AUSTRALIA GROUP: CLARIFYING LISTED MATERIALS ON

UNCLAS SECTION 01 OF 06 STATE 087597 SENSITIVE SIPDIS E.O. 12958: N/A TAGS: PARM ETTC SUBJECT: AUSTRALIA GROUP: CLARIFYING LISTED MATERIALS ON THE DUAL-USE CHEMICAL EQUIPMENT CONTROL LIST (#3 OF 4) ¶1. (U) This is an action request. Please see paragraph 2. -------------- ACTION REQUEST -------------- ¶2. (SBU) Drawing on the background below, Department requests AG country Embassies provide the non-paper in paragraph 6 to appropriate host government officials and elicit a response. (Note: This is the third of four cables conveying U.S. proposals. End Note) In delivering this non-paper, posts should indicate that the U.S. is sharing this non-paper as part of preparations for the September 21-25 AG plenary and that we would appreciate hearing their views or any suggestions they may have on the non-paper. Also, request Embassy Canberra provide the non-paper to the AG chair for circulation as an official AG document. -------------- REPORTING DEADLINE -------------- ¶3. (U) Embassy should report results of this demarche by cable before September 7. Please contact ISN/CB Andrew Souza at 202-647-4838 or via e-mail for further information. -------------- BACKGROUND -------------- ¶4. (SBU) The manufacturing process for many chemical warfare agents can be extremely caustic, requiring equipment that is made of specialized corrosion and heat resistant materials. To help limit the proliferation of chemical weapons, the 40-country Australia Group (AG) has agreed to require government permission for exports of this specialized chemical production equipment. For this year's AG plenary session, the United States will present three proposals to refine this control list for dual-use chemical equipment. One proposal, detailed herein, is to clarify some of the terms used to describe the corrosion and heat resistant materials on the chemical production equipment control list. ¶5. (SBU) Specifically, this proposal sets out to clarify three issues, the first of which is ambiguity about what constitutes a controlled metal alloy or fluoropolymer. To resolve this, the United States recommends setting a minimum threshold of 35% fluorine by weight for fluoropolymers and defining tantalum, titanium, zirconium, and niobium alloys as being mostly (i.e. 50 percent or more) tantalum, titanium, zirconium or niobium by weight. The second issue is that the list uses the overly broad term 'ferrosilicon' to refer to a specialized group of silicon-iron alloys that are only 10-18% silicon by weight. Ferrosilicon is often used to describe an alloy that is 15-90% silicon by weight that is typically used in the production of carbon or stainless steels. The final issue is correcting the inconsistent use of the term ceramics, throughout the list. The entries for heat exchangers and valves refer to specific types of ceramics, such as silicon carbide, while the entries for pumps and incinerators use the general word ceramics., -------------- BACKGROUND -------------- ¶6. (SBU) Begin text of non-paper: AG-In-Confidence AUSTRALIA GROUP Australia Group Doc AG/Jul09/CL/USA/xx Clarifying Listed Materials for Controlled Chemical Equipment Issue STATE 00087597 002 OF 006 Should the Australia Group (AG) clarify the controlled materials for dual-use chemical manufacturing equipment by adding concentration thresholds? Background At the April 2008 AG Plenary, the United States tabled a non-paper on clarifications to controls for dual-use chemical equipment. One of these concerns discussed in the paper was the ambiguity in listed materials in most control list entries. Elemental concentration limits are provided for high nickel and nickel/chromium alloys, but not for tantalum, titanium, zirconium, and niobium alloys. Fluoropolymers also lack a minimum fluorine percentage. In addition, one listed material, ferrosilicon is improbable as a material of construction for chemical equipment. We recommended in our non-paper that "ferrosilicon" be replaced with the term "high silicon iron" and a minimum silicon percentage be added to more accurately describe the material of concern. Finally, there is an inconsistency in the description of ceramic materials listed for heat exchangers and condensers (specifically, "silicon carbide" and "titanium carbide") and pumps (just "ceramics"). Based on our discussions with AG members during the 2008 plenary and based on the information provided below, the United States believes AG members should consider the following changes to the control list to provide greater clarity to its listed materials. Discussion Metal Alloys: Tantalum, Titanium, Zirconium, Niobium Absent definitions, industry and government officials may find it difficult to comply with and enforce controls on dual-use equipment composed of tantalum, titanium, zirconium, or niobium alloys. To the best of our knowledge, the following information for each alloy is accurate: Tantalum: Tantalum alloys for chemical equipment comes in two forms 97.5% tantalum and 2.5% tungsten and 90% tantalum and 10% tungsten. Titanium: The American Society for Testing and Materials (ASTM) defines a number of titanium alloys varying from commercially pure titanium used in orthopedic and dental applications to 55% titanium (ASTM grade 36 with 45% niobium). For most applications in the chemical industry, titanium is alloyed with varying amounts of molybdenum and/or chromium with trace amounts of other elements. Although titanium is also used in other alloys as a minor additive, alloys are generally categorized according to the element that forms the majority or plurality of the material. Hence such alloys would generally not be considered to be titanium alloys. Zirconium: Zirconium alloys that are used in the chemical industry contain elemental concentrations between 95% and 99%. Niobium: We could not find any references for the use of niobium in the chemical industry as a principal element at a specific elemental concentration. Therefore, we recommend that tantalum, titanium, zirconium and niobium alloys be defined, via a technical note, as containing a "higher percentage by weight" of the stated metal than any other metal. Fluorpolymers Fluoropolymers are among the most chemically inert of all materials and are typically manufactured as homopolymers, such as PTFE (Teflon); co-polymers, such as FEP; or as ter-polymers, such as THV (For more information on the properties of commercial fluoropolymers, see Technology of Fluoropolymers, 2nd edition, by Jiri George Drobny). Fluoropolymers can also be physically mixed with non-fluoronated plastics to create unique engineered materials. Based on their unit structures or smallest repeating units, the percent of fluorine present in some common fluoropolymers can be calculated as follows: PTFE (Teflon) -- Polytetrafluoroethylene -- 76% fluorine by STATE 00087597 003 OF 006 weight PVDF -- Polyvinylidene fluoride -- 59% fluorine by weight PCTFE -- Polychlorotrifluoroethylene -- 49% fluorine by weight FEP -- Fluorinated ethylene propylene -- 76% fluorine by weight ETFE -- Polyethylenetetrafluoroethylene -- 59% fluorine by weight ECTFE -- Polyethylenechlorotrifluoroethylene -- 39% fluorine by weight PFA -- perfluoroalkoxy -- 76% fluorine by weight THV -- Ter-polymer of tetrafluoroethylene, hexafluoropropylene and vinylidene fluoride -- 73% fluorine by weight Based on these calculations, a reasonable minimum threshold for fluoropolymers and plastic mixtures containing fluoropolymers would be more than 35% fluorine by weight. Therefore, it would be useful to define the fluoropolymers category as materials with more than 35% fluorine by weight. Ferrosilicon Ferrosilicon is an alloy of iron and silicon containing between 15% and 90% silicon. It is used industrially as a source of silicon in the production of carbon steels, stainless steels, and other ferrous alloys. In contrast, iron castings with element concentrations of silicon from 10% to 18% are used for pump rotors and pump impellers in the chemical industry for processing and transporting highly corrosive liquids, such as sulfuric acid and nitric acid, and in the manufacture of fertilizers, textiles, and explosives. For example, Duriron is an iron alloy containing 14.5% silicon and 1% carbon that shows excellent resistance to sulfuric acid and nitric acid at all concentrations. Durichlor contains 14.5% silicon, 1% carbon and 4% chromium and is resistant to severe chloride containing solutions and other strongly oxidizing environments. The high silicon content of these iron alloys improves corrosion resistance, but at the expense of resistance to thermal and mechanical shock. They cannot be subjected to sudden fluctuations in temperature nor can they withstand any substantial stressing or impact. They are also extremely brittle and difficult to machine. (For more information on high silicon iron, see 1) Metals Handbook, 9th Edition, Volume 15 (Casting) (1978) by D.M. Stefanesca; 2) Encyclopedia or Corrosion Technology, 2nd Edition (2004) by P.A. Schweitzer; 3) Corrosion Engineering Handbook, Fundamentals of Metallic Corrosion, 2nd Edition (2007) by P.A. Schweitzer; 4) Environmental Degradation of Metals (2001) by U.K. Cahtterjee, S.K. Bose, and S.K. Roy; and 5) Foseco Foundryman's Handbook (2001) by J.R. Brown, ed. For more information on ferrosilicon, see ASTM Standard A100-07) In order to distinguish between these different types of silicon-containing alloys, we recommend clarifying the term "ferrosilicon" in the control for pumps by adding the words 'with 10 to 18 percent silicon by weight.' Ceramics We were able to find only limited information in the United States verifying the use of ceramics of any type in the production of controlled dual-use chemical equipment, as few companies in the U.S. manufacture or sell chemical equipment with ceramic wetted parts. Based on one industry source (a manufacturer of ball valves),silicon carbide has excellent corrosion protection properties in all chemical environments. Another ceramic, alumina (Al2O3),offers very good protection in most acids (except for HF) and fairly good protection in other environments. We were also able to verify the use of alumina wetted parts in pumps based on U.S. licensing records. We therefore recommend replacing ceramics in the control language for pumps with the language for valves that was adopted by AG participants during the 2009 intersessional period. Entry Harmonization STATE 00087597 004 OF 006 Finally, we have noted that the order and phrasing of the listed materials varies across entries on the control list for dual-use chemical production equipment. We recommend that the order and phrasing of the materials listed in each entry be arranged in the same order, wherever possible. Recommendation We propose clarifying listed materials for dual-use chemical production equipment through the adoption of the following changes to the control text and the addition of a technical note: ¶1. Reaction Vessels, Reactors or Agitators Reaction vessels or reactors, with or without agitators, with total internal (geometric) volume greater than 0.1 m3 (100 L) and less than 20 m3 (2000 L) where all surfaces that come into direct contact with the chemical(s) being processed or contained are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; or h. niobium and niobium alloys; Agitators for use in the above mentioned reaction vessels or reactors; and impellers, blades or shafts designed for such agitators, where all surfaces of the agitator or component that come in direct contact with the chemical(s) being processed or contained are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; or h. niobium and niobium alloys; ¶2. Storage tanks, containers, and Receivers Storage tanks, containers or receivers with a total internal (geometric) volume of greater than 0.1 m3 (100 L) where all surfaces that come in direct contact with chemical(s) being processed or contained are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; or h. niobium and niobium alloys; Heat Exchangers and Condensers Heat exchangers or condensers with a heat transfer surface area greater than 0.15 m2, and less than 20 m2; and tubes, plates, coils or blocks (cores) designed for such heat exchangers or condensers, where all surfaces that come in direct contact with the chemical(s) being processed are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; STATE 00087597 005 OF 006 d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; h. niobium and niobium alloys; i. graphite or carbon-graphite; j. silicon carbide; or k. titanium carbide Distillation or Absorption Columns Distillation or absorption columns of internal diameter greater than 0.1 m; and liquid distributors, vapor distributors or liquid collectors designed for such distillation or adsorption columns, where all surfaces that come in direct contact with the chemical(s) being processed are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; h. niobium and niobium alloys; or i. graphite or carbon-graphite. Technical note: carbon-graphite is a composition of carbon and graphite, in which the graphite content is eight percent or more by weight. ... ¶6. Valves Valves with nominal sizes greater than 1.0 cm (3/8 inch) and casings (valve bodies) or preformed casing liners designed for such valves, in which all surfaces that come into direct contact with the chemical(s) being produced, processed or contained are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; or h. niobium and niobium alloys; ¶7. Multi-Walled Piping Multi-walled piping incorporating a leak detection port, in which all surfaces that come in direct contact with the chemicals being processed or contained are made from the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; h. niobium and niobium alloys; or i. graphite or carbon-graphite. Technical note: carbon-graphite is a composition of carbon and graphite, in which the graphite content is eight percent or more by weight. ¶8. Pumps STATE 00087597 006 OF 006 Multiple-seal and seal-less pumps with manufacturer's specified maximum flow-rate greater than 0.6 m3/h or vacuum pumps with manufacturer's specified maximum flow-rate greater than 5 m3/h (under standard temperature (273 K (0oC)) and pressure (101.3 kPa) conditions),and casings (pump bodies), preformed casing liners, impellers, rotors or jet pump nozzles designed for such pumps, in which all surfaces that come into contact with the chemical(s) being processed are made from any of the following materials: a. fluoropolymers with more than 35% fluorine by weight; b. glass or glass-lined (including vitrified or enamelled coating); c. nickel or nickel alloys with more than 40% nickel by weight; d. alloys with more than 25% nickel and 20% chromium by weight; e. tantalum and tantalum alloys; f. titanium and titanium alloys; g. zirconium and zirconium alloys; h. niobium and niobium alloys; i. graphite or carbon-graphite; j. ferrosilicon with 10 to 18% silicon by weight; or h. ceramic materials as follows: ¶1. silicon carbide with a purity of 80% or more by weight. ¶2. aluminum oxide (alumina) with a purity of 99.9% or more by weight. ¶3. zinconium oxide (zirconia) Technical note: carbon-graphite is a composition of carbon and graphite, in which the graphite content is eight percent or more by weight. ... Technical note: for the listed materials in the above entries, the term alloy, when not accompanied by a specific elemental concentration is understood as identifying those alloys where the identified metal is present in a higher percentage by weigh than any other element. End nonpaper. ¶7. (U) Please begin all responses with AUSTRALIA GROUP and slug for ISN. ¶8. (U) Department thanks posts for their support. CLINTON