potential alternatives report md-a-1-1 for alternatives to...

Engineering and Technical Servicesfor Joint Group on AcquisitionPollution Prevention (JG-APP) PilotProjects

Potential Alternatives ReportMD-A-1-1

For Alternatives toChromate-Containing Primersfor Aircraft Exterior Mold LineSkins

May 1, 1998

Contract No. DAAA21-93-C-0046Task No. N.072CDRL No. A004

Prepared byNational Defense Center for Environmental Excellence (NDCEE)

Operated by Concurrent Technologies Corporation

Engineering and Technical Servicesfor Joint Group on Acquisition Pollution

Prevention (JG-APP) Pilot Projects

Potential Alternatives ReportMD-A-1-1

For Alternatives toChromate-Containing Primers

for Aircraft Exterior Mold Line Skins

DRAFT

May 1, 1998

Distribution Statement “A” applies.Approved for public release; distribution is unlimited.

Contract No. DAAA21-93-C-0046Task No. N.072CDRL No. A004

Prepared by:National Defense Center for Environmental Excellence (NDCEE)

Operated by: Concurrent Technologies Corporation (CTC)1450 Scalp Avenue

Johnstown, PA 15904

Potential Alternatives Report i

TABLE OF CONTENTS

Page

PREFACE ...................................................................................................................................... iv

EXECUTIVE SUMMARY............................................................................................................. v

1. INTRODUCTION............................................................................................................... 1

2. BASELINE PROCESS ....................................................................................................... 42.1. Baseline Process Equipment and Material and Energy Usage ................................ 52.2. Baseline Wastes and Emissions .............................................................................. 62.3. Baseline Environmental, Safety, and Occupational Health (ESOH) Status............ 7

2.3.1. Environmental Issues .................................................................................. 82.3.2. Safety and Occupational Health Issues ..................................................... 10

2.4. Baseline Capital and Operating Costs ................................................................... 13

3. IDENTIFIED ALTERNATIVES AND PRELIMINARY SCREENING......................... 153.1. Alternative Technology Selection ......................................................................... 153.2. Product Identification............................................................................................ 16

4. PROCESS DESCRIPTIONS FOR VIABLE ALTERNATIVES ..................................... 184.1. High-Solids Primers .............................................................................................. 18

4.1.1. High-Solids Primer–Alternative Process Equipment................................ 194.1.2. High-Solids Primer–Anticipated Material and Energy Usage .................. 194.1.3. High-Solids Primer–Anticipated Wastes and Emissions .......................... 214.1.4. High-Solids Primer–Anticipated Capital and Operating Costs................. 214.1.5. High-Solids Primer–Estimated Return-on-Investment ............................. 24

4.2. Waterborne Conventionally Applied Primers ....................................................... 244.2.1. Waterborne Primer Alternative Process Equipment and AnticipatedMaterial and Energy Usage ................................................................................... 254.2.2. Waterborne Primer–Anticipated Wastes and Emissions........................... 264.2.3. Waterborne Primer–Anticipated Capital and Operating Costs ................. 274.2.4. Waterborne Primer–Estimated Return-on-Investment.............................. 29

4.3. Electrocoating........................................................................................................ 304.3.1. Electrocoating Alternative Process Equipment......................................... 314.3.2. Electrocoating Anticipated Material and Energy Usage ........................... 324.3.3. Electrocoating Anticipated–Wastes and Emissions .................................. 334.3.4. Electrocoating–Anticipated Capital and Operating Costs......................... 344.3.5. Electrocoating–Estimated Return-on-Investment ..................................... 37

4.4. Sustainment (DoD Depot Community) Implications of Replacing ChromatePrimers .................................................................................................................. 374.4.1. Cost Avoidance Implications for Replacing Chromate Primers with

Nonchromate Primers................................................................................ 38

ii Potential Alternatives Report

4.4.2. Cost Avoidance Implications for Eliminating Chromium from AircraftExteriors .................................................................................................... 38

5. PRELIMINARY ESOH ANALYSIS OF VIABLE ALTERNATIVES ........................... 39

6. SELECTION OF POTENTIAL ALTERNATIVES.......................................................... 41

7. SUMMARY ......................................................................................................................42

LIST OF FIGURES

Page

Figure 1. Primer Spray Application Flow Diagram ....................................................................... 4Figure 2. High-Solids Primer Spray Application Flow Diagram ................................................. 19Figure 3. Waterborne Primer Spray Application Flow Diagram.................................................. 25Figure 4. Primer Application by Electrocoating Flow Diagram .................................................. 30

LIST OF TABLES

Table 1. Target HazMat Summary .............................................................................................. 3Table 2. Currently Used Chromate Primers ................................................................................ 5Table 3. Baseline Material and Energy Usage............................................................................. 6Table 4. Baseline Wastes and Emissions Summary.................................................................... 7Table 5. Toxicity Ratings for Currently Used Products ............................................................ 10Table 6. Exposure Ratings for Currently Used Products .......................................................... 11Table 7. Summary of Safety, Health, and Environmental Analysis of Currently Used Chromate

Primers ........................................................................................................................12Table 8. Capital and Annual Operating Cost Estimates for Currently Used Chromate Primer

Application.................................................................................................................. 14Table 9. Properties of Candidate Primer Types......................................................................... 16Table 10. Viable Alternatives to Chromate-Containing Primers for Aircraft Exterior Mold Line

Skins............................................................................................................................ 17Table 11. Material and Energy Usage of High-Solids Nonchromate Primers for Aircraft Exterior

Mold Line Skins .......................................................................................................... 20Table 12. Estimated Wastes and Emissions for High-Solids Primer Spray Application to

Aircraft Exterior Mold Line Skins .............................................................................. 21Table 13. Capital and Annual Operating Cost Estimates for High-Solids Nonchromate Primer

Application.................................................................................................................. 23Table 14. Material and Energy Usage of Waterborne Primers for Aircraft Exterior Mold Line

Skins............................................................................................................................ 26Table 15. Estimated Wastes and Emissions for Waterborne Primer Spray Application to Aircraft

Exterior Mold Line Skins............................................................................................ 27

Potential Alternatives Report iii

Table 16. Capital and Annual Operating Cost for Waterborne Nonchromate PrimerApplication.................................................................................................................. 28

Table 17. Material and Energy Usage of Electrocoat Primer for Aircraft Exterior Mold LineSkins............................................................................................................................ 33

Table 18. Estimated Wastes and Emissions for Electrocoat Primer Application to AircraftExterior Mold Line Skins............................................................................................ 34

Table 19. Capital and Annual Operating Cost for Electrocoat Nonchromate Primer Application35Table 20. Summary Results for Nonchromate Primer Environmental, Safety, and Occupational

Health Analysis........................................................................................................... 40Table 21. Nonchromate Primers Selected for Screening Tests................................................... 41

LIST O F APPENDICES

Appendix A. Environmental, Safety, and Occupational Health (ESOH) Analysis of CurrentlyUsed Chromate Primers

Appendix B. Technology Survey to Identify Candidate Alternative Technologies to ChromatePrimers

Appendix C. Product IdentificationAppendix D. Preliminary ESOH Analysis of Viable Alternative Nonchromate PrimersAppendix E. References

Products and companies mentioned here may be the trademarks of their respective owners.

iv Potential Alternatives Report

PREFACE

This report was prepared by Concurrent Technologies Corporation (CTC) through the NationalDefense Center for Environmental Excellence (NDCEE) under Contract Number DAAA21-93-C-0046. This report was prepared on behalf of, and under guidance provided by, the Joint Groupon Acquisition Pollution Prevention (JG-APP) through the Joint Pollution Prevention AdvisoryBoard (JPPAB). The structure, format, and depth of technical content of the report weredetermined by the JPPAB, government contractors, and other government technicalrepresentatives in response to the specific needs of this project.

The organizations and groups listed below provided invaluable contributions to the creation ofthis report.

Aeronautical System Center, Environmental Management OfficeAir Education and Training CommandAir Force Corrosion Program OfficeAir Force Materiel CommandApache Program OfficeArmy Materiel Command, HeadquartersAV-8B Program OfficeBoeing CompanyC-17 Program OfficeChief of Naval Operations, Environmental Protection, Safety and Occupational HealthDefense Contract Audit Agency — St. Louis, MissouriDefense Logistics Agency, HeadquartersF/A-18 Program OfficeF-15 Program OfficeHarpoon/SLAM Program OfficeIndustrial Operations Command, HeadquartersJoint Depot Environmental PanelMarine Corps Air Station BeaufortNational Aeronautics and Space AdministrationNational Defense Center for Environmental ExcellenceNaval Air Station Cecil FieldNaval Air Station KingsvilleNaval Air Station LemooreNaval Air Systems CommandNaval Air Warfare Center - Aircraft DivisionNaval Air Warfare Center – Weapons DivisionNaval Aviation Depot - Cherry PointNaval Aviation Depot - JacksonvilleNaval Aviation Depot - North IslandTyndall Air Force BaseT-45 TS Program OfficeWarner-Robins Air Logistics Center

Potential Alternatives Report v

EXECUTIVE SUMMARY

At the Boeing Company Aircraft & Missiles (B-A&M, formerly McDonnell Douglas Aerospace)JG-APP project site in St. Louis, Missouri, chromium in primer coatings was identified as ahazardous material of concern, and targeted for elimination or reduction. Chromate primers areused to increase corrosion resistance and improve paint adhesion. These primers are mostcommonly applied to aluminum alloys, but other substrates such as steel, composites, andtitanium are also present on aircraft exterior surfaces and will be coated by these primers.

This Potential Alternatives Report (PAR) provides analyses of identified alternatives to chromateprimers and a list of those alternatives selected for testing.

A number of nonchromate primers having potential to replace chromate primer coatings wereidentified through literature searches and direct vendor queries in early 1996. Manufacturers anddistributors of the identified alternatives were contacted, and technical, environmental, safety,and occupational health characteristics of the alternatives were compared with those of thebaseline process. Seventeen high-solids or waterborne nonchromate primers were classified aspotentially viable alternatives based on available information and the judgement of the projectparticipants. In addition, the participants agreed to investigate at least one electrocoat primer,even though there are no near-term plans to implement an electrocoating process at the BoeingSt. Louis facility.

These 17 high-solids or waterborne nonchromate primers, as well as one electrocoatnonchromate primer, were classified as potential alternatives to be subjected to screening tests inaccordance with the Joint Test Protocol (MD-P-1-1) for Validation of Alternatives to Chromate-Containing Primer Coatings for Aircraft Exterior Mold Line Skins, dated December 23, 1997.The results of the screening tests were used to select a smaller number of nonchromate primers tobe tested further in accordance with the Joint Test Protocol (JTP), in laboratory tests. The resultsof laboratory testing are reported in the Joint Test Report (MD-R-1-1) for Laboratory Validation(Testing) of Alternatives to Chromate-Containing Primer Coatings for Aircraft Exterior MoldLine Skins, dated February 24, 1998. After the laboratory testing was completed, a small numberof nonchromate primers were selected for field evaluation in accordance with the JTP. Theresults of operational testing will be reported in the Joint Test Report (MD-R-1-2) for FieldEvaluation and Validation of Alternatives to Chromate-Containing Primer Coatings for AircraftExterior Mold Line Skins.

If one of the high-solids or waterborne nonchromate primers meets performance requirementsand is used, B-A&M may realize cost avoidance due to reduced hazardous waste generation andworker exposure to hazardous materials. In addition, the replacement of chromate primers withnonchromate primers at Department of Defense (DoD) maintenance facilities has been estimatedto result in cost avoidance of at least $1 million through the year 2024. The actual costavoidance realized during aircraft production and maintenance will depend on the exactproduct(s) and procedure(s) used. Concurrent Technologies Corporation (CTC) has estimatedthat B-A&M may realize a reduction in operating costs between $30,000 and $70,000 per year.

Potential Alternatives Report 1

1. INTRODUCTION

The Joint Logistics Commanders (JLC) chartered the Joint Group on AcquisitionPollution Prevention (JG-APP) to coordinate joint service activities affecting pollutionprevention issues identified during a weapon system’s acquisition process. The primaryobjectives of JG-APP are to:

• Reduce or eliminate the use of hazardous materials (HazMats)• Avoid duplication of efforts in actions required to reduce or eliminate

HazMats through joint service cooperation and technology sharing.

The focus of JG-APP is on contractor design, manufacturing, and remanufacturinglocations with technology transfer to the Sustainment Community. To reduce HazMats, the JG-APP process first identifies the HazMat, related process, andaffected substrates or parts at an original equipment manufacturer (OEM) facility. Detailsof the process are provided by the OEM including equipment requirements; material andenergy usage; waste and emission generation; environmental, safety, and occupationalhealth (ESOH) issues; and capital and operating costs. This information is thendocumented in a Potential Alternatives Report (PAR) for comparison with identifiedalternative processes (refer to Section 2 and Appendix A). Identifying and selecting alternative processes that have the potential to reduce theidentified HazMats can be a complicated task due to the fast pace at which newtechnologies emerge and the ever-increasing volume of published and unpublisheddocumentation. In the JG-APP process, a technology survey is performed to identifycommercially available or near commercially available alternative technologies. Thealternatives are identified through literature searches, electronic database searches,Internet searches, customized surveys, and/or personal and professional contacts. Thetechnology survey, which is documented in the PAR, serves as a foundation for theremainder of the PAR and for selection of alternative processes (refer to Appendix B). After reviewing technical information received from the technology survey, U. S.Department of Defense (DoD) and OEM technical representatives that are involved withthe JG-APP process at a specific OEM site select a shortened list of viable alternativetechnologies. The selection rationale and conclusions are documented in the PAR andvendors of the selected technologies are contacted concerning their specific products.DoD and OEM technical representatives then select a shortened list of products to befurther considered, based on information in the PAR (refer to Section 3 and Appendix C). The identified products then undergo more in-depth technical and ESOH analyses. Thetechnical analysis includes determining how well the alternatives match the OEM’soperations and future needs. A summary of the expected additional equipment, materialand energy usage, waste and emission generation, and capital and operating costs for thealternatives is provided for comparison with the current process (refer to Section 4). The

2 Potential Alternatives Report

preliminary ESOH analysis provides an initial qualitative assessment of viablealternatives, identifying conspicuous ESOH issues that may be a factor when selecting analternative to the baseline process (refer to Section 5 and Appendix D). After reviewing the technical and ESOH analyses, DoD and OEM technicalrepresentatives jointly selected potential alternatives for testing in accordance with theJoint Test Protocol (MD-P-1-1) for the Validation of Alternatives to Chromate-Containing Primer Coatings for Aircraft Exterior Mold Line Skins, dated December 23,1997, developed for the OEM (refer to Section 6). The results of laboratory testing arereported in the Joint Test Report (MD-R-1-1) for Laboratory Validation (Testing) ofAlternatives to Chromate-Containing Primer Coatings for Aircraft Exterior Mold LineSkins, dated February 24, 1998. The results of operational testing will be reported in theJoint Test Report (MD-R-1-2) for Field Evaluation and Validation of Alternatives toChromate-Containing Primer Coatings for Aircraft Exterior Mold Line Skins. At Boeing Company Aircraft & Missiles (BA&M, formerly McDonnell DouglasAerospace), located in St. Louis, Missouri, chromate in primer coatings was identified asthe target HazMat to be eliminated or reduced. The identified process was primerapplication by wet-spray coating. The identified application is aircraft exterior mold lineskins. The main substrates are aluminum alloys that have been anodized or chromateconversion coated, but other substrates such as steel, composites, and titanium are alsopresent on aircraft exterior surfaces and will be coated by these primers. Table 1 lists thetarget HazMat, baseline process, application, current specifications, affected programs,and candidate substrates. The currently used chromate primers are intended to meet therequirements of military specifications (MILSPECs) MIL-P-23377 Class C (strontiumchromate-based corrosion inhibitors) or MIL-P-85582 Class C2 (strontium chromate-based corrosion inhibitors). The most recent versions of these MILSPECs are MIL-P-85582B (Primer Coatings: Epoxy, Waterborne, issued May 23, 1994, interimamendment issued August 31, 1994) and MIL-P-23377G (Primer Coatings: Epoxy,High-Solids, issued September 30, 1994).


Table 1. Target HazMat Summary

TargetHazMat

Baseline Process Application CurrentSpecifications

Affected Programs Candidate Substrates

Chromium PrimerApplication byWet-SprayCoating

ExteriorAircraft MoldLine Skins

MIL-P-23377Class C

MIL-P-85582Class C2

MMS 423A

DMS 2104E

DMS 2144C

Air Force: F-15, C-17

Navy: F/A-18,T-45 TS,Harpoon/SLAM

Marine Corps: AV-8B

• Aluminum alloy 2024-T3;bare and clad; conversioncoated, anodized, ordeoxidized

• Aluminum alloy 7075-T6;bare and clad; conversioncoated or anodized

• Aluminum alloy 2014-T6,clad, conversion coated

• Steel alloy 4130; cadmiumplated or IVD Al coated

• Titanium alloy Ti-6Al-4V• Magnesium alloy AZ 312B• Carbon Epoxy


2. BASELINE PROCESS The following description and estimates of the current operating procedures were derivedfrom interviews with engineers at B-A&M in St. Louis, Missouri. Figure 1 below illustrates the flow of the baseline process. The term “parts” in the figurerefers to aircraft exterior mold line skins. Volatile organic compounds (VOCs) arereleased during many steps of the process.

QUALITYCHECK

HazardousWaste

HazardousWaste

Parts

AIRDRY

Parts

AIRDRY

SECONDPRIMERCOAT

(SPRAY)

Parts

VOCs

FIRSTPRIMERCOAT

(SPRAY)

PrimerCoating

Parts Parts a

HazardousWaste

PartsAccepted

ChemicalStripper

STRIPat operatordiscretion

VOCs

VOCs

Parts toReprocess

VOCs

VOCs

PrimerCoating

PartsRejected

Parts a

a A second primer coat may be applied, the decision is based on applied film thickness.

May not be required

Figure 1. Primer Spray Application Flow Diagram In the baseline process, chromate-containing primers are sprayed on aircraft exterior moldline skins in spray booths. One to two coats of primer are applied as required to achievethe prescribed coating thickness of 0.8 mil to 1.4 mil for interior surfaces and 0.4 mil to0.8 mil for exterior surfaces. B-A&M prepares approximately 2,000 gallons per year ofchromate-containing primers for application to aircraft exterior mold line skins. Thedrying times vary according to the parts being primed and the primers applied. In someinstances, a second primer coat is applied; the second primer coat may be dried by forcedair. Depending on the reason for rejection, some of the rejected parts are immediatelyrecoated without being stripped.


Prior to primer application, the exterior mold line skins are treated to prevent corrosionand provide a good adhesion base for the primer. All 2024 and 7075 aluminum alloyexterior mold line skins are anodized or treated with a chromate conversion coating priorto primer application. The primer must adhere to the surface created by the chromateconversion coating. The primer must also provide good adhesion for the subsequenttopcoat applied. The chromate-containing primers listed in Table 2 below have been used by B-A&M onaircraft exterior mold line skins for the affected defense systems.

Table 2. Currently Used Chromate Primers

Primer Designation Manufacturer/Supplier 515X379/910X563(a) Courtaulds Aerospace 515X386/910X831 (Type II) Courtaulds Aerospace 515X332/910X457(b) Courtaulds Aerospace 513X408/910X831(c) Courtaulds Aerospace 10P20-12/EC-212 Dexter Aerospace Materials/Crown Metro Aerospace EEAY051 A/B Spraylat Corporation 44-GN-36 Deft, Inc.

a Replaced by 10P20-12/EC-212 b Replaced by EEAY051 A/B c Replaced by 44-GN-36 A/B

Courtaulds Aerospace primers 513X408/910X831 and 515X386/910X831 and Deftprimer 44-GN-36 are on the qualified products list for MIL-P-85582B (Primer Coatings:Epoxy, Waterborne, issued May 23, 1994, interim amendment issued August 31, 1994);Courtaulds Aerospace 513X408/910X831 and Deft 44-GN36 are Type I, Class C2 andCourtaulds Aerospace 515X386/910X831 is Type II, Class C2. Spraylat Corporationprimer EEAY051 A/B is on the qualified products list for MIL-P-23377G (PrimerCoatings: Epoxy, High-Solids, issued September 30, 1994).

2.1. Baseline Process Equipment and Material and Energy Usage Primer spray is applied in spray booths with high-volume low-pressure (HVLP)manual spray guns. No other process equipment information is available at thistime. Approximately 2,000 gallons per year of primer are prepared for application onaircraft exterior mold line skins. Based on the assumption that a 5.5 horsepowerturbine HVLP system is used to apply the primer, and that such a system iscapable of spraying approximately three gallons of primer per hour, the energyused in the baseline process is estimated to be approximately 2,750 kilowatt-hours(kW-hr) per year. The chemical stripper used on rejected parts is ignored for two


reasons: less than 1% of aircraft exterior mold lines need to be stripped andrecoated, and neither the type nor quantity of stripper used is expected to changesignificantly if the currently used chromate primers are replaced by nonchromateprimers. Table 3 lists the estimated amount of material and energy used for theapplication of nonchromate primers to aircraft exterior mold line skins. Theenergy use estimate is based on assumptions made by Concurrent TechnologiesCorporation (CTC), and does not necessarily reflect the actual operatingconditions at B-A&M.

Table 3. Baseline Material and Energy Usage

Material Quantity/Year

Chromate-Containing Primers 2,000 gal

Energy Quantity/Year

Electricity for Running HVLP System 2,750 kW-hr

2.2. Baseline Wastes and Emissions

No detailed waste stream or emission information is available at this time.Table 4 contains an estimate of primer wastes and emissions based on theassumptions listed below.

• Approximately 50% of the primer mixed is applied to aircraft moldlines. The remaining 50% is accounted for through overspray,unacceptable primer application, paint equipment cleaning, expiredshelf-life of primer components, and expired pot-life of mixedprimer.

• The primers used contain approximately five pounds of solids pergallon of primer.

• The chemical stripper used on rejected parts is ignored for tworeasons: less than 1% of aircraft exterior mold lines need to bestripped and recoated, and neither the type nor quantity of stripperused is expected to change significantly if the currently usedchromate primers are replaced by nonchromate primers.

• Military specifications MIL-P-85582B and MIL-P-23377G haveupper limits for VOCs of 340 grams per liter (g/l) (2.84 poundsVOCs per gallon of primer coating). The estimated quantity ofVOC emissions from the primer application process is derived byassuming that the primer used contains the maximum VOCconcentration allowed in these military specifications, and all ofthe VOCs are released as emissions.

The assumptions listed here and used to arrive at Table 4 were made by CTC forthe purpose of estimating wastes and emissions from the baseline process, and donot necessarily reflect the actual conditions at B-A&M.


Table 4. Baseline Wastes and Emissions Summary

Waste Quantity/Year

Waste Primer 1,000 gal

Waste Primer Solidsa

(Contain Chromates)

5,000 lb

Emissions Quantity/Year

VOCs 5,700 lb a Waste primer solids are a portion of waste primer

2.3. Baseline Environmental, Safety, and Occupational Health (ESOH) Status The baseline process at B-A&M complies with environmental and occupationalsafety and health regulations. Workers wear appropriate personal protectiveequipment, and suitable emission control equipment is in operation. No detailedinformation about the ESOH status of the baseline process is available at thistime. At the federal level, chromium is regulated under the Occupational Safety andHealth Act, the Clean Air Act (CAA), and the Clean Water Act (CWA), amongother regulations. It is often also regulated at the state and local levels. Theregulatory trend with chromium has been and continues to be toward increasingcontrol. An example of this trend is the inclusion of chromium on the EPA 17list—a list of particularly harmful compounds that the United StatesEnvironmental Protection Agency (EPA) targeted in its “33/50 Program.” To limit worker exposure to hazardous substances, the Occupational Safety andHealth Administration (OSHA) has promulgated permissible exposure limits(PELs) which establish numerical standards to limit exposure in the workplace.Currently, there is no PEL specifically addressing hexavalent chromium which isthe form of chromium present in strontium chromate. Instead, hexavalentchromium compounds are covered by the more general “chromic acid andchromates” heading at Table Z-2 in Title 29, Code of Federal Regulations,Part 1910.1000 (29 CFR §1910.1000). The current PEL for chromic acid andchromates is a ceiling limit of 100 micrograms per cubic meter of air (100 µg/m³,or 0.1 mg/m3), measured as chromium trioxide (CrO3). OSHA is currentlyworking toward establishing a new, stricter standard for worker exposure tohexavalent chromium (chromium (VI)). OSHA is expected to issue a rule forgeneral industry, agriculture, and maritime work, with a separate standard forconstruction. Reports indicate that OSHA is considering a new exposure limit inthe range of 0.5 µg/m³ to 5 µg/m³, and likely closer to 0.5 µg/m³. With thecurrently used chromate primers, meeting this chromium exposure limit for


workers using engineering controls and personal protective equipment will bevery difficult; this is one reason for eliminating chromium from primers used foraircraft exterior mold line surfaces. In addition, chromium compounds have been included on the list of189 hazardous air pollutants (HAPs) designated in the CAA. In September 1995,EPA issued national emission standards for hazardous air pollutants (NESHAP)that specifically address chromium primer application operations at AerospaceManufacturing and Rework Facilities (60 Fed. Reg. 45948, September 1, 1995).The aerospace NESHAP applies to facilities that are involved in the manufactureor rework of commercial, civil, or military aerospace vehicles or components.Under this new NESHAP, chromium primers must be applied using only thelisted application techniques and air pollution control devices. Replacement ofchromate primers with nonchromate primers would help reduce the BoeingSt. Louis requirements for specialized air pollution control devices. Chromium compounds have also been targeted by the CWA. EPA recentlyproposed effluent guidelines, new source performance standards, and pretreatmentstandards for wastewater discharges from sources that fall under the new MetalProducts and Machinery (MP&M) industrial category (60 Fed. Reg. 28209,May 30, 1995). For the seven industrial sectors included in Phase I of the MP&Mcategory (including the aerospace and aircraft sectors), EPA has proposed aone-day maximum concentration for total chromium of 0.3 milligrams per liter(mg/l). Also, under the proposed rule, the monthly average concentration of totalchromium would be limited to 0.2 mg/l. These proposed new limits areconsiderably stricter than the current levels. In 1995, when this project began, thePhase I MP&M category standards were scheduled to be finalized inSeptember 1996. At present, the Phase I MP&M category standards are expectedto be finalized in 2002. An ESOH analysis of the currently used chromate primers was performed asdescribed below, and a summary of this analysis may be found in Table 7.Appendix A provides a detailed description of the ESOH characteristics of thebaseline chromate primers, and the source information for this summary.

2.3.1. Environmental Issues

The currently used chromate primers were evaluated to determine theextent of their regulation under the major federal environmental laws.Using available resources, each currently used chromate primer wasevaluated based on the criteria listed below.

• Air Emissions: The constituents of each currently used

chromate primer were analyzed to determine if they are


regulated under the CAA as HAPs, VOCs, or ozone-depleting substances (ODSs).

• Solid/Hazardous Waste Generation: Each currently usedchromate primer was evaluated to determine whether its usegenerates solid waste, and if so, whether that waste may beregulated as hazardous or otherwise, under subtitle C of theResource Conservation and Recovery Act (RCRA).

• Wastewater Discharges: Each currently used chromateprimer was analyzed to determine whether its use wouldcause the discharge of any wastewaters regulated under theCWA. Spills or other discharges of CWA hazardoussubstances into navigable waters must be reported when theamount meets or exceeds the substance’s reportablequantity. Toxic and priority pollutants must be treatedbefore they can be discharged to receiving waters or apublicly owned treatment works (POTW). Pretreatmentpollutants must undergo pretreatment to ensure that theirdischarge to a POTW is compatible with the capabilities ofthat POTW. In addition, effluent limitation guidelines havebeen developed for some pollutants. These effluentlimitations establish a minimum level of treatment that isrequired for all direct dischargers in an industry categorybased upon the application of various control technologies.

• Reporting Requirements: The currently used chromateprimers were examined to determine whether any of theconstituents are required to be listed on Toxics ReleaseInventory (TRI) reports under Section 313 of theEmergency Planning and Community Right-to-Know Act(EPCRA).

• CERCLA Hazardous Substances: Each currently usedchromate primer was assessed to determine if itsconstituents are listed as hazardous substances under theComprehensive Environmental Response, Compensationand Liability Act (CERCLA).

• EPA 17: The constituents of each currently used chromateprimer were compared to the EPA 17 list. Thosesubstances on the EPA 17 list have been targeted by EPAbecause they are released in large quantities each year; theyare generally identified as toxic or hazardous pollutants;and pollution prevention practices have the potential todiminish releases of these chemicals. The EPA 17 arelikely to be targeted for more stringent regulation.

This assessment only uses product information that is readily availablefrom the material safety data sheet (MSDS), technical data sheet, and other


reference materials. Based on this information, the regulatory impacts ofbaseline chromate primers are not easily compared, since it is impossibleto say that a process that emits a hazardous waste sludge is any more orless desirable than a process that emits a HAP. Therefore, it is notpossible to categorize each of the currently used chromate primers basedon some type of regulatory rating system. However, a chromate primerthat has few regulated constituents is clearly preferable to one that hasmany regulated constituents, so the extent to which a currently usedchromate primer is regulated should be considered as an element of theanalysis process.

2.3.2. Safety and Occupational Health Issues Toxicity Rating: As part of the preliminary ESOH analysis, the currentlyused chromate primers were qualitatively assessed for evident hazards(i.e., toxicity and exposure). Toxicity was qualitatively reviewed, andeach product given a final toxicity rating. Toxicity ratings of high,medium, or low were assigned to currently used products based onanalysis of the available literature, the relative quantities of eachconstituent of the product, and best professional judgement. Parametersreviewed included median lethal concentrations (LC50) and/or median orallethal doses (LD50). The qualitative toxicity rating scheme is summarizedin Table 5.

Table 5. Toxicity Ratings for Currently Used Products

ToxicityRating

Descriptive Term LC50

(ppm) LD50 Single Dose

(per kg body mass) High Highly Toxic < 50 < 50 mg

Medium Moderately Toxic 50 - 50,000 50 mg - 5 g Low Relatively Nontoxic > 50,000 > 5 g

Exposure Rating: Because ESOH hazard is a function of toxicity andexposure, a qualitative exposure rating scheme is also used. Exposure canoccur only when the potential exists for a receptor to directly contactreleased chemical constituents from the primer, or if there is a mechanismfor released constituents to be transported to a receptor. Each component(released constituents, mechanism of transport, point of contact, andpresence of a receptor) must be present for a complete exposure pathwayto exist. Without exposure, there is no risk; therefore, the exposureassessment is a key element when assessing potential risks associated witha currently used chromate primer. A complete state-of-the-art riskassessment for the currently used chromate primers would be necessary fora reliable calculation of exposure. Because this assessment is intended to


be a basis for evaluating the viable alternative products, a complete riskassessment was not performed. In lieu of a complete risk assessment, exposure level was qualitativelyreviewed, and each product was given a final exposure rating. Exposureratings of high, medium, or low were assigned to currently used productsbased on analysis of the available literature, the relative quantities of eachconstituent of the product, and best professional judgement. Parametersreviewed included OSHA-promulgated PELs and the AmericanConference of Governmental Industrial Hygienists (ACGIH) thresholdlimit values (TLVs). Three exposure rating levels and associated TLV andPEL intervals were chosen based on ACGIH recommendations. Thequalitative exposure rating scheme is summarized in Table 6.

Table 6. Exposure Ratings for Currently Used Products

ExposureRating

Descriptive Term TLV (ppm) PEL (ppm)

High High Exposure Level <100 <100 Medium Moderate Exposure Level 100 - 500 100 - 500

Low Relatively No ExposureLevel

>500 >500

Hazard Rating: A final hazard rating designation was given to eachcurrently used product based on the toxicity ratings and exposure ratings.For each component of a product, the hazard rating is the average of thetoxicity rating and exposure rating. A hazard rating was assigned to eachproduct based on the component hazard ratings, the relative quantities ofeach constituent, and best professional judgement. An ESOH discussiondescribing constituent-specific information and the hazard rating for eachcurrently used chromate primer is presented in Appendix A. It should be noted that these judgements are based on available scientificinformation. Also note that this assessment is based on a limited scope,and the authors of this report assume no responsibility for safe operation ofthe process based on these hazard ratings.


Table 7. Summary of Safety, Health, and Environmental Analysis of Currently Used Chromate Primers

Air Emissions Wastes Generated Waste- TRI CERCLA EPA 17 Product TR ER HR HAPs VOCs ODSs Solid Hazardous water Report HazSub List

515X379/910X563 M H M-H 5 Yes No Yes Yes Yes 6 5 4 515X386/910X831 M H M-H 3 Yes No Yes Yes Yes 3 3 1 513X332/910X457 M H M-H 3 Yes No Yes Yes Yes 4 5 3 513X408/910X831 M H M-H 3 Yes No Yes Yes Yes 3 3 1 10P20-12/EC-212 M H M-H 5 Yes No Yes Yes Yes 6/4a 5/3a 5/4b

EEAY051 A/B N.R. N.R. N.R. 5 Yes No Yes Yes Yes 4 5 4 44-GN-36 M M-H M 1 Yes No Yes Yes Yes 2 1 1

TR = Toxicity Rating; ER = Exposure Rating; HR = Hazard Rating L = Low; M = Medium; M-H = Medium to High; H = High N.R. = Not Rated a Two of the identified chemicals (formaldehyde and benzene) are present only in trace quantities.

b One of the listed chemicals (benzene) is present only in trace quantities.


2.4. Baseline Capital and Operating Costs B-A&M currently uses a number of primers in their baseline process. Based onavailable data, CTC estimated that the average baseline chromate primer cost is$72.19/gal, and the average coverage is 750 square feet per gallon primer per milcoating thickness (ft2/gal/mil). Table 8 summarizes the estimated costs for the baseline chromate primerapplication process. The information in Table 8 is based on the assumptionslisted below.

• The average baseline chromate primer cost is $72.19/gal, and theaverage coverage is 750 ft2/gal/mil.

• According to 40 CFR 63.745, controlled primers (those containingmore than 350 g/l VOCs, less water, and exempt solvents) must beused with equipment that reduce the total VOC and organichazardous air pollutant emissions to the atmosphere by 81% ormore. The currently used chromate-containing primers thatconform to MIL-P-23377G or MIL-P-85582B each contain nomore than 340 g/l of VOCs, allowing these primers to be appliedwithout control equipment to reduce VOC emissions. As a result,no cost is assumed for this equipment.

• B-A&M currently uses enclosed spray booths with appropriate aircirculation and filtering mechanisms to reduce particulateemissions and protect worker health and safety. It is anticipatedthat this equipment will remain in operation after theimplementation of nonchromate primers into B-A&M processes,so the cost of this equipment is ignored in this analysis.

• Efficiency of HVLP spraying is typically estimated atapproximately 65%. For this analysis, 50% overall primerapplication efficiency is assumed. One half of the primer mixedfor use is accounted for through overspray, unacceptable primerapplication, paint equipment cleaning, expired shelf-life of primercomponents, and expired pot-life of mixed primer.

The costs presented in Table 8 are based on CTC estimates of costs and laborhours, and are not intended to provide details of B-A&M operations.


Table 8. Capital and Annual Operating Cost Estimates for CurrentlyUsed Chromate Primer Application

Item Capital Cost, $

Capture and Control Equipment 0a

Item Annual Operating Cost, $

Materials

(2,000 gal mixed primer at an averageb of$72.19/gal)

144,380

Labor

1. Primer preparation, application, and clean-up(1,000 hr @ $65/hr)

65,000

2. Time required for use of protective equipment(100 hr @ $65/hr)

6,500

Waste Management

1. Disposal of waste primer (50%c of 2,000 gal(18.2 drums) @ $150/drum)

2,730

2. Disposal of rags and filters (5.2 drums (284gal) @ $375/drum)

1,950

3. Waste handling in priming area (50 hr @$65/hr)

3,250

4. Reporting/administration associated with waste(35 hr @ $90/hr)

3,150

Utilities

(2,750 kW-hr @ $0.08/kW-hr)

220

Maintenance (100 hr @ $65/hr) 6,500

Total/Year 230,000da No capture and control equipment required.b Average estimated cost based on available data for current primers used.c Efficiency of HVLP spraying is typically estimated at approximately 65%.d Total operating cost estimates rounded to two significant figures.


3. IDENTIFIED ALTERNATIVES AND PRELIMINARY SCREENING

To identify alternative technologies to MIL-P-23377 Class C and MIL-P-85582 chromate(Class C1 and Class C2) coatings, a technology survey was performed in early 1996. Thetechnology survey, which identified conventional nonchromate primers as well as threealternative technologies, is provided in Appendix B and summarized in Section 3.1. Thethree alternative technologies investigated were high-solids nonchromate primers,waterborne nonchromate primers, and electrocoat (nonchromate) primers. Theparticipating DoD and OEM technical representatives decided to consider all threealternative technologies as viable technologies; conventional (high-VOC) primers willnot be further considered because the participating DoD and OEM technicalrepresentatives chose to limit VOC levels in primers while eliminating chromate primers.

Vendors of these viable alternative technologies were identified, and a list of vendorproducts was selected by DoD and OEM technical representatives for furtherconsideration. Most of the products were selected in early 1996, but a few products wereidentified in late 1996. Product identification and selection are described in Appendix Cand Section 3.2, respectively. Vendors selected to identify products for furtherconsideration discussed in Sections 4 and 5 include:

• BASF Corporation• Courtaulds Aerospace• Dexter Aerospace Materials/Crown Metro Aerospace• Deft, Inc.• Lord Corporation• U. S. Paint Corporation• Spraylat Corporation• Sterling Lacquer Manufacturing Company.

3.1. Alternative Technology Selection

Several nonchromate primers are currently available. These alternatives areintended to generate less hazardous waste and cause fewer and/or less severehealth and safety risks than the currently used primers. The primers may begrouped as conventional alternatives, high-solids alternatives, waterbornealternatives, or electrocoat alternatives. The participating DoD and OEMtechnical representatives decided to continue to consider high-solids, waterborne,and electrocoat primer alternatives. Conventional primers were eliminated fromfurther consideration to limit VOC levels in primers. Some general properties ofthe candidate primer types are summarized in Table 9.


Table 9. Properties of Candidate Primer Types

Candidate Primer Type(Technology)

General Properties

Conventional Primers Solvent-borne, spray applicationHigh-Solids Primers Reduced VOC content, spray application, may

require slight process modifications to ensuresmooth application and correct film thickness,typically slow to dry

Waterborne Primers Reduced VOC content, spray application, oftenslow to dry and cure without adequate air flow

Electrocoat Primers Reduced VOC content, applied by dipping intanks with appropriate electrical connections(special equipment), switching from one primer toanother difficult

3.2. Product Identification

The technical representatives selected 19 viable alternatives for furtherconsideration based on reported performance characteristics and the knowledge ofthe technical representatives. The viable alternatives that were further consideredare listed below in Table 10. Most of these products were selected in late 1995(before the technology survey was started), but Aeroglaze 9741, AlumigripR1204/S3800, 44-W-18, and 10PW22-3/ECW-123 were selected in 1996, afterscreening tests, in accordance with the Joint Test Protocol (JTP) written for thisproject, were started.


Table 10. Viable Alternatives to Chromate-Containing Primersfor Aircraft Exterior Mold Line Skins

Primer Type Designation Manufacturer

High-Solids 02-W-38 Deft, Inc.

High-Solids 10P22-3/EC-270 Dexter Aerospace Materials/Crown Metro Aerospace

High-Solids Aeroglaze 9740 Lord Corporation


High-Solids EEAE136 A/B Spraylat Corporation

High-Solids U-1201-NC/U-1202-F Sterling Lacquer ManufacturingCompany

High-Solids Alumigrip R1204/S3800 U.S. Paint Corporation

Waterborne RW-3151-64 Courtaulds Aerospace


Waterborne 44-W-16 Deft, Inc.



Waterborne 10PW22-2/ECW-119 Dexter Aerospace Materials/Crown Metro Aerospace


Waterborne EWDY048 A/B Spraylat Corporation

Waterborne EWAE118 A/B Spraylat Corporation

Waterborne U-4800-NC/U-4801 Sterling Lacquer ManufacturingCompany

Electrocoat G28AD012 BASF Corporation

Electrocoat U32CD210/U32AD290 BASF Corporation


4. PROCESS DESCRIPTIONS FOR VIABLE ALTERNATIVES

The majority of the viable alternatives would require no changes in processing steps orequipment to be used as replacements for the chromate-containing primers now used.Only the electrocoat primers would require major process changes. This sectiondescribes in detail the alternative processes recommended for further evaluation (refer toSection 3 of this PAR).

Each process discussion includes a description of the process, a process flow diagram, alist of equipment, estimated material and energy usage, and anticipated wastes andemissions. The description also points out required modifications to the baseline process.

The process descriptions for the viable alternatives can be compared to the baselineprocess in which parts are coated using chromate primers (refer to Section 2 of this PAR).This comparison can then be used as a basis for further screening of specific products.

4.1. High-Solids Primers

High-solids primers are sometimes used in the existing process at B-A&M. Nomajor changes are expected in the process due to the use of high-solidsnonchromate primers instead of chromate-containing primers.

Replacement of HVLP spray equipment with electrostatic liquid sprayingequipment may be possible, to take advantage of the higher applicationefficiencies achievable with electrostatic spraying; B-A&M has no current plansto implement electrostatic liquid spraying.

Figure 2 below illustrates the flow of the high-solids primer spray applicationprocess. The term “parts” in the figure refers to aircraft exterior mold line skins.


QUALITYCHECK

Wastea

AIRDRY

Parts

VOCs

PRIMERCOAT

(SPRAY)

PrimerCoating

Parts

Wastea

PartsAccepted

ChemicalStripper


VOCs

Parts toReprocess

VOCs

PartsRejected

a Waste may or may not be hazardous

Parts

Figure 2. High-Solids Primer Spray Application Flow Diagram

4.1.1. High-Solids Primer–Alternative Process Equipment

In the baseline process, primer is applied by HVLP spray guns, in spraybooths. Replacement of the HVLP spray equipment with electrostaticliquid spraying equipment may be possible, to take advantage of the higherapplication efficiencies achievable with electrostatic spraying; B-A&Mhas no current plans to implement electrostatic liquid spraying. Thefollowing analysis assumes that such a change is feasible. Beforeelectrostatic liquid spraying is attempted with any coating, the electricalresistance of that coating should be tested to determine the suitability ofthat coating for electrostatic spraying.

4.1.2. High-Solids Primer–Anticipated Material and Energy Usage

Table 11 contains an estimate of the material and energy usage requiredfor applying high-solids nonchromate primers to aircraft exterior mold lineskins. The estimate is based on the assumptions listed below.

• Electrostatic liquid spraying equipment will be incorporatedinto the process, replacing HVLP spray gun(s). Note that


B-A&M has no current plans to implement electrostaticliquid spraying equipment.

• Electrostatic liquid spraying equipment is typicallyestimated to be approximately 70% to 85% efficient inapplying organic coatings, so an overall primer applicationefficiency of 65% (primer is wasted through overspray,unacceptable primer application, paint equipment cleaning,expired shelf-life of primer components, and expiredpot-life of mixed primer) is assumed.

• The overall primer application efficiency using HVLP sprayguns is assumed to be 50%.

• The average coverage of a high-solids nonchromate primeris estimated to be 922 square feet per gallon of fully mixedprimer per mil of dry film thickness (ft2/gal/mil).

• The average coverage of the currently used chromateprimers is approximately 750 ft2/gal/mil.

• The area that must be coated remains constant (same asbaseline), and one coat of high-solids nonchromate primerwill be applied.

• The chemical stripper used on rejected parts is ignored fortwo reasons: less than 1% of aircraft exterior mold linesneed to be stripped and recoated, and neither the type norquantity of stripper used is expected to change significantlyif the currently used chromate primers are replaced byhigh-solids nonchromate primers.

The quantities presented in Table 11 are based on CTC estimates, and arenot intended to provide details of B-A&M operations.

Table 11. Material and Energy Usage of High-Solids NonchromatePrimers for Aircraft Exterior Mold Line Skins


High-Solids Nonchromate Primers 1,250 gal


Electricity for Running ElectrostaticLiquid Spraying System

4,100 kW-hr


4.1.3. High-Solids Primer–Anticipated Wastes and Emissions Table 12 contains an estimate of the quantity of high-solids primer wastegenerated, based on the assumptions listed below.

• Approximately 35% of the primer used is wasted throughoverspray, unacceptable primer application, paintequipment cleaning, expired shelf-life of primercomponents, and expired pot-life of mixed primer.

• The high-solids nonchromate primer(s) that will be usedcontains approximately 340 g/l (2.8 lb/gal of primer)VOCs.

• The high-solids nonchromate primer(s) that will be usedcontains approximately 8 lb solids/gal mixed primer.

• The chemical stripper used on rejected parts is ignored fortwo reasons: less than 1% of aircraft exterior mold linesneed to be stripped and recoated, and neither the type norquantity of stripper used is expected to change significantlyif the currently used chromate primers are replaced byhigh-solids nonchromate primers.


Table 12. Estimated Wastes and Emissions for High-Solids PrimerSpray Application to Aircraft Exterior Mold Line Skins

Waste Quantity/Year

Waste Primer 440 gal


(no chromates)

3,500 lb


VOCs 3,500 lba Waste primer solids are a portion of waste primer.

4.1.4. High-Solids Primer–Anticipated Capital and Operating Costs

Table 13 summarizes the estimated costs for the use of nonchromate high-solids primers. These costs were estimated based on the assumptionslisted below.

• Based on available information, the average cost of a high-solids nonchromate primer was estimated to be $61.90/gal,


and the average coverage was estimated to be922 ft2/gal/mil.

• According to 40 CFR 63.745, controlled primers (thosecontaining more than 350 g/l VOCs, less water, and exemptsolvents) must be used with equipment that reduce the totalVOC and organic hazardous air pollutant emissions to theatmosphere by 81% or more. The proposed high-solidsprimers each contain no more than 340 g/l of VOCs,allowing these primers to be applied without controlequipment to reduce VOC emissions. As a result, no costis assumed for this equipment.

• B-A&M currently uses enclosed spray booths withappropriate air circulation and filtering mechanisms toreduce particulate emissions and protect worker health andsafety. It is anticipated that this equipment will remain inoperation after the implementation of nonchromate primersinto B-A&M processes, so the cost of this equipment isignored in this analysis.

• It is estimated that the labor required to apply a givenvolume of high-solids nonchromate primer usingelectrostatic liquid spray equipment will be the same as thelabor required to apply that same volume of a currentlyused chromate primer using the baseline applicationprocess.

• It is assumed that the time “lost” to the use of protectiveequipment will decrease approximately 70% compared tothe baseline process, because less severe health and safetyrisks are associated with the proposed high-solids primers.

• The labor required for the reporting and administrationassociated with the waste is expected to be less than that forthe baseline process because none of the waste streamscontain chromium.

The costs presented in Table 13 are based on CTC estimates, and are notintended to provide details of B-A&M operations.


Table 13. Capital and Annual Operating Cost Estimatesfor High-Solids Nonchromate Primer Application


Capture And Control Equipment 0a

Electrostatic Liquid Spraying Equipment 7,500


Materials (1,250 gal of mixed primer at anaverage of $61.90/gal)

77,375

Laborb

1. Primer preparation, application, andclean-up (1,000 hr @ $65/hr)

65,000

2. Time required for use of protectiveequipment (30 hr @ $65/hr)

1,950

Waste Management

1. Disposalc of waste primer (35% of1,250 gal (8.0 drums) @ $100/drum)

800

2. Disposalc of rags and filters (3.4 drums(185 gal) @ $250/drum)

850

3. Waste handling in priming area (22 hr@ $65/hr)

1,430

4. Reporting/administration associatedwith wasted (30 hr @ $90/hr)

2,700

Utilities (electricity, 4100 kW-hr @$0.08/kW-hr)

328


Total/Year 160,000ea

No capture and control equipment required.b

Estimates are based on and comparable to the currently used chromate primers. Lesstime is needed for protective equipment use.

cIt is assumed that disposal costs for a given quantity of chromate primer and associatedwastes are approximately 150% of the disposal costs for that quantity of nonchromateprimer and associated wastes.

dNo waste streams contain chromium; therefore less labor is required.

eTotal operating cost estimates rounded to two significant figures.

Replacing the currently used chromate primers with high-solidsnonchromate primers applied by electrostatic liquid spraying may generateadditional cost savings that are somewhat intangible and are not calculatedhere. Some benefits may include:

• Reduced compliance costs


• Reduced liabilities for environmental problems at both on-site and off-site treatment, storage, and disposal locations

• Reduced worker exposure to hazardous materials• Improved community relations.

4.1.5. High-Solids Primer–Estimated Return-on-Investment Compared to the baseline process, an annual savings of approximately$70,000 is estimated for the application of high-solids nonchromate primerto aircraft exterior mold line skins using electrostatic liquid sprayingequipment. This cost avoidance is expected to occur after a $7,500investment in electrostatic liquid spraying equipment, leading to a simplepayback period of less than two months, and a simple return-on-investment of approximately 900%. This cost avoidance estimate is basedon CTC assumptions. B-A&M has no current plans to replace HVLP paintspraying equipment with electrostatic liquid spraying equipment. If high-solids nonchromate primers are implemented, the exact costavoidance achieved will depend on the details of the primer(s) used, andthe specific processing, labor, reporting/compliance, and waste disposalcosts incurred by the B-A&M St. Louis facility.

4.2. Waterborne Conventionally Applied Primers Waterborne primers are sometimes used in the baseline process. Waterborneprimers generally contain VOCs, though in concentrations lower than found inconventional primers. No significant changes are expected in the process due tothe use of waterborne nonchromate primers as substitutes for chromate-containingprimers. Figure 3 below illustrates the flow of the waterborne primer spray applicationprocess. The term “parts” in the figure refers to aircraft exterior mold line skins.


QUALITYCHECK

Wastea

Wastea

Parts

AIRDRY

Parts

AIRDRY

SECONDPRIMERCOAT

(SPRAY)

Parts

VOCs

FIRSTPRIMERCOAT

(SPRAY)

PrimerCoating

Parts Parts b

Wastea

PartsAccepted

(~99%)

ChemicalStripper


VOCs

VOCs

Parts toReprocess

VOCs

VOCs

PrimerCoating

PartsRejected

(~1%)

a Waste may or may not be hazardousb A second primer coat may be applied, the decision is based on applied film thickness.

Parts b

May not be required

Figure 3. Waterborne Primer Spray Application Flow Diagram

4.2.1. Waterborne Primer Alternative Process Equipment and AnticipatedMaterial and Energy Usage No significant changes in process equipment are anticipated forapplication waterborne primers. Table 14 contains an estimate of the material and energy usage requiredfor applying waterborne nonchromate primers to aircraft exterior mold lineskins. The estimate is based on the assumptions listed below.


• The coverage of a waterborne nonchromate primer isapproximately 706 ft2/gal/mil.

• The average coverage of the baseline chromate primers isapproximately 750 ft2/gal/mil.

• The area that must be coated remains constant (same asbaseline practice), and two coats of waterbornenonchromate primer will be applied.

• The chemical stripper used on rejected parts is ignored fortwo reasons: less than 1% of aircraft exterior mold linesneed to be stripped and recoated, and neither the type nor


quantity of stripper used is expected to change significantlyif the currently used chromate primers are replaced bywaterborne nonchromate primers.


Table 14. Material and Energy Usage of Waterborne Primers forAircraft Exterior Mold Line Skins


Waterborne Nonchromate Primers 2,120 gal


Electricity for Running HVLPSystem

2,915 kW-hr

4.2.2. Waterborne Primer–Anticipated Wastes and Emissions Table 15 contains an estimate of the quantity of waterborne primer wastegenerated, based on the assumptions listed below.

• Approximately 50% of the primer used is wasted throughoverspray, unacceptable primer application, paintequipment cleaning, expired shelf-life of primercomponents, and expired pot-life of mixed primer.

• The waterborne nonchromate primers that will be usedcontain approximately 340 g/l (2.8 lb/gal of primer) VOCs.

• The waterborne nonchromate primer(s) that will be usedcontains approximately 4lb solids/gal mixed primer.

• The chemical stripper used on rejected parts is ignored fortwo reasons: less than 1% of aircraft exterior mold linesneed to be stripped and recoated, and neither the type norquantity of stripper used is expected to change significantlyif the currently used chromate primers are replaced bywaterborne nonchromate primers.



Table 15. Estimated Wastes and Emissions for Waterborne PrimerSpray Application to Aircraft Exterior Mold Line Skins

Waste Quantity/Year

Waste Primer 1,060 gal


(no chromates)

4,240 lb


VOCs 5,940 lba Waste primer solids are a portion of waste primer.

4.2.3. Waterborne Primer–Anticipated Capital and Operating Costs

Table 16 summarizes the estimated costs for the use of nonchromatewaterborne primers. These cost estimates were based on the assumptionslisted below.

• Based on available information, the average cost of awaterborne nonchromate primer was estimated to be$53.67/gal, and the average coverage was estimated to be706 ft2/gal/mil.

• According to 40 CFR 63.745, controlled primers (thosecontaining more than 350 g/l VOCs, less water, and exemptsolvents) must be used with equipment that reduce the totalVOC and organic hazardous air pollutant emissions to theatmosphere by 81% or more. The proposed waterborneprimers each contain no more than 340 g/l of VOCs,allowing these primers to be applied without controlequipment to reduce VOC emissions. As a result, no costis assumed for this equipment.

• B-A&M currently uses enclosed spray booths withappropriate air circulation and filtering mechanisms toreduce particulate emissions and protect worker health andsafety. It is anticipated that this equipment will remain inoperation after the implementation of nonchromate primersinto B-A&M processes, indicating no additional cost in thisarea.

• It is estimated that the labor required to apply a givenvolume of waterborne nonchromate primer will be the sameas the labor required to apply that same volume of acurrently used chromate primer.

• It is assumed that the time ”lost” to the use of protectiveequipment will decrease compared to baseline process,


because less severe health and safety risks are associatedwith the proposed nonchromate waterborne primers.



Table 16. Capital and Annual Operating Cost for WaterborneNonchromate Primer Application


Capture and Control Equipment 0 a


Materials (2,120 gal of mixed primer at anaverage of $53.67/gal)

113,780

Laborb

1. Primer preparation, application, andclean-up (1,060 hr @ $65/hr)

68,900

2. Time required for use of protectiveequipment (32 hr @ $65/hr)

2,080

Waste Management

1. Disposalc of waste primer (50% of2,120 gal (19.3 drums) @ $100/drum)

1,930

2. Disposalc of rags and filters (5.4 drums(298 gal) @ $250/drum)

1,350

3. Waste handling in priming area (53 hr@ $65/hr)

3,445

4. Reporting/administration associatedwith wasted (30 hr @ $90/hr)

2,700

aNo capture and control equipment required

bEstimates are based on and comparable to the currently used chromate primers. Lesstime is needed for protective equipment use.




(Table 16 continued on next page)


Table 16. Capital and Annual Operating Cost for WaterborneNonchromate Primer Application (Continued)


Utilities (electricity, 2915 kW-hr @$0.08/kW-hr)

233


Total/Year 200,000ea

No capture and control equipment requiredb

Estimates are based on and comparable to the currently used chromate primers. Lesstime is needed for protective equipment use.




Replacing the current chromate primers with waterborne nonchromateprimers may generate additional cost savings that are somewhat intangibleand are not calculated here. Some benefits may include:

• Reduced compliance costs• Reduced liabilities for environmental problems at both

on-site and off-site treatment, storage, and disposallocations

• Reduced worker exposure to hazardous materials• Improved community relations.

4.2.4. Waterborne Primer–Estimated Return-on-Investment The application of waterborne nonchromate primer to aircraft exteriormold line skins has been estimated to save approximately $30,000 per yearas compared to the baseline practice of applying chromate primers withHVLP spray equipment. This cost avoidance is expected to occur with noinvestment in processing equipment, leading to an infinite calculatedreturn-on-investment. This cost avoidance was estimated based on CTCassumptions. If this alternative is implemented, the exact cost avoidance achieved willdepend on the details of the primer(s) used, and the specific processing,labor, reporting/compliance, and waste disposal costs incurred by theB-A&M St. Louis facility.


4.3. Electrocoating The following process description is based on a general cathodic electrocoatingprocess. It is not anticipated that B-A&M will replace the current sprayapplication equipment with an electrocoating process because of the relativelyhigh capital investment estimated. Instead, the electrocoating alternative is beingevaluated for comparison purposes only. Both G28AD012 andU32CD210/U32AD290 have been considered for testing, but G28AD012 hasbeen discontinued by the manufacturer, so the following analysis is based on theproperties of U32CD210/U32AD290. Figure 4 below illustrates the flow of the electrocoat primer application process.The term “parts” in the figure refers to aircraft exterior mold line skins.

Parts

PartsQUALITYCHECK

Primer

Waste

PartsRejected (~1%)

Waste

Parts

StrippingSolution

E-COATDIP

29-35°C2-4 minutes

PERMEATERINSE (DIP)

DI WATERRINSE (DIP)

Evaporation(VOCs)

Parts

PrimerRecycle

CURE

175-230°C20-30 minutes

PartsAccepted

(~99%)

STRIP

PartsPERMEATE

RINSE (SPRAY)

Parts

PrimerRecycle

Evaporation(VOCs)

Figure 4. Primer Application by Electrocoating Flow Diagram

An electrocoating process can be used to apply primer to aluminum alloy andother metal substrates. In an electrocoating process, the part to be coated iselectrically charged and immersed in a paint bath of the opposite charge. Bothanodic and cathodic electrocoating systems exist, but the cathodic system, inwhich the substrate is negatively charged, is generally preferred because it createshigher corrosion resistance and does not dissolve the substrate metal. Theelectrocoating bath is agitated to ensure uniform distribution of constituents. For


U32CD210/U32AD290, the bath should be operated at 29°C to 35°C, and the partto be coated should be immersed for two to four minutes. After immersion in the electrocoating bath, the substrate is sprayed with apermeate rinse (water, solvents, low molecular weight resins, and salts) to removeexcess coating and recover drag-out material. The permeate rinse is made byultrafiltering the electrocoat primer to remove solids, and adding deionized waterto achieve the desired concentration. The permeate spray rinse should then befollowed by a permeate dip rinse and a deionized (DI) water dip rinse. TheU32CD210/U32AD290 coating is cured by baking for twenty to thirty minutes at175°C to 230°C. Electrocoated parts can be inspected prior to curing, and unacceptable coatingscan be removed. It has been reported that a wide range of organic solvents aresuitable for removing uncured electrocoat primers; the manufacturer ofU32CD210/U32AD290 recommends a mixture of isopropyl alcohol, acetic acid,and deionized water to remove uncured U32CD210/U32AD290. Because the paint bath is water-based, fire hazards and emissions of VOCs andHAPs are generally reduced over conventional primers. In addition, theelectrocoating process is very efficient, with primer waste amounting toapproximately 2% of the total primer used. Electrocoating also eliminates sagsand runs, and produces a high quality uniform coating.

4.3.1. Electrocoating Alternative Process Equipment The use of electrocoating instead of spray application for the primer willrequire that the spray equipment be replaced by an electrocoat systemconsisting of an electrocoat dip tank, a direct current (DC) rectifier powersupply, and other ancillary equipment to coat the parts.

• Electrocoat Dip Tank – The maximum panel size isassumed to be four ft by eight ft, and the panels areassumed to be essentially flat. This means that a tankintended to hold the electrocoat primer should beapproximately 4 ft wide by 11 ft long by 8 ft deep (fluiddepth of approximately 6 ft and total fluid volume ofapproximately 1,975 gallons). It is assumed that only onepanel can be in the electrocoating tank at a time.

• Chiller for Electrocoat Dip Tank – The electrocoatingprocess generates heat, so a chiller is required to keep thetemperature of the electrocoat bath between 29°C and35°C.


• DC Rectifier Power Supply and Control Panel – A DCrectifier power supply and control panel are required toprovide the appropriate electrical charge difference betweenthe electrocoat bath and the panel to be coated.

• Upgraded Panel Handling System – The currently usedpanel handling system is only required to move panelshorizontally, but the use of an electrocoat dip tank wouldrequire vertical motion of panels as well.

• Permeate Spray Rinse System – This permeate spray rinsesystem should include a collection and recycle system.

• Permeate Dip Rinse System – The tank for dipping thecoated panels into permeate solution should beapproximately 4 ft wide by 11 ft long by 8 ft deep (fluiddepth of approximately 6 ft and total fluid volume ofapproximately 1,975 gallons).

• Deionized Water Dip Rinse System – The tank fordipping the coated panels into deionized water should beapproximately 4 ft wide by 11 ft long by 8 ft deep (fluiddepth of approximately 6 ft and total fluid volume ofapproximately 1,975 gallons).

• Curing System – The electrocoat primer used for thisanalysis, as well as many other electrocoat coatings,requires a heat-curing system.

• Post Curing Ventilation System – The hot-curedelectrocoat will continue to release some organiccompounds after it leaves the curing system; a ventilationsystem will reduce any nuisance caused by this gas release.

4.3.2. Electrocoating Anticipated Material and Energy Usage Table 17 shows an estimate of the material and energy usage required forapplying electrocoat nonchromate primers to aircraft exterior mold lineskins. This estimate is based on the assumptions listed below.


• The average coverage of the baseline chromate primers isapproximately 750 ft2/gal/mil.

• The coverage of an electrocoat nonchromate primer isapproximately 400 ft2/gal/mil.

• The overall application efficiency of electrocoating isassumed to be 98%.

• The area that must be coated remains constant (same asbaseline practice), but only one coat of electrocoat primer


will be applied. This coating should be twice as thick as asingle coat of conventional chromate primer. If it isassumed that all panels to be coated have dimensions offour feet by eight feet, this means that approximately23,450 panels must be coated each year.

• The stripping solution used on rejected parts is ignoredbecause only about 1% of aircraft exterior mold lines needto be stripped and recoated, keeping the quantity of stripperused very small.


Table 17. Material and Energy Usage of Electrocoat Primer forAircraft Exterior Mold Line Skins


Electrocoat Nonchromate Primer 1,800 gal


Electricity needed to:

1. Circulate electrocoat primer

2. Circulate electrocoat dip tank coolant

3. Operate compressor and fans for chillersystem

4. Operate DC rectifier power supply

5. Operate permeate spray rinse

6. Circulate permeate rinse

7. Operate deionized water spray rinse

8. Operate ventilation system exhaust fan

413,600 kW-hr

Natural Gas for Curing System 800,000 ft3

4.3.3. Electrocoating Anticipated–Wastes and Emissions

Table 22 contains an estimate of the quantity of electrocoat primer wastegenerated, based on the assumptions listed below.

• Approximately 2% of the electrocoat primer used is wasted.• The electrocoat nonchromate primer(s) that will be used

contains approximately 96 g/l (0.8 lb/gal of primer) VOCs.• The electrocoat nonchromate primer(s) that will be used

contains approximately 2 lb solids/gal mixed primer.


• The stripping solution used on rejected parts is ignoredbecause only about 1% of aircraft exterior mold lines needto be stripped and recoated, keeping the quantity of stripperused very small.


Table 18. Estimated Wastes and Emissions for Electrocoat PrimerApplication to Aircraft Exterior Mold Line Skins

Waste Quantity/Year

Waste Primer 210 gal


(no chromates)

420 lb


VOCs 1,440 lb a Waste primer solids are a portion of waste solids.

4.3.4. Electrocoating–Anticipated Capital and Operating Costs Table 19 summarizes the estimated costs for the use of nonchromateelectrocoat primers. Costs of removing the current spray system andinstalling the required equipment have been ignored for this analysis.Additional assumptions used in estimating these costs are listed below.

• Based on available information, the average cost of anelectrocoat nonchromate primer was estimated to be $9/gal,and the average coverage was estimated to be425 ft2/gal/mil.

• It is assumed that the time ”lost” to the use of protectiveequipment per labor hour will decrease by approximately70% compared to the baseline process, because less severehealth and safety risks are associated with the proposedelectrocoat primer.




Table 19. Capital and Annual Operating Costfor Electrocoat Nonchromate Primer Application


Capture And Control Equipment 0 a

Initial Primer to Fill Dip Tank (1,975 gal@ $9/gal)

17,775

Initial Primer to Charge Permeate RinseSystems (2,500 gal @ $9/gal)

22,500

Electrocoat Dip Tank with UltrafiltrationSystem

200,000

Chiller System for Electrocoat Dip Tank 50,000

DC Rectifier with Control Panel forElectrocoat Dip Tank

300,000

Upgraded Panel Handling System 200,000

Permeate Rinse Spray System 150,000

Deionized Water Rinse System 50,000

Curing System 150,000

Post-Cure Ventilation System 100,000

Total/Year 1,200,000ba

The existing capture and control system is not suitable for use with an electrocoatingline as proposed; for this analysis, it is assumed that the salvage value of the system isequivalent to the cost of removing the system.

bTotal capital cost and total operating cost estimates rounded to two significant figures.

cEstimates are based on and comparable to the currently used chromate primers. Lesstime is needed for protective equipment use.


(Table 19 continued next page)


Table 19. Capital and Annual Operating Costfor Electrocoat Nonchromate Primer Application (Continued)


Materials (1,800 gal of mixed primer at anaverage of $9/gal)

16,200

Laborc

1. Electrocoating, rinsing, and curingpanels (8,000 hour @ $65/hour; twoshifts, each with two full-time persons)

520,000

2. Time required for use of protectiveequipment (240 hr @ $65/hour)

15,600

Waste Management

1. Disposal of waste rinse solutions(1,500 gal @ $3.00/gal)

4,500

2. Disposal of rags and filters (4 drums @$250/drum)

1,000

3. Waste handling in priming area (80hour @ $65/hr)

5,200

4. Reporting/administration associatedwith wasted (30 hour @ $90/hour)

2,700

Utilities

1. Electricity (413,600 kW-hour @$0.08/kW-hour)

33,088

2. Natural gas (800,000 cubic ft @$6.60/1,000 cubic ft

5,280

Maintenance (800 hour @ $65/hr) 52,000

Total/Year 660,000aa

The existing capture and control system is not suitable for use with an electrocoatingline as proposed; for this analysis, it is assumed that the salvage value of the system isequivalent to the cost of removing the system.

bTotal capital cost and total operating cost estimates rounded to two significant figures.

cEstimates are based on and comparable to the currently used chromate primers. Lesstime is needed for protective equipment use.


Replacing the baseline process with an electrocoating system may generatecost savings that are somewhat intangible and are not calculated here.Some benefits will include:


• Reduced compliance costs• Reduced liabilities for environmental problems at both on-

site and off-site treatment, storage, and disposal locations• Reduced worker exposure to hazardous materials• Improved impact on community relations.

4.3.5. Electrocoating–Estimated Return-on-Investment The installation of an electrocoating system at B-A&M for the purpose ofapplying nonchromate primer to aircraft exterior mold line skins has beenestimated to require a capital investment of over $1 million. Theapplication of electrocoat nonchromate primer to aircraft exterior moldline skins has been estimated to cost approximately $430,000 per yearmore than the baseline practice of applying chromate primers with HVLPspray equipment. This results in a negative return-on-investment, makingthis alternative economically unattractive.

4.4. Sustainment (DoD Depot Community) Implications of Replacing ChromatePrimers The elimination of chromium from the primers used by B-A&M in paintingmilitary aircraft is expected to reduce costs associated with handling and disposalof hazardous materials. Further cost avoidance will be realized during recurringmaintenance performed by the Sustainment Community.

B-A&M and government depots/air logistics centers provided information aboutthe maintenance needs and programmed depot maintenance (PDM) cycles for theaircraft in question. This information included:

• Number of aircraft through PDM each year through 2024 − thisincludes the planned production of new aircraft and phase-out ofold aircraft

• Exterior surface area of aircraft• Quantity of plastic media blasting (PMB) pellets required per

aircraft surface area• Costs associated with PMB, including disposal• Personnel required for the PDM depaint and paint processes• Personal protective equipment (PPE) requirements• Costs associated with PPE, including training, and lost productivity

due to time required for changing into and out of PPE and reduceddexterity while wearing PPE.


4.4.1. Cost Avoidance Implications for Replacing Chromate Primers withNonchromate Primers CTC estimated that PPE requirements would remain constant if chromateconversion coatings continue to be used under nonchromate primers. Notethat in actual practice PPE requirements may decrease due to lesschromium. Elimination of chromium in primers would decrease the totalamount of chromate per aircraft, decreasing HazMat disposal costs. CTCfurther assumed that aircraft free of chromate primer will enter the PDMcycle in the year 2005. Cumulative cost avoidance for this case, ignoringany potential for decreased PPE, is estimated to be approximately$1 million for the 20-year period from 2005 through 2024.

4.4.2. Cost Avoidance Implications for Eliminating Chromium fromAircraft Exteriors For the purposes of this analysis, CTC assumed that complementarytechnology to replace chromate conversion coating (currently used onaluminum alloys under the primer) will soon become available for use atthe depots/air logistics centers, thereby eliminating all chromate fromaircraft exterior surfaces and making the maintenance cycle chromium-free. CTC made additional assumptions as listed below.

• The first aircraft free of chromate will enter the PDM cyclein the year 2005. Note that the date of implementation ofnonchromate primers will affect this date.

• No changes in the purchase costs of PMB, primer, or otherchemicals are expected.

• The elimination of chromate will decrease PMB disposalcosts.

• The elimination of chromate will prevent approximately$11,600 per worker per year in PPE, training, and lostproductivity costs.

Based on the PDM throughput data and the above assumptions, thecumulative cost avoidance in the PDM cycle associated with theelimination of chromate from aircraft exteriors was estimated to beapproximately $30 million, in constant 1995 dollars, over the 20-yearperiod from 2005 through 2024.


5. PRELIMINARY ESOH ANALYSIS OF VIABLE ALTERNATIVES

As part of the selection of potential alternatives, each viable alternative was qualitativelyassessed for associated ESOH concerns. This initial assessment was conducted toidentify any conspicuous ESOH issues that may need to be addressed when selectingalternatives for testing. The criteria used for this analysis are described in Section 2.3 ofthis PAR. The results of the ESOH analysis are contained in Appendix D andsummarized below.

Using available resources, each viable alternative was evaluated to determine the extentof its regulation under major federal environmental laws: CAA, RCRA, CWA,Section 313 of EPCRA, and CERCLA. In addition, the constituents of each candidatenonchromate primer were compared to the EPA 17 list. The criteria used for thisevaluation are described in Section 2.3.1 of this PAR. Each alternative process will begoverned, to a greater or lesser extent, by federal environmental laws and regulations.Even constituents that are heavily regulated under one or more of these laws are stillavailable for use by facilities, although most facilities wisely restrict their use.

Each viable alternative was given a toxicity rating, exposure rating, and an overall hazardrating based on the criteria explained in Section 2.3.2 of this PAR. Toxicity ratings andexposure ratings of high, medium, or low were assigned to candidate products based onthe analysis of the available literature, the relative quantities of each constituent in eachproduct, and best professional judgement. Parameters reviewed included LC50, LD50,PELs promulgated by OSHA, and TLVs issued by the ACGIH. The hazard rating foreach product is a combination of the toxicity rating and exposure rating, and gives anoverall safety and occupational health rating to the viable alternative.

A summary of the results of the ESOH analysis can be found in Table 20.


Table 20. Summary Results for Nonchromate Primer Environmental, Safety, and Occupational Health Analysis

Air Emissions Wastes Generated Waste- TRI CERCLA EPA 17Product TR ER HR HAPs VOCs ODSs Solid Hazardous water Report HazSub List

02-W-38 M M M 2 Yes No Yes Yes Yes 4 3 110P22-3/EC-270 M H M-H 6 Yes No Yes Yes Yes 3 4 4Aeroglaze 9740 M M-H M 0 Yes No Yes Yes Yes 1 2 0Aeroglaze 9741 M M-H M 0 Yes No Yes Yes Yes 1 2 0EEAE136 A/B M H M-H 2 Yes No Yes Yes Yes 2 3 2U-1201-NC/U-1202-F M H M-H 2 Yes No Yes Yes Yes 2 3 2AlumigripR1204/S3800

M H M-H 3 Yes No Yes Yes Yes 4 4 3

RW-3151-64 M M-H M 3 Yes No Yes No Yes 1 1 0RW-3181-64 M M-H M 3 Yes No Yes No Yes 1 1 044-W-16 M M M 0 Yes No Yes Yes No 1 0 044-W-17 M M M 0 Yes No Yes Yes No 1 0 044-W-18 M M M 0 Yes No Yes Yes No 1 0 010PW22-2/ECW-119 M M-H M 9/5a Yes No Yes Yes Yes 8 8 410PW22-3/ECW-123 M M M 8/4a Yes No Yes Yes Yes 7 7 4EWDY048 A/B M M-H M-H 1 Yes No Yes No No 1 1 0EWAE118 A/B M H M-H 1 Yes No Yes No No 2 1 0U-4800-NC/U-4801 M M M 4 Yes No Yes No No 1 2 0G28AD012 M M M 1 Yesb No Yes No No 1 1 0U32CD210/U32AD290 M H M-H 2 Yes No Yes No No 2 1 0

TR = Toxicity Rating; ER = Exposure Rating; HR = Hazard RatingL = Low; M = Medium; M-H = Medium to High; H = Higha

Four of the identified chemicals that could contribute to HAPs emitted by this primer (arsenic, cadmium, lead, and beryllium) are reported to be present innonvolatile form.

bThe quantity of VOCs associated with the use of this product is unknown, but the presence of 2-butoxyethanol (ethylene glycol monobutyl ether) in theproduct makes it likely that VOCs are released at some measurable level.


6. SELECTION OF POTENTIAL ALTERNATIVES

Table 21 lists the nonchromate primers the participants selected to undergo screeningtests as described in the JTP (MD-P-1-1).

Table 21. Nonchromate Primers Selected for Screening Tests

Primer Type Designation Manufacturer

High-Solids 02-W-38 Deft, Inc.

High-Solids 10P22-3/EC-270 Dexter Aerospace Materials/Crown Metro Aerospace



High-Solids EEAE136 A/B Spraylat Corporation

High-Solids U-1201-NC/U-1202-F Sterling Lacquer Manufacturing Company

High-Solids Alumigrip R1204/S3800 U.S. Paint Corporation








Waterborne EWDY048 A/B Spraylat Corporation

Waterborne EWAE118 A/B Spraylat Corporation

Waterborne U-4800-NC/U-4801 Sterling Lacquer Manufacturing Company

Electrocoat G28AD012 BASF Corporation


7. SUMMARY

At the B-A&M facility in St. Louis, Missouri, chromate primers are currently applied toaircraft exterior mold line surfaces to provide corrosion resistance and improve topcoatadhesion. These primers are most commonly applied to aluminum alloys, but othersubstrates such as steel, composites, and titanium are also present on aircraft exteriorsurfaces and will be coated by these primers. As part of the JG-APP pilot program,chromium in these primers was targeted for elimination or reduction.

A number of nonchromate primers having potential to replace chromium primer coatingswere identified through literature searches and direct vendor queries in early 1996.Manufacturers and distributors of the identified alternatives were contacted and technical,environmental, safety, and occupational health information about the alternatives werecompared with the baseline process. Seventeen high-solids or waterborne nonchromateprimers were classified as potentially viable alternatives based on available informationand the judgement of the participants. In addition, the participants agreed to investigateat least one electrocoat primer, even though electrocoat primers are not viable for fullaircraft paint and repaint, and the estimated capital costs make this alternativeeconomically unattractive. The key process characteristics of these alternatives werecompared to those of the existing process, and the ESOH characteristics of these viablenonchromate primers were evaluated.

These 17 high-solids or waterborne nonchromate primers, as well as one electrocoatnonchromate primer, were classified as potential alternatives to be subjected to screeningtests in accordance with the JTP. The results of the screening tests were used to select asmaller number of nonchromate primers to undergo more laboratory tests in accordancewith the JTP. After the laboratory testing has been completed, a small number ofnonchromate primers were selected for field evaluation in accordance with the JTP. Theresults of laboratory testing are reported in the Joint Test Report (MD-R-1-1) forLaboratory Validation (Testing) of Alternatives to Chromate-Containing PrimerCoatings for Aircraft Exterior Mold Line Skins, dated February 24, 1998. The results ofoperational testing will be reported in the Joint Test Report (MD-R-1-2) for FieldEvaluation and Validation of Alternatives to Chromate-Containing Primer Coatings forAircraft Exterior Mold Line Skins.

If any high-solids or waterborne nonchromate primer meets performance requirementsand is implemented, B-A&M may experience reduced operating costs due to reducedhazardous waste generation and worker exposure to hazardous materials. CTC hasestimated that B-A&M operating costs may decrease by $30,000 to $70,000 per year. Inaddition, replacement of chromate primers with nonchromate primers at DoDmaintenance facilities has been estimated to result in cost avoidance of at least $1 milliondollars over 20 years from 2005 through 2024. The exact cost avoidance realized inaircraft production and maintenance will depend on such factors as the primer(s) used andthe characteristics of each facility using nonchromate primer(s).

APPENDIX A

Environmental, Safety, And Occupational Health (ESOH) Analysis ofCurrently Used Chromate Primers

Potential Alternatives Report A-i

TABLE OF CONTENTS

Page

A.1. INTRODUCTION...........................................................................................................A-1

A.2. BACKGROUND INFORMATION FOR ESOH ANALYSIS OF CURRENTLY USEDCHROMATE PRIMERS ................................................................................................A-2A.2.1. Environmental Analysis ......................................................................................A-2A.2.2. Safety and Occupational Health Analysis ...........................................................A-2

A.3. ESOH ANALYSIS OF CURRENTLY USED CHROMATE PRIMERS......................A-5A.3.1. 515X379/910X563 (Courtaulds Aerospace).......................................................A-6

A.3.1.1. Environmental Issues ...........................................................................A-7A.3.1.2. Safety and Occupational Health Issues ................................................A-8

A.3.2. 515X386/910X831 (Courtaulds Aerospace).....................................................A-10A.3.2.1. Environmental Issues .........................................................................A-11A.3.2.2. Safety and Occupational Health Issues ..............................................A-12



A.3.5. 10P20-12/EC-212 (Dexter Aerospace Materials Division/Crown MetroAerospace).........................................................................................................A-22A.3.5.1. Environmental Issues .........................................................................A-23A.3.5.2. Safety and Occupational Health Issues ..............................................A-25

A.3.6. EEAY051 A/B (Spraylat Corporation) .............................................................A-27A.3.6.1. Environmental Issues .........................................................................A-28A.3.6.2. Safety and Occupational Health Issues ..............................................A-29

A.3.7. 44-GN-36 (Deft, Inc.)........................................................................................A-31A.3.7.1. Environmental Issues .........................................................................A-31A.3.7.2. Safety and Occupational Health Issues ..............................................A-32

A-ii Potential Alternatives Report

LIST OF TABLES

Page

Table A-1. Background ESOH Analysis of Currently Used Chromate Primers ...................A-4Table A-2. Ingredients of Courtaulds Aerospace 515X379/910X563 ..................................A-6Table A-3. ESOH Analysis of Courtaulds Aerospace 515X379/910X563.........................A-10Table A-4. Ingredients of Courtaulds Aerospace 515X386/910X831 ................................A-11Table A-5. ESOH Analysis of Courtaulds Aerospace 515X386/910X831.........................A-14Table A-6. Ingredients of Courtaulds Aerospace 515X332/910X457 ................................A-15Table A-7. ESOH Analysis of Courtaulds Aerospace 515X332/910X457.........................A-18Table A-8. Ingredients of Courtaulds Aerospace 513X408/910X831 ................................A-19Table A-9. ESOH Analysis of Courtaulds Aerospace 513X408/910X831.........................A-22Table A-10. Ingredients of Dexter Aerospace Materials/Crown Metro Aerospace

10P20-12/EC-212..............................................................................................A-23Table A-11. ESOH Analysis of Dexter Aerospace Materials Division/Crown Metro Aerospace

10P20-12/EC-212..............................................................................................A-26Table A-12. Ingredients of Spraylat EEAY051 A/B .............................................................A-27Table A-12. Ingredients of Spraylat EEAY051 A/B (Continued).........................................A-28Table A-13. ESOH Analysis of Spraylat EEAY051 A/B......................................................A-30Table A-14. Ingredients of Deft 44-GN-36 ...........................................................................A-31Table A-15. ESOH Analysis of Deft 44-GN-36....................................................................A-34


Potential Alternatives Report A-1

A.1. INTRODUCTION

The environmental, safety, and occupational health (ESOH) analysis below containsdetailed descriptions of ESOH characteristics of the currently used chromate primers, as asupplement to the summary presented in Section 2.3 of this Potential Alternative Report(PAR). This analysis is intended to provide appropriate information for comparing theESOH characteristics of the currently used chromate primers with the characteristics ofthe viable alternative nonchromate primers (see Section 5 and Appendix D).

Because of the limited scope of this ESOH analysis, this analysis provides a generaloutline of the ESOH characteristics of the currently used chromate primers and may notreveal every possible deficiency or hazard. Concurrent Technologies Corporation (CTC)assumes no responsibility for the safe operation and maintenance of the manufacturingtechnology or for any environmental, safety, and occupational health hazards or releasesresulting from operation and maintenance of the manufacturing technology.

A-2 Potential Alternatives Report

A.2. BACKGROUND INFORMATION FOR ESOH ANALYSIS OF CURRENTLYUSED CHROMATE PRIMERS

A.2.1. Environmental Analysis

Each currently used chromate primer may be governed, to a greater or lesser extent, by federalenvironmental laws and regulations. Therefore, a regulatory review of each currently used chromateprimer was conducted as part of the ESOH analysis. Each chromate primer was reviewed todetermine the extent of its regulation under the Clean Air Act (CAA); Clean Water Act (CWA);Resource Conservation and Recovery Act (RCRA); Emergency Planning and Community Right-to-Know Act (EPCRA); and Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA). Currently used chromate primers were also compared to the United StatesEnvironmental Protection Agency’s (EPA’s) list of 17 high-risk priority chemicals, called the “EPA17” list. Even chromate primers containing ingredients that are heavily regulated under one or moreof these laws are still available for use by facilities, although most facilities wisely restrict their use.

A currently used chromate primer is only described as having “failed”environmental criteria on regulatory grounds if it contains a constituent whose usehas been banned, or is scheduled to be banned, by EPA. Otherwise, the currentlyused chromate primer “passes” this background analysis.

A.2.2. Safety and Occupational Health Analysis

Each identified constituent of the currently used chromate primers, when available, was reviewed interms of its potential toxicity as a known or suspected human carcinogen, human genotoxicant,human teratogen, or human neurotoxicant. Each of these categories is briefly defined and describedbelow.

• Human Carcinogen: Those agents, including organic andinorganic compounds that have an ability to induce carcinomas(cancer) in humans. For this background analysis, thoseconstituents that show clear or suspected evidence of carcinogenicactivity in humans (as concluded by the National ToxicologyProgram (NTP), EPA’s Office of Science and TechnologyWeight-of-Evidence Policy, and/or the International Agency forResearch on Cancer (IARC) guidelines) are considered to behuman carcinogens.

• Human Genotoxicant: Those agents determined or suspected to bedeoxyribonucleic acid (DNA)-reactive (genotoxic), where availableinformation is sufficient, are considered to be humangenotoxicants.

• Human Teratogen: Those agents that are determined or suspectedto cause any detrimental effect (structural or functional) duringembryonic development after exposure are considered to be


teratogens. Such exposure may occur before conception or duringpregnancy.

• Human Neurotoxicant: Those agents that are determined orsuspected to cause toxic effects to the human nervous system fromexposure at expected occupational concentrations are considered tobe neurotoxicants.

Those chromate primers containing constituents determined to be known orsuspected toxicants in the categories listed above, based on available literature,are noted as “failed.” Those chromate primers containing constituents, for whichdata are not sufficient to classify the primer constituents as known or suspectedhuman toxicants, are noted as “passed.” The results of the ESOH analysisperformed using these criteria are summarized in Table A-1. A more detailedESOH analysis of the currently used chromate primers is contained inSection A.3.


Table A-1. Background ESOH Analysis of Currently Used Chromate Primers

HEALTH AND SAFETY CRITERIA

Product Carcinogen Teratogen Genotoxicant Neurotoxicant Environmental Known Suspected Known Suspected Known Suspected Known Suspected Criteria

515X379/910X563 Fail Fail Pass Pass+ Fail Fail Fail Fail Pass 515X386/910X831 Fail Fail Pass Pass+ Pass Pass+ Fail Fail Pass 513X332/910X457 Fail Fail Pass Pass+ Pass Pass+ Fail Fail Pass 513X408/910X831 Fail Fail Pass Pass+ Pass Pass+ Fail Fail Pass 10P20-12/EC212 Fail Fail Pass Pass+ Fail Fail Fail Fail Pass EEAY051 A/B Fail Fail Pass Pass+ Fail Fail Fail Fail Pass 44-GN-36 Fail Fail Pass Pass+ Pass Pass+ Pass Pass Pass

+ Experimental animal data have been noted. Note: Because of the limited scope of this ESOH analysis, this analysis provides only a general outline of the ESOH characteristics of the currently used

chromate primers and may not reveal every possible deficiency or hazard. CTC assumes no responsibility for the safe operation and maintenance of themanufacturing technology or for any environmental, safety, and occupational health hazards or releases resulting from operation and maintenance of themanufacturing technology.


A.3. ESOH ANALYSIS OF CURRENTLY USED CHROMATE PRIMERS This section describes in detail the ESOH impact of the currently used chromate primers(refer to Section 2.3 of this PAR). Each product discussion includes a description ofchemicals of concern, an analysis of regulatory concerns, summaries of acute and chronicexposure effects, toxicity and exposure ratings, and suggested personal protectiveequipment. This information was obtained by analyzing Material Safety Data Sheets(MSDSs) from the vendors of the current products as well as other reference materials.Please note that the current permissible exposure limit (PEL) for airborne chromates is0.1 mg/m3, measured as chromium trioxide (CrO3); for the purpose of this analysis, thisnumber has been converted to an equivalent level of 0.05 mg/m3, measured as chromium(Cr). Using available resources, each currently used chromate primer was evaluated todetermine the extent of its regulation under major federal environmental laws: CAA,RCRA, CWA, Section 313 of EPCRA, and CERCLA. In addition, the constituents ofeach chromate primer were compared to the EPA 17 list. The criteria used for thisevaluation are described in Section 2.3.1 of this PAR. Each primer will be governed, to agreater or lesser extent, by federal environmental laws and regulations. Even constituentsthat are heavily regulated under one or more of these laws are still available for use byfacilities, although most facilities wisely restrict their use. Each currently used chromate primer was given a toxicity rating, exposure rating, and anoverall hazard rating based on the criteria explained in Section 2.3.2 of this PAR.Toxicity ratings and exposure ratings of high, medium, or low were assigned to theprimers based on analysis of the available literature, the relative quantities of eachconstituent in each product, and best professional judgment. Parameters reviewedincluded median lethal concentrations (LC50), median oral lethal doses (LD50), PELspromulgated by the Occupational Safety and Health Administration (OSHA), andthreshold limit values (TLVs) issued by the American Conference of GovernmentIndustrial Hygienists (ACGIH). The hazard rating for each product is a combination ofthe toxicity rating and exposure rating, and gives an overall safety and occupationalhealth rating to the viable alternative. This ESOH analysis can be used to make direct comparisons to the ESOH issuesassociated with viable alternative nonchromate primers (refer to Section 5 of this PAR,and Appendix D). A summary of the following ESOH analysis of the currently used chromate primers maybe found in Table 7 in Section 2.3 of this PAR.


A.3.1. 515X379/910X563 (Courtaulds Aerospace) Courtaulds Aerospace 515X379/910X563 epoxy primer is supplied as a basecomponent (515X379) and a curing solution (910X563). In preparation forapplication, the base component is mixed with the curing solution. The mixedprimer contains approximately 500 g/l volatile organic compounds (VOCs). Theingredients of the two parts of the primer, as reported on the MSDSs, are listed inTable A-2.

Table A-2. Ingredients of Courtaulds Aerospace 515X379/910X563

Chemical CAS # Percentage(by Mass)

OSHAPEL

ACGIHTLV

515X379 (base)

NonhazardousAdditives, Resin,and Pigments

N.E. 25 N.E. N.E.

Toluene 00108-88-3 15 100 ppm 50 ppm Methyl n-AmylKetone

00110-43-0 <5 100 ppm 50 ppm

Strontium Chromate 07789-06-2 20 0.05mg/m3 asCr

0.0005mg/m3 as Cr

Titanium Dioxide 13463-67-7 <5 3.0 mg/m3

as Dust 3.0 mg/m3 asDust

Xylene 01330-20-7 10 100 ppm 100 ppm Ethyl Benzene 00100-41-4 <5 100 ppm 100 ppm Isopropyl Alcohol 00067-63-0 <5 400 ppm 400 ppm Methyl Ethyl Ketone 00078-93-3 5 200 ppm 200 ppm Talc 14801-96-6 15 0.5 mg/m3


Crystalline Silica(quartz, silicondioxide)

14808-60-7 <1 0.02mg/m3 asDust

0.02 mg/m3

as Dust

910X563 (curing solution)

Isopropyl Alcohol 00067-63-0 35 400 ppm 400 ppm Toluene 00108-88-3 45 100 ppm 50 ppm Polyamide Resin 68082-29-1 15 N.E. N.E. TriethyleneTetramine

00112-24-3 <5 N.E. N.E.

N.E. = Not Established


A.3.1.1. Environmental Issues

A brief regulatory analysis of Courtaulds Aerospace 515X379/910X563epoxy primer is provided below.

• Air Emissions: The 515X379/910X563 epoxy primer

contains five constituents that are hazardous air pollutants(HAPs), methyl ethyl ketone, chromium (in strontiumchromate), toluene, ethyl benzene, and xylene. Althoughthere are no ozone-depleting substances (ODSs) present in515X379/910X563, the combined VOC content of theprimer and activator is approximately 500 grams per liter.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 515X379/910X563 epoxy primer may beclassified as RCRA D001 ignitable wastes due to the lowflash point of this product. At least five constituents of515X379/910X563 may generate hazardous waste: methylethyl ketone, toluene, xylene, ethyl benzene, and strontiumchromate. Methyl ethyl ketone is listed as hazardous wastenumbers D035, F005, and U159; toluene is listed as F005and U220; xylene is listed as F003 and U239; ethyl benzeneis listed as F003; and strontium chromate is listed as D007.

• Wastewater Discharges: Under the CWA, the use of515X379/910X563 may result in waste streams containingany of five regulated chemicals: xylene, toluene, ethylbenzene, chromium (in strontium chromate), and methyln-amyl ketone. Xylene, toluene, ethyl benzene, andchromium are designated hazardous substances underCWA Section 311. Toluene, ethyl benzene, and chromiumare designated under the CWA as both toxic and prioritypollutants. Toluene, ethyl benzene, and methyl n-amylketone are listed as pretreatment pollutants. In addition,effluent limitation guidelines have been developed fortoluene, ethyl benzene, and chromium.

• Reporting Requirements: The following constituents of515X379/910X563 are required to be listed on ToxicsRelease Inventory (TRI) reports under EPCRA Section 313:methyl ethyl ketone, toluene, xylene, isopropyl alcohol,ethyl benzene, and strontium chromate (containschromium).

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: methyl ethyl ketone, toluene,xylene, ethyl benzene, and chromium (in strontiumchromate).


• EPA 17: Four of the constituents of 515X379/910X563,methyl ethyl ketone, toluene, chromium, and xylene, areincluded on the EPA 17 list of chemicals targeted for strictregulation.

A.3.1.2. Safety and Occupational Health Issues

An overall medium to high hazard rating is given to 515X379/910X563chromate primer. This rating is based on a determination that515X379/910X563 has a medium toxicity rating and a high exposurerating. The medium to high hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be thoroughly reviewed and properly implemented for workerhealth and safety. Constituents of concern and exposure effects arediscussed below. Constituents of concern in 515X379/910X563 include titanium dioxide,crystalline silica (quartz), strontium chromate, toluene, xylene, ethylbenzene, methyl n-amyl ketone, methyl ethyl ketone, isopropyl alcohol,and triethylene tetramine. Strontium chromate is a known humancarcinogen, and titanium dioxide and crystalline silica are suspectedhuman carcinogens. Ethyl benzene is a known human genotoxicant.Toluene, xylene, ethyl benzene, methyl ethyl ketone, and isopropyl alcoholare known human neurotoxicants. No other known or suspected humancarcinogens, teratogens, genotoxicants or neurotoxicants were noted in515X379/910X563 primer. However, experimental laboratory animalteratogenic/reproductive toxicity data were identified for toluene, xylene,ethyl benzene, isopropyl alcohol, and triethylene tetramine. Test results inlaboratory animals and lower organisms (e.g., bacteria) also indicate thattoluene, xylene, isopropyl alcohol, strontium chromate, and triethylenetetramine are genotoxicants. Toxic effects for the constituents of concernmay range from irritation of the respiratory tract to dizziness andheadaches. Additional health effects of the primer constituents arediscussed below.

• Acute Effects: Acute overexposure to ingredients in thisprimer may cause narcotic effects characterized byweakness, dizziness, headaches, and nausea with vomiting.The agent may cause asphyxiation at higher concentrations.Contact with eyes, skin, respiratory tract, or mucousmembranes will cause irritation. Ingestion may causegastrointestinal irritation, nausea, and diarrhea.


• Chronic Effects: Prolonged and repeated contact with thisproduct can cause permanent damage to the brain andnervous system. Animals receiving repeated and prolongeddoses of components of this product develop damage to theheart, adrenals, kidneys, liver, lung, and spleen. Ulcerationof the nasal septum is an effect of chronic chromiuminhalation exposure. Constituents of this product areknown or suspected to cause cancer in humans.

Chromate primer 515X379/910X563 was assigned a medium toxicityrating based on published toxicity data (LD50 and LC50) for individualconstituents. Based on published exposure limits (PEL and TLV) of itsingredients, 515X379/910X563 was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be used during theprocess, and administrative controls may be appropriate (e.g., exposure timelimits and job sharing). Also, all ignition sources should be removed. Personalprotective equipment is required for worker health protection throughout theprocess, and must include protective clothing (e.g., eye protection and chemical-resistant gloves), approved fitted respirators, and approved emergency facilities(e.g., eye wash station and shower).

A summary of the ESOH analysis of Courtaulds Aerospace515X379/910X563 epoxy primer is provided in Table A-3.


Table A-3. ESOH Analysis of Courtaulds Aerospace515X379/910X563

Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions - HAPs 5 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Wastewater Discharged Yes TRI Reporting 6 CERCLA Hazardous Substances 5 EPA 17 Constituents 4

a The toxicity rating is based on the criteria described in Section 2.3.2.

b The exposure rating is based on criteria described in Section 2.3.2.

c The hazard rating is determined by considering the toxicity ratings and exposureratings of the individual constituents and the relative quantities of each constituent.

Additional Supporting Literature

• DeSoto Aerospace Coatings, Inc., “515X379,” Material

Safety Data Sheet, February 28, 1991• Courtaulds Aerospace, “910X563 Epoxy Polyamide

Activator,” Material Safety Data Sheet, July 18, 1995.

A.3.2. 515X386/910X831 (Courtaulds Aerospace) Courtaulds Aerospace 515X386/910X831 waterborne epoxy primer meets therequirements of MIL-P-85582B Type II, Class C2. It is supplied as a base component(515X386) and a curing solution (910X831). In preparation for application, three partsby volume of the base component is mixed with one part of the curing solution. Themixed primer contains approximately 340 g/l VOCs. The mixed primer may be reduced(thinned) with deionized water if a lower viscosity is desired. The ingredients of the twoparts of the primer, as reported on the MSDSs, are listed in Table A-4.




OSHAPEL

ACGIH TLV

515X386 (base)

Epoxy Resin 68334-76-9 20 N.E. N.E. 2-Propoxyethanol(ethylene glycolmonopropyl ether)

02807-30-9 10 N.E. N.E.

StrontiumChromate

07789-06-2 10 0.05 mg/m3

as Cr 0.0005 mg/m3

as Cr Carbon Black 01333-86-4 <5 3.5 mg/m3


Silica AluminaCeramic Alloy

07732-18-5 N.R. N.E. N.E.

Iron Oxide Hydrate 51274-00-1 N.R. N.E. N.E. 910X831 (curing solution)

2-Butoxyethanol(ethylene glycolmonobutyl ether)

00111-76-2 15 50 ppm(skin)

25 ppm (skin)

ModifiedPolyamine

N.E. 20 N.E. N.E.

2-Propoxyethanol 02807-30-9 15 N.E. N.E. N.E. = Not Established N.R. = Percentage Not Reported

In addition, the manufacturer recommends that a TLV of 25 ppm be observed for2-propoxyethanol (ethylene glycol monopropyl ether).


A brief regulatory analysis of Courtaulds Aerospace 515X386/910X831waterborne epoxy primer is provided below.

• Air Emissions: The 515X386/910X831 waterborne epoxy

primer contains three constituents that are HAPs,2-propoxyethanol, 2-butoxyethanol, and chromium (instrontium chromate). Although there are no ODSs presentin 515X386/910X831, the combined VOC content of thebase component and curing solution is approximately340 grams per liter.

• Solid/Hazardous Waste Generation: At least oneconstituent of 515X386/910X831, strontium chromate, may


generate hazardous waste. Due to its toxicity, strontiumchromate is listed as hazardous waste number D007.

• Wastewater Discharges: Under the CWA, the use of515X386/910X831 may result in waste streams containingeither or both of two regulated chemicals: chromium (instrontium chromate) and 2-butoxyethanol. Chromium isdesignated as a hazardous substance under CWASection 311. Spills or other discharges of CWA hazardoussubstances into navigable waters must be reported when theamount meets or exceeds the substance’s reportablequantity. Chromium is designated under the CWA as botha toxic and a priority pollutant. Toxic and prioritypollutants must be treated before they can be discharged toreceiving waters or a publicly owned treatment work(POTW). 2-Butoxyethanol is listed as a pretreatmentpollutant. Pretreatment pollutants must undergopretreatment to ensure that their discharge to a POTW iscompatible with the capabilities of that POTW. In addition,effluent limitation guidelines have been developed forchromium. Effluent limitations establish a minimum levelof treatment that is required for all direct dischargers in anindustry category based upon the application of variouscontrol technologies.

• Reporting Requirements: The following constituents of515X386/910X831 are required to be listed on TRI reportsunder EPCRA Section 313: 2-propoxyethanol,2-butoxyethanol, and strontium chromate (containschromium).

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: 2-propoxyethanol,2-butoxyethanol, and chromium (in strontium chromate).

• EPA 17: One of the constituents of 515X386/910X831,chromium (in strontium chromate), is included on theEPA 17 list of chemicals targeted for strict regulation.


An overall medium to high hazard rating is given to 515X386/910X831chromate primer. This rating is based on a determination that515X386/910X831 has a medium toxicity rating and a high exposure rating. Themedium to high hazard rating indicates that an overall moderate to high ESOHconcern is caused by the chemical toxicity and worker exposure properties ofthis alternative. Worker exposure controls should be thoroughly reviewed and


properly implemented for worker health and safety. Constituents of concern andexposure effects are discussed below.

Constituents of concern in 515X386/910X831 include strontium chromate,carbon black, 2-propoxyethanol and 2-butoxyethanol. Both2-propoxyethanol and 2-butoxyethanol may be absorbed through the skin.Strontium chromate is a known human carcinogen and carbon black is asuspected human carcinogen. 2-Butoxyethanol is a known humanneurotoxicant. No other known or suspected human carcinogens,teratogens, genotoxicants or neurotoxicants were noted in this chromateprimer. However, experimental laboratory animal teratogenic data wereidentified for 2-propoxyethanol and 2-butoxyethanol. Strontium chromateis a known genotoxicant in laboratory animals. Toxic effects for theconstituents of concern may range from irritation of the respiratory tract todizziness and headaches. Additional health effects of the primerconstituents are discussed below.

• Acute Effects: Contact with eyes, skin, respiratory tract, ormucous membranes will cause irritation.

• Chronic Effects: Animals receiving repeated andprolonged doses develop hemolytic anemia and damage tothe kidneys and liver. Ulceration of the nasal septum is aneffect of chronic chromium inhalation exposure.Constituents of this product are known or suspected tocause cancer in humans.

Chromate primer 515X386/910X831 was assigned a medium toxicityrating based on published toxicity data (LD50 and LC50) for individualconstituents. Based on published exposure limits (PEL and TLV) of itsingredients, 515X386/910X831 was given a high exposure rating.

Appropriate engineering controls (e.g., local ventilation) must be used during theprocess, and administrative controls may be appropriate (e.g., exposure timelimits and job sharing). Also, all ignition sources should be removed. Personalprotective equipment is required for worker health protection throughout theprocess, and must include protective clothing (e.g., eye protection and chemical-resistant gloves), approved fitted respirators, and approved emergency facilities(e.g., eye wash station and shower).

A summary of the ESOH analysis of Courtaulds Aerospace515X386/910X831 waterborne epoxy primer is provided in Table A-5.



Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions – HAPs 3 Air Emissions – VOCs Yes Air Emissions – ODSs No Wastes Generated – Solid Yes Wastes Generated – Hazardous Yes Wastewater Discharged Yes TRI Reporting 3 CERCLA Hazardous Substance 3 EPA 17 Constituents 1





• Courtaulds Aerospace, “MIL-P-85582A Ty II Cl 2,”

Product Information – Primer, September 1993• Courtaulds Aerospace, “515X386,” Material Safety Data

Sheet, July 15, 1994• Courtaulds Aerospace, “910X831,” Material Safety Data

Sheet, September 25, 1995• QPL-85582-4, “Qualified Products List of Products under

Military Specification MIL-P-85582, Primer Coatings:Epoxy, Waterborne,” December 30, 1994.

A.3.3. 515X332/910X457 (Courtaulds Aerospace) Courtaulds Aerospace 515X332/910X457 epoxy primer is supplied as a base component(515X332) and a curing solution (910X457). In preparation for application, one part byvolume of the base component is mixed with one part of the curing solution. The mixedprimer contains approximately 600 g/l VOCs. The ingredients of the two parts of theprimer, as reported on the MSDSs, are reported in Table A-6.




OSHAPEL

ACGIHTLV

515X332 (base)

n-Butyl Acetate 00123-86-4 15 150 ppm 150 ppm Epoxy Resin 68334-76-9 20 N.E. N.E. Toluene 00108-88-3 10 100 ppm 50 ppm Methyl EthylKetone

00078-93-3 15 200 ppm 200 ppm

Cyclohexanone 00108-94-1 <5 25 ppm(skin)

25 ppm (skin)

StrontiumChromate

07789-06-2 10 0.05 mg/m3

as Cr 0.0005mg/m3 as Cr



Crystalline Silica(quartz)

14808-60-7 15 0.02 mg/m3

as Dust 0.02 mg/m3

as Dust Amorphous Silica 112926-00-8 <5 15 mg/m3

as Dust 10 mg/m3 asDust


Isopropyl Alcohol 00067-63-0 55 400 ppm 400 ppm Toluene 00108-88-3 25 100 ppm 50 ppm Polyamide Resin 68082-29-1 15 N.E. N.E. TriethyleneTetramine

00112-24-3 <5 N.E. N.E.



A brief regulatory analysis of Courtaulds Aerospace 515X332/910X457epoxy primer is provided below.

• Air Emissions: The 515X332/910X457 epoxy primer

contains three constituents that are HAPs, methyl ethylketone, chromium (in strontium chromate), and toluene.Although there are no ODSs present in 515X332/910X457,the combined VOC content of the primer and activator isapproximately 600 g/l.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 515X332/910X457 may be classified as RCRAD001 ignitable wastes due to the low flash point of this


product. At least four constituents of 515X332/910X457may generate hazardous waste: methyl ethyl ketone,toluene, cyclohexanone, and strontium chromate. Methylethyl ketone is listed as hazardous waste numbers D035,F005, and U159, toluene is listed as F005 and U220,cyclohexanone is listed as F003 and U057, and strontiumchromate is listed as D007.

• Wastewater Discharges: Under the CWA, the use of515X332/910X457 may result in waste streams containingany of four regulated chemicals: toluene, chromium (instrontium chromate), n-butyl acetate, and cyclohexanone.Toluene, n-butyl acetate, and chromium are designatedhazardous substances under CWA Section 311. Tolueneand chromium are designated under the CWA as both toxicand priority pollutants. Toluene and cyclohexanone arelisted as pretreatment pollutants. In addition, effluentlimitation guidelines have been developed for toluene andchromium.

• Reporting Requirements: The following constituents of515X332/910X457 are required to be listed on TRI reportsunder EPCRA Section 313: methyl ethyl ketone, toluene,isopropyl alcohol, and strontium chromate (containschromium).

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: methyl ethyl ketone, toluene,n-butyl acetate, cyclohexanone, and chromium (instrontium chromate).

• EPA 17: Three of the constituents of 515X332/910X457,methyl ethyl ketone, toluene, and chromium, are includedon the EPA 17 list of chemicals targeted for strictregulation.


An overall medium to high hazard rating is given to 515X332/910X457chromate primer. This rating is based on a determination that515X332/910X457 has a medium toxicity rating and a high exposurerating. The medium to high hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be thoroughly reviewed and properly implemented for workerhealth and safety. Constituents of concern and exposure effects arediscussed below.


Constituents of concern in 515X332/910X457 include strontium chromate,titanium dioxide, crystalline silica (quartz), toluene, methyl ethyl ketone,cyclohexanone, isopropyl alcohol, n-butyl acetate, and triethylenetetramine. Strontium chromate is a known human carcinogen, andtitanium dioxide and crystalline silica are suspected human carcinogens.Toluene, methyl ethyl ketone, cyclohexanone, and isopropyl alcohol areknown human neurotoxicants. Cyclohexanone is a known humangenotoxicant. No other known or suspected human carcinogens,teratogens, genotoxicants or neurotoxicants are noted in this chromateprimer. However, experimental laboratory animal teratogenic/reproductive toxicity data were identified for toluene, cyclohexanone,isopropyl alcohol, n-butyl acetate, and triethylene tetramine. Test resultsin laboratory animals and lower organisms (e.g., bacteria) also indicatethat toluene, isopropyl alcohol, strontium chromate, and triethylenetetramine are genotoxicants. Toxic effects for the constituents of concernmay range from irritation of the respiratory tract to dizziness andheadaches.

• Acute Effects: Acute overexposure to ingredients in thisprimer may cause narcotic effects characterized byweakness, dizziness, headaches, and nausea with vomiting.Contact with eyes, skin, respiratory tract, or mucousmembranes will cause irritation. Transient corneal injuryor clouding may result from contact with the eyes.

• Chronic Effects: Animals receiving repeated andprolonged doses develop damage to the kidneys and liver.Ulceration of the nasal septum is an effect of chronicchromium inhalation exposure. Constituents of thisproduct are known or suspected to cause cancer in humans.

Chromate primer 515X332/910X457 was assigned a medium toxicityrating based on published toxicity data (LD50 and LC50) for individualconstituents. Based on published exposure limits (PEL and TLV) of itsingredients, 515X332/910X457 was given a high exposure rating.

Appropriate engineering controls (e.g., local ventilation) must be usedduring the process and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker healthprotection throughout the process, and must include protective clothing(e.g., eye protection and chemical-resistant gloves), approved fittedrespirators, and approved emergency facilities (e.g., eye wash station andshower).

A summary of the ESOH analysis of Courtaulds Aerospace


515X332/910X457 epoxy primer is provided in Table A-7.


Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions – HAPs 3 Air Emissions – VOCs Yes Air Emissions – ODSs No Wastewater Discharged Yes Wastes Generated – Solid Yes Wastes Generated – Hazardous Yes TRI Reporting 4 CERCLA Hazardous Substance 5 EPA 17 Constituents 3





• Courtaulds Aerospace, “MIL-P-23377F Ty I, Cl 2,”

Product Information – Primer, August 1993• Courtaulds Aerospace, “515X332,” Material Safety Data

Sheet, August 30, 1996• Courtaulds Aerospace, “910X457 Epoxy Polyamide

Activator,” Material Safety Data Sheet, July 18, 1995.

A.3.4. 513X408/910X831 (Courtaulds Aerospace) Courtaulds Aerospace 513X408/910X831 waterborne epoxy primer meets therequirements of MIL-P-85582B Type I, Class C2. It is supplied as a base component(513X408) and a curing solution (910X831). In preparation for application, three partsby volume of the base component is mixed with one part of the curing solution. Themixed primer contains approximately 340 g/l VOCs. The ingredients of the two parts ofthe primer, as reported on the MSDSs, are reported in Table A-8.




OSHAPEL

ACGIH TLV

513X408 (base)

Epoxy Resin 68334-76-9 20 N.E. N.E. 2-Propoxyethanol(ethylene glycolmonopropyl ether)

02807-30-9 10 N.E. N.E.


as dust 3.0 mg/m3 asdust

StrontiumChromate

07789-06-2 15 0.05 mg/m3

as Cr 0.0005 mg/m3

as Cr Silica AluminaCeramic Alloy

07732-18-5 N.R. N.E. N.E.



00111-76-2 15 50 ppm(skin)

25 ppm (skin)

ModifiedPolyamine

N.E. 20 N.E. N.E.

2-Propoxyethanol 02807-30-9 15 N.E. N.E. N.E. = Not Established N.R. = Percentage Not Reported

In addition, the manufacturer recommends that a TLV of 25 ppm be observed for2-propoxyethanol (ethylene glycol monopropyl ether).


A brief regulatory analysis of Courtaulds Aerospace 513X408/910X831waterborne epoxy primer is provided below.

• Air Emissions: The 513X408/910X831 waterborne epoxy

primer contains three constituents that are HAPs,2-propoxyethanol, 2-butoxyethanol, and chromium (instrontium chromate). Although there are no ODSs presentin 513X408/910X831, the combined VOC content of thebase component and curing solution is approximately340 g/l.

• Solid/Hazardous Waste Generation: At least oneconstituent of 513X408/910X831, strontium chromate, may


generate hazardous waste. Due to its toxicity, strontiumchromate is listed as hazardous waste number D007.

• Wastewater Discharges: Under the CWA, the use of513X408/910X831 may result in waste streams containingeither or both of two regulated chemicals: strontiumchromate, and 2-butoxyethanol. Chromium (in strontiumchromate) is designated as a hazardous substance underCWA Section 311. Chromium is designated under theCWA as both a toxic and a priority pollutant.2-Butoxyethanol is listed as a pretreatment pollutant. Inaddition, effluent limitation guidelines have been developedfor chromium (in strontium chromate).

• Reporting Requirements: The following constituents of513X408/910X831 are required to be listed on TRI reportsunder EPCRA Section 313: 2-propoxyethanol,2-butoxyethanol, and strontium chromate (containschromium).

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: 2-propoxyethanol,2-butoxyethanol, and chromium (in strontium chromate).

• EPA 17: One of the constituents of 513X408/910X831,chromium, is included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium to high hazard rating is given to 513X408/910X831chromate primer. This rating is based on a determination that513X408/910X831 has a medium toxicity rating and a high exposure rating. Themedium to high hazard rating indicates that an overall moderate to high ESOHconcern is caused by the chemical toxicity and worker exposure properties ofthis alternative. Worker exposure controls should be thoroughly reviewed andproperly implemented for worker health and safety. Constituents of concern andexposure effects are discussed below.

Constituents of concern in 513X408/910X831 include strontium chromate,titanium dioxide, 2-propoxyethanol, and 2-butoxyethanol. Both2-propoxyethanol and 2-butoxyethanol may be absorbed through the skin.Strontium chromate is a known human carcinogen and titanium dioxide isa suspected human carcinogen. 2-Butoxyethanol is a known humanneurotoxicant. No other known or suspected human carcinogens,teratogens, genotoxicants or neurotoxicants were noted in this chromateprimer. However, experimental laboratory animal teratogenic/reproductive toxicity data were identified for 2-propoxyethanol and


2-butoxyethanol. Strontium chromate is a known genotoxicant inlaboratory animals. Toxic effects for the constituents of concern mayrange from irritation of the respiratory tract to dizziness and headaches.Additional health effects of the primer constituents are discussed below.

• Acute Effects: Contact with eyes, skin, respiratory tract, ormucous membranes will cause irritation.

• Chronic Effects: Animals receiving repeated andprolonged doses develop hemolytic anemia and damage tothe kidneys and liver. Ulceration of the nasal septum is aneffect of chronic chromium inhalation exposure.Constituents of this product are known or suspected tocause cancer in humans.

Chromate primer 513X408/910X831 was assigned a medium toxicityrating based on published toxicity data (LD50 and LC50) for individualconstituents. Based on published exposure limits (PEL and TLV) of itsingredients, 513X408/910X831 was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be used during theprocess and administrative controls may be appropriate (e.g., exposure timelimits and job sharing). Also, all ignition sources should be removed. Personalprotective equipment is required for worker health protection throughout theprocess, and must include protective clothing (e.g., eye protection and chemical-resistant gloves), approved fitted respirators, and approved emergency facilities(e.g., eye wash station and shower).

A summary of the ESOH analysis of Courtaulds Aerospace 513X408/910X831epoxy primer is provided in Table A-9.



Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions - HAPs 3 Air Emissions - VOCs Yes Air Emissions – ODSs No Wastewater Discharged Yes Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes TRI Reporting 3 CERCLA Hazardous Substance 3 EPA 17 Constituents 1





• Courtaulds Aerospace, “MIL-P-85582A Type I Class 2,”

Product Information, May 23, 1994• Courtaulds Aerospace, “515X408B,” Material Safety Data

Sheet, April 23, 1996• Courtaulds Aerospace, “910X831,” Material Safety Data

Sheet, September 25, 1995• QPL-85582-4, “Qualified Products List of Products under

Military Specification MIL-P-85582, Primer Coatings:Epoxy, Waterborne,” December 30, 1994.

A.3.5. 10P20-12/EC-212 (Dexter Aerospace Materials Division/Crown MetroAerospace) 10P20-12/EC-212 chromate primer is supplied as a base component (10P20-12)and a catalyst (EC-212). The ingredients of the two parts of the primer, asreported on the MSDSs, are reported in Table A-10.


Table A-10. Ingredients of Dexter Aerospace Materials/CrownMetro Aerospace 10P20-12/EC-212


OSHA PEL ACGIH TLV

10P20-12 (base)

Proprietary EpoxyResin

N.E. <10 N.E. N.E.

Crystalline Silica(quartz)

14808-60-7 10 - 20 0.02 mg/m3


StrontiumChromate

07789-06-2 20 - 30 0.05 mg/m3

as Cr 0.0005 mg/m3

as Cr Toluene 00108-88-3 <10 100 ppm 50 ppm Methyl n-AmylKetone

00110-43-0 <10 100 ppm 50 ppm

Methyl IsobutylKetone

00108-10-1 10 - 20 50 ppm 50 ppm

Aluminum Oxide(in nonvolatiles)

01344-28-1 1 - 2 N.E. 10 mg/m3

Formaldehyde 00050-00-0 Trace 0.75 ppm 0.3 ppma

Benzene 00071-43-2 Trace 10 ppm 0.5 ppm (skin)

EC-212 (catalyst)

DimethylAminmethylPhenol Mixture

N.E. 10 - 20 N.E. N.E.

Toluene 00108-88-3 30 - 40 100 ppm 50 ppm Benzyl Alcohol 00100-51-6 <10 N.E. N.E. m-XyleneDiamine

01477-55-0 <10 0.1 mg/m3

(skin) 0.1 mg/m3

(skin) Benzene 00071-43-2 Trace 10 ppm 0.5 ppm (skin)

N.E. =Not Established a Ceiling Value


A brief regulatory analysis of Dexter Aerospace Materials/Crown MetroAerospace 10P20-12/EC-212 chromate primer is provided below.

• Air Emissions: 10P20-12/EC-212 chromate primer

contains five constituents that are HAPs, toluene, methylisobutyl ketone, formaldehyde, benzene, and chromium (instrontium chromate). Benzene and formaldehyde arereported to be present only in trace quantities. Althoughthere are no ODSs present in 10P20-12/EC-212, the VOC


content of 10P20-12 is 2.7 lb/gal and the VOC content ofEC-212 is 3.8 lb/gal.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 10P20-12/EC-212 may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product. At least five constituents of10P20-12/EC-212 may generate hazardous waste: methylisobutyl ketone, toluene, strontium chromate, formaldehyde(trace), and benzene (trace). Methyl isobutyl ketone islisted as hazardous waste numbers F003 and U161; tolueneis listed as F005 and U220; and strontium chromate is listedas D007. In addition, formaldehyde is listed as U122, andbenzene is listed as D018, F003, and U019.

• Wastewater Discharges: Under the CWA, the use of10P20-12/EC-212 may result in waste streams containingany of seven regulated chemicals: toluene, strontiumchromate, methyl isobutyl ketone, benzyl alcohol,formaldehyde (trace), benzene (trace), and methyl n-amylketone. Toluene, formaldehyde, benzene, and chromium(in strontium chromate) are designated hazardoussubstances under CWA Section 311. Toluene, benzene,and chromium are designated under the CWA as both toxicand priority pollutants. Toluene, methyl isobutyl ketone,benzene, benzyl alcohol, and methyl n-amyl ketone arelisted as pretreatment pollutants. In addition, effluentlimitation guidelines have been developed for toluene,benzene, and chromium.

• Reporting Requirements: The following constituents of10P20-12/EC-212 are required to be listed on TRI reportsunder EPCRA Section 313: aluminum oxide,formaldehyde, benzene, toluene, methyl isobutyl ketone,and strontium chromate (contains chromium).Formaldehyde and benzene are present in trace quantities.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: formaldehyde, benzene,toluene, methyl isobutyl ketone, and chromium (instrontium chromate). Formaldehyde and benzene arepresent in trace quantities.

• EPA 17: Seven of the constituents of 10P20-12/EC-212,methyl isobutyl ketone, benzene (trace), toluene, m-xylenediamine, and chromium (in strontium chromate), areincluded on the EPA 17 list of chemicals targeted for strictregulation.



An overall medium to high hazard rating is given to 10P20-12/EC-212chromate primer. This rating is based on a determination that10P20-12/EC-212 has a medium toxicity rating and a high exposurerating. The medium to high hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be thoroughly reviewed and properly implemented for workerhealth and safety. Constituents of concern and exposure effects arediscussed below. Constituents of concern in 10P20-12/EC-212 include crystalline silica(quartz), strontium chromate, toluene, methyl n-amyl ketone, methylisobutyl ketone, and benzyl alcohol. Benzene and formaldehyde arepresent as trace contaminants. Strontium chromate is a known humancarcinogen, as are the trace constituents benzene and formaldehyde.Crystalline silica is a suspected human carcinogen. Benzyl alcohol,benzene, and formaldehyde are known human genotoxicants. Toluene andmethyl isobutyl ketone and the trace constituents benzene andformaldehyde are known human neurotoxicants. No other known orsuspected human carcinogens, teratogens, genotoxicants or neurotoxicantswere noted in this chromate primer. However, experimental laboratoryanimal teratogenic/reproductive toxicity data were identified for toluene,methyl isobutyl ketone, and benzyl alcohol and for the trace contaminantbenzene. Test results in laboratory animals and lower organisms (e.g.,bacteria) also indicate that toluene, methyl n-amyl ketone, and strontiumchromate and the trace constituent formaldehyde are genotoxicants. Thisproduct contains formaldehyde and benzene, which are considered by thestate of California to cause cancer. Benzene and formaldehyde areconsidered by the state of California to cause birth defects or otherreproductive harm. Toxic effects for the constituents of concern mayrange from irritation of the respiratory tract to dizziness and headaches.Additional health effects of the primer constituents are discussed below.

• Acute Effects: Acute overexposure to ingredients in thisprimer may cause narcotic effects characterized byweakness, dizziness, and headaches. Contact with eyes,skin, respiratory tract, or mucous membranes will causeirritation.

• Chronic Effects: Prolonged and repeated contact with thisproduct can cause permanent damage to the central nervoussystem, cardiac sensitization, and allergic respiratory orskin reactions. Animals receiving repeated and prolongeddoses of components of this product develop damage to the


kidneys, liver, and lungs. Ulceration of the nasal septum isan effect of chronic chromium inhalation exposure.Constituents of this product are known or suspected tocause cancer in humans.

Chromate primer 10P20-12/EC-212 was assigned a medium toxicity ratingbased on published toxicity data (LD50 and LC50) for individualconstituents. Based on published exposure limits (PEL and TLV) of itsingredients, 10P20-12/EC-212 was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedduring the process and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker healthprotection throughout the process, and must include protective clothing(e.g., eye protection and chemical-resistant gloves), approved fittedrespirators, and approved emergency facilities (e.g., eye wash station andshower). A summary of the ESOH analysis of Dexter Aerospace Materials/CrownMetro Aerospace 10P20-12/EC-212 primer is provided in Table A-11.

Table A-11. ESOH Analysis of Dexter Aerospace Materials

Division/Crown Metro Aerospace 10P20-12/EC-212

Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions - HAPs 5 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Wastewater Discharged Yes TRI Reporting 6/4d

CERCLA Hazardous Substance 5/3d

EPA 17 Constituents 5/4e




d Two of the identified chemicals (formaldehyde and benzene) are present in tracequantities.

e One of the listed chemicals (benzene) is present in trace quantities.



• Dexter Corporation, “10P20-12 High Solids UrethaneCompatible Epoxy Primer,” Technical Data Sheet, 1997

• Balster, G., “10P20-12,” Material Safety Data Sheet,April 17, 1998

• Stuart, K., “EC-212,” Material Safety Data Sheet, June 27,1996.

A.3.6. EEAY051 A/B (Spraylat Corporation)

Spraylat EEAY051 A/B high-solids chromate primer meets the requirements ofMIL-P-23377G Type I, Class C. It is supplied as a base component(component A) and an activator (component B). In preparation for application,three parts by volume of the base component are mixed with one part of thecatalyst. The mixed primer contains approximately 340 g/l VOCs. Theingredients of the two parts of the primer, as reported on the MSDSs, are reportedin Table A-12.

Table A-12. Ingredients of Spraylat EEAY051 A/B


OSHA PEL ACGIHTLV

EEAY051 A (base)

Methyl Ethyl Ketone 00078-93-3 <10 200 ppm 200 ppm Methyl n-Amyl Ketone 00110-43-0 <10 100 ppm 50 ppm Methyl Isobutyl Ketone 00108-10-1 <10 50 ppm 50 ppm Amorphous Silica 67762-90-7 <10 N.E. N.E. Titanium Dioxide 13463-67-7 <10 3.0 mg/m3

as Dust 3.0 mg/m3

as Dust Xylene 01330-20-7 <10 100 ppm 100 ppm Epoxy Resin N.E. <25 N.E. N.E. Talc 14807-96-6 <25 0.5 mg/m3

as Dust 0.5 mg/m3

as Dust Barium Sulfate 07727-43-7 <10 15 mg/m3,

5 mg/m3

Respirable

10 mg/m3

Chromium Compound(hexavalent)

07440-47-3a 14 0.05 mg/m3

as Cr 0.0005mg/m3 as Cr

N.E. =Not Established a The CAS # of the chromium compound was not reported; this CAS # is that of chromium

metal. (Table A-12 continued on the next page)


Table A-12. Ingredients of Spraylat EEAY051 A/B (Continued)


OSHA PEL ACGIH TLV

EEAY051 B (activator)

Methyl n-AmylKetone

00110-43-0 <10 100 ppm 50 ppm


00108-10-1 <25 50 ppm 50 ppm

Cyclohexanone 00108-94-1 <10 25 ppm (skin) 25 ppm (skin) Aliphatic Amine(2,4,6-Tris(Dimethylamino-methyl) Phenol)

00090-72-2 <10 N.E. N.E.

Polyamide(N,N-Dimethyl-benzylamine)

00103-83-3 <10 N.E. N.E.

N.E. = Not Established a The CAS # of the chromium compound was not reported; this CAS # is that of chromium

metal.


A brief regulatory analysis of Spraylat EEAY051 A/B high-solidschromate primer is provided below.

• Air Emissions: EEAY051 A/B chromate primer contains

five constituents that are HAPs, methyl ethyl ketone,methyl n-amyl ketone, methyl isobutyl ketone, xylene, andchromium. Although there are no ODSs present in thisproduct, the mixed primer contains approximately 340 g/lVOCs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of EEAY051 A/B may be classified as RCRA D001ignitable wastes due to the low flash point of this product.At least five constituents of EEAY051 A/B may generatehazardous waste: methyl ethyl ketone, methyl isobutylketone, xylene, chromium, and cyclohexanone. Methylethyl ketone is listed as hazardous waste numbers D035,F005, and U159; methyl isobutyl ketone is listed ashazardous waste numbers F003 and U161; xylene is listedas hazardous waste numbers F003 and U239; chromium islisted as hazardous waste number D007; and


cyclohexanone is listed as hazardous waste numbers F003and U057.

• Wastewater Discharges: The use of EEAY051 A/B mayresult in waste streams containing any of five regulatedchemicals: methyl n-amyl ketone, methyl isobutyl ketone,xylene, chromium, and cyclohexanone. Xylene andchromium are designated as hazardous substances underCWA Section 311. Chromium is designated under theCWA as both a toxic and a priority pollutant. Methyln-amyl ketone, methyl isobutyl ketone, and cyclohexanoneare listed as pretreatment pollutants. In addition, effluentlimitation guidelines have been developed for chromium.

• Reporting Requirements: The following constituents ofEEAY051 A/B are required to be listed on TRI reportsunder EPCRA Section 313: methyl ethyl ketone, methylisobutyl ketone, xylene, and chromium.

• CERCLA Hazardous Substances: This primer contains fiveconstituents which are listed as hazardous substances underCERCLA: methyl ethyl ketone, methyl isobutyl ketone,xylene, chromium, and cyclohexanone.

• EPA 17: Four of the constituents of EEAY051 A/B, methylethyl ketone, methyl isobutyl ketone, xylene, andchromium, are included on the EPA 17 list of chemicalstargeted for strict regulation.


No toxicity rating, exposure rating, or hazard rating was developed for SpraylatEEAY051 A/B.

Constituents of concern in EEAY051 A/B include methyl ethyl ketone,methyl n-amyl ketone, methyl isobutyl ketone, amorphous silica, titaniumdioxide, xylene, epoxy resin, talc, barium sulfate, hexavalent chromium,cyclohexanone, 2,4,6-tris(dimethylaminomethyl) phenol, andN,N-dimethylbenzylamine. Amorphous silica and titanium dioxide are listed on the MSDS with theirPELs as required by 29 CFR 1910.1200. However, these constituents arein fully encapsulated form and therefore are not generally consideredhazardous during normal primer application. If the cured primer is sandedor ground, a suitable respirator is required. Hexavalent chromium is aknown human carcinogen. Talc, barium sulfate, and titanium dioxide aresuspected human carcinogens. Cyclohexanone is a known humangenotoxicant and neurotoxicant. Other known human neurotoxicants


include methyl isobutyl ketone, methyl n-amyl ketone, and methyl ethylketone. This primer contains no other known human carcinogens,teratogens, genotoxicants or neurotoxicants. Experimental animalteratogen data was noted for the constituents methyl isobutyl ketone,methyl ethyl ketone, and cyclohexanone. Test results in laboratoryanimals and lower organisms (e.g., bacteria) also indicate that methyl ethylketone, amorphous silica, and barium sulfate are genotoxicants. Toxiceffects for the constituents of concern may range from mild to severeirritation of the respiratory tract to headache, dizziness, or nausea.

Appropriate engineering controls (e.g., local ventilation) must be usedduring the process and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker healthprotection throughout the process, and must include protective clothing(e.g., eye protection and chemical-resistant gloves), approved fittedrespirators, and approved emergency facilities (e.g., eye wash station andshower).

A summary of the ESOH analysis of Spraylat EEAY051 A/B primer isprovided in Table A-13.

Table A-13. ESOH Analysis of Spraylat EEAY051 A/B

Category Rating Toxicity Rating Not Rated Exposure Rating Not Rated Hazard Rating Not Rated Air Emissions - HAPs 5 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Wastewater Discharged Yes TRI Reporting 4 CERCLA Hazardous Substance 5 EPA 17 Constituents 4


• Spraylat Aerospace Coatings, “ECO-PRIMER: “Epoxy,

Chemical and Solvent Resistant”, Compliance, MIL-P-23377G Type I Class C, EEAY051 A & B,” Product Data,1998


• Schmidt, Jim, “EEAY051A, MIL-P-23377G Type IClass C Primer – Yellow P/A,” Material Safety Data Sheetfor Coatings, Resins and Related Material, April 17, 1998

• Schmidt, Jim, “EEAE136B, MIL-P-23377G Type I Class CPrimer – Activator,” Material Safety Data Sheet forCoatings, Resins and Related Materials, April 17, 1998.

A.3.7. 44-GN-36 (Deft, Inc.)

Deft 44-GN-36 chromate primer meets the requirements of MIL-P-85582B Type I, ClassC2. It is supplied as a base component and a catalyst. In preparation for application, twoparts by volume of the base component are mixed with one part of the catalyst. Themixed primer contains approximately 340 g/l VOCs. The primer may be further reducedbefore application with approximately 4.5 parts deionized water, by volume, to one partmixed primer. The ingredients of the two parts of the primer, as reported on the MSDSs,are reported in Table A-14.

Table A-14. Ingredients of Deft 44-GN-36


OSHAPEL

ACGIH TLV

44-GN-36 (base)

sec-Butyl Alcohol 00078-92-2 25 100 ppm 100 ppm C8 & C10 AromaticHydrocarbons

64742-95-6 <1 N.E. N.E.

StrontiumChromate

07789-06-2 25 0.05 mg/m3

as Cr 0.0005 mg/m3

as Cr Aluminum Pigment 07429-90-5 5 10 mg/m3 15 mg/m3

Mineral Spirits 64742-88-7 <5 N.E. N.E. 44-GN-36 (catalyst)

Nitroethane 00079-24-3 30 100 ppm 100 ppm N.E. = Not Established


A brief regulatory analysis of Deft 44-GN-36 chromate primer is providedbelow.

• Air Emissions: 44-GN-36 chromate primer contains one

constituent that is a HAP, chromium (in strontiumchromate). Although there are no ODSs present in thisproduct, the mixed primer contains approximately 340 g/lVOCs.


• Solid/Hazardous Waste Generation: Wastes generated bythe use of 44-GN-36 may be classified as RCRA D001ignitable wastes due to the low flash point of this product.At least one constituent of 44-GN-36, strontium chromate,may generate hazardous waste. Due to its toxicity,strontium chromate is listed as hazardous waste numberD007.

• Wastewater Discharges: The use of 44-GN-36 may resultin a regulated waste stream due to the presence of strontiumchromate. Chromium (in strontium chromate) is designatedas a hazardous substance under CWA Section 311.Chromium is designated under the CWA as both a toxicand a priority pollutant. In addition, effluent limitationguidelines have been developed for chromium.

• Reporting Requirements: The following constituents of44-GN-36 are required to be listed on TRI reports underEPCRA Section 313: strontium chromate (containschromium) and sec-butyl alcohol.

• CERCLA Hazardous Substances: This primer contains oneconstituent which is listed as a hazardous substance underCERCLA, chromium (in strontium chromate).

• EPA 17: One of the constituents of 44-GN-36, chromium,is included on the EPA 17 list of chemicals targeted forstrict regulation.


An overall medium hazard rating is given to 44-GN-36 chromate primer. Thisrating is based on a determination that 44-GN-36 has a medium toxicity ratingand a medium to high exposure rating. The medium hazard rating indicates thatan overall moderate ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controls shouldbe reviewed and properly implemented for worker health and safety.Constituents of concern and exposure effects are discussed below.

Constituents of concern in 44-GN-36 include sec-butyl alcohol andstrontium chromate. Strontium chromate is a known human carcinogen.No other known or suspected human carcinogens, teratogens,genotoxicants, or neurotoxicants were noted in this chromate primer.However, experimental laboratory animal teratogenic/reproductive toxicitydata were identified for sec-butyl alcohol. Test results in laboratoryanimals and lower organisms (e.g., bacteria) also indicate that strontiumchromate is a genotoxicant. Toxic effects for the constituents of concernmay range from irritation of the respiratory tract to dizziness and


headaches. Additional health effects of the primer constituents arediscussed below.

• Acute Effects: Acute overexposure to ingredients in thisprimer may cause narcotic effects characterized byweakness, dizziness, and headaches. Contact with eyes,skin, respiratory tract, or mucous membranes will causeirritation.

• Chronic Effects: Prolonged and repeated contact with thisproduct can cause permanent damage to the central nervoussystem, and allergic respiratory or skin reactions. Animalsreceiving repeated and prolonged doses of components ofthis product develop damage to the kidneys and liver.Ulceration of the nasal septum is an effect of chronicchromium inhalation exposure. Constituents of thisproduct are known or suspected to cause cancer in humans.

Chromate primer 44-GN-36 was assigned a medium toxicity rating basedon published toxicity data (LD50 and LC50) for individual constituents.Based on published exposure limits (PEL and TLV) of its ingredients,44-GN-36 was given a medium to high exposure rating.

Appropriate engineering controls (e.g., local ventilation) must be usedduring the process and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower).

A summary of the ESOH analysis of Deft 44-GN-36 primer is provided inTable A-15.


Table A-15. ESOH Analysis of Deft 44-GN-36

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 1 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Wastewater Discharged Yes TRI Reporting 2 CERCLA Hazardous Substance 1 EPA 17 Constituents 1





• Deft, Inc., “44-GN-36,” Product Information Data Sheet• Smith, Mike, “44GN036,” Material Safety Data Sheet,

October 18, 1994• Smith, Mike, “44GN036CAT,” Material Safety Data Sheet,

October 18, 1994.

APPENDIX B

Technology Survey To Identify Candidate AlternativeTechnologies To Chromate Primers

Potential Alternatives Report B-i

TABLE OF CONTENTS

Page

B.1. DESCRIPTION OF SEARCH ........................................................................................ B-1

B.2. IDENTIFIED ALTERNATIVE TECHNOLOGIES ....................................................... B-3B.2.1. Conventional Alternatives................................................................................... B-3

B.2.1.1. Technical Considerations ..................................................................... B-3B.2.1.2. Environmental Issues ........................................................................... B-5B.2.1.3. Health and Safety Issues....................................................................... B-5

B.2.2. High-Solids Coatings .......................................................................................... B-5B.2.2.1. General Information ............................................................................. B-5B.2.2.2. MIL-P-23377G Class N: Nonchromate High-Solids Epoxy

Primers ................................................................................................. B-6B.2.2.3. MIL-P-53022B Type II: Lead- and Chromate-Free Corrosion-

Inhibiting Epoxy Primer Coating ......................................................... B-8B.2.3. Waterborne Alternatives ................................................................................... B-11

B.2.3.1. General Information ........................................................................... B-11B.2.3.2. MIL-P-85582B Class N: Non-Chromate Waterborne Epoxy Primer

Coatings.............................................................................................. B-12B.3. BIBLIOGRAPHIC INFORMATION ON RELEVANT ABSTRACTS

IDENTIFIED................................................................................................................. B-15

LIST OF TABLES

Table B-1. Search A – DIALOG Database ................................................................................ B-1Table B-2. Search B – ENVIRO$EN$E..................................................................................... B-2Table B-3. Search C – NCMS....................................................................................................B-2Table B-4. Search D – NTTC..................................................................................................... B-2Table B-5. Requirements of MIL-P-23377G Type I and A-A-2786.......................................... B-3Table B-6. Requirements of MIL-P-23377G Type I and MIL-P-53022B Type II .................... B-9


Potential Alternatives Report B-1

B.1. DESCRIPTION OF SEARCH

Various information sources are available to Concurrent Technologies Corporation(CTC). Among the information sources used to identify nonchromate primers weredatabase searches, Internet searches, vendor contacts, the CTC Information ResourceCenters, and personal contacts. Four main searches were performed on databases in early1996. One search was performed on DIALOG Database, which has access to over370 individual databases. The DIALOG Database contains over 260 million records, allof which are available with a variety of search strategies. The DIALOG search strategy isnamed Search A. The other searches were performed on the Environmental ProtectionAgency’s (EPA’s) Enviro$en$e database (Search B), the National Center forManufacturing Sciences (NCMS) database (Search C), and the National TechnologyTransfer Center (NTTC) database (Search D). Searches A through D are describedbelow.

Table B-1. Search A – DIALOG Database

Search Sequence Search Term Number of MatchesA1 Primer and (chromium or chromate or

non_chromate or non-chromate)(individual performing search requestedthat these terms should be in the title)

199

A2 Remove Duplicates 155A3 Limit Search A2 to 1990-1996 56A4 Limit Search A3 to English only 41

Applicable Articles 21

Within DIALOG, the following databases were identified as containing information:

• Aerospace Database (1962-1996)• Aluminum Industry Abstracts (1996)• CA SEARCH (1967-1996)• EI Compendex*Plus (1970-1996)• Energy Science and Technology (1974-1995)• Federal Register (1988-1996)• IHS International Standards and Specifications (1996)• METADEX (1966-1996)• NTIS (1964-1996)• RAPRA Abstracts (1972-1996).

B-2 Potential Alternatives Report

Table B-2. Search B – ENVIRO$EN$E

Search Sequence Search Term Number of MatchesB1 Primer or Chromate or Alternative 500B2 Primer and (chromate or chromium) and

Alternative not Conversion8

Applicable Articles 0

Table B-3. Search C – NCMS

Search Sequence Search Term Number of MatchesC1 Primer and (chromate or chromium) and

Alternative0

C2 Primer and (chromate or chromium) 0

Table B-4. Search D – NTTC

Search Sequence Search Term Number of MatchesD1 Non Chromate Primer 0

The relevant abstracts from Search Sequence A4 and abstracts that discuss replacingchromium-containing primers with general alternatives or alternatives not discussed arelisted in Section B.3.

In addition to the database searches, Internet sources were scanned with search enginessuch as InfoSeek, Excite, Lycos, Web Crawler, and Yahoo. Search strategies on thesesearch engines are listed below. The actual syntax for performing searches varies foreach search engine, so Boolean search descriptors are listed for simplicity:

1. Non-chromate and primer2. (23377 or 85582) and alternative

Although several matches were obtained with some of the search engines, no Internetsites that are applicable to this technology survey were identified.


B.2. IDENTIFIED ALTERNATIVE TECHNOLOGIES

B.2.1. Conventional Alternatives

Conventional nonchromate primer alternatives are available that can potentiallyreplace the originally used primers. The term “conventional” in this case meansthat the products contain relatively high levels of volatile organic compounds(VOCs). One primer was identified through the database searches as a potentialreplacement for MIL-P-23377G primers.

The Federal Specification known as A-A-2786 has been authorized by the GeneralServices Administration (GSA), and may potentially replace MIL-P-23377Gprimers. This specification is a lead- and chromate-free primer that is dispensedfrom an aerosol container. The specification states that, in order to qualify, aproduct must not sputter, and a smooth uniform film must be deposited. Thecontainer shall deliver a minimum of 98% by weight of its contents. Finally, theprimer may not contain halogenated solvents nor propellants.

B.2.1.1. Technical Considerations

The performance requirements of A-A-2786 and MIL-P-23377G arecompared in Table B-5.

Table B-5. Requirements of MIL-P-23377G Type I and A-A-2786

Parameter Requirement ofMIL-P-23377G, Type I

Requirement ofA-A-2786

Maximum VOC Content(lb/gal)

2.8 N/A

Compatibility with MIL-T-81772 Type II Thinner

Compatible N/A

Storage Stability ofUnopened Package

1 yr between 35°F and115°F

N/A

Drying Time 5 hr “Tack Free”8 hr dry hard

15 min dry hard2 hr dry through

Pot Life 4 hr N/AStrippability Using MIL-R-81294 Type I, Class 1

90% stripped in 1 hr N/A

Wet Tape Adhesion Pass after 24 hr immersion N/AN/A = Not Applicable

(Table B-5 continued on next page)


Table B-5. Requirements of MIL-P-23377G Type I and A-A-2786(Continued)


Requirement ofA-A-2786

Impact Flexibility(elongation)

10% minimum elongation N/A

Flexibility N/A bend over 1/8 inchmandrel

Filiform CorrosionResistance

Pass N/A

Salt Spray Resistance(aluminum)

2,000 hr (scribed) 1,000 hr (scribed)

Fluid Resistance:Lubricating Oil

24 hr at 250 + 5°F N/A

Fluid Resistance:Hydraulic Fluid

24 hr at 150 + 5°F N/A

Fluid Resistance:Distilled Water

4 days at 120 + 5°F 1 day (temperaturenot specified)

Fluid Resistance:Hydrocarbon Fluid

N/A 4 hr at 70°F

Lifting None visible None visibleSpecular Gloss, 60Degrees

N/A 6 maximum

Comments Solvent-borneHigh-solids

Solvent-borneaerosol containers

N/A = Not Applicable


B.2.1.2. Environmental Issues

This specification does not identify the type of solvents that are present inindividual products. Many of the solvents used in conventional primerformulations are VOCs and may be hazardous air pollutants (HAPs), bothof which are subject to regulation under the Clean Air Act (CAA), asamended in 1990. In addition, Subtitle C of the Resource Conservationand Recovery Act (RCRA) governs the proper management, treatment,and disposal of hazardous wastes, such as spent paint resulting fromoverspray. If lead is present in the primer (a maximum of 0.06 % ispermitted to be in the formulation), then related environmental issues willalso arise. Also, because the product is dispensed in aerosol containers,proper precautions, such as puncturing the containers, must be takenbefore disposal.

B.2.1.3. Health and Safety Issues

Permissible exposure limits (PELs) established by the Occupational Safetyand Health Administration (OSHA) limit the use of some solvents. Thetype of solvent used depends on the product that qualifies for thisspecification.


General Services Administration, “Commercial Item Description, PrimerCoating (Aerosol, Lead and Chromate Free),” A-A-2786, March 31, 1992.

B.2.2. High-Solids Coatings

B.2.2.1. General Information

Conventional solvent-borne paints typically contain 8% to 30% solids.High-solids paints contain an increased amount of nonvolatiles, resultingin formulations that range from 40% to nearly 100% solids. These paintformulations use low-molecular-weight resins (500 to 2,000 as comparedto 20,000 for conventional resins) that require less solvent to attain thedesired application viscosity. These resins have highly reactive sites to aidin coating polymerization. Use of these paints reduces the amount of paintrequired to achieve the desired film thickness, as well as reduces VOCemissions. High-solids paints may be one- or two-component systemsbased on acrylic, alkyd, epoxy, polyester, or urethane resins. The curingrequired for a high-solids coating can range from an ambient air dry to ahigh temperature bake (above 350°F or 180°C).


B.2.2.1.1. Technical Considerations

The reduced solvent content may cause difficulties in application. Surfacepreparation is more critical, because oils, greases, and other surfacecontaminants normally dissolved by solvents in conventional formulationsmay affect paint adhesion. Although some high-solids paints may beapplied by conventional application techniques (e.g., air spraying, curtaincoating, dip coating, electrostatic spraying, or flow coating), specialequipment may be required for others, especially those approaching100% solids. For high-viscosity materials, it may be necessary to heat thepaint to maintain a workable paint consistency, increase the pressure inspray applications, or use two-component formulations and pluralcomponent equipment that meters and mixes the materials at the spraygun. Because thicker coatings do not blend as well as thinner coatings,color matching may be more complicated. In addition, the reduced solventcontent may make clean-up more difficult.

B.2.2.1.2. Environmental Issues

Because high-solids primers contain reduced amounts of solvents, VOCemission compliance with the CAA amendments may be achieved byusing these formulations. Sludge from a spray booth applying a high-solids primer may be a listed or characteristic hazardous waste, dependingon the solvents used in the primer formulations and the properties of thewaste. Disposal should be performed in accordance with federal [Title 40,Code of Federal Regulations, Part 261 (40 CFR 261)], state, and localenvironmental control regulations. If a waste is determined to behazardous, a licensed hazardous waste transporter and disposal facilitymust be used.

B.2.2.2. MIL-P-23377G Class N: Nonchromate High-Solids Epoxy Primers

MIL-P-23377G Class N coatings may replace chromate-containingMIL-P-23377G Class C coatings. This military specification requires thatqualifying primers contain no more than 340 grams of solvent per liter(g/l) [2.8 pounds per gallon (lb/gal)]. In addition, chlorinated solvents,cadmium, and cadmium compounds are not allowed in the formulation,and no more than 0.06 weight percent of lead or lead compounds isallowed in the formulation. The MIL-P-23377G primers are formulated assprayable coatings that can be applied by conventional, airless, highvolume low pressure (HVLP), or electrostatic spray equipment. The


primers are intended to be applied to a dry-film thickness of 0.6 mil to0.9 mil (0.0006 - 0.0009 inches).

MIL-P-23377G groups waterborne coatings into two types and twoclasses, as listed below. Only Class N coatings will be further consideredin this discussion because the Class C coatings contain chromate.

Type ClassType I - Standardpigments

Class C - Strontium chromate-based corrosion inhibitors

Type II - Low infraredreflective pigments

Class N - Nonchromate-basedcorrosion inhibitors

The most recent Qualified Products List of MIL-P-23377G does not listany Class N coating products.

B.2.2.2.1. Technical Considerations

The performance requirements of MIL-P-23377G Class N coatings are thesame as the conventional MIL-P-23377G Class C coatings. Therefore,these coatings should be technically acceptable alternatives for allapplications currently using MIL-P-23377G Class C. Note that MIL-P-23377G states that “Class N may not be substituted for Class C, unlessauthorization for its use is given by the procuring activity or engineeringauthority for the system or item to which the primer coating is to beapplied.”

B.2.2.2.2. Environmental, Health, and Safety Issues

By transitioning from the Class C coatings of MIL-P-23377G to theClass N coatings, all environmental, health, and safety implications ofchromium are eliminated. Other environmental, health, and safety issuesdepend on the specific primer chosen.


• Naval Air Systems Command, “Military Specification,Primer Coatings: Epoxy, High-Solids,” MIL-P-23377Gand preceding amendments, September 30, 1994

• Naval Air Systems Command, “Qualified Products List ofProducts under Military Specification MIL-P-23377,


Primer Coatings: Epoxy, High-Solids,” QPL-23377-16,February 10, 1995

• Naval Air Systems Command, “Qualified Products List ofProducts under Military Specification MIL-P-23377,Primer Coatings: Epoxy, High-Solids,” QPL-23377-17,March 28, 1997.

B.2.2.3. MIL-P-53022B Type II: Lead- and Chromate-Free Corrosion-Inhibiting Epoxy Primer Coating The following primers are included on the QPL for MIL-P-53022BType II:

• 02-W-36 (Deft, Inc.)• 4241-T101/0200T106 (Dexter Specialty)• 04488WEP/04489CEH (Hentzen Chemical)• 04488WEP-3 (Hentzen Chemical)• Y-867/Y-868 (Lenmar, Inc.)• N-1981 (Niles Chemical)• 724-730 (Pratt and Lambert)• 724-732/724-731 (Pratt and Lambert)• 724-736/724-737 (Pratt and Lambert)• E-9874 (Randolph Products)• HS-022 (Spraylat - Everseal)• 961W006/990T054 (Valspar).

B.2.2.3.1. Technical Considerations The requirements of the conventional MIL-P-23377G Type I coatings arecompared to the alternative MIL-P-53022B Type II coatings in Table B-6.


Table B-6. Requirements of MIL-P-23377G Type I andMIL-P-53022B Type II

Parameter Requirement of MIL-P-23377G, Type I

Requirement ofMIL-P-53022B,

Type II Maximum VOCContent (lb/gal)

2.8 3.5

Compatibility withMIL-T-81772 TypeII Thinner

Compatible N/R

Storage Stability ofUnopened Package



Drying Time 5 hr “tack free” 8 hr dry hard

0.5 hr set to touch 4 hr dry hard 6 hr dry through

Pot Life 4 hr N/R Strippability usingMIL-R-81294Type I, Class 1

90% stripped in 1 hr N/R

Wet Tape Adhesion Pass after 24 hrimmersion

N/R

Dry Tape Adhesion N/R Pass Impact Flexibility(elongation)

10% minimumelongation

N/R

Filiform CorrosionResistance

Pass N/R

Salt SprayResistance(aluminum)

2,000 hr (scribed) 336 hr (unscribed)

Fluid Resistance:Lubricating Oil

24 hr at 250 + 5°F N/R

Fluid Resistance:Hydraulic Fluid

24 hr at 150 + 5°F N/R

Fluid Resistance:Distilled Water

4 days at 120 + 5°F 7 days at 23°C

Fluid Resistance:Hydrocarbon Fluid

N/R Pass ASTM D 1308

DS2 Resistance N/R 30 min at 70°F Lifting None visible N/R

N/R = No Requirement (Table B-6 continued on next page)


Table B-6. Requirements of MIL-P-23377G Type I andMIL-P-53022B Type II (Continued)


Requirement ofMIL-P-53022B, Type

II Solvent retention Less than 1% after

7 days N/R

Specular gloss, 60degrees

N/R 10 minimum 30 maximum

Comments Solvent-borne High-solids

Solvent-borne High-solids

N/R = No Requirement Environmental Issues Environmental issues are dependent on the specific primers chosen. Health and Safety Issues Health and safety issues are dependent on the specific primer chosen. Additional Supporting Literature

• U.S. Army Research, Development, and EngineeringCenter, “Military Specification, Primer, Epoxy Coating,Corrosion Inhibiting, Lead and Chromate Free,”MIL-P-53022B, June 1, 1988

• U.S. Army Research, Development, and EngineeringCenter, “Qualified Products List of Products under MilitarySpecification MIL-P-53022, Primer, Epoxy Coating,Corrosion Inhibiting, Lead and Chromate Free,”QPL-53022-11, September 25, 1995.

Points of Contact

Deft, Inc.17451 Von Karman AvenueIrvine, CA 92714Phone: 714-474-0400 Extension 744Fax: 714-474-7269Point of Contact: Marisa Tarango,Lab Secretary

Pratt and LambertP.O. Box 2153Wichita, KS 67201Phone: 316-733-1361


Dexter Specialty1 East Water StreetWaukegan, IL 60085Phone: 312-241-2077

Randolph ProductsPark Place EastCarlstadt, NJ 07072Phone: 201-438-3700

Hentzen Chemical6937 W. Mill RoadMilwaukee, WI 53218Phone: 414-353-4200

Spraylat - Everseal1701 E. 122nd StreetChicago, IL 60633Phone: 312-646-5900

Lenmar, Inc.150 S. Calverton RoadBaltimore, MD 21223Phone: 301-947-2300

Valspar2841 S. Ashland Ave.Chicago, IL 60608Phone: 312-650-9415

Niles Chemical Paint225 Fort StreetNiles, MI 49120Phone: 800-253-7389

B.2.3. Waterborne Alternatives

B.2.3.1. General Information

Another alternative to chromium-containing solvent-borne and waterborneprimers is nonchromate waterborne primers. Waterborne coatings areformulated with water as the main solvent (dispersal medium), but stillmay contain 5% to 20% organic solvent to aid in wetting, viscositycontrol, and pigment dispersion. Waterborne coatings, which may beclassified as emulsions (latexes), colloidal dispersions, or solutions, maybe applied by air or airless spraying, autodeposition, curtain coating, dipcoating, electrocoating, electrostatic spraying, flow coating, or fluidizedbed coating. A wide variety of waterborne coatings are commerciallyavailable.

B.2.3.1.1. Environmental Issues

Because these waterborne coatings only contain a small amount ofsolvents, compliance with CAA amendment’s VOC emissions standardsmay be achieved by using these formulations. Sludge from the clean-up ofspray booths may be a listed or characteristic hazardous waste, dependingon the composition of the waterborne formulations and the properties ofthe waste. Disposal should be performed in accordance with federal (40


CFR 261), state, and local environmental control regulations. If a waste isdetermined to be hazardous, a licensed hazardous waste transporter anddisposal facility must be used.

B.2.3.1.2. Health and Safety Issues

In addition to reducing VOC emissions, the use of water in place of someorganic solvents also decreases objectionable odors, fire hazards, andexplosion potential. Specific OSHA PELs and American Conference ofGovernmental Industrial Hygienists (ACGIH) threshold limit values(TLVs) will depend on the chosen waterborne coatings.

B.2.3.2. MIL-P-85582B Class N: Non-Chromate Waterborne Epoxy PrimerCoatings

MIL-P-85582B Class N coatings may replace the original chromate-containing MIL-P-85582B Class C1 and Class C2 coatings. Althoughwaterborne primers may contain some solvents, this military specificationrequires that qualifying primers have less than 340 g/l (2.8 lb/gal). Inaddition, chlorinated solvents, cadmium, and cadmium compounds are notallowed in the formulation, and no more than 0.06 weight percent of leador lead compounds is allowed in the formulation. The MIL-P-85582Bprimers are formulated as sprayable coatings that can be applied byconventional, airless, HVLP, or electrostatic spray equipment. Theprimers are intended to be applied to a dry-film thickness of 0.6 mil to0.9 mil (0.0006 - 0.0009 inches).

MIL-P-85582B groups waterborne coatings into two types and threeclasses, as listed below. Only Class N coatings will be further consideredin this discussion because the Class C1 and Class C2 coatings containchromate.

Type ClassType I - StandardPigments

Class C1 - Barium chromate-based corrosion inhibitors

Type II - Low-infraredReflective Pigments

Class C2 - Strontium chromate-based corrosion inhibitorsClass N - Nonchromate-basedcorrosion inhibitors

The Qualified Products List of MIL-P-85582B lists several products forClass N coatings. These qualified products are available from seven


manufacturers. Refer to the “Points of Contact” at the end of this sectionfor a list of these manufacturers. The qualified Class N products listed inQPL-85582-4 and QPL-85582-4 Amendment 2 include:

• EWAE118 A/B, Type II (Spraylat Corporation)• EWDY048 A/B, Type I (Spraylat Corporation).

B.2.3.2.1. Technical Considerations The performance requirements of MIL-P-85582B Class N coatings are thesame as the conventional MIL-P-85582B Class C1 and Class C2 coatings.Therefore, these coatings should be technically acceptable alternatives inall applications currently using MIL-P-85582B Class C1 and Class C2.Note that MIL-P-85582B states that “Class N may not be substituted forClass C1 or Class C2, unless authorization for its use is given by theprocuring activity or engineering authority for the system or item to whichthe primer coating is to be applied.”

B.2.3.2.2. Environmental and Health and Safety Issues By transitioning from the Class C1 and Class C2 coatings of MIL-P-85582B to the Class N coatings, all environmental, health, and safetyimplications of chromium are eliminated. Other environmental, health,and safety issues depend on the specific primer chosen. Additional Supporting Literature

• Naval Air Systems Command, “Military Specification,Primer Coatings: Epoxy, Waterborne,” MIL-P-85582B andpreceding amendments, May 23, 1994

• Naval Air Systems Command, “Military Specification,Primer Coatings: Epoxy, Waterborne,” MIL-P-85582BInterim Amendment 1, August 31, 1994

• Naval Air Systems Command, “Qualified Products List ofProducts under Military Specification MIL-P-85582,Primer Coatings: Epoxy, Waterborne,” QPL-85582-4,December 30, 1994

• Naval Air Systems Command, “Qualified Products List ofProducts under Military Specification MIL-P-85582,Primer Coatings: Epoxy, Waterborne,” QPL-85582-4Amendment 2, April 17, 1995.


Points of Contact

Courtaulds Aerospace (DeSoto Brand)5454 San Fernando RoadP.O. Box 1800Glendale, CA 91209Phone: 708-668-1912Point of Contact: Tom Kearney

Deft, Inc.17451 Von Karman AvenueIrvine, CA 92714Phone: 714-474-0400 Extension 744Fax: 714-474-7269Point of Contact: Marisa Tarango, Lab Secretary

Dexter Aerospace Materials Division/Crown Metro Aerospace1 East Water StreetWaukegan, IL 60085Phone: 847-625-3338Fax: 847-623-4284Point of Contact: Marcie Dixon, Marketing Support Specialist

Products/Techniques, Inc.Box 760Bloomington, CA 92316

Spraylat Corporation1701 East 122nd StreetChicago, IL 60633-2362Phone: 312-646-590Point of Contact: Florence Lubick

Sterling Lacquer Manufacturing Company3150 Brannon AvenueSt. Louis, MO 63139Phone: 314-776-4450Point of Contact: Pete Moore

U.S. Paint Corporation831 South 21st StreetSt. Louis, MO 63103Point of Contact: Michael CaseyPhone: (800) 605-9696


B.3. BIBLIOGRAPHIC INFORMATION ON RELEVANT ABSTRACTS IDENTIFIED

Primer Coating (Aerosol, Lead and Chromate Free)A-A-2786, Federal Specification/Commercial Item Description (CID)Active 3/31/92, 2 pp.Qualified Products List (QPL) Required: None

Primer, Epoxy Coating, Corrosion Inhibiting, Lead and Chromate FreeMIL-P-53022BActive 6/1/88, 26 pp.Qualified Products List: QPL-53022-11, Active 9/25/95, 3 pp.MR - Army - Materials Directorate, Army Research Laboratory

An Assessment of Chromium-Free Primers for Prepainted Steel StripRichards, M. W.Welsh Laboratories, British Steel Technical, United KingdomProc. Chem. Conf., Vol. 45, 1993, pp. 49-56

Characterization of Chromium-Free No-Rinse Prepaint Coatings on Aluminum andGalvanized SteelDeck, Phillip D. and David W. ReichgottBetz Metchem, Trevose, PennsylvaniaMet. Finish., Vol. 90, No. 9, 1992, pp. 29-35

Chromate-Free, VOC Compliant Polyurethane Primer for AluminumUrethane Plastics and Products, Vol. 22, No. 1, January 1992, pp. 5-6

Chromate-Free Wash Primers for Steel or Aluminum AlloysBlattler, Paul and Marek SzandorowskiCanada, Minister of National DefenseUS Patent 5077332 A, 12/31/915 pp.

Development of a Chromate-Free Primer for Aluminum and Steel to meet CGSBSpecificationsFoster, T.; G. N. Blenkinsop; P. Blattler; and M. SzandorowskiCanada Department of National Defense, CanadaJournal of Coating Technology, Vol. 63, No. 801, 1991, pp. 101-10


Evaluation of Chromate Free Corrosion Inhibited Primers for Airbus AircraftsMatz, C. W.Dtsch. Aerosp. Airbus GmbH, Bremen, Germany, D-2800/1Corros. Control Low-Cost Reliab., Proc.-Int. Corros. Congr., 12th, Vol. 5A, 1993

Ion-Exchanged Silicas as Alternatives to Strontium Chromate in Coil Coating PrimersFletcher, T.Polym. Paint Col. J., Vol. 182, No. 4302, March 18, 1992, pp. 144-57

Lead- and Chromate-Free Anticorrosive Primers, High Solids, 100 Percent Solids, andWaterborne Coatings as Environmentally Sound Coatings for Reclamation Infrastructures(Final report)Baker, J. S.Bureau of Reclamation, Denver, CO. Materials Engineering BranchReport No.: REC-ERC-94-2September 1994, 96 pp.

Paints for Equipment Including Ships - Part 4: Solvent-Borne - Lead and Chromate Free- Anticorrosive Metal PrimerDocument Number: AS 4025.4, Non US Industry Standard (FSTD)Issuing Organization: SAA - Standards Association of Australia1994, 11 pp.

Paint Specification No. 26 Slow Drying Linseed Oil Black Maintenance Primer (WithoutLead and Chromate Pigments) (Steel Structures Painting Manual, Chapter 4 - PaintSpecifications)Document Number: PAINT 26, US Industry Standard (USTDIssuing Organization: SSPC - Steel Structures Painting Council1991, 4 pp.

Paint Specification No. 25 Red Iron Oxide, Zinc Oxide, Raw Linseed Oil and AlkydPrimer (Without Lead and Chromate Pigments) (Steel Structures Painting Manual,Ch. 4 - Paint Specs.)Document Number: PAINT 25, US Industry Standard (USTD)Issuing Organization: SSPC - Steel Structures Painting CouncilApproved by: DOD1991, 4 pp.


Primer, Alkyd, Fast Dry, Corrosion Inhibiting, Lead and Chromate Free, VOC CompliantMIL-P-11414EME - Army - Headquarters, CECOM Rde CenterActive 7/22/92, 14 pp.Qualified Products List: QPL-11414-18, Active 8/31/92, 3 pp.

Primer Coating, Alkyd, Corrosion-Inhibiting Lead and Chromate Free, VOC-CompliantTT-P-664DActive 8/28/92, 19 pp.Qualified Products List: QPL-TT-P-664-20, Active 2/9/94, 2 pp.

Primer Coating, Epoxy, Water Reducible, Lead and Chromate FreeMIL-P-53030AQualified Products List: QPL-53030-6, Active 9/25/95, 1 pp.MR - Army - Materials Directorate, Army Research LaboratoryActive 8/20/92

Replacement of Corrosion Protection Chromate Primers and Paints used in CryogenicApplications on the Space Shuttle with Wire Arc Sprayed Aluminum CoatingsDaniel, R. L.; H. L. Sanders (Rockwell International Corp., Rocketdyne Div., Huntsville,Alabama); and F. R. Zimmerman (NASA, Marshall Space Flight Center, Huntsville,Alabama)Aerospace Environmental Technology Conference, Huntsville, Alabama, August 10-11,1994, Washington, DC, National Aeronautics and Space Administration (NASAConference Publications, No. 3298), 1995, p. 285-291Contract No.: NAS8-40000

Replacement of Corrosion Protection Chromate Primers and Paints Used in CryogenicApplications on the Space Shuttle with Wire Arc Sprayed Aluminum CoatingsNational Aeronautics and Space Administration, Huntsville, AL. George C. MarshallSpace Flight CenterMarch 1995, 7 pp.Aerospace Environmental Technology Conference, pp. 285-291Contract No.: NAS8-40000

Search for a Chromate-Free Wash PrimerFoster, T.; G. N. Blenkinsop; P. Blattler; and M. SzandorowskiCan. Department of National Defense, CanadaJ. Coat. Technol, Vol. 63, No. 801, 1991, pp. 91-9


The Development of Alternatives to Chromate Inhibitors for the Protection of AerospaceAluminum AlloysBaldwin, K. R.; M. C. Gibson; P. L. Lane; and C. J. E. SmithRoyal Aerospace Establishment, Paint Research AssociationConference: 7th European Symposium on Corrosion Inhibitors-Proceedings. Vol. 2,Ferrara, Italy, 17-21 September 1990Published by Universita degli Studi di Ferrara, 44100 Ferrara, Italy, 1990, pp. 771-785

APPENDIX C

Product Identification

Potential Alternatives Report C-i

TABLE OF CONTENTS

Page

C.1. INTRODUCTION........................................................................................................... C-1

C.2. HIGH-SOLIDS PRIMERS.............................................................................................. C-2C.2.1. 02-W-38 (Deft, Inc.)............................................................................................ C-2C.2.2. 10P22-3/EC-270 (Dexter Aerospace Materials/Crown Metro Aerospace)......... C-4C.2.3. Aeroglaze 9740 (Lord Corporation)................................................................. C-6C.2.4. Aeroglaze 9741 (Lord Corporation)................................................................. C-8C.2.5. EEAE136 A/B (Spraylat Corporation)................................................................ C-9C.2.6. U-1201-NC/U-1202-F (Sterling Lacquer Manufacturing Company)................ C-11C.2.7. Alumigrip R1204/S3800 (U.S. Paint Corporation)........................................... C-13

C.3. WATERBORNE PRIMERS......................................................................................... C-16C.3.1. RW-3151-64 (Courtaulds Aerospace)............................................................... C-16C.3.2. RW-3181-64 (Courtaulds Aerospace)............................................................... C-18C.3.3. 44-W-16 (Deft, Inc.).......................................................................................... C-20C.3.4. 44-W-17 (Deft, Inc.).......................................................................................... C-21C.3.5. 44-W-18 (Deft, Inc.).......................................................................................... C-22C.3.6. 10PW22-2/ECW-119 (Dexter Aerospace Materials/Crown Metro Aerospace)C-23C.3.7. 10PW22-3/ECW-123 (Dexter Aerospace Materials Division/Crown Metro

Aerospace)......................................................................................................... C-25C.3.8. EWDY048 A/B MIL-P-85582 Type I (Spraylat Corporation).......................... C-28C.3.9. EWAE118 A/B MIL-P-85582 Type II (Spraylat Corporation)......................... C-29C.3.10.U-4800-NC/U-4801 (Sterling Lacquer Manufacturing Company) ................... C-31

C.4. ELECTROCOAT PRIMERS........................................................................................ C-33C.4.1. G28AD012 (BASF Corporation) ...................................................................... C-33C.4.2. U32CD210/U32AD290 (BASF Corporation)................................................... C-33

LIST OF TABLES

Table C-1. Ingredients of Deft 02-W-38 ............................................................................... C-2Table C-2. Ingredients of Dexter Aerospace Materials/ Crown Metro Aerospace

10P22-3/EC-270.................................................................................................. C-5Table C-3. Ingredients of Lord Corporation Aeroglaze 9470 ............................................... C-7Table C-4. Ingredients of Lord Corporation Aeroglaze 9741 ............................................... C-8Table C-5. Ingredients of Spraylat Corporation EEAE136 A/B ......................................... C-10Table C-6. Characteristics of U-1201-NC/U-1202F Reported by Sterling Lacquer

Manufacturing Company................................................................................... C-12

C-ii Potential Alternatives Report

Table C-7. Ingredients of Sterling Lacquer Manufacturing CompanyU-1201-NC/U-1202-F....................................................................................... C-12

Table C-8. Ingredients of U.S. Paint Corporation Alumigrip R1204/S3800 ...................... C-14Table C-9. Ingredients of Courtaulds Aerospace RW-3151-64 .......................................... C-16Table C-10. Ingredients of Courtaulds Aerospace RW-3181-64 .......................................... C-18Table C-11. Ingredients of Deft 44-W-16 ............................................................................. C-20Table C-12. Ingredients of Deft 44-W-17 ............................................................................. C-21Table C-13. Ingredients of Deft 44-W-18 ............................................................................. C-22Table C-14. Ingredients of Dexter Aerospace Materials/Crown Metro Aerospace

10PW22-2/ECW-119 ........................................................................................ C-24Table C-15. Ingredients of Dexter Aerospace Materials/Crown Metro Aerospace

10PW22-3/ECW-123 ........................................................................................ C-26Table C-16. Ingredients of Spraylat Corporation EWDY048 A/B........................................ C-28Table C-17. Ingredients of Spraylat Corporation EWAE118 A/B........................................ C-30Table C-18. Ingredients of Sterling Lacquer Manufacturing Company

U-4800-NC/U-4801 .......................................................................................... C-31Table C-19. Ingredients of BASF Corporation G28AD012.................................................. C-33Table C-20. Ingredients of BASF Corporation U32CD210/U32AD290 .............................. C-34


Potential Alternatives Report C-1

C.1. INTRODUCTION

Chromate-containing primers are currently being used in many applications due to thecorrosion-resistance and adhesion properties they provide. However, the continued use ofthese primers is undesirable due to the environmental, health, and safety concerns causedby the use of chromium. Three of the military specifications and types that specify thecurrently used primers are:

• MIL-P-23377G, Class C: High-Solids Epoxy Primer Coating withStrontium Chromate-Based Corrosion Inhibitors

• MIL-P-85582B, Class C1: Waterborne Epoxy Primer Coating withBarium Chromate-Based Corrosion Inhibitors

• MIL-P-85582B, Class C2: Waterborne Epoxy Primer Coating withStrontium Chromate-Based Corrosion Inhibitors.

Primers without chromium have been formulated that may be suitable to replace thesecoatings. This project focuses on exterior applications because depainting and paintingsubjects field personnel to chromium and exterior corrosion can be easily inspected andrepaired. A number of general alternatives to MIL-P-23377G and MIL-P-85582B have beenidentified in the technology survey (Appendix B). Most of the alternatives reduce theenvironmental, health, and safety issues associated with the original chromium-containingmilitary specifications, while having the potential to perform as well as the baselinecoatings. Nineteen products have been selected for further investigation. Informationabout these candidate nonchromate primers is given below. The information reportedabout each candidate nonchromate primer includes primer ingredients, permissibleexposure limits (PELs) established by the Occupational Safety and Health Administration(OSHA), and threshold limit values (TLVs) established by the American Conference ofGovernment Industrial Hygienists (ACGIH).

C-2 Potential Alternatives Report

C.2. HIGH-SOLIDS PRIMERS

C.2.1. 02-W-38 (Deft, Inc.) Primer 02-W-38 is a high-solids primer manufactured by Deft, Inc. which isdelivered in two components. The base component, Component A, is pigmented,and the catalyst, sometimes identified as Component B, is clear. To formulate theprimer, three parts by volume of the base component are mixed with one part byvolume of the catalyst. This product is proposed to meet the performancerequirements of MIL-P-23377G, Type I, Class N coatings. Because this primer isproposed to meet the requirements of MIL-P-23377G, it should have similarperformance characteristics to the original primers used. As mixed, the primer has a volatile organic compound (VOC) content of339 grams per liter (g/l), or 2.83 pounds per gallon (lb/gal). The ingredients listedon the Material Safety Data Sheets (MSDSs) for the two components are reportedin Table C-1.

Table C-1. Ingredients of Deft 02-W-38


OSHAPEL

ACGIHTLV

02-W-38 Component A (base)

Xylene 01330-20-7 <1 100 ppm 100 ppm Ethyl Benzene 00100-41-4 <1 100 ppm 100 ppm n-Butyl Acetate 00123-86-4 <1 150 ppm 150 ppm Methyl n-Propyl Ketone 00107-87-9 25 200 ppm 200 ppm C8 and C10 AromaticHydrocarbons

64742-95-6 <5 N.E. N.E.

N.E. = Not Established (Table C-1 continued on the next page)


Table C-1. Ingredients of Deft 02-W-38 (Continued)


OSHAPEL

ACGIHTLV

02-W-38 Component B (catalyst)

Mixture: 50

Polyamide Resin 68410-23-1 N.E. N.E. Triethylene Tetramine 00112-24-3 N.E. N.E. 1,3-Propanediamine,N-[3-(BranchedTridecyloxy) Propyl]

68479-04-9 N.E. N.E.

Polypropylene Oxide,Diamine Terminated

09046-10-0 N.E. N.E.

Bisphenol A 00080-05-7 50 N.E. N.E. Mixture: 15

N-Aminoethylpiperazine 00140-31-8 N.E. N.E. Nonylphenol (mixed) 25154-52-3 N.E. N.E. Benzyl Alcohol 00100-51-6 N.E. N.E. Bisphenol A 00080-05-7 N.E. N.E. N,N-Dimethylbenzyl-amine

00103-83-3 N.E. N.E.

sec-Butyl Alcohol 00078-92-2 30 150 ppm 100 ppm C8 and C10 AromaticHydrocarbons

64742-95-6 <5 N.E. N.E.

N-(3-Trimethoxysilyl-propyl) Ethylenediamine(amino silane ester)

01760-24-3 <5 N.E. N.E.

2,4,6-Tris(Dimethyl-aminomethyl) Phenol

00090-72-2 <5 N.E. N.E.

N.E. = Not Established While there is no PEL or TLV for benzyl alcohol, there is an American IndustrialHygiene Association (AIHA) Workplace Environmental Exposure Limit (WEEL)of 10 ppm. In addition, the manufacturer recommends an occupational exposurelimit of 100 ppm for the C8 and C10 aromatic hydrocarbons, and Ciba-Geigyrecommends an occupational exposure limit of 5 ppm for 2,4,6-tris(dimethyl-aminomethyl) phenol. Additional Supporting Literature

• Deft, Inc., “02-W-38,” Product Information Data Sheet• Smith, Mike, “02W038CAT,” Material Safety Data Sheet,

January 31, 1997


• Smith, Mike, “02W038,” Material Safety Data Sheet,May 31, 1995

• Tarango, Marisa, Deft, Inc., Telephone Conversation,February 28, 1996.

Point of Contact Marisa Tarango, Lab Secretary Deft, Inc. 17451 Von Karman Avenue Irvine, CA 92714 Phone: 714-474-0400 Extension 744 Fax: 714-474-7269

C.2.2. 10P22-3/EC-270 (Dexter Aerospace Materials/Crown Metro Aerospace) Primer 10P22-3/EC-270, manufactured by Dexter Aerospace Materials (formerlyCrown Metro Aerospace), is a fluid-resistant, high-solids epoxy primer that iscompatible with urethane topcoats. Its intended use is coating exterior andinterior components of aircraft. This primer can be applied to a recommendedthickness of 0.6 mil to 0.9 mil (0.0006 - 0.0009 inches) by standard suction,pressure pot, air-assist airless, high-volume low-pressure (HVLP), or electrostaticliquid spray equipment. This primer is delivered in two components: (1) 10P22-3, the base, and(2) EC-270, the activator. To mix the primer, three parts by volume of 10P22-3 isadded to one part by volume of EC-270. At 77°F and 50% relative humidity, theapplied coating requires four to five hours to dry before topcoating. The60 degree geometry specular gloss of the primer is 10 to 60. The mixed pot life isfour hours. As mixed, the primer has a VOC content of 340 g/l. The constituents of theprimer that are listed on the MSDSs are provided in Table C-2.


Table C-2. Ingredients of Dexter Aerospace Materials/Crown Metro Aerospace 10P22-3/EC-270


OSHAPEL

ACGIHTLV

10P22-3 (base)

Trimethylol-propaneTriacrylate

15625-89-5 <10 N.E. N.E.

Toluene 00108-88-3 <10 200 ppm 50 ppm(skin)

Methyl n-AmylKetone

00110-43-0 10 - 20 100 ppm 50 ppm


00108-10-1 <10 100 ppm 50 ppm

Formaldehyde 00050-00-0 Trace 0.75 ppm 0.3 ppma

Benzene 00071-43-2 Trace 10 ppm 0.5 ppm(skin)

EC-270 (activator)

Mixture: <10

Dimethylamine 00124-40-3 10 ppm 5 ppm Methylphenol(cresol)

01319-77-3 5 ppm(skin)

5 ppm (skin)

Toluene 00108-88-3 20 - 30 200 ppm 50 ppm(skin)

Benzyl Alcohol 00100-51-6 <10 N.E. N.E. m-Xylene Diamine 01477-55-0 <10 N.E. 0.1 mg/m3

(skina) Benzene 00071-43-2 Trace 10 ppm 0.5 ppm

(skin) N.E. =Not Established a Ceiling Value

While there is no PEL or TLV for benzyl alcohol, there is an AIHA WEEL of10 ppm. Although there is no OSHA PEL for m-xylene diamine, the NationalInstitute of Occupational Safety and Health (NIOSH) suggests a ceilingRecommended Exposure Limit (REL) of 0.1 mg/m3, with dermal penetrationbeing a particular concern. Additional Supporting Literature

• High Solids Urethane Compatible Non Chromate Epoxy Primer,”Technical Data, July 1995


• Sanchez, Marie, Dexter Aerospace Materials Division/CrownMetro Aerospace, Telephone Conversation, February 27, 1996

• The Dexter Corporation, “10P22-3,” Material Safety Data Sheet,April 18, 1997

• The Dexter Corporation, “EC-270,” Material Safety Data Sheet,April 18, 1997.

Point of Contact Marcie Dixon, Marketing Support Specialist Dexter Aerospace Materials Division/Crown Metro Aerospace 1 East Water Street Waukegan, IL 60085 Phone: 847-625-3338 Fax: 847-623-4284

C.2.3. Aeroglaze 9740 (Lord Corporation) Aeroglaze 9740, which is an epoxy-based high-solids primer, is one possiblealternative to the currently used chromate primers. It is designed to be used onproperly treated aluminum or other metal surfaces that need corrosion resistance.During application of Aeroglaze 9740, the surface and ambient temperatures mustbe above 50°F and at least 5°F above the dew point. Aeroglaze 9740 can beapplied with either conventional or HVLP spray equipment. Depending on theapplication, the primer is typically applied to a thickness between0.6 mil and 0.9 mil. Topcoating within 18 hours of applying this primer isrecommended by Lord Corporation. The theoretical coverage of Aeroglaze 9740is 1.030 ft2/gal/mil. The mixture has a pot life of four hours at 77°F and a shelflife of one year from the date of shipment. The cure time is five hours at 77°F toachieve a tack-free surface. As measured in accordance with ASTM D 3960-89, the VOC content ofAeroglaze 9740 (as mixed) is 2.6 lb/gal (311 g/l). The primer constituents listedon the MSDSs are reported in Table C-3.


Table C-3. Ingredients of Lord Corporation Aeroglaze 9470


OSHAPEL

ACGIHTLV

Aeroglaze 9740 Part A

Epoxy Resin N.E. <30 N.E. N.E.

n-Butyl Acetate 00123-86-4 <30 150 ppm 150 ppm

Aeroglaze 9740 Part B

ProprietaryAmineCompounds

N.E. <19 N.E. N.E.

ProprietaryPolyamine

N.E. <70 N.E. N.E.

n-Butyl Alcohol 00071-36-3 <20 100 ppm 25 ppma

Proposed N.E. = Not Established a Ceiling Value


• Lord Corporation, Chemical Products Division, “Aeroglaze 9740

Part A,” Material Safety Data Sheet, February 1, 1995• Lord Corporation, Chemical Products Division, “Aeroglaze 9740

Part B,” Material Safety Data Sheet, August 5, 1994• Lord Industrial Coatings, “9740 Chromate-Free, Low VOC, Epoxy

Primer,” Aeroglaze Coatings for the Aerospace Industry, 1993• Markley, Darcie, Lord Corporation, Telephone Conversation,

February 28, 1996.

Point of Contact Darcie Markley Lord Corporation P.O. Box 10038 2000 Grandview Blvd. Erie, PA 16514-0038 Phone: 814-868-0924


C.2.4. Aeroglaze 9741 (Lord Corporation)

Aeroglaze 9741 is a two-part epoxy primer designed for use on preparedaluminum and other metal surfaces; this primer is also suitable for use on manycomposite surfaces. Aeroglaze 9741 (gray color) is very similar toAeroglaze 9740 (yellow color). Aeroglaze 9741 is intended to meet theperformance requirements of MIL-P-23377G, although it is not yet on the QPL.Lord Corporation has tested this primer against the requirements of MIL-P-23377G. The results of this testing indicate that the primer will meet therequirements of MIL-P-23377G. The primer is currently undergoing qualificationtesting at several air force facilities. The primer is reported to have excellentchemical- and corrosion-resistance properties. The pot life of the mixed primer at77°F is four hours. Fully mixed Aeroglaze 9741 contains approximately 310 g/l VOCs. The chemicalconstituents of the Aeroglaze 9741 primer, as listed on the MSDSs are reported inTable C-4.

Table C-4. Ingredients of Lord Corporation Aeroglaze 9741


OSHAPEL

ACGIHTLV

Aeroglaze 9741 Part A

Carbon Black 01333-86-4 1 3.5 mg/m3 3.5 mg/m3


n-Butyl Acetate 00123-86-4 <25 150 ppm 150 ppm

Aeroglaze 9741 Part B

ProprietaryAmineCompounds

N.E. <15 N.E. N.E.

ProprietaryPolyamine

N.E. <70 N.E. N.E.

n-Butyl Alcohol 00071-36-3 <20 100 ppm 25 ppma

Proposed N.E. = Not Established a Ceiling Value


• Lord Corporation, Chemical Products Division, “Aeroglaze 9741Part A,” Material Safety Data Sheet, September 12, 1996

• Lord Corporation, Chemical Products Division, “Aeroglaze 9741Part B,” Material Safety Data Sheet, September 12, 1996


• Markley, Darcie, Lord Corporation, Telephone Conversation,November 20, 1996

• Wasieski, Steve, Lord Corporation, Telephone Conversation,December 3, 1996.

Point of Contact Steve Wasieski Lord Corporation P.O. Box 10038 2000 West Grandview Blvd. Erie, PA 16514-0038 Phone: 814-868-3366

C.2.5. EEAE136 A/B (Spraylat Corporation) Primer EEAE136 A/B is a solvent-borne low-density nonchromate primer thatoffers corrosion resistance and chemical, solvent, and Skydrol resistance. PrimerEEAE136 A/B is compatible with urethane topcoats (MIL-C-85285B) and isformulated to be used with various spray equipment and spray techniques. The manufacturer of this product intends it as a qualified product of MIL-P-23377G Type I Class N although it is not yet on this Qualified Product List. Theprimer is prepared for application by mixing three parts by volume of EEAE136 Abase with one part by volume of EEAE136 B curing solution. The followinginformation was also available: Pot Life: Six hours Curing Time: Four hours dry to touch Eight hours dry hard Seven days full cure. The maximum VOC content of this mixture is 340 g/l. The constituents of theprimer listed on the MSDSs of the two components are reported in Table C-5.


Table C-5. Ingredients of Spraylat Corporation EEAE136 A/B


OSHAPEL

ACGIHTLV

EEAE136 Component A


00108-10-1 <10 100 ppm 50 ppm

Methyl n-AmylKetone

00110-43-0 <10 100 ppm 50 ppm

Titanium Dioxide 13463-67-7 <10 15 mg/m3

as Dust 10 mg/m3

as Dust Methyl Ethyl Ketone 00078-93-3 <10 200 ppm 200 ppm

Di-Isobutyl Ketone 00108-83-8 <10 50 ppm 25 ppm

Mineral Spirits 64741-41-9 <10 N.E. N.E.


Amorphous Silica 67762-90-7 <10 N.E. N.E.

Talc 14807-96-6 <50 20 mppcf 2 mg/m3

Respirable Silicon Dioxide(crystalline silica)

14808-60-7 0.27 0.1 mg/m3

asRespirableDust

0.1 mg/m3

asRespirableDust

EEAE136 Component B


00108-10-1 <25 100 ppm 50 ppm

Methyl n-AmylKetone

00110-43-0 <25 100 ppm 50 ppm

Cyclohexanone 00108-94-1 <25 50 ppm 25 ppm(skin)

N,N-Dimethyl-benzylamine

00103-83-3 <10 N.E. N.E.

2,4,6-Tris(Dimethyl-aminomethyl)Phenol

00090-72-2 <10 N.E. N.E.


While there is not a PEL or a TLV for 2,4,6-tris(dimethylaminomethyl) phenol,Ciba-Geigy recommends a limit of 5 ppm. In addition, while no PEL or TLVexists for mineral spirits (CAS #64741-41-9, also known as heavy straight-runnaphtha), Stoddard Solvent may be considered a surrogate for mineral spiritswhen predicting the occupational health and safety effects of this product. TheOSHA PEL for Stoddard Solvent is 500 ppm, and the ACGIH TLV for StoddardSolvent is 100 ppm.



• Lubick, Florence, Spraylat Corporation, Telephone Conversation,February 27, 1996

• Schmidt, Jim, Material Safety Data Sheet for Coatings, Resins andRelated Material, “EEAE136A, MIL-P-23377G Type I Class NEpoxy Part A,” February 27, 1996

• Schmidt, Jim, Material Safety Data Sheet for Coatings, Resins andRelated Materials, “EEAE136B, MIL-P-23377G Type I Class NEpoxy Primer – Activator,” February 27, 1996

• Spraylat Aerospace Coatings Corporate Literature, 1995.

Point of Contact Florence Lubick Spraylat Corporation 1701 East 122nd Street Chicago, IL 60633-2362 Phone: 312-646-5900 Fax: 312-646-3743

C.2.6. U-1201-NC/U-1202-F (Sterling Lacquer Manufacturing Company) Primer U-1201-NC/U-1202-F, produced by Sterling Lacquer ManufacturingCompany, is intended to meet the requirements of MIL-P-23377G Type IClass N. The coating consists of two components: Component A, which is theepoxy resin, pigments, and solvents; and Component B, which consists of thepolyamide and/or resins and solvents. Component B is the curing agent forComponent A. The primer formulation consists of two parts by volume ofComponent A to one part by volume of Component B. The viscosity of theprimer is suitable for spray applications. The manufacturer of this coating intends it to meet the performance requirementsof MIL-P-23377G, Class N coatings, although it is not yet on the QualifiedProduct List. Some of the performance requirements that were measured bySterling Lacquer Manufacturing Company and presented in a test report areprovided in Table C-6.


Table C-6. Characteristics of U-1201-NC/U-1202F Reported bySterling Lacquer Manufacturing Company

Parameter Performance of U-1201-NC/U-1202-F Salt Spray, on Aluminum 2,000 Hour Salt Spray, on Aluminum/Graphite 500 Hour Filiform Corrosion Resistance Pass MEK Resistance Withstand Rubbing Fluid Resistance: Lubricating Oil 24 Hour at 121°C Fluid Resistance: Hydraulic Fluid 24 Hour at 66°C Fluid Resistance: Water 4 Days at 49°C Storage Stability 1 Year Accelerated Storage Stability 14 Days at 140°F Pot Life 4 Hour Impact Flexibility (elongation) 10% Adhesion 24 Hour in Water

The VOC content is a maximum of 340 grams per liter. The constituents that arelisted on the MSDSs for the two components are reported in Table C-7.

Table C-7. Ingredients of Sterling Lacquer Manufacturing CompanyU-1201-NC/U-1202-F


OSHA PEL ACGIH TLV

U-1201-NC (Component A)

Toluene 00108-88-3 22 200 ppm 50 ppm (skin)

Reaction Productsof Epichlorohydrinand Bisphenol A

25085-99-8 33 N.E. N.E.

Xylene 01330-20-7 9 100 ppm 100 ppm

Solvent Naphtha(petroleum),Heavy Alkylate

64741-65-7 0.10 N.E. N.E.

Titanium Dioxide 13463-67-7 <5 15 mg/m3 10 mg/m3

Aliphatic GlycidylEther

68081-84-5 5 N.E. N.E.

Silicon Dioxide(crystalline silica)

14808-60-7 N.R. 0.1 mg/m3 asRespirableDust

0.1 mg/m3 asRespirableDust

N.E. = Not Established N.R. = Percentage Not Reported

(Table C-7 continued on next page)


Table C-7. Ingredients of Sterling Lacquer Manufacturing Company U-1201-NC/U-1202-F (Continued)


OSHAPEL

ACGIHTLV

U-1202-F (Component B)

Benzyl Alcohol 00100-51-6 21 N.E. N.E.

Toluene 00108-88-3 24 200 ppm 50 ppm


00090-72-2 5 N.E. N.E.

N.E. = Not Established N.R. = Percentage Not Reported Although there is no PEL or TLV for solvent naphtha (petroleum), heavy alkylate,the manufacturer recommends a limit of 300 ppm. The AIHA WEEL is 10 ppmfor benzyl alcohol. Ciba-Geigy recommends an exposure limit of 5 ppm fortri(dimethylaminomethyl) phenol. Additional Supporting Literature

• Moore, P. D., “U-1201-NC,” Material Safety Data Sheet,November 2, 1995

• Moore, P. D., “U-1202-F,” Material Safety Data Sheet,October 7, 1993

• Moore, Pete, Sterling Lacquer Manufacturing Company,Telephone Conversation, February 29, 1996

• Sterling Lacquer Manufacturing Company, Test Report,MIL-P-23377G, Primer Coatings: Epoxy, High-Solids, Type IClass N, VOC Compliant, Non-Chromate.

Point of Contact Pete Moore Sterling Lacquer Manufacturing Company 3150 Brannon Avenue St. Louis, MO 63139-1498 Phone: 314-776-4450

C.2.7. Alumigrip R1204/S3800 (U.S. Paint Corporation) This product is a high-solids chromate-free primer intended for use as ananti-corrosive coating for aluminum. The primer is a two-component, modifiedpolyamide-epoxy resin. The R1204 component contains the epoxy resin andpigment. The S3800 component is the high-solids converter for the epoxy primer.


The theoretical coverage of this primer is 980 ft2/gal/mil dry film thickness. Themixture has a pot life of four hours at 77°F and 50% relative humidity. The “totape” cure time is six hours at 77°F and 50% relative humidity. The mixed primercan be further reduced by adding T0006 Reducer at up to 20% of its mixedvolume to improve flow characteristics. The VOC content of the mixed and fully reduced primer is approximately340 g/l. The chemical constituents of the primer listed on the MSDSs are reportedin Table C-8.

Table C-8. Ingredients of U.S. Paint Corporation Alumigrip R1204/S3800


OSHAPEL

ACGIHTLV

R1204 (base)

Di-Isobutyl Ketone 00108-83-8 9 50 ppm 25 ppm

Epoxy Resin N.E. 31 N.E. N.E.

Methyl Ethyl Ketone 00078-93-3 5 200 ppm 200 ppm

Aromatic PetroleumDistillates

64742-95-6 2 N.E. N.E.

4-Hydroxy-4-Methyl-2-Pentanone(diacetone alcohol)

00123-42-2 4 50 ppm 50 ppm

Xylene 01330-20-7 4 100 ppm 100 ppm

Talc 14807-96-6 9 20 mppcf 2 mg/m3

S3800 (converter)

Methyl Ethyl Ketone 00078-93-3 10 200 ppm 200 ppm

Toluene 00108-88-3 19 200 ppm 50 ppm(skin)

n-Butyl Alcohol 00071-36-3 6 100 ppm 25 ppma

Proposed Polymeric Fatty AcidAmide

N.E. N.R. N.E. N.E.

2,4,6-Tris(Dimethyl-aminomethyl) Phenol

00090-72-2 1 N.E. N.E.

N.R. = Percentage Not Reported N.E. = Not Established a Ceiling Value mppcf = million particles per cubic foot Although there is not a PEL or TLV for aromatic petroleum distillates, themanufacturer recommends a limit of 100 ppm. Ciba-Geigy recommends anexposure limit of 5 ppm for 2,4,6-tris(dimethylaminomethyl) phenol.



• U.S. Paint Corporation, “High Solids Non-Chromated PrimerR1204,” Material Safety Data Sheet, May 2, 1995

• U.S. Paint Corporation, “High Solids Converter for Anti-CorrosiveEpoxy Primer S3800,” Material Safety Data Sheet, May 2, 1995

• U.S. Paint Corporation, “High Solids R1204-K13,” TechnicalProduct Data Bulletin, September 1, 1994

• Roemer, Jeffrey, U.S. Paint Corporation, Telephone Conversation,November 19, 1996

• Casey, Michael, U.S. Paint Corporation, Telephone Conversation,December 2, 1996.

Point of Contact Michael Casey U.S. Paint Corporation 831 South 21st Street Saint Louis, Missouri 63103 Phone: (800) 605-9696


C.3. WATERBORNE PRIMERS C.3.1. RW-3151-64 (Courtaulds Aerospace)

This nonchromate primer from Courtaulds Aerospace has two components:RW-3151-64 B001, the base compound, and RW-3151-64 A004, the activator.Prior to primer application, four parts of the base are mixed with one part of theactivator. The manufacturer has had RW-3151-64 tested for conformance withMIL-P-85582B Type I Class 2 requirements. This primer has conformed to allrequirements tested. Tests not performed to date include one-year storage stability(test in progress), strippability with MIL-R-81294, and aluminum/graphitecorrosion resistance. As mixed, the primer has a VOC content of 321 g/l. The constituents, as listed onthe MSDSs for the two components are reported in Table C-9.

Table C-9. Ingredients of Courtaulds Aerospace RW-3151-64


OSHAPEL

ACGIHTLV

RW-3151-64 B001 (base)


2-Propoxyethanol(ethylene glycolmonopropyl ether)

02807-30-9 5 N.E. N.E.

Benzyl Alcohol 00100-51-6 <5 N.E. N.E.

1-Butoxy-2-Propanol (propyleneglycol n-butyl ether)

05131-66-8 <5 N.E. N.E.

Dipropylene GlycolMethyl Ether

34590-94-8 <5 100 ppm(skin)

100 ppm(skin)

Amorphous Silica 112926-00-8 10 20 mppcf 10 mg/m3

Titanium Dioxide 13463-67-7 10 15 mg/m3 10 mg/m3

CalciumMetasilicate

13983-17-0 N.R. N.E. N.E.

CeramicMicrospheres

66402-68-4 N.R. N.E. N.E.

Barium Sulfate 07727-43-7 N.R. 15 mg/m3,5 mg/m3

Respirable

10 mg/m3

N.R. = Percentage Not Reported N.E. = Not Established mppcf = million particles per cubic foot



Table C-9. Ingredients of Courtaulds Aerospace RW-3151-64 (Continued)

Chemical CAS # Percentage(by mass)

OSHAPEL

ACGIHTLV

RW-3151-64 A004 (activator)

Isophorone Diamine 02855-13-2 5 N.E. N.E.


00090-72-2 <5 N.E. N.E.


34590-94-8 <5 100 ppm(skin)

100 ppm(skin)

(3-Aminopropyl)Silanetriol

58160-99-9 10 N.E. N.E.

N.R. = Percentage Not Reported N.E. = Not Established mppcf = million particles per cubic foot In addition to the above listed PELs and TLVs, the manufacturer recommends alimit of 25 ppm for 2-propoxyethanol. The AIHA WEEL for benzyl alcohol is10 ppm. Ciba-Geigy recommends an exposure limit of 5 ppm for 2,4,6-tris(dimethylaminomethyl) phenol. Additional Supporting Literature

• Courtaulds Aerospace, “RW-3151-64 Activator,” Material SafetyData Sheet, June 5, 1995

• Courtaulds Aerospace, “RW-3151-64 Base Compound,” MaterialSafety Data Sheet, June 6, 1995

• Courtaulds Aerospace, Qualification Test Report, RW-3151-64,Chromate Free Waterborne Epoxy Primer, June 27, 1995.

Point of Contact Tom Kearney Courtaulds Aerospace 5430 San Fernando Road P.O. Box 1800 Glendale, CA 91209 Phone: 708-668-1912


C.3.2. RW-3181-64 (Courtaulds Aerospace) Primer RW-3181-64 is very similar to the RW-3151-64 primer described inSection C.3.1 above, with the exception that the RW-3181-64 primer contains lessaccelerator than the RW-3151-64 primer and therefore cures at a slower rate. This nonchromate primer from Courtaulds Aerospace has two components:RW-3181-64 base and RW-3181-64 activator. In preparation for primerapplication, four parts of the base are mixed with one part of the activator. Thisprimer is intended to meet the requirements of MIL-P-85582. As mixed, the primer has a VOC content of approximately 320 grams per liter.The constituents listed on the MSDSs are reported in Table C-10.

Table C-10. Ingredients of Courtaulds Aerospace RW-3181-64


OSHAPEL

ACGIHTLV

RW-3181-64 Base



02807-30-9 5 N.E. N.E.


1-Butoxy-2-Propanol (propyleneglycol n-butyl ether)

05131-66-8 <5 N.E. N.E.


34590-94-8 <5 100 ppm(skin)

100 ppm(skin)

Amorphous Silica 112926-00-8 10 20 mppcf 10 mg/m3


CalciumMetasilicate

13983-17-0 N.R. N.E. N.E.

CeramicMicrospheres

66402-68-4 N.R. N.E. N.E.

Barium Sulfate 07727-43-7 N.R. 15 mg/m3,5 mg/m3

Respirable

10 mg/m3

N.R. = Percentage Not Reported N.E. = Not Established



Table C-10. Ingredients of Courtaulds AerospaceRW-3181-64 (Continued)


OSHAPEL

ACGIHTLV

RW-3181-64 Activator

Isophorone Diamine 02855-13-2 10 N.E. N.E.

2,4,6-Tris(Dimethyl-aminomethyl)phenol

00090-72-2 <5 N.E. N.E.


34590-94-8 <5 100 ppm(skin)

100 ppm(skin)

(3-Aminopropyl)Silanetriol

58160-99-9 15 N.E. N.E.

N.R. = Percentage Not Reported N.E. = Not Established In addition to the above listed PELs and TLVs, the manufacturer recommends aTLV of 25 ppm for 2-propoxyethanol. There is an AIHA WEEL of 10 ppm forbenzyl alcohol. Ciba-Geigy recommends an exposure limit of 5 ppm for2,4,6-tris(dimethylaminomethyl) phenol. Additional Supporting Literature

• Courtaulds Aerospace, “RW-3181-64 Activator,” Material SafetyData Sheet, August 13, 1996

• Courtaulds Aerospace, “RW-3181-64 Base,” Material Safety DataSheet, August 13, 1996

• Ebraham, Yousry, Courtaulds Aerospace, TelephoneConversations, December 2, 1996 and December 4, 1996.

Point of Contact Yousry Ebraham Courtaulds Aerospace 5430 San Fernando Road P.O. Box 1800 Glendale, CA 91209 Phone: (818) 549-7548


C.3.3. 44-W-16 (Deft, Inc.) One alternative to chromate-containing waterborne primers is 44-W-16,manufactured by Deft, Inc. This primer is proposed to meet specificationMIL-P-85582 as a Type I, Class N coating, although it is not listed on theApril 17, 1995 Qualified Products List. Because this product is proposed to meetMIL-P-85582 performance requirements, it should have similar characteristics tothe currently used chromate primers. Primer 44-W-16 is provided as a polyamide base component and a catalyst. Tomix the primer, two parts by volume of the base component are added to one partof the catalyst, and deionized water is mixed in to achieve the desired viscosity. As mixed, this product has a VOC content of 339 grams per liter (or 2.8 poundsper gallon). The following constituents are listed on the MSDSs are reported inTable C-11.



OSHAPEL

ACGIHTLV

44-W-16 Base

sec-Butyl Alcohol 00078-92-2 25 150 ppm 100 ppm

C8 and C10

AromaticHydrocarbons

64742-95-6 <1 N.E. N.E.

Dispersion Agent N.E. <1 N.E. N.E.

44-W-16 Catalyst

Nitroethane 00079-24-3 30 100 ppm 100 ppm N.E. = Not Established In addition, the manufacturer recommends a limit of 100 ppm for C8 and C10

aromatic hydrocarbons. Additional Supporting Literature

• Deft, Inc., “44-W-16,” Product Information Data Sheet• Smith, Mike, “44W016,” Material Safety Data Sheet, May 31,

1995• Smith, Mike, “44W016CAT,” Material Safety Data Sheet,

May 31, 1995• Tarango, Marisa, Deft, Inc., Telephone Conversation,

February 28, 1996.



C.3.4. 44-W-17 (Deft, Inc.) Similar to 44-W-16 (Section C.3.3), 44-W-17 is proposed to meet thespecification requirements of MIL-P-85582B Type I, Class N. The primer iscomprised of two parts: a pigmented base component, and a catalyst for curingthe epoxy primer. The primer is prepared by mixing two parts of the base withone part of the catalyst. Because this product is proposed to meet MIL-P-85582performance requirements, it should have similar characteristics to the currentlyused chromate primers. The VOC content of the mixture is 327 g/l, or 2.81 lb/gal. Table C-12 reports theconstituents listed in the MSDSs.



OSHAPEL

ACGIHTLV

44-W-17 Base


C8 and C10

AromaticHydrocarbon

64742-95-6 <1 N.E. N.E.

44-W-17 Catalyst


In addition, the manufacturer recommends a limit of 100 ppm for C8 and C10

aromatic hydrocarbons. Additional Supporting Literature

• Deft, Inc., “44-W-17,” Product Information Data Sheet• Smith, Mike, “44W017,” Material Safety Data Sheet,

May 31, 1995


• Smith, Mike, “44W017CAT,” Material Safety Data Sheet,May 31, 1995

• Tarango, Marisa, Deft, Inc., Telephone Conversation,February 28, 1996.


C.3.5. 44-W-18 (Deft, Inc.) Primer 44-W-18 is similar to 44-W-16 and 44-W-17 primers (Sections C.3.3 andC.3.4), and is proposed to meet the specification requirements of MIL-P-85582BType I, Class N. The primer is comprised of two parts: a pigmented basecomponent, and a catalyst for curing of the epoxy primer. The primer is preparedby mixing two parts of the base with one part of the catalyst. Because this productis proposed to meet MIL-P-85582 performance requirements, it should havesimilar characteristics to the currently used chromate primers. The VOC content of the mixture is approximately 340 g/l, or 2.8 lb/gal. Theingredients listed on the MSDSs for the two components of the primer arereported in Table C-13.



OSHAPEL

ACGIHTLV

44-W-18 Base


C8 and C10

AromaticHydrocarbon

64742-95-6 <1 N.E. N.E.

44-W-18 Catalyst


In addition, the manufacturer recommends an exposure limit of 100 ppm for C8

and C10 aromatic hydrocarbons.



• Albers, Richard, “44W018,” Material Safety Data Sheet, April 24,1997

• Albers, Richard, “44W018CAT,” Material Safety Data Sheet,April 24, 1997

• Tarango, Marisa, Deft, Inc., Telephone Conversation,November 20, 1996.


C.3.6. 10PW22-2/ECW-119 (Dexter Aerospace Materials/Crown Metro Aerospace) The 10PW22-2/ECW-119 is a chemically cured, water-reducible epoxy primerthat was designed by Dexter Aerospace Materials Division/Crown MetroAerospace to provide corrosion and chemical resistance for aluminum substrates.The primer comes in two parts: (1) 10PW22-2, which is the base, and(2) ECW-119, which is the waterborne epoxy curing solution. To mix the primer,four parts by volume of 10PW22-2, one part by volume of ECW-119, and two andone-half parts by volume of deionized water are combined. This primer can beapplied to a recommended film thickness of 0.6 mil to 1.0 mil with standardsuction or pressure spray equipment. The primer has a pot life of four hours aftermixing. After application, the primer should be allowed to dry for two hoursbefore topcoating. Other performance characteristics are available from DexterAerospace Materials. As mixed, the primer has a VOC content of 340 g/l. The constituents of theprimer listed on the MSDSs are reported in Table C-14.


Table C-14. Ingredients of Dexter Aerospace Materials/CrownMetro Aerospace 10PW22-2/ECW-119


OSHA PEL ACGIHTLV

10PW22-2 (base)

Glycidyl EtherPhenol FormaldehydeCopolymer

28064-14-4 <10 N.E. N.E.


02807-30-9 <10 N.E. N.E.

1-Methoxy-2-Propanol

00107-98-2 <10 N.E. 100 ppm

1-Butoxy-2-Propanol(propylene glycoln-butyl ether)

05131-66-8 <10 N.E. N.E.


Zinc in Nonvolatiles 07440-66-6 7 - 8 N.E. N.E.

Lead in Nonvolatiles 07439-92-1 Trace 0.05 mg/m3 0.05 mg/m3

Arsenic inNonvolatiles

07440-38-2 Trace 0.01 mg/m3 0.01 mg/m3

Beryllium inNonvolatiles

07440-41-7 Trace 0.002mg/m3

0.002 mg/m3

Cadmium inNonvolatiles

07440-43-9 Trace 0.005mg/m3

0.01 mg/m3

Inhalable; 0.002 mg/m3

Respirable ECW-119 (curing solution)


00107-98-2 30 - 40 N.E. 100 ppm

1-Butoxy-2-Propanol 05131-66-8 <10 N.E. N.E.

Benzyl Alcohol 00100-51-6 10 - 20 N.E. N.E.

Xylene 01330-20-7 4 100 ppm 100 ppm

n-Propyl Alcohol 00071-23-8 <10 200 ppm 200 ppm(skin)


N.E. = Not Established In addition, the manufacturer recommends a time-weighted average exposurelimit of 25 ppm for 2-propoxyethanol. AIHA recommends a WEEL of 10 ppmfor benzyl alcohol.



• The Dexter Corporation, “10PW22-2,” Material Safety Data Sheet,April 18, 1997

• The Dexter Corporation, “ECW-119,” Material Safety Data Sheet,April 18, 1997

• Dexter Aerospace Materials Division, Crown Metro Aerospace,“10PW22-2, Skydrol Resistant Water Reducible Epoxy PrimerChromate Free,” Technical Data, July 1995

• Sanchez, Marie, Dexter Aerospace Materials Division/CrownMetro Aerospace, Telephone Conversation, February 27, 1996.


C.3.7. 10PW22-3/ECW-123 (Dexter Aerospace Materials Division/Crown MetroAerospace) Primer 10PW22-3/ECW-123, also known as Skydrol-Resistant Water-ReducibleEpoxy Primer, is a chromate-free chemically cured, water-reducible epoxy primer.The primer is designed to provide corrosion and chemical resistance overaluminum substrates. The primer comes in two parts: (1) 10PW22-3, which isthe base; and (2) ECW-123, which is the waterborne epoxy curing solution. Tomix the primer, add four parts by volume of 10PW22-3 to one part by volume ofECW-123. Then reduce the mixture with two parts by volume of deionized (DI)water to an admixed viscosity (#4 Ford) of 21 ± 3 seconds. The mixed materialmust be continually stirred under low-speed agitation (130 RPM ± 30) for theduration of pot life. The pot life of the mixed material is four hours. The materialcan be further reduced with up to 5% by volume of DI water (total admixvolume). This primer can be sprayed via standard suction or pressure equipment. A singleuniform wet coat is sprayed to a dry film thickness of 0.6 mil to 0.9 mil. Theprimer has a “dust-free” dry time of 25 minutes and a “dry-to-topcoat” drying timeof 2 hours. The primer has an admixed VOC content of 340 g/l. The constituents of theprimer listed on the MSDSs for the two components are reported in Table C-15.


Table C-15. Ingredients of Dexter Aerospace Materials/Crown MetroAerospace 10PW22-3/ECW-123


OSHAPEL

ACGIHTLV

10PW22-3 (base)

Glycidyl EtherPhenolFormaldehydePolymer

28064-14-4 <10 N.E. N.E.


00107-98-2 <10 N.E. 100 ppm

1-Butoxy-2-Propanol

05131-66-8 <10 N.E. N.E.


Xylene 01330-20-7 <10 100 ppm 100 ppm


Zinc inNonvolatiles

07440-66-6 15 - 16 N.E. N.E.

Lead inNonvolatiles

07439-92-1 Trace 0.05 mg/m3 0.05 mg/m3

Arsenic inNonvolatiles

07440-38-2 Trace 0.01 mg/m3 0.01 mg/m3

Beryllium inNonvolatiles

07440-41-7 Trace 0.002mg/m3

0.002 mg/m3

Cadmium inNonvolatiles

07440-43-9 Trace 0.005mg/m3

0.01 mg/m3

Inhalable; 0.002 mg/m3

Respirable N.E. = Not Established



Table C-15. Ingredients of Dexter Aerospace Materials/Crown MetroAerospace 10PW22-3/ECW-123 (Continued)


OSHAPEL

ACGIHTLV

ECW-123 (curing solution)

TriethyleneTetramine

00112-24-3 <10 N.E. N.E.


00107-98-2 30 - 40 N.E. 100 ppm

1-Butoxy-2-Propanol

05131-66-8 <10 N.E. N.E.

Benzyl Alcohol 00100-51-6 10 - 20 N.E. N.E.

n-Propyl Alcohol 00071-23-8 <10 200 ppm 200 ppm(skin)


In addition, the AIHA recommends that a WEEL of 10 ppm be observed forbenzyl alcohol. Additional Supporting Literature

• The Dexter Corporation, “10PW22-3,” Material Safety Data Sheet,September 5, 1996

• The Dexter Corporation, “ECW-123,” Material Safety Data Sheet,September 5, 1996

• The Dexter Corporation, “10PW22-3 Skydrol-Resistant Water-Reducible Epoxy Primer Chromate Free,” Technical Data Sheet,September 1996

• Sanchez, Marie, Dexter Aerospace Materials Division/CrownMetro Aerospace, Telephone Conversation, November 21, 1996.



C.3.8. EWDY048 A/B MIL-P-85582 Type I (Spraylat Corporation) This low-density nonchromate primer is intended to provide a chemical- andsolvent-resistant coating that protects steel and aluminum against corrosion.Primer EWDY048 A/B is reported to be compatible with polyurethane and epoxytopcoats, sealants, and adhesives. The nonchromate primer EWDY048 A/B is onthe QPL for MIL-P-85582B, Type I, Class N. This means that EWDY048 A/Bpassed the same performance tests as are required of Class C1 and Class C2chromate primers, so this nonchromate primer should be a technically acceptablealternative to currently used chromate primers. Prior to application, three parts by volume of EWDY048 A (base) must bethoroughly mixed with one part by volume of EWDY048 B (curing solution).The pot life of the mixed primer is four hours at room temperature.EWDY048 A/B should be applied by spraying with HVLP or air spray equipmentto a dry film thickness of 0.6 mil to 0.9 mil. At room temperature, the appliedprimer will be dry-to-recoat in one hour, and dry hard in four hours. In order to be on the QPL for MIL-P-85582B, EWDY048 A/B must contain nomore than 340 g VOC l primer when fully mixed. The ingredients ofEWDY048 A/B, as identified on the MSDSs, are listed in Table C-16.

Table C-16. Ingredients of Spraylat Corporation EWDY048 A/B


OSHAPEL

ACGIHTLV

EWDY048 A (base)

2-Propoxyethanol(ethylene glycolmonopropylether)

02807-30-9 <10 N.E. N.E.

Titanium Dioxide 13463-67-7 <10 15 mg/m3 10 mg/m3

EWDY048 B (catalyst)

2-Propoxyethanol 02807-30-9 <50 N.E. N.E. N.E. = Not Established

In addition to the information on the table above, the manufacturer recommendsan exposure limit of 25 ppm for 2-propoxyethanol. Additional Supporting Literature

• Schmidt, Jim, “EWDY048A,” Material Safety Data Sheet,April 16, 1996

• Schmidt, Jim, “EWDY048B,” Material Safety Data Sheet,April 16, 1996


• QPL-85582-4 Amendment 2, “Qualified Products List of Productsunder Military Specification MIL-P-85582, Primer Coatings:Epoxy, Waterborne,” April 17, 1995.


C.3.9. EWAE118 A/B MIL-P-85582 Type II (Spraylat Corporation) This low-density, low-infrared-reflectance nonchromate primer is intended toprovide a chemical- and solvent-resistant coating that protects steel and aluminumagainst corrosion. EWAE118 A/B is reported to be compatible with polyurethaneand epoxy topcoats, sealants, and adhesives. The nonchromate primerEWAE118 A/B is on the QPL for MIL-P-85582B, Type II, Class N. This meansthat EWAE118 A/B passed the same performance tests as are required ofClass C1 and Class C2 chromate primers, so this nonchromate primer should be atechnically acceptable alternative to currently used chromate primers. Prior to application, three parts by volume of EWAE118 A (base) must bethoroughly mixed with one part by volume of EWAE118 B (curing solution). Thepot life of the mixed primer is four hours at room temperature. EWAE118 A/Bshould be applied by spraying with HVLP or air spray equipment to a dry filmthickness of 0.6 mil to 0.9 mil. At room temperature, the applied primer will bedry-to-recoat in one hour, and dry hard in four hours. In order to be on the QPL for MIL-P-85582B, EWAE118 A/B must contain nomore than 340 g VOC l primer when fully mixed. The ingredients ofEWAE118 A/B, as listed on the MSDSs of the two components, are reported inTable C-17.


Table C-17. Ingredients of Spraylat Corporation EWAE118 A/B


OSHAPEL

ACGIHTLV

EWAE118 A (base)

2-Propoxyethanol(ethylene glycolmonopropylether)

02807-30-9 <10 N.E. N.E.

Clay N.E. <10 N.E. N.E.

EWAE118 B (catalyst)

tert-ButylAlcohol

00075-65-0 <10 100 ppm 100 ppm

2-Propoxyethanol 02807-30-9 <50 N.E. N.E.

Benzyl Alcohol 00100-51-6 <10 N.E. N.E. N.E. = Not Established

In addition, the manufacturer recommends an exposure limit of 25 ppm for2-propoxyethanol. The AIHA recommends that a WEEL of 10 ppm be observedfor benzyl alcohol. Additional Supporting Literature

• Schmidt, Jim, “EWAE118A,” Material Safety Data Sheet,April 16, 1996

• Schmidt, Jim, “EWAE118B,” Material Safety Data Sheet,April 16, 1996

• QPL-85582-4 Amendment 2, “Qualified Products List of Productsunder Military Specification MIL-P-85582, Primer Coatings:Epoxy, Waterborne,” April 17, 1995.



C.3.10. U-4800-NC/U-4801 (Sterling Lacquer Manufacturing Company) Primer U-4800-NC/U-4801 is a waterborne epoxy primer intended to meet therequirements of MIL-P-85582, Class N. The primer is prepared for application bymixing four parts by volume of U-4800-NC base with one part U-4801 catalyst. The mixed primer contains approximately 330 grams VOCs per liter of primer.The ingredients of U-4800-NC/U-4801, as listed on the MSDSs for the base andcatalyst, are reported in Table C-18.

Table C-18. Ingredients of Sterling Lacquer Manufacturing CompanyU-4800-NC/U-4801


OSHAPEL

ACGIHTLV

U-4800-NC (base, off white)


02807-30-9 4 N.E. N.E.

Propylene Glycolt-Butyl Ether

57018-52-7 <5 N.E. N.E.

1-Propoxy-2-Propanol(propylene glycoln-propyl ether)

01569-01-3 5 N.E. N.E.


Amorphous Silica 07631-86-9 <5 20 mppcf 10 mg/m3

Silicon Dioxide(crystalline silica)

14808-60-7 16 0.1 mg/m3

Respirable 0.1 mg/m3

Respirable

1-Phenoxy-2-Propanol(propylene glycolphenyl ether)

00770-35-4 <5 N.E. N.E.

U-4801 (catalyst)

Reaction Productsof Epichlorohydrinand Bisphenol A

25085-99-8 35 N.E. N.E.


In addition, the manufacturer recommends an exposure limit of 25 ppm for2-propoxyethanol.



• Moore, P. D, “U-4800-NC,” Material Safety Data Sheet,February 21, 1995

• Moore, P. D., “U-4801,” Material Safety Data Sheet, April 18,1994.

Point of Contact Pete Moore Sterling Lacquer Manufacturing Company 3150 Brannon Avenue St. Louis, MO 63139-1498 Phone: 314-776-4450


C.4. ELECTROCOAT PRIMERS

C.4.1. G28AD012 (BASF Corporation) The ingredients listed on the MSDS for G28AD012 (also known as Cathoguard300 Electrocoat) are reported in Table C-19.

Table C-19. Ingredients of BASF Corporation G28AD012


OSHAPEL

ACGIHTLV

Titanium Dioxide 13463-67-7 1 - 5 15 mg/m3 10 mg/m3


00111-76-2 0.5 - 1.5 50 ppm(skin)

25 ppm(skin)

The exact VOC content of this product is unknown, but 2-butoxyethanol isprobably released to the atmosphere at some level during application of thiselectrocoat primer. Additional Supporting Literature

• BASF Corporation, “G28AD012,” Material Safety Data Sheet,April 17, 1996.

Point of Contact Rob Schiller BASF Corporation 26701 Telegraph Road P.O. Box 5009 Southfield, MI 48086 Phone: 800-347-2273 248-948-2189

C.4.2. U32CD210/U32AD290 (BASF Corporation) Chrome- and lead-free U32CD210/U32AD290 electrocoat is a possiblealternative to MIL-P-85582 for specific applications. This primer consists of twoparts: (1) U32CD210, or Cathode 200 Emulsion, and (2) U32AD290, orElectrocoat Pigment Paste. To mix, 8.7 parts of the emulsion, 1.0 part of thepigment, and 9.5 parts of water should be added to an electrocoating tank. Thisproduct is typically applied to a recommended dry film thickness of18 - 24 micrometers (µm) (0.71 mil to 0.94 mil). It requires a minimum of two


minutes for deposition, and the bath should be maintained at 29.4°C to 35.0°C.To cure the coating, the metal temperature should be held at 177°C for20 minutes. This product is low fuming, has low-film shrinkage, and hasimproved throw power over previous BASF electrocoat products. In addition, ithas excellent corrosion resistance at 0.8 mil. As mixed, U32CD210/U32AD290 electrocoat primer is reported to contain amaximum of 0.8 pounds VOCs per gallon of primer. The MSDSs list theconstituents reported in Table C-20.

Table C-20. Ingredients of BASF Corporation U32CD210/U32AD290


OSHA PEL ACGIH TLV

U32CD210 Cathode 200 Emulsion

Ethylene GlycolHexyl Ether

00112-25-4 0.5 - 1.5 N.E. N.E.


00111-76-2 0.5 - 1.5 50 ppm (skin) 25 ppm (skin)

U32AD290 Electrocoat Pigment Paste

2-Butoxyethanol 00111-76-2 0 - 4 50 ppm (skin) 25 ppm (skin)

Carbon Black 01333-86-4 1 - 5 3.5 mg/m3 3.5 mg/m3

Dibutyloxo-stannane(organotincompound)

00818-08-6 1 - 5 0.1 mg/m3

as Sn 0.1 mg/m3

(skin) as Sn

AluminumSilicate

01332-58-7 5 - 15 15 mg/m3,5 mg/m3

Respirable

2mg/m3

Respirable

TitaniumDioxide

13463-67-7 30 - 50 15 mg/m3 10 mg/m3

N.E. = Not Established Additional Supporting Literature

• BASF Corporation, “Cathode 200 Emulsion,” Material SafetyData Sheet, August 15, 1994

• BASF Corporation, “Electrocoat Pigment Paste,” Material SafetyData Sheet, April 9, 1994

• BASF Corporation, “U32AD300 Gray Cathode 300,” AutomotiveProducts Sheet, August 20, 1995.

Point of Contact


Rob SchillerBASF Corporation26701 Telegraph RoadP.O. Box 5009Southfield, MI 48086Phone: 800-347-2273

248-948-2189


APPENDIX D

Preliminary Environmental, Safety, And Occupational Health (ESOH)Analysis of Viable Alternative Nonchromate Primers

Potential Alternatives Report D-i

TABLE OF CONTENTS

Page

D.1. INTRODUCTION...........................................................................................................D-1

D.2. BACKGROUND INFORMATION FOR ESOH ANALYSIS OF VIABLEALTERNATIVES...........................................................................................................D-2D.2.1. Environmental Analysis ......................................................................................D-2D.2.2. Safety and Occupational Health Analysis ...........................................................D-2

D.3. ESOH ANALYSIS OF VIABLE ALTERNATIVES .....................................................D-5D.3.1. 02-W-38 (Deft, Inc.)............................................................................................D-6

D.3.1.1. Environmental Issues ........................................................................D-6D.3.1.2. Safety and Occupational Health Issues .............................................D-7

D.3.2. 10P22-3/EC-270 (Dexter Aerospace Materials/Crown Metro Aerospace).........D-9D.3.2.1. Environmental Issues ........................................................................D-9D.3.2.2. Safety and Occupational Health Issues ...........................................D-10

D.3.3. Aeroglaze 9740 (Lord Corporation)...............................................................D-12D.3.3.1. Environmental Issues ......................................................................D-12D.3.3.2. Safety and Occupational Health Issues ...........................................D-13

D.3.4. Aeroglaze 9741 (Lord Corporation)...............................................................D-15D.3.4.1. Environmental Issues ......................................................................D-15D.3.4.2. Safety and Occupational Health Issues ...........................................D-16

D.3.5. EEAE136 A/B (Spraylat Corporation)..............................................................D-18D.3.5.1. Environmental Issues ......................................................................D-18D.3.5.2. Safety and Occupational Health Issues ...........................................D-19

D.3.6. U-1201-NC/U-1202-F (Sterling Lacquer Manufacturing Company)................D-21D.3.6.1. Environmental Issues ......................................................................D-21D.3.6.2. Safety and Occupational Health Issues ...........................................D-22

D.3.7. Alumigrip R1204/S3800 (U.S. Paint Corporation)...........................................D-24D.3.7.1. Environmental Issues ......................................................................D-24D.3.7.2. Safety and Occupational Health Issues ...........................................D-25

D.3.8. RW-3151-64 (Courtaulds Aerospace)...............................................................D-27D.3.8.1. Environmental Issues ......................................................................D-27D.3.8.2. Safety and Occupational Health Issues ...........................................D-28

D.3.9. RW-3181-64 (Courtaulds Aerospace)...............................................................D-30D.3.9.1. Environmental Issues ......................................................................D-30D.3.9.2. Safety and Occupational Health Issues ...........................................D-31

D.3.10.44-W-16 (Deft, Inc.)..........................................................................................D-33D.3.10.1. Environmental Issues ......................................................................D-33D.3.10.2. Safety and Occupational Health Issues ...........................................D-34

D.3.11.44-W-17 (Deft, Inc.)..........................................................................................D-36

D-ii Po

D.3.11.1. Environmental Issues ......................................................................D-36D.3.11.2. Safety and Occupational Health Issues ...........................................D-36

D.3.12.44-W-18 (Deft, Inc.)..........................................................................................D-38D.3.12.1. Environmental Issues ......................................................................D-38D.3.12.2. Safety and Occupational Health Issues ...........................................D-39

D.3.13.10PW22-2/ECW-119 (Dexter Aerospace Materials/Crown Metro Aerospace)D-41D.3.13.1. Environmental Issues ......................................................................D-41D.3.13.2. Safety and Occupational Health Issues ...........................................D-42

D.3.14.10PW22-3/ECW-123 (Dexter Aerospace Materials/Crown Metro Aerospace)D-44D.3.14.1. Environmental Issues ......................................................................D-44D.3.14.2. Safety and Occupational Health Issues ...........................................D-45

D.3.15.EWDY048 A/B MIL-P-85582 Type I (Spraylat Corporation)..........................D-48D.3.15.1. Environmental Issues ......................................................................D-48D.3.15.2. Safety and Occupational Health Issues ...........................................D-48

D.3.16.EWAE118 A/B MIL-P-85582 Type II (Spraylat Corporation).........................D-50D.3.16.1. Environmental Issues ......................................................................D-50D.3.16.2. Safety and Occupational Health Issues ...........................................D-51

D.3.17.U-4800-NC/U-4801 (Sterling Lacquer Manufacturing Co., Inc.).....................D-53D.3.17.1. Environmental Issues ......................................................................D-53D.3.17.2. Safety and Occupational Health Issues ...........................................D-53

D.3.18.G28AD012 (BASF Corporation) ......................................................................D-55D.3.18.1. Environmental Issues ......................................................................D-55D.3.18.2. Safety and Occupational Health Issues ...........................................D-56

D.3.19.U32CD210/U32AD290 (BASF Corporation)...................................................D-58D.3.19.1. Environmental Issues ......................................................................D-58D.3.19.2. Safety and Occupational Health Issues ...........................................D-58

LIST OF TABLES

Page

Table D-1. Background ESOH Analysis of Viable Alternatives to Chromate-ContainingPrimers ................................................................................................................D-4

Table D-2. ESOH Analysis of Deft 02-W-38........................................................................D-8Table D-3. ESOH Analysis of Dexter Aerospace Materials/ Crown Metro Aerospace

10P22-3/EC-270................................................................................................D-12Table D-4. ESOH Analysis of Lord Corporation Aeroglaze 9740......................................D-15Table D-5. ESOH Analysis of Lord Corporation Aeroglaze 9741......................................D-18Table D-6. ESOH Analysis of Spraylat Corporation EEAE136 A/B..................................D-21

Potential Alternatives Report D-iii

Table D-7. ESOH Analysis of Sterling Lacquer Manufacturing CompanyU-1201-NC/U-1202-F.......................................................................................D-24

Table D-8. ESOH Analysis of U.S. Paint Corporation Alumigrip R1204/S3800..............D-27Table D-9. ESOH Analysis of Courtaulds Aerospace RW-3151-64...................................D-30Table D-10. ESOH Analysis of Courtaulds Aerospace RW-3181-64...................................D-33Table D-11. ESOH Analysis of Deft 44-W-16......................................................................D-35Table D-12. ESOH Analysis of Deft 44-W-17......................................................................D-38Table D-13. ESOH Analysis of Deft 44-W-18......................................................................D-40Table D-14. ESOH Analysis of Dexter Aerospace Materials/Crown Metro Aerospace

10PW22-2/ECW-119........................................................................................D-44Table D-15. ESOH Analysis of Dexter Aerospace Materials/Crown Metro Aerospace

10PW22-3/ECW-123........................................................................................D-47Table D-16. ESOH Analysis of Spraylat Corporation EWDY048 A/B................................D-50Table D-17. ESOH Analysis of Spraylat Corporation EWAE118 A/B ................................D-52Table D-18. ESOH Analysis of Sterling Lacquer Manufacturing Company

U-4800-NC/U-4801 ..........................................................................................D-55Table D-19. ESOH Analysis of BASF Corporation G28AD012 ..........................................D-57Table D-20. ESOH Analysis of BASF Corporation U32CD210/U32AD290.......................D-60


Potential Alternatives Report D-1

D.1. INTRODUCTION

The environmental, safety, and occupational health (ESOH) analysis below describesESOH characteristics of the viable alternative nonchromate primers, as a supplement tothe summary presented in Section 5 of this Potential Alternative Report (PAR). ThisESOH analysis can be used to provide direct comparison to the ESOH issues related tothe baseline use of chromate primers on aircraft exterior mold line surfaces (refer toSection 2.3 of this PAR, and Appendix A). These comparisons can then serve as a basisfor further elimination of specific nonchromate primers.

Because of the limited scope of this ESOH analysis, this analysis provides a generaloutline of the ESOH issues related to the alternatives, and may not reveal every possibledeficiency or hazard. Concurrent Technologies Corporation (CTC) assumes noresponsibility for the safe operation and maintenance of the manufacturing technology orfor any ESOH hazards or releases resulting from use of nonchromate primers for aircraftexterior mold line surfaces.

D-2 Potential Alternatives Report

D.2. BACKGROUND INFORMATION FOR ESOH ANALYSIS OF VIABLEALTERNATIVES

D.2.1. Environmental Analysis

Each alternative primer may be governed, to a greater or lesser extent, by federalenvironmental laws and regulations. Therefore, a regulatory review of each viablealternative was conducted as part of the ESOH analysis. Each nonchromateprimer was reviewed to determine the extent of its regulation under the Clean AirAct (CAA); Clean Water Act (CWA); Resource Conservation and Recovery Act(RCRA); Emergency Planning and Community Right-to-Know Act (EPCRA);and Comprehensive Environmental Response, Compensation, and Liability Act(CERCLA). Constituents of the viable alternatives were also compared to theUnited States Environmental Protection Agency’s (EPA’s) list of 17 high-riskpriority chemicals, called the “EPA 17” list. Even primers containing ingredientsthat are heavily regulated under one or more of these laws are still available foruse by facilities, although most facilities wisely restrict their use.

A viable alternative primer is only described as having “failed” environmentalcriteria on regulatory grounds if it contains a constituent whose use has beenbanned, or is scheduled to be banned, by EPA. Otherwise, the alternative“passes” this background analysis.

D.2.2. Safety and Occupational Health Analysis

Each identified constituent of each alternative nonchromate primer, whenavailable, was reviewed in terms of its potential toxicity as a known or suspectedhuman carcinogen, human genotoxicant, human teratogen, or humanneurotoxicant. Each of these categories is briefly defined and described below.

• Human Carcinogen: Those agents, including organic andinorganic compounds, that have an ability to induce carcinomas(cancer) in humans are considered carcinogens. For this analysis,those constituents that show clear or suspected evidence ofcarcinogenic activity in humans, as concluded by the NationalToxicology Program (NTP); EPA’s Office of Science andTechnology Weight-of-Evidence Policy; and/or the InternationalAgency for Research on Cancer (IARC) guidelines, are consideredto be human carcinogens.

• Human Genotoxicant: Those agents determined or suspected to beDNA-reactive (genotoxic), where available information issufficient, are considered human genotoxicants.

• Human Teratogen: Those agents that are determined or suspectedto cause any detrimental effect (structural or functional) during


embryonic development after exposure are considered to beteratogens. Such exposure may occur before conception or duringpregnancy.

• Human Neurotoxicant: Those agents that are determined orsuspected to cause toxic effects to the human nervous system fromexposure at expected occupational concentrations are considered tobe neurotoxicants.

Those primers containing constituents determined to be known or suspectedtoxicants in the categories listed above, based on available literature, are noted as“failed”. Those primers containing constituents, for which data are not sufficientto classify the primers as known or suspected human toxicants, are noted as“passed.” The results of the ESOH analysis performed using these criteria aresummarized in Table D-1. A more detailed ESOH analysis of the viablealternative nonchromate primers is contained in Section D.3.


Table D-1. Background ESOH Analysis of Viable Alternatives to Chromate-Containing Primers

HEALTH AND SAFETY CRITERIA

Product Carcinogen Teratogen Genotoxicant Neurotoxicant Environmental Known Suspected Known Suspected Known Suspected Known Suspected Criteria 02-W-38 Pass Pass Pass Pass+ Fail Fail Fail Fail Pass 10P22-3/EC-270 Pass Fail Pass Pass+ Fail Fail Fail Fail Pass Aeroglaze 9740 Pass Pass Pass Pass+ Pass Pass+ Fail Fail Pass Aeroglaze 9741 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass EEAE136 A/B Pass Fail Pass Pass+ Fail Fail Fail Fail Pass U-1201-NC/U-1202-F Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass Alumigrip R1204/S3800 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass RW-3151-64 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass RW-3181-64 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass 44-W-16 Pass Pass Pass Pass+ Pass Pass Fail Fail Pass 44-W-17 Pass Pass Pass Pass Pass Pass Fail Fail Pass 44-W-18 Pass Pass Pass Pass Pass Pass Fail Fail Pass 10PW22-2/ECW-119 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass 10PW22-3/ECW-123 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass EWDY048 A/B Pass Fail Pass Pass+ Pass Pass Pass Pass Pass EWAE118 A/B Pass Pass Pass Pass+ Pass Pass+ Fail Fail Pass U-4800-NC/U-4801 Pass Fail Pass Pass+ Pass Pass Pass Pass Pass G28AD012 Pass Fail Pass Pass+ Pass Pass Fail Fail Pass U32CD210/U32AD290 Pass Fail Pass Pass+ Pass Pass+ Fail Fail Pass

+ Experimental animal data have been noted. Note: Because of the limited scope of this ESOH analysis, this analysis provides only a general outline of the ESOH characteristics of the alternatives and may not

reveal every possible deficiency or hazard. CTC assumes no responsibility for the safe operation and maintenance of the manufacturing technology or forany ESOH hazards or releases resulting from operation and maintenance of the alternative manufacturing technology.


D.3. ESOH ANALYSIS OF VIABLE ALTERNATIVES This section describes in detail the ESOH impact of the viable alternative primersrecommended for further evaluation (refer to Section 4 of this PAR). Each productdiscussion includes a description of the chemicals of concern, and an analysis ofregulatory concerns, exposure effects, toxicity and exposure ratings (explained below),and suggested personal protective equipment. This information was obtained byanalyzing Material Safety Data Sheets (MSDSs) from the vendors of the viablealternative products as well as other reference materials. Please note that the currentpermissible exposure limit (PEL) for airborne chromates is 0.1 mg/m3, measured aschromium trioxide (CrO3); for the purpose of this analysis, this number has beenconverted to an equivalent level of 0.05 mg/m3, measured as chromium (Cr). Using available resources, each candidate nonchromate primer was evaluated todetermine the extent of its regulation under major federal environmental laws: CAA,RCRA, CWA, Section 313 of EPCRA, and CERCLA. In addition, the constituents ofeach nonchromate primer were compared to the EPA 17 list. The criteria used for thisevaluation are described in Section 2.3.1 of this PAR. Each primer will be governed, to agreater or lesser extent, by federal environmental laws and regulations. Even constituentsthat are heavily regulated under one or more of these laws are still available for use byfacilities, although most facilities wisely restrict their use. Each viable alternative nonchromate primer was given a toxicity rating, exposure rating,and an overall hazard rating based on the criteria explained in Section 2.3.2 of this PAR.Toxicity ratings and exposure ratings of high, medium, and low were assigned to theprimers based on the analysis of the available literature, the relative quantities of eachconstituent in each product, and best professional judgement. Parameters reviewedincluded median lethal concentrations (LC50s), median oral lethal doses (LD50s), PELspromulgated by the Occupational Safety and Health Administration (OSHA), andthreshold limit values (TLVs) issued by the American Conference of GovernmentalIndustrial Hygienists (ACGIH). The hazard rating for each product is a combination ofthe toxicity rating and exposure rating, and gives an overall safety and occupationalhealth rating to the viable alternative. This ESOH analysis can be used to make direct comparisons to the ESOH issuesassociated with currently used chromate primers (refer to Section 2.3 of this PAR, andAppendix A). A summary of the following ESOH analysis of the viable alternative nonchromateprimers may be found in Table 20 in Section 5 of this PAR.


D.3.1. 02-W-38 (Deft, Inc.)

D.3.1.1. Environmental Issues

A brief regulatory analysis of 02-W-38 nonchromate primer from Deft,Inc. is provided below.

• Air Emissions: The 02-W-38 primer contains two

constituents that are HAPs, xylene and ethyl benzene,which are both found in the base component(Component A). While this product emits volatile organiccompounds (VOCs) totaling 339 grams per liter (g/l) whenfully mixed, it does not contain any regulated ozone-depleting substances (ODSs).

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 02-W-38 primer may be classified as RCRAD001 ignitable wastes due to the low flash point of thisproduct. At least two constituents of 02-W-38 primer maygenerate RCRA hazardous waste: ethyl benzene andxylene. Ethyl benzene is listed as hazardous waste numberF003, and xylene is listed as F003 and U239.

• Wastewater Discharges: Under the CWA, the use of02-W-38 primer may result in waste streams containing anyof three regulated compounds: xylene, ethyl benzene, andn-butyl acetate. Xylene and n-butyl acetate are designatedas hazardous substances under CWA Section 311. Ethylbenzene is designated under the CWA as both a toxic and apriority pollutant. Ethyl benzene is listed as a pretreatmentpollutant. In addition, effluent limitation guidelines havebeen developed for ethyl benzene.

• Reporting Requirements: The following constituents of02-W-38 are required to be listed on Toxics ReleaseInventory (TRI) reports under EPCRA Section 313:xylene, ethyl benzene, polyamide resin (containingbisphenol A), and sec-butyl alcohol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: xylene, ethyl benzene, andn-butyl acetate.

• EPA 17: Xylene is included on the EPA 17 list ofchemicals targeted for strict regulation.


D.3.1.2. Safety and Occupational Health Issues

An overall medium hazard rating is given to alternative 02-W-38. Thisrating is based on a determination that 02-W-38 has a medium toxicityrating and a medium exposure rating. The medium hazard rating indicatesthat both chemical toxicity and worker exposure cause moderate ESOHconcerns when using this alternative. Worker exposure controls should bereviewed and properly implemented for worker health and safety.Constituents of concern and exposure effects are discussed below. Constituents of concern in 02-W-38 include xylene, ethyl benzene, n-butylacetate, methyl n-propyl ketone, sec-butyl alcohol,N-(3-trimethoxysilylpropyl) ethylenediamine, C8-C10 aromatichydrocarbons, triethylene tetramine, bisphenol A, N-aminoethylpiperazine,N,N-dimethylbenzylamine, 2,4,6-tris(dimethylaminomethyl) phenol, andbenzyl alcohol. For information on exposure limits and productcomposition (percent weights), see Appendix C. Experimental animalteratogen data was noted for the constituents xylene, ethyl benzene, n-butyl acetate, triethylene tetramine, bisphenol A, N-aminoethylpiperazine,benzyl alcohol and sec-butyl alcohol. Ethyl benzene is considered aknown human genotoxicant. Test results in laboratory animals and lowerorganisms (e.g., bacteria) also indicate that xylene, methyl n-propylketone, triethylene tetramine, N-aminoethylpiperazine, and benzyl alcoholare genotoxicants. Xylene, ethyl benzene, and methyl propyl ketone areknown human neurotoxicants. Toxic effects for the constituents ofconcern may range from irritation of the respiratory tract and acutenervous system depression (i.e., headache, dizziness) to coma fromrepeated inhalation of vapors (overexposure). None of the compoundslisted on the MSDS are considered by the state of California to causecarcinogenic or reproductive effects. Identified oral LD50s and inhalationLC50s for the chemicals of concern also indicate a moderate level oftoxicity. The lowest oral LD50, identified for the constituent N,N-dimethylbenzylamine, was 265 milligrams per kilogram of body mass.The lowest LC50 was found to be 1800 mg/m3, also for N,N-dimethylbenzylamine. Additional health effects of the primer constituentsare discussed below.

• Acute Effects: Acute effects may include, but may not be

limited to, the following: dermatitis, irritation of the skin,eyes, or mucous membranes with symptoms such asswelling, redness, and rash. Extreme exposure to theprimer may result in extreme irritation and cracking of theskin. Inhalation of vapors and mists can cause mild toextreme irritation of the nose, throat, and respiratory tract,headache and dizziness, and confusion. Death from


extreme acute overexposure can occur. Accidentalingestion can result in gastrointestinal damage includingdigestive tract irritation and corrosive burns.

• Chronic Effects: Chronic effects from prolonged orrepeated contact and/or inhalation may include drying andcracking of the skin, skin sensitization, asthma, or otherallergic and sensitization responses.

Nonchromate primer 02-W-38 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (TLVs and PELs),02-W-38 was given a medium exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and should include protectiveclothing (e.g., gloves), approved respirators, and approved emergencyfacilities (e.g., eye wash station and shower).

A summary of the ESOH analysis of Deft 02-W-38 nonchromate high-solids primer is provided in Table D-2.

Table D-2. ESOH Analysis of Deft 02-W-38

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 2 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 4 CERCLA Hazardous Substances 3 EPA 17 Constituents 1



c The hazard rating is determined by considering the toxicity ratings and exposure ratingsof the individual constituents and the relative quantities of each constituent.


D.3.2. 10P22-3/EC-270 (Dexter Aerospace Materials/Crown Metro Aerospace)


A brief regulatory analysis of Dexter Aerospace Materials10P22-3/EC-270 high-solids nonchromate epoxy primer is providedbelow.

• Air Emissions: 10P22-3/EC-270 primer contains six

constituents that are HAPs: toluene, methyl isobutylketone, m-xylene diamine, methylphenol (cresol),formaldehyde, and benzene. Two of these chemicals(benzene and formaldehyde) are reported to be present onlyin trace quantities. Although there are no ODSs present in10P22-3/EC-270, the VOC content of fully mixed10P22-3/EC-270 is 340 grams per liter.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 10P22-3/EC-270 may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product. At least four constituents of 10P22-3/EC-270may generate hazardous waste: methyl isobutyl ketone,toluene, formaldehyde, and benzene. Methyl isobutylketone is listed as hazardous waste numbers F003 andU161, toluene is listed as F005 and U220, formaldehyde islisted as U122, and benzene is listed as D018, F003 andU019.

• Wastewater Discharges: Under the CWA, the use of10P22-3/EC-270 may result in waste streams containingany of six regulated compounds: toluene, methyl isobutylketone, benzyl alcohol, formaldehyde, benzene, and methyln-amyl ketone. Toluene, formaldehyde, and benzene aredesignated hazardous substances under CWA Section 311.Toluene and benzene are designated under the CWA asboth toxic and priority pollutants. Toluene, methyl isobutylketone, benzene, benzyl alcohol, and methyl n-amyl ketoneare listed as pretreatment pollutants. In addition, effluentlimitation guidelines have been developed for toluene andbenzene.

• Reporting Requirements: The following constituents of10P22-3/EC-270 are required to be listed on TRI reportsunder EPCRA Section 313: formaldehyde, benzene, andmethyl isobutyl ketone.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardous


substances under CERCLA: formaldehyde, benzene,toluene, and methyl isobutyl ketone.

• EPA 17: Toluene, methyl isobutyl ketone, m-xylenediamine, and benzene are included on the EPA 17 list ofchemicals targeted for strict regulation.


An overall medium to high hazard rating is given to alternative 10P22-3/EC-270.This rating is based on a determination that 10P22-3/EC-270 has a mediumtoxicity rating and a high exposure rating. The medium to high hazard ratingindicates that an overall moderate to high ESOH concern is caused by thechemical toxicity and worker exposure properties of this alternative. Workerexposure controls should be thoroughly reviewed and properly implemented forworker health and safety. Constituents of concern and exposure effects arediscussed below.

Constituents of concern in 10P22-3/EC-270 include trimethylolpropanetriacrylate, toluene, methyl n-amyl ketone, methyl isobutyl ketone, benzylalcohol, dimethylamine methylphenol mixture, and m-xylene diamine.Benzene and formaldehyde are also present at trace levels. Forinformation on exposure limits and product composition (percent weights),see Appendix C. Cresol (mixed isomers), a component of thedimethylamine methylphenol mixture, is a suspected human carcinogen.Experimental animal teratogen data was noted for the constituents toluene,methyl isobutyl ketone, m-cresol (an isomer of methylphenol), and benzylalcohol. o-Cresol and m-cresol are confirmed human genotoxicants. Testresults in laboratory animals and lower organisms (e.g., bacteria) alsoindicate that trimethylolpropane triacrylate, toluene, dimethylamine andbenzyl alcohol are genotoxicants. The constituents toluene, methyl n-amylketone, and methyl isobutyl ketone are known human neurotoxicants.Benzene and formaldehyde (present only as trace contaminants) are knownhuman carcinogens, genotoxicants, and neurotoxicants and are genotoxicto experimental animals or lower organisms. This product contains traceamounts of formaldehyde and benzene, which are considered by the stateof California to have carcinogenic or mutagenic effects, and toluene whichhas reproductive effects. Toxic effects for the constituents of concern mayrange from irritation of the respiratory tract to acute nervous systemdepression (i.e., headache, dizziness, or drowsiness). Identified oral LD50sand inhalation LC50s for the constituents of concern also indicate amoderate level of toxicity. The lowest oral LD50, identified for thedimethylamine, was 316 milligrams per kilogram (mg/kg) of body mass.


The lowest LC50 was found to be 179 mg/m3 (two-hour mouse study) foro-cresol. Additional health effects of the primer constituents are discussedbelow.


limited to, the following: dermatitis, irritation of the skin,eyes, or mucous membranes with symptoms such asswelling, redness, and rash. Extreme exposure to theprimer may result in extreme irritation and cracking of theskin. Inhalation of vapors and mists can cause mild toextreme irritation of the nose, throat, and respiratory tract,headache and dizziness, drowsiness, and confusion.

• Chronic Effects: Chronic effects from prolonged orrepeated contact and/or inhalation may include drying andcracking of the skin, skin sensitization, asthma, or otherallergic and sensitization responses. Target tissues ofchronic effects may include kidneys, liver, reproductivesystem, central nervous system and/or cardiac sensitization.Exposure to benzene and formaldehyde may lead to thedevelopment of carcinomas (cancer).

Nonchromate primer 10P22-3/EC-270 was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (TLVs and PELs),10P22-3/EC-270 was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower).

A summary of the ESOH analysis of Dexter Aerospace Materials 10P22-3/EC-270 nonchromate high-solids primer is provided in Table D-3.


Table D-3. ESOH Analysis of Dexter Aerospace Materials/Crown Metro Aerospace 10P22-3/EC-270

Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions - HAPs 6 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 3 CERCLA Hazardous Substances 4 EPA 17 Constituents 4




D.3.3. Aeroglaze 9740 (Lord Corporation)


A brief regulatory analysis of Lord Corporation Aeroglaze 9740 high-solids nonchromate epoxy primer is provided below.

• Air Emissions: Although the Aeroglaze 9740 primer emits

no HAPs, fully mixed Aeroglaze 9740 containsapproximately 310 grams VOCs per liter of primer. Thisproduct does not contain any regulated ODSs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of Aeroglaze 9740 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product. At least one constituent of Aeroglaze 9740primer may generate RCRA hazardous waste: n-butylalcohol, which is listed as hazardous waste number F003and U031.

• Wastewater Discharges: Under the CWA, the use ofAeroglaze 9740 primer may result in waste streamscontaining either or both of two regulated compounds:n-butyl alcohol and n-butyl acetate. n-Butyl acetate isdesignated as a hazardous substance under CWA


Section 311. In addition, n-butyl alcohol is listed as apretreatment pollutant.

• Reporting Requirements: The following constituent ofAeroglaze 9740 is required to be listed on TRI reportsunder EPCRA Section 313: n-butyl alcohol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: n-butyl acetate and n-butylalcohol.

• EPA 17: None of the constituents of the Aeroglaze 9740primer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to the alternativeAeroglaze 9740. This rating is based on a determination thatAeroglaze 9740 has a medium toxicity rating and a medium to highexposure rating. The medium hazard rating indicates that an overallmoderate ESOH concern is caused by the chemical toxicity and workerexposure properties of this alternative. Worker exposure controls shouldbe reviewed and properly implemented for worker health and safety.Constituents of concern and exposure effects are discussed below.

Constituents of concern in Aeroglaze 9740 include n-butyl acetate andn-butyl alcohol. Other constituents include proprietary amines. Forinformation on exposure limits and product composition (percent weights),see Appendix C. Experimental animal teratogen data was noted for theconstituents n-butyl acetate and n-butyl alcohol. n-Butyl alcohol wasdetermined to be a known human neurotoxicant. However, no knownhuman carcinogens, teratogens, or genotoxicants were noted. The humantoxic response of the proprietary constituents is unknown. Toxic effectsfor the constituents of concern may range from irritation of the respiratorytract, skin, and eyes to acute nervous system depression (i.e., headache,dizziness). None of the compounds listed on the MSDS are considered bythe state of California to cause carcinogenic or reproductive effects.Identified oral LD50s and inhalation LC50s for the constituents of concernalso indicate a moderate level of toxicity. The lowest oral LD50, identifiedfor the constituent n-butyl alcohol, was 790 mg/kg of body mass. Thelowest LC50 was found to be 2000 ppm (four-hour rat study) for n-butylacetate. Additional health effects of the primer constituents are discussedbelow.


• Acute Effects: Acute effects may include, but may not belimited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes with symptoms such asswelling, redness, and rash. Extreme exposure to theprimer may result in extreme irritation and cracking of theskin. Inhalation of vapors and mists can cause mild toextreme irritation of the nose, throat, and respiratory tract.A variety of symptoms such as dryness of the throat, chesttightness, and shortness of breath can also occur. Headacheand dizziness, and confusion and/or coma may also occurfrom overexposure. Accidental ingestion can result ingastrointestinal damage including digestive tract irritationand corrosive burns.

• Chronic Effects: Repeated or prolonged solventoverexposure may result in permanent central nervoussystem damage. Skin contact may also cause severedermatitis.

Nonchromate primer Aeroglaze 9740 was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on exposure limits (PELs and TLVs), Aeroglaze 9740was given a medium to high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and should include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedrespirators, and approved emergency facilities (e.g., eye wash station andshower).

A summary of the ESOH analysis of Lord Corporation Aeroglaze 9740 isprovided in Table D-4.


Table D-4. ESOH Analysis of Lord Corporation Aeroglaze 9740

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 0 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 1 CERCLA Hazardous Substances 2 EPA 17 Constituents 0




D.3.4. Aeroglaze 9741 (Lord Corporation)


A brief regulatory analysis of Lord Corporation Aeroglaze 9741 high-solids nonchromate epoxy primer is provided below.

• Air Emissions: Although the Aeroglaze 9741 primer emits

no HAPs, fully mixed Aeroglaze 9741 containsapproximately 310 g/1 VOC. This product does notcontain any regulated ODSs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of Aeroglaze 9741 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product. At least one constituent of Aeroglaze 9741primer may generate RCRA hazardous waste: n-butylalcohol. n-Butyl alcohol is listed as hazardous wastenumber F003 and U031.

• Wastewater Discharges: Under the CWA, the use ofAeroglaze 9741 primer may result in waste streamscontaining either or both of two regulated compounds:n-butyl alcohol and n-butyl acetate. n-Butyl acetate isdesignated as a hazardous substance under CWA


Section 311. In addition, n-butyl alcohol is listed as apretreatment pollutant.

• Reporting Requirements: The following constituent ofAeroglaze 9741 is required to be listed on TRI reportsunder EPCRA Section 313: n-butyl alcohol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: n-butyl acetate and n-butylalcohol.

• EPA 17: None of the constituents of the Aeroglaze 9741primer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to the alternativeAeroglaze 9741. This rating is based on a determination thatAeroglaze 9741 has a medium toxicity rating and a medium to highexposure rating. The medium hazard rating indicates that an overallmoderate ESOH concern is caused by the chemical toxicity and workerexposure properties of this alternative. Worker exposure controls shouldbe reviewed and properly implemented for worker health and safety.Constituents of concern and exposure effects are discussed below. Constituents of concern in Aeroglaze 9741 include n-butyl acetate andn-butyl alcohol. Other constituents include proprietary amines. Forinformation on exposure limits and product composition (percent weights),see Appendix C. Carbon black is a suspected human carcinogen.Experimental animal teratogen data was noted for the constituents n-butylacetate and n-butyl alcohol. n-Butyl alcohol was determined to be aknown human neurotoxicant. However, no known human carcinogens,teratogens or genotoxicants were noted. The human toxic response of theproprietary constituents is unknown. Toxic effects for the constituents ofconcern may range from irritation of the respiratory tract, skin, and eyes, toacute nervous system depression (i.e., headache, dizziness). None of thecompounds listed on the MSDS are considered by the state of California tocause carcinogenic or reproductive effects. Identified oral LD50s andinhalation LC50s for the constituents of concern also indicate a moderatelevel of toxicity. The lowest oral LD50, identified for the constituent n-butyl alcohol, was 790 mg/kg of body mass. The lowest LC50 was foundto be 2000 ppm (four-hour rat study) for n-butyl acetate. Additional healtheffects of the primer constituents are discussed below.


• Acute Effects: Acute effects may include, but may not belimited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes with symptoms such asswelling, redness, and rash. Exposure to the primer mayresult in extreme irritation and cracking of the skin.Inhalation of vapors and mists can cause mild to extremeirritation of the nose, throat, and respiratory tract. A varietyof symptoms such as dryness of the throat, chest tightness,and shortness of breath can also occur. Headache,dizziness, confusion, and/or coma may also occur fromoverexposure. Accidental ingestion can result ingastrointestinal damage including digestive tract irritationand corrosive burns.

• Chronic Effects: Repeated or prolonged solventoverexposure may result in permanent central nervoussystem damage. Skin contact may also cause severedermatitis.

Nonchromate primer Aeroglaze 9741 was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on the published exposure limits (PELs and TLVs) forits ingredients, Aeroglaze 9741 was given a medium to high exposurerating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and should include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedrespirators, and approved emergency facilities (e.g., eye wash station andshower). A summary of the ESOH analysis of Lord Corporation Aeroglaze 9741 isprovided in Table D-5.


Table D-5. ESOH Analysis of Lord Corporation Aeroglaze 9741

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 0 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 1 CERCLA Hazardous Substances 2 EPA 17 Constituents 0




D.3.5. EEAE136 A/B (Spraylat Corporation)


A brief regulatory analysis of Spraylat Corporation EEAE136 A/B high-solids nonchromate epoxy primer is provided below.

• Air Emissions: The EEAE136 A/B primer contains two

constituents that are HAPs, methyl ethyl ketone and methylisobutyl ketone. Although there are no ODSs present inthis product, fully mixed EEAE136 A/B primer contains upto 340 g/l VOCs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of EEAE136 A/B primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product. At least two constituents of EEAE136 A/Bprimer may generate RCRA hazardous waste: methyl ethylketone and methyl isobutyl ketone. Methyl ethyl ketone islisted as hazardous waste numbers D035, F005 and U159and methyl isobutyl ketone is listed as F003 and U161.

• Wastewater Discharges: The use of EEAE136 A/B primermay result in waste streams containing any of threeregulated compounds. Under the CWA, methyl n-amyl


ketone, methyl isobutyl ketone, and cyclohexanone arelisted as pretreatment pollutants.

• Reporting Requirements: The following constituents ofEEAE136 A/B are required to be listed on TRI reportsunder EPCRA Section 313: methyl ethyl ketone andmethyl isobutyl ketone.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: cyclohexanone, methyl ethylketone, and methyl isobutyl ketone.

• EPA 17: Two of the constituents of the EEAE136 A/Bprimer, methyl ethyl ketone and methyl isobutyl ketone, areincluded on the EPA 17 list of chemicals targeted for strictregulation.


An overall medium to high hazard rating is given to the alternativeEEAE136 A/B. This rating is based on a determination thatEEAE136 A/B has a medium toxicity rating and a high exposure rating.This rating indicates that an overall moderate to high ESOH concern iscaused by the chemical toxicity and worker exposure properties of thisalternative. Worker exposure controls should be thoroughly reviewed andproperly implemented for worker health and safety. Constituents ofconcern and exposure effects are discussed below. Constituents of concern in EEAE136 A/B include methyl isobutyl ketone,methyl n-amyl ketone, titanium dioxide, methyl ethyl ketone, mineralspirits, amorphous silica, talc, silicon dioxide, cyclohexanone,N,N-dimethylbenzylamine, 2,4,6-tris(dimethylaminomethyl) phenol, anddi-isobutyl ketone, as well as proprietary polyamides, aliphatic amines,and resins. For information on exposure limits and product composition(percent weights), see Appendix C. Amorphous silica and titaniumdioxide are listed on the MSDS with their PELs as required by Title 29,Code of Federal Regulations, Part 1910, Subpart 1200(29 CFR 1910.1200). However, these constituents are in fullyencapsulated form and therefore are not generally considered hazardousduring normal primer application. If the cured primer is sanded or ground,a suitable respirator is required. Some experimental data exists indicatingthat titanium dioxide may be carcinogenic. Silicon dioxide, talc, andtitanium dioxide are suspected human carcinogens. Cyclohexanone is aknown human genotoxicant and neurotoxicant. Other known humanneurotoxicants include methyl isobutyl ketone, methyl n-amyl ketone,methyl ethyl ketone and di-isobutyl ketone. Experimental animal


teratogen data was noted for the constituents methyl isobutyl ketone,methyl ethyl ketone, and cyclohexanone. Test results in laboratoryanimals and lower organisms (e.g., bacteria) also indicate that amorphoussilica and methyl ethyl ketone are genotoxicants. This primer contains noother known human carcinogens, teratogens, genotoxicants orneurotoxicants. None of the compounds listed on the MSDS areconsidered by the state of California to cause carcinogenic or reproductiveeffects. Toxic effects for the constituents of concern found in the primermay range from mild to severe irritation of the respiratory tract toheadache, dizziness, or nausea. Identified oral LD50s and inhalation LC50sfor the constituents of concern also indicate a moderate level of toxicity.The lowest oral LD50, identified for N,N-dimethylbenzylamine, was265 mg/kg of body mass. The lowest LC50 was found to be 1800 mg/m3

(four-hour rat study) for N,N-dimethylbenzylamine. Additional healtheffects of the primer constituents are discussed below.


limited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes; symptoms such asswelling, redness, and rash. Extreme exposure to theprimer may result in extreme irritation and cracking of theskin. Inhalation of vapors and mists can cause mild toextreme irritation of the nose, throat, and respiratory tract,as well as headache, dizziness, vomiting, diarrhea, andnausea.

• Chronic Effects: Chronic overexposure may cause kidneyand liver injury, and central nervous system depression ordisorders. Prolonged overexposure by inhalation maycause delayed lung injury or diseases (silicosis) andcarcinomas (cancer). Silicon dioxide is a suspected humancarcinogen. Chronic dermal exposure may cause severeirritation, drying, cracking, or dermatitis.

Nonchromate primer EEAE136 A/B was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, EEAE136 A/B was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approved


fitted respirators, and approved emergency facilities (e.g., eye wash stationand shower). A summary of the ESOH analysis of Spraylat Corporation EEAE136 A/Bis provided in Table D-6.

Table D-6. ESOH Analysis of Spraylat Corporation EEAE136 A/B





D.3.6. U-1201-NC/U-1202-F (Sterling Lacquer Manufacturing Company)


A brief regulatory analysis of Sterling Lacquer Manufacturing CompanyU-1201-NC/U-1202-F high-solids nonchromate epoxy primer is providedbelow.

• Air Emissions: The U-1201-NC/U-1202-F primer containstwo constituents that are HAPs, xylene and toluene.Although there are no ODSs present in this alternative,fully mixed U-1201-NC/U-1202-F contains up to 340 g/lVOCs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of U-1201-NC/U-1202-F primer may be classifiedas RCRA D001 ignitable wastes due to the low flash pointof this product. At least two constituents of theU-1201-NC/U-1202-F primer may generate hazardouswaste: toluene and xylene. Toluene is listed as hazardous


waste numbers F005 and U220 and xylene is listed as F003and U239.

• Wastewater Discharges: Under the CWA, the use ofU-1201-NC/U-1202-F primer may result in waste streamscontaining any of three regulated compounds: xylene,toluene, and benzyl alcohol. Xylene and toluene aredesignated hazardous substances under CWA Section 311.Toluene is designated under the CWA as both a toxic and apriority pollutant. Toluene and benzyl alcohol are listed aspretreatment pollutants. In addition, effluent limitationguidelines have been developed for toluene.

• Reporting Requirements: The following constituents ofU-1201-NC/U-1202-F are required to be listed on TRIreports under EPCRA Section 313: toluene and xylene.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: toluene, reaction products ofepichlorohydrin and bisphenol A, and xylene.

• EPA 17: Two of the constituents of theU-1201-NC/U-1202-F primer, xylene and toluene, areincluded on the EPA 17 list of chemicals targeted for strictregulation.


An overall medium to high hazard rating is given to the alternativeU-1201-NC/U-1202-F. This rating is based on a determination thatU-1201-NC/U-1202-F has a medium toxicity rating and a high exposurerating. The medium to high rating indicates that an overall moderate tohigh ESOH concern is caused by the chemical toxicity and workerexposure properties of this alternative. Worker exposure controls shouldbe thoroughly reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below. Constituents of concern in U-1201-NC/U-1202-F include toluene, xylene,solvent naphtha, titanium dioxide, aliphatic glycidyl ether, benzyl alcohol,2,4,6-tris(dimethylaminomethyl) phenol, and silicon dioxide. Forinformation on exposure limits and product composition (percent weights),see Appendix C. Silicon dioxide, which is present in this primer, isreported by IARC to be a suspected carcinogen; if excessive exposureoccurs, it may cause silicosis, a cancerous lung disease. Titanium dioxideis listed on the MSDS with its PEL as required by 29 CFR 1910.1200.However, this compound is in fully encapsulated form and therefore is notgenerally considered hazardous during normal primer application. If the


cured primer is sanded or ground, a suitable respirator is required. Someexperimental data exists indicating that titanium dioxide may becarcinogenic. Silicon dioxide is also a suspected human carcinogen.Toluene and xylene are known human neurotoxicants. Experimentalanimal teratogen data was also noted for the constituents toluene, benzylalcohol, and xylene. Test results in laboratory animals and lowerorganisms (e.g., bacteria) also indicate that toluene, xylene, and benzylalcohol are genotoxicants. No other known human carcinogens,teratogens, genotoxicants, or neurotoxicants have been identified. Thisproduct contains toluene, which is considered by the state of California tohave reproductive effects. Toxic effects for the constituents of concernmay range from mild to severe irritation of the respiratory tract, toheadache, dizziness, or nausea. Identified oral LD50s and inhalation LC50sfor the constituents of concern also indicate a moderate level of toxicity.The lowest oral LD50, identified for 2,4,6-tris(dimethylaminomethyl)phenol, was 1200 milligrams per kilogram of body mass. The lowest LC50

was found to be 400 ppm for toluene. Additional health effects of theprimer constituents are discussed below.


limited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes with symptoms such asswelling, redness, and rash. Exposure to the primer mayresult in extreme irritation and cracking of the skin.Inhalation of vapors and mists can cause mild to extremeirritation of the nose, throat, and respiratory tract, as well asheadache, dizziness, vomiting, diarrhea, and nausea.

• Chronic Effects: Chronic overexposure may causepermanent central nervous system depression or disorders.Prolonged overexposure by inhalation may cause delayedlung injury or diseases (silicosis) and carcinomas (cancer).Silicon dioxide is a suspected human carcinogen. Chronicdermal exposure may cause severe irritation, drying,cracking, or dermatitis.

Nonchromate primer U-1201-NC/U-1202-F was assigned a mediumtoxicity rating based on published toxicity data (LD50s and LC50s) ofindividual constituents. Based on exposure limits (PELs and TLVs) of itsingredients, alternative U-1201-NC/U-1202-F was given a high exposurerating. Appropriate engineering controls (e.g., local ventilation) must be used whileapplying this primer, and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker health protectionthroughout the process, and must include protective clothing (e.g., eye protection


and chemical-resistant gloves), approved fitted respirators, and approvedemergency facilities (e.g., eye wash station and shower). A summary of the ESOH analysis of Sterling Lacquer ManufacturingCompany U-1201-NC/U-1202-F is provided in Table D-7.

Table D-7. ESOH Analysis of Sterling Lacquer ManufacturingCompany U-1201-NC/U-1202-F





D.3.7. Alumigrip R1204/S3800 (U.S. Paint Corporation)


A brief regulatory analysis of U.S. Paint Corporation AlumigripR1204/S3800 high-solids nonchromate epoxy primer is provided below.

• Air Emissions: The Alumigrip R1204/S3800 primer

contains three constituents that are HAPs, methyl ethylketone, toluene, and xylene. Although there are no ODSspresent in the primer, fully mixed Alumigrip R1204/S3800contains approximately 340 grams VOCs per liter ofprimer.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of Alumigrip R1204/S3800 primer may beclassified as RCRA D001 ignitable wastes due to the lowflash point of this product. At least four constituents of the


Alumigrip R1204/S3800 primer may generate hazardouswaste: methyl ethyl ketone, toluene, xylene, and n-butylalcohol. Methyl ethyl ketone is listed as hazardous wastenumbers D035, F005, and U159, toluene is listed as F005and U220, xylene is listed as F003 and U239, and n-butylalcohol is listed as F003 and U031.

• Wastewater Discharges: Under the CWA, the use ofAlumigrip R1204/S3800 primer may result in wastestreams containing any of four regulated compounds:xylene, toluene, 4-hydroxy-4-methyl-2-pentanone, andn-butyl alcohol. Xylene and toluene are designatedhazardous substances under CWA Section 311. Toluene isdesignated under the CWA as both a toxic and a prioritypollutant. Toluene, 4-hydroxy-4-methyl-2-pentanone, andn-butyl alcohol are listed as pretreatment pollutants. Inaddition, effluent limitation guidelines have been developedfor toluene.

• Reporting Requirements: The following constituents ofAlumigrip R1204/S3800 are required to be listed on TRIreports under EPCRA Section 313: methyl ethyl ketone,toluene, xylene, and n-butyl alcohol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: methyl ethyl ketone, toluene,xylene and n-butyl alcohol.

• EPA 17: Three of the constituents of AlumigripR1204/S3800, methyl ethyl ketone, toluene, and xylene, areincluded on the EPA 17 list of chemicals targeted for strictregulation.


An overall medium to high hazard rating is given to the alternativeAlumigrip R1204/S3800. This rating is based on a determination thatAlumigrip R1204/S3800 has a medium toxicity rating and a high exposurerating. The medium to high hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below. Constituents of concern in Alumigrip R1204/S3800 include toluene,xylene, di-isobutyl ketone, methyl ethyl ketone, n-butyl alcohol,4-hydroxy-4-methyl-2-pentanone (diacetone alcohol), epoxy resin,aromatic petroleum distillates, talc, and 2,4,6-tris(dimethylaminomethyl)


phenol. For information on exposure limits and product composition(percent weights), see Appendix C. Talc is a suspected human carcinogen.Toluene, xylene, di-isobutyl ketone, methyl ethyl ketone,4-hydroxy-4-methyl-2-pentanone, and n-butyl alcohol are known humanneurotoxicants. Experimental animal teratogen data was also noted for theconstituents methyl ethyl ketone, n-butyl alcohol, toluene and xylene.Experimental animal mutation data exists for methyl ethyl ketone, xylene,toluene, and n-butyl alcohol. No other known human carcinogens,teratogens, genotoxicants, or neurotoxicants were identified. This productcontains toluene, which is considered by the state of California to havereproductive effects. Identified oral LD50s and inhalation LC50s for theconstituents of concern indicate a moderate level of toxicity. The lowestoral LD50, identified for n-butyl alcohol, was 790 mg/kg of body mass.The lowest LC50 was found to be 400 ppm for toluene. Additional healtheffects of the primer constituents are discussed below.


limited to, the following: irritation of the skin, eyes, or theupper respiratory tract, with possible blurred vision,irreversible burns to the eyes, and allergic skin reactions.Inhalation of vapors and mists can cause nervous systemeffects such as fatigue, loss of coordination, headaches,dizziness, hallucinations, vomiting, diarrhea, and nausea.

• Chronic Effects: Chronic overexposure may cause lungdiseases, kidney damage secondary to red blood hemolysis,anemia, bone marrow changes, liver damage, pulmonaryfibrosis, shortness of breath, chronic cough, and permanentbrain and nervous system damage.

Nonchromate primer Alumigrip R1204/S3800 was assigned a mediumtoxicity rating based on published toxicity data (LD50s and LC50s) ofindividual constituents. Based on exposure limits (PELs and TLVs) of itsingredients, alternative Alumigrip R1204/S3800 was given a highexposure rating.

Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower).


A summary of the ESOH analysis of U.S. Paint Corporation AlumigripR1204/S3800 is provided in Table D-8.

Table D-8. ESOH Analysis ofU.S. Paint Corporation Alumigrip R1204/S3800

Category RatingToxicity Ratinga MediumExposure Ratingb HighHazard Ratingc Medium to HighAir Emissions - HAPs 3Air Emissions - VOCs YesAir Emissions - ODSs NoWastes Generated - Solid YesWastes Generated - Hazardous YesRegulated Wastewaters YesTRI Reporting 4CERCLA Hazardous Substances 4EPA 17 Constituents 3

aThe toxicity rating is based on the criteria described in Section 2.3.2.

bThe exposure rating is based on criteria described in Section 2.3.2.

cThe hazard rating is determined by considering the toxicity ratings and exposure ratingsof the individual constituents and the relative quantities of each constituent.

D.3.8. RW-3151-64 (Courtaulds Aerospace)


A brief regulatory analysis of Courtaulds Aerospace RW-3151-64waterborne nonchromate epoxy primer is provided below.

• Air Emissions: The RW-3151-64 primer contains threeconstituents that are listed as HAPs: 2-propoxyethanol(ethylene glycol monopropyl ether), 1-butoxy-2-propanol(propylene glycol n-butyl ether), and dipropylene glycolmethyl ether. Although there are no ODSs present in theRW-3151-64 primer, the combined VOC content of the twocomponents of this primer is 321 g/l.

• Solid/Hazardous Waste Generation: While the use ofRW-3151-64 primer does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of RW-3151-64 primermay result in a waste stream containing one regulated


compound, benzyl alcohol. Under the CWA, benzylalcohol is listed as a pretreatment pollutant.

• Reporting Requirements: The following constituent ofRW-3151-64 is required to be listed on TRI reports underEPCRA Section 313: 2-propoxyethanol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituent which is listed as a hazardoussubstance under CERCLA: 2-propoxyethanol.

• EPA 17: None of the constituents of the RW-3151-64primer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to alternative RW-3151-64.This rating is based on a determination that RW-3151-64 has a mediumtoxicity rating and a medium to high exposure rating. The medium hazardrating indicates that an overall moderate ESOH concern is caused by thechemical toxicity and worker exposure properties of this alternative.Worker exposure controls should be thoroughly reviewed and properlyimplemented for worker health and safety. Constituents of concern andexposure effects are discussed below. Constituents of concern in RW-3151-64 include dipropylene glycol methylether, amorphous silica, barium sulfate, titanium dioxide,2-propoxyethanol, epoxy resin, 2,4,6-tris(dimethylaminomethyl) phenol,benzyl alcohol, 1-butoxy-2-propanol, isophorone diamine, and(3-aminopropyl)silanetriol. For information on exposure limits andproduct composition (percent weights), see Appendix C. Amorphoussilica and titanium dioxide are listed on the MSDS with their PELs asrequired by 29 CFR 1910.1200. However, these constituents are in fullyencapsulated form and therefore are not generally considered hazardousduring normal primer application. If the cured primer is sanded or ground,a suitable respirator is required. Some experimental data exists indicatingthat titanium dioxide may be carcinogenic. Calcium metasilicate andbarium sulfate are also suspected human carcinogens. Experimentalanimal teratogen data was noted for the constituents 2-propoxyethanol andbenzyl alcohol. Experimental animal mutation data exists for benzylalcohol and barium sulfate. Dipropylene glycol methyl ether is asuspected human neurotoxicant. This primer contains no other knownhuman carcinogens, teratogens, genotoxicants or neurotoxicants. None ofthe compounds listed on the MSDS are considered by the state ofCalifornia to cause carcinogenic or reproductive effects. Toxic effects forthe constituents of concern found in the primer may range from mild to


severe irritation of the respiratory tract, to dangerous corrosive burns andsevere eye damage. Identified oral LD50s and inhalation LC50s for theconstituents of concern also indicate a moderate level of toxicity. Thelowest oral LD50, identified for isophorone diamine, was 1030 mg/kg ofbody mass. The oral LD50 for the constituent 2-propoxyethanol wasdescribed as “low”. The only LC50 found was 1530 mg/m3, for2-propoxyethanol. Additional health effects of the primer constituents arediscussed below.


limited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes. Symptoms such asswelling, redness, itching and burning, and rash may occurfrom acute overexposure. Inhalation of vapors and mistscan cause mild to extreme irritation of the nose, throat, andrespiratory tract, as well as headache, nausea, vomiting, anddiarrhea. Central nervous system depression is possible.

• Chronic Effects: Chronic overexposure may causepermanent damage to the following organs; kidneys, liver,upper respiratory tract. Prolonged or repeated exposure tochemicals in this product may cause the development ofsensitization and dermatitis.

Nonchromate primer RW-3151-64 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, RW-3151-64 was given a medium to high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), and approvedfitted respirators. Air supplied respirators are required when hazardousingredient airborne levels are in excess of TLVs. Approved emergencyfacilities (e.g., eye wash station and shower) should also be available.

A summary of the ESOH analysis of Courtaulds Aerospace RW-3151-64is provided in Table D-9.


Table D-9. ESOH Analysis of Courtaulds Aerospace RW-3151-64

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 3 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters Yes TRI Reporting 1 CERCLA Hazardous Substances 1 EPA 17 Constituents 0




D.3.9. RW-3181-64 (Courtaulds Aerospace) RW-3181-64 is virtually identical, with one exception, to the RW-3151-64 primerdescribed above. The exception is that the RW-3181-64 primer contains less acceleratorthan the RW-3151-64 primer, and therefore cures at a slower rate. ESOH and regulatoryconcerns regarding RW-3181-64 are thus likely to be the same as for RW-3151-64.


A brief regulatory analysis of Courtaulds Aerospace RW-3181-64waterborne nonchromate epoxy primer is provided below.

• Air Emissions: The RW-3181-64 primer contains three

constituents that are listed as HAPs: 2-propoxyethanol(ethylene glycol monopropyl ether), 1-butoxy-2-propanol(propylene glycol n-butyl ether), and dipropylene glycolmethyl ether. Although there are no ODSs present in theRW-3181-64 primer, the combined VOC content of the twocomponents of this primer is approximately 320 g/l.

• Solid/Hazardous Waste Generation: While the use ofRW-3181-64 primer does not appear to result in the


generation of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of RW-3181-64 primermay result in a waste stream containing one regulatedcompound, benzyl alcohol. Under the CWA, benzylalcohol is listed as a pretreatment pollutant.

• Reporting Requirements: The following constituent ofRW-3181-64 is required to be listed on TRI reports underEPCRA Section 313: 2-propoxyethanol.


• EPA 17: None of the constituents of the RW-3181-64primer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to alternative RW-3181-64.This rating is based on a determination that RW-3181-64 has a mediumtoxicity rating and a medium to high exposure rating. The medium hazardrating indicates that an overall moderate ESOH concern is caused by thechemical toxicity and worker exposure properties of this alternative.Worker exposure controls should be thoroughly reviewed and properlyimplemented for worker health and safety. Constituents of concern andexposure effects are discussed below. Constituents of concern in RW-3181-64 include dipropylene glycol methylether, amorphous silica, barium sulfate, titanium dioxide,2-propoxyethanol, epoxy resin, 2,4,6-tris(dimethylaminomethyl) phenol,benzyl alcohol, 1-butoxy-2-propanol, and (3-aminopropyl) silanetriol. Forinformation on exposure limits and product composition (percent weights),see Appendix C. Amorphous silica and titanium dioxide are listed on theMSDS with their PELs as required by 29 CFR 1910.1200. However, theseconstituents are in fully encapsulated form and therefore are not generallyconsidered hazardous during normal primer application. If the curedprimer is sanded or ground, a suitable respirator is required. Someexperimental data exists indicating that titanium dioxide may becarcinogenic. Calcium metasilicate and barium sulfate are also suspectedhuman carcinogens. Experimental animal teratogen data was noted for theconstituents 2-propoxyethanol and benzyl alcohol. Experimental animalmutation data exists for benzyl alcohol and barium sulfate. Dipropyleneglycol methyl ether is a suspected human neurotoxicant. This primercontains no other known human carcinogens, teratogens, genotoxicants, or


neurotoxicants. None of the compounds listed on the MSDS areconsidered by the state of California to cause carcinogenic or reproductiveeffects. Toxic effects for the constituents of concern found in the primermay range from mild to severe irritation of the respiratory tract, todangerous corrosive burns and severe eye damage. Identified oral LD50sand inhalation LC50s for the constituents of concern also indicate amoderate level of toxicity. The lowest oral LD50, identified for isophoronediamine, was 1030 mg/kg of body mass. The oral LD50 for the constituent2-propoxyethanol was described as “low.” The only LC50 found was1530 mg/m3, for 2-propoxyethanol. Additional health effects of the primerconstituents are discussed below.


limited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes. Symptoms such asswelling, redness, itching and burning, and rash may occurfrom acute overexposure. Inhalation of vapors and mistscan cause mild to extreme irritation of the nose, throat, andrespiratory tract, as well as headache, nausea, vomiting, anddiarrhea. Central nervous system depression is possible.

• Chronic Effects: Chronic overexposure may causepermanent damage to the following organs; kidneys, liver,upper respiratory tract. Prolonged or repeated exposure tochemicals in this product may cause the development ofsensitization and dermatitis.

Nonchromate primer RW-3181-64 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, RW-3181-64 was given a medium to high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), and approvedfitted respirators. Air-supplied respirators are required when hazardousingredient airborne levels are in excess of TLVs. Approved emergencyfacilities (e.g., eye wash station and shower) should also be available. A summary of the ESOH analysis of Courtaulds Aerospace RW-3181-64is provided in Table D-10.


Table D-10. ESOH Analysis of Courtaulds Aerospace RW-3181-64

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 3 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters Yes TRI Reporting 1 CERCLA Hazardous Substances 1 EPA 17 Constituents 0




D.3.10. 44-W-16 (Deft, Inc.)


A brief regulatory analysis of 44-W-16 waterborne nonchromate epoxyprimer from Deft, Inc. is provided below.

• Air Emissions: Although the 44-W-16 primer contains no

HAPs or ODSs, the fully mixed primer containsapproximately 340 g/l VOCs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 44-W-16 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product.

• Wastewater Discharges: The use of 44-W-16 primer doesnot appear to result in the discharge of any regulated wastestreams under the CWA.

• Reporting Requirements: The following constituent of44-W-16 is required to be listed on TRI reports underEPCRA Section 313: sec-butyl alcohol.

• CERCLA Hazardous Substances: This primer does notcontain any constituents that are listed as hazardoussubstances under CERCLA.


• EPA 17: None of the constituents of the 44-W-16 primerare included on the EPA 17 list of chemicals targeted forstrict regulation.


An overall medium hazard rating is given to alternative 44-W-16. This rating isbased on a determination that 44-W-16 has a medium toxicity rating and amedium exposure rating. The medium hazard rating indicates that both chemicaltoxicity and worker exposure cause moderate ESOH concerns when using thisalternative. Worker exposure controls should be thoroughly reviewed andproperly implemented for worker health and safety. Constituents of concern andexposure effects are discussed below. Constituents of concern in 44-W-16 include sec-butyl alcohol andnitroethane. For information on exposure limits and product composition(percent weights), see Appendix C. Experimental animal teratogen datawas noted for the constituent sec-butyl alcohol. Both sec-butyl alcoholand nitroethane are suspected human neurotoxicants. No other knownhuman carcinogens, teratogens, genotoxicants or neurotoxicants wereidentified. None of the compounds listed on the MSDS are considered bythe state of California to cause carcinogenic or reproductive effects. Toxiceffects for the constituents of concern found in the mixture may rangefrom mild to severe irritation of the respiratory tract to central nervoussystem depression. Identified oral LD50s and inhalation LC50s for theconstituents of concern also indicate a moderate level of toxicity. Thelowest oral LD50, identified for nitroethane, was 860 mg/kg of body mass.No LC50 was found for either hazardous ingredient. Additional healtheffects of the primer constituents are discussed below.

• Acute Effects: Vapors and mists are irritating to the eyes,

nose, throat, and respiratory tract. Inhalation may causeheadaches, difficulty in breathing, and loss ofconsciousness. Dizziness, staggering gait, and confusionare signs of overexposure.

• Chronic Effects: Prolonged chronic overexposure maycause redness, and drying and cracking of the skin. Skinsensitization is a chronic exposure concern. Asthma orother allergic responses may also develop. This producthas a potential to cause kidney and liver damage.

Nonchromate primer 44-W-16 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, 44-W-16 was given a medium exposure rating.


Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., safety eye protection and chemical-resistant gloves),approved fitted respirators, and approved emergency facilities (e.g., eyewash station and shower). The use of long sleeve and long leg clothing isalso recommended.

A summary of the ESOH analysis of Deft 44-W-16 is provided inTable D-11.


Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 0 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substance 0 EPA 17 Constituents 0





D.3.11. 44-W-17 (Deft, Inc.)




HAPs or ODSs, the fully mixed primer contains 337 g/lVOCs.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 44-W-17 primer may be classified as RCRAD001 ignitable wastes due to the low flash point of thisproduct.






An overall medium hazard rating is given to alternative 44-W-17. Thisrating is based on a determination that 44-W-17 has a medium toxicityrating and a medium exposure rating. The medium hazard rating indicatesthat both chemical toxicity and worker exposure cause moderate ESOHconcerns when using this alternative. Worker exposure controls should bethoroughly reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below. Constituents of concern in 44-W-17 include sec-butyl alcohol andnitroethane. For information on exposure limits and product composition(percent weights), see Appendix C. Experimental animal teratogen datawas noted for the constituent sec-butyl alcohol. Both sec-butyl alcoholand nitroethane are suspected human neurotoxicants. None of thecompounds listed on the MSDS are considered by the state of California tocause carcinogenic or reproductive effects. No other known human


carcinogens, teratogens, genotoxicants, or neurotoxicants were identified.Toxic effects for the constituents of concern found in the mixture mayrange from mild to severe irritation of the respiratory tract to centralnervous system depression. Identified oral LD50s and inhalation LC50s forthe constituents of concern also indicate a moderate level of toxicity. Thelowest oral LD50, identified for nitroethane, was 860 mg/kg of body mass.No LC50 was found for either hazardous ingredient. Additional healtheffects of the primer constituents are discussed below.


nose, throat, and respiratory tract. Inhalation may causeheadaches, difficulty in breathing and loss ofconsciousness. Dizziness, staggering gait, and confusionare signs of overexposure.

• Chronic Effects: Prolonged chronic overexposure maycause redness, drying, and cracking of the skin. Skinsensitization is a chronic exposure concern. Asthma orother allergic responses may also develop. This producthas a potential to cause kidney and liver damage.

Nonchromate primer 44-W-17 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, 44-W-17 was given a medium exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., safety eye protection and chemical-resistant gloves),approved fitted respirators, and approved emergency facilities (e.g., eyewash station and shower). The use of long sleeve and long leg clothing isalso recommended.




Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 0 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substances 0 EPA 17 Constituents 0




D.3.12. 44-W-18 (Deft, Inc.)




HAPs or ODSs, the fully mixed primer containsapproximately 340 grams VOCs per liter of primer.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 44-W-18 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofthis product.







An overall medium hazard rating is given to alternative 44-W-18. Thisrating is based on a determination that 44-W-18 has a medium toxicityrating and a medium exposure rating. The medium hazard rating indicatesthat both chemical toxicity and worker exposure cause moderate ESOHconcerns when using this alternative. Worker exposure controls should bethoroughly reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below.

Constituents of concern in 44-W-18 include sec-butyl alcohol andnitroethane. For information on exposure limits and product composition(percent weights), see Appendix C. Experimental animal teratogen datawas noted for the constituent sec-butyl alcohol. Both sec-butyl alcoholand nitroethane are suspected human neurotoxicants. No other knownhuman carcinogens, teratogens, genotoxicants, or neurotoxicants wereidentified. None of the compounds listed on the MSDS are considered bythe state of California to cause carcinogenic or reproductive effects. Toxiceffects for the constituents of concern found in the mixture may rangefrom mild to severe irritation of the respiratory tract to central nervoussystem depression. Identified oral LD50s and inhalation LC50s for theconstituents of concern also indicate a moderate level of toxicity. Thelowest oral LD50, identified for nitroethane, was 860 mg/kg of body mass.No LC50 was found for either hazardous ingredient. Additional healtheffects of the primer constituents are discussed below.


nose, throat, and respiratory tract. Inhalation may causeheadaches, difficulty in breathing, and loss ofconsciousness. Dizziness, staggering gait, and confusionare signs of overexposure.

• Chronic Effects: Prolonged chronic overexposure maycause redness, drying, and cracking of the skin. Skinsensitization is a chronic exposure concern. Asthma orother allergic responses may also develop. This producthas a potential to cause kidney and liver damage.

Nonchromate primer 44-W-18 was assigned a medium toxicity ratingbased on published toxicity data (LD50s and LC50s) of individual


constituents. Based on published exposure limits (PELs and TLVs) of itsingredients, 44-W-18 was given a medium exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., safety eye protection and chemical-resistant gloves),approved fitted respirators, and approved emergency facilities (e.g., eyewash station and shower). The use of long sleeve and long leg clothing isalso recommended.



Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 0 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substances 0 EPA 17 Constituents 0





D.3.13. 10PW22-2/ECW-119 (Dexter Aerospace Materials/Crown Metro Aerospace)


A brief regulatory analysis of Dexter Aerospace Materials10PW22-2/ECW-119 waterborne nonchromate epoxy primer is providedbelow.

• Air Emissions: The 10PW22-2/ECW-119 primer emits

nine constituents that are HAPs: 2-propoxyethanol(ethylene glycol monopropyl ether), 1-butoxy-2-propanol(propylene glycol n-butyl ether), 1-methoxy-2-propanol(propylene glycol methyl ether), xylene, benzene, arsenic,cadmium, lead, and beryllium. Note that four of thesechemicals (arsenic, cadmium, lead, and beryllium) arereported to be present in nonvolatile form. In addition,these four chemicals and benzene are reported to be presentonly in trace quantities. Although there are no ODSspresent in the 10PW22-2/ECW-119 primer, the fully mixedVOC content of this product is 340 g/l.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 10PW22-2/ECW-119 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofECW-119. At least five constituents of10PW22-2/ECW-119 primer may generate hazardouswaste: benzene, cadmium, lead, arsenic, and xylene.Benzene is listed as hazardous waste numbers D018, F003,and U019, cadmium is listed as D006, lead is listed asD008, arsenic is listed as D004, and xylene is listed as F003and U239.

• Wastewater Discharges: Under the CWA, the use of10PW22-2/ECW-119 primer may result in waste streamscontaining any of eight regulated compounds: benzylalcohol, benzene, cadmium, lead, beryllium, arsenic,xylene, and zinc. Benzene and xylene are designated ashazardous substances under CWA Section 311. Benzene,cadmium, lead, zinc, beryllium, and arsenic are designatedunder the CWA as both toxic and priority pollutants.Benzene and benzyl alcohol are listed as pretreatmentpollutants. In addition, effluent limitation guidelines havebeen developed for cadmium, lead, benzene, zinc,beryllium, and arsenic.

• Reporting Requirements: The following constituents of10PW22-2/ECW-119 are required to be listed on TRIreports under EPCRA Section 313: 2-propoxyethanol,


zinc, xylene, lead, cadmium, beryllium, arsenic, andbenzene.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: 2-propoxyethanol, zinc,xylene, cadmium, beryllium, lead, arsenic, and benzene.

• EPA 17: Four of the constituents of 10PW22-2/ECW-119primer, xylene, benzene, cadmium compounds, and leadcompounds, are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to alternative10PW22-2/ECW-119. This rating is based on a determination that10PW22-2/ECW-119 has a medium toxicity rating and a medium to highexposure rating. The medium hazard rating indicates that an overallmoderate ESOH concern is caused by the chemical toxicity and workerexposure properties of this alternative. Worker exposure controls shouldbe thoroughly reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below. Constituents of concern in 10PW22-2/ECW-119 include2-propoxyethanol, 1-methoxy-2-propanol, 1-butoxy-2-propanol, benzylalcohol, zinc, xylene, and n-propyl alcohol. Lead, arsenic, beryllium,cadmium, and benzene are present as trace contaminants. For informationon exposure limits and product composition (percent weights), seeAppendix C. n-Propyl alcohol is a suspected human carcinogen.Experimental animal teratogen data was noted for the constituents2-propoxyethanol, 1-methoxy-2-propanol, benzyl alcohol and xylene. Testresults in laboratory animals and lower organisms (e.g., bacteria) alsoindicate that benzyl alcohol, xylene, and n-propyl alcohol aregenotoxicants. Xylene, 1-methoxy-2-propanol, and n-propyl alcohol werealso determined to be known human neurotoxicants. The tracecontaminants benzene, arsenic, beryllium, and cadmium are known humancarcinogens. The trace contaminant lead is a suspected human carcinogen.Experimental animal teratogen data was noted for the constituentsbenzene, lead, arsenic, and cadmium. Benzene, lead and beryllium areknown human mutagens (genotoxicants). Test results in laboratoryanimals and lower organisms (e.g., bacteria) also indicate that arsenic andcadmium are genotoxicants. Benzene, lead and arsenic were alsodetermined to be known human neurotoxicants. The primer contains noother known human carcinogens, teratogens, genotoxicants, orneurotoxicants. This product contains lead, arsenic, beryllium, cadmium,


and benzene, which are considered by the state of California to causecancer. Lead, arsenic, and cadmium are considered by the state ofCalifornia to cause birth defects or other reproductive harm. Toxic effectsfor the constituents of concern found in the mixture may range from mildto severe irritation of the respiratory tract to headache, dizziness, ornausea. Identified oral LD50s and inhalation LC50s for the constituents ofconcern also indicate a moderate level of toxicity. The lowest oral LD50,identified for benzyl alcohol, was 1230 mg/kg of body mass. The lowestLC50 was found to be 1530 mg/m3 for 2-propoxyethanol. Additionalhealth effects of the primer constituents are discussed below.


limited to, the following: dermatitis and irritation of theskin, eyes, or mucous membranes. Symptoms such asswelling, redness, and rash may occur from acuteoverexposure. Inhalation of vapors and mists can causemild to extreme irritation of the nose, throat, andrespiratory tract, as well as headache and dizziness, anddrowsiness.

• Chronic Effects: Chronic overexposure may causepermanent damage to the following organs: central nervoussystem, kidneys, respiratory tract, liver and/or cornealinjury. Chemicals in this product may cause thedevelopment of carcinomas (cancer), birth defects, or otherreproductive harm.

Nonchromate primer 10PW22-2/ECW-119 was assigned a mediumtoxicity rating based on published toxicity data (LD50s and LC50s) ofindividual constituents. Based on published exposure limits (PELs andTLVs) of its ingredients, 10PW22-2/ECW-119 was given a medium tohigh exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower). A summary of the ESOH analysis of Dexter Aerospace Materials10PW22-2/ECW-119 is provided in Table D-14.


Table D-14. ESOH Analysis of Dexter Aerospace Materials/Crown Metro Aerospace 10PW22-2/ECW-119

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium Air Emissions - HAPs 9/5d

Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 8 CERCLA Hazardous Substances 8 EPA 17 Constituents 4




d Four of the identified chemicals that could contribute to HAPs emitted by this primer(arsenic, cadmium, lead, and beryllium) are reported to be present in nonvolatile form.

D.3.14. 10PW22-3/ECW-123 (Dexter Aerospace Materials/Crown Metro Aerospace)


A brief regulatory analysis of Dexter Aerospace Materials 10PW22-3/ECW-123waterborne nonchromate epoxy primer is provided below.

• Air Emissions: The 10PW22-3/ECW-123 primer emits

eight constituents that are HAPs: 1-butoxy-2-propanol(propylene glycol n-butyl ether), 1-methoxy-2-propanol(propylene glycol methyl ether), xylene, benzene, arsenic,cadmium, lead, and beryllium. Note that four of thesechemicals (arsenic, cadmium, lead, and beryllium) arereported to be present in nonvolatile form. In addition,these four chemicals and benzene are reported to be presentonly in trace quantities. Although there are no ODSspresent in the 10PW22-3/ECW-123 primer, the fully mixedVOC content of this primer is 340 g/l.

• Solid/Hazardous Waste Generation: Wastes generated bythe use of 10PW22-3/ECW-123 primer may be classified asRCRA D001 ignitable wastes due to the low flash point ofECW-123. At least five constituents of


10PW22-3/ECW-123 primer may generate hazardouswaste: benzene, cadmium, lead, arsenic, and xylene.Benzene is listed as hazardous waste numbers D018, F003,and U019, cadmium is listed as D006, lead is listed asD008, arsenic is listed as D004, and xylene is listed as F003and U239.

• Wastewater Discharges: Under the CWA, the use of10PW22-3/ECW-123 primer may result in waste streamscontaining any of eight regulated compounds: benzylalcohol, benzene, cadmium, lead, beryllium, arsenic,xylene, and zinc. Benzene and xylene are designated ashazardous substances under CWA Section 311. Benzene,cadmium, lead, zinc, beryllium, and arsenic are designatedunder the CWA as both toxic and priority pollutants.Benzene and benzyl alcohol are listed as pretreatmentpollutants. In addition, effluent limitation guidelines havebeen developed for cadmium, lead, benzene, zinc,beryllium, and arsenic.

• Reporting Requirements: The following constituents of10PW22-3/ECW-123 are required to be listed on TRIreports under EPCRA Section 313: zinc, cadmium, lead,beryllium, arsenic, xylene, and benzene.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: zinc, cadmium, lead,beryllium, arsenic, xylene, and benzene.

• EPA 17: Four of the constituents of 10PW22-3/ECW-123primer, xylene, benzene, cadmium compounds, and leadcompounds, are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium hazard rating is given to alternative10PW22-3/ECW-123. This rating is based on a determination that10PW22-3/ECW-123 has a medium toxicity rating and a mediumexposure rating. The medium hazard rating indicates that both chemicaltoxicity and worker exposure cause moderate ESOH concerns when usingthis alternative. Worker exposure controls should be thoroughly reviewedand properly implemented for worker health and safety. Constituents ofconcern and exposure effects are discussed below. Constituents of concern in 10PW22-3/ECW-123 include1-methoxy-2-propanol, 1-butoxy-2-propanol, benzyl alcohol, triethylene


tetramine, zinc, xylene, and n-propyl alcohol. Benzene, lead, arsenic,beryllium, cadmium, and benzene are present as trace contaminants. Forinformation on exposure limits and product composition (percent weights),see Appendix C. n-Propyl alcohol is a suspected human carcinogen.Experimental animal teratogen data was noted for the constituents2-propoxyethanol, 1-methoxy-2-propanol, benzyl alcohol, triethylenetetramine, and xylene. Test results in laboratory animals and lowerorganisms (e.g., bacteria) also indicate that benzyl alcohol, xylene,triethylene tetramine, and n-propyl alcohol are genotoxicants. Xylene,1-methoxy-2-propanol, and n-propyl alcohol were also determined to beknown human neurotoxicants. The trace contaminants benzene, arsenic,beryllium, and cadmium are known human carcinogens. The tracecontaminant lead is a suspected human carcinogen. Experimental animalteratogen data was noted for the constituents benzene, lead, arsenic, andcadmium. Benzene, lead and beryllium are known human mutagens(genotoxicants). Test results in laboratory animals and lower organisms(e.g., bacteria) also indicate that arsenic and cadmium are genotoxicants.Benzene, lead and arsenic were also determined to be known humanneurotoxicants. The primer contains no other known human carcinogens,teratogens, genotoxicants or neurotoxicants. This product contains lead,arsenic, beryllium, cadmium, and benzene, which are considered by thestate of California to cause cancer. Lead, arsenic, and cadmium areconsidered by the state of California to cause birth defects or otherreproductive harm. Toxic effects for the constituents of concern found inthe mixture may range from mild to severe irritation of the respiratory tractto headache, dizziness, or nausea. Identified oral LD50s and inhalationLC50s for the constituents of concern also indicate a moderate level oftoxicity. The lowest oral LD50, identified for benzyl alcohol, was1230 mg/kg of body mass. The lowest LC50 was found to be 1530 mg/m3

for 2-propoxyethanol. Additional health effects of the primer constituentsare discussed below.


limited to, the following: dermatitis or irritation of theskin, eyes, or mucous membranes. Symptoms such asswelling, redness, and rash may occur from acuteoverexposure. Inhalation of vapors and mists can causemild to extreme irritation of the nose, throat, andrespiratory tract, headache and dizziness, and drowsiness.

• Chronic Effects: Chronic overexposure may causepermanent damage to the following organs: central nervoussystem, kidneys, respiratory tract, liver, and cornea.Chemicals in this product may cause the development ofcarcinomas (cancer), birth defects, or other reproductiveharm.


Nonchromate primer 10PW22-3/ECW-123 was assigned a mediumtoxicity rating based on published toxicity data (LD50s and LC50s) ofindividual constituents. Based on published exposure limits (PELs andTLVs) of its ingredients, 10PW22-3/ECW-123 was given a mediumexposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower). A summary of the ESOH analysis of Dexter Aerospace Materials10PW22-3/ECW-123 is provided in Table D-15.

Table D-15. ESOH Analysis of Dexter Aerospace Materials/CrownMetro Aerospace 10PW22-3/ECW-123

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 8/4d

Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous Yes Regulated Wastewaters Yes TRI Reporting 7 CERCLA Hazardous Substances 7 EPA 17 Constituents 4




d Four of the identified chemicals that could contribute to HAPs emitted by this primer(arsenic, cadmium, lead, and beryllium) are reported to be present in nonvolatile form.


D.3.15. EWDY048 A/B MIL-P-85582 Type I (Spraylat Corporation)


A brief regulatory analysis of Spraylat Corporation EWDY048 A/B waterbornenonchromate epoxy primer is provided below.

• Air Emissions: The EWDY048 A/B primer contains one

component that is considered a HAP, 2-propoxyethanol(ethylene glycol monopropyl ether). While the primercontains no chemicals considered to be ODSs, the fullymixed primer contains up to 340 g/l VOCs.

• Solid/Hazardous Waste Generation: While the use ofEWDY048 primer does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of EWDY048 primerdoes not appear to result in the discharge of any regulatedwaste streams under the CWA.

• Reporting Requirements: The following constituent ofEWDY048 A/B is required to be listed on TRI reportsunder EPCRA Section 313: 2-propoxyethanol.


• EPA 17: None of the constituents of the EWDY048 A/Bprimer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium to high hazard rating is given to alternativeEWDY048 A/B. This rating is based on a determination thatEWDY048 A/B has a medium toxicity rating and a medium to highexposure rating. The medium hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be thoroughly reviewed and properly implemented for workerhealth and safety. Constituents of concern and exposure effects arediscussed below. Constituents of concern in EWDY048 A/B include 2-propoxyethanol andtitanium dioxide. For information on exposure limits and productcomposition (percent weights), see Appendix C. Titanium dioxide is


listed on the MSDS with its PEL as required by 29 CFR 1910.1200.However, this compound is in fully encapsulated form and therefore is notgenerally considered hazardous during normal primer application. If thecured primer is sanded or ground, a suitable respirator is required. Someexperimental data exists indicating that titanium dioxide may becarcinogenic. No other known or suspected human carcinogens,teratogens, genotoxicants or neurotoxicants were identified in this primer.However, experimental animal teratogenic data was identified for2-propoxyethanol. None of the compounds listed on the MSDS areconsidered by the state of California to cause carcinogenic or reproductiveeffects. Toxic effects for the constituents of concern may range fromirritation of the respiratory tract to severe lung damage. Only an oral LD50

(3089 mg/kg) and an inhalation LC50 (1530 ppm) for the constituent2-propoxyethanol were found. Additional health effects of the primerconstituents are discussed below.


limited to, the following: dermatitis and irritation of theskin, eyes, or mucous membranes, with symptoms such asswelling, redness, and rash.

• Chronic Effects: Chronic effects from prolonged orrepeated contact and/or inhalation may include drying andcracking of the skin, skin sensitization, or other allergic andsensitization responses. Severe lung damage can alsooccur.

Nonchromate primer EWDY048 A/B was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, EWDY048 A/B was given a medium to high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be used whileapplying this primer, and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker health protectionthroughout the process, and must include protective clothing (e.g., eye protectionand chemical-resistant gloves), approved fitted respirators, and approvedemergency facilities (e.g., eye wash station and shower). A summary of the ESOH analysis of Spraylat Corporation EWDY048 A/Bis provided in Table D-16.


Table D-16. ESOH Analysis of Spraylat Corporation EWDY048 A/B

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium to High Hazard Ratingc Medium to High Air Emissions - HAPs 1 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substances 1 EPA 17 Constituents 0




D.3.16. EWAE118 A/B MIL-P-85582 Type II (Spraylat Corporation)


A brief regulatory analysis of Spraylat Corporation EWAE118 A/Bwaterborne nonchromate epoxy primer is provided below.

• Air Emissions: The EWAE118 A/B primer contains one

component that is considered a HAP, 2-propoxyethanol(ethylene glycol monopropyl ether). Although the primercontains no ingredients that are considered ODSs, the fullymixed primer contains up to 340 g/l VOCs.

• Solid/Hazardous Waste Generation: While the use ofEWAE118 A/B primer does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of EWAE118 A/B primermay result in a waste stream containing one regulatedcompound, benzyl alcohol. Under the CWA, benzylalcohol is listed as a pretreatment pollutant.

• Reporting Requirements: The following constituents ofEWAE118 A/B are required to be listed on TRI reportsunder EPCRA Section 313: 2-propoxyethanol andtert-butyl alcohol.



• EPA 17: None of the constituents of the EWAE118 A/Bprimer are included on the EPA 17 list of chemicalstargeted for strict regulation.


An overall medium to high hazard rating is given to alternativeEWAE118 A/B. This rating is based on a determination thatEWAE118 A/B has a medium toxicity rating and a high exposure rating.The medium to high rating indicates that an overall moderate to highESOH concern is caused by the chemical toxicity and worker exposureproperties of this alternative. Worker exposure controls should bethoroughly reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below. Constituents of concern in EWAE118 A/B include 2-propoxyethanol, clay,tert-butyl alcohol and benzyl alcohol. For information on exposure limitsand product composition (percent weights), see Appendix C. tert-Butylalcohol is a confirmed human genotoxicant. No other known or suspectedhuman carcinogens, teratogens, or genotoxicants were identified in thisprimer. However, experimental laboratory animal teratogenic data wasidentified for tert-butyl alcohol, benzyl alcohol and 2-propoxyethanol.Experimental animal genotoxic effects were identified for benzyl alcohol.Test results in laboratory animals and lower organisms (e.g., bacteria) alsoindicate that benzyl alcohol is a genotoxicant. None of the compoundslisted on the MSDS are considered by the state of California to causecarcinogenic or reproductive effects. Toxic effects for the constituents ofconcern may range from irritation of the respiratory tract to shortness ofbreath. Oral LD50s for the constituents of concern were found to be as lowas 1230 mg/kg of body mass (for benzyl alcohol). An inhalation LC50 wasidentified for the constituent 2-propoxyethanol (1530 ppm). Additionalhealth effects of the primer constituents are discussed below.

• Acute Effects: Acute overexposure to ingredients in this

agent may cause shortness of breath, as well as nose, throat,and upper respiratory tract irritation. Eyes may alsobecome irritated. Dermatitis and skin reactions are apossibility.

• Chronic Effects: Chronic effects from prolonged orrepeated contact and/or inhalation may include drying andcracking of the skin, skin sensitization, or other allergic and


sensitization responses. Pulmonary edema may developwith repeated inhalation of high concentrations of thismaterial. This product may be harmful if swallowed.

Nonchromate primer EWAE118 A/B was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, EWAE118 A/B was given a high exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower). A summary of the ESOH analysis of Spraylat Corporation EWAE118 A/Bis provided in Table D-17.

Table D-17. ESOH Analysis of Spraylat Corporation EWAE118 A/B

Category Rating Toxicity Ratinga Medium Exposure Ratingb High Hazard Ratingc Medium to High Air Emissions - HAPs 1 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters No TRI Reporting 2 CERCLA Hazardous Substances 1 EPA 17 Constituents 0





D.3.17. U-4800-NC/U-4801 (Sterling Lacquer Manufacturing Co., Inc.)


A brief regulatory analysis of Sterling Lacquer Manufacturing Company U-4800-NC/U-4801 waterborne nonchromate epoxy primer is provided below.

• Air Emissions: The U-4800-NC/U-4801 primer contains

four constituents that are HAPs: 2-propoxyethanol(ethylene glycol monopropyl ether), propylene glycolt-butyl ether, 1-propoxy-2-propanol (propylene glycoln-propyl ether), and 1-phenoxy-2-propanol (propyleneglycol phenyl ether). Although there are no ODSs presentin this product, fully mixed U-4800-NC/U-4801 containsapproximately 330 g/l VOCs.

• Solid/Hazardous Waste Generation: While the use ofU-4800-NC/U-4801 primer does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of U-4800-NC/U-4801primer does not appear to result in the discharge of anyregulated waste streams under the CWA.

• Reporting Requirements: The following constituent ofU-4800-NC/U-4801 is required to be listed on TRI reportsunder EPCRA Section 313: 2-propoxyethanol.

• CERCLA Hazardous Substances: This primer contains thefollowing constituents which are listed as hazardoussubstances under CERCLA: 2-propoxyethanol and reactionproducts of epichlorohydrin and bisphenol A.

• EPA 17: None of the constituents of U-4800-NC/U-4801are included on the EPA 17 list of chemicals targeted forstrict regulation.


An overall medium hazard rating is given to alternativeU-4800-NC/U-4801. This rating is based on a determination thatU-4800-NC/U-4801 has a medium toxicity rating and a medium exposurerating. The medium hazard rating indicates that both chemical toxicityand worker exposure cause moderate ESOH concerns when using thisalternative. Worker exposure controls should be reviewed and properlyimplemented for worker health and safety. Constituents of concern andexposure effects are discussed below.


Constituents of concern in U-4800-NC/U-4801 are 2-propoxyethanol,propylene glycol t-butyl ether, 1-propoxy-2-propanol (propylene glycoln-propyl ether), 1-phenoxy-2-propanol (propylene glycol phenyl ether),amorphous silica, silicon dioxide (quartz), titanium dioxide, and reactionproducts of epichlorohydrin and bisphenol A. For information onexposure limits and product composition (percent weights), seeAppendix C. Amorphous silica and titanium dioxide are listed on theMSDS with their PELs as required by 29 CFR 1910.1200. However, theseconstituents are in fully encapsulated form and therefore are not generallyconsidered hazardous during normal primer application. If the curedprimer is sanded or ground, a suitable respirator is required. Someexperimental data exists indicating that titanium dioxide may becarcinogenic. Silicon dioxide is a suspected human carcinogen. No otherknown or suspected human carcinogens, teratogens, genotoxicants orneurotoxicants were identified in this primer. However, experimentallaboratory animal teratogenic/reproductive toxicity data were identified for2-propoxyethanol. None of the compounds listed on the MSDS areconsidered by the state of California to cause carcinogenic or reproductiveeffects. Additional health effects of the primer constituents are discussedbelow.


agent may cause narcotic effects, and nausea and vomiting.Contact with eyes, skin, or respiratory tract will causeirritation.

• Chronic Effects: Prolonged and repeated contact with thisproduct can cause liver effects, silicosis, and blooddisorders.

Nonchromate primer U-4800-NC/U-4801 was assigned a medium toxicityrating based on published toxicity data (LD50s and LC50s) of individualconstituents. Based on published exposure limits (PELs and TLVs) of itsingredients, U-4800-NC/U-4801 was given a medium exposure rating. Appropriate engineering controls (e.g., local ventilation) must be used whileapplying this primer, and administrative controls may be appropriate (e.g.,exposure time limits and job sharing). Also, all ignition sources should beremoved. Personal protective equipment is required for worker health protectionthroughout the process, and must include protective clothing (e.g., eye protectionand chemical-resistant gloves), approved fitted respirators, and approvedemergency facilities (e.g., eye wash station and shower).

A summary of the ESOH analysis of Sterling Lacquer ManufacturingCompany U-4800-NC/U-4801 is provided in Table D-18.

Table D-18. ESOH Analysis of Sterling Lacquer ManufacturingCompany U-4800-NC/U-4801


Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 4 Air Emissions - VOCs Yes Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substances 2 EPA 17 Constituents 0




D.3.18. G28AD012 (BASF Corporation)


A brief regulatory analysis of BASF Corporation G28AD012 electrocoatnonchromate primer is provided below.

• Air Emissions: The G28AD012 primer emits one

constituent that is a HAP, 2-butoxyethanol (ethylene glycolmonobutyl ether). This product does not contain anyregulated ODSs and the VOC content is unknown.However, the presence of 2-butoxyethanol in the productmeans it is likely that VOCs are released at somemeasurable level during its use.

• Solid/Hazardous Waste Generation: While the use ofG28AD012 primer does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use of G28AD012 primermay result in a waste stream containing one regulatedcompound, 2-butoxyethanol. Under the CWA,2-butoxyethanol is listed as a pretreatment pollutant.

• Reporting Requirements: The following constituent ofG28AD012 is required to be listed on TRI reports underEPCRA Section 313: 2-butoxyethanol.


• CERCLA Hazardous Substances: This primer contains thefollowing constituent which is listed as a hazardoussubstance under CERCLA: 2-butoxyethanol.

• EPA 17: None of the constituents of G28AD012 primerare included on the EPA 17 list of chemicals targeted forstrict regulation.


An overall medium hazard rating is given to alternative G28AD012. Thisrating is based on a determination that G28AD012 has a medium toxicityrating and a medium exposure rating. The medium hazard rating indicatesthat an overall moderate ESOH concern is caused by the chemical toxicityand worker exposure properties of this alternative. Worker exposurecontrols should be thoroughly reviewed and properly implemented forworker health and safety. Constituents of concern and exposure effects arediscussed below. Constituents of concern in G28AD012 electrocoat primer include titaniumdioxide and 2-butoxyethanol (ethylene glycol monobutyl ether). Forinformation on exposure limits and product composition (percent weights),see Appendix C. 2-Butoxyethanol is a known human neurotoxicant.Titanium dioxide is listed on the MSDS with its PEL as required by29 CFR 1910.1200. However, this compound is in fully encapsulatedform and therefore is not generally considered hazardous during normalprimer application. If the cured primer is sanded or ground, a suitablerespirator is required. Some experimental data exists indicating thattitanium dioxide may be carcinogenic. No other known or suspectedhuman carcinogens, teratogens, genotoxicants or neurotoxicants wereidentified in this primer. However, experimental laboratory animalteratogenic data was identified for 2-butoxyethanol. None of thecompounds listed on the MSDS are considered by the state of California tocause carcinogenic or reproductive effects. Toxic effects for theconstituents of concern may range from irritation of the respiratory tract todizziness and headaches. An oral LD50 (470 mg/kg) and inhalation LC50

(700 ppm) were only identified for the constituent 2-butoxyethanol.Additional health effects of the primer constituents are discussed below.


agent may cause narcotic effects characterized byweakness, dizziness, headaches, and nausea with vomiting.The agent may cause asphyxiation at higher concentrations.


• Contact with eyes, skin, respiratory tract, or mucousmembranes will cause irritation.

• Chronic Effects: Ingestion or skin absorption of significantquantities of 2-butoxyethanol may result in red blood cellhemolysis. Animals receiving repeated and prolongeddoses develop hemolytic anemia and damage to the kidneysand liver.

Nonchromate electrocoat primer G28AD012 was assigned a mediumtoxicity rating based on published toxicity data (LD50s and LC50s) ofindividual constituents. Based on published exposure limits (PELs andTLVs) of its ingredients, G28AD012 was given a medium exposure rating. Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approvedfitted respirators, and approved emergency facilities (e.g., eye wash stationand shower). A summary of the ESOH analysis of BASF Corporation G28AD012 isprovided in Table D-19.

Table D-19. ESOH Analysis of BASF Corporation G28AD012

Category Rating Toxicity Ratinga Medium Exposure Ratingb Medium Hazard Ratingc Medium Air Emissions - HAPs 1 Air Emissions - VOCs Yesd

Air Emissions - ODSs No Wastes Generated - Solid Yes Wastes Generated - Hazardous No Regulated Wastewaters No TRI Reporting 1 CERCLA Hazardous Substances 1 EPA 17 Constituents 0




d The quantity of VOCs associated with the use of this product is unknown, but thepresence of 2-butoxyethanol in the product makes it likely that VOCs are released atsome measurable level.


D.3.19. U32CD210/U32AD290 (BASF Corporation)


A brief regulatory analysis of BASF Corporation U32CD210/U32AD290electrocoat nonchromate primer is provided below.

• Air Emissions: U32CD210/U32AD290 contains two

constituents that are HAPs, 2-butoxyethanol (ethyleneglycol monobutyl ether) and ethylene glycol hexyl ether.The maximum VOC content of the mixed electrocoat bathis 0.8 lb/gal, and this product does not contain anyregulated ODSs.

• Solid/Hazardous Waste Generation: While the use ofU32CD210/U32AD290 does not appear to result in thegeneration of any RCRA hazardous wastes, solid wastesmay result and must be disposed of properly.

• Wastewater Discharges: The use ofU32CD210/U32AD290 may result in waste streamscontaining either or both of two regulated compounds,2-butoxyethanol and ethylene glycol hexyl ether. Under theCWA, 2-butoxyethanol and ethylene glycol hexyl ether arelisted as pretreatment pollutants.

• Reporting Requirements: The following constituents ofU32CD210/U32AD290 is required to be listed on TRIreports under EPCRA Section 313: 2-butoxyethanol andethylene glycol hexyl ether.

• CERCLA Hazardous Substances: This primer contains thefollowing constituent which is listed as a hazardoussubstance under CERCLA: 2-butoxyethanol.

• EPA 17: None of the constituents ofU32CD210/U32AD290 are included on the EPA 17 list ofchemicals targeted for strict regulation.


An overall medium to high hazard rating is given to alternativeU32CD210/U32AD290. This rating is based on a determination thatU32CD210/U32AD290 has a medium toxicity rating and a high exposurerating. The medium to high hazard rating indicates that an overallmoderate to high ESOH concern is caused by the chemical toxicity andworker exposure properties of this alternative. Worker exposure controlsshould be reviewed and properly implemented for worker health andsafety. Constituents of concern and exposure effects are discussed below.


Constituents of concern in U32CD210/U32AD290 are ethylene glycolhexyl ether (2-(hexyloxy)-ethanol), 2-butoxyethanol, carbon black,dibutyloxostannane (an organotin compound), aluminum silicate (Kaolin),and titanium dioxide. For information on exposure limits and productcomposition (percent weights), see Appendix C. Titanium dioxide islisted on the MSDS with its PEL as required by 29 CFR 1910.1200.However, this compound is in fully encapsulated form and therefore is notgenerally considered hazardous during normal primer application. If thecured primer is sanded or ground, a suitable respirator is required. Someexperimental data exists indicating that titanium dioxide may becarcinogenic. Carbon black is also a suspected human carcinogen.2-Butoxyethanol and organotin compounds are known humanneurotoxicants. No other known or suspected human carcinogens,teratogens, genotoxicants or neurotoxicants were identified in this primer.However, experimental laboratory animal teratogenic/reproductive toxicitydata were identified for aluminum silicates and 2-butoxyethanol. Testresults in laboratory animals and lower organisms (e.g., bacteria) alsoindicate that carbon black is a genotoxicant. None of the compoundslisted on the MSDS are considered by the state of California to causecarcinogenic or reproductive effects. Additional health effects of theprimer constituents are discussed below.


agent may cause narcotic effects characterized byweakness, dizziness, and headaches. Contact with eyes,skin, respiratory tract, or mucous membranes will causeirritation.

• Chronic Effects: Prolonged and repeated contact with thisproduct can cause red blood cell hemolysis, kidney andliver damage, damage to the lymphoid system, dermatitis,stomach granuloma, or chronic pulmonary fibrosis.

Nonchromate electrocoat primer U32CD210/U32AD290 was assigned amedium toxicity rating based on published toxicity data (LD50s and LC50s)of individual constituents. Based on published exposure limits (PELs andTLVs) of its ingredients, U32CD210/U32AD290 was given a highexposure rating.

Appropriate engineering controls (e.g., local ventilation) must be usedwhile applying this primer, and administrative controls may be appropriate(e.g., exposure time limits and job sharing). Also, all ignition sourcesshould be removed. Personal protective equipment is required for workerhealth protection throughout the process, and must include protectiveclothing (e.g., eye protection and chemical-resistant gloves), approved


fitted respirators, and approved emergency facilities (e.g., eye wash stationand shower).

A summary of the ESOH analysis of BASF CorporationU32CD210/U32AD290 is provided in Table D-20.

Table D-20. ESOH Analysis of BASF Corporation U32CD210/U32AD290

Category RatingToxicity Ratinga MediumExposure Ratingb HighHazard Ratingc Medium to HighAir Emissions - HAPs 2Air Emissions - VOCs YesAir Emissions - ODSs NoWastes Generated - Solid YesWastes Generated - Hazardous NoRegulated Wastewaters NoTRI Reporting 2CERCLA Hazardous Substances 1EPA 17 Constituents 0

aThe toxicity rating is based on the criteria described in Section 2.3.2.

bThe exposure rating is based on criteria described in Section 2.3.2.

cThe hazard rating is determined by considering the toxicity ratings and exposure ratingsof the individual constituents and the relative quantities of each constituent.

APPENDIX E

REFERENCES

Potential Alternatives Report E-1

REFERENCES

• American Conference of Government Industrial Hygienists (ACGIH), Documentationof the Threshold Limit Values and Biological Exposure Indices., 6th ed., Vols. I-III, Cincinnati, OH, 1991.

• ACGIH, Industrial Ventilation: A Manual of Recommended Practice, 22nd ed.,Cincinnati, OH, 1995.

• ACGIH, 1996 TLVs and BEIs, Threshold Limit Values for Chemical Substances andPhysical Agents, Biological Exposure Indices, Second Printing, ACGIH,Cincinnati, OH, 1996.

• Lewis, Richard J., Sr, Sax’s Dangerous Properties of Industrial Materials, 9th ed.,Vols. I-III, Van Nostrand Reinhold, New York, 1996.

• MDL Information Systems Inc., OHS MSDS on Disk, January 1996.• National Center for Manufacturing Sciences (NCMS), Alternatives to Chromium for

Metal Finishing, Ann Arbor, Michigan, 1995.• National Institute of Occupational Safety and Health (NIOSH), NIOSH Pocket Guide

to Chemical Hazards, U.S. Government Printing Office, Washington, DC, 1994.• State of California Environmental Protection Agency, Safe Drinking Water and Toxic

Enforcement Act of 1986; Chemicals Known to the State of California to CauseCancer or Reproductive Toxicity. Internet Site athttp://www.calepa.cahwnet.gov/oehha/docs/5-97list.htm, revised May 1, 1997.

• United States Environmental Protection Agency (U.S. EPA), “EPA’s 33/50 ProgramFifth Progress Update”

• U.S. EPA, Internet Site at http://es.epa.gov/new/contacts/newsltrs/derm93.html,November 20, 1997.

• 40 CFR part 261 et seq.• 40 CFR part 400 et seq.• 40 CFR part 129 et seq.• 40 CFR part 302 et seq.• 40 CFR §51.100• 42 USC §7671• 42 USC §7412(b)• 42 USC §11023

http://www.calepa.cahwnet.gov/oehha/docs/5-97list.htm

http://es.epa.gov/new/contacts/newsltrs/derm93.html,

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