic
Long-term storage stability
Hot dip galvanizing corrosion
Workmanship
Effect on polysulfide sealants
Rubber compatibility
Effect on polyimide insulated wire
Does not conform(b)
Does not conform(b)
Does not conform(b)
Conforms(b)
Does not confornr '
Conforms(b)
Conforms(b)
Conforms(b)(c)
Conforms(b)(c)
Not performed
Conforms(b)
Was "certified" by manufacturer to
conform with requirements
Conforms(b)
Conforms(b)
Conforms(b)
(a)  Toxicity data is reported, but not as the widely accepted LD50 values. Additional toxicity testing was conducted.
(b)  Test performed using "as received" solution (ready-to-use) instead of dilution required by specification.  Results
    were not considered for qualified product listing (QPL).
(c)  Because of the high surfactant content of Eagle Kleen™, it should craze most stressed transparent plastics when
    subjected to extended exposure. Passing of these tests was unexpected and could not be duplicated in
    subsequent tests.

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2.3    Analytical Laboratory Testing - Eagle Kleen II
HTCI, along with their manufacturing partner, decided to reformulate the Eagle Kleen I degreaser by
adding a corrosion-controlling agent, and designated the resulting new formulation Eagle Kleen II. After
HTCI submitted a sample of the newly revised formulation, Battelle performed QA/QC tests in addition
to an additional cleaning test.  It then was decided by the evaluation team that, in order to reduce testing
time and conserve funds, only the tests that failed the initial analytical testing at SMI would be run on
Eagle Kleen II. If all passed, the full set of tests would be continued. The sample was submitted to SMI
on September 10, 2004 and the results report was received on September 30, 2004. Results are
summarized in Table 4. The SMI Report is included in Appendix C.
              Table 4. Eagle Kleen II Analytical Test Results per MIL-PRF-87937D
MIL-PRF-87937D
Section Number
3.7
3.7.1
3.7.2
3.7.3
3.7.5
Test Name
Results(a)
Effect on metals
Hydrogen embrittlement
Total immersion corrosion
Low-embrittling cadmium plate
corrosion
Sandwich corrosion
Conforms
Does not conform
Does not conform
Conforms
(a)  Test performed using "as received" solution (ready-to-use) instead of dilution required by specification.  Results
    were not considered for QPL listing.
Although this reformulation was an improvement over Eagle Kleen I, Eagle Kleen II continued to fail
some of the required tests. Of great significance, however, was the ability of this degreaser to pass the
hydrogen embrittlement test. Most, if not all, near neutral pH aqueous cleaners fail this test.  The ability
of the reformulated fluid to not embrittle high-strength steels made the degreaser unique and opened the
door for use in many aerospace applications.

2.4    Analytical Laboratory Testing - Eagle Kleen III
HTCI and their manufacturing partner decided to reformulate again, creating Eagle Kleen III  using a
different concentration of an alternative corrosion agent. After QA/QC testing by Battelle, a sample was
submitted to SMI for testing. Initial testing at HTCFs manufacturing partner and by Battelle  indicated
that this formulation should pass the tests that were not passed by Eagle Kleen II. Therefore, the entire
testing sequence at SMI was initiated.  SMI received the sample of Eagle Kleen III on December 1, 2004
and the results report was issued on March 7, 2005. Results are summarized in Table 5.  The SMI Report
is included in Appendix D.

Again, because the material is intended to be used at room temperature, the team determined that failing
the heat stability tests alone was not a reason to reformulate and retest.  However, the corrosion testing
passed and the fluid continued to meet the hydrogen embrittlement requirements, the changes to the
formulation appeared to cause stress crazing failures on the acrylic and polycarbonate plastics. To
confirm that the correct results were obtained, these tests were performed once more.  Eagle Kleen III did
not pass these repeat tests.

After consulting with the demonstration team, including representatives from Robins AFB and Hill AFB,
it was determined that the parts that were processed in each of their shops did not require much, if any,
processing of plastics, and the demonstrations could commence without passing these two tests.

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              Table 5. Eagle Kleen III Analytical Test Results per MIL-PRF-87937D
MIL-PRF-87937D
Section Number
3.3
3.3.4
3.4
3.5
3.5.1
3.5.2
3.6
3.6.1
3.6.2
3.6.3
3.6.3.1
3.6.3.2
3.7
3.7.1
3.7.2
3.7.3
3.7.4
3.7.5
3.7.6
3.8
3.9
3.10
3.11
3.12
3.13
3.14
3.15
3.16
Test Name
Toxicity
Biodegradability
Compositional assurance
Results
Informational1^
Conforms
Informational
Chemical properties
Chemical Requirements
Insoluble matter
Flash point
Emulsion characteristics
Wet adhesion tape test
% Cleaning efficiency
Terpene hydrocarbons
Residue rinsibility
Conforms
Conforms
Conforms(b)
Conforms(b)
Conforms(b)
Not applicable
Conforms(b)
Physical properties
Heat stability
Cold stability
Does not conform
Conforms
Rheology
Consistency
Spray ability
Not applicable
Not applicable
Effect on metals
Hydrogen embrittlement
Total immersion corrosion
Low-embrittling cadmium plate
corrosion
Effects on unpainted metal surfaces
Sandwich corrosion
Wet adhesion tape test
Effect on painted surfaces
Stress crazing of MIL-PRF-5425 and MIL -
PRF-25690 (Type A and C) acrylic plastics
Stress crazing of polycarbonate plastic
Long-term storage stability
Hot dip galvanizing corrosion
Workmanship
Effect on polysulfide sealants
Rubber compatibility
Effect on polyimide insulated wire
Conforms(b)
Conforms(b)
Conforms(b)
Conforms(b)
Conforms(b)
Conforms(b)
Conforms(b)
Does not conform*' c)
Does not conform*' c)
Not performed
Conforms(b)
Was "certified" by manufacturer to
conform with requirements
Conforms(b)
Conforms(b)
Conforms(b)
(a) Toxicity data is reported, but not as the widely accepted LD50 values. Additional toxicity testing was conducted.
(b) Test performed using "as received" solution (ready-to-use) instead of dilution required by specification. Results
    were not considered for QPL listing.
(c)  Because of the high surfactant content of Eagle Kleen™, it should craze most stressed transparent plastics when
    subjected to extended exposure.
                                               10

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 2.5    Analytical Laboratory Testing - Eagle Kleen III, Vapor Pressure
During laboratory evaluation of the Eagle Kleen™ formulations, it was noted that the odor from the fluid
was strong, even at room temperature. In addition, the evaluation team wanted to confirm that the fluid
was low to non-volatile, in order to avoid engineering control requirements and confirm that Eagle
Kleen™ was below the 7-mm Hg limit set under the Aerospace National Environmental Standards for
Hazardous Air Pollutants (NESHAP). The Air Force defines an aqueous cleaner as having greater than
80% water. As Eagle Kleen™ does not meet this criterion, it would be subject to the NESHAP
restrictions.

SMI was contracted to perform the "Test Method for Vapor Pressure of Petroleum Products (Reid
Method)", ASTM D 323.  This test was performed on the same fluid lot of Eagle Kleen III used for the
analytical testing described in Section 2.0, and the results are shown in Table 6. The Reid Vapor Pressure
of the fluid was determined to be less that 0.2 mm Hg at 20°C, which is less than the 7-mm Hg limit.
Therefore, Eagle Kleen™ was exempt from any VOC regulations set by the Air Force, and testing could
proceed.  The SMI test report on vapor pressure is included as Appendix E.
                    Table 6. Reid Vapor Pressure Results for Eagle Kleen III
                    Sample	Reid Vapor Pressure
               Eagle Kleen III    | <0.2 mm Hg at 20 °C
2.6    Material Compatibility Evaluation
While conducting the Robins AFB demonstration, it was determined that Eagle Kleen™ is not suitable
for use with or on certain types of polymers. A scrub brush used during the hand cleaning at the Vehicle
shop was left to lay in approximately !/2-inch of Eagle Kleen III degreaser over the weekend. Upon return
to the shop the following week, employees found that the scrub brush had "melted" (see Figure 3 for the
"before" photograph and Figure 4 for the "after" photograph).

At this point, Russ Markesbery of HTCI supplied the team with a list of materials that should be
compatible with Eagle Kleen™.  This list was not comprehensive and additional testing was deemed
necessary. Testing at Battelle found that the handle was composed of either a copolymer of polystyrene
and methylene (copolyfstyrene-methylene]) or a copolymer of styrene and polyethylene. Although the
spectrum more closely matched the first copolymer listed, the second is a much more widely available
material.  Because this fluid would be used in conjunction with seals, hoses, pumps, and various personal
protective equipment (PPE), Battelle completed a short, non-comprehensive study of material compat-
ibility. Materials that may be used with, or cleaned by, this fluid were chosen for this study. Results are
detailed in Table 7.

After reviewing this study, it became apparent that if Eagle Kleen™ were to be used in a large-scale
setting, care would need to be taken to ensure the materials of construction for the equipment used in
conjunction with the fluid were compatible with Eagle Kleen™. In addition, the facility would need to
stress the importance of using the appropriate PPE for this task and set up a stringent replacement
schedule of said PPE. However, from the preliminary compatibility testing performed, it appears that
acceptable alternatives,  such as neoprene gloves, Viton or Teflon gaskets and seals, and high-density
polyethylene (HDPE) tanks and containers are readily available.
                                             11

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Figure 3. Handle Before Exposure to Eagle Kleen III
 Figure 4.  Handle After Exposure to Eagle Kleen III
                     12

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                        Table 7. Material Compatibility Analysis Results
Materials
Vinyl-acrylics
PVC
Tygon
Polycarbonate
SBR Rubber Sheet
Neoprene
Viton
Buna-N
EDPM
PVC/Tygon
Polyurethane
Silicone
Polycarbonate
Polyethylene (including
HDpeO
CPVC
Nylon
Phenolic
Fiberglass
Polyester
Polypropylene
PTFE (i.e., Teflon)
Delrin
Disclosed by HTCI
after Brush Incident
as being
Incompatible
X
X
X
X


















Incompatible
After an Hour of
Exposure




X
x(a)
x(a)
X
X
X












Incompatible
After 3 Weeks' of
Exposure










X
X


X







Initial Testing Did
Not Result in
Signs of
Incompatibility












X
X

X
X
X
X
X
X
X
    (a) Minor discoloration of solution after one hour exposure but no evidence of performance
       deterioration.
2.7    Analytical Laboratory Toxicity Testing - Eagle Kleen III

The toxicity test run as part of the initial MIL-PRF-87937D screening indicated that Eagle Kleen™ may
not be as "non-toxic" as originally indicated by the manufacturer.  Specifically, after 24 hours at only
10 ppm, no fathead minnows remained alive in the Eagle Kleen solution (see Tables 8 and 9). This
indicated that Eagle Kleen™ has some toxicity even at low levels.

A data search was conducted to determine the toxicity in relation to this information, but no results were
found that were in a comparable format.  Therefore, to make a fair comparison, LC50 data were collected
for Eagle Kleen III and for the other cleaners used in this study, Safety Kleen PRF 680 Type II (hydro-
carbon solvent) and Turco 6849 (alkaline cleaner). In general,  LC50 values below 1,000 mg/L indicate a
toxic  substance; and, as noted in Table 10, all three cleaners have low LC50 figures, meaning they are
toxic to aquatic life; see Appendix F for details.
2.8
Conclusions
After the third reformulation, it was determined that although Eagle Kleen™ still did not pass all labora-
tory certification tests specified in MIL-PRF-87937D, it passed all except (1) stress crazing of acrylic
plastics and polycarbonate plastics, and (2) heat stability.  These results were deemed sufficient by the
evaluation team, Robins AFB, and Hill AFB to proceed with the demonstrations. In order to actually
                                              13

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certify Eagle Kleen™, a new category of degreaser must be added to MIL-PRF-87937D or another
specification written for it because it did not fall into an established category.

                         Table 8.  96-Hour Pimephales promelas Bioassay
Percentage of Fathead minnows (Pimephales promelas) Surviving
Concentration
1 ppm
lOppm
50 ppm
100 ppm
After 24 Hours
100
0
0
0
After 48 hours
100
0
0
0
After 96 Hours
100
0
0
0
                         Table 9. 48-Hour Ceriodaphnia dubia Bioassay
Percentage of Water Fleas Cladoceran
(Ceriodaphania dubia) Surviving
Concentration
1 ppm
10 ppm
50 ppm
100 ppm
After 24 Hours
90
50
0
0
After 48 hours
50
20
0
0
                Table 10. Aquatic Toxicity as Measured by Lethal Concentrations
Fluid
Eagle Kleen III (100%)
Safety Kleen PRF 680 Type II (100%);
hydrocarbon solvent
Turco 6849 (20%), alkaline cleaner
Turco Rust Bloc (4%), anti-rusting
compound
LC50, 48-hr
Daphnia magna (mg/L)
25
125
150
79,200
LC50, 96-hr
Pimephales promelas (mg/L)
30
>70,000(a)
225
33,500
(a)  The lighter-than water solvent floated on the surface, and this may have biased the results.

From initial laboratory evaluations, Eagle Kleen™ did appear to degrease, but did not seem to degrease
quickly or by immersion alone. From previous experiments, it did not immediately appear to be a signif-
icant improvement over traditional degreasers. Site demonstrations at Hill AFB and Robins AFB were
conducted to gauge its actual cleaning ability and cost effectiveness.

Areas of improvement and development still remain.  Eagle Kleen™ does not appear to be compatible
with all materials used in the construction of hoses, pumps, seals, and gaskets.  Eagle Kleen™ is a
powerful degreaser and, in some cases, could dissolve polymeric materials used for gloves, seals, gaskets,
tank construction plastics and certain materials used for tubing and hoses.  But, acceptable alternatives for
these items are commonly available, such as neoprene gloves, Viton or Teflon gaskets and seals, and
HDPE tanks and containers.

Limited aquatic toxicity testing with 100% Eagle Kleen III, as part of the MIL-PRF-87937D evaluation,
indicated that Eagle Kleen™ was toxic to some aquatic life forms even at low concentrations. Additional
toxicity tests, where Eagle Kleen™ was compared to a typical solvent and a typical alkaline cleaner,
indicated that all three were toxic to aquatic life forms at typical use concentrations.
                                             14

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                                 3.0  TASK 2 - SITE TESTING
3.1    Background
The Task 2 site demonstration took place at two primary locations: the Vehicle Shop of Robins AFB,
located at the Warner Robins Air Logistics Center of the U.S. Air Force; and the gas turbine engine
(GTE) Shop at Hill AFB, located at the Ogden Air Logistics Center. Two parts washers were used at
each demonstration location.  One was filled with the conventional cleaner and operated at standard
conditions, and the other was filled with Eagle Kleen™. By running two parts washers simultaneously,
side-by-side results were obtained allowing a direct comparison of cleaning performance.

The tests included cleaning approximately the same type and number of parts, having a similar degree of
contamination, through each bath under real world conditions.  Cleaning fluids from the parts washers,
and where applicable the rinse tanks, were sampled on a daily basis. At the Vehicle Shop the parts were
restricted to wheel bearings. In the GTE Shop a variety of parts, representative of normal parts processed
is the shop were evaluated. A limited number of condemned parts were used for off-site follow-on testing
(see Section 3.4).

Operating parameters, such as cleaning efficiency and bath life, were evaluated. A qualitative cleaning
evaluation score was assigned to each run for the conventional treatment and for Eagle Kleen™.  In Table
11, scores in red (1 and 2) were ranked as "unacceptable" cleaning, whereas those in green (3, 4, and 5)
indicated as acceptable. Critical measurements are listed in Table 12. Also, observations  on bath
cleanliness were made, and the pH was measured for the aqueous cleaner and rinse waters.

                              Table 11. Cleaning Score Description
Score
1
2
o
J
4
5
Grease Contamination Level After cleaning
Still very dirty
Not cleaned well; a lot of contamination still remains
Definitely contaminant present
Maybe some contaminant present, but fairly cleaned
Perfectly clean
                        Table 12. Critical Measurements for Site Testing
Critical Measurements
Number of parts cleaned
Number of parts needing reprocessing
Fluid efficiency
Bath condition
Fluid addition and replacement
Cost of fluid
Visual observation of bath sample for
cleanliness
Qualitative/
Quantitative
Quantitative
Quantitative
Qualitative
Qualitative
Qualitative
Quantitative
Qualitative
Measurement Time Basis
At time of degreasing
At time of degreasing
At time of degreasing, daily, and
weekly
Daily and weekly
As needed
Once during project
Weekly
                                             15

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3.2    Robins AFB Testing
The Vehicle Shop at Robins AFB processed a high throughput of 3-inch-diameter steel wheel bearings,
which were degreased using a traditional hydrocarbon-based solvent in a parts washer. This
demonstration study was structured for side-by-side testing of parts cleaning with the shop's regular
solvent and with Eagle Kleen™ degreaser.  This allowed the evaluation team, which consisted of
personnel from Robins AFB and Battelle, to compare the performance of both fluids under controlled
conditions. Information was tracked on cleaning efficiency, bath life (longevity), time for cleaning, and
other noticeable effects that would be of concern to shop staff. By comparing these data, the suitability of
Eagle Kleen™ as a replacement fluid in this application was assessed.

During the first week of testing (March 28-31, 2005), several different vehicle-shop mechanics were
asked to assess the performance of both Eagle Kleen™ and Safety Kleen™ (PRF 680 Type II
hydrocarbon degreaser) using three conventional parts washers set up for the demonstration (a parts
washer and an aqueous rinse washer were used for Eagle Kleen™, and  a single parts washer was used for
Safety Kleen™), see Figures 5 and 6.

The initial assessment used actual wheel bearings removed from base vehicles for routine maintenance.
Photographs of the bearings before and after cleaning with Eagle Kleen™ (Figure 7) showed that the
degreaser was effective at removing grease and oil. However, this study also showed that there was little
or no difference in the appearance of the cleaned parts, regardless of the degreaser used.

After conducting the side-by-side tests, the following characteristics were noted for Eagle Kleen™:

       •   In general, the level of cleaning was adequate, but on an individual part basis, the
           performance was either equal to or slightly inferior to the hydrocarbon degreaser;

       •   Cleaning times were approximately 50% longer for a part of similar size, shape, and
           type of contamination than using Safety Kleen;

       •   Eagle Kleen™ had an odor that was objectionable to some  operators;

       •   Parts felt more slippery in gloved hands, until the parts were rinsed with water.

The Vehicle Shop manager indicated that he was interested in the potential degreasing ability of Eagle
Kleen™, but that the product may not be cost-effective due to the longer cleaning time that was required
(he was quoted as saying "time is money"). For Eagle Kleen™ to be economically attractive, according
to the manager, its base cost, handling cost, and disposal costs would have to be lower, and/or its lifetime
would have to be much longer than that of a traditional solvent.

HTCI, the supplier of Eagle Kleen™, stated that the degreaser could solubilize grease and oil up to 23%
of its weight (e.g., 23 Ib of grease or oil could be solubilized in 100 Ib of Eagle Kleen™). This ratio of
contaminant to degreaser would be equivalent to cleaning hundreds, or even thousands, of parts, making a
true part-by-part test of this claim impractical in the time period allocated for the demonstration. To
overcome these constraints, an accelerated contamination protocol was  used, where both cleaning baths
were contaminated with heavy grease and heavy-duty motor oil, and testing was done to determine
cleaning effectiveness. Some of the same parts were contaminated and cleaned several times as part of
the assessment. This portion of the demonstration was conducted during the week of April 18-22, 2005.
                                             16

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Figure 5. Degreaser and Rinse Tanks for Eagle Kleen™ and Safety Kleen™ Bath
        Figure 6. Wheel Bearings Being Degreased with Eagle Kleen™
                                  17

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      Figure 7. Wheel Bearings Before (left) and After (right) Degreasing with Eagle Kleen1
To rank the cleaning efficiency of the two degreasing fluids, the scoring system noted in Table 11 was
employed. After cleaning each set of bearings, the cleaning performance was assessed and assigned a
score. Before testing began, the team decided that if a part received an overall score below 3.0, the
operator would need to perform additional cleaning for the part to be acceptable. After cleaning more
than 1,000 equivalent parts, cleaning scores ranged from 4.0, when the degreasers were fresh, to 2.5.  In
general, both degreasers were effective in removing heavy oils, transmission and hydraulic fluids, regular
lubricating oils, and grease. In general, it was found that Eagle Kleen™ has the ability to degrease a large
number of parts and, under normal use, would tend to have a very long bath life. However, the hydro-
carbon degreaser (Safety Kleen™) degreased a similar number of contaminated parts, and therefore also
can be said to have performed well in this study.  Based on results of the side-by-side comparison, it was
concluded that Eagle Kleen™ would not have a longer life than the traditional solvent degreaser (see
Figure 8).

At the conclusion of the testing program, the Vehicle Shop expressed interest in continuing to use Eagle
Kleen™ and moved the three parts washers to a different building (Building  148) where the shop main-
tained powered equipment, such as portable generators and tug trucks. Testing was not supervised at the
same level as was done in the Vehicle Shop. A preliminary assessment, based on a limited number of
tests, indicated that the mechanics in this area did not find the degreaser suitable for this equipment.  They
cited longer degreasing times as the main deficiency in Eagle Kleen™ and noted that the degreaser's odor
was a potential concern to shop staff.

A formal request for an Environmental Impact Analysis of Eagle Kleen™ was submitted to the Robins
AFB Environmental Management Department. The approval criteria included environmentally friend-
liness and cost-effectiveness as compared to the current solvent degreaser.  The application assumed that
rinse water containing Eagle Kleen™ (drag-out) and dissolved contaminants could be discharged to the
Robins AFB industrial wastewater treatment plant (IWTP). Discharge of spent Eagle Kleen™ to the
IWTP appears to be impractical and probably not allowed by the base. This would require the  spent
Eagle Kleen™, like the spent hydrocarbon degreaser, to be drummed for off-site disposal. Approval for
use at Robins AFB was not received.

A cost comparison between Eagle Kleen™ and the traditional solvent degreaser was not performed due to
the longer cleaning time, odor issues, and the unfavorable  review by the Building 148 shop.
                                             18

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Cleaning Score vs. Total Number of Equivalent Parts Cleaned
4 5 -,
A
ٕ3 El
o.a
O
o
V)
o) 3 -,
- 25
o z-°
0
1 5




" -V



0 200 400 600 800 1000 1200
Number of Equivalent Parts Cleaned




• Safety Kleen
-Water Baseline
^^ Pass/Fail Cut-off
• Eagle Kleen
Kleen)
2 per. Mov. Avg. (Eagle
Kleen)

   Figure 8.  Cleaning Score for Equivalent Number of Parts Cleaned Using the Two Degreasers


3.3    Hill AFB Testing
The evaluation at Hill AFB was conducted for one week, over the period September 12-16, 2005.  The
GTE shop degreases parts on a routine basis and installed an automated RAMCO system for degreasing,
rinsing, and drying operations  (see Figure 9). The shop's RAMCO degreasing system was used for
testing two types of degreasers. The normal cleaning tank was filled with Turco 6849 (prepared by
diluting 10 gallons of Turco 6849 to approximately 65 gallons of water). Another tank was filled with
Eagle Kleen™, which was prepared without dilution (see Figure 10).

Both tanks initially were heated to 145°F. However, the optimum temperature for Eagle Kleen™ was not
known, so the bath temperature for Eagle Kleen™ was controlled at approximately  90°F in an initial
series of tests and 120°F in a second series.  Results indicated increasing the temperature  did not
significantly improve performance; however, the change in temperature  dramatically increased
complaints related to odor.  A flow diagram illustrating the cleaning process during the demonstration is
shown in Figure  11.

Many of the parts that were degreased in the GTE shop had heavy carbon contamination. All had  some
degree of oil contamination and some also had grease contamination. During the evaluation, parts were
processed in the same manner as in normal operations.  Similar types of parts with comparable levels of
contamination were placed into steel baskets and prepared for cleaning.  Each basket of parts was inserted
into a cleaning tank for approximately 60 minutes, with mild agitation by circulating fluid.  Ultrasonic
energy was applied for approximately one minute in the Turco 6849 bath.  No ultrasonic energy was used
in the Eagle Kleen™ bath or its rinse tank. After the cleaning step, the baskets were transferred to a rinse
tank for 30 minutes,  and then dried for 30 minutes in air heated to 240°F.
                                             19

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              Figure 9. RAMCO Cleaning Line at Hill AFB GTE Shop
                     Figure 10. Eagle Kleen™ Degreaser Bath



Tank 9856
Eagle
Kleen





Tank
Turco



9855
6849



•\



Tank 9854
Rinse w/
Rust Bloc



i





Tank 9853
Rinse




i

i -\


Tank 9852
Dryer
Figure 11. Process Flow Diagram for Cleaning in the Hill AFB Gas Turbine Engine Shop
                                    20

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The number of baskets processed through each bath was recorded and the shop work load was divided
equally between the two degreasers.  Cleaning times were staggered to allow use of only one dryer. After
drying, the parts were allowed to cool and were examined side by side.  Several cleaning operators in the
GTE Shop were asked to evaluate the performance of Eagle Kleen™ against Turco 6849. The operators
reported that Turco 6849 removed the oil and grease, and nearly all the carbon deposits. In contrast,
Eagle Kleen™ removed part of the oil and grease, but was not effective at removing heavy carbon
contamination.  A comparison of heavily-carbon contaminated parts, after cleaning with the two
degreasers, is shown in  Figure 12.
      Figure 12.  Example of Air Inlet Housing Prior to Cleaning (left), After Degreasing with
               Turco 6849 (center), and After Degreasing with Eagle Kleen™ (right)
In general, tests at the GTE shop revealed the following about Eagle Kleen™:

       .   Removal of oil and grease tended to be equal to or slightly inferior to Turco 6849
           degreaser for lightly soiled parts.

       •   Eagle Kleen™ was not effective at cleaning carbon-contaminated parts.

       •   Parts cleaned using Eagle Kleen™ required more manual cleaning than Turco 6849
           after the 30-minute degreasing step for all types of contamination.

       •   The strong odor of Eagle Kleen™ was objectionable to the operators.  Operation
           without a ventilation system caused some operators to complain of headaches,
           irritation of mucous membranes, and light headedness.

After each basket of parts was processed, the cleanliness of each part was ranked on a scale from 0 to 5,
taking into account the appearance and feel (greasy/clean) (see Figure  13). Depending on the number of
parts requiring reprocessing, the scores were reduced accordingly (see Figure 14).  Parts that were
degreased with Eagle Kleen™ required reprocessing on a consistent basis. In total, it was concluded
based on these test results that Turco 6849 outperformed Eagle Kleen™.

Due to the odor issue and Eagle Kleen™'s ineffectiveness at cleaning heavy carbon-contaminated parts,
the  degreasing team decided to suspend the demonstration at the close of the first week (September 16,
2005).  Better ventilation, or respirators, would be required for future use of Eagle Kleen™ in this
operation.
                                             21

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  5 T
                                                   • Eagle Kleen     ATurco 6849
                                                     AA-
O

5 3
u
w

D)
ro
o 2

O
                                     4       5

                                    Cleaning Batch
                      Figure 13. Overall Cleaning Score
                                                    • Eagle Kleen    ATurco 6849
ro
o.

"o

o

Ł
                                     4       5

                                   Cleaning Batch
                   Figure 14. Parts Requiring Reprocessing
                                    22

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After the suspension of Eagle Kleen™ operations for the main degreasing area in the GTE shop, the
cleaning engineer indicated that the shop may be interested in considering Eagle Kleen™ for non-carbon
contaminated cleaning applications. He requested a quote form Hydra-Tone for a three-step cleaning
system to replace a PD-680 solvent cleaning application. HTCI and the shop engineer independently
pursued this option.

Additionally, the Plating Shop at Hill AFB expressed interested in considering Eagle Kleen™ for
replacing certain alkaline cleaning baths. The SMI materials compatibility data (per MIL PRF 87937D)
indicated that the fluid should be compatible with these application needs.  The plating shop also explored
this option with HTCI.

The tests in a standard parts washer, without ultrasonic energy, indicated that Eagle Kleen™ was effective
in removing oil and grease but not for removing heavy carbon deposits.

Subsequent tests in November 2005 and March 2006 indicated that such carbon deposits could be
removed when a diluted solution (5% Eagle Kleen™ and 95% water) were used in an appropriate
cleaning bath.

After these tests, the cleaning engineer in the GTE Shop expressed renewed interest. A major driving
force was economics.  The conventional alkaline cleaner contains chelating agents.  Because of the
chelating agent's deleterious affect on metals precipitation at the Hill  AFB IWTP plant, the IWTP staff
required that all degreaser solutions and rinse water be drummed, and transported to their site for
specialized treatment.  The expense of pursuing this path made a non-chelating agent degreaser especially
attractive, so an Engineering Cost Assessment was performed (see Section 4.0).

3.4     Ransohoff Testing

Once primary site demonstration testing was done, additional testing was conducted at Ransohoff, Inc., a
manufacturer of parts cleaners, located in Cincinnati, OH, to determine whether a diluted solution of
Eagle Kleen III in an ultrasonic-enhanced parts washer could remove  carbon deposits and/or oil and
grease from  parts. First,  on November 2, 2005, a series of cleaning tests were performed on condemned
parts obtained from Hill AFB using a 100% solution of Eagle Kleen III.  The tests were run using an
unagitated 5.6-gal Ransohoff HT-1212 heated tank operated at 25 kHz with a 600-watt density.  Initially,
the results indicated showed poor de-carbonizing.  However, after dilution to 5% and operation at 120°F,
good (in some cases dramatic) carbon removal was achieved with immersion times ranging form 5 to 15
minutes.

Then, on March 14, 2006, tests were conducted on parts obtained from Hill AFB to gather additional data
operated at similar conditions.  The parts were too large to fit in the small lab unit, so an available
"Grease Monkey" CLASSIC 3523 Blackstone~Ney unit (sold by Ransohoff, Inc.) was adapted for the
tests (see Figure 15). The unit dimensions were 35 inches long, 23 inches wide, and 13 inches deep, with
built-in 40 kHz transducers, and was operated at 25 kHz and a 2000-watt density. However, operation at
a more aggressive frequency (25 kHz) was desired, so two portable, rectangular transducers were inserted
into the unit. The unit was filled with distilled with 120°F water, and two gallons of Eagle Kleen III were
added and allowed to warm up  (see Figure 16). Results with 5% Eagle Kleen™ at 120°F and  15 minutes
immersion times indicated dramatic removal of encrusted grease and  carbon for some parts; however, the
dilute Eagle  Kleen™ solution was not effective at removing oils and grease.
                                             23

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           Figure 15.  "Grease Monkey" CLASSIC 3523 Blackstone~Ney Parts Washer
                      Figure 16. Parts Washer after Eagle Kleen1 V1 Added
In an attempt to allow a better evaluation of the effectiveness of Eagle Kleen™ a fan assembly along with
a different part (some type of housing) were submerged and suspended over the solution (see Figure  17).
The fan assembly after 15 minutes showed a dramatic removal of the black coating. On the front, there is
a clear demarcation of where the fan was immersed in the cleaner, and in this area the surface looks very
clean (see Figure 18). The area cleaned is free of the black deposit.  Another view, showing the dramatic
cleaning achieved, is shown in Figure 19. On the rear side, where the fins are observed, it shows the
surface substantially cleaned, but not totally (see Figure 20).  This photo also shows an area that was not
submerged, and is still completely covered with the dark brown/black substance.
                                            24

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Figure 17. Parts Partially Suspended in Cleaning Bath
Figure 18.  Top View of Fan Assembly After Cleaning
                      25

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Figure 19. Front View of Fan Assembly after Cleaning
       Figure 20. Rear View of Fan Assembly
                      26

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In general, tests at the Ransohoff facility included the following:

       •   A dilute solution of Eagle Kleen III can be used in an ultrasonically enhanced parts
           washer to remove a substantial portion of carbon deposited on typical GTE parts.
       •   Cleaning appeared good, but was not complete. A longer immersion time or hand
           cleaning might be required for complete carbon removal.
       •   The solution was not effective in removing grease/heavy oils.
       •   Eagle Kleen III odor was detectable, but not overpowering even with the top off the
           cleaning unit.  Odor when the top was open only a few minutes per hours would be
           less. However, some type of ventilation would probably be required in many
           applications.

A tank arrangement for Hill AFB GTE-parts cleaning was devised based on the test results.  It consisted
of the five-step degreasing and carbon removal set up presented in Table 13. Russ Markesbery indicated
that he had proposed a similar tank configuration to Jeff Powell at Hill AFB. Photos of the Agisonic
AG-30 are provided on Figures 21 and 22.

                    Table 13. Aqueous Cleaning Tank Operating Conditions
Step
1
o(a)
3
4
5
Aqueous Concentration
100% Eagle Kleen III
5% Eagle Kleen III in Water
4%RustBlocinWater(b)
Water
Dryer
Temperature (°F)
120
120
150
150
200
Duration (minutes)
30-60
15
30
30
60
Other
Expect bath life: 4 to
8 weeks
Ultrasonics



(a)  All other units could employ the existing RAMCO line cleaning tanks.  The ultrasonics would be conducted in a
    new 80-gallon, Blackstone~Ney Agisonic AG-30 agitated, parts cleaner.
(b)  Rust Bloc may not be needed, but because Hill AFB is comfortable with its use, it was included in this process
    configuration.
                          Figure 21.  Agisonic AG-30 Shown from Front
                           (Note: the lid is set off to the right of the tank)
                                             27

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Figure 22. Agisonic AG-30 Looking Down into Basket
     (Note: the tray is in the parts-loading position)
                      28

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                      4.0  TASK 3 - ENGINEERING COST ASSESSMENT

Task 3 is an Engineering Cost Assessment (ECA) designed to evaluate the functional, financial, and
Environmental, Safety, and Occupational Health (ESOH) performance of Eagle Kleen™ based on infor-
mation obtained at Hill AFB.  The calculations were made using degreaser costs from Hill AFB and
HTCI, equipment costs from Ransohoff Inc., and engineering estimates.  (Because the Eagle Kleen™
degreaser was not found to be an acceptable replacement for the hydrocarbon solvent degreaser, no ECA
was prepared for Robins AFB.)

The baseline ESOH and cost data for the conventional, alkaline immersion degreaser were collected by
Battelle engineers during the Hill AFB demonstration task. Operating costs (labor, materials, energy) for
industrial processes were difficult to collect, and were assumed to be the same for the conventional and
Eagle Kleen™ degreasers.

Similarly, environmental treatment costs associated with a small operation or a process within a larger
industrial facility also were difficult to obtain; engineering estimates were used to estimate wastewater
collection, handling, and treatment for the conventional degreaser.  (Note: the alkaline cleaner contains
chelating agents and requires special collection and treatment, whereas the chelating-agent free Eagle
Kleen™ can be discharged directly to the IWTP.)

Most industrial facilities track environmental costs at an aggregate level and rarely for a specific
operation. The safety and  occupational health profile of Eagle Kleen™ indicated ventilation was required
to provide a similar profile as the alkaline cleaner.  The ESOH evaluation included review of the material
and safety data sheets (MSDS) and the physical and chemical properties of the degreasers. The
assessment of their workplace impacts, based on aquatic toxicity, corrosivity, inhalation, skin contact, and
flammability during operating conditions of the cleaning process, indicated similar impact should be
expected once ventilation was installed.

The ECA included a list of assumptions, and appropriate extrapolations are documented for data gaps
from the baseline data collection process. The assumptions were based on direct interviews with the shop
floor workers and supervisors.

The ECA assumes that three of the four cleaning tanks, and the dryer, from the RAMCO system will be
utilized in the new system. Only one new unit and ventilation for the two cleaning tanks, are included in
the capital costs estimate. The assessment also includes a payback period for transitioning from
conventional degreasers to Eagle Kleen™.

The assessment factors are noted in Table 14. The cost for handling, treatment and disposal of the spent
alkaline cleaner and spent rinse could not be determined and was estimated.  Because this cost was a
major contributor to the positive cash  flow projected, this value should be determined.  A sensitivity
analysis was performed varying the drummed waste handling and disposal fee (see Table 15).  Even with
a relatively conservative $100/drum handling fee, the payback is only 3.2 years.  Under the  base case,
where a rate of $150/drum was assumed, the payback is 2.2 years.
                                             29

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                                  Table 14.  EGA Assessment Factors
No.
Item
Information
      Project Title
              Replacement of Alkaline Cleaner with Chelating Agent-Free Biobased Cleaner
      Project Description
              This effort will qualify a new cleaning tank and alternative degreaser in the GTE
              shop.  Implementation will improve degreasing and carbon removal performance,
              reduce waste generation, eliminate the discharge of chelating agents to the IWTP,
              and lower operating costs.  Project duration is one-year and will start with the
              requirements definition phase that will include a 1-week on-site technology
              verification task that will help develop the design package for the new degreaser
              system.  A new degreasing tank with an improved ultrasonic generator will be
              integrated into the existing RAMCO small-parts degrease line in the GTE shop.
              The equipment, installation in Building 238 at Hill AFB, training, and performance
              evaluation will be completed during FY07.	
      Justification
              This project could provide significant reductions in waste generation: 2 IK gal/yr.
              of wastewater would be avoided.  Also chemical and water usage would be reduced:
              1100 gal/yr. of Turco 6849 alkaline cleaner, and 21K gal/yr. of fresh water.  Waste-
              waters from the current operations contain chelating agents and require transport to
              the IWTP in carboys and special treatment.  Substitution with Eagle Kleen III
              degreaser would eliminate the special handing requirements allowing the rinse
              water to be discharged directly to  the industrial sewer.  This will reduce handling
              labor and paperwork while ensuring un-interrupted metals precipitation in the
              IWTP.  Additionally, the longer service life possible with Eagle Kleen™ will allow
              less frequent cleaning of the tanks, labor cost savings, and reduce degreaser
              chemical requirements and costs.  Drivers: TRI, performance, and cost reduction.
      Current Process
      Description
              Small GTE parts are subjected to 1 hour of degreasing in two stages (30 minutes
              each) of hot degreasing (145°F) using Turco 6849 alkaline cleaner. Each part is
              hand cleaned after the first stage. The parts are then rinsed for 1 hour in two hot
              (145°F) aqueous rinse tanks (30 minutes each) fortified with Rustbloc rust inhibitor.
              The degreased parts are then sent to a dryer.  In the current degreasing and rinsing
              operations, significant quantities of alkaline cleaner and inhibitor are consumed.
              Turco 6849 contains several compounds listed as hazardous materials.	
      Implementation
      Project Description
      and Budget
              Total Project Cost: $200K
              Requirements Definition & Design Package: $15K
              Technology Verification (1 week) using Rented Equipment (on actual parts): $40K
              Technology Transfer: $100K (based on $68K of equipment and $22K for
              installation)
              Technology Validation 1-month (cleaning performance): $45K.

              Description of tasks:
              •    The design package and specifications will be developed as part of the Re-
                   quirements definition phase of the task. A test plan will be produced for
                   1-week onsite technology verification on serviceable parts. The results will
                   help develop the design package for a full  scale unit to be installed in the GTE
                   shop. The  1-week technology verification will demonstrate the effectiveness
                   of the integrated degreasing equipment and solvent.
              .    Technology Transfer includes the purchase and installation of a new ultrasonic
                   parts-cleaner, reconfiguration of the existing RAMCO cleaning and rinse
                   tanks, and the addition of a ventilation system. It also includes training and
                   integration of the new unit into the shop-floor cleaning operations.
              .    Technology Validation will follow the operation of the equipment to ensure it
                   is meeting the cleaning specifications.  It will include a final report outlining
                   the system performance.
                                                 30

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                          Table 14. EGA Assessment Factors (Continued)
No.
Item
Information
      Costs and Savings*
             Current Annual Environmental Costs (~3 IK gal/yr. wastewater treated @ $15/Kgal;
             570 drums/yr of drummed waste @ $150/drum) = $86K

             New Annual Environmental Costs (~10K gal/yr. wastewater treated @ $15/Kgal;
             18 drums/yr of drummed waste @ $150/drum) = $3K

             Annual Environmental Savings = $83K

             Current Annual Operational Costs (29 Kgal/yr process makeup water @
             $1.16/Kgal, 1100 gal Turco 6849 @ $13.75/gal, 8 gal of Rustbloc @ $17.40/gal) =
             $15,300 + solvent remaking time (4 hrs/week @$100/hr over 52 weeks/year) =
             $20,800 for a total of $36K.

             New Annual Operational Costs (8 Kgal/yr process makeup water @ $1.16/Kgal,
             2300 gal Eagle Kleen III @ $9.98/gal, and 8 gal of Rustbloc @ $17.40/gal) =
             $23,100 + solvent remaking time (4 hrs every 4 weeks @ $100/hr over 52 weeks/yr)
             = $5,200 for a total of $28K

             Annual Operational Cost Savings = $8K

             Total Investment = $200K
             Total Savings = $83K + $8K = $91K/year

             Payback = Total Project Cost ($200K)/Savings ($9IK) = 2.2 years

             Note: If Equipment is not needed, then payback is immediate	
                                Table 15. ECA Sensitivity Analysis
Costs of Wastewater Handling
and Treatment ($/drum)
100
150
200
250
Savings
($K/year)
63
91
118
146
Payback Period
(years)
3.2
2.2
1.7
1.4
                                               31

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5.0 CONCLUSIONS AND RECOMENDATIONS

5.1    Conclusions
Based on the laboratory evaluation, field testing, and engineering cost assessment, the following
conclusions were drawn:

       1.  Concentrated Eagle Kleen™:
           o   The concentrated degreaser passed substantially all the MIL-PRF 87937D requirements
               for water dilatable degreasers, including physical property, corrosion, and the all-
               important hydrogen embrittlement test. However, it failed the heat stability and stressed-
               plastics crazing requirements, preventing it from being listed on the qualified fluids list.
           o   In cleaning applications that do not involve acrylic or polycarbonates, the fluid may be
               used on a case-by-case basis. Eagle Kleen™ is a very aggressive degreaser and can
               dissolve certain plastics and elastomers. Attention must be paid to proper selection of
               construction material and PPE.
           o   The fluid after degreasing leaves a slimy, slippery surface that must be rinsed with water.

           o   The fluid can effectively remove oil and grease, but without ultrasonic energy is not
               effective  at removing heavy carbon contamination.

           o   The degreaser has a noticeable odor that some operators found offensive. Operation at
               elevated temperature (120°F) dramatically  increased complaints related to odor.
           o   Ventilation during use is required.

       2.  Dilute Eagle Kleen™:
           o   A dilute solution of Eagle Kleen III can be used in an ultrasonically enhanced parts
               washer to remove a substantial portion of carbon deposited on typical GTE parts.
               Cleaning appeared good, but was  not complete.  A longer immersion time or hand
               cleaning might be  required for complete carbon  removal.
           o   The solution was not effective in removing grease/heavy oils.
           o   The dilute degreaser in not slippery.

           o   The odor of the dilute solution was detectable, but less severe an issues as with
               concentrated Eagle Kleen™.
           o   Ventilation during use is required.

       3.  The economic cost assessment indicated a payback of 2.7 years with a positive NPV,
           indicating there are economic benefits to be gained when using Eagle Kleen™.

5.2    Recommendations
       1.  The degreaser should be evaluated in a real-world test using a suitable ultrasonically
           enhanced parts washer equipped with a suitable ventilation system.  If cleaning results are
           verified, the degreaser should be considered for implementation.
       2.  The cost of handling, treatment, and disposal of spent alkaline cleaner and spent rinse should
           be verified, and the costs/savings/payback projections should be re-examined for specific
           applications.
                                             32

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                                    6.0  REFERENCES

Anonymous. 1997. MIL-PRF-87937D "Cleaning Compound, Aerospace Equipment" (See Appendix A
       for a full copy.)

Tarn, T.M., et al. 1993. "Evaluation Performance Test Methods for Aqueous Cleaner," Plating and Shop
       Finishing, December, pp. 58-62.

Cohen, L. E. 1987. "How Clean is Your "Clean" Metal Surface?," Plating and Surface Finishing,
       November, pp. 58- 61.

U. S. EPA. 1999. EPA-745-R-99-004, "33/50 Program The Final Record," March, p. 2.
                                          33

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                      Appendix A




MIL-PRF-87937D "Cleaning Compound, Aerospace Equipment"

-------
                                                                           INCH-POUND
                                                                        MIL-PRF-87937D
                                                                        24 September 2001
                                                                        SUPERSEDING
                                                                        MIL-PRF-87937C
                                                                        14 August 1997
                                 PERFORMANCE SPECIFICATION

                         CLEANING COMPOUND, AEROSPACE EQUIPMENT

                              This specification is approved for use by all
                       Departments and Agencies of the Department of Defense,
1.  SCOPE
1.1  Scope.  This specification establishes the requirements for biodegradable, water dilutable,
environmentally safe cleaning compounds for use on aerospace equipment to include aircraft, aerospace
ground equipment (AGE) and AGE engines.

1.2  Classification. The cleaning compounds covered by this specification will be of the following types.

  Type I  -Terpene Based, Solvent Emulsion, Water Dilutable Cleaning Compound

  Type II -Water Dilutable Cleaning Compound

  Type III -Gel-Type Cleaning Compound

  Type IV -Heavy Duty, Water Dilutable Cleaning Compound

2.  APPLICABLE DOCUMENTS

2.1  General. The documents listed in this section are specified in sections 3 and 4 of this standard. This
section does not include documents cited in other sections of this standard or recommended for additional
information or as examples.  While every effort has been made to ensure the completeness of this list,
document users are cautioned that they must meet all specified requirements documents cited in sections
4 and 5 of this standard, whether or not they are listed.

2.2  Government Documents.

2.2.1 Specifications, standards,  and handbooks. The following specifications, standards and handbooks
form a part of this specification to the extent specified herein. Unless otherwise specified, the issues of
these documents will be those listed in the issue of the Department of Defense Index of Specifications and
Standards (DoDISS) and supplement thereto, cited in the solicitation (see 6.2).
 Beneficial comments (recommendations, additions, deletions) and any pertinent data which may be of use in
 improving this document should be addressed to:  Code (68) DET 3, WR-ALC/AFTT, BUILDING 1621-K, 2261
 HUGHES AVE STE 123, LACKLAND AFB TX 78236-9823, by using the Standardization Document
 Improvement Proposal (DD Form 1426) appearing at the end of this document or by letter.
AMSC N/A                                                                              FSC 6850
DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.

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                                     M1L-PRF-87937D
SPECIFICATIONS

   FEDERAL

     A-A-58054
     TT-l-735
     TT-P-2760
     PPP-P-704
Abrasive Mats, Non-Woven, Non-Metallic
Isopropyl Alcohol
Primer Coating, Polyurethane, Elastomeric, High-Solids.
Pails, Metal:  (Shipping, Steel, 1 through 12 gallons)
  DEPARTMENT OF DEFENSE
     MIL-PRF-2104
     MIL-PRF-5425
     MIL-C-5541
     MIL-A-8625
     MIL-G-21164

     MIL-PRF-22750
     MlL-PRF-23377
     MlL-PRF-25690

     MlL-DTL-81381
     MIL-PRF-81733
     MIL-PRF-83282

     MIL-P-83310
     MIL-DTL-83488
     MIL-PRF-85285
     MIL-PRF-85582
Lubricating Oil, Internal Combustion Engine, Combat/Tactical Service
Plastic, Sheet, Acrylic, Heat Resistant
Chemical Conversion Coatings on Aluminum and Aluminum Alloys.
Anodic Coatings, For Aluminum and Aluminum Alloys
Grease, Molybdenum Disulfide,  For Low and High Temperatures, NATO
Code Number G-353
Coating, Epoxy, High-Solids
Primer Coatings: Epoxy, High-Solids.
Plastic, Sheets And Formed Parts, Modified Acrylic Base, Monolithic, Crack
Propagation Resistant
Wire, Electric, Polyimide-lnsulated, Copper or Copper Alloy
Sealing and Coating Compound, Corrosion Inhibitive
Hydraulic Fluid, Fire Resistant, Synthetic Hydrocarbon Base, Aircraft, NATO
Code Number H-537.
Plastic Sheet, Polycarbonate, Transparent
Coating, Aluminum, High Purity
Coating:  Polyurethane, High Solids
Primer Coatings: Epoxy, Waterborne.
STANDARDS

   FEDERAL
     EPA-600-4-90-027

     FED-STD-141

     FED-STD-313
     FED-STD-595
Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters
to Freshwater and Marine Organisms
Paint, Varnish, Lacquer and Related Materials: Methods of Inspection,
Sampling and Testing
Material Safety Data Sheets, Preparation and the Submission of
Colors Used In Government Procurement
(Unless otherwise indicated, copies of the above specifications, standards, and handbooks are available
from the Standardization Document Order Desk, 700 Robbins Avenue, Building 4D, Philadelphia, PA
19111-5094.)

2.2.2 Other Government documents, drawings, and publications. The following other Government
documents form a part of this specification to the extent specified herein. Unless otherwise specified, the
issue should be that in effect on the date of the solicitation.

CODE OF FEDERAL REGULATIONS

   40 CFR  -   Protection of Environment
   49 CFR  -   Transportation

(Application for copies should be addressed to Superintendent of Documents, U.S. Government Printing
Office, Washington, D.C. 20402.)

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                                     MIL-PRF-87937D
2.3 Other publications. The following non-government documents form a part of this specification to the
extent specified herein. Unless otherwise specified, the issues of tie documents which are DoD adopted
will be those listed in the issue of the DoDISS specified in the solicitation. Unless otherwise specified, the
issues of documents not listed in the DoDISS will be the issue of the non-government documents which is
current on the date of the solicitation.

AMERICAN SOCIETY FOR TESTING AND MATERIALS

   ASTM STANDARDS

     A 153        Specification for Zinc Coating (Hot Dip) on Iron and Steel Hardware (DoD Adopted)
     D 56         Test Method for Flash Point by Tag Closed Tester (DoD Adopted)
     D 92         Test Method for Flash and Fire Points by Cleveland Open Cup (DoD Adopted)
     D 93         Standard Test Methods for Flash Point by Pensky-Martens Closed Cup Tester (DoD
                  Adopted)
     D 235        Mineral Spirits (Petroleum Spirits) (Hydrocarbon Dry Cleaning Solvent) (DoD
                  Adopted)
     D 1193       Specification for Reagent Water (DoD Adopted)
     D 2240       Test Method for Rubber Property - Durometer Hardness (DoD Adopted)
     E 70         Test Method for pH of Aqueous Solutions with the Glass Electrode (DoD Adopted)
     F 483        Test Method For Total Immersion Corrosion Test for Aircraft Maintenance Chemicals
                  (DoD Adopted)
     F 484        Test Method for Stress Crazing of Acrylic Plastics in Contact with Liquid or
                  Semi-Liquid Compounds (DoD Adopted)
     F 485        Test Method for Effects of Cleaners on Unpainted Aircraft Surfaces
     F 502        Standard Test Method for Effects of Cleaning and Chemical Maintenance Materials
                  on Painted Aircraft Surfaces.
     F 519        Test Method for Mechanical Hydrogen Embrittlement Testing of Plating Processes
                  and Aircraft Maintenance Chemicals
     F 1104       Test Method for Preparing Aircraft Cleaning Compounds, Liquid Type, Water Base,
                  for Storage Stability Testing
     F 1110       Test Method for Sandwich Corrosion Test
     F 1111       Test Method for Corrosion of Low-Embrittling Cadmium Plate by Aircraft  Maintenance
                  Chemicals

 (Application for copies should be addressed to the American Society for Testing and Materials, 100 Barr
 Harbor Drive, West Conshohocken PA 19428-2959.)

SOCIETY OF AUTOMOTIVE ENGINEERS

   SAE STANDARDS

     AMS QQ-A-250  Aluminum and Aluminum Alloy, Plate and Sheet
     AMS 1640       Corrosion Removing Compound, Prepalnt, For Aircraft Aluminum Surfaces.
     AMS 2410       Plating, Silver, Nickel Strike, High Bake
     AMS M-3171     Magnesium Alloy, Processes for Pretreatment and Prevention of Corrosion on
     AMS 3204       Rubber, Synthetic Low-Temperature Resistant 25-35 (DoD Adopted)
     AMS 3209       Chloroprene (CR) Rubber, Weather Resistant, 65-75 (DoD Adopted)
     AMS 4377       Sheet and Plate, Magnesium Alloy, 3.01 A-1 .OZn-0.20Mn (AZ31B-H24) Cold
                     Rolled, Partially Annealed (DoD Adopted)
     AMS 5046       Sheet, Strip, and Plate, Carbon Steel (SAE 1020 and 1025) Annealed
     AMS S-8802     Sealing Compound, Temperature-Resistant, Integral Fuel Tanks and Fuel Cell
                     Cavities, High-Adhesion
     AMS T-9046     Titanium and Titanium Alloy, Sheet, Strip and Plate

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                                       M1L-PRF-87937D

(Application for copies should be addressed to the Society of Automotive Engineers, Inc., 400
Commonwealth Drive, Warrendale PA 15096.)

AMERICAN IRON AND STEEL INSTITUTE

   AISI STANDARDS

     AISI 4340  High Strength, Low Alloy Steel

(Application for copies should be addressed to American Iron and Steel Institute, 1133 15th St N.W, Suite
300, Washington DC 20005.)

(Industry association specifications and standards are generally available for reference from libraries.
They are also distributed among technical groups and using Federal agencies.)

2.4 Order of precedence,. In the event of a conflict between the text of this specification and a reference
cited herein, the text of this specification will take precedence.

3.  REQUIREMENTS

3-1 Qualification.

3.1.1 Qualification (Initial). The cleaning compound furnished under this specification shall be a product
which has been tested and has passed the qualification tests specified herein and has been listed or
approved for listing on the applicable Qualified Products List (QPL).

3.1.2 Re-Qualification (Periodic).  The cleaning compound furnished under this specification shall be
retested or recertified by the qualifying activity at least every three years for the product to remain listed on
the QPL. Re-Qualification testing shall be accomplished on any qualified cleaning compound for which a
using activity issues  a valid deficiency report. The cleaning compound shall also be subject to re-
qualification testing for arty change in chemical formulation, material, process, or procedure in
manufacturing the cleaning compound. Upon periodic re-qualification, any cleaning compound which does
not conform to all the qualification tests specified herein shall be removed from the QPL.

3.1.3 Qualifying activity. The activity responsible for specification qualification and the QPL is the Air
Force Petroleum Office, Product Engineering Branch, San Antonio TX.  Activity mailing address is: DET 3
WR-ALC/AFTT, BUILDING 1621-K, 2261 HUGHES AVE STE 123, LACKLAND AFB TX 78236-9823.

3-2 Materials. The composition and formulation of the cleaning compound shall be optional with the
manufacturer within the restrictions specified herein.

3-2.1 Acceptable materials,

3.2.1.1  Type  I.  Type I compounds shall contain terpene hydrocarbons as specified in Table I.
Certification from the manufacturer is required on the percentage of total terpenes contained in the
cleaning compound. The terpene hydrocarbons used shall be of a high grade with no extraneous
materials.

3.2.1.2 Type  li. Type ill, and Type IV.  Types II, III, and IV compounds shall consist of one or more of the
following:  Surfactants, adjuvant solubilizers for organic soils such as greases and oils, alkaline builders,
water conditioning agents and corrosion inhibitors.

3.2.2 Unacceptable materials. The cleaning compound shall not contain any hazardous compounds as
defined in 40 CFR 261, toxic pollutants in 40 CFR 301, nor hazardous air pollutants in 40 CFR 63 (see
4,6). The cleaning compound shall not contain any chemical listed by the current report of known
carcinogens of the National Toxicology Program (NTP). The cleaning compound shall not contain
detectable amounts of any of the following: abrasives, chromates, cadmium, lead, mercury, phenols,

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                                       MIL-PRF-87937D

cresols, ketones, chlorinated compounds or ozone depleting substances (ODS), except where specified
within this specification. The following materials are unacceptable unless they are being used as an
essential active ingredient in the cleaner: sodium chloride, urea, sodium sutfate, nitrites, nitrates, sucrose
or any sugars. Types II, 111, and IV compounds shall contain no terpene hydrocarbons or other
hydrocarbon solvents.

3.3 Toxicitv.  The cleaning compound shall have no adverse effect on the health of personnel or the
environment when used for its intended purpose and with proper personal protective equipment (when
required). The product shall be evaluated for aquatic toxicity with a 96 hour Fathead minnow (pimephales
promelas) bioassay and a 48 hour Ceriodaphnia dubia bioassay in accordance with Methods for
Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms,
EPA/600/4-90/027. The percent survival at 1,  10, 50, and 100 ppm shall be reported for both organisms.

3.3.1  Formulation. The manufacturer shall submit to the qualifying activity a certified statement that
provides the identity and percentage by weight of each ingredient in the cleaning compound, including
solvent, using a readily recognizable chemical name and CAS number. Trade names alone shall not be
considered satisfactory. All proprietary information shall be protected as such.

3.3.1.1  Type I. The manufacturer shall submit to the qualifying activity the chemical name of each
terpene used in the formulation including its CAS number and range of values in percent by weight of the
formulation. The manufacturer shall also submit test procedures used to verify the terpene percentages
within these ranges. All procedures shall be subject to approval by the qualifying activity.

3.3.2  Material safety data sheet (MSDS). The manufacturer shall submit to the qualifying activity an
MSDS for the finished  product and for each component in the finished product. The MSOS shall be
prepared in a 16 part format in accordance with the latest revision of FED-STD-313.

3.3.3  Toxicological data.  The manufacturer shall submit to the qualifying activity a copy of pertinent
toxicological data/information (see 4.6) for their product.

3.3.4  Biodegradabilitv. The supplier of the cleaning compound shall furnish certification from the
surfactant manufacturers that the surfactants are readily biodegradable in accordance with 40 CFR, Part
796, Subpart D. Biodegradability testing shall be accomplished as specified in paragraph 4.5.22 on the
finished product by an  independent laboratory approved by the qualifying activity. Biodegradability on the
finished product shall be determined over 28 days by the Shake Flask Method monitored by analysts of
Total Organic Carbon (TOC). The Type I compound shall meet the requirement of a minimum of 75%
biodegradable and Types  II,  III, and IV compounds shall meet the requirement of a minimum of 85%
biodegradable at the end of the 28 day period.

3.4 Compositional assurance. The cleaning compound shall be tested for nonvolatile matter as specified
in paragraph 4.5.1. The concentrated cleaning compound and a 10% solution of the cleaning compound
in distilled water shall be tested for pH as specified in paragraph 4.5.3.  Results of these tests as well as
an infrared spectrogram of the nonvolatile matter (see 4.8.2) and a gas chromatogram  (see 4.8.1 for Type
I only) shall be recorded by the qualifying activity for use in conformance inspections (see 4.3).
Conformance inspection results for nonvolatile matter shall not differ by more than 2 percent absolute
from the recorded value. Conformance inspection results for pH shall not differ by more than 1 pH unit
from the recorded value. Conformance inspection infrared spectrograms and gas  chromatograms shall
show no significant difference when compared to the original qualifying spectrogram.

3.5 Chemical properties.

3.5.1  Chemical requirements. The cleaning compound shall meet the requirements listed in Table I.

3.5.2  Residue rinsibilitv. When a freshly prepared solution of the cleaning compound is tested in
accordance with 4.5.4, it shall not leave any residue or stains.  A freshly prepared solution is defined as
one being prepared no longer than 30 minutes prior to testing. The weight change shall be not greater
than that obtained with standard hard water tested under the same conditions.

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                                       MIL-PRF-87937D
3.6 Physical properties (All types unless otherwise noted).

3-6-1  Heat stability.  The concentrated cleaning compound, when tested in accordance with 4.5.5, shall
show no marked color change or precipitation and shall not corrode or stain the AMS 5046 (SAE 1020)
steel strip (a slight darkening of the steel strip shall not be objectionable).  Layering or separation shall
constitute failure if it does not return to its original homogeneous state upon cooling.

3.6.2  Cold stability.  The concentrated cleaning compound shall return to its original homogeneous
condition when tested in accordance with 4.5.6.

3.6.3  Rheoloav (Type III only).

3.6.3.1 Consistency. When tested as specified in 4.5.24, the concentrated cleaning compound shall flow
between 10 and 20 centimeters in 10 seconds.  The product shall also exhibit rheology which enables it to
meet the sprayability requirement.

3.6.3.2 Solvability. The concentrated cleaning compound, when dispensed at 45 psig and tested in
accordance with 4.5.25, shall give satisfactory spray characteristics and deposit a uniform layer on a
vertical surface 3 feet away from the nozzle.

3-7 Effect on metals (All types unless otherwise noted).

3.7.1  Hydrogen embrittlement. When tested in accordance with 4.5.9, the concentrated cleaner (all
types) and a 10% solution of the cleaner (Types  I, II and IV only) in distilled water shall not cause
hydrogen embrittlement of cadmium plated or IVD aluminum coated AISI4340 steel.

3.7.2  Total immersion corrosion.  When tested in accordance with 4.5.10  (ASTM F 483), the concentrated
cleaning compound  (all types) and a 10% solution of the cleaning compound (Types I, II and IV only) in
distilled water shall not show any indication of staining, etching, pitting, or localized attack  on any of the
panels, or cause a weight change of an average of three (3) test panels greater than that shown in Table
II. A slight discoloration of the panels shall not be objectionable. The cleaning compound shall not layer
or separate for the duration of the test.

3.7.3  Low-embrittling cadmium plate corrosion.  Steel panels coated with  low-embrittling cadmium plate
immersed in the concentrated cleaning compound (all types) and a 10% solution of the cleaning
compound (Types I,  II and IV only) in distilled water shall not show a weight change greater than 0.14
mg/cm2 for 24 hours when tested in accordance with 4.5.11.

3.7.4  Effects on unpainted metal surfaces. The concentrated cleaning compound (Type 111 only) and a
10% solution (Types I, II and IV) of the cleaning compound in distilled  water shall not cause streaking,
stains or other deposits that cannot be easily removed with water when tested in accordance with 4.5.12.

3.7.5  Sandwich corrosion.  When tested in accordance with 4.5.16, the concentrated cleaner (all types)
and a 10% solution (Types I, II and IV only) shall show no corrosion in excess of that shown by control test
coupons in ASTM D1193, Type IV, reagent water.

3.7.6  Wet adhesion tape test  (Types II and IV).  A ten (10) percent solution of the cleaning compound,
when used as directed, shall remove soil from a painted surface in preparation for repainting such that
paint applied after cleaning with the compound shall adhere to the surface when tested in accordance with
4.5.27.

3.8 Effect on painted surfaces. The concentrated cleaning compound (Type 111 only) and a 25% solution
(Types I, II, and IV) of the cleaning compound in distilled water shall not cause streaking, blistering,
discoloration or a permanent decrease in film hardness of more than one (1) pencil hardness level when

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                                       MIL-PRF-87937D

tested in accordance with 4.5.13. The Type I material shall be tested using only the Polyurethane Paint
Systems (H).

3.9 Stress crazing of MIL-PRF-5425 and MIL-PRF-2S690 (Type A and C) acrylic plastics.  The
concentrated product (Type III only) and a 10% solution (Types I, II and IV) in distilled water shall not
cause stress crazing or staining of acrylic plastics when tested in accordance with 4.5.14.

3.10 Stress crazing of polycarbonate plastic.  The concentrated product (Type III only) and a 10% solution
(Types I, II and IV) in distilled water shall not cause stress crazing or staining of polycarbonate plastic
conforming to MIL-P-83310 when tested in accordance with 4.5.15.

3.11 Long term storage stability.  After being stored for a period of 12 months, in accordance with 4.5.17,
the cleaning compound shall not layer,  separate, precipitate or corrode the shipping container.  Plastic
containers shall not show leakage nor any cracking, crazing, or softening. All cleaning compounds shall
meet the requirements of paragraphs 3.5.1, 3.7.1, 3.7.2, 3.15, and 3.16 of this specification.

3,12 Hot dip galvanizing corrosion.  The concentrated product (Type III only) and a 10% solution of the
cleaning compound  (Types I, !l and IV) in distilled water shall not show a weight change of an average of
three (3) test panels greater than 0.14 mg/cm* when tested in accordance with 4.5.18.

3.13 Workmanship. The cleaning compound shall be a liquid having a uniform and homogenous
appearance. The cleaning compound shall be manufactured from materials that shall produce a product
harmless to metal surfaces and humans when used as directed.

3.14 Effect on polvsulfide sealants. The concentrated cleaning compound (Type III only) and a 25%
solution (Types I, II and IV) of the cleaning compound in distilled water shall not change the durometer
hardness of the polysulfide sealant by more than 5 units when tested in accordance with 4.5.19.

3.15 Rubber compatibility.  The concentrated cleaning compound (Type III only) and a 25% solution
(Types I, II and IV) of the cleaning compound in distilled water shall not change the durometer hardness
more than 5 units when tested in accordance with 4.5.20.

3.16 Effect on polvimide insulated wire. The cleaning compound, when tested according to 4.5.26, shall
not cause dissolution, cracking, or dielectric breakdown (leakage) of the polyimlde insulated wire in excess
of that produced by distilled water.

4. VERIFICATION

4.1 Classification of tests.  The inspection and testing of the cleaning compound shall be as follows.

   a. Qualification inspection (4.2).

   b. Conformance inspection (4.3).

4.2 Qualification inspection. Qualification inspection shall consist of all inspections and tests specified
herein.

4.2.1 Qualification samples. The initial qualification samples shall consist of 12 liters (3 gallons) of the
cleaning compound. The cleaning compound shall be furnished in containers of the type to be used in
filling contract orders.  Samples shall be identified as follows and forwarded to the laboratory responsible
for testing, as designated in the letter of authorization from the qualifying activity (see 3.1.3):

   - Samples for Qualification Tests.
   - Cleaning Compound, Aerospace Equipment, (Types I, II, III, and IV).
   - MIL-PRF-87937D.
   - (Manufacturers Product and Code Number)

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                                       MIL-PRF-87937D

  - (Name and Address of Contractor)
  - Submitted by (Name), (Date) for Qualification Testing in Accordance with the Requirements of
    MIL-PRF-87937D Under Authorization (Reference Authority Letter).
  - (Mixing and Other Important Instructions.)
  - (Safety Information and Precautions.)

4.2.2  Test reports. The contractor shall provide certified test reports showing that the material conforms
to all the requirements of this specification.  The initial report consisting of all specification requirements
except tie storage stability tests shall be provided upon completion of those tests.  The final report shall
be provided after the completion of the storage stability tests and shall consist of those test results.
Certified test reports shall include the gas chromatogram (4.8,1) or the infrared spectrogram (4.8.2) as
required.

4,2.3  Qualification required. Prior to actual procurement, the cleaning compound shall pass the
qualification inspections and requirements specified herein.  If the product is later modified in any way, the
modified form shall be subjected to and shall pass the same qualification inspections (see 3.1). Any
changes or modifications from the formulation used at the initial qualification shall be approved by the
qualifying activity and may require re-qualification. All initial qualifications shall be granted contingent upon
compliance with the long term  storage stability requirement specified in paragraph 3.11.

4.3 Conformance tests. Conformance tests (see 6.5) for acceptance of the cleaning compound shall
consist of the following tests.

                             A.     Workmanship
                             B.     Cold Stability
                             C.     Insoluble Matter
                             D.     Consistency (Type III only)
                             E,     Immersion Corrosion*
                             F.     Emulsion Characteristics
                             G.     Nonvolatile Matter
                             H,     pH
                             I.     Flash Point
                             J.     Infrared Spectrogram (Types II,  III and IV)
                             K.     Gas Chromatogram (Type I only)

'Immersion Corrosion Conformance Test ran on Aluminum SAE AMS-QQ-A-250/4, Bare T3 alloy panel
only.

If during conformance testing a lot fails any of the above acceptance tests, all tests required for
qualification shall be reinstituted.  These qualification tests shall be required until two successive lots meet
all requirements of the specification, after which conformance testing shall again be authorized (see
4.3.5).

4.3.1  Sampling. Unless otherwise specified, not less than a 3.8 liter (1 gal) container of the cleaning
compound shall be selected at random from each lot and subjected  to the tests specified in 4.3. The
contents of each selected container for sampling shall be thoroughly mixed by rolling and inverting
immediately prior to sampling.

4.3.2  Lot. A  lot shall consist of one of the following:

  a. The Gleaning compound  produced in not more than 24 consecutive hours from a continuous process
  which is used to fill shipping containers directly from the process output. A continuous process shall be
  the production of product by continuous input of raw materials and output of finished product by one
  manufacturer in one plant with no change in manufacturing conditions or materials.

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                                       MIL-PRF-87937D

  b. The cleaning compound from individual runs of a batch process which is used to fill shipping
  containers directly from the process output, A batch process shall be the production of product by
  runs from single additions of raw materials which are mixed, reacted, or purified forming the product,

  c. The cleaning compound from either or both the continuous and batch processes which is held in a
  single storage tank and subsequently withdrawn to fill shipping containers. The product shall be
  homogeneous at the time of withdrawal and shall not be added to while being withdrawn. After each
  addition to the storage tank, the contents shall constitute a separate lot.

4.3.3  Sampling of product. Unless otherwise specified, conformance tests (4.3) shall be made on the
sample of product taken directly from the filled containers.  The number of filled containers selected for
sampling from each lot shall be in accordance with Table III.  The first and last containers to be filled
within a given lot shall be sampled. Other containers shall be selected at random.  The samples may be
obtained in any convenient manner that does not compromise the integrity of the sample.

4.3.4  Inspection of materials. The contractor is responsible for ensuring that materials and components
used are manufactured, tested and inspected in accordance with the requirements of referenced
subsidiary specifications and standards to the extent specified, or, if none, in accordance with this
specification, (see 2.3)

4.3.5  Rejection and, retest. When any sample of the product examined and tested in accordance with this
specification fails to conform to the requirements specified herein, the entire lot represented by the sample
shall be rejected.  Rejected material shall not be resubmitted for acceptance without prior approval of the
qualifying activity.  The application for resubmission shall contain full particulars concerning previous
rejections and all measures taken to correct those defects. Samples for retest shall be taken only from a
sealed container.

4.4  Testing standards. Ail laboratory tests shall be conducted at standard conditions unless otherwise
specified herein. Standard conditions are defined by  FED-STD-141, Section 9.  Unless otherwise
specified, all chemical tests shall be made with ACS specification reagent grade chemicals. Unless
otherwise specified, all product dilutions shall be made with distilled water which conforms to the
requirements of ASTM D 1193, Type IV, reagent water. The term "concentrated" cleaner or compound
refers to that concentration of the cleaner/compound as received from the manufacturer. No further
concentration shall be performed on the product.

4.5  Test methods.

4.5.1  Nonvolatile matter.  Weigh 5.00 ± 0.01 g of the sample in a porcelain or glass dish about 6 to 8 cm
in diameter and about 2 to 4 cm in depth. Dry to constant weight in an air oven at a temperature of
105 ± 2°C.  Constant weight is attained when successive heating for 1-hour periods shows a loss (or gain)
of not more than 0.1%. Nonvolatile matter determinations shall be made on a minimum of two samples
and the average shall be reported.  If the two weights differ by more than 0.5% (absolute) the  procedure
shall be repeated. The nonvolatile content of each sample shall be calculated as follows:


                                  %NVM = |-
                                            LB

                          Where:   A - Weight of residue
                                    B = Weight of sample
                              %NVM= Percent nonvolatile matter

4.5.2  Insoluble matter. The concentrated cleaning compound shall be thoroughly agitated and a 200 ml
test sample withdrawn. The insoluble matter shall be collected with the aid of a vacuum filtering apparatus
consisting of a water tap filter pump, a 2,000 ml Erlenmeyer flask, a size 4 (126 mm ID)  Buchner funnel
and a piece of 126 mm diameter Whatman No 5 filter paper, or equivalent. The filter paper shall be dried
at 60°C (140°F) for 30  minutes in a gravity convection oven, cooled for 3 minutes in a desiccator, and
weighed to the nearest 0.1 mg. The filter paper shall be placed in the Buchner funnel so that its
                                              9

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                                       MIL-PRF-87937D

circumference coincides with the circumference of the funnel.  The vacuum shall be started and the filter
paper wetted with approximately 10 ml of distilled water in order to secure it properly in place. The test
sample shall be filtered.  The sides of the beaker which contained the test sample shall be rinsed with 25
ml of distilled water from a wash bottle, and the rinse transferred to the funnel, insuring that any remaining
insoluble matter is completely transferred with the rinse. When all the initial liquid and the rinse have been
transferred through the filter, the sides of the funnel shall be washed with 25 ml of distilled water from a
wash bottle and the rinse allowed to filter. The vacuum on the flask shall be relieved and the filter paper
removed from the funnel. The filter paper shall be dried for 1 hour at 60°C (140°F) in a gravity convection
oven, cooled for 3 minutes in a desiccator, and weighed to the nearest 0.1  mg.  The percent insolubles
shall be calculated as follows:
                                  Where:  A = Final filter paper weight
                                           B = Initial filter paper weight
                                           W = Weight of sample
                                           / - % Weight insoluble matter

Care should be exercised throughout the final drying and weighing cycle to maintain the flat surface of the
filter paper in a horizontal position so that none of the insoluble matter will be lost.  Insoluble matter
determinations shall be made on a minimum of two samples and the average shall be reported. If the two
results differ by more than 0.5% (absolute) the procedure shall be repeated.

4.5.3  pH value. The pH value of the concentrated cleaning compound and a 10 percent solution of the
cleaning compound in freshly boiled distilled water shall be measured in accordance with ASTM E 70.

4.5.4  Residue rinsibility. Six smooth aluminum dishes, containing no creases or crevices, shall be
cleaned in a solution of Brite-Boy, (from 3D Inc., or equivalent), rinsed, and dried to constant weight.  Ten
ml of a 25% by volume  solution of the cleaning compound in standard hard water (see 4.5.4.1) shall be
placed in three of the precleaned dishes and tested according to the procedure in 4.5,42

4.5.4.1 Preparation of standard hard water. A 20-grain (as CaCOs) hard-water stock solution shall be
prepared by dissolving 0.40 ± 0.005 g of reagent grade Calcium Acetate, Ca(C2H3O2)2»2H2O and 0.28 ±
0.005 g of reagent grade Magnesium Sulfate, MgSCV7H20, in 1 liter of boiled distilled water.

4.5.4.2 Procedure. Dry three dishes each containing 10.0 ml of a 25% cleaning solution for 7 1/2 hours in
a circulating oven at 68 ± 2 °C with full draft. Cool in desiccator overnight and weigh. Rinse with running
distilled water for 1  minute.  Brush with  a sash-type brush containing long-fiber bristles (2,5 cm diameter
by 3.8 cm to 6.4 cm long) for 1 minute using distilled water. Rinse for 30 seconds with running distilled
water.  Dry in oven as before, cool and  re weigh. Standard  hard water (4.5.4.1) shall be tested as control
for weight change comparison in the remaining three precleaned dishes, using the same procedure as
above.

4.5.5  Heat stability. A141.75 g sample of the well mixed concentrated cleaning compound shall be
placed into each of two clean 255 ml (12 oz) clear glass bottles having approximate dimensions of 24 cm
in height by 6.35 cm in diameter (9.5 in x 2.5 in). One bottle containing the concentrated cleaning
compound shall be sealed with a screw type cap and stored in a dark place at standard conditions for 6
days (144 hrs) for reference purposes.  Place into the second bottle of concentrated cleaning compound a
strip of steel, 15.24 cm  by 1.27 cm by 0.05 cm (6 in x 0.5 in x 0.02 in) conforming to AMS 5046 (SAE
1020). Clean the steel strip by abrasively polishing to remove surface scale and corrosion followed by
immersion for one minute in ASTM D 235 Mineral Spirits or equivalent followed by immersion for one
minute in isopropyl alcohol (TT-l-735, grade A) at standard conditions. Wipe test panels with an alcohol
wetted tint free cloth and dry with a clean, lint free doth. Oven drying is optional. Seal the bottle
containing the concentrated cleaning compound and the cleaned steel strip with a screw type cover and
shake thoroughly for 1 minute.  Place the bottle in a bath maintained at 46 ± 2 °C (115 ± 3 °F) for 5 hours,

                                               10

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                                       MIL-PRF-87937D

then remove and allow to cool to ambient conditions for 19 hours. This heating/cooling cycle shall be
repeated 5 times. After completion of the test period, remove the test strip and inspect the portion of the
strip which was immersed in the cleaning compound and the portion exposed to the vapor. Any corrosion,
pitting or discoloration constitutes failure. The bottle is reseated and along with the control bottle that has
been maintained in the dark is shaken thoroughly for 1 minute, then allowed to remain undisturbed for 1
hour at room temperature.  The bottles are then examined. Any marked change in color, precipitation,
layering or separation constitutes failure.

4.5.6 Cold stability. A 50 ml sample of the cleaning compound shall be poured into a test tube and cooled
to 0°C. This temperature shall be maintained for one hour. The compound shall then be allowed to reach
room temperature. After 5 (five) complete temperature inversion cycles of the test tube, the compound
shall be examined for homogeneity. A slight turbidity shall not be objectionable provided no precipitation is
present.

4.5.7 Flash point. The flash point of the concentrated cleaning compound (Type I, II, III, and IV) shall be
determined in accordance with ASTM D 56 (Tag Closed Cup) and for materials that have a tendency to
form a surface film under the test conditions, use ASTM 0 93.  The flash point of the 10% solution in
distilled water (Type I only) shall be determined in accordance with ASTM  0 92.

4,5.8 Emulsion characteristics. Twenty ml of a 25% by volume solution (Types I and II) of the cleaning
compound (12.5% by volume solution for Types 111 and IV) shall be placed in a 50  ml glass stoppered
graduated cylinder. Twenty ml of lubricating oil conforming to MIL-PRF-2104, grade 10W, shall be added.
An emulsion shall be formed by 10  inversions of the graduated cylinder followed by a vigorous 15 second
shake.  After the  emulsion has stood for 5 minutes, the 15 second shake shall be repeated.  At 5 minutes
and 8 hours for Type I and at 5 minutes and 24 hours for Types II, III and IV cleaners, the amount of free
water and cleaner which separates  from the lubricating oil shall conform to the requirements of Table I.

4.5.9 Hydrogen embrittlement.  The hydrogen embrittlement properties of the cleaning compound shall be
determined as passive chemicals in a service environment according to ASTM F 519 using two (2) sets of
either Type 1a, 1c, or 2a AlSl 4340  steel specimens.  One set shall be  plated per Table 2 Treatment B,
ASTM F 519. The second set shall be coated with Ion Vapor Deposited (IVD) Aluminum per MIL-DTL-
83488D, Class 2, Type I. Prior to coating, specimens for IVD Aluminum shall be prepared by grit blasting,
including notched area, with size 180 virgin grain white aluminum oxide grit.  The applied IVD coating shall
not be peened or burnished in any manner.  All specimens must be completely plated or coated except
for the screw threads.

4.5.10 Total immersion corrosion.  The total immersion corrosion effects of the cleaning compound on the
new, unused metals and metal alloys listed in Table II shall be determined in accordance with
ASTM F 483. After immersion for 24 hours and after 138 hours, panels shall be evaluated for appearance.
Conformance to the requirements in Table II shall be for weight loss after 168 hours.  In order to obtain
the best results on test panels in this very low weight category, the panels  shall be handled with gloves,
cleaned in a very careful manner and dried in an oven. They are cooled and dried in a desiccator both
before and after each weighing.

4.5.11 Low-embrittling cadmium plate corrosion. The cleaning compound shall be evaluated for corrosion
on low-embrittling cadmium plate in accordance with ASTM F 1111.

4.5.12 Effects on unoainted metal surfaces. The cleaning compound shall be evaluated for effects on
unpainted metal surfaces in accordance with ASTM F 485.

4.5.13 Effect on  painted surfaces.  The concentrated cleaning compound (Type 111 only) and a 25%
solution  (Types I, II and IV) with distilled water shall be tested in accordance with ASTM F  502 except that
the panels used for testing shall be  coated with the paint systems listed in  Table IV. For all paint systems
tested, a separate panel shall be required for both 25% solution and concentrate.  For Types II, III and IV
compounds,  conduct the test on all  paint systems listed in Table IV.  For Type I compounds, conduct the
test only on the polyurethane paint systems (H).
                                              11

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                                       MIL-PRF-87937D

4.5.14  Stress crazing of MIL-PRF-5425 and MIL-PRF-25690 (Type A and C) acrylic plastics. The
cleaning compound shall be evaluated for stress crazing of stretch (Type A and C) acrylic plastics in
accordance with ASTM F 484.

4.5.15  Stress crazing of polycarbonate plastic.  The cleaning compound shall be evaluated for stress
crazing of polycarbonate plastics using the test procedure outlined in ASTM F 484 with the exception that
the acrylic plastics called for in the procedure be replaced with polycarbonate plastic conforming to
MIL-P-83310 of the same dimensions and the polycarbonate specimens shall be stressed for 30 ± 2
minutes to an outer fiber stress of 2000 psi.

4.5.16  Sandwich corrosion. The cleaning compound shall be tested in accordance with ASTM F 1110 as
specified  in paragraph 3.7.5.

4.5.17  Long term storage stability.  The cleaning compound shall be prepared and stored for long term
storage stability in accordance with ASTM F 1104 using one (1) 3.8 liter (one-gallon) can conforming to
Federal Specification PPP-P-704 or DOT UN 1A1  steel container. Plastic containers shall conform to DOT
UN 1H1 as required by 49 CFR 178. Manufacturers using both type materials in production packaging
shall test  each type container with their product.

4.5.18  Hot dip galvanizing corrosion. The total immersion corrosion effect of the cleaning compound shall
be evaluated as specified in 3.12 after 24 hour immersion per ASTM F 483. Test coupons shall be AMS
5046 (SAE 1020) steel panels prepared by hot dip galvanizing per ASTM A 153.

4.5.19  Effects on polysulfide  sealant.

4.5.19.1  Preparation of test specimens. MIL-PRF-81733, Type I, and SAE AMS S-8802 sealants shall be
mixed as specified by their respective manufacturers and each pressed into a 1/8 inch thick sheet mold
until  cured (this shall be the sheet stock for each sealant). The sealants shall be cured for 7 days at 49°C.
The specimens shall be cut from the sheet stock.

4.5.19.2  Test procedures.  Immerse two specimens of each sealant in the concentrated product (Type III
only) and a 25% solution of the cleaning compound (Types I, II and IV) at room temperature for 30
minutes.  Remove from the solution, rinse with cool tap water, and test within 30 minutes for Shore A
hardness in accordance with ASTM D 2240.

4.5.20  Test  on rubber compatibility. Tests shall be conducted on AMS 3204  and AMS 3209 rubbers for
compatibility with the cleaning compounds.

4.5.20,1  Preparation of test specimens. Three (3) test specimens shall be used for each type rubber
specified. Test specimens  shall be cut from 1/8 inch sheet stock.

4.5.20.2  Test procedure. Test and record ttie Shore A hardness of each test specimen in accordance
with ASTM D 2240.  Immerse each specimen in the concentrated product (Type III only) and a 25%
solution of the cleaning compound (Types I, II and IV) at room temperature for 30 minutes. Remove from
the solution,  rinse with cool tap water, and test within 30 minutes for a Shore A hardness in accordance
with ASTM D 2240.

4.5.21  Cleaning efficiency (all types). The cleaning efficiency of the cleaning compound shall be reported
as the average of three test results and shall conform to the requirements of Table I.

4.5.21.1  Preparation of control formula. The control formula shall be prepared by the testing laboratory in
accordance with Table V and subjected to the cleaning test (4.5.21.5) and evaluation (4.5.21.6). Valid
control formula preparations shall produce denominator values greater than 0.95 during testing.

4.5.21.2  Panel preparation. Aluminum SAE AMS QQ-A-250/4, bare T3 panels, 40.6 x 12.7 x 0.05 cm
(16 x 5 x  .02 in) shall be used.
                                              12

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                                       MIL-PRF-87937D

4.5.21,3 Soil preparation. Molybdenum disulfide grease soil shall be prepared by blending 50 grams of
carbon black and 500 grams MIL-G-21164 grease with a mechanical grease worker for 15 minutes.

4.5.21.4 Application of grease soil.  Panels shall be wiped with clean lint free cloths soaked in reagent
grade acetone then dried to  a constant weight.  Record the weight to the nearest 0.1 mg. Apply
approximately 200 mg grease soil using a soft bristle brush over an area approximately 2" x 7" in the
center of the panel. Remove excess grease soil by covering the test panel with a folded absorbent tissue
and exerting pressure by rolling a five pound rubber cylinder over the tissue. Repeat this blotting
procedure twice. Each freshly soiled panel shall be baked at 105 ± 5 °C for 60 minutes then cooled to
room temperature and weighed to the nearest O.t mg. Only use panels with more than 50 mg of grease
soil.  Panels shall be used within 4 hours.

4.5.21.5 Cleaning test. The test panels shall be cleaned using a Gardner heavy duty wear tester, or
equivalent, fitted with a cellulose sponge. The sponge shall be cut such that the dimension parallel to the
cleaning stroke is 9 cm (3.5  in) and the width is 7 cm (2.75 in).  The cleaning head with the dry sponge
attached shall be weighed to a mass of 495 to 505 grams. The cleaning stroke of the scrub tester shall be
12 inches. The cleaning compound (including Type HI) and the control formula shall be diluted 1 part
cleaner with 9 parts distilled  water.  After placing a soiled test panel in  the template 100 ml of the cleaning
solution shall be applied to the sponge then applied to the soiled test panel so that it is completely
covered.  After allowing a 30 seconds dwell time, the test panel shall be cleaned using 5 cycles of the
wear tester.  The panel shall then be rinsed with sufficient amounts of distilled water.

4.5.21.6 Evaluation. The rinsed panel shall be heated to 105°C ± 5°C for 10 minutes, cooled to room
temperature, then weigh to the nearest 0.1 mg. Report the % Cleaning Efficiency as the average of three
(3) tests using the following:
                          % Qeaning Efficiency=
                                                A-B
,-d
                                                X
                                                     x-n
     x/GO
where:   A = Weight of the soiled panel before cleaning with product
         B = Weight of the soiled panel after cleaning with product
         C = Weight of the unsoiled panel used in the product cleaning test
         X= Weight of the soiled panel before cleaning with the control formula
         Y - Weight of the soiled panel after cleaning with the control formula
         Z = Weight of the unsoiled panel used in the control formula cleaning test

4.5.22 Biodeqradabilitv  Biodegradation shall be determined by the "Shake Flask Biodegradation Tests"
for measuring ultimate or ready degradation potential, as found in EPA Chemical Fate Test Guidelines 40
CFR Method 796.3100 (Aerobic Aquatic Biodegradation Test) or 40 CFR Method 796.3240 (OECD
Screening Test for Ready Biodegradability). Biodegradability shall be shown as carbon transformation by
both soluble organic carbon reduction and CO? evolution.

4.5.23 Teroene hydrocarbons (Type I only).  An approved test procedure shall be used (see 3.3.1.1).

4.5.24 Consistency (Type III only). A consistometer (Central Scientific Company, Chicago, it; Catalog
No. 24925 or equivalent) shall be used as follows:  Shake the container of cleaning compound by hand for
10 seconds. Pour the material into the well of the consistometer completely filling it. Release the gate and
determine the extent of flow in ten seconds.

4.5.25  Soravabilitv (Type III only). Fill the reservoir of the application test equipment with Type 111
compound, as supplied.  Release the compound flow valve and gradually increase the nozzle tip pressure
to not more than 8 psi pressure observing the discharge spray characteristics.  Report the following:

    a,   The maximum pressure at which no bubbles are released into the surrounding air.


                                               13

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                                      MIL-PRF-87937D

    b.    The distance the gel can be satisfactorily projected.

4.5.25.1 Technique.  Under these optimized conditions apply with a sideways sweeping motion the
compound to a vertical surface and examine the deposited film and record assessment. The product
should display uniformity with absence of large and entrained air bubbles or a consistency which would not
inhibit effective cleaning.

4.5.25.2 Application test equipment.

    a.    Reservoir: Hand pump pressure sprayer (modified), or pressure pot with air pressure applied
from external compressor.

    b.    Nozzle:  Fan jet with an equivalent orifice diameter 1.1 mm and spray angle 65°.  (Spraying
Systems Co., Wheaton Illinois, Item Number H-W 6503)

4.5.26  Effect on polvimide Insulated wire. Coil two segments of MIL-DTL-81381/11-20 wire approximately
61 cm (24 in) and place into separate 118 ml (4 oz) wide mouth jars. To one jar add sufficient concentrate
cleaning compound to completely cover the wire coil. To the other jar (control sample) add sufficient
distilled water to cover the wire coil. Cap both jars and store at room temperature (20 - 25 °C) for 14 days.
At the end of the storage period remove both coils, rinse thoroughly with distilled water and suspend to
allow complete draining and drying. Uncoil the wires, examine each closely for dissolution, and report the
results.  The wire immersed in the cleaner shall perform as well as the wire immersed in distilled water,
Both wires shall then be subjected to a double reverse wrap on a 0.3 cm (0.125 in)  mandrel and examined
for cracking. (Note:  Failure of the control sample here voids the test and shall be repeated using new
MIL-DTL-81381/11-20 material). Wire immersed in the cleaner shall then be examined for cracking. If
cracking occurs results shall be reported and the test ended.  Passing wire shall then withstand a one
minute dielectric test of 2,500 volts (rms), using a Hypot model number 4045 or equivalent, and examined
for breakdown or leakage. Wire immersed in the cleaner shall perform equally well as the control wire
immersed in distilled water.

4.5,27 Wet adhesion tape test. This method tests the coating to metal and the intercoat adhesion of an
organic coating system. This procedure is used to determine the cleanliness of the surface prior to
coating.

4.5.27.1 Preparing test coupons.  The test coupons shall consist of nine (9) 4 in x 6 in aluminum alloy
coupons conforming to SAE AMS QQ-A-250/12. The coupons shall be cleaned with reagent grade
acetone, then cleaned with the diluted cleaning compound (10% solution) agitated for 20 seconds with a
Scotch Bright pad  (A-A-58054, Type I Class 1, Grade B, maroon color) and thoroughly rinsed with water
and allowed to dry. Pretreat the coupons with AMS 1640 and MIL-C-5541. The coupons shall be air dried
and primed with MIL-PRF-23377, Type I Class C high solids epoxy primer. Topcoat the coupons
according to Table VI as follows:


            Set1  Six coupons (Code A plus D)
            Primer:  MIL-PRF-23377, Type I, Class C High-Solids Epoxy
            Topcoat: MIL-PRF-85285, Type I High Solids Polyurethane Color * 34092

            Set 2: Three coupons (Code A plus D)
            Primer:  MIL-PRF-23377, Type I, Class C High-Solids Epoxy
            Topcoat: MIL-PRF-85285, Type I High Solids Polyurethane Color # 17925.


The coatings should be allowed to cure for a minimum of seven (7) days before being validated by
performing the wet tape test.

4.5,27.2 Coupon validation procedure. The nine coupons (two sets in 4.5.27.1) shall be validated using
the following wet tape test.

                                              14

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                                       MIL-PRF-87937D



       a.     Immerse the test coupons in distilled water for 24 hours.

       b.     Remove tie test coupons from the water and wipe dry with a clean lint free cloth.

       c.     Immediately apply a 25.4 mm wide strip of Masking Tape (3M Co., Code No. 250) with the
adhesive side down. Do not apply the tape within 1/2 inch of any edge.

       d.     Press the tape against the surface of the coating by passing a 2.0 kg rubber covered roller,
having a surface Ourometer hardness value of 70 to 80, across the tape eight times.

       e.     Remove the tape with one quick motion and examine for damage to the intercoat or
surface adhesion.

       f.      If there is no damage to the surface, note and proceed to 4.5.27.3.  If three or more
coupons fail the wet tape test or there is any unusual or non-typical condition, investigate to determine if
use of cleaner contributed to failure or unusual condition.  Report findings.  Failed coupons or coupons
with unusual surface conditions shall not be validated nor used in the repaint testing of Section 4.5.27.3.

4,5.27.3 Test procedure.  This test shall verify the cleaning compound's effectiveness to remove soil from
a painted surface in preparation for repainting (touch up).  Immerse the coupons validated in 4.5.27.2 in
hydraulic fluid conforming to MIL-PRF-83282 for ten (10) minutes. Remove the panels from the fluid and
blot excess fluid from the coupons with a paper napkin. Spray the diluted cleaning compound (10%
solution) on the coupons, agitate for 20 seconds with a 3M Scotch Bright Pad (A-A-58054) and thoroughly
rinse with clean water.  After the coupons have air dried, recoat the panels from Table VI as follows:


            Set 1: Three coupons (code B plus D)
            Primer; MIL-PRF-85582, Type I, Class 1B Waterborne Epoxy
            Topcoat:  MIL-PRF-85285 Type I High Solids Polyurethane, Color #34092

            Set 2: Three coupons (Code A plus D)
            Primer: MIL-PRF-23377, Type I, Class C High Solids Epoxy
            Topcoat:  MIL-PRF-85285 Type I High Solids Polyurethane, Color # 34092

            Set 3: Three coupons (Code C plus D)
            Primer: TT-P-2760, Type I,  Class C High Solids Elastomeric, Polyurethane
            Topcoat:  MIL-PRF-85285 Type I High Solids Polyurethane, Color # 34092


After the above coatings have air dried for seven (7) days, perform the Wet Tape Test in paragraph
4.5.27.2, steps (a) through (e). The coating system shall show no signs of damage.

4.6 Toxicltv and waste disposal characteristics. The supplier shall provide the lexicological data and
formulations required (see 3.3) to evaluate the safety of the material proposed for use. The manufacturer
shall provide current procedures for disposal per federal EPA regulations.

4.7 Filler materials. The contractor shall furnish certification that the cleaning compound contains only the
materials allowed and does not contain any filler materials disallowed per 3.2.

4.8 Qualitative identification of components (Types I, II, III, and IV).

4.8.1  Gas chromatogram  (Type I only). A gas chromatogram of the Type I product shall be provided by a
Government approved qualification laboratory (see 3.4). The chromatogram shall report all salient
instrumental parameters (column type and dimensions, temperature(s), carrier gas and flow rate, detector
type, sample dilution(s), etc. required to produce it.
                                              15

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                                       MIL-PRF-87937D

4.8.2  Infrared spectrogram  (Types II. Ill, and IV).  Infrared spectrograms of the nonvolatile matter shall
be prepared by a Government approved qualification laboratory (see 3.4).  The spectrogram, including
method for sample preparation, shall be provided to the qualifying activity by the qualification laboratory.

5. PACKAGING

5.1  Packaging. For acquisition purposes, the packaging requirements shall be as specified in the
contract or order (see 6.2). When actual packaging of material is to be performed by DoO personnel,
these personnel need to contact the responsible packaging activity to ascertain requisite packaging
requirements. Packaging requirements are maintained by the Inventory Control Point's packaging activity
within the Military Department or Defense Agency,  or within the Military Department's System Command.
Packaging data retrieval is available from the managing Military Department's or Defense Agency's
automated packaging files, CD-ROM products,  or by contacting the responsible packaging activity

6. NOTES

6.1  Intended use.  The four types of cleaning compounds covered by this specification are intended to be
used for cleaning Aerospace Equipment including aircraft, aerospace ground equipment (AGE) and AGE
engines. These cleaners will be used in place of other cleaners when approved by the System Program
Manager of the equipment being cleaned. Type I should be used only on polyurethane and enamel
coatings as it may attack acrylic nitrocellulose lacquer coatings found in numerous aircraft. Types I and IV
materials are intended for light to heavy duty removal of greases, oils, hydraulic fluid, and  carbon. Type II
is intended for light to medium cleaning and is not intended to remove heavy soils.  Types II  and IV
cleaning compounds are also intended for cleaning aircraft and aerospace ground equipment surfaces of
contaminants prior to coating or recoatmg with primers, topcoats, sealants and adhesives. Types I, II and
IV must be diluted with water before use. Type III is intended for light to heavy duty removal of greases,
oils, hydraulic fluid, and carbon in  wheel wells, wing butts and other areas where complete rinsing with
water can  be tolerated.  After cleaning, rinse off with water. These cleaners are not intended to be used
as canopy cleaners. These products have not been tested for use at elevated temperatures.

6.2  Acquisition requirements. Acquisition documents should specify the following:

        a. Title, number and date of this specification.
        b. Type I, Type II, Type III or Type IV,
        c. Size containers required.
        d. QPL reference or test number.
        e. Level of packing required.
        f.  Palletization, when applicable.

6.3  Material safety data sheets.  Contracting officers should  identify those activities requiring copies of
completed Material Safety Data Sheets prepared in accordance with FED-STD-313

6.4 Qualification. With respect to products requiring qualification, awards will be made only for products
which are at the time set for opening of bids, qualified for inclusion in the applicable QPL whether or not
such products have actually been so listed by that date.  The attention of the contractors is called to this
requirement, and contractors are urged to arrange to have their products that they propose to offer to the
Federal Government tested for qualification in order that they may be eligible to be awarded  contracts or
orders for the products covered by this specification.  Information pertaining to qualification of products
may be obtained from the qualifying activity (see 3.1.3).

6.5 Conformance tests. Conformance inspection should consist of examinations and tests necessary to
ensure that production items meet specification requirements.  Conformance inspection should include a
description of the inspection procedure, sequence of inspections, number of units to be inspected, and the
criteria for determining Conformance to the requirement specified. Conformance examinations and tests
should not duplicate any long term or special tests that were  used to justify inclusion of qualification in a
specification.
                                               16

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                                      MIL-PRF-87937D

6.6 Changes from previous issue. Marginal notations are not used in this revision to identify changes with
respect to the previous issue due to the extent of the changes.

6.7 Key words.

        AGE

        Biodegradable

        Gel-type

        QPL

        Terpene
Custodians:                                                   Preparing activity:
  Air Force - 68                                                 Air Force - 68
  Navy - AS                                                    (Project 6850-1441)

Review activities:
  Air Force-11
  DLA-GS
                                             17

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                                   MIL-PRF-87937D



                                     Appendix A





                           TABLE I. Quantitative Requirements
REQUIREMENT
Insoluble Matter (WT%)
Flash Point (°F)
10% Solution
Concentrated Solution
Emulsion Characteristics
(ml free water)
5min
8 hours
24 hours
Wet Adhesion Tape Test
% Cleaning Efficiency
Terpene Hydrocarbons
(%WT)
TYPE I
MIN


200
120



13.0


95

25
MAX
0.05





5.0





40
TYPE II
MIN



None I/




13.0
Pass
65


MAX
0.05





5.0





None
TYPE III
MIN



Nonel/




8.0

65


MAX
0.05





5.0





None
TYPE IV
MIN



None I/




11.0
Pass
90


MAX
0.05





5.0





None
TEST
METHOD
4.5.2


4.5.7



4.5.8

4.5.27
4.5.21

4.5.23
y No flash point should be observed up to the boiling point of the compound.
                                          18

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                    yiL-PRF-87937D

                       Appendix A


       TABLE II. Total Immersion Corrosion Requirements
         Alloy
Average of 3 Panels
Weight Loss, Max
(mg/cma/168 hrs)
Magnesium {AZ 31B-H24)
AMS 4377 surface treatment
per SAE AMS M-3171, Type I

Aluminum, SAE AMS
QQ-A-250/4.T3
surface treatment per
MIL-A-8625, Type I, Class I

Aluminum, SAE AMS
QQ-A-250/4, Bare T3 Alloy

Aluminum, SAE AMS
QQ-A-2SO/12, Bare T6 Alloy

Titanium, SAE AMS T-9046,
6AL-4V Class III,
Composition C

Steel, AMS 5046, SAE 1020

Steel, 410 SS, Silver Plated
per SAE AMS 2410
      0.50



      0.15




      0.15


      0.15


      0.10



      0.25

      0.10
                           19

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    MIL-PRF-87937D



       Appendix A






TABLE 111. Sampling for Tests
Number of Containers
in lot
2 to 15
16 to 25
26 to 90
91 to 150
151 to 280
281 to 500
501 to 1200
1201 to 3200
3201 to 10000
10001 to 35000
35001 to 150000
150001 to 500000
500001 and over
Number of Containers
to be sampled
2
3
5
8
13
20
32
50
80
126
200
315
500
           20

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     MIL-PRF-87937D



       Appendix A
TABLE IV. Test Panei Finishes
Primer Coatings
Panel
Set
No.
EH
Primer Material Specification
MIL-PRF-23377, Type 1, Class
C High-Solids Epoxy Primer
Dry Film Thickness
Per Coat/
mm (inches)
0.0152-0.0229
(0.0006-0.0009)
No. of
Coats
1
Drying Time Before
Topcoating
2 - 8 hours
Top Coats, Color Number 17925 per FED-STD-595
Panel
Set
E
H
Topcoat
Material
MIL-PRF-22750
Coating, Epoxy
Topcoat
MIL-PRF-85285
Type I Coating:
Polyuretftane,
High Solids
Dry Film
Thickness Per
Coat/ mm
(inches)
0.0203 - 0.0305
(0.0008 - 0.0012)
0.0203 - 0.0305
(0.0008-0.0012)
No. of
Coats
2
2
Drying
Time
Between
Coats
1 hour
1 hour
Dry Film
Thickness mm
(inches)
0.0406-0.0610
(0.0016-0.0024)
0.0408-0.0610
(0.0016 - 0.0024)
Days to
Dry
Before
Testing
7
7
           21

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                                      MIL-PRF-87937D
                                         Appendix A
                     TABLE V. Control Formula for the Cleaning Efficiency Test
                          Component
       d-limonene
       diethanolamine
       nonionic surfactant (Triton X-100)
       distilled water (ASTM D 1193, Type IV)
      Control Formula
Composition {% by weight) jj
           30.0
            5,0
            5.0
           60.0
I/,       This formulation is corrosive and intended solely for use as the control for the cleaning efficiency
test. It will not qualify to the requirements in this specification.
                                 TABLE VI. Test Panel Finishes
Primer Coatings
Code
A
B
C
Primer Material Specification
MIL-PRF-23377,Type I, Class
C Primer Coatings; Epoxy,
High-Solids
MIL-PRF-85582, Type I, Class
1 B Primer Coatings: Epoxy,
Waterbome
TT-P-2760, Type I, Class C
Primer Coating: Polyurethane,
Elastomeric, High-Solids
Dry Film Thickness
Per Coat/
mm (inches)
0.0152-0.0229
(0.0006-0.0009)
0.0152-0.0229
(0.0006 - 0.0009)
0.0380-0.0510
(0.0015-0.0020)
No. of
Coats
1
1
1
Drying Time Before
Topcoating
2-8 hours
2-8 hours
2 - 8 hours
Top Coats
Code

D
Topcoat Material
MIL-PRF-85285,
Type I Coating:
Polyurethane,
High-Solids
Dry Film
Thickness Per
Coat/ mm
(inches)

0.0203 - 0.0305
(0.0008-0.0012)
No. of
Coats

2
Drying
Time
Between
Coats

1 hour
Dry Film
Thickness mm
(inches)

0.0406-0.0610
(0.0016 - 0.0024)
Time
Before
Testing
(Days)

7
                                             22

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         STANDARDIZATION DOCUMENT IMPROVEMENT  PROPOSAL
                                               INSTRUCTIONS
   1.   The preparing activity must complete blocks 1,2,3, and 8. In block 1, both the document number and revision letter should be
      given.

   2.   The submitter of this form must complete blocks 4, 5, 6, and 7, and send to preparing activity.

   3.   The preparing activity must provide a reply within 30 days from receipt of the form.

   NOTE:  This form may not be used to request copies of documents, nor to request waivers, or clarification of requirements on current
  contracts.  Comments submitted on  this form do not constitute or imply authorization to waive any portion of the referenced
  document(s) or to amend contractual requirements.
   I RECOMMEND A CHANGE:
1. DOCUMENT NUMBER
MIL-PRF-87937D
2. DOCUMENT DATE (YYYYMMDD)
20010924
 3.  DOCUMENT TITLE  CLEANING COMPOUND, AEROSPACE EQUIPMENT
 4, NATURE OF CHANGE (Identify paragraph number and include proposed rewrite, if passible Attach extra sheets as needed.)
 5. REASON FOR RECOMMENDATION
 6. SUBMITTER
 a. NAME (Last, First, Middle Initial)
                b. ORGANIZATION
 c. ADDRESS f/nc/ucte Zip Code)
                d. TELEPHONE (Include Area Code)
                (1) Commercial
                (2) AUTOVON
                   Ofapplicable)
         7.0ATE SUBMITTED
           (YYYYMMOD)
 8. PREPARING ACTIVITY
 a.  NAME  Code(68)DŁT3
         WR-ALC/AFTT, Bldg. 1621-K
                b. TELEPHONE Include Area Code)
                (1) Commercial
          (2) AUTOVON
 c. ADDRESS (Include Zip Code)
    2261 Hughes Ave. Ste 123
    Lackland, AFB, TX 78236-9823
                IF YOU DO NOT RECEIVE A REPLY WITHIN 45 DAYS, CONTACT:
                    Defense Standardization Program Office (DLSC-LM)
                    8725 John J. Kingman road, Suite 2533  Ft Belvoir, VA 22060-2533
                    Telephone (703) 767-6888       AUTOVON 427-6888
DD Form 1426, FEB1999 (EG)
                                          PREVIOUS EDITION IS OBSOLETE
                                                     WHS/DIOR, Fetl 99

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                 Appendix B




SMI Results from Eagle Kleen I Analytical Testing

-------
SMI,  Inc.
12219 SW 131 Avenue                               Phone:    (305)971-7047
Miami, Florida 33186-6401  USA                      Fax:       (305)971-7048
Attn:        BATTELLE MEMORIAL INSTITUTE         Date:      20-Sep-2004
            505 King Avenue                         SMI REF:   04JUL562
            Columbus, OH  43201

PRODUCT:  EAGLE KLEEN                          Page 1 of 9
            (received 14-Jul-2004)
            40 CFR 796.3100: AEROBIC AQUATIC BIODEGRADATION
                         Code of Federal Regulations
                       Environmental Protection Agency
                      Title 40: Protection of Environment
                   Part 796: Chemical Fate Testing Guidelines
                          Shake Flask Method
Summary of Results:

Based on dissolved organic carbon analysis:
            "EAGLE KLEEN" = 87.8 % Biodegradable in 28 days
See Appendix A for graphical representation of Biodegradability vs. Time .
PROCEDURE

I.  Introduction

This procedure provides  a  way to determine the rate and  extent of aerobic
biodegradation that might occur when chemical substances are released to aquatic
environments. A high biodegradability result in this test provides evidence that the test
substance will be biodegradable in natural aerobic freshwater environments.  A low
biodegradability  result may not necessarily  indicate poor biodegradation, as other
factors may interfere, such as inhibition of the microbial inoculum by the test material.
   SCIENTIFIC   MATERIAL    INTERNATIONAL
                          www. smiinc.com
                                  B-l

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Client:      Battelle Memorial Institute                   Date:       20-Sep-2004
Product:     EAGLE KLEEN                            SMI REF:    04JUL562
                                                      Page 2 of 9
EPA796.3100: AEROBIC AQUATIC BIODEGRADATION	

II. Principle of the Test Method

The method consists of a 2-week inoculum buildup period during which the microbes
are allowed to adapt to the test compound. The acclimated media containing a defined
amount of test compound is added to specially equipped  Ertenmeyer flasks. The test
media is sampled periodically and analyzed for dissolved organic carbon  (DOC). A
reservoir filled with  barium hydroxide  is utilized to measure the amount of  carbon
dioxide evolved.  The degree of biodegradation is determined by comparison of the
extent of DOC  disappearance and the amount of carbon dioxide liberated. Control
flasks containing no test compounds are run simultaneously and are used to estimate
the degree  of  ultimate  biodegradation.    Reference substances  which will  exhibit
ultimate biodegradation may be run  simultaneously to check the activity  of the
inoculum.  If the reference samples do not exhibit at least 60  percent of theoretical
maximum carbon dioxide, and at least 70 percent DOC removal within 28 days, the test
will be regarded as invalid and shall be repeated using different inoculum.

This  method is believed to be appropriate for a screening test which has solely an
acceptance but no rejective function.

III. Test Procedure

The total organic carbon (TOC) of the test compound is first determined by analysis or
calculation  if the formulation is  known. Determination  of  the minimum  inhibitory
concentration is useful to insure that the test compound will  not be inhibitory to the
microbes at the required concentration.  The shake flask apparatus  is assembled
utilizing a 2-liter Erlenmeyer flask and a 50 ml centrifuge tube.  The tube containing 10
mis of barium hydroxide will be suspended over the contents of the flask in such a way
that liberated carbon dioxide may diffuse into the barium hydroxide, while allowing the
contents of the tube to be  removed for analysis without spilling into the test  media.
Glass  tubing may be  utilized  as access into the flask for  sparging, venting,  and
sampling.

Stock solutions I,  II, and III are  prepared (see Appendix  B), along with 0.2 N  barium
hydroxide and 0.1 N.HCI.   Acclimation medium is prepared  by adding  1 ml each of
stock solutions I, II and III to 1 liter of  distilled, deionized  water (DIW). The microbial
inoculum is  obtained from sewage and soil  or from  Polyseed  and is  added to the
acclimation medium.  Test compounds  are added incrementally during the acclimation
period at concentrations equivalent to 4, 8,  and 8 mg/L carbon on days 0,  7, and 11,
respectively. On day 14, the medium is ready for use in the test.
                                    B-2

-------
Client:      Battelle Memorial Institute                   Date:        20-Sep-2004
Product:     EAGLE KLEEN                            SMI REF:    04JUL562
                                                      Page 3 of 9
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION	____
Biodegradability test flasks are prepared by adding 100 mis of acclimation medium to
900 mis of DIW along with 1 ml each of solutions I, II, and III to the 2-liter Erlenmeyers.
Additional test compound equivalent to 10 mg/L carbon is added to the flasks. Ten mis
of barium hydroxide are added to the suspended reservoirs in each flask and 10 mis
are also saved for use as a titration blank. Flasks are sparged with carbon dioxide-free
air, sealed and placed on a shaking table (approx. 125 rpm) at 20 - 25 deg C in the
dark.  Test flasks should be run in triplicate and sampling should occur at time zero and
at least four other times to allow for a smooth plot of biodegradation.  Each sample for
DOC analysis is first centrifuged or filtered through  a 0.45 micrometer or smaller pore
diameter. On the day prior to terminating the test, 3 mis of 20 percent sulfuric acid are
added to release carbonate bound carbon dioxide.
IV.  ANALYTICAL MEASUREMENTS

The quantity of carbon dioxide evolved is measured by titration of the entire barium
hydroxide sample with 0.1 N HCI to the phenolphthalein end point, blank subtracted.
Theoretically, 10 mg of carbon is converted to 0.833 mmol of carbon dioxide. Absorbed
carbon dioxide precipitates as barium carbonate, causing a reduction in alkalinity by the
equivalent of 16.67 ml of 0.1 N HCI for complete conversion of the test compound
carbon to carbon dioxide. Therefore, the  percent theoretical carbon dioxide evolved
from the test compound is calculated at any sampling time from the formula:
                  % CO2 evolution = [(TF - CF)/16.67] • 100

                  where:

                  TF =  mis of 0.1 N HCI used in titration of test flask

                  CF =  mis of 0.1 N HCI used in titration of control flask
                                    B-3

-------
Client:       Battelle Memorial Institute                  Date:        20-Sep-2004
Product:     EAGLE KLEEN                           SMI REF:    04JUL562
                                                    Page 4 of 9
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION	
The DOC analysis is performed using a suitable organic carbon method.  The percent
DOC disappearance from the test compound is calculated from the formula:

            % DOC removal  = [1 - (DTFX - DCFX)/(DTFO - DCFO)] • 100

            where:

            DTF  = Dissolved organic carbon from test flask
            DCF  = Dissolved organic carbon from control flask

            o    = Day zero measurements
            x    = Day x measurements


V. REPORT OF RESULTS


Inoculum: Polyseed and Mixed inoculum

Date Received: July, 2004

Source:  Fisher Scientific and Metro-Dade County Water & Sewer Authority

Storage: Ambient temperature, used within 24 hours

Minimum Inhibitory Concentration:  MIC < 3.125 %   (non-inhibitory to  microbes at
concentrations lower than 3.125%)

Percent Biodegradation based on DOC analysis:
EAGLE KLEEN:                87.8 % after 28 days (see Table 1)
Reference (Sodium citrate):       92,3 % after 28 days (see Table 1)

Percent Biodegradation based on carbon dioxide evolution:
EAGLE KLEEN:                34,5 % after 28 days (see Table 2)
Reference (Sodium citrate):        42.7 % after 28 days (see Table 2)
                                   B-4

-------
Client:       Battelle Memorial Institute                   Date:        20-Sep-2004
Product:     EAGLE KLEEN                            SMI REF:    04JUL562
                                                     Page 5 of 9
EPA 796.3100:  AEROBIC AQUATIC BIODEGRADATION	

Summary: Since the test compound was found to be over 70 % biodegradable based
on the DOC analysis, it is reasonable to assume that the substance will undergo rapid
and ultimate biodegradation in aerobic aquatic  environments, also known as "ready
biodegradability". The test is validated by the fact that the reference compound, sodium
citrate, exhibited a biodegradability over 70%.

The percent biodegradability based on carbon dioxide evolution is typically lower than
that of the DOC based numbers. In this case, the carbon dioxide evolution measured
was  significant,  both  on the test compound and on  the  reference,  and the  results
generally agree.
                              Respectfully submitted,
                                           ;i  PY
                                           \A
                              Patricia D. Viani
                              SMI, Inc.
                                   B-5

-------
Client:     Battelle Memorial Institute
Product:    EAGLE KLEEN

EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION
                           Date:      20-Sep-2004
                           SMI REF:   04JUL562
                           Page 6 of 9
          TABLE I - DISSOLVED ORGANIC CARBON (DOC} VALUES
Sample:  EAGLE KLEEN

A
B
C
AVERAGE
CORRECTED AV
% BIODEGRADED
Reference: Sodium
A
B
C
AVERAGE
CORRECTED AV
% BIODEGRADED
BLANK A
B
C
DAYO
38.2
35.7
37.9
37.3
34.1
N/A
Citrate
38.8
37.1
36.2
37.4
34.2
N/A
3.3
3.2
3.0
DAY 7
12.7
8.2
7.1
9.3
6.0
82.5%

9.5
12.9
10.7
ii.o
7.7
77.6%
3.5
3.2
3.4
DAY 14
9.5
7.5
7.0
8.0
4.7
86.3%

5.9
8.2
7.1
7.1
3.7
89.1%
3.2
3.5
3.3
DAY 21
8.1
7.2
7.1
7.5
4.2
87.8%

5.7
6.3
5.9
6.0
2.7
92.2%
3.1
3.6
3.2
DAY 28
8.1
7.2
7.2
7.5
4.2
87.8%

5.8
6.1
6.0
6.0
2.6
92.3%
3.6
3.0
3.4
AVERAGE
3.2
3.4
3.3
3.3
3.3
                               B-6

-------
Client:     Battelle Memorial Institute
Product:    EAGLE KLEEN

EPA 796.3100: AEROBIC AQUATIC BIODEGRADATIQN
                                 Date:      20-Sep-2004
                                 SMI REF:   04JUL562
                                 Page 7 of 9
                  Table II - Titration Data for CO2 Evolution
Sample:  EAGLE KLEEN
              A
              B
              C

AVERAGE
CORRECTED AVG
% BIODEGRADED
mis theoretical:       56.9

Reference:  Sodium Citrate

              A
              B
              C
AVERAGE
CORRECTED AVG
% BIODEGRADED
mis theoretical:       57.0
BLANK
AVERAGE
A
B
C
DAY 7
4.2
5.2
4.6
4.7
12.9
22.6%

3.4
3.8
3.8
3.7
13.9
24.3%

17.8
17.0
17.8
DAY 14 DAY 21
11.8
13.8
10.2
11.9
5.9
10.4%

11.8
7.8
7.4
9.0
8.9
15.6%

18.2
17.6
17.8
17,4
17.4
17.2
17.3
0.7
1.3%

16.8
17.2
15.8
16.6
1.5
2.6%

18.0
18.2
18.0
DAY 28
17.6
18.2
18.2
18.0
0.1
0.2%
TOTAL=
18.2
18.0
17.8
18.0
0.1
0.2%
TOTAL =
18.2
17.8
18.4
                                          34.5%
                                          42.7%
             17.5
17.9
18.1
18.1
                               B-7

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN

EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION
                                           Date:       20-Sep-2004
                                           SMI REF:   04JUL562
                                           Page 8 of 9
B
I
0
D
E
G
R
A
D
E
D
    100 T
     90--
     80--
     70--
60--
                              Appendix A

                      BIODEGRADABILITY VS. TIME
                             EAGLE KLEEN
                               B-8

-------
Client:     Battelle Memorial Institute
Product:    EAGLE KLEEN

EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION
                          Date:
                          SMI REF:
                          Page 9 of 9
20-Sep-2004
04JUL562
                             Appendix B
                     STOCK SOLUTIONS I, II, AND
     SOLUTION I:
     SOLUTION II:
     SOLUTION III:
35   g/L   NH4CI
15   g/L   KNO3
75   g/L   K2HP04-3H2O

25   g/L   NaH2PO4-H2O
10   g/L   KCI
20   g/L   MgSO4
 1   g/L   FeSO4-7H2O

adjust pH of Soln II to 3.0
5 g/L
0.05 g/L
0.5 g/L
0.05 g/L
0.001 g/L
0.001 g/L
0.0004 g/L
CaCI2
ZnCI2
MnCI2-4H20
CuCI2
CoCI2
H3BO3
MoO3
                               B-9

-------
                  Appendix C




SMI Results from Eagle Kleen II Analytical Testing

-------
SMI, Inc.
12219SW131 Avenue
Miami, Florida 33186-6401  USA
                                       Phone:
                                       Fax:
         (305)971-7047
         (305)971-7048
Attn:
Product:

Dilution:
Sara F. Kuczek
Battelle Memorial Inst.
505 King Avenue
Columbus, OH  43201
Date:       30-Sep-2004

SMI/REF:   04AUG682
EAGLE KLEEN II  (received 10-Sep-2004)

Ready to Use                             Page 1 of 4
               Modified partial testing of section 3.7, Effect on Metals
                      (product was tested neat - [undiluted])
                        M1L-PRF-87937D  (24Sep2001)
               CLEANING COMPOUND, AEROSPACE EQUIPMENT
            Type IV - Heavy Duty, Water Dilutable Cleaning Compound
3.7   Effect on metals
      3.7.1  Hydrogen embrittlement
      3.7.2  Total immersion corrosion
      3.7.3  Low-embrittling cadmium plate corrosion
      3.7.4  Effects on unpainted metal surfaces
      3.7.5  Sandwich corrosion
      3.7.6  Wet adhesion tape test
                                               Conforms*
                                            Does not conform*
                                            Does not conform*
                                              Not performed
                                               Conforms*
                                              Not performed
* Test performed using "as received" solution (ready to use) instead of dilution required by
specification.   Results should not be considered for QPL listing.
                       Respectfully^submitted ,
                       Patricia D. Viani, SMI Inc.
   SCIENTIFIC
              MATERIAL    INTERNATIONAL
               www. smiinc.com

-------
Client:       BATTELLE                                Date:        30-Sep-2004
Product:     EAGLE KLEENII                            SMI/REF:    04AUG682
Dilution:     Ready to use
MIL-PRF-87937D (Type IV)	Page 2 of 4	
3.7   Effect on metals
3.7.1  Hydrogen embrittlement: When tested in accordance with 4.5.9, the concentrated
      cleaner (all types) and a 10% solution of the cleaner (Types I, II, and IV only) in
      distilled water shall not cause hydrogen embrittlement of cadmium plated or IVD
      aluminum coated AISI4340 steel.

      Test temperature:  21 - 23°C (69 - 73°FJ
      Specimens: Type  1c, cadmium plated in accordance with Treatment B ofASTM F519

            As received:      No failures within 150 hours.
            Dilute (10 %):     Not performed

                                                Result	Conforms*	

      Test temperature:  21 - 23°C (69 - 73PF)
      Specimens: Typelc, grit blasted, IVD Aluminum plated per MIL-DTL-83488D, CI2, Tyl.

            As received:      No failures within 150 hours.
            Dilute (10%):     Not performed
                                                Result  	  Conforms*	
      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      BATTELLE
Product:     EAGLE KLEEN II
Dilution:     Ready to use
MIL-PRF-87937D (Type IV)
Date:
SMI/REF:

Page 3 of 4
30-Sep-2004
04AUG682
3.7.2  Total immersion corrosion: When tested in accordance with 4.5.10 (ASTM F 483),
      the concentrated cleaning compound (all types) and a 10% solution of the cleaning
      compound (Types I, II and IV only) in distilled water shall not show any indication of
      staining, etching, pitting, or localized attack on any of the panels, or cause a weight
      change of an average of three (3) test panels greater than that shown in Table II. A
      slight  discoloration of the panels shall  not  be objectionable.   The cleaning
      compound shall not layer or separate for the duration of the test.

                 Table II Total Immersion Corrosion Requirements
Alloy
Magnesium (AZ 31B-H24) AMS 4377 surface
treatment per SAE AMS-M-3171, Ty III
Aluminum, SAE AMS-QQ-A-250/4, T3 surface
treatment per MIL-A-8625, Type I, Class I
Aluminum, SAE AMS-QQ-A-250/4, Bare T3 Alloy
Aluminum, SAE AMS-QQ-A-250/12, Bare T6 Alloy
Titanium, SAE AMS-T-9046, 6AI-4V Cl III, Comp. C
Steel, AMS 5046, Grade 1 020
Steel, 410 SS, Silver Plated per SAE AMS 2410
Weight Loss (mg/cm2/168hrs)
Maximum
allowed
0.50
0.15
0.15
0.15
0.10
0.25
0.10
As
received
0.14
0.01
0.01
0.01
0.01
0.571
0.01
10%
NOT PERFORMED
1 Exceeds allowable weight change; significant discoloration/darkening
                                                Result     Does not conform*
3.7.3  Low-embrittling cadmium plate corrosion: Steel panels coated with low-embrittling
      cadmium plate immersed in the concentrated cleaning compound (all types) and a
      10% solution of the cleaning compound (Types I, II and IV only) in distilled water
      shall not show a weight change greater than 0.14 mg/cm2 for 24 hours when tested
      in accordance with 4.5.11.
            As received:      0.20* mg/cm2/24hrs
            Dilute (10%):      Not performed
                                                Result     Does not conform*
      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      BATTELLE
Product:     EAGLE KLEEN II
Dilution:     Ready to use
MIL-PRF-87937D (Type IV)
                                                Date:       30-Sep-2004
                                                SMI/REF:    04AUG682

                                                Page 4 of 4	__
3.7.4
Effects on unpainted metal surfaces: The concentrated cleaning compound (Type III
only) and a 10% solution (Types I, II and IV only) of the cleaning compound in
distilled water shall not cause streaking, stains or other deposits that cannot be
easily removed with water when tested in accordance with 4.5.12.
                                                Result
                                                      Not performed
3.7.5
Sandwich corrosion: When tested in accordance with 4.5.16, the concentrated
cleaner (all types) and a 10% solution (Types I, II and IV only) shall show no
corrosion in excess of that shown by control test coupons in ASTM D1193, Type IV,
reagent water.

As received
Dilute (10%)
Control
2024-T3 Bare
Anodized
1
2024-T3
Alclad
1
7075-T6 Bare
Anodized
1
7075-T6
Alclad
1
Not performed
1
1
1
1
                                                Result
                                                       Conforms*
3.7.6  Wet adhesion tape test (Types II and IV): A ten (10) percent solution of the cleaning
      compound, when used as directed, shall remove soil from a painted surface in
      preparation fro repainting such that paint applied after cleaning with the compound
      shall adhere to the surface when tested in accordance with 4.5.27.
                                                Result
                                                      Not performed
* Test performed using "as received" solution (ready to use) instead of dilution required by
specification.

-------
                  Appendix D




SMI Results from Eagle Kleen III Analytical Testing

-------
SMI, Inc.
12219 SW 131 Avenue                               Phone:    (305)971-7047
Miami, Florida 33186-6401  USA                      Fax:       (305)971-7048
Attn:        Sara Kuczek                              Date:       07-Mar-2005
            Battelle Memorial Institute
            505 King Ave                             SMI/REF:   04DEC086
            Columbus, OH  43201                                Final Report

Product:     EAGLE KLEEN III (Lot C531-84-1)
            (received 01-Dec-2004)

Dilution:     As received                               Page 1 of 12
           Modified testing (product was tested "as received" [undiluted] )
                       MIL-PRF-87937D (24Sep2001)
              CLEANING COMPOUND, AEROSPACE EQUIPMENT
            Type IV - Heavy Duty, Water Dilutable Cleaning Compound
3.3   Toxicity                                       	Informational
3.3.4  Biodegradability                                	Conforms

3.4   Compositional assurance                        	Informational

3.5   Chemical properties

3.5.1  Chemical requirements
            Insoluble matter                          	Conforms
            Flash point                              	Conforms
            Emulsion characteristics                   	Conforms*
            Wet adhesion tape test                    	Conforms*
            % Cleaning efficiency                     	Conforms*
            Terpene hydrocarbons                    	Not applicable

3.5.2  Residue rinsibility                              	Conforms*

3.6   Physical properties
      3,6.1  Heat stability                                 Does not conform*
      3.6.2  Cold stability                            	Conforms
      3.6.3  Rheology
            3.6.3.1      Consistency                  	Not applicable
            3.6.3.2      Sprayability                        Not applicable

* Test performed using "as received" solution (ready to use) instead of dilution required by
specification.   Results should not be considered for QPL listing.


    SCIENTIFIC   MATERIAL   INTERNATIONAL
                           www. smiinc.com

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN 111 Lot # C531 -84-1
Dilution:     Per specification
MIL-PRF-87937P (Type IV)	
Date:       07-Mar-2005
SMI/REF:    04DEC086
            Final Report
Page 2 of 12	
3.7   Effect on metals
      3.7.1  Hydrogen embrittlement
      3.7.2  Total immersion corrosion
      3.7.3  Low-embrittling cadmium plate corrosion
      3.7.4  Effects on unpainted metal surfaces
      3.7.5  Sandwich corrosion
      3.7.6  Wet adhesion tape test

3.8   Effect on painted surfaces

3.9   Stress crazing of MIL-PRF-5425 and
      MIL-PRF-25690 (Type A and C) acrylic plastics

3.10  Stress crazing of polycarbonate plastic

3.11  Long-term storage stability

3.12  Hot dip galvanizing corrosion

3.13  Workmanship

3.14  Effect on polysulfide sealants

3.15  Rubber compatibility

3.16  Effect on polyimide insulated wire
        Conforms*
        Conforms*
        Conforms*
        Conforms*
        Conforms*
        Conforms*
        Conforms*
    Does not conform*
    Does not conform*
      Not performed
        Conforms*
   To be Cert, by Mfr.
        Conforms*
        Conforms*
        Conforms
* Test performed using "as received" solution (ready to use) instead of dilution required by
specification.   Results should not be considered for QPL listing.
                        Respectfully submitted,
                        Patricia D. Viani, SMI Inc.

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN III Lot # C531 -84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)	
Date:
SMI/REF:

Page 3 of 12
07-Mar-2005
04DEC086
Final Report
3-1.1  Qualification (Initial): Thecleaning compound furnished under this specification shall
      be a product which has been tested and has passed the qualification tests specified
      herein and has been listed or approved  for listing on the applicable Qualified
      Products List (QPL).
3.3   Toxicity: The cleaning compound shall have no adverse effect on the health of
      personnel or the environment when used for its intended purpose and with proper
      personal protective equipment (when required). The product shall be evaluated for
      aquatic toxicity with a 96-hour Fathead minnow (Pimephales promelas) bioassay
      and a 48-hour Ceriodaphnia dubia bioassay in accordance  with Methods for
      Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and
      Marine Organisms, EPA/600/4-90/027. The percent survival at 1,10, 50, and 100
      ppm shall be reported for both organisms.
% of Fathead Minnows (P/Vnej
Concentration
1 ppm
10 ppm
5.0 ppm
1 00 ppm
After 24 hours
100%
0%
0%
0%
shales promelas) Surviving
After 48 hours
100%
0%
0%
0%
After 96 hours
100%
0%
0%
0%
% of Cladoceran (Ceriodaphnia dub/a) Surviving
Concentration
1 ppm
1.0 ppm
50 ppm
100 ppm
After 24 hours
90%
50%
0%
0%
After 48 hours
50%
20%
0%
0%
                                               Result
      Informational

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN III Lot # C531 -84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)	
Date:
SMI/REF:

Page 4 of 12
07-Mar-2005
04DEC086
Final Report
3.3.4  Biodegradability: The supplier of the cleaning compound shall furnish certification
      from the surfactant manufacturers that the surfactants are readily biodegradable in
      accordance with 40 CFR, Part 796, Subpart D. Biodegradability testing shall be
      accomplished as specified in  paragraph 4.5.22 on the finished  product by an
      independent laboratory approved by the qualifying activity. Biodegradability on the
      finished product shall be determined over  28  days by the Shake Flask Method
      monitored by analysis of Total Organic Carbon (TOC). The Type I compound shall
      meet the requirement of a minimum of 75% biodegradable and Types II, III, and IV
      compounds shall meet the requirement of a minimum of 85 % biodegradable at the
      end of the 28-day period.
            Biodegradability after 28 days: 87.1 %
                                                Result
        Conforms
3.4   Compositional assurance: The cleaning compound shall be tested for nonvolatile
      matter as specified in paragraph 4.5.1. The concentrated cleaning compound and a
      10% solution of the cleaning compound in distilled water shall be tested for pH as
      specified in  paragraph 4.5.3.  Results of these tests as  well as an  infrared
      spectrogram of the nonvolatile matter (see 4.8.2) and a gas chromatogram (see
      4.8.1  for Type I  only)  shall be  recorded by the qualifying activity for use in
      conformance inspections (see 4.3). Conformance inspection results for nonvolatile
      matter shall not differ by more than 2 percent absolute from the recorded value.
      Conformance inspection results for pH shall not differ by more than 1 pH unit from
      the recorded value.  Conformance inspection infrared  spectrograms and gas
      chromatograms shall show no significant difference when compared to the original
      qualifying spectrogram.
PROPERTY
Nonvolatile matter
pH (undiluted)
pH (10%)
Infrared spectrogram
RESULT
13.1%
6.9
N/A (RTU)
Attached
                                                Result
      Informational
3.5   Chemical properties.
3.5.1  Chemical requirements: The cleaning compound shall meet the requirements listed
      in Table I.

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN 111 Lot # C531 -84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)            	
                        Date:        07-Mar-2005
                        SMI/REF:    04DEC086
                                    Final Report
                        Page 5 of 12	
3.5.1  Chemical requirements (continued):

                                   TABLE
Requirement
Insoluble Matter (WT%)
Flash Point (°F)
10 % solution
concentrate
Emulsion Characteristics
(mis free water)
5 minutes
8 hours
24 hours
Wet Adhesion Tape Test
% Cleaning Efficiency
Terpene Hydrocarbons
(% WT)
Type IV
Min.
—
None1
None'
11.0
Max.
0.05
—
5.0
Pass
90%
_
—
None
Test
Method
4.5.2
4.5.7
4.5.8
4.5.27
4.5.21
4.5.23
I/ No flash point should be observed up to the boiling point of the compound.
4.5.2  Insoluble matter The percent insolubles shall be calculated as follows:

            ! = A-B X100
               W
Where:
A = Final filter paper weight
B = Initial filter paperweight
W = Weight of sample
I = % wt. insoluble matter
      Insoluble matter = < 0,01 %
                                                Result
                               Conforms
4.5.7  Flash point:  The flash point of the concentrated cleaning compound (Type I, II, III
      and IV) shall be determined in accordance with ASTM D 56 (Tag Closed Cup) and
      for materials that have a tendency to form a surface film under the test conditions,
      use ASTM D 93. The flash point of the 10% solution in distilled water (Type I only)
      shall be determined in accordance with ASTM D 92.
            Wo flash point observed to initial boiling point (212°F).
                                                Result       Conforms	

-------
Client:      Battelle Memorial Institute                   Date:       07-Mar-2005
Product:     EAGLE KLEEN III Lot #0531-84-1          SMI/REF:   04DEC086
Dilution:     Per specification                                       Final Report
MIL-PRF-87937D (Type IV)	Page 6 of 12	

3.5.1  Chemical requirements (continued):

4.5.8  Emulsion characteristics: Twenty ml of a 25% by volume solution (Types I and II) of
      the cleaning compound (12.5% by volume solution for Types III and IV) shall be
      placed in a 50 ml glass stoppered graduated cylinder.  Twenty ml of lubricating oil
      conforming to MIL-PRF-2104, grade 10W, shall be added.  An emulsion shall be
      formed by 10 inversions of the graduated cylinder followed by a vigorous 15-second
      shake. After the emulsion has stood for 5 minutes, the 15-second shake shall be
      repeated.  At 5 minutes and 8 hours for the Type I and at 5 minutes and 24 hours
      for the Types II, III  and IV cleaners, the amount of free water and cleaner which
      separates from the  lubricating oil shall conform to the requirements of Table I.
            Amount of free water remaining:
            After S minutes  fewer than 5 mis      After 24 hours:  >11 mis

                                                Result	Conforms*	

4.5.21       Cleaning Efficiency: The cleaning efficiency of the cleaning compound shall
            be reported  as the average of three test results and shall conform to the
            requirements of Table I.
            Cleaning Efficiency: 98.5%            Result	Conforms*	

4.5.23      Terpene hydrocarbons (Type I only): An approved test procedure shall be
            used.                               Result	Not applicable

3.5.2  Residue Rinsibility:  When a freshly prepared solution of the cleaning compound is
      tested in accordance with 4.5.4, it shall not leave any residue or stains.  A freshly
      prepared solution is defined as one being prepared  no longer than 30 minutes prior
      to testing. The weight change shall be not greater than that obtained with standard
      hard water tested under the same conditions.
      Wo residue nor stains; no weight change   Result	Conforms*	

3.6   Physical properties (All types unless otherwise noted).
3.6.1  Heat stability: The concentrated  cleaning compound, when tested in accordance
      with 4.5.5, shall show no marked color change or precipitation and shall not corrode
      or stain the AMS 5046 (SAE 1020) steel strip (a slight darkening of the steel strip
      shall not be objectionable). Layering or separation shall constitute failure if it does
      not return to its original  homogeneous state upon cooling.
            Visible corrosion of steel strip; rust-colored precipitation; no layering
                                                Result    Does not conform

      * Tesf performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      Battelle Memorial Institute                   Date:       07-Mar-2005
Product:     EAGLE KLEEN III Lot #C531-84-1          SMI/REF:   04DEC086
Dilution:     Per specification                                       Final Report
MIL-PRF-87937D (Type IV)	   Page 7 of 12	
3.6.2  Cold stability: The concentrated cleaning compound shall return to its original
      homogeneous condition when tested in accordance with 4.5.6.
            Compound returned to original homogeneous condition after 5 cycles

                                                Result	Conforms

3.6.3  Rheology (Type III only).

3.6.3.1      Consistency: When tested as specified in 4.5.24, the concentrated cleaning
            compound shall flow between 10 and 20 centimeters in 10 seconds. The
            product shall also exhibit rheology, which enables it to meet the sprayability
            requirement.
                                                Result	Not applicable

3.6.3.2      Sprayability: The concentrated cleaning compound, when dispensed at 45
            psig  and tested in accordance with 4.5.25, shall  give satisfactory spray
            characteristics and deposit a uniform layer on a vertical surface 3 feet away
            from the nozzle.
                                                Result	Not applicable

3.7   Effect on metals (All types unless otherwise noted).
3.7,1  Hydrogen embrittlement: When tested in accordance with 4.5.9, the concentrated
      cleaner (all types) and a 10%  solution of the cleaner (Types I, II, and IV only) in
      distilled water shall not cause  hydrogen embrittlement of cadmium plated or IVD
      aluminum coated AISI 4340 steel.

      Specimens: Type 1c, cadmium plated in accordance with Treatment B ofASTM F519
            As received:      No  failures within 150 hours.
            Dilute (10 %):      Not performed

                                                Result	Conforms*	

      Specimens: Type 1c, grit blasted, IVD Aluminum plated per MIL-DTL-83488D, CI2, Tyl.
            As received:      No  failures within 150 hours.
            Dilute (10 %):      Not performed
                                                Result	Conforms*	

      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN III Lot # C531-84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)	
Date:
SMI/REF:

Page 8 of 12
     07-Mar-2005
     04DEC086
     Final Report
3.7.2  Total immersion corrosion: When tested in accordance with 4.5.10 (ASTM F 483),
      the concentrated cleaning compound {all types) and a 10% solution of the cleaning
      compound (Types I, II and IV only) in distilled water shall not show any indication of
      staining, etching, pitting, or localized attack on any of the panels, or cause a weight
      change of an average of three (3) test panels greater than that shown in Table II. A
      slight  discoloration of the panels  shall not  be objectionable.   The  cleaning
      compound shall not layer or separate for the duration of the test.

                 Table II Total Immersion Corrosion Requirements
Alloy
Magnesium (AZ 31B-H24) AMS 4377 surface
treatment per SAE AMS-M-31 71 , Ty III
Aluminum, SAE AMS-QQ-A-250/4, T3 surface
treatment per MIL-A-8625, Type I, Class I
Aluminum, SAE AMS-QQ-A-250/4, Bare T3 Alloy
Aluminum, SAE AMS-QQ-A-250/12, Bare T6 Alloy
Titanium, SAE AMS-T-9046, 6AI-4V Cl III, Comp. C
Steel, AMS 5046, Grade 1 020
Steel, 410 SS, Silver Plated per SAE AMS 2410
Weight Loss (mg/cm2/168hrs)
Maximum
allowed
0.50
0.15
0.15
0.15
0.10
0.25
0.10
As
received
0.07
0.02
0.02
0.01
0.01
0.02*
0.02
10%
NOT PERFORMED
Slight discoloration
                                                Result
Conforms*
3.7.3  Low-embrittling cadmium plate corrosion: Steel panels coated with low-embrittling
      cadmium plate immersed in the concentrated cleaning compound (all types) and a
      10% solution of the cleaning compound (Types I, II and IV only) in distilled water
      shall not show a weight change greater than 0.14 mg/cm2 for 24 hours when tested
      in accordance with 4.5.11.
            As received:      0.07* mg/cm2/24hrs
            Dilute (10 %):      Not performed
                                                Result       Conforms*	._
      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN III Lot # C531-84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)	'
                                                Date:
                                                SMI/REF:

                                                Page 9 of 12
07-Mar-2005
04DEC086
Final Report
3.7.4  Effects on unpainted metal surfaces: The concentrated cleaning compound (Type III
      only) and a 10% solution (Types I, II and IV only) of the cleaning compound in
      distilled water shall not cause streaking, stains or other deposits that cannot be
      easily removed with water when tested in accordance with 4.5.12.
                                                Result
                                                       Conforms*
3.7.5
Sandwich  corrosion: When tested in accordance with 4.5.16, the concentrated
cleaner (all types) and a  10% solution (Types I, II and IV only) shall show no
corrosion in excess of that shown by control test coupons in ASTM D 1193, Type IV,
reagent water.

As received
Dilute (10%)
Control
2024-T3 Bare
Anodized
1
2024-T3
Alclad
1
7075-T6 Bare
Anodized
1
7075-T6
Alclad
1
Not performed
1
1
1
1
'staining/etching in excess of 25% of the surface area
                                                Result
                                                       Conforms*
3.7.6  Wet adhesion tape test (Types II and IV): A ten (10) percent solution of the cleaning
      compound, when used as directed, shall remove soil from a painted surface in
      preparation fro repainting such that paint applied after cleaning with the compound
      shall adhere to the surface when tested in accordance with 4.5.27.
COATING SYSTEM
SET1:
Primer: MIL-PRF-85582, Type I, Class 1B Waterborne Epoxy
Topcoat: MIL-PRF-85285 Type I High Solids Polyurethane, Color #34092
SET 2:
Primer: MIL-PRF-23377, Type I, Class C High Solids Epoxy
Topcoat: MIL-PRF-85285 Type I High Solids Polyurethane, Color # 34092
SET 3:
Primer: TT-P-2760, Type I, Class C High Solids Elastomeric, Polyurethane
Topcoat: MIL-C-85285 Type I High Solids Polyurethane, Color # 34092
OBSERVATIONS
Coating system
showed no sign of
damage.
Coating system
showed no sign of
damage.
Coating system
showed no sign of
damage.
                                                Result
                                                       Conforms*
* Test performed using "as received" solution (ready to use) instead of dilution required by
specification.

-------
Client:      Battelle Memorial Institute
Product:     EAGLE KLEEN III Lot # C531-84-1
Dilution:     Per specification
MIL-PRF-87937D (Type IV)	
Date:
SMI/REF:
Page 10 of ,12
07-Mar-2005
04DEC086
Final Report
3.8   Effect on painted surfaces: The concentrated cleaning compound (Type III only) and
      a 25% solution (Types I, II and IV) of the cleaning compound in distilled water shall
      not cause streaking,  blistering, discoloration or a permanent decrease in film
      hardness of more than one (1) pencil hardness level when tested in accordance
      with 4.5.13.  The Type I material shall be tested using only the (H) Polyurethane
      paint systems.
PANEL SET
E (Epoxy topcoat)
Primer: MIL-PRF-23377, Ty I, Class C High-Solids Epoxy Primer
Topcoat: MIL-PRF-22750 Epoxy Topcoat, Color #: 17925
H (Polyurethane)
Primer: MIL-PRF-23377, Ty I, Class C High-Solids Epoxy Primer
Topcoat: MIL-PRF-85285 Ty I, Polyurethane, High Solids, Color #: 17925
F (Enamel)
Primer: MIL-PRF-23377, Ty I, Class C High-Solids Epoxy Primer
Topcoat: TT-E-529 Enamel, Semi-gloss, Color #: 27925
RESULT
Cone.
Pass
Pass
Pass
25%
Not performed
                                                 Result
       Conforms*
3.9   Stress cra_2ing.._olJdlLj:PR_^5_425_ and MJL-PRF-25690 (Type A and C) acrylic
      plastics: The concentrated product (Type III only) and a 10% solution (Types I, II
      and IV) in distilled water shall not cause stress crazing or staining of acrylic plastics
      when tested in accordance with 4.5.14.
Material
MIL-PRF-5425 (Type A)
MIL-PRF-25690 (Type C)
As received
"Crazing: Fails
No crazing: Pass
Dilution (10%)
Not performed
Not performed
                                                 Result     'Does not conform

      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:      Battelle Memorial Institute                    Date:        07-Mar-2005
Product:     EAGLE KLEEN III Lot #C531 -84-1           SMI/REF:    04DEC086
Dilution:     Per specification                                        Final Report
MIL-PRF-87937D (Type IV)	Page 11 of 12	
3.10  Stress crazing of polycarbonate plastic: The concentrated product (Type III only)
      and a  10% solution (Types I, II and IV) in  distilled water shall not cause stress
      crazing or staining of polycarbonate plastic conforming to MIL-P-83310 when tested
      in accordance with 4.5.15.
I Material
MIL-P-8331 0 (Polycarbonate)
As received
Crazing: Fails
Dilution (10%)
Not performed
                                                 Result    *Does not conform

3.11  Long-term storage stability: After being stored for a period  of .12 months, in
      accordance  with  4.5.17, the  cleaning  compound shall  not layer, separate,
      precipitate or corrode the shipping container.  Plastic containers shall not show
      leakage nor any cracking, crazing, or softening.  All cleaning compounds shall meet
      the requirements of paragraphs 3.5.1, 3.7.1, 3.7.2,  3.15,  and 3.16 of this
      specification.
                                                 Result	Not performed

3.12  Hot dip galvanizing corrosion: The concentrated product (Type III only) and a 10%
      solution of the cleaning compound (Types I, II  and IV) in distilled water shall not
      show a  weight change  of an average of three (3) test panels greater than 0.14
      mg/cm2 when tested in  accordance with 4.5.18.
            As received:      0.04 mg/cm2
            Dilute (10%):       Not performed
                                                 Result       *Conforms	
3.13  Workmanship; The cleaning compound shall be a liquid having a uniform and
      homogenous appearance. The cleaning compound shall be manufactured from
      materials that shall produce a product harmless to metal surfaces and humans
      when used as directed.
                                                Result   To be Cert, by Mfr.
      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
Client:       Battelle Memorial Institute                   Date:       07-Mar-2005
Product:     EAGLE KLEENIH Lot #C531-84-1           SMI/REF:   04DEC086
Dilution:     Per specification                                       Final Report
MIL-PRF-87937D (Type IV)	            Page 12 of 12	

3.14  Effect on polysulfide sealants: The concentrated cleaning compound (Type III only)
      and a 25% solution (Types I, II and IV) of the cleaning compound in distilled water
      shall not change the durometer hardness of the polysulfide sealant by more than 5
      units when tested in accordance with 4.5.19.
            Sealants:   MIL-S-81733 Type 1:    <5 units hardness change
                        MIL-S-8802  Type 1:     <5 units hardness change

                                               Result        Conforms*
3.15  Rubber compatibility: The concentrated cleaning compound (Type III only) and a
      25% solution (Types I, II and IV only) of the cleaning compound in distilled water
      shall not change the  durometer hardness  more than 5 units when tested in
      accordance with 4.5.20.
            Rubbers:   AMS 3204:              < 5 units hardness change
                        AMS 3209:              < 5 units hardness change

                                                Result        Conforms* 	.
3.16  Effect on polyimide insulated wire: The cleaning compound, when tested according
      to 4.5.26, shall not cause dissolution, cracking, ordielectric breakdown (leakage)of
      the polyimide insulated wire in excess of that produced by distilled water.
            Polyimide wire did not exhibit dissolution, cracking or dielectric
            breakdown.
                                                Result       Conforms  	
      * Test performed using "as received" solution (ready to use) instead of dilution required by
      specification.

-------
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-------
SMI, Inc.
12219 SW131 Avenue
Miami, Florida 33186-6401  USA
                         Phone:
                         Fax:
(305) 971-7047
(305) 971-7048
Attn:       Sara Kuczek
           Battelte Memorial Institute
           505 King Avenue
           Columbus,  OH 43201-2693
                          Date:       Q4-Mar-2005

                          SMI/REF:   04DEC086
Product:    Eagle Kleen III Lot # C531-84-1 (received 01-December-2004)

Dilution:    Ready to use
                               ASTM D 323
                      Test Method for Vapor Pressure of
                      Petroleum Products (Reid Method)
SCOPE
      This test method provides procedures for the determination of vapor pressure of
      gasoline, volatile crude oil, and other volatile petroleum products.
SUMMARY OF TEST METHOD
      The liquid chamber of the vapor pressure apparatus is filled with the chilled sample
      and connected to the vapor chamber that has been heated to 37.8°C (100°F) in a
      bath. The assembled apparatus is immersed in a bath at 37.8°C (100°F) until a
      constant pressure is observed. The reading, suitably corrected, is reported as the
      Reid vapor pressure.
Sample
Eagle Kleen III
Reid Vapor Pressure
<0.2 mm Hg @ 20°C
                            Resectfullvsubmitted,
                            Patricia D. Viani, SMI Inc.
   SCIENTIFIC
MATERIAL    INTERNATIONAL
 www. smiinc.com

-------
SMI, Inc.
12219 SW131 Avenue                               Phone:    (305)971-7047
Miami, Florida 33186-6401  USA                      Fax:       (305)971-7048
Attn:       BATTELLE MEMORIAL INSTITUTE          Date:       07-Mar-2005
           505 King Avenue                         SMI REF:   04DEC086
           Columbus, OH  43201

PRODUCT: EAGLE KLEEN III (Lot # C531 -84-1)             Page 1 of 9
           (received 01-Dec-2004)
           40 CFR 796.3100: AEROBIC AQUATIC BIODEGRADATION
                         Code of Federal Regulations
                       Environmental Protection Agency
                      Title 40:  Protection of Environment
                  Part 796:  Chemical Fate Testing Guidelines
                         Shake Flask Method
Summary of Results:

Based on dissolved organic carbon analysis:
           "EAGLE KLEEN III"  = 87.1 % Biodegradable in 28 days
See Appendix A for graphical representation of Biodegradability vs. Time .


PROCEDURE

I. Introduction

This  procedure provides  a  way to determine  the  rate  and extent  of aerobic
biodegradation  that might occur when chemical substances are released to aquatic
environments. A high biodegradability result in this test provides evidence that the test
substance will be biodegradable in natural aerobic freshwater environments.  A low
biodegradability result may not necessarily indicate poor  biodegradation, as other
factors may interfere, such as inhibition of the rnicrobial inoculum by the test material.
   SCIENTIFIC   MATERIAL    INTERNATIONAL
                          www. smiinc.com

-------
Client:      Battelle Memorial Institute                   Date:        07-Mar-2005
Product:     EAGLE KLEEN III                          SMI REF:    04DEC086
                                                      Page 2 of 9
EPA 796.3100: AEROBIC AQUATIC BIQDEGRADATION             	

II. Principle of the Test Method

The method consists of a 2-week inoculum buildup period during which the microbes
are allowed to adapt to the test compound. The acclimated media containing a defined
amount of test compound is added to specially equipped  Erlenmeyer flasks. The test
media is  sampled periodically and analyzed for dissolved organic carbon  (DOC).  A
reservoir  filled with  barium hydroxide  is utilized to measure the amount of  carbon
dioxide evolved.  The degree of biodegradation is determined by comparison of the
extent of DOC disappearance and the amount of carbon dioxide liberated.  Control
flasks containing no test compounds are run simultaneously and are used to estimate
the degree of ultimate  biodegradation.    Reference substances  which will  exhibit
ultimate biodegradation may be run  simultaneously to check the activity  of the
inoculum.  If the reference samples do not exhibit at least 60 percent of theoretical
maximum carbon dioxide, and at least 70 percent DOC removal within 28 days, the test
will be regarded as invalid and shall be repeated using different inoculum.

This  method is believed to be appropriate for a screening test which has solely an
acceptance but no rejective function.

III. Test Procedure

The total  organic carbon (TOC) of the test compound is first determined by analysis or
calculation  if the formulation  is  known.  Determination  of the minimum  inhibitory
concentration is useful to insure that the test compound  will not be inhibitory to the
microbes at the required concentration.  The shake flask apparatus  is assembled
utilizing a 2-liter Erlenmeyer flask and a 50 ml centrifuge tube.  The tube containing 10
mis of barium hydroxide will be suspended over the contents of the flask in such a way
that liberated  carbon dioxide  may diffuse into the barium hydroxide, while allowing the
contents of the tube to be removed for analysis without  spilling  into the test  media.
Glass  tubing  may  be utilized  as access  into the flask for sparging, venting, and
sampling.

Stock solutions I, II, and III are  prepared (see Appendix  B), along with 0.2 N  barium
hydroxide  and 0.1 N HCI.  Acclimation medium is prepared by adding 1 ml each of
stock solutions I, II and III  to 1  liter of  distilled, deionized  water (DIW). The microbial
inoculum  is obtained from sewage and soil  or from  Polyseed and is  added to the
acclimation medium.  Test compounds are added incrementally during the acclimation
period at concentrations equivalent to 4, 8, and 8 mg/L carbon on days 0,  7, and 11,
respectively. On day 14, the medium is ready for use in the test.

-------
Client:      Battelie Memorial Institute                   Date:        07-Mar-2005
Product:     EAGLE KLEEN III                          SMI REF:    04DEC086
                                                      Page 3 of 9
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION	
Biodegradability test flasks are prepared by adding 100 mis of acclimation medium to
900 mis of DIW along with 1 ml each of solutions I, II, and III to the 2-liter Erlenmeyers.
Additional test compound equivalent to 10 mg/L carbon is added to the flasks. Ten mis
of barium hydroxide are added to the suspended reservoirs in each flask and 10 mis
are also saved for use as a titration blank. Flasks are sparged with carbon dioxide-free
air, sealed and placed on a shaking table (approx. 125 rpm) at 20 - 25 deg C in the
dark.  Test flasks should be run in triplicate and sampling should occur at time zero and
at least four other times to allow for a smooth plot of biodegradation.  Each sample for
DOC analysis is first centrifuged or filtered through a 0.45 micrometer or smaller  pore
diameter. On the day prior to terminating the test, 3 mis of 20 percent sulfuric acid are
added to release carbonate bound carbon dioxide.
IV.  ANALYTICAL MEASUREMENTS

The quantity of carbon dioxide evolved is measured by titration of the entire barium
hydroxide sample with 0.1 N HCI to the phenolphthalein end point, blank subtracted.
Theoretically, 10 mg of carbon is converted to 0.833 mmol of carbon dioxide. Absorbed
carbon dioxide precipitates as barium carbonate, causing a reduction in alkalinity by the
equivalent of  16.67 ml of 0,1 N HCI for complete conversion of the test compound
carbon to carbon dioxide. Therefore, the  percent theoretical carbon dioxide evolved
from the test compound is calculated at any sampling time from the formula:
                  % CO2 evolution = [(TF - CFX16.67] • 100

                  where:

                  TF  = mis of 0.1 N HCI used in titration of test flask

                  CF  = mis of 0.1 N HCI used in titration of control flask

-------
Client:       Battelle Memorial Institute                  Date:       07-Mar-2005
Product:     EAGLE KLEEN III                        SMI REF:    04DEC086
                                                   Page 4 of 9
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION	._
The DOC analysis is performed using a suitable organic carbon method.  The percent
DOC disappearance from the test compound is calculated from the formula:

           % DOC removal  = [1 - (DTFX - DCFX)/(DTFO - DCFO)] • 100

           where:

           DTP  = Dissolved organic carbon from test flask
           DCF  = Dissolved organic carbon from control flask

           o     = Day zero measurements
           x     = Day x measurements


V. REPORT OF RESULTS


Inoculum: Polyseed and Mixed inoculum

Date Received: Jan, 2004

Source:  Fisher Scientific and Metro-Dade County Water & Sewer Authority

Storage: Ambient temperature, used within 24 hours

Minimum Inhibitory  Concentration:  MIC  < 3.125  %  (non-inhibitory to microbes at
concentrations lower than 3.125%)

Percent Biodegradation based on DOC analysis:
 EAGLE KLEEN III:             87.1 % after 28 days (see Table 1)
 Reference (Sodium citrate):      92.6 % after 28 days (see Table 1)

-------
Client:      Battelle Memorial Institute                   Date:       07-Mar-2005
Product:     EAGLE KLEEN III                         SMI REF:   04DEC086
                                                     Page 5 of 9
EPA 796.3100:  AEROBIC AQUATIC BIODEGRADATION	

Summary: Since the test compound was found to be over 70 % biodegradable based
on the DOC analysis, it is reasonable to assume that the substance will undergo rapid
and ultimate biodegradation in aerobic aquatic environments, also  known as "ready
biodegradability". The test is validated by the fact that the reference compound, sodium
citrate, exhibited a biodegradability over 70%.

The percent biodegradability based on carbon dioxide evolution is typically lower than
that of the DOC based numbers. In this case, the carbon dioxide evolution measured
was  significant,  both on the  test compound and on the  reference, and the results
generally agree.
                             Respectfully submitted,
                                                \
                             Patricia D. Viani
                             SMI, Inc.

-------
Client:     Battelle Memorial Institute                 Date:       07-Mar-2005
Product    EAGLE KLEEN III                       SMI REF:   04DEC086
                                               Page 6 of 9
EPA 796.3100: AEROBIC AQUATIC BIQDEGRADATION     	
          TABLE I - DISSOLVED ORGANIC CARBON (PUC) VALUES
Sample:  EAGLE KLEEN III

A
B
C
AVERAGE
CORRECTED AV
% BIODEGRADED
Reference: Sodium
A
B
C
AVERAGE
CORRECTED AV
% BIODEGRADED
BLANK A
B
C
DAYO
35.7
39.1
37.0
37.3
34.0
N/A
Citrate
38.0
39.9
39.1
39.0
35.7
N/A
3.5
3.0
3.4
DAY 7
11.6
9.3
15.2
12.0
8.7
74.3%

14.2
9.1
8.4
10.6
7.3
79.6%
3.1
3.6
3.2
DAY 14
9.2
8.8
13.8
10.6
7.2
78.7%

6.8
6.9
7.3
7.0
3.6
89.8%
3.3
3.6
3.2
DAY 21
8.3
7.2
9.9
8.5
5.1
85.1%

5.2
6.2
6.7
6.0
2.6
92.6%
3.7
3.2
3.3
DAY 28
7.3
7.4
8.5
7.7
4.4
87.1%

5.5
6.0
6.5
6.0
2.6
92,6%
3.0
3.7
3.4
AVERAGE           3.3      3.3     3.4      3.4     3.4

-------
Client:     Battelle Memorial Institute
Product:    EAGLE KLEEN III

EPA 796.3100: AEROBIC AQUATIC BIODEGRADATIQN
                                 Date:      07-Mar-2005
                                 SMI REF:   04DEC086
                                 Page 7 of 9
                  Table II - Titration Data for CO2 Evolution
Sample:  EAGLE KLEEN III
              A
              B
              C

AVERAGE
CORRECTED AVG
% BIODEGRADED
mis theoretical:       56.7

Reference:  Sodium Citrate

              A
              B
              C
AVERAGE
CORRECTED AVG
% BIODEGRADED
mis theoretical:       59.5
BLANK
A
B
C
DAY 7
6.8
5.6
6.0
6.1
11.9
20.9%

4.6
6.0
5.2
5.3
12.7
21.4%

18.2
18.2
17.6
DAY 14 DAY 21
8.8
12.4
9.2
10.1
7.6
13.4%

7.8
9.2
6.2
7.7
10.0
16.8%

18.0
17.4
17.8
15.8
16.0
16.6
16.1
1.9
3.3%

17.0
14.8
16.8
16.2
1.8
3.0%

18.2
18.0
17.8
DAY 28
18.0
18.0
17.6
17.9
0.2
0.4%
TOTALs
18.0
17.8
18.0
17.9
0.1
0.2%
TOTAL =
17.8
17.8
18.6
                                          38.0%
                                          41.4%
AVERAGE
             18.0
17.7
18.0
18.1

-------
Client:      Battelle Memorial Institute
Product:    EAGLE KLEEN III
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATIQN

                               Appendix A

                      BIODEGRADABILITY VS. TIME
                             EAGLE KLEEN III
B
 I
0
D
E
G
R
A
D
E
D
    100 T
     90--
     80--
     70-
                          Date:       07-Mar-2005
                          SMI REF:   04DEC086
                          Page 8 of 9
DOC:EAGLEKLEEN II!
C02:EAGLEKLEEN II)
                                         -•- DOC: REFERENCE
                                         -o- C02: REFERENCE

-------
Client:     Battelle Memorial Institute
Product:    EAGLE KLEEN III
EPA 796.3100: AEROBIC AQUATIC BIODEGRADATION
                          Date:
                          SMI REF:
                          Page 9 of 9
07-Mar-2005
04DEC086
                             Appendix B
                     STOCK SOLUTIONS I, II, AND III
     SOLUTION I:
     SOLUTION II:
     SOLUTION III:
35   g/L  NH4CI
15   g/L  KNO3
75   g/L  K2HPO4-3H2O
25 g/L
10 g/L
20 g/L
1 g/L
adjust pH of
5 g/L
0.05 g/L
0.5 g/L
0.05 g/L
0.001 g/L
0.001 g/L
NaH2PO4-H2O
KCI
MgSO4
FeSO4-7H2O
SolnlltoS.O
CaCI2
ZnCI2
MnCI2-4H20
CuCI2
CoCI2
H3B03
                     0.0004 g/L

-------
SMI, Inc.
12219 SW 131 Avenue
Miami, Florida 33186-6401
USA
Phone:
Fax:
(305)971-7047
(305)971-7048
Attn:        Nick Conkle
            Battelle Memorial Institute
            505 King Ave
            Columbus, OH 43201

Product:     EAGLE KLEEN III
            (received 20-Jun~2005)

Dilution:     Ready to use	
                            Date:       24-Jun-2005

                            SMI/REF:   04JUN604
                            Page 1 of 1
               Modified testing (product was tested neat - [undiluted])
                        MIL-PRF-87937D (24Sep2001)
               CLEANING COMPOUND, AEROSPACE EQUIPMENT
	Type IV - Heavy Duty, Water Dilatable Cleaning Compound	

3-9   Stress crazing of  MIL-PRF-5425 and MIL-PRF-25690 (Type A and C) acrylic
      plastics: The concentrated product (Type III only) and a 10% solution (Types I, II
      and IV) in distilled water shall not cause stress crazing or staining of acrylic plastics
      when tested in accordance with 4.5.14.
Material
MIL-PRF-5425 (Type A)
MIL-PRF-25690 (Type C)
As received
Crazing: Fails
No crazing: Pass
Dilution (10%)
Not performed
Not performed
                                               Result    Does not conform

      3.10  Stress crazing of polycarbonate plastic: The concentrated product (Type III
only) and a 10% solution (Types I, II and IV) in distilled water shall not cause stress crazing
or staining of polycarbonate plastic conforming to MIL-P-83310 when tested in accordance
with 4.5.15.
Material
MIL-P-83310 (Polycarbonate)
As received
Crazing: Fails
Dilution (10%)
Not performed
                                               Result    Does not conform

  Tests performed using "as received" solution (ready to use) instead of dilution required by
      specification.
                        Respectfully submitted,
                                . Viani, SMI Inc.
   SCIENTIFIC    MATERIAL    INTERNATIONAL
                           www. smiinc.com

-------
                    Appendix E




SMI Results from Eagle Kleen III Vapor Pressure Testing

-------
SMI, Inc.
12219 SW131 Avenue
Miami, Florida 33186-6401 USA
                         Phone:
                         Fax:
(305) 971-7047
(305) 971-7048
Attn:       Sara Kuczek
           Battelle Memorial Institute
           505 King Avenue
           Columbus,  OH 43201-2693
                          Date:       04-Mar-2005

                          SMI/REF:   04DEC086
Product:    Eagle Kleen III Lot # C531-84-1 (received 01-December-2004)

Dilution:    Ready to use
                               ASTM D 323
                      Test Method for Vapor Pressure of
                      Petroleum Products (Reid Method)
SCOPE
      This test method provides procedures for the determination of vapor pressure of
      gasoline, volatile crude oil, and other volatile petroleum products.
SUMMARY OF TEST METHOD
      The liquid chamber of the vapor pressure apparatus is filled with the chilled sample
      and connected to the vapor chamber that has been heated to 37.8°C (100°F) in a
      bath. The assembled apparatus is immersed in a bath at 37.8°C (100°F) until a
      constant pressure is observed. The reading, suitably corrected, is reported as the
      Reid vapor pressure.
Sample
Eagle Kleen III
Reid Vapor Pressure
<0,2 mm Hg @ 20°C
                                       submitted,
                            Patricia D. Viani, SMI Inc.
   SCIENTIFIC
MATERIAL    INTERNATIONAL
 www. smiinc.com

-------
                 Appendix F




SMI Results from Eagle Kleen III Toxicity Testing

-------
SMI, Inc.
12219SW131 Avenue
Miami, Florida 33186-6401  USA
                                      Phone:
                                      Fax:
         (305)971-7047
         (305)971-7048
Attn:




Product:

Dilution:
Nick Conkle
Battelle Memorial Institute
505 King Avenue
Columbus, Oh 43201-2693
Date:       09-Dec-2005

SMI/REF:   05XCT045
EAGLE KLEEN III (50540-98-5) (received 27-Oct-2005)

Ready to Use                             Page 1 of 1
                       Partial testing in accordance with:
                                AMS 1424F
                   Deicing/Anti-icing, Fluid, Aircraft SAE Type I
                  	       (Fluid is ready to use)	
3.1.4.4      Aquatic Toxicity:  Formulated fluid shall be tested in accordance with EPA
            (40CFR 797.1300 and 797.1400, revised July 1,1989 and 40 CFR 136.3) or
            OECD (Organization for Economic Cooperation and Development Guidelines
            for Testing of Chemicals, Methods 202 and 203) procedures using test
            species required by regulatory agencies for permitted discharges. Examples
            include: fathead minnows (96-hour LC^), Ceriodaphnia dubia (48-hour EC^),
            Daphnia magna (48-hour EC^) and rainbow trout (96-hour LCM). The LCSO
            (for fish) or ECgo (for invertebrates) concentration (the highest concentration
            at which 50% of the organisms do not survive the test period) shall be given
            in milligrams per liter.

      EPA 40 CFR 797.1300 DAPHNID ACUTE TOXICITY TEST
                        Daphnia magna, static system
                           48 hour LCSO: 25 mg/L
      EPA 40 CFR 797.1400 FISH ACUTE TOXICITY TEST
                      Pimephales promelas, static system
                           96 hour LC50: 30 mg/L

                                              Result
                                              Informational
                       Respectfully submitted
                       Patricia D. Viani, SMI, Inc.
   SCIENTIFIC
              MATERIAL   INTERNATIONAL
               www. smiinc.com

-------
SMI, Inc.
12219SW131 Avenue
Miami, Florida 33186-6401  USA
                                       Phone:
                                       Fax:
         (305)971-7047
         (305)971-7048
Attn:




Product:

Dilution:
Nick Conkle
Battelle Memorial Institute
505 King Avenue
Columbus, Oh 43201-2693
Date:       09-Dec-2005

SMI/REF:   05XCT046
SAFETY KLEEN (50540-98-24) (received 27-Oct-2005)

Ready to Use                            Page 1 of 1
                       Partial testing in accordance with:
                                AMS 1424F
                   Deicing/Anti-icing, Fluid, Aircraft SAE Type I
                  	    (Fluid is ready to use)	
3.1.4.4      Aquatic Toxicity:  Formulated fluid shall be tested in accordance with EPA
            (40CFR 797.1300 and 797,1400, revised July 1,1989 and 40 CFR 136.3) or
            OECD (Organization for Economic Cooperation and Development Guidelines
            for Testing of Chemicals, Methods 202 and 203) procedures using test
            species required by regulatory agencies for permitted discharges. Examples
            include: fathead minnows (96-hour LC^,), Ceriodaphnia dubia (48-hour ECgo),
            Daphnia magna (48-hour EC^,) and rainbow trout (96-hour LC50). The LC^,
            (for fish) or EC50 (for invertebrates) concentration (the highest concentration
            at which 50% of the organisms do not survive the test period) shall be given
            in milligrams per liter.

      EPA 40 CFR 797.1300 DAPHNID ACUTE TOXICITY TEST
                         Daphnia magna, static system
                           48 hour LC50:  125 mg/L
      EPA 40 CFR 797.1400 FISH ACUTE TOXICITY TEST
                      Pimephales promelas, static system
                         96 hour LCm: >70,000 mg/L*

*Note: Product left a distinct layer on top of water layer. Since product was not water
soluble, results are suspect.
                                              Resu It	Informational
                       Ftespectfully submitted,v
                       Patricia D. Viani, SMI, Inc.
    SCIENTIFIC
              MATERIAL    INTERNATIONAL
               www. smiinc.com

-------
SMI, Inc.
12219 SW 131 Avenue
Miami, Florida 33186-6401  USA
                         Phone:
                         Fax:
(305) 971-7047
(305) 971-7048
Attn:        Nick Conkle
            Battelle Memorial Institute
            505 King Avenue
            Columbus, Oh 43201-2693
                          Date:       09-Dec~2005

                          SMI/REF:   05XCT047
Product:     TURCO 6849 SOLN 20% by volume (50540-98-13) (received 27-Oct-2Q05)

Dilution:     Ready to Use                             Page 1 of 1
                       Partial testing in accordance with:
                                AMS 1424F
                   Deicing/Anti-icing, Fluid, Aircraft SAE Type I
                             (Fluid is ready to use)	
3,1,4.4      Aquatic Toxicjty: Formulated fluid shall be tested in accordance with EPA
            (40CFR 797.1300 and 797.1400, revised July 1,1989 and 40 CFR 136.3) or
            OECD (Organization for Economic Cooperation and Development Guidelines
            for Testing of Chemicals, Methods 202 and 203) procedures using test
            species required by regulatory agencies for permitted discharges. Examples
            include: fathead minnows (96-hour LCgo), Ceriodaphnia dubia (48-hour ECgo),
            Daphnia magna (48-hour EC50) and rainbow trout (96-hour LC50). The LC^
            (for fish) or EC50 (for invertebrates) concentration (the highest concentration
            at which 50% of the organisms do not survive the test period) shall be given
            in milligrams per liter.

      EPA 40 CFR 797,1300 DAPHNID ACUTE TOXICITY TEST
                         Daphnia magna, static system
                           48 hour LCSO:  150 mg/L
      EPA 40 CFR 797.1400 FISH ACUTE TOXICITY TEST
                      Pimephales promelas, static system
                           96 hour LC50:  225 mg/L

                                              Result
                                Informational
                       Respectfully submitted,
                       Patricia D. Viani, SMI, Inc.
    SCIENTIFIC
MATERIAL    INTERNAT
 www. smiinc.com
  O N A L

-------
SMI, Inc.
12219 SW 131 Avenue
Miami, Florida 33186-6401 USA
Phone:
Fax:
(305)971-7047
(305) 971-7048
Attn;        Nick Conkle
            Battelle Memorial Institute
            505 King Avenue
            Columbus, Oh 43201-2693
                           Date:       09-Dec-2005

                           SMI/REF:   05XCT048
Product:     RUST BLOC SOLN 4% by weight (50540-98-20) (received 27-Oct-2Q05)

Dilution:     Ready to Use                             Page 1 of 1
                       Partial testing in accordance with:
                                AMS 1424F
                   Deicing/Anti-icing, Fluid, Aircraft SAE Type I
                  	     (Fluid is ready to use)	
3.1.4.4     Aquatic Toxicity: Formulated fluid shall be tested in accordance with EPA
           (40CFR 797.1300 and 797.1400, revised July 1,1989 and 40 CFR 136.3) or
           OECD (Organization for Economic Cooperation and Development Guidelines
           for Testing of Chemicals, Methods 202 and 203) procedures using test
           species required by regulatory agencies for permitted discharges. Examples
           include: fathead minnows (96-hour LCm), Ceriodaphnia dubia (48-hour EC^),
           Daphnia magna (48-hour EC50) and rainbow trout (96-hour LCSO). The LC50
           (for fish) or EC50 (for invertebrates) concentration (the highest concentration
           at which 50% of the organisms do not survive the test period) shall be given
           in milligrams per liter.

      EPA 40 CFR 797.1300 DAPHNID ACUTE TOXICITY TEST
                        Daphnia magna, static system
                          48hourLC50:  79,200 mg/L
      EPA 40 CFR 797.1400 FISH ACUTE TOXICITY TEST
                      Pimephales promelas, static system
                         96 hour LC50: 33,500 mg/L

                                              Result
                                 Informational
                       Respectfully submitted,
                       Patricia D. Viani, SMI, Inc.
   SCIENTIFIC
MATERIAL   INTERNATIONAL
 www. smiinc.com

-------