VZCZCXRO8920
PP RUEHSL
DE RUEHC #7597/01 2341840
ZNR UUUUU ZZH
P 221820Z AUG 09
FM SECSTATE WASHDC
TO AUSTRALIA GROUP COLLECTIVE PRIORITY
RUEHVB/AMEMBASSY ZAGREB PRIORITY 3165
RUEHKV/AMEMBASSY KYIV PRIORITY 1134
INFO RUEKJCS/SECDEF WASHINGTON DC PRIORITY
RHMFISS/JOINT STAFF WASHINGTON DC PRIORITY
RUEAIIA/CIA WASHINGTON DC PRIORITY
RUCPDOC/USDOC WASHINGTON DC PRIORITY 5529
RHMCSUU/DEPT OF ENERGY WASHINGTON DC PRIORITY

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. 
 
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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. 
 
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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. 
 
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BACKGROUND 
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¶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., 
 
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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