EPA-600/R-97-101
September 1997
Powder Coat Applications
Final Report
by
Michael J. Docherty and Fredrick J. Mulkey
Concurrent Technologies Corporation
1450 Scalp Avenue
Johnstown, PA 15904
EPA/DOD IAG DW97936814
DOD Contract: DAAA21-93-C-0046
U.S. EPA Project Officer:
J. Kaye Whitfield
National Risk Management Research Laboratory
Air Pollution Prevention and Control Division
Research Triangle Park, NC 27711
Prepared for:
U.S. Environmental Protection Agency
Office of Research and Development
Washington, DC 28460
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before comph
1. REPORT NO,
EPA-600/R-97-101
2,
4. TITLE AND SUBTITLE
Powder Coat Applications
5. REPORT DATE
September 1997
6. PERFORMING ORGANIZATION CODE
lllllllllllllllllllllll1
PB98-108624
7. AUTHORCS!
Michael J. Docherty and Fred J, Mulkey
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Concurrent Technologies Corporation
1450 Scalp Avenue
Johnstown, Pennsylvania 15904
10. PROGRAM ELEMENT NO.
11, CONTRACT/GRANT NO.
EPA/DOE IAG DW97936814
DOD DAAA 21-93-C-0046
12, SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
EPA, Office of Research and Development
Air Pollution Prevention and Control Division
Research Triangle Park, NC 27711
Final; 12/95 - 12/96
14. SPONSORING AGENCY CODE
EPA/600/13
15. SUPPLEMENTARY NOTES AppCD pr0ject officer is J.
541-2509.
Kaye Whitfield, Mail Drop 61, 919/
16. abstractreport discusses an investigation of critical factors that affect the use
of powder coatings on the environment, cost, quality, and production. The investiga-
tion involved a small business representative working with the National Defense Cen-
ter for Environmental Excellence (NDCEE), operated by Concurrent Technologies
Corporation (CTC), through the EPA's Environmental Technology Initiative. The in-
vestigation demonstrated that powder has the potential to provide unique and val-
uable benefits when considering each of these areas. (NOTE: Powder coating is an
organic finishing technology that offers users the potential to reduce volatile organic
compound (VOC) emissions to zero. Due to ever-increasing YOC emission restric-
tions placed on manufacturers, powder coating production and use have been growing
dramatically over the past few years. Powder coating has been accepted by such
manufacturing communities as automotive, appliance, furniture, and equipment.
However, small business manufacturers have difficulty investigating new technolo-
gies due to size and budget restrictions.)
17, KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Pollution
Pollution Prevention
13 B
Powder (Particles)
Stationary Sources
14G
Coatings
Volatile Organic Com-
11C
Volatility
pounds (VOCs)
20M
Organic Compounds
07C
Emission
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (ThisReport)
21. NO. OF PAGES
Unclassified
67
Release to Public
20, SECURITY CLASS (This pageJ
22. PRICE
Unclassified
EPA Form 2220-1 (9-73)
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NOTICE
This document has been reviewed in accordance with
U.S. Environmental Protection Agency policy and
approved for publication. Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
ii
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FOREWORD
The U. S. Environmental Protection Agency is charged by Congress with pro-
tecting the Nation's land, air, and water resources. Under a mandate of national
environmental laws, the Agency strives to formulate and implement actions lead-
ing to a compatible balance between human activities and the ability of natural
systems to support and nurture life. To meet this mandate, EPA's research
program is providing data and technical support for solving environmental pro-
blems today and building a science knowledge base necessary to manage our eco-
logical resources wisely, understand how pollutants affect our health, and pre-
vent or reduce environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for
investigation of technological and management approaches for reducing risks
from threats to human health and the environment. The focus of the Laboratory's
research program is on methods for the prevention and control of pollution to air,
land, water, and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites and groundwater; and prevention and
control of indoor air pollution. The goal of this research effort is to catalyze
development and implementation of innovative, cost-effective environmental
technologies; develop scientific and engineering information needed by EPA to
support regulatory and policy decisions; and provide technical support and infor-
mation transfer to ensure effective implementation of environmental regulations
and strategies.
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 Re-
search and Development to assist the user community and to link researchers
with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
iii
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ABSTRACT
Powder coating is an organic finishing technology that offers users the potential to reduce Volatile
Organic Compound (VOC) emissions to zero. Due to ever-increasing VOC emission restrictions placed on
manufacturers, powder coating production and use have been growing dramatically over the past few
years. Powder coating has been accepted by such manufacturing communities as automotive, appliance,
furniture, and equipment. However, small business manufacturers have difficulty investigating new
technologies due to size and budget restrictions. Through the EPA's Environmental Technology Initiative,
the National Defense Center for Environmental Excellence (NDCEE), operated by Concurrent
Technologies Corporation (CTC'), has worked with a small business representative to demonstrate the
applicability of powder coating. During the project, critical factors that affect the cost, quality, and
production were investigated. The investigation demonstrated that powder has the potential to provide
unique and valuable benefits when considering each of those areas.
iv
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CONTENTS
ABSTRACT lv
LIST OF FIGURES vii
LIST OF TABLES vii
METRIC EQUIVALENTS viii
EXECUTIVE SUMMARY ¦ ix
INTRODUCTION 1
Project Background 1
Project O bjecti ves 1
APPROACH . 1
Identification of a Small Business Representative 1
Facility Baseline Survey 1
Powder Coating Technology Feasibility Testing 2
Powder Coating Technology Optimization Testing 2
Powder Coating Validation Demonstrations 2
Technology Transfer Activities 2
PROJECT RESULTS ...2
Identification of Small Business Project Partner 2
Baseline Survey of The Bilco Company's Flowcoat Finishing Operation 3
Methodologies Used 3
On-site Survey 3
Survey Questionnaire 3
Follow-up Phone Interviews 3
Bilco Process Description 4
General Process Descriptions of Manufacturing and Coating Operations 4
Equipment Description 4
Materia] and Utilities Usage 4
Material Usage. 4
Utilities Usage 4
Production Flow Rates 4
Procedures and Practices 5
Surface Preparation 5
Coating Application and Mixing Process 5
Coating Performance Testing 6
Waste and Emissions Summary 6
Regulatory Profile 6
The Clean Air Act, as Amended in 1990 (CAA) 7
National Ambient Air Quality Standards (NAAQS) 7
State of Connecticut 7
The Resource Conservation and Recovery Act (RCRA) 7
D007 Hazardous Waste (Paint Sludge) 8
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Powder Coating Alternative Process Description 8
Powder Coating Equipment Used for this Project Descriptions.. 9
Controls and Data Collection 9
Conveyor System 9
Pretreatment 9
Dry-off and Cure Ovens.... 9
Automatic Powder with Manual Touch-up 9
Material and Utilities Usage 9
Pretreatment Process Selection Background 9
Pretreatment Materials 10
Powder Coating and Topcoating Materials 10
Procedures/Practices 11
Surface Preparation 11
Coating Application 11
Coating Performance Testing 11
Waste and Emissions Summary 11
Liquid Wastes 11
Solid and Hazardous Wastes 11
Air Emissions 11
Regulatory Profile. 12
The Clean Water Act (CWA) 12
Future Considerations 12
Local POTW Requirement.... 14
Requirements of the New Haven Code 14
Prohibited Discharges 15
Requirements for Wastewater Discharge Permits.... 15
Other Considerations 15
Feasibility Demonstrations 15
Pretreatment System and Powder Coating System Conditions 16
Feasibility Laboratory Testing Results 16
Primer to Metal Performance Data 16
Primer to Topcoat Performance Data 16
Feasibility Demonstration Major Lessons Learned 16
Optimization Demonstrations....... 17
Pretreatment System and Powder Coating System Conditions 19
Racking Considerations 19
Iron Phosphating Pretreatment Considerations. 19
Powder Coating Considerations 19
Optimization Trial Laboratory Testing Results 19
Supplemental Powder Coat/Topcoat Compatibility Trial 20
Optimization Demonstration Major Results 20
Validation Trials 20
Parts Processing... 20
Process Operating Conditions 20
Material, Utility and Labor Usage 21
Laboratory Results 21
Powder Coat Primer to Metal Performance Data. 21
Basement Door Parts Thickness Profile Data 22
Major Results Summary From Validation Testing 22
COST ANALYSIS. 22
Environmental Analysis....... 26
vi
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Regulatory Comparisons 26
Quality Analysis Summary 27
Primer to Metal Performance Category 27
Primer to Topcoat Performance 27
Additional Process Quality Considerations 27
CONCLUSIONS 28
DCCCDCMfCC OQ
rttirCKCiNwClo /~.*3
APPENDIX A 30
Facility Baseline Survey Questionnaire 30
APPENDIX B 46
Material Safety Data Sheets for Bilco Primer and Solvent Thinner 46
LIST OF FIGURES
Figure 1 Exploded Top View Of Bilco Basement Door System 3
Figure 2. Exploded Bottom View Of Bilco Basement Door System 3
Figure 3. Process Flow Diagram 5
Figure 4. CTC Line & Overall Process Schematic 9
Figure 5. Average Thickness Profile On Front Surface , 23
Figure 6. Average Thickness Profile On Back Side Surfaces 23
¦ iot r\c xadi ce
Lib I Ur I AtJLLo
Table 1. Flowcoating Process Equipment 4
Table 2. 1995 Primer And Solvent Usage In Bilco Flowcoating Process 4
Table 3. Summary Of Energy Usage By The Bilco Company 4
Table 4. Bilco Basement Door Primer Specifications 6
Table 5. Waste And Emissions Summary For The Bilco Flowcoating Process 6
Table 6. Iron Phosphate Process Materials Summary 10
Table 7. Summary Of Powder Coating And Topcoating Materials 13
Table 8. Iron Phosphate Process Summary 13
Table 9. Scope Of Coatings Testing For Technology Demonstration Trials 14
Table 10. Iron Phosphate Pretreatment System Conditions 16
Table 11. Powder Coating System Conditions 16
Table 12. Feasibility Testing Results For The Primer Only And Primer / Topcoat Specimens 18
Table 13. Optimization Testing Results For The Powder Primer And Primer/Topcoat Specimens... 20
Table 14. Supplemental Intercoat Adhesion Data For Topcoats And Powder Coats 21
Table 15. Validation Trial Material And Utility Usage Summary 22
Table 16. Validation Trial Inventory Of Parts For AM And PM Shifts 24
Table 17. Validation Trial Process Operating Conditions Summary 24
Table 18. Validation Testing Results For The Primer And Primer / Topcoat Specimens 25
Table 19. Total Capital Cost 26
Table 20. Operating Cost Summary 26
Table 21. Life Cycle Cost Comparison 26
Table 22. Bilco Basement Door Primer Specifications 27
vii
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METRIC EQUIVALENTS
This report combines metric and nonmetric units as the need arises. Readers who are
more familiar with metric units may use the following factors to convert to that system.
NON-METRIC MULTIPLIED BY YIELDS METRIC
°F 5/9 (°F-32) °C
ft 0.3048 m
ft2 0.0929 m2
ft3 28.32 (or 0.02832) L (m3)
gal 3.785 L
lb 0.4536 kg
in 2.54 cm
mil 0.0254 mm
psi 6.895 kPa
viii
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EXECUTIVE' SUMMARY
This document summarizes the results of a National Defense Center for Environmental Excellence (NDCEE) task conducted by
Concurrent Technologies Corporation (CTC). The task, "Powder Coat Applications,"' is an Environmental Technology Initiative
project funded by the US Environmental Protection Agency (EPA). The task objective is to demonstrate powder coating
technology as a method of eliminating volatile organic compounds (VOCs) from coating operations in small business.
Small business manufacturers often do not have the resources to investigate new technologies such as powder coating. This
task leveraged the existence of the NDCEE Technology Demonstration Factory to test and evaluate powder coatings for small
business applications. A small business manufacturer, The Bilco Company, was selected to participate in the project. Bilco,
located in West Haven, CT, manufactures steel basement doors and coats these with a solvent-based primer.
Environmental analysis of the alternative, powder coating, demonstrated the potential to eliminate VOC emissions. Currently,
approximately 39 tons per year of VOCs are produced by the current system. These VOCs are sent to a catalytic incinerator
destruction system that is nearing the end of its useful life and will need to be replaced in order to meet regulations if the current
coating system is kept. This VOC destruction system reduces the amount of VOCs emitted into the atmosphere to 2.5 tons per
year.
During quality analysis, powder coating demonstrated the potential to dramatically improve upon performance of the current
coating system. Performance characteristics such as salt spray corrosion resistance, impact resistance, and hardness were
improved with the use of powder coating. With increased coating performance, Bilco could investigate the possibility of offering
an extended warranty on its products.
Powder coating systems can be designed to meet Bilco's present and future production requirements. Automatic and manual
powder equipment presently exists that can be configured to meet Bilco's present 235 door/day production level.
Using the N1ST Building Life Cycle Cost program with a study period of 15 years, it was calculated that through powder
coating, Bilco can save over $142,000 each year in operating costs when compared to using the current coating system with
increased VOC controls. In addition, a Life Cycle Cost savings of over $280,000 can be obtained with powder.
Bilco's current finishing system, flow coating, is a high-transfer efficiency coating process resulting in a low cost per part. As a
result, it is estimated that an investment in powder coating equipment will not realize payback until year 7 after investment. This
payback period is much longer than observed when powder systems have replaced liquid spray coating technologies in industry.
However, benefits such as increased part quality and reduced use of hazardous materials are difficult to quantify. Powder
coating, while offering a payback period of 7 years, has the potential to increase product quality and provide a cleaner, healthier
workplace.
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INTRODUCTION
New environmental regulations continue to place tighter
restrictions on how manufacturers can coat parts by limiting
the amount of volatile organic compounds (VOCs) that can be
released. A reduction in VOC emissions can be achieved by
technologies such as higher-efficiency spray equipment, e.g.,
high-volume, low-pressure (HVLP) and electrostatic
equipment. In addition, a process material change can reduce
VOC emissions by eliminating VOCs from coating
formulations. Coatings manufacturers offer a range of
technologies such as high-solids paint, waterborne, and
powder coating materials to lower VOC emissions.
Powder coating, invented in the early 1950s, is an
environmental technology with near-zero-VOC emissions.
Although powder coatings have been in existence for over 40
years, they have not gained widespread acceptance until the
recent introduction of strict VOC emission regulations.
Powder coating manufacturers have continually refined their
formulations and now offer coatings that match or exceed
performance characteristics of previously-used liquid spray
coatings.
Although powder coating technology has been adopted by
large industries such as automotive, appliance, and furniture
manufacturing, small businesses often do not have the
resources to investigate new technologies. To successfully
transition a new technology, a company must be able to
investigate all aspects of a new technology that affect:
• cost,
• environmental impact,
• part quality, and
• production.
Once these areas are evaluated, an informed decision can be
made regarding the implementation of new technology.
Project Background
The US Environmental Protection Agency (EPA), through its
Environmental Technology Initiative, has funded the National
Defense Center for Environmental Excellence (NDCEE) to
work with a small business to demonstrate powder coating
and identify opportunities for its use by these businesses.
This project focused on commercially-available powder
coating materials that could potentially be implemented into
small business manufacturing. These powder coatings have
been developed for and used by larger manufacturers and the
Department of Defense (DOD) but have performance
characteristics similar to those required by smaller businesses.
Working with the EPA and the Powder Coating Institute
(PCI), a project plan was developed to meet this objective.
Project Objectives
The project objectives, as stated in the original Statement of
Work (SOW) and Project Plan, are as follows:
• work with a small business partner who is presently using
a solvent-based coating system to conduct technology
demonstrations and process simulations involving the
application of powder coatings on sample production
parts
• gather technical, economic, and environmental data to
determine the feasibility of converting from a solvent-
based coating system to a powder coating system for a
small business project partner
• derive lessons learned that are applicable to the
conversion of powder coating by other businesses using
solvent-based finishes
• conduct technology transfer activities to small businesses
on powder coating.
APPROACH
The approach used by the project consists of six major steps
as described in this section.
Identification of a Small Business Representative
• Collaborate with the DOD, EPA, PCI, and the Small
Business Association (SBA) to identify a candidate small
business for direct participation in the Powder Coating
Applications project. The basic requirement for selecting
a small business candidate was that the candidate had to
be using solvent-based liquid finishing technologies as a
major component of their manufacturing process and
have an interest in transitioning to powder coating
technology.
Facility Baseline Survey
• Establish a baseline for the process economics, technical
requirements, and environmental aspects for the small
business candidate's current finishing operation by
conducting an on-site facility survey, prepare a detailed
survey questionnaire to be completed by the small
business, and perform follow-up telephone conversations
with the small business.
• Use this information to prepare life cycle cost,
environmental, and technical performance comparative
analyses of the candidate's present finishing process to
the powder coating alternative process.
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Powder Coating Technology Feasibility Testing
» Prior to conducting full-scale powder coating technology
demonstrations and formal economic and product
performance data collection, perform initial feasibility
testing to determine if powder coating technology is
appropriate for the parts manufactured by the small
business. The primary objective of this activity is to
demonstrate that powder coatings show promise in terms
of coating performance data for meeting existing coating
requirements.
Powder Coating Technology Optimization
Testing
• Following the successful feasibility demonstration of
powder coating, perform an optimization trial. The
optimization phase is intended to accomplish the
following goals:
focus on those aspects of the powder coating process
that demonstrate a need for further refinement based
on process engineering lessons learned and/or
laboratory testing results from the feasibility trial
- demonstrate that current coating requirements could
be maintained after optimization process changes
were made
- serve as a technical preparation phase for the final
technology validation demonstration trials.
Powder Coating Validation Demonstrations
• Following completion of the optimization testing, conduct
a final powder coating validation demonstration. The
goals of the validation testing arc as follows:
- using the process parameters and lessons learned
from prior trials, prove-out the ability of powder
coating technology to successfully coat parts under
simulated production conditions
- make any final process engineering observations that
would translate into powder coating process
implementation recommendations
- collect "on-line" technical, economic, and quality
data for powder coating the selected candidate's
parts.
Technology Transfer Activities
• One of the primary objectives of the Powder Coating
Applications project is to provide information to the
small business community demonstrating that powder
coating can be a cost-effective methodology to replace
liquid processes while yielding improved product quality,
reduced life cycle production costs, and reduced
hazardous air emissions.
• Complete the following technology transition activities:
- distribute this report to other small businesses
through the EPA, PCI, SBA, and trade publications
- conduct classroom, factory, and laboratory hands-on
training sessions in powder coating.
PROJECT RESULTS
Identification of Small Business Project Partner
The first project activity identified a small business project
partner. To maximize the impact of the program,
demonstration of powder coating technology on real parts
from a small business manufacturer was critical. A meeting
was first held, attended by:
• the EPA project sponsors
• DOD technical monitors
• PCI Executive Director
• industry consultants
• in-house technical and business personnel.
During the meeting, the type of small business participation
was discussed. Small businesses, as categorized by the SBA,
consists of any manufacturer with 500 or fewer employees.
To select a manufacturer for the project that would produce
sufficient data that would be widely applicable to many of the
small manufacturers currently performing liquid coating
operations, the decision was made by the meeting attendees to
work with a manufacturer that at least had a conveyorized
paint line.
After an extensive search, the Bilco Company in West Haven,
CT, was identified. Bilco is currently coating its products
with a solvent-based coating system and is interested in
investigating powder coating. Because of Bilco's small size,
an investigation of this nature was not feasible without
external support. This project offered Bilco a way to
accomplish that investigation while expending little resources
and avoiding any production interruptions.
Bilco is a small manufacturer of exterior basement doors.
Bilco currently has approximately 110 employees at its
manufacturing site. Approximately half of the employees
work producing doors in the factory. The remaining
employees work in administrative and sales areas.
Figures 1 and 2, show the type of product that Bilco
manufactures. These parts are produced using hot-rolled steel
and are coated with a solvent-based primer at the
manufacturing site. The doors may be topcoated later by an
installation contractor in the field. The primer that Bilco
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currently applies is a solvent-based coating that contains 3.99
pounds of VOCs per gallon as supplied. However, to properly
coat the parts, Bilco adds additional solvent to the primer at an
average yearly ratio of approximately 3:4. This produces a
high level of VOCs from the coating process.
If the current paint system is kept, Bilco faces replacement of
their current VOC control system with a new $380,000 VOC
incinerator to comply with the VOC emissions limit. The
current equipment is nearing the end of its useful life. This
type of 'end-of-pipe' VOC control is typically expensive to
purchase and operate.
Figure 1. Exploded Top View of Bilco Basement Door System
Figure 2. Exploded Bottom View of Bilco Basement Door
System
Baseline Survey of The Bilco Company's
Flowcoat Finishing Operation
This section presents the methods used to collect information
and describes the coating process for Bilco's finishing
operations.
Methodologies Used
Three techniques were used to collect information about
Bilco's finishing process. These were:
• an initial on-site survey,
• a facility questionnaire, and
• follow-up phone interviews.
On-site Survey
An initial project kick-off meeting and brief survey of Bilco's
finishing operation was conducted in December 1995.
Contractor personnel and an NDCEE program representative
from the Armament Research Development and Engineering
Center (ARDEC) worked with Bilco staff to collect
information.
During a one-day meeting, Bilco representatives led the
survey team on a tour of its manufacturing facility. The tour
included receiving, cutting, stamping, forming, welding,
coating, packaging, and storage. During the tour, information
was collected about Bilco's process equipment, procedures,
and material usage. Bilco provided the team with process
material safety data sheets (MSDSs), material usage volumes,
and coating details.
The most detailed information, however, was collected from
the survey questionnaire and follow-up phone interviews.
Survey Questionnaire
As a follow-up to the initial on-site facility baseline survey, a
15-page questionnaire was prepared and completed by Bilco
personnel. A sample questionnaire is located in Appendix A.
The questionnaire requested information on Bilco's process
operating data, quality assurance practices, environmental
practices, and operating costs.
Follow-up Phone Interviews
The information collected from the on-site survey and the
follow-up questionnaire was supplemented as necessary by
conducting phone interviews with Bilco personnel throughout
the duration of the project.
The input received from all three data collection techniques
forms the basis of the information reported below for Bilco's
finishing process.
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Bilco Process Description
The following is an overview of Bilco's current process. For
relevancy, detailed discussion will be limited to those portions
of Bilco's manufacturing that directly affect the coating
process.
General Process Descriptions of Manufacturing and Coating
Operations
Bilco receives hot-rolled steel in sheets to manufacture the
doors and steel rods to manufacture the handle and locking
assemblies. All necessary cutting, stamping, bending, and
welding are performed on-site by Bilco personnel. Following
welding, the parts are hung on a conveyor and sent to the
flow-coater where a one-coat primer is applied.
In flowcoating, the parts are sprayed with paint from the top,
bottom, and sides with high-pressure spray nozzles. The paint
that does not adhere to the part falls through the bottom of the
floweoater and is recirculated through the system's large paint
reservoir. All required paint and solvent are added to this
reservoir. The overall transfer efficiency of this type of
system is very high, similar to that of powder coating, but the
paint currently used is high in VOC content.
Following application of the primer, it is dried in a baking
oven connected to the flow coater. Once the coating is dried,
the parts are packaged and sent to storage for shipment.
Figure 3 shows a schematic process flow diagram of Bilco's
facility.
An important factor to note about Bilco's current paint system
is that there is no cleaning or pretreatment of the parts prior to
painting. With solvent-based paint systems and low levels of
oily soils, this can sometimes work. Apparently, Bilco's
solvent-based paint system is able to accommodate the low
levels of soils present on its products.
Equipment Description
Table 1 lists Bilco's current flowcoating equipment size,
capacity, pollution control, and other information.
Table 1. Flowcoating Process Equipment
Unit Details
OVERALL
Process Footprint
15'x 125'
VOC CONTROL
Catalytic Incinerator
Installed 1985, 93-94% destruction
efficiency
COATING SYSTEM
Floweoater Booth
90 gallon tank, 6" x 10' x 30'
Baking Oven
Gas fired oven, 6' x 10' x 30'
Materia! and Utilities Usage
Material Usage
In the single-step flowcoating process used by Bilco, the only
material inputs are the primer coating and a solvent used to
reduce the viscosity or thin the primer. There are no other
parts cleaning or metal pretreatment steps. The door
components enter the floweoater directly after fabrication.
The primer is listed by the coating vendor as being a red oxide
primer. The thinner is a mixture of aromatic hydrocarbon
solvents.
In addition to reducing the primer, the solvent is used
periodically to clean the spray nozzles in the floweoater. The
total annual (1995) usage and the major hazardous
constituents as listed on the MSDSs are shown in Table 2.
The complete MSDSs are in Appendix B.
Table 2. 1995 Primer and Solvent Usage In Bilco
Flowcoating Process
Material
Annual Usage,
Hazardous
gallons
Components
Low VOC Red
5,740
Etliylamine
Oxide Primer
Alkylolammonium Salt
10.773 lbs/gal
Petroleum
(3.99 lb/gal VOC)
Hydrocarbons
1,2,4, Trimethylbenzene
Naphthalene
Cobalt
Manganese
Aromatic 100
7,560
Trimcthylbenzencs
Solvent
Xylene
7.3 lbs/gal
Cumene
Ethylbcnzene
Utilities Usage
The Bilco flowcoating process primarily uses natural gas and
electricity. The utility usage details are summarized in Table
3.
Table 3. Summary of Energy Usage by the Bilco Company
ENERGY QUANTITY
Electricity 23,107 kW-hr/yr
Natural Gas 2,149,600 ft3/yr
Production Flow Rates
Bilco operates one 8-hour production shift per day, 5 days per
week, 249 days per year. A total of eight operators and one
supervisor work in the finishing area, which includes
flowcoating, packaging, and distribution operations.
Per shift, Bilco manufactures and flowcoats approximately
235 complete hot rolled steel basement door systems, which
come in four standard sizes. Each door consists of two
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Paint Waste Sludge
(Hazardous)
* capture efficiency not available
Figure 3. Process Flow Diagram
rectangular door panels, two triangular side pieces, a
rectangular header piece, and a rectangular footer piece, for a
total of six major components. The doors and side pieces also
have various hinges and latches attached for operation of the
doors. On a typical production day, therefore, Bilco
manufactures 470 door panels, 470 side pieces, 235 headers,
and 235 footers. Average annual total production equates to
50,000 to 60,000 complete doors per year.
The average total surface area per complete door system (six
main panels with subassemblies) is approximately 91 ft2.
Assuming equal production of all standard door sizes, 21,385
ft2 of surface area are coated with primer each shift, and over
5.3 million ft2 of surface area are coated annually.
Procedures and Practices
Surface Preparation
After fabrication of the hot rolled steel into panels and
welding of various subassemblies such as handles, rods, and
hinges onto the appropriate panels, the parts are sent directly
to the flovvcoating booth.
There are no additional surface preparation steps such as
blasting, cleaning, conversion coating, or scale removal. The
physical and/or chemical action of the primer and solvent
mixture is relied upon to maintain film integrity and adhesion.
Bilco does perform a visual inspection of the hot rolled steel
prior to flowcoating to check for the presence of excessive
scale or oil. Upon close visual inspection, weld spots and
other small, random metal surface imperfections and
contamination such as dust may occasionally be observed in
the Final Coating Film.
Coating Application and Mixing Process
The flowcoating operation is conveyorized and requires little
manual attendance during coating and baking other than
loading and unloading of the parts. The door components are
racked individually onto the conveyor so that the parts for one
complete basement door assembly exit the baking booth as a
group. The racking configuration would not be described as
being high density.
The primer and solvent are mixed to achieve the viscosity
recommended by the vendor which is 20-22 seconds in a Zahn
#2 cup. The parts are automatically coated as they pass
through the flowcoating booth. A reservoir collects any
unvolatilized primer/thinner overspray as well as any solvent
used to periodically clean the spray nozzles. The contents of
the reservoir are continuously recycled with virgin coating
material during production and sprayed back onto the parts.
When applied and cured according to the coating supplier's
instructions, the dry film thickness of the primer should range
from 0.5-1.5 mils. The theoretical coverage of the primer,
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when thinned as prescribed, is 636 ft2/gallon. Actual coverage
varies based on actual viscosity, process operating,
environmental conditions, and coating thickness. Based on
the 55,740 gallons of primer used annually by Bilco and the
stated coverage for the coating, the calculated surface area
coated annually by Bilco is approximately 3.6 million ft2 at a
film thickness of 1 mil. However, based on Bilco's
production data of 235 doors per day, which equates to about
5.3 million ft2 of coated surface annually, Bilco is achieving a
yield that is on the higher end of the expectation boundary.
This may indicate, as do the panels tested, that Bilco is
applying films at the lower end of the film thickness range.
Coating Performance Testing
Bilco reports that it performs visual inspections and dry film
thickness quality checks on its parts after baking and that there
are few if any rejects after these checks. The coating supplier
is responsible for any primer raw materials checks and for
periodic testing for salt spray corrosion resistance.
Bilco has a performance specification sheet for its basement
door primer. Table 4 summarizes the overall primer
requirements as found in Bilco's written specification and as
determined through discussion with Bilco representatives.
Table 4. Bilco Basement Door Primer Specifications
ITEM REQUIREMENTS
Corrosion
. 175 hours AST VI B117 salt spray
Resistance
* Resist rust to a rating of 10 according to ASTM
D610
. No blisters according to ASTM D714
Environmental
• VOC compliant in the State of Connecticut
Compliance
Appearance and
• Smooth finish when applied to hot rolled steel
Thickness
weldments
• Complete coverage, no bare spots, drips or
sags
• Red oxide color
• 0.7 to 1.1 mils thickness
Topcoating
• Compatible with a finish coat of alkyd enamel
applied in the field after installation
• Alternative topcoats acceptable as long as
these have equal field performance and
customer appeal
Waste and Emissions Summary
The fiowcoating process produces two waste streams: a D007
paint sludge waste and VOC air emissions. The paint sludge
waste comes from the primer/thinner recycling reservoir at the
bottom of the flowcoater booth. This sludge must be removed
and periodically disposed off-site. Although this waste stream
is primarily paint related along with oils and other surface
contaminants removed during the coating step, according to
environmental regulations it must be listed as D007 due to the
possible presence of chromium from the steel parts being
coated. There are no other operations, such as cleaning or
maintaining equipment, or replacing filters, that generate
additional solid wastes.
Air emissions are generated as the result of VOCs in the
primer and thinner. There are minimal fugitive emissions
reported for the process. The only opening in the process
booths other than the exit slit from the bake oven and the
openings for the emission stacks is the narrow entrance slit for
the parts. The spray segment occurs well enough inside the
fiowcoating booth to minimize fugitive emissions. All
emissions are assumed to travel through the interconnected
emission stack system above the fiowcoating and bake oven
booths to a catalytic incinerator that reduces the amount of
VOCs entering the atmosphere by 93-94%. Secondary air
contaminants may be generated during the incineration
process and result in the release of additional air emissions.
These secondary air contaminants can include nitrogen
oxides, carbon monoxide, carbon dioxide, and sulfur dioxide.
Table 5 summarizes the waste streams generated and the
amounts of each reported by Bilco.
Table 5. Waste and Emissions Summary for the Bilco
Fiowcoating Process
Waste Stream ] Quantity
D007 Hazardous Paint Waste
Sludge
11,000 Ibs/yr
VOC Air Emissions
39 tons/yr before incineration
2.5 tons/yr after incineration
Nitrogen Oxides
140 lb/million cubic feet gas
fired*
Carbon Monoxide
35 lb/million cubic feet gas
fired*
Carbon Dioxide
120,000 lb/million cubic feet
gas fired*
Sulfur Dioxide
0.6 lb/million cubic feet gas
fired*
"(Estimated values based on information found in EPA document AP-
42 for uncontrolled small industrial boilers1.)
Regulatory Profile
This section describes the legislative and regulatory
requirements at the federal, state, and local level that relate to
the management of hazardous waste and the control of VOC
emissions as they impact Bilco's current flow coating
operation.
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The flow coating operation is a two-step process. The first
step includes the application of the coating (primer) itself.
The second step is a curing process where the primer is dried
and the VOC emissions are captured for incineration.
The regulatory analysis that follows is based on the following
data reported by Bilco:
• Bilco currently emits less than three tons of VOCs per
year from its flow coating operation (after incineration).
• Bilco generates approximately 11,000 Ibs/yr (5,000 kg/yr)
or 416 kg/month of D007 hazardous waste (paint sludge).
Based on these facts, the primary regulations impacting Bilco
at this time are the Clean Air Act and the Resource
Conservation and Recovery Act.
The Clean Air Act, as Amended in 1990 (CAA)
National Ambient Air Quality Standards (NAAQS')
Under Title I of the Clean Air Act, as amended in 1990
(CAA), the EPA is required to establish national ambient air
quality standards (NAAQS) for criteria pollutants, such as
ozone, sulfur dioxide, nitrogen dioxide, particulate matter,
carbon monoxide, and lead. NAAQS establish certain levels
of criteria pollutants that may not be exceeded in the ambient
air of specified geographical areas. Each state is responsible
for adopting and enforcing the NAAQS. An area where the
quality of the ambient air fails to meet any of the NAAQS for
a given pollutant is referred to as a non-attainment area.
Ozone non-attainment areas are classified into one of the
following five categories based on the extent of non-
attainment: marginal, moderate, serious, severe, and extreme.
Each classification has its own date by which attainment is
required and its own major source threshold based on a
source's potential to emit a certain number of tons of VOCs
per year. Sources located in ozone non-attainment areas
classified with a greater extent of non-attainment generally
require more stringent controls.
Because Bilco generates VOCs that are considered to be a
precursor to ozone, Bilco's conventional flowcoating process
is primarily affected by the NAAQS pertaining to ozone.
Bilco is located in New Haven, Connecticut, which is in a
geographical area that has been designated as a serious non-
attainment area for ozone. In serious ozone non-attainment
areas, a major source is defined as a source that emits 50 tons
or more of VOCs per year. Therefore, Bilco does not qualify
as a major source emitter of VOCs.
State of Connecticut
Control of VOC Emissions - Emissions Standards
The state of Connecticut has established regulations to control
emissions of organic compounds. These regulations can be
found in 22 (Connecticut Code) CT Code part 174, section 20
(i.e., Section 22a-174-20). The regulations include emission
standards to control VOC emissions related to "miscellaneous
metal parts and products," which includes the following
industrial categories:
• fabricated metal products (metal covered doors, frames,
etc.) and
• any other industrial category which coats metal parts or
products under the Standard Industrial Classification
(SIC) Code of Major Group 34 (fabricated metal
products).
The regulation prohibits facilities engaged in the surface
coating of miscellaneous metal parts and products from
operating a coating application system that emits VOCs from
any coating in excess of the following amounts:
1. 4.3 pounds per gallon (lb/gal) of coating, excluding water
and exempt VOCs, delivered to a coating applicator that
applies a clear coat
2. 3.5 lb/gal of coating, excluding water and exempt VOCs,
delivered to a coating applicator in a coating application
system that is air dried or forced warm air dried at
temperatures up to 90 degrees C
3. 3.5 lb/gal of coating, excluding water and exempt VOCs,
delivered to a coating applicator that applies extreme
performance coatings
4. 3.0 lb/gal of coating, excluding water and exempt VOCs,
delivered to a coating applicator for all other coatings,
adhesives, fillers, or sealant and coating application
systems
5. 6.3 lb/gal of coating, excluding water and exempt VOCs,
delivered to a coating applicator which applies high
performance architectural aluminum coatings.
Item No. 2, in particular, is relevant to Bilco's operation.
The Resource Conservation and Recovery Act (RCRA)
Subtitle C of the federal Resource Conservation and Recovery
Act (RCRA) authorizes the EPA to regulate the management
and disposal of hazardous wastes. The designation of a waste
as hazardous subjects all those charged with managing that
waste to the stringent "cradle-to-grave" requirements of
RCRA Subtitle C. The state of Connecticut has been
authorized to administer its own hazardous waste program and
enforce hazardous waste law.
If wastes from the Bilco process qualify as hazardous under
RCRA, Bilco is considered a hazardous waste generator
subject to the RCRA requirements for hazardous waste
generators, such as hazardous waste manifesting of wastes and
reporting. A generator is defined as "any person, by site,
whose act or process produces hazardous waste identified or
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listed in [40 CFR] part 261 or whose act first causes a
hazardous waste to become subject to regulation."
Hazardous wastes are designated as either (1) a solid waste
that is specifically listed as being hazardous, or (2) a solid
waste that exhibits hazardous characteristics (e.g., ignitability,
corrosivity, reactivity, or toxicity). This report assumes that
the paint sludge generated in the flow coating process at Bilco
is a characteristic hazardous waste (D007). According to the
EPA, chromium occurs in the paint sludge because metal
chips or flakes from the treated steel substrate contain
chromium. The EPA defines a DO07 waste as a waste that
contains 5.0 mg/L of chromium in the extract from a toxicity
characteristic leaching procedure (TCLP).
D0Q7 Hazardous Waste (Paint Sludge)
The process wastes from Bilco's flowcoating operation
include hazardous waste paint sludge, EPA identification
number D0O7, due to the potential to contain heavy metals
(chromium). Bilco generates approximately 11,000 Ibs/yr
(5,000 kg/yr), or 416 kg/month, of this hazardous waste.
Based on this quantity, Bilco is classified as a small quantity
generator, subject to the requirements for small quantity
generators. A small quantity generator is defined as a facility
that generates more than 100 kilograms of hazardous waste
per month, but less than 1,000 kilograms per month.
Powder Coating Alternative Process Description
The EPA has targeted powder coating as a potential
alternative coating technology due to its elimination of VOC
emissions. In addition, the process is less hazardous, less
expensive, and can prdvide a healthier work environment for
employees.
Any powder coating operation, whether a large multi-million-
square-foot-per-year production line or a small custom shop
has three main components:
• cleaning/pretreatment
• powder application
• powder cure.
Many other sub-processes are involved such as racking,
process control, and shop environmental controls, but these
are all in support of the three main areas and will be described
as such.
Adequate cleaning and pretreatment is perhaps the single most
important aspect to consider when designing any new paint
system, whether it is a powder system or not. The most
common reason for paint failures is improper cleaning prior to
painting. Although a coating's performance is dependent on
its final application, even the most expensive, high
performance coating will fail if applied over a contaminate, or
improperly prepared substrate, particularly in highly corrosive
environments.
There are many different types of pretreatments available for
steel parts prior to powder coating ranging from a high-
performance 6- to 7-stage zinc phosphate system to a 1-stage
cleaner/phosphator solution. If the 1 -stage system provides
adequate performance for the product, then the more
expensive system is not necessary unless product performance
suffers or an improvement is desired.
For this project, an iron phosphate material was selected
because of its low cost, few stages (2), and performance that
met requirements.
Following pretreatment, the parts are dried in a convection
oven to remove excess water. An infrared oven (IR) can also
be used for this purpose and may reduce operating costs even
further.
Once the parts are dried, the powder can be applied. Although
there are several methods of powder coating, electrostatic
spray is the most commonly used and is the method that was
used for this study.
Electrostatic spray offers a high degree of control, is easily
automated, and can coat a variety of different part shapes and
sizes. In the electrostatic powder application process, powder
is electrically charged at the gun tip and applied to a grounded
part.
An overview of CTC's powder coating process is shown in
Figure 4. After cleaning and pretreatment, parts are conveyed
to the powder booth. Powder is loaded into a fluidizing
hopper and delivered to the spray guns using a pneumatic
pump system. Any powder that does not reach the part is
pulled into the reclaim module and can be filtered and re-
sprayed.
Following application of the powder, the parts are sent to a
curing oven. Here, the powder is taken past its melting point
where it flows evenly over the part, cross-links, and cures.
Convection ovens are popular for curing because of their
versatility and cost. IR ovens are gaming widespread
acceptance because of their increased efficiency and process
flow rate. IR ovens cannot, however, cure every type of part.
Since IR is a light-wave radiation process, line-of-sight
exposure to IR is required, so a part with hidden areas will not
cure. IR ovens are also valuable when combined with a
convection oven to speed up the cure process.
The CTC powder coating system is capable of applying
powder coating manually or automatically using up to 10
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Figure 4. CTC Line & Overall Process Schematic
electrostatic guns, A variety of part configurations can be
accommodated up to dimensions of 3'x4'x4* and up to 250
pounds per part.
The system is Programmable Logic Controller (PLC)-
controlled and tied into a Factory Data Integration System that
collects process and ambient data during each run.
Powder Coating Equipment Used for this Project
Descriptions
Controls and Data Collection
The controls and data collection were briefly discussed in the
previous section and played a major part in this program. The
PLC control system allowed one to experiment with a variety
of process settings in order to find the optimum setup for
Bilco's parts.
Conveyor System
The conveyor system uses a power-and-free overhead
conveyor system with a total of 5 separate chains. Parts can
travel from 5 to 40 feet per minute through the system. A
power and free system was selected because it provides the
maximum amount of process flexibility and versatility in a
small space.
Pretreatment
The pretreatment system consists of a 7-stage spray washer
with variable temperature, pressure, and flow controls at each
stage. A variety of chemical pretreatment solutions can be
demonstrated because of the system's unique flexibility.
Dry-off and Cure Ovens
The dry-off oven and cure ovens used at CTC are direct gas-
fired convection ovens. In addition, an IR oven was used for
testing.
Automatic Powder with Manual Touch-up
CTC's powder coating system is capable of manual
application or automatic application using two banks of
automatic guns on vertical reciprocators.
Material and Utilities Usage
Pretreatment Process Selection Background
To apply powder coatings to steel, the metal parts should first
be pretreated to create a surface which will accept the organic
coating with good appearance, adhesion and corrosion
resistance properties. Phosphating processes are common
pretreatment steps used on steel before powder coating. Two
major types of phosphating include zinc phosphating and iron
phosphating. There are economic, quality and operational
tradeoffs associated with each process that factor into
selection of one for use.
Zinc phosphating, while often giving superior adhesion and
corrosion resistance when compared to iron phosphating
typically will have more process stages, be more costly to
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install and operate, require greater effort to control
chemically, and produce a zinc metal contaminated solution.
Iron phosphating provides the requisite finished product
performance in many applications and typically consists of
fewer process stages with less chemical constituents to
monitor in the phosphating stage. The iron phosphating
process would thus be expected to have less expensive startup
and operating costs and be simpler to operate and control. In
addition, the desired iron oxide and iron phosphate (FeO and
FeP04) sites on the metal surface are created using iron
inherent in the base metal, eliminating heavy metals arising
from the phosphating chemicals.
A one-step cleaner/coater iron phosphate process followed by
a city water rinse was chosen as the pretreatment technology
for demonstration due to anticipated operational, life cycle
cost and environmental advantages. After selection of this
process, two technical challenges required further attention;
a) applying an iron phosphate pretreatment to hot rolled steel
and b) the level of surface cleanliness of the parts after
fabrication. The first challenge results from the buildup of
mill-scale, or unwanted iron oxides, from the action of oxygen
with steel at higher temperatures during the making of the hot
rolled steel raw material. This issue is addressable by
operating the phosphating process at sufficiently low pH to
remove any scale (unwanted oxides) through acidic
dissolution while simultaneously depositing the desired
phosphate layer. It should be noted that the hot rolled raw
material Bilco uses is reported to contain minimal scale,
further mitigating this potential problem. With respect to the
latter concern, surface cleanliness, the required approach is to
ensure that parts are in contact with the phosphating/cleaning
stage for a long enough period to remove any oils and smut.
Pretreatment Materials
The materials required for the iron phosphating process used
for this project are summarized in Table 6. The phosphating
stage consists of the phosphating chemical and an additive to
enhance detergency for cleaning of the parts. The only
chemical control requirements are a titration for total acid
content and pH measurement which was recorded by an in-
line meter. The titration was used to maintain the total acid at
a level which required control between 6.0 to 14.0 milliliters,
or points, of the vendor supplied titrant. To increase the
concentration of the chemical for tank replenishment
purposes, 0.5 gallons of fresh chemical is added per 100
gallons of tank volume for each point of desired concentration
increase. To maintain the concentration at 10.0 +/- 0.5 points
required the addition of approximately 9-14 gallons of fresh
chemical at the start of each day of experimentation. It should
be noted that a pretreatment system which has been explicitly
designed and optimized for two or three stage iron
phosphating would be expected to operate more efficiently
with respect to chemical consumption.
Table 6. Iron Phosphate Process Materials Summary
Material Purpose Active Chemical
Components
Parker Amchem
Prep-n-Coat 700
Phosphating
Monosodium
Phosphate
Surfactants
Hydrofluoric Acid
Parker Amchem
Parco Cleaner
3140
Cleaning
Additive
Ammonium Hydroxide
Nonionic Surfactants
Parker Amchem
Caustic Soda
pH adjustment
Sodium Hydroxide
Parker Amchem
Parcolene 6
pH adjustment
Phosphoric Acid
Rinse Stags
Parts Rinsing
City Water
Powder Coating and Topcoating Materials
A key component of this project is to demonstrate that powder
coating materials are commercially available which meet
Bilco's existing primer performance requirements including;
• coirosion resistance (175 hours salt spray),
• environmental compliance (VOC compliant),
• appearance (smoothness, coverage and color), and
• the ability to be topcoated (adhesion and appearance).
Of Bilco's criteria, the greatest technical challenge by far is
applying a liquid topcoat to a cured powder coating and
achieving adequate adhesion. Because powder coatings tend
to be extremely durable and chemical resistant, it is sometimes
difficult for a topcoat to "bite" into the surface to achieve
good adhesion. There are a number of powder coat
primer/liquid topcoat systems that work well and Bilco will
need to consider this when selecting a material for production.
Potential powder coating candidates were identified through
discussions with vendors. Based on the discussions with
major vendors of powder coatings that considered Bilco's
primer criteria as well as product availability, a red oxide,
thermosetting urethane polyester material was chosen as the
baseline powder coating. A VOC-compliant alkyd enamel
product was chosen as the baseline topcoating material. A
summary of all the powder coating and topcoating materials
used for this project is shown in Table 7.
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Procedures/Practices
Surface Preparation
As stated above, an iron phosphating process was used for all
metal pretreatment needs. Two processing stages, one for
phosphating and one for a city water rinse were required. The
chief technical challenges were to establish suitable process
operating conditions such as for exposure times, temperatures,
chemical concentration and to keep the parts wet after
phosphating to avoid flash rusting. The vendor of the
pretreatment chemicals assisted with process optimization
through preliminary pretreatment runs in its laboratories and
through on-site consultation. The iron phosphate process
operating conditions used for this project are summarized in
Table 8.
Coating Application
An automated powder coating process with manual touchup
was necessary to deliver powder to all surfaces of the parts.
Two banks of four guns each were programmed for automatic
spray, while an organic finishing technician used a hand-held
gun for manual touchup.
Coating Performance Testing
The objectives of coating performance testing were to:
• generate quantitative and qualitative baseline comparison
data on the flowcoat and powder coat primers
• determine the minimum product quality achieved during
each project phase
Laboratory and shop floor testing were performed to
determine the primer to metal and topcoat to primer
performance properties. Tests were performed on 4" x 12"
cold rolled and hot rolled steel coupons and on actual
basement door parts in each of the three major technology
demonstration phases of the project (feasibility, optimization,
and validation).
Commercially obtained cold rolled steel coupons were used
where the heavier gauge of Bilco's hot rolled steel interfered
with the testing requirements. These panels, because of their
increased thickness, could not be used for standard ASTM
impact and flexibility tests. Table 9 summarizes the various
test procedures used for this project. Actual results for the
testing programs conducted during each phase of the project
may be found in the appropriate discussion for the particular
phase.
Waste and Emissions Summary
The following waste and emissions practices are observed for
the pretreatment and powder coating process used for this
study. The Pennsylvania Department of Environmental
Protection (DEP) has determined that all air emissions sources
associated with this facility's powder coating operation,
except the burn-off oven, do not require air operating permits.
The DEP's decision not to require the facility to obtain air
operating permits for these sources was made because the
powder coating operation emits extremely low (de-minimis)
quantities of air contaminants. The quantities of emissions
generated during the various powder coating demonstration
projects are significantly under state reportable amounts
Liquid Wastes
Non-hazardous aqueous wastes are generated as a result of
metal cleaning and phosphating pretreatment operations for
technology demonstration and validation purposes. Projects
involve strictly batch type operations of varying scope. The
facility does not directly discharge liquid pretreatment wastes
to a body of water or to a Publicly Owned Treatment Works
(POTW). Phosphating wastes are placed into totes for on-site
recycle/recovery purposes and returned to the pretreatment
process or are placed into drums and sent off-site to a
permitted wastewater treatment facility.
Water from rinsing stages is fed directly to an atmospheric
evaporator for volume reduction. The non-hazardous sludge
remaining in the evaporator is removed and taken off-site for
disposal periodically by a permitted waste disposal company.
Solid and Hazardous Wastes
The only solid wastes generated by the pretreatment and
powder coating processes are the sludges from the
phosphating pretreatment line and atmospheric evaporator
discussed above and any excess raw powder coating material
that is not recycled. Currently, excess powder coating
material is considered, by the DEP, as residual waste and can
be disposed at a sanitary landfill. There may also be
additional solid wastes generated if pretreatment solutions
become contaminated and need to be replaced.
There are no hazardous wastes associated with the
demonstration facility's pretreatment and powder coating
processes.
Air Emissions
There are air emissions associated with the phosphating
pretreatment system, the pretreatment dry-off oven, the curing
oven and the atmospheric evaporator. However, because the
quantities of these air emissions are very low, the DEP has not
require the facility to obtain air operating permits for these
sources. There is also a burn-off oven associated with the
powder coating operation. This burn-off oven is used
periodically to remove coatings from the conveyor system's
hooks and racks. The DEP has not made a final determination
regarding the need for an air operating permit for this oven.
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Regulatory Profile
This section describes the federal, state and local requirements
that Bilco should be aware of as it considers the merits of the
proposed powder coating operation. The powder coating
operation would include a three step process:
1. substrate pretreatment with an aqueous phosphate process
2. application of the powder coat to the phosphated parts
3. baking and curing.
A changeover to powder coating from flowcoating will
virtually eliminate the use of solvents, and therefore the
production of VOCs, and paint sludge wastes. However, a
powder coating system will generate contaminated
phosphating and rinse waters. The primary regulations
applicable to the phosphating process are the Clean Water Act
and local discharge regulations.
The Clean Water Act (CWA)
Phosphating and rinse waters from Bilco would be considered
an indirect discharge under the Clean Water Act (CWA) if it
discharges waste water from the pretreatment lines of the
proposed powder coat operation to a local publicly owned
treatment works (POTW). As a general rale, facilities that
discharge wastewater to POTWs must pretreat their wastes to
specified levels prior to discharging to a POTW system.
Indirect discharges are not required to obtain a National
Pollutant Discharge Elimination System (NPDES) permit;
however, the POTWs they discharge to are covered by the
NPDES system, POTWs may impose certain discharge
limitations (e.g., local pollutant limits) on facilities to ensure
that the POTW will not violate its NPDES permit. (For
further information about local POTW limits, see Section
entitled Local POTW Requirements.)
As an indirect discharger, Bilco may be subject to the national
industry-wide pretreatment standards for the metal finishing
(MF) industry. These standards, which are also called
national categorical pretreatment standards, contain specific
numeric limitations which are used by POTWs in setting
pretreatment limits. These standards, which can be found at
40 CFR part 433, establish limits for:
• cadmium
• chromium
• copper
• lead
• nickel
• silver
• zinc
• cyanide
• total toxic organics
The pretreatment standards for metal finishers apply to 46
different operations ("covered operations"). If Bilco decides
to install a powder coating line, it may operate one of these 46
covered operations - conversion coating. For Bilco to be
subject to the MF pretreatment standards, it must perform
at least one of the following six covered operations:
1) conversion coating, 2) electroplating, 3) electroless plating,
4) anodizing, 5) chemical etching and milling, and 6) printed
circuit board manufacturing. If Bilco does not perform one of
these six operations it will not be covered under the MF
regulation. If Bilco performs one of these six operations, it
may be subject to the MF regulation for that operation plus
any of the other 40 covered operations present. These other
40 covered operations include electrostatic painting.
Future Considerations
The EPA has proposed standards to regulate a new category
under the CWA called the Metal Products and Machinery
(MP&M) category. Facilities currently covered under 40 CFR
part 433 may be subject to the new MP&M regulation in the
future, if certain criteria are satisfied. The MP&M regulation
is a broader regulation and it may cover Bilco even if Bilco is
not currently covered under the MF regulation.
The MP&M category is intended to regulate wastewater from
facilities that "manufacture, maintain, or rebuild finished
metal parts, products or machines." The regulation will
establish technology-based limits for the discharge of
pollutants into POTWs by new and existing facilities.
The regulation of the MP&M category will be accomplished
in two phases: Phase I and Phase II. Phase I of the MP&M
regulation was proposed on May 30, 1995 (see 60 Fed. Reg.
28209), The second phase of the regulation is not expected to
be proposed by the EPA until December 1997.
Phase 1 of the MP&M category targets seven industrial
sectors, and one of these categories is "hardware." Typical
products produced by the hardware industry are the following:
• fabricated metal products
• fabricated structural metal.
EPA has identified 47 unit operations typically performed by
MP&M facilities. These operations include the following:
• chemical conversion coating
• painting
• metal spraying
• corrosion preventive coating (other than conversion
coating).
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Table 7, Summary of Powder Coating and Topcoating Materials
Vendor
Vendor Product Description
Color
Purpose
Powder Coatings
O'Brien
Morton
PPG
Top Coatings
Sherwin Williams
Sherwin Williams
Sherwin Williams
Sherwin Williams
Aromatic Urethane Polyester
Corvel Zinc Rich Epoxy
Envirocron Polyester
Industrial Alkyd Enamel
VOC Complying
DTM Waterborne Acrylic
High Solids, Low VOC Polyurethane
Mctalatex Acrylic Multiple Surface
Coating
Red Oxide Baseline Powder Coating
Gray Powder - Topcoat
Adhesion Data
Black Powder-Topcoat
Adhesion Data
Gray Baseline Topcoating
Gray Powder - Topcoat
Adhesion Data
Gray Powder - Topcoat
Adhesion Data
Gray Powder-Topcoat
Adhesion Data
Table 8, Iron Phosphate Process Summary
Material
Purpose
Parameter
Setpoint
Phosphating Tank
Parker Amchem
Prep-n-Coat 700
Phosphating
Parker Amchem
Parco Cleaner 3140
Parker Amchem
Caustic Soda
Parker Amchem
Parcolene 6
Cleaning
Additive
pH adjustment
pH adjustment
Tank Capacity
Initial Charge
Subsequent Charges for Demonstration Trials
Total Acid
(6.0 -14.0 titrant points)
pH
Time
Temperature
Nozzle Pressure
Concentration
Desired pH
Desired pH
1,290 gal
70 gal
9-14 gal/day
10.0 points
4,6
60 sec
150°F
10 psi
0.25% by tank
volume
As Needed
As Needed
Rinse Tank
City Water Rinse
Dry Off Oven
Parts Rinsing
Post-Rinse
Water Removal
Tank Capacity
Time
Temperature
Nozzle Pressure
A Side
B Side
Time
Temperature
950 gat
30 sec
110°F
15.5 psi
9.0 psi
6 minutes
275°F
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Table 9. Scope of Coatings Testing for Technology Demonstration Trials2"3,4
Title
Procedure
Application
Units/
of Test
Reference
Rating Scales
coating weight
Parker Amchem
iron phosphate pretreatment
mg tff
coating
visual inspection
N/A
appearance check of
qualitative
phosphate, primer and
topcoat layers
coating thickness
ASTM B499 (magnetic)
dry film thickness of primers
0.001"
ASTM D4138 (tooke gage)
and topcoats
(mils)
tape adhesion
ASTM D3359
adhesion of primers to metal
0-5 scale
(cross-hatch & x-cut)
surface
intercoat adhesion
ASTM D3359
adhesion of topcoat to primer
0-5 scale
layer
salt spray
ASTM B117
corrosion resistance
175 hours
of primers
ASTM 610
degree of rusting
0-10 scale
ASTM 714
degree of blistering
0-10 scale
reverse impact
ASTM D2794
impact resistance
0-160
of primers
in-lbs
direct impact
ASTM D2794
impact resistance
0-160
of primers
in-lbs
conical mandrel bend
ASTM D522
flexibility of primers
1/8" diameter
check for cracking
gloss consistency
ASTM D523
gloss of primers and topcoats
0-100
color consistency
ASTM D2244
color of primers and topcoats
CIE Scale
pencil hardness
ASTM D3363
hardness of coating
6B-8H
(gouge resistance)
softer - harder
(scratch resistance)
Local POTW Requirement
Bilco may be subject to requirements imposed by the New
Haven Water Pollution Control Authority (WPCA), Local
POTW limits are imposed to protect a POTW from discharges
that would inhibit or disrupt the POTW's operation or cause
the POTW to violate its NPDES permit.
Local POTWs may adopt and enforce their own requirements
for industrial facilities that discharge wastewater to the
POTW. The New Haven WPCA recently started its own
prctreatment program. The New Haven WPCA's limitations
are reflected in agreements between the WPCA and its
industrial users.
The New Haven WPCA can be contacted at the following
address:
Attention: Mr. Bill Root
New Haven Water Pollution Control Authority (WPCA)
345 East Shore Parkway
New Haven, CT 06512
Requirements of the New Haven Code
The New Haven Code requires anyone who wishes to connect
and discharge to the New Haven WPCA to apply to the
general manager for a permit authorizing the connection. The
discharge application must be made on forms supplied by the
WPCA. The general manager may require the discharger to:
1. File a discharge report which includes the following
information:
• nature of the process
• volume
• rate of flow
• production quantities.
2. Submit a plan showing the location and size of on-site
sewers, sampling point, pretreatment facilities, and city
sewers.
3. Describe activities, facilities and plant processes
proposing to discharge waste water.
4. name the types of products produced, amounts, and rate
of production.
5. Name the chemical components and quantities of liquid
or gaseous material bulk stored on-site, even though they
may not normally be discharged into New Haven's sewer
system.
14
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Prohibited Discharges
The discharge of the following materials into the city sewer is
prohibited by the New Haven Code:
• any liquid or vapor having a temperature higher than 150
degrees Fahrenheit
• any waste water containing grease, oil or other substances
in excess of 100 mg/1 that will solidify or become
discernibly viscous at temperatures between 32 degrees
and 150 degrees Fahrenheit
• solid or viscous substances capable of causing
obstructions to the flow in sanitary sewers or interference
with the proper operation of the treatment works, such as
metal, shavings, paint residues, and chemical residues.
The New Haven Code also prohibits waste water discharges to
the city sewer containing:
• free or emulsified oil and grease exceeding an average of
100 mg/1 of either or both, or a combination of, free or
emulsified oil and grease, if the waste:
- obstructs the sewer
overloads the grease handling equipment
- cannot be treated
- adversely affects the treatment process.
• acids or alkalies that attack or corrode the sewers or
sewage disposal structures, equipment and/or personnel,
or have a pH value lower than 5.5 or higher than 9.5, or
which may be reduced or changed with age or by sewage
to produce acid or alkaline reactions
• any metallic ions and salts of the heavy metals that
exceed specified concentrations
• excessive discoloration
• unusual biological oxygen demand, chemical oxygen
demand, or chlorine requirements
• unusual concentrations of solids.
Requirements for Wastewater Discharge Permits
Wastewater discharge permits may specify the following:
• allowable average and maximum strengths,
characteristics, or constituents of the waste water
discharge
• limits on the rate and time of discharge or requirements
for flow and equalization
• requirements for the installation of inspection and
sampling facilities
• pretreatment requirements (e.g., Bilco may be required to
adjust the pH of its waste water before discharge.)
• requirements for monitoring programs, such as sampling
locations, frequency and method of sampling, number,
types and standards of tests, and reporting schedules
• requirements for the submission of technical or discharge
reports
• requirements for maintaining plant records on waste
water discharges.
• Bilco must comply with all permit requirements
established by the WPCA.
Other Considerations
The powder coat booth typically does not have an emission
point; therefore, a permit is not required. In addition, the
curing oven for the proposed powder coat operation will emit
volatile organics to the atmosphere. Generally, these
emissions are so low (0-4% by weight) that an air operating
permit will not likely be required. Typically, the VOC content
of the powder used is low or nonexistent. However, some
powders contain listed HAPs which may be regulated.
Feasibility Demonstrations
The primary objective of the feasibility trial was to powder
coat an initial short run of coupons and basement doors to
demonstrate that this technology shows promise for meeting
Bilco's primer performance requirements. Feasibility work
also allowed the project team to accomplish the following:
• establish initial process operating parameters for the
entire powder coating process including iron phosphate
pretreatment, dry off, parts racking, powder application
and powder curing
• establish a product quality baseline for powder coating
primer on Bilco's hot rolled steel substrate
• establish a product quality baseline for flowcoating
primer on hot rolled steel coupons prepared and
submitted by Bilco.
Leading up to the formal feasibility demonstration several
cold rolled and hot rolled steel coupons were pretreated with
iron phosphate for process check and adjustment purposes.
Also, several coupons and basement door parts were
temperature profiled using a Datapaq temperature logging
device to determine the optimum cure oven settings for the
powder coating material.
For the feasibility trial, one complete basement door assembly
(consisting of the 6 individual parts), 20 Bilco hot rolled steel
coupons, and 20 cold rolled steel coupons were iron
phosphated and powder coated with the O'Brien red oxide
powder primer. Following powder coating, several powder
coated door parts and coupons were top coated with the
Sherwin-Williams alkyd enamel material for topcoat
compatibility assessment.
15
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Specimens from each stage of the coating process
(pretreatment, powder coating, and topcoating) were then
tested in the laboratory to determine a quality baseline for the
powder coating process. In addition, coupons of flowcoated
hot rolled steel received from Bilco were tested in the
laboratory to determine a flow coating product quality
baseline. The laboratory data allowed comparison of the two
processes (powder coating to flow coating) according to
Bileo's primer performance criteria.
Pretreatment System and Powder Coating System
Conditions
The iron phosphate pretreatment and powder coating system
conditions used for the feasibility demonstration, arrived at
through material vendor input and project team process
engineering expertise, are shown in Table 10 and Table 11
respectively.
Table 10. Iron Phosphate Pretreatment System Conditions
Parameter Setpoint
Table 11. Powder Coating System Conditions
Parameter Setpoint
Conveyor Speed
Iron Phosphate Cleaner
Coater Stage
Total Acid
PH
Nozzle Pressure
Temperature
Time
Misting Risers Pressure (to
keep parts wet between
stages)
City Water Rinse Stage
Total Acid Carryover
Temperature
Time
Nozzle Pressure
ASide
B Side
pH
Chemical Usage
Prep-n-Coat 700
Parco Cleaner 3140
Caustic Soda Neutralizer
Dry Off Oven
Time
Temperature
Iron Phosphate Coating
Weight Achieved
4.8 ft/min
10.0 titration points
4.6
10 psi
145°F
1 min
Riser 1 - 7.0 gals/min
Riser 2 -4.5 gals/min
< 0.5 titration points
110°F
1 min
15.5 psi
9.0 psi
6.0
70 gals initial charge
36 gals additional needed to
maintain conditions through
preliminary setup trials
3.5 gals (0.27% total tank volume)
1 gal
6 minutes
275°F
Conveyor Speed
12 ft/min
Automatic Spray Gun
Configuration
No. of Spray Guns
4 per side
Stroke Speed
14 cycles per 30 seconds
Kilovolts
100 kV/gun
Fluidizing Air
14 psi
Atomizing Air
20 psi
Manual Touchup
not used for feasibility
Cure Oven (Optimized
from Datapaq Trials)
Time
27 min
Temperature
425°F
76 mg/ft2
Feasibility Laboratory Testing Results
Primer to Metal Performance Data
Laboratory testing was performed for the powder coated and
flowcoated primer specimens and for topcoated specimens of
each primer according to Bileo's primer performance
requirements. The most obvious performance difference in
the primer to metal performance data for the two primers is
significantly better corrosion resistance for the powder coated
specimens. Gloss, impact resistance and dry film thickness
values are the only other significant differences in primer to
metal performance for the two primers materials. The test
data results performed on 4" x 12" coupons for the primered
and topcoated specimens are summarized in Table 12.
Primer to Topcoat Performance Data
The Bilco topcoat compatibility performance requirement was
assessed through the use of a semi-quantitative scribe and tape
pull intercoat adhesion test. An !x-cut scribe is made through
the topcoat just down to the primer coat layer. Tape is
uniformly applied to the x-cut and then rapidly removed at a
180° backward angle. The specimen is then visually inspected
for loss of coating along the x-cut scribed area, which is also
measured in fractions of an inch from the scribe, and in the
regions between the lines of the scribe. The flowcoated
primer provided an adequate surface for adhesion of the
topcoat by exhibiting no loss of coating using this test method.
Some of the powder primed specimens completely failed the
test exhibiting a loss of coating on the scribe and in between
the lines of the x-cut scribed region. After additional testing,
successful combinations of powder primers and liquid
topcoats were identified.
Feasibility Demonstration Major Lessons Learned
The following lessons learned were obtained from the
feasibility work efforts:
a two stage iron phosphate pretreatment can be
successfully applied to Bileo's specific base material
16
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• powder coating can be successfully applied to Bilco's
parts, however some manual touchup is required
• based on laboratory testing, powder coating materials can
meet Bilco's primer to metal performance criteria
• all basement door parts are able to be racked successfully
using the existing holes punched into the products which
was a concern to the small business participant.
Sufficient success was achieved during feasibility testing to
warrant proceeding to optimization trials which not only focus
on product performance, but also on additional process
engineering and life-cycle cost issues. Additional powder
coating and topcoating materials were investigated for data
completeness.
Optimization Demonstrations
The powder coating technology optimization trial primarily
focused on refinement and tailoring of the powder coating
systems for Bilco's basement door parts based on lessons
learned from the feasibility demonstration. The optimization
trial also aided refinement of operating data collection
practices such as material and energy usage and served as a
preparation run for the technology validation phase. The
following processes were changed or optimized from the
feasibility trial based on process engineering observations and
expertise:
• iron phosphating pretreatment
• parts racking
• powder coating application.
The optimization trial consisted of using the O'Brien red
oxide material to powder coat two carriers of cold rolled and
hot rolled steel 4" x 12" coupons for lab quality testing and
two complete basement door assemblies (12 total
components). One complete powder coated door assembly
and several coupons were then coated with the alkyd enamel
topcoat. The following sections summarize the activities and
results from the optimization trial.
17
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Table 12. Feasibility Testing Results for the Primer Only and Primer / Topcoat Specimens
Test or
Evaluation
Flowcoated Primer Only Coupon
Baseline Data
Powder Coated Primer Only Coupon Baseline Data
Visual Appearance *
Smoothness
smooth, except in areas of substrate defects
smooth except in areas of substrate defects
some orange peel effect
Coverage
complete coverage on coupons
complete coverage on coupons
areas requiring manual touchup observed on basement door parts
Color
no significant numerical differences among
specimens determined by spectrophotometer
no significant numerical differences among specimens determined
by spectrophotometer
no noticeable differences
to the naked eye
no noticeable differences
to the naked eye
Gloss
3.6 at 60°
39.9 at 60°
Coating Thickness
0.5 mils average
1.6 mils average
Corrosion
Resistance *
Salt Spray -175
Hours
ASTM D610 Rusting
0-1 (50-100% rusted area)
8-9 (< 0.10% rusted area)
ASTM D714
Blistering
6(1% affected area)
8 (< 0.10% affected area)
Physical Properties
Pencil Hardness
(Scratch Toughness)
2H
2H
Pencil Hardness
(Gouge Toughness)
>8H
>8H
Direct impact
passes to 44 in/lbs
passes > 160 in/lbs
Reverse Impact
passes to 100 in/lbs
passes > 160 in/lbs
Conical Mandrel
pass 1/8" bend
pass 1/8" bend
Tape Adhesion (X-
cut)
5 - no failure
5 - no failure
Tape Adhesion
(Cross-cut)
5 - no failure
5 - no failure
Flowcoated Primer with
Alkyd Enamel Topcoat Coupon Baseline
Data
Powder Coat Primer with
Alkyd Enamel Topcoat
Coupon Baseline Data
Visual Appearance
smooth, even coverage
smooth, even coverage
uniform color and gloss
uniform color and gloss
~Denotes specific Bileo Performance Requirement.
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Pretreatnient System and Powder Coating System
Conditions
This section describes the changes or refinements to the
powder coating process for the optimization trial.
Racking Considerations
To ensure clearance of the largest of the Bilco basement door
components through the pretreatnient system and to properly
adjust the positions of the automatic powder guns, several of
the basement door parts were run through the entire powder
coating line while it was off-lined. Measurements were taken
to provide for the proper racking distance between the tops of
the parts to the conveyor system. For the powder coating
system used, a minimum carrier to part distance of about 19.5
inches was required.
Any seams or places where oils or other contamination from
the steel manufacturing or door fabrication process could
become trapped had to be oriented vertically so that the
contaminants would drain thoroughly from the parts in the
cleaner / coater pretreatment step. Retention of oils would
prevent proper adhesion of the powder coating in these places.
This was particularly critical for one area along a seam on the
larger triangular side panels where two strips of metal overlap.
It was also necessary to devise "S" shaped hooks to rack the
parts, and in some cases to add bolts to existing holes in some
of the parts to attach the hooks. This racking approach was
necessary to avoid drilling additional holes in the parts solely
for racking purposes which would not be used in the final
assembly of the door systems.
Iron Phosphating Pretreatment Considerations
The time of exposure in the pretreatment cleaner/coater
phosphating stage had to be increased to allow for better
cleaning of the hot rolled steel parts based on the visual
appearance of the parts exiting the washer stage. This was
accomplished by decreasing the conveyor speed through the
washer system from 4.8 ft/min to about 4 ft/min. Parts
remained in the phosphating stage approximately 75 seconds
instead of 60 seconds as used for the feasibility trial. Iron
phosphate coating weight, determined from a weigh-acid
strip-weigh procedure, averaged 75 mg/ft2 which compared
favorably to the feasibility trials (76 mg/ft2).
Due to the multi-purpose configuration of the
test/demonstration powder coating line as opposed to one
which would be built for a single manufacturing purpose, a
carrier delay of three minutes between each rack of parts had
to be utilized. This delay prevented the parts from remaining
in the phosphating stage too long while carriers just ahead
were being held for 6 minutes in the dry off oven. In an
actual manufacturing setting, the system design would not
require such a carrier delay. Approximately 13 gallons of
fresh Prep-n-Coat 700 chemical was required to recharge the
phosphating stage from the feasibility trial. All other
pretreatment process conditions, such as temperatures,
concentrations and pressures were kept the same as for the
feasibility trial shown in Table 10.
Powder Coating Considerations
Several changes were made in the powder coating application
process. The most significant change was the addition of a
manual touchup step, with other adjustments consisting of
changes to the spray gun settings. It was determined from the
feasibility trial that the dry film coating thickness could be
adjusted downward slightly from 1.6 mils and not
significantly impact the coating to metal performance while
offering powder raw material savings during automatic spray.
To accomplish the thickness reduction, the tluidizing air on
each of the automatic spray guns was decreased from 14 psi to
13 psi. The atomizing air also had to be decreased, from 20
psi to 16 psi, to avoid blowing the powder back off the parts
before curing. Similar considerations of gun settings would
be required in the actual implementation of powder
technology for the basement door parts.
A manual spray gun was configured to apply powder to the
basement door parts just after automatic application to
touchup any inadequately covered zones. These were
primarily at bends in the metal or where handles, rods and
latches had been welded to the main panels. To achieve
proper manual delivery of the powder, the fluidizing air was
set higher than for the automatic guns, to 24 psi, to ensure
delivery of enough powder through a single gun, while the
atomizing air was set lower than the automatic process, to 12
psi, to avoid blowing the powder back off of the parts.
Optimization Trial Laboratory Testing Results
Laboratory testing was performed on the powder coated and
topcoated coupons to quantify the effects of process changes
on coating performance. The results are summarized in Table
13. The most significant difference in the data from the
feasibility trial was a decrease in the to failure in the salt spray
test. The degree of rusting value fell from a rating of 8-9 to a
rating of 6, with 10 being the highest quality. Most likely, the
lower film thickness or perhaps slightly more porosity of the
powder coating contributed to this change. This would still be
significantly higher than the value of 1 for the degree of
rusting for the flowcoat primer reported in the feasibility trial
discussion, The degree of blistering remained constant from
the feasibility to the optimization trial.
The only other notable exception in the data was an increase
in the intercoat adhesion quality due to the application of a
short forced cure bake cycle of the topcoat onto the primer.
This raised the intercoat adhesion value from a 0 first week
rating from the feasibility trial to a 3-4 initial rating.
19
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However, forced curing in this manner would not be an option
for field application of topcoats in most cases. Forced curing
was performed just to determine the best intercoat adhesion
possible with this powder primer/topcoat combination. (See
Table 14).
Table 13. Optimization Testing Results for the Powder Primer
and Primer/Topcoat Specimens
Test or Evaluation Powder Coated Primer
Coupon Test Data
Visual Appearance *
Smoothness
smooth except in areas of substrate
defects
Coverage
some orange peel effect
complete coverage on coupons
Color
no significant numerical differences
among specimens determined by
spectrophotometer
no noticeable differences
to the naked eye
Coating Thickness
1.3 mils average
Gloss
32.5 at 60°
Corrosion Resistance
Salt Spray -175 Hours
ASTWI D610 Rusting
6 (1.00% rusted area)
ASTM D714 Blistering
8 (< 0.10% affected area)
Physical Properties
Pencil Hardness
4H
(Scratch Toughness)
Pencil Hardness
>8H
(Gouge Toughness)
Direct Impact
passes 140 in/lbs
Reverse Impact
passes >160 in/lbs
Conical Mandrel
pass 1/8" bend
Tape Adhesion (X-cut)
5 - no failure
Tape Adhesion (Cross-
5 - no failure
cut)
Powder Coat Primer with Alkyd
Enamel Topcoat Coupon Data
Visual Appearance
smooth, even coverage
uniform color and gloss
Intercoat Tape
3-4 - trace loss of coating 1/16" or
Adhesion
less from scribe after forced curing
(X-cut scribe)
* Denotes specific Bilco Performance Requirement.
Supplemental Powder Coat/Topcoat Compatibility Trial
Several additional primer/topcoat compatibility trials were
performed using commercially available materials to gather
intercoat adhesion data. This data is intended to supplement
the experimental data from initial topcoat compatibility testing
and provide data using other powder coatings. Primer/topcoat
compatibility was determined through the intercoat adhesion
test described earlier and by visual appearance. The topcoat
materials used and the powder coatings with the compatibility
data obtained are summarized in Table 14.
The data shows that the Hi-Solids Polyurethane topcoat
performed best with all three powder materials in terms of
intercoat adhesion and appearance. The only other coating
that had acceptable intercoat adhesion was the DTM Acrylic-
topcoat with the O'Brien powder coat.
A positive result is the finding of at least one topcoat that is
compatible with powder primers and has good appearance.
The data, at a minimum, shows the potential to find other
topcoat / powder coat combinations that would work together
successfully.
Optimization Demonstration Major Results
The optimization trial provided the opportunity to achieve
enhanced parts cleaning and racking, and a demonstration that
manual touchup would cover bare or thin areas after automatic
spray application. Furthermore, these changes resulted in
little effect, other than salt spray results, to the final product
quality test data.
Validation Trials
A technology validation trial was conducted to simulate a
production environment for powder coating the Bilco
basement door parts. The trial focused on proving out the
system settings and lessons learned from the previous trials,
and to allow the collection of "live" material and utility data
for operation cost estimation purposes.
Parts Processing
One "production" day was simulated consisting of a morning
(AM) and afternoon (PM) powder coating shift. During each
shift the line was loaded to capacity, consisting of 18 parts
carriers. Either one large part, such as a rectangular door
panel or triangular side panel, or two smaller parts were
loaded per carrier.
Table 16 is an inventory of the parts and square footage
processed during the "AM" and "PM" shifts. Bilco
manufactures four standard sizes of basement doors which are
given the designations O, 0. C and S/L. Just under a total of
six complete basement door systems were powder coated
during the simulated production day.
Process Operating Conditions
The complete process cycle consisted of a part passing
through the iron phosphate washer system, the dry off oven,
the powder coating booth and the powder curing oven. Table
17 summarizes the critical iron phosphate and powder coating
process parameters for the "AM" and "PM" shifts. All
pretreatment system values were within the target ranges.
20
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Table 14. Supplemental Intercoat Adhesion Data for Topcoats and Powder Coats
Topcoat Topcoat Topcoat
Sherwin-Williams
Sherwin-Williams
Sherwin-Williams
Direct to Metal
Hi-Solids
Metalatex
(DTM)
Polyuretfiane
Semi-Gloss
Semi-Gloss Acrylic
(2 component)
Major
• Water
Base Paint
• Water
Liquid
~ Ethylene Glycol
• Mineral Spirits
• 2-(2-Butoxyethoxy)-Ethanol
Components
• 2-{2-Methoxyethoxy)-
~ Xylenes
* Ethylene Glycol
Ethanol
• Trimethylbertzenes
• 2-{2-Butoxyethoxy)-
• Methyl Isobutyl Ketone
Ethanol
» Methyl n-Amyl Ketone
Part 2
• n-Butyl Acetate
* Hexamethylene Diisocyanate
Polymer
• Hexamethylene Diisocyanate
VOC Content
1.5-1.9
2.3-2.5 Base
1.1-1.8
(lbs/gallon)
2.7 Part 2
Powder Coating
Visual Intercoat
Visual intercoat
Visual Intercoat
Appearance Adhesion
Appearance Adhesion
Appearance Adhesion
O'Brien Red Oxide
Poor. 5
Good 5
Fair 0
Runs, Sags
Zinc-Rich Gray
Poor, 0
Good 5
Fair 0
Runs, Sags
PPG Black
Poor, 0
Good 3
Fair 0
Runs, Sags
established from the feasibility and optimization trials. The
amount of iron phosphate coating weight, which indicates the
buildup of phosphate film on the steel surface was fairly
consistent with the results from previous trials.
Material, Utility and Labor Usage
Actual material and utility usage information was collected for
the validation trial. The material data consisted of monitoring
pretreatrnent chemical and raw powder coating usage. Water
is also used in the pretreatrnent process, however, actual usage
data for the day of the trial was not available. The utility data
which was tracked consisted of the natural gas and electricity
consumption. Table 15 summarizes the material and utility
data for the production trial. The data for utilities and powder
coating are reported for the whole day, and are not broken
down by shift.
Labor was required to activate and program the complete
coating system process through the electronic user interface,
to supervise the coating operations, to load parts onto the
conveyor, to prepare and titrate the pretreatrnent washer
system phosphating stage, to apply powder coating using
manual touchup, and to unload the finished parts. For this
work a process engineer, a pretreatrnent system operator, a
painting technician and a material handler were required for a
total of four personnel.
Laboratory Results
Powder Coat Primer to Metal Performance Data
Coupon specimens and basement door parts from the "AM"
and "PM" shifts were analyzed for powder coating to metal
performance. The same tests as for the feasibility and
optimization trials were performed to ensure consistency with
the previous trials and to determine process quality
consistency during production conditions. No additional
topcoating was performed for the validation trial as the
feasibility and optimization trials generated the required
topcoat to powder primer testing data. Table 18 summarizes
the results of this testing. The data reported is taken from the
analysis of the actual powder coated basement door parts
unless otherwise noted as being from coupon specimens.
Each door part was also tested for coating thickness in
multiple locations and for visual appearance. The thickness
data is treated in a separate discussion.
21
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The lab testing in general shows good agreement with
previous trials and good shift to shift repeatability. One
difference from the feasibility and optimization trials is that
the coupon coating thickness is slightly higher. The visual
inspections of the actual basement door parts also showed that
some of the edges and subassemblies such as hooks and
handles appeared to have a thinner layer of coating. The
corrosion resistance, however, is equal to or better than all
previous trials. (See Table IB)
Table 15. Validation Trial Material arid Utility Usage Summary
Material AM Shift PM Shift
Prep-n-Coat 700
9 gallons
13 gallons
Phosphating Recharge
Sodium Hydroxide
1/8 gallon
1/18 gallon
Neutralizer
Total Day's
Usage
Powder Coating
55 pounds
Utilities
Electricity (kW-hrs)
Washer & Dry Off Oven
375
Conveyor
11
Powder Booth
169
Powder Cure Oven
79
Natural Gas (SCF)
9,523
Water
not monitored
Basement Door Parts Thickness Profile Data
Each of the 20 AM shift and 14 PM shift basement door parts
powder coated during the validation trial was checked for
coating thickness at several points per part to determine the
thickness profile and the degree of consistency for all the parts
processed. Figures 5 and 6 show the average front side and
back side thickness values directly on drawings of the various
part types at the locations evaluated. The thickness values
shown are averages for that particular location point from all
of the parts of the same type (shape) processed during the
validation trial.
A majority of the data points fall in the 1.1 mil to 2.9 mil
thickness range. This includes 24 of the 25 front surface
locations and 21 of the 28 back, or underside surface
locations. The highest degree of consistency is found on the
larger continuous surface areas. Several locations on the parts
have an average thickness of over 3.0 mils. Higher coating
buildup is observed on one backside edge of the header (3.4 to
6.5 mils), one backside edge of the door panel (4.3 to 5.1
mils), and at the front and back side middle data point on the
footer. These regions were consistently higher for these
locations on all parts processed.
Several powder coating application factors, which may
explain the spread in the thickness profile data, include:
• surface temperature differences
• differences in electrostatic effects on and around the parts
• differences which occur during manual touchup.
Locations which cool more slowly than other points on the
part after exiting the 275°F pretreatment dry off oven step will
be hotter and thus may attract a greater film build.
Differences in electrostatic potential at various locations on
the parts can cause uneven coating on the initial pass of
powder and for the attraction of any overspray, particularly at
the edges of parts. And finally, even the most carefully
applied manual touchup will result in some thickness
variability. Electrostatics and manual touchup are the primary
factors contributing to the thickness variation. Since the hot
rolled steel base metal for all the parts is the same thickness
and composition, very little difference in cooling rates and
surface temperature should exist.
Each of these factors potentially can be optimized to tighten
the range of thickness for the parts, depending upon the
degree of control required. The primary consideration would
be to achieve a total thickness and profile uniformity which
meet product quality and cost goals.
Major Results Summary From Validation Testing
The following major results occurred through validation
testing:
• basement door parts were powder coated in a simulated
production environment
• final process engineering improvements were successfully
implemented
• collection of "real-time" material and utility usage and cost
data collected
• consistent shift to shift product quality was demonstrated.
COST ANALYSIS
Through material and energy comparisons, powder coating
offers a distinct advantage over liquid systems by the
elimination or significant reduction of VOC emissions and
hazardous wastes. The future operation of liquid finishing
systems could be impacted by the potential increases in the
costs associated with disposal of hazardous wastes and control
of VOC and HAP emissions. Because of the difficulty in
predicting these increases, economic evaluations were
performed to estimate the feasibility of powder coating based
on current costs and production rates.
The cost analysis was performed on the two primary
alternatives identified by Bilco, These alternatives are:
• continuing with the current flow coating system with the
addition of a new VOC control system, and
» powder coating.
22
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Figure 5. Average Thickness (Mils) Profile on Front Surface
Figure 6. Average Thickness (Mils) Profile on Back Side Surfaces
23
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Table 16. Validation Trial Inventory of Parts for AM and PM Shifts
AM SHIFT
PM SHIFT
Part
Part
Square
Part
Part
Square
No,
Description
Footage
No.
Description
Footage
1
0 Door Panel
20 9
1
B Door Panel
21.6
2
0 Header
4.6
2
C Footer
2.0
3
O Door Panel
18.9
3
B Door Panel
22.6
4
B Footer
1.9
4
C Header
5.5
5
C Footer
2.0
5
C Door Panel
27.3
6
0 Side Panel
19,5
6
C Footer
2.0
7
S/L Footer
1.9
7
C Door Panel
25.8
8
0 Footer
1.7
8
C Header
5.5
9
B Door Panel
22,6
9
C Door Panel
27,3
10
C Header
5.5
10
C Door Panel
25,8
11
B Door Panel
21.8
11
C Side Panel
17.2
12
S/L Side Panel
23.6
12
C Side Panel
17.2
13
B Side Panel
17.1
13
C Side Panel
17.2
14
B Side Panel
17.1
14
C Side Panel
17.2
15
B Header
5.1
15
16 QC Coupons
10.6
16
C Door Panel
27,3
17
B Header
5.1
18
S/L Footer
1.9
19
C Door Panel
25.8
20
S/L Side Panel
23,8
21
16 QC Coupons
10,8
Table 17. Validation Trial Process Operating Conditions Summary
Parameter AM Shift PM Shift
Total Processing Time (min)
108
113
Total ft2 Processed
278.4
245,1
Iron Phosphate
Pretreatment System
Total Acid (ml points)
10.2
10.2
pH
4.62
4.63
Pressure (psi)
10
10
Temperature (°F)
146
145
Conveyor Speed (ft/mln)
4
4
Phosphating Time (sec)
75
75
Coating Weight (mg/ft2)
51
57
Dry Off Oven
Time (min)
6
6
Temperature (°F)
275
275
Powder Coating
Application System
Conveyor Speed (ft/rain)
12
12
No. Automatic Guns
8
8
Powder Electrostatics (kV)
100
100
Fluidizing Air (psi)
13
13
Atomizing Air (psi)
16
16
No. Manual Touchup Guns
1
1
Powder Electrostatics (kV)
80
80
Fluidizing Air (psi)
24
24
Atomizing Air (psi)
12
12
24
-------
Table 18. Validation Testing Results for the Primer and Primer I Topcoat Specimens
Test or Evaluation
Powder Coated
Primer Test Data
AM Shift
Powder Coated
Primer Test Data
PM Shift
Visual Appearance *
Smoothness
smooth except in areas of steel substrate
defects
smooth except in areas of stee! substrate
defects
no fisheyes, craters, inclusions or other
powder related defects
no fisheyes, craters, inclusions or other
powder related defects
Coverage
some orange peel effect
complete powder coverage
some orange peel effect
complete powder coverage
some occurrences of visually thinner
areas on latch and hook subassemblies
some occurrences of visually thinner
areas on latch and hook subassemblies
Color
some thinning on bottom edges
no significant numerical differences
among specimens determined by
spectrophotometer
some thinning on bottom edges
no significant numerical differences
among specimens determined by
spectrophotometer
Gloss (60°)
Coating Thickness**
(coupon testing)
no noticeable differences
to the naked eye
40.7
1.62 mils
no noticeable differences
to the naked eye
40.9
1.84 mils
Corrosion Resistance *
Salt Spray -175 Hours
ASTM D610 Rusting
ASTM D714 Blistering
10 (no rust)
10 (no blistering)
9-10 (no rust to < 0.03% affected area)
8 (few blisters, < 1/32" dia.)
Physical Properties
Pencil Hardness
(Scratch Toughness)
Pencil Hardness
(Gouge Toughness)
Direct Impact
Reverse Impact
Conical Mandrel
Tape Adhesion (X-cut)
Tape Adhesion (Cross-cut)
2H
8H
passes > 160 in/lbs
passes > 160 in/lbs
pass 1/8" bend
5 - no failure
5 - no failure
2H
8H
passes >150 in/lbs
passes >160 in/lbs
pass 1/8" bend
5 - no failure
5 - no failure
{" denotes specific Bilco performance requirement)
(** thickness data for actual basement door specimens shown on Figures 5 and 6)
The alternatives were evaluated using the National Institute of
Standards and Technology (NIST) "Building Life-Cycle Cost"
(BLCC) Program. BLCC provides economic analysis of
proposed capital investments that are expected to reduce long-
term operating costs. While BLCC was designed for the
evaluation of alternative buildings and building-related
projects, BLCC can also be applied to almost any project
investment which is primarily intended to reduce future
operating-related costs. BLCC calculations comply with:
• The American Society for Testing and Materials (ASTM)
• Criteria outlined in the DOD memorandum of agreement
"Criteria/Standards for Economic Analysis/Life-Cycle
Costing for MILCON Design", March 18, 1991
• OMB Circular A-94 Revised, "Guidelines and Discount
Rates for Cost Analysis of Federal Programs," October
19, 1992.
Life-Cycle Cost (LCC) analysis is used as a decision-making
tool for choosing among alternatives, based on their long-term
economic performance, rather than on their initial costs. LCC
is a technique of economic evaluation which sums, over a
given study period, the costs of initial investment and
operating costs. In this case, a study period of 15 years was
25
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used. The results from the BLCC program are presented in a
comparison of current year costs of the alternatives.
The estimated total capital costs for the alternatives are based
on the approximate purchased equipment costs and are
summarized in Table 19. The equipment cost for the VOC
control system was obtained from Bilco, and the powder costs
were obtained from vendors.
Table 19. Total Capital Cost
Item
Spray System
with VOC
Control
Powder Coat
System
Purchased Equipment
380,000
1,293,046
Installation & Start-Up
95,000
120,000
Total Capital Cost
475,000
1,413,046
Operating costs used in the LCC comparisons were limited to
raw materials, waste management, and utilities. Powder costs
were estimated using the Powder Coating Institute's Finisher's
Handbook5, Powder material costs were estimated based on
the current production rate and an estimated powder cost of
$2.50/pound from the powder vendor. Powder coat and liquid
usage was estimated by using a 1.0 mil film thickness, which
is an industry standard for estimating material usage and
coverage. Costs for VOC control were estimated using the
EPA Handbook6 for estimating supplementary fuel and
electricity requirements. Annual operating costs are shown in
Table 20.
Table 20. Operating Cost Summary
Process
Raw
Waste
Total
Materials
Management
Utilities
Operating
$/year
$/year
$/year
Cost
S/year
Current +
89,911
2,750
218,500
311,161
VOC
Control
Powder
132,500
500
35,895
168,895
The Life Cycle Cost for each alternative is shown in Table 21.
Table 21. Life Cycle Cost Comparison
Process Initial Cost Life-Cycle Cost
$ $
Current + VOC 475,000 3,138,377
Control
Powder 1,413,046 2,854,420
Based on this analysis, simple payback occurs in year 7 after
investment. This period is longer than that obtained when
replacing a conventional liquid spray system with powder
because of flowcoating's high transfer efficiency and resultant
low cost per part. One of the main benefits of powder coating
is that material can be recycled and reused, and this is already
occurring with the flowcoating system.
As mentioned earlier, escalating costs for hazardous waste
disposal must be taken into account when considering the
current coating system. Since these costs are so difficult to
predict, they were not included in the analysis, but should be
considered when evaluating the alternatives.
In addition, no attempt was made to place a value on the
increased part performance realized through the use of
powder. Through a significant increase in hardness and
corrosion resistance, Bilco could potentially offer an extended
warrantee on its products. As a result, this creates the
potential to increase product price.
At current manufacturing rates of over 50,000 doors per year,
this could mean an increase in revenue from sales of over
$50,000 for a $ 1 per door price increase. With a $2 per door
price increase, leading to over $100,000 in additional revenue,
Bilco could dramatically increase the rate of return on its
initial powder coat equipment investment.
Environmental Analysis
Regulatory Comparisons
The powder coating process can offer several advantages over
the traditional flow coating operation. Typically, the powder
coat process eliminates or significantly reduces the VOC
emissions and hazardous waste generated as a result of
traditional painting methods. The VOC content of the powder
used in the powder coat process is usually low. Typically, the
powder paint is considered to be a non-hazardous waste, and
waste generation can be reduced by recycling the powder.
Although there are several advantages to the powder coat
process, the waste water from the pretreatment line of the
powder coat operation may subject Bilco to applicable CWA
requirements and to local control by the New Haven WPCA.
Presumably, the powder coat operation would involve the
discharge of pretreatment rinse waters to the New Haven
WPCA. This practice would subject Bilco to the WPCA's
limitations and to all applicable requirements of the New
Haven Code, which may include prohibitions on certain
discharges, pretreatment requirements, and requirements for a
waste water discharge permit.
Air emissions requirements are getting more stringent, and
while they may not significantly impact Bilco's current
26
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operation, they may restrict Bilco's ability to increase
production in the future if increased production would also
result in an increase in air emissions. Although the switch to a
powder coating line with a pretreatment process that generates
waste water would subject Bilco to regulation under the
CWA, the powder coat system nevertheless can offer several
advantages in that it reduces or virtually eliminates the
generation of VOCs and hazardous waste that would occur
using traditional painting methods.
Quality Analysis Summary
The Bilco Company's basement door primer performance
criteria, shown in Table 22, serves as the basis for determining
the suitability of powders to replace liquid coatings. Bilco's
requirements basically fall into primer to metal or primer to
topcoat performance categories. Flowcoated and powder
coated specimens were tested to determine adherence to both
performance categories.
Table 22. Bilco Basement Door Primer Specifications
Primer to Metal
Requirements
175 hours ASTM B117 salt
spray
Resist rust to a rating of 10
according to ASTM D610
No blisters according to ASTM
D714
Smooth finish when applied to
hot rolled steel weldments
Complete coverage, no bare
spots, drips or sags
Red oxide color preferable
0.7 to 1.1 mils thickness
Primer to Topcoat
Requirements
Topcoating Compatible with a finish coat of
alkyd enamel applied in the field
after installation
Alternative topcoats acceptable
as long as these have equal
field performance and customer
appeal
Primer to Metal Performance Category
The primer to metal performance of powder coating
technology was determined to be equivalent or superior to the
liquid primer presently in use for most of the evaluations
where direct comparison is logical. The baseline powder
coating material demonstrated significantly better resistance to
corrosion for degree of rusting and degree of blistering and
better resistance to delamination upon direct and reverse
impact. The baseline powder coating material was equivalent
to the liquid primer for pencil hardness (gouge and scratch
resistance), flexibility (mandrel bending), and tape adhesion.
The cured film thickness of the powder coating was higher
than the flowcoated primer. However, due to the inherent
differences in liquid and powder application technologies and
among various coating products in general, the powder
thickness' achieved in this project are not necessarily relevant
or logical for direct comparison. Product performance,
material usage, waste generation, total cost and coating system
capabilities are the key factors for determining optimum film
thickness. The powder coating thickness was demonstrated
during the optimization trials to have the ability to be adjusted
downward while maintaining suitable overall primer to metal
performance.
The final set of evaluations in the primer to metal
performance category involved appearance ratings. The
baseline powder coating was red in color, as per Bilco's
requirements, and was consistent from specimen to specimen
qualitatively and quantitatively as were the flowcoated
baseline specimens. All of the flowcoating and the powder
coating specimens were smooth in appearance with the
exception of some characteristic orange peel effect exhibited
by the powder coating. The baseline powder material also had
a much higher gloss, which may or may not be desired, but
which can be changed with a suitable powder coating material
change to a flatter finish. A change to a flat finish might also
enhance the topcoat performance data, discussed below in the
next section, since certain components which impart increased
gloss may also inhibit the adhesion of certain topcoats.
Primer to Topcoat Performance
A topcoat material was found which would adhere to the
baseline powder material with equivalent intercoat adhesion
performance as for the flowcoated primer with the preferred
alkyd enamel topcoat.
Additional Process Quality Considerations
The flowcoating process requires few quality checks other
than visual appearance and cured film thickness checks.
However, a switch to powder coating would introduce at least
one other series of process quality checks. The iron phosphate
pretreatment system, at a minimum, would require control of
the phosphating chemical concentration via an acid-base
titration, and possibly periodic gravimetric determinations of
iron phosphate coating weight. Bilco also would have to work
with their pretreatment chemical supplier to optimize the
pretreatment process initially and to obtain periodic advice for
maintaining peak.
Corrosion
Resistance
Appearance
and Thickness
27
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CONCLUSIONS
New environmental regulations are placing more stringent
restrictions on how manufacturers can coat parts. Powder
coating is an environmental technology with the potential for
reducing VOC emissions to zero. CTC, through the
performance of the EPA Powder Coat Applications Task has
demonstrated that powder coatings offer a viable solution to
small business manufacturers for coating parts. First, powder
coat materials have demonstrated the ability to meet and
exceed current liquid coating performance.
Second, powder coatings offer small businesses a way to
significantly reduce coating costs by reducing air exhaust and
air make-up requirements, reducing wasted paint material
through recycling, and avoiding costs such as the installation
and maintenance of VOC destruction systems.
Finally, powder coatings offer small businesses a way to
reduce VOC emissions. By virtually eliminating VOC
emissions from the coating process, manufacturers may avoid
the cost of installation and maintenance of VOC destruction
systems.
28
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REFERENCES
1. Compilation of Air Pollutant Emission Factors, 5th
Edition, January 1995, U.S. EPA, Vol. 1. AP-42 (GPO-
055-000-005-001).
2. Annual Books of ASTM Standards, Volume 6.01, Paint-
Tests for Chemical, Physical, and Optical Properties
Appearance. Copyright 1995 American Society for
Testing and Materials, Philadelphia, PA. ASTM 1916
Race Street, Philadelphia, PA 19103-1187, U.S.A.,
Publication Code Number (PCN): 01-060195-14.
3. Annual Books of ASTM Standards, Volume 6.02, Paint -
Products and Applications; Protective Coatings; Pipeline
Coatings. Copyright 1995 American Society for Testing
and Materials, Philadelphia, PA. ASTM 1916 Race
Street, Philadelphia, PA 19103-1187, U.S.A., PCN: 01-
060295-14.
4. Annual Books of ASTM Standards, Volume 2.05, Metallic
and Inorganic Coatings, Metal Powders, Sintered P/M
Structural Parts. Copyright 1993 American Society for
Testing and Materials, Philadelphia, PA. ASTM 1916
Race Street, Philadelphia, PA 19103-1187, U.S.A. PCN:
01-020593-05.
5. Powder Coating, The Complete Finisher's Handbook,
Alexandria, VA, Powder Coating Institute, First Edition,
1994; 351-360.
6. EPA Handbook; Control Technologies for Hazardous
Air Pollutants, Chapter 4, Design & Cost of HAP Control
Technologies, Section 4.2, Thermal Incineration, p, 4-1-4-
10, U.S. EPA-625/6-86-014 (NTIS PB91-228809), 1986.
29
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APPENDIX A
Facility Baseline Survey Questionnaire
30
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OPERATING DATA
SITE: PROCESS:
SITE POC AND PHONE NO.: (
ADDITIONAL POC(S) AND NO.(S): ... (_
( ).
(Please attach additional information as required.)
PROCESS FLOW DIAGRAM:
• Label all process units
• Identify and label input and output streams (Note where outputs go)
• Identify direction of flow
• Note previous operations/processes (Where do parts come from?)
• Note subsequent operations/processes (Where do parts go?)
Explanatory Notes:
31
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OPERATING DATA
PROCESS DESCRIPTION:
1. How long has current process operated?
2. What past process changes have been made to enhance pollution prevention efforts?
(Equipment changes, material changes, operational changes, other.)
3. Assuming continued use for the existing process technology, what future pollution
prevention upgrades would be required? (Equipment changes, material changes,
operational changes, etc.)
4, Is the current process batch or continuous?
5. Estimate or provide actual data for identified representative ("typical") parts that are
processed; Name(s) of Representative Parts, End Item (what do parts belong to), and
Quantities processed;
PART NAME
END ITEM
ANNUAL QUANTITY
QUANTITY PER SHIFT
or HOUR
6. Provide data to characterize the identified parts, as applicable:
PART NAME
TYPICAL SIZE(S), WEIGHT(S), SHAPE(S), SUBSTRATE(S)
32
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OPERATING DATA
1. Please list any raw materials (substrates, pretreatment and coatings) inspections (visual, chemical,
instrumental, destructive, nondestructive, other) performed or required and the quantitative or
qualitative target results for these checks.
Raw Material
Check Performed
Quality/Quantity
Range or Result
2, Please list the critical automated or manual process control checks (on materials an equipment)
performed during a production run to control or monitor process conditions such as chemical
analyses, equipment settings, etc.
In-Process Material/Equipment
Check Performed
Quality/Quantity Target Control
Result or Range
3. Please list any in-service or field quality or performance requirements for the finished product.
ii
2.
%
4,
4. Please list any quality inspections performed on the manufactured parts and the target result or range
for product quality.
Type of Quality Cheek
on Products
Quality/Quantity Target
Result or Range
33
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OPERATING DATA
5. Please list typical number of parts re-worked or rejected during a production run and the attributable
cause(s).
Type of Problem
Number
Re-worked
or
Rejected
Attributable Cause(s)
6. Please list the total number of parts manufactured and the total number sampled for quality checks for
a normal production run or period.
1. Number of parts manufactured:
2. Number of parts sampled for quality inspection:
7. Please list the quality checks, if any, performed by your material or equipment suppliers on a regular
basis for your facility.
1.
2.
3.
4.
8. Please list any types of field or in-service problems with your product that have been encountered.
Parts Type
Nature of Problem |
1
34
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OPERATING DATA
PROCESS EQUIPMENT:
1. identify overall process footprint.
2. Identify major process equipment size(s) and/or capacity(s) (tanks, booths, motors, blowers,
etc.), as applicable.
ITEM
SIZE/CAPACITY
3. What are minimum and maximum part size envelopes?
Minimum:
Maximum:
4. Are there any maximum weight restrictions? If so, identify:
5. List all utilities used by the process:
6. List any additional utilities, available to the process:
7. List any recent or anticipated equipment modifications, and denote if they are being
made to improve production, quality, poliution prevention, other:
35
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OPERATING DATA
INPUT STREAMS:
List input streams from process flow diagram and Estimate quantities where possible: such as
amount used/day, week, or year. Annual quantities are preferred. Please attach MSDS sheets
for significant input materials.
Also, for annual quantities, provide the baseline year.
STREAM NAME
QUANTITY/UNITS
OUTPUT STREAMS:
List output streams from process flow diagram and Estimate quantities where possible: quantity
discharged/day, week, year; quantity disposed/day, week, or year; etc. Annua! quantities are
preferred. Provide % compositions or waste profiles if known, as well as hazardous waste codes
(D001, D003, etc.).
Also, for annual quantities, provide the baseline year.
STREAM NAME
QUANTITY/UNITS
36
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OPERATING DATA
OPERATIONS:
For the entire production process, identify operating days, shifts, # of operators, etc.
ITEM
QUANTITY/UNITS
OPERATING DAYS
days/week
days/year
# OF SHIFTS
shifts/day
OPERATING HOURS
hours/shift
OPERATORS
#/shift
OPERATOR HOURS
hours/shift
SUPERVISOR HOURS
hours/shift
SCHEDULED MAINTENANCE
days/year
MAINTENANCE HOURS
hours/week
hours/year
REGULATORY COMPLIANCE:
1. Identify regulations that affect the process, If applicable;
2. Identify any permit(s) for the process, ifapplicable:
3, Identify the significant requirements of the permit(s), if applicable;
37
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OPERATING DATA
4. Identify for each waste stream or for the entire process, as applicable, what if any of the
following activities are performed, by whom (company personnel, outside contractor, etc.),
how often (1/mo., 1/yr., etc.), and number of hours associated to each task.
Manifesting:
Reporting:
Monitoring:
Testing:
Labeling:
Permitting:
Training (facility wide related to this manufacturing process, also internal & external training):
38
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OPERATING DATA
WASTE MANAGEMENT:
1. For each waste stream, identify which of the following waste management categories apply,
arid whether or not they are performed on or off-site, as applicable:
Pre-Treatment: , ,
On-Site Storage:
T reatment:
Hauling:
Insurance:
Disposal:
Recycling:
39
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OPERATING DATA
HEALTH AND SAFETY:
1. identify any physical hazards associated with the current process:
2. Identify any chemical hazards associated with the current process:
3. List any personal protection equipment necessary to operate the process:
4. List any safety training that is required for the operators} and frequency:
40
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COST DATA
MATERIAL & MAINTENANCE COSTS:
Identify costs for all materials identified as Input Streams on the process flow diagram, for all recycled
materials, and for all significant maintenance items.
ITEM
COST/UNIT
LABOR COSTS:
Identify cost of all manufacturing process direct labor.
ITEM
COST/UNIT
OPERATOR(S)
SUPERVISION
MAINTENANCE
UTILITIES:
Identify cost of utilities used by the process, such as gas, electricity and water, and any additional utilities
that are available to the process.
ITEM
COST/UNIT
41
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COST DATA
REGULATORY COMPLIANCE:
Quantify regulatory compliance costs for waste stream(s) or for the entire process, where possible, for
activities identified previously.
ITEM
WASTE STREAM/ PROCESS
COST/UNIT
MANIFESTING
REPORTING
MONITORING
TESTING
LABELING
PERMITTING
TRAINING
42
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COST DATA
WASTE MANAGEMENT:
Quantify waste management costs, where possible and applicable, for identified waste streams.
ITEM
WASTE STREAM
COST/UNIT
PRE-TREATMENT
ON-SITE HANDLING
STORAGE
TREATMENT
HAULING
INSURANCE (include all
process related insurance
costs)
DISPOSAL
RECYCLING
43
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COST DATA
HEALTH AND SAFETY:
Identify costs associated to personal protection equipment, safety monitoring, and safety training for the
process.
ITEM
COST/UNIT
Explanatory Notes:
FUTURE LIABILITY:
For the following items, identify any recent/known fines, penalties, injury, or damage associated to the
process. Identify any potential costs in the future, where possible. What risks/ramifications are
associated the operation of the process while in and/or out of compliance?
ITEM
COST/UNIT
FINES/PENALTIES
PERSONAL INJURY
PROPERTY DAMAGE
ENVIRONMENTAL DAMAGE
Explanatory Notes:
44
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COST DATA
CAPITAL COSTS:
Quantify any of the previously identified capital equipment expenditures.
ITEM
COST
REVENUES and FINAL COSTS
Revenues: Total Sales of Product;
Revenues: Revenues per Unit
Revenues: Marketable By-Products
Your Calculated Cost To Coat Per Unit
and to Coat Per Square Foot
Any Other Cost/Revenue Figures Used
45
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APPENDIX B
Material Safety Data Sheets for Bilco Primer and Solvent Thinner
46
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MATERIAL SAFETY DATA SHEET
EXXON CHEMICAL AMERICAS, P.O. BOX 3378, HOUSTON, TEXAS 77081
A Division of EXXON CHEMICAL COMPANY, A Division of EXXON CORPORATION
PAGE:
1
AROMATIC 100 SOLVENT
DATE PREPARED;
JUNE 3, 1992
NO:
92940652
SECTION 1: PRODUCT IDENTIFICATION & EMERGENCY INFORMATION
PRODUCT NAME: AROMATIC 100 Solvent
CHEMICAL NAME: Aromatic Hydrocarbon
CHEMICAL FAMILY: Petroleum Hydrocarbon
PRODUCT DESCRIPTION: Clear colorless liquid.
CAS 64742-95-6
EMERGENCY TELEPHONE NUMBERS:
CHEMTREC:
713-870-6000
800-424-9300
SECTION 2: HAZARDOUS INGREDIENT INFORMATION
The composition of this mixture may be proprietary information. In the event of a medical
emergency, compositional information will be provided to a physician or nurse. This product is
hazardous as defined in 29 CFR1918.1200, based on the following compositional information;
COMPONENT OSHA HAZARD
Petroleum Hydrocarbons Combustible
Trimethylbenzene OSHA PEL; ACGIN TLV
Zylene OSHA PEL; ACGIN TLY
Cumene OSHA PEL; ACGIN TLV
Ethylbenzene OSHA PEL; ACGIN TLV
For additional information see Section 3.
SECTION 3; HEALTH INFORMATION & PROTECTION
NATURE OF HAZARD
EYE CONTACT:
Slightly irritating but does not injure eye tissue.
SKIN CONTACT:
Frequent or prolonged contact may irritate and cause dermatitis.
Low order of toxicity.
Skin contact may aggravate an existing dermatitis condition.
47
-------
AROMATIC 100 SOLVENT
PAGE:
2
DATE PREPARED:
JUNE 3, 1992
NO;
92940652
INHALATION:
High vapor/aerosol concentration (greater than approximately 1000 ppm) are irritating
to the eyes and the respiratory tract, may cause headaches, dizziness, anesthesia,
drowsiness, unconsciousness, and other central nervous system afftects, including
death.
INGESTION:
Small amounts of this product aspirated into the respiratory system during ingestion or
vomiting may cause mild to severy pulmonary injury, possibly progressing to death.
Minimal toxicity.
FIRST AID
EYE CONTACT:
Flush eyes with large amounts of water until irritation subsides. If irritation persists,
get medical attention.
SKIN CONTACT:
Flush with large amounts of water; use soap if available.
Remove grossly contaminated clothing, including shoes, and launder before reuse.
INHALATION:
Using proper respiratory protection, immediately remove the affected victim from
exposure. Administer artificial respiration if breathing is stopped. Keep at rest. Call
for prompt medical attention.
INGESTION:
If swallowed, DO NOT induce vomiting. Keep at rest. Get prompt medical attention.
ACUTE TOXICITY DATA IS AVAILABLE UPON REQUEST.
WORKPLACE EXPOSURE LIMITS
OSHA REGULATION 29CFR1910.1000 REQUIRES THE FOLLOWING PERMISSIBLE EXPOSURE
LIMITS:
A TWA of 25 ppm (125 mg/m3) for Trimethyl Benzene.
A TWA of 100 ppm (435 mg/m3) and a STEL of 150 ppm (655 mg/m3) for Xylene.
A TWA of 50 ppm (246 mg/m3) for Cumene (skin).
A TWA of 100 ppm (435 mg/m3), and a STEL of 125 ppm (545 mg/m3) for Ethyl
Benzene.
THE ACGIII RECOMMENDS THE FOLLOWING THRESHOLD LIMIT VALUES:
A TWA of 25 ppm (123 mg/m3) for Trimethyl Benzene.
A TWA of 100 ppm (434 mg/m3), and a STEL of 150 ppm (651 mg/m3) for Xylene.
A TWA of 50 ppm (246 mg/m3) for Cumene (skin).
A TWA of lOOppm (434 mg/m3) and a STEL of 125 ppm (543 mg/mj) for Ethyl Benz.
48
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AROMATIC 100 SOLVENT
PAGE:
3
DATE PREPARED:
JUNE 3, 1992
NO:
92940652
EXXON RECOMMENDS THE FOLLOWING OCCUPATIONAL EXPOSURE LIMITS:
50 ppm total hydrocarbon based on composition.
PRECAUTIONS
SPECIAL PRECAUTION:
Health studies have shown that many petroleum hydrocarbons pose potential human
health risks which may vary from person to person. As a precaution, exposure to
liquids, vapors, mists or fumes should be minimized.
PERSONAL PROTECTION:
For open systems where contact is likely, wear safety glasses with side shields, long
sleeves, and chemical resistant gloves.
Where contact may occur, wear safety glasses with side shields.
Where concentrations in air may exceed the limits given in this section and
engineering, work practice or other means of exposure reduction are not adequate,
NIOSH/NSMA approved respirators may be necessary to prevent overexposure by
inhalation.
VENTILATION:
The use of local exhaust ventilation is recommended to control process emissions near
the source. Laboratory samples should be stored and handled in a lab hood. Provide
mechanical ventilation of confined spaces.
See respiratory protection recommendations.
SECTION 4: FIRE & EXPLOSION HAZARD
FLASHPOINT: 106 Deg. F, METHOD: TCC NOTE: Minimum
FLAMMABLE LIMITS: LEL: 1.9 WEL: 12.6 77 °F. Note: Approximate
A UTOIGNITION TEMPERATURE: 880 °F. Note: Approximate
GENERAL HAZARD:
Combustible Liquid, can form combustible mixtures at temperatures at or above the
flashpoint.
Static Discharge, material can accumulate static charges which can cause an incendiary
electrical discharge.
"Empty" containers retain product residue (liquid and/or vapor) and can be dangerous,
DO NOT PRESSURIZE, CUT, WELD, BRAZE, SOLDER, DRILL, GRIND, OR
EXPOSE SUCH CONTAINERS TO HEAT, FLAME, SPARKS, STATIC
ELECTRICITY, OR OTHER SOURCES OF IGNITION; THEY MAY EXPLODE
AND CAUSE INJURY OR DEATH.
Empty drums should be completely drained, properly bunged and promptly returned to
a drum reconditioner, or properly disposed of.
49
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AROMATIC 100 SOLVENT
PAGE:
4
DATE PREPARED:
JUNE 3, 1992
NO:
92940652
tjrpc PTnTJTTTSjn-
rlivD JrXvIirl 1 UN vJ.
Use water spray to cool fire exposed surfaces and to protect personnel.
Isolate "fuel" supply from fire.
Use foam, dry chemical, or water spray to extinguish fire.
Avoid spraying water directly into storage containers due to danger of boilover.
This liquid is volatile and gives off invisible vapors. Either the liquid or vapor may
settle in low areas or travel some distance along the ground or surface to ignition
sources where they may ignite or explode.
HAZARDOUS COMBUSTION PRODUCTS: No Unusual
SECTION 5: SPILL CONTROL PROCEDURE
LAND SPILL:
Eliminate sources of ignition. Prevent additional discharge of material, if possible to
do so without hazard. For small spills implement cleanup procedures; for large spills
implement cleanup procedures and, if in public area, keep public away and advise
authorities. Also, if this product is subject to CERCLA reporting (see Section 7)
notify the National Response Center.
Prevent liquid from entering sewers, watercourses, or low areas. Contain spilled liquid
with sand or earth. Do not use combustible materials such as sawdust.
Recover by pumping (use an explosion proof or hand pump) or with a suitable
absorbent.
Consult an expert on disposal of recovered material and ensure conformity to local
disposal regulations.
WATER SPILL:
Remove from surface by skimming or with suitable adsorbents. If allowed by local
authorities and environmental agencies, sinking and/or suitable dispersants may be
used in non-confined waters. Consult an expert on disposal of recovered material
and ensure conformity to local disposal regulations.
SECTION 6: NOTES
HAZARD RATING SYSTEMS:
This information is for people trained in: National Paint & Coatings Association's
(NPCA) Hazardous Materials Identification System (NMIS)
National Fire Protection Association (NFPA 704)
Identification of the Fire Hazards of Materials KEY
HEALTH
FLAMMABILITY
REACTIVITY
NPCA-NMIS
1
2
0
NFPA 704
1
2
0
4 = Severe
3 = Serious
2 = Moderate
1 = Slight; 0 = Min.
50
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AROMATIC 100 SOLVENT
PAGE:
5
DATE PREPARED:
JUNE 3,1992
NO:
92940652
SECTION 7: REGULATORY INFORMATION
DEPARTMENT OF TRANSPORTATION (DOT):
DOT PROPER SHIPPING NAME:
Petroleum Kaphtha, Combustible Liquid Uk 1255
DOT HAZARD CLASS: Combustible Liquid
DOT IDENTIFICATION NUMBER: UK 1255 NAME: Kaphtha, petroleum
FLASHPOINT: 106 °F, METHOD: TCC, NOTE: Minimum
TSCA:
This product is listed on the TSCA Inventory as a UVCS (Unknown, Variable
Composition or Biological) Chemical at CAS Registry Number 64742-95-6
CERCLA:
This product, as sold, is derived from a fraction of crude oil and is excluded from the
spill reporting requirements by CERCLA Section 101(14)(F). When this product is
used in a mixture or as an ingredient in another product or in a manufacturing
operation, the petroleum exclusion may terminate and an accidental spill may require
reporting to the National Response Center at 556-424-3302.
This product contains approximately 3% of Xylene.
The reportable quantity of Zylene is 1,000 pounds.
This product contains approximately 2% of Cumene.
The reportable quantity of Cumene is 5,000 pounds.
This product contains approximately 1% of Ethylbenzene.
The reportable quantity of Ethylbenzene is 1,000 pounds.
SARA TITLE III:
Under the provisions of Title III, Sections 311/312 of the Superfund Amendments and
Reauthorization Act, this product is classified into the following hazard categories:
Delayed Health, Fire.
This product contains the following Section 313 Reportable ingredients:
COMPONENT
1,2,4-Trimethylbenzene
Zylene
Cumene
Ethylbenzene
CAS NO.
95-63-6
1330-20-7
98-82-8
100-41-4
MAXIMUM %
32.0
3.0
1.5
0.5
SECTION 8: TYPICAL PHYSICAL & CHEMICAL PROPERTIES
SPECIFIC GRAVITY: 0.87 AT 50
Density: 7.3 lbs/gal at 59
VAPOR PRESSURE, mmHg at °F:
11 @ 100 Approx.; 4 @ 68 Approx.
51
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AROMATIC 100 SOLVENT
PAGE:
6
DATE PREPARED:
JUNE 3,1992
NO:
92940652
SOLUBILITY IN WATER, Wt.%, °F:
0.02 at 77 Calculated.
VISCOSITY OF LIQUID, CST AT °F:
1 at 77 Approximate
SP. GRAV. OF VAPOR, at 1 atm (Air=l)
20
FREEZING/MELTING POINT, °F:
-76
EVAPORATION RATE,
(n-Bu Acetate =1) 0.3 Approximate
BOILING POINT, °F:
318 TO 338
SECTION 9; REACTIVITY DATA
STABILITY:
Stable
HAZARDOUS POLYMERIZATION:
Will not occur
CONDITIONS TO AVOID INSTABILITY:
Not applicable
MATERIALS AND CONDITIONS TO AVOID INCOMPATIBILITY;
Nitric acid, sulfuric acid, strong oxidizing agents.
HAZARDOUS DECOMPOSITION PRODUCTS:
None
SECTION 10: STORAGE AND HANDLING
ELECTROSTATIC ACCUMULATION HAZARD:
Yes, use proper grounding procedure.
STORAGE TEMPERATURE, °F:
Ambient
LOADING/UNLOADING TEMP., °F:
Ambient
STORAGE/TRANSPORT PRESSURE:
Atmospheric
Vise. AT LOADING/UNLOADING TEMP.,
cST:
REVISION SUMMARY:
Since May 8,1992 this MSDS has been revised in Section 7
REFERENCE NUMBER:
WDMA-C-25028
DATE PREPARED: SUPERSEDES ISSUE DATE:
June 3, 1992 May 8,1992
FOR ADDITIONAL PRODUCT INFORMATION, CONTACT YOUR TECHNICAL SALES
REPRESENTATIVE
FOR ADDITIONAL HEALTH/SAFETY INFORMATION, CALL 713-670-6884
52
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MATERIAL SAFETY DATA SHEET
For Chemicals, Coatings, and Related Materials
In Compliance with OS HA 29 CFR 1910.1200
RED OXIDE BAKE PRIMER
PAGE:
1
DATE PREPARED;
FEB. 16,1995
NO:
41U 318
SECTION 1: PRODUCT
PRODUCT NAME: RED OXIDE BAKE PRIMER
CLASS: MODIFIED ALKYD BAKE ENAMEL
NUMBER: 41U-318
HMIS HAZARD CODES
Health: 2 MODERATE
Flammabiiity: 2 MODERATE
Reactivity: 0 MINIMAL
Personal Protective Equipment: G
SECTION 2; HAZARDOUS INGREDIENTS
Ingredient
Mat'l.
Description
% By
Weight
C.A.S.
Registry
No.
PEL
OSHA
TLV
ACGIH
UNIT
Ethylamine
0.09
121-44-8
15.0
10.0
PPM
Alkylolammonium
Salt Sol'n.
0.99
MIXTURE
50.0
50.0
PPM
Petroleum
Hydrocarbon
6.32
64742-95-6
50.0
PPM
1,2,4-Trimethyl-
benzene
0.99
95-63-6
25.0
25.0
PPM
Medium Aliphatic
Petroleum Sol'n.
28.98
64742-88-7
100.0
100.0
PPM
Naphthalene
0.14
91-20-3
10.0
10.0
PPM
Cobalt
0.03
7440-48-4
0.1
MG/M3
Manganese
Compound
0.04
7439-96-5
5.0
1.0
MG/M3
SECTION 3: PHYSICAL DATA
Boiling range: 193.1 - 413,0 °F
Freezing Range: -174.50 °F
Vapor Pressure: 0.0 mm @ 20 °C
Vapor Density: LIGHTER
Specific Gravity: 1.29
H2O Soluble: Negligible <0.1%
Evaporation Rate: SLOWER (relative to n-butyl acetate)
% Volatile by Volume:
60.45
Density:
10.773 lbs/gal
VOC:
3.99
APPEARANCE AND ODOR: RED LIQUID, SOLVENT ODOR
53
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RED OXIDE BAKE PRIMER
PAGE:
2
DATE PREPARED:
FEB. 16,1995
NO:
41U-318
SECTION 4: FIRE AND EXPLOSION HAZARD DATA
FlashPoint; 110.0 °F
(Method Used) SETAFLASH
Explosive Limits: LEL UEL (% in air)
1.0 12.6
FLAMMABILITY CLASSIFICATION:
OSHA: COMBUSTIBLE LIQUID - CLASS II
DOT: COMBUSTIBLE LIQUID
EXTINGUISHING MEDIA:
Use water fog, foam, dry chemical, or carbon dioxide.
SPECIAL FIRE FIGHTING PROCEDURES:
WARNING,, .FLAMMABLE
Do not enter fire space without full bunker gear.
Cool fire exposed containers with water.
UNUSUAL FIRE AND EXPLOSION HAZARDS:
Vapors may travel considerable distances by air and become ignited by ignition
sources.
Material creates a special hazard because it floats on water.
Dangerous when exposed to heat, sparks, flame or oxidants.
Handle in properly bonded and grounded equipment.
Vapors may form explosive mixtures in the air.
SECTION 5: HEALTH HAZARD DATA
Ingredient
Material Description
Carcinogenicity
Listing
OSHA NTP IARC
LD50 (mg/kg)
(rat).»(rbt)
ORAL: DERMAL
Triethylamine
N/A
N/A .
N/A
Alkylolammonium Salt
Solution
N/A
N/A
N/A
250.00
Petroleum Hydrocarbon
NO
NO
NO
1,2,4-T rimethylbenzene
NO
NO
NO
Medium Aliphatic
Petroleum Solvent
N/A
N/A
N/A
Naphthalene
NO
NO
NO
Manganese Compound
N/A
N/A
N/A
54
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RED OXIDE BAKE PRIMER
PAGE:
3
DATE PREPARED:
FEB. 16,1995
NO:
41U-318
SECTION 6: HEALTH HAZARD INFORMATION
EFFECTS OF OVEREXPOSURE
INHALATION:
Chronic exposure may cause liver and kidney damage.
May cause dizziness, anesthesia, drowsiness or unconsciousness.
Vapors may irritate nose, throat, and respiratory tract.
Pre-existing respiratory disorders may be aggravated.
Excessive inhalation causes headache, dizziness, & nausea.
Aspiration may cause pulmonary edema & chemical Pneumoniti.
May cause injury to bone marrow, blood cells, kidney & liver.
May produce central nervous system depression.
Aspiration into lungs may occur during vomiting which may result in lung injury.
Vapor may cause Trachaitis, Bronchitis, & Pulmonary edema.
Results have associated repeated, intentional exposure with permanent brain and
nervous system damage.
Vapors may be harmful or fatal.
INGESTION:
Chronic exposure may cause liver and kidney damage.
May cause headaches, dizziness, anesthesia, and drowsiness.
Fatigue.
Vomiting.
May cause irritation to the gastrointestinal tract.
Aspiration may cause pulmonary edema and chemical pneumoniti.
Moderately irritating.
May produce central nervous system depression.
Moderately toxic and may be harmful if swallowed.
Burns to mouth, throat, and stomach.
Possible liver and kidney damage,
EYES:
Pre-existing eye disorders may be aggravated.
Moderately irritating.
Corneal injury may be severe.
Unpleasant deposits in eyes,
SKIN:
Repeated contact may cause skin irritation and dermatitus.
Pre-existing skin disorders may be aggravated.
55
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RED OXIDE BAKE PRIMER
PAGE:
4
DATE PREPARED:
FEB. 16, 1995
NO:
41U 318
SKIN: (eon't)
Prolonged skin contact may result in the absorption of harmful amounts of material.
EMERGENCY AND FIRST AID PROCEDURES
EYES:
Flush eyes with large amounts of water for 15 minutes.
See a physician.
Seek medical attention immediately.
SKIN:
Wash exposed skin with soap and water.
See a physician.
INHALATION:
Remove to fresh air.
Preform artificial respiration if breathing has stopped.
See a physician.
Seek medical attention immediately.
INGESTION:
Do not induce vomiting.
Have conscious patient drink several glasses of water.
Seek medical attention immediately.
See a physician.
SECTION 7: REACTIVITY DATA
STABILITY:
Yes
POLYMERIZATION:
No
STABILITY CONDITIONS TO
AVOID:
Avoid heat, flame, fire, and sparks.
Under normal conditions, this material is
stable.
POLYMERIZATION CONDITIONS TO
AVOID:
Hazardous Polymerization will not occur.
INCOMPATIBILITY:
Strong Oxidixing Agents
Heat or Flame Permanganates
Nitric Acid Sulfuric Acid
Alkali Metals Sodium Hydroxide
Aldehydes Mineral Acids
HAZARDOUS DECOMPOSITION
PRODUCTS:
Oxides of Carbon and Nitrogen
Carbon Monoxide
Toxic Vapors
Phosphoric Oxide
56
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RED OXIDE BAKE PRIMER
PAGE:
5
DATE PREPARED:
FEB. 16,1995
NO:
41U-318
SECTION 8: SPILL OR LEAK PROCEDURES
STEPS FOR MATERIAL SPILLAGE:
Remove all ignition sources.
Ventilate the area.
Wear appropriate respirator and other protective clothing.
Contain large spills with dikes.
Pump to storage tanks if possible.
Absorb with an inert material.
Place in non-leaking container for disposal.
Flush area with water to remove trace residue.
Keep product out of sewers and watercourses.
Do not use Combustible Materials such as Sawdust.
Use foam to control vapors.
Toxic to fish.
Handling equipment must be grounded to prevent sparking,
WASTE DISPOSAL METHODS:
Landfill in accordance with Local, State, & Federal regulations.
Must be treated as a hazardous ignitable waste.
SECTION 9: SPECIAL PROTECTION INFORMATION:
RESPIRATORY PROTECTION:
Self contained breathing apparatus
VENTILATION:
Exhaust at point of use
Explosion proof ventilation
PROTECTIVE GLOVES:
Gloves impervious to solvents
EYE PROTECTION:
Splashproof safety goggles
OTHER PROTECTIVE EQUIPMENT:
Eyewash station
Emergency shower
Use chemical resistant apron
Wear impervious clothing & boots for prolonged exposure
SECTION 10: SPECIAL PRECAUTIONS
REGULATORY DATA:
UN/NA Number: UN 1263
Hazard Class: COMBUSTIBLE LIQUID Shipping Name: PAINT
CERCLA Reportable Quantity: See Section 11
57
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RED OXIDE BAKE PRIMER
PAGE:
6
DATE PREPARED:
FEB. 16, 1995
NO:
41U-318
HANDLING AND STORAGE PRECAUTIONS:
Overheating may cause container to rupture.
Use explosion-proof equipment.
Keep containers closed when not in use.
Do not store near high heat or ignition.
Wash thoroughly after handling.
OTHER PRECAUTIONS:
Avoid prolonged breathing or contact with skin or eyes.
Do not cut, puncture, or weld near container.
Should be grounded or bonded to reduce static electricity.
Sudden release of hot organic chemical vapors or mists from process equipment
operating at elevated temperatures or pressure or sudden ingress of air into vacuum
equipment may result in ignition without the presence of obvious ignition sources.
Empty drums retain hazardous product residue.
Use non-sparking tools.
SECTION 11: SARA SECTION 313 TOXIC CHEMICALS
Chemical
CAS Number
Weight %
Rep. Qty.
Acute
Hazard
Chron.
A1 kylolammonium
Salt Sol n.
MIXTURE
0.99
X
X
X
1,2,4-Trimethyl-
benzene
95-63-6
0.99
X
X
Naphthalene
91-20-3
0.14
X
X
Cobalt
7440-48-4
0.03
X
X
SARA TITLE III COMPLIANCE:
This product contains the above toxic chemicals subject to the reporting requirements
of SARA TITLE III EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-
KNOW act of 1986 and 40 CFR 372.
DISCLAIMER
Every effort has been made to ensure that the safety information on this sheet is accurate, but
because CHEMCOAT, INC. has no control over the condition under which the product will be
used, liability is limited exclusively to replacement or refundof the purchased price of this
product. Except as stated herein, there are no EXPRESSOR IMPLIED WARRANTIES
INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY OR FINESS FOR A
PARTICULAR PURPOSE. CHEMCOAT, INC. assumes no liability for injury or incidental
or consequential damages arising out of the storage and handling or use of this product.
58
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