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[0032-02] [PPD and IONIT OX] [07 October 2015]

Third party submission of information on alternatives for

Applications for Authorisation

NON-CONFIDENTIAL

Legal name of submitter(s): Oerlikon Balzers Coating Germany GmbH

SUBMISSION OF INFORMATION ON ALTERNATIVES (NON-CONFIDENTIAL)


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TABLE OF CONTENTS

1. ALTERNATIVE ID AND PROPERTIES ........................................................................ 4

2. TECHNICAL FEASIBILITY ....................................................................................... 12

3. ECONOMIC FEASIBILITY........................................................................................ 21

4. HAZARDS AND RISKS OF THE ALTERNATIVE............................................................ 25

5. AVAILABILITY ...................................................................................................... 29

6. CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE .................... 30

7. OTHER COMMENTS............................................................................................... 31

REFERENCES ........................................................................................................... 31

APPENDICES ........................................................................................................... 31



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CONTACT DETAILS

Philip Read Market Segment Manager Forming Tools Oerlikon Balzers Coating Germany GmbH Hohe-Flum-Straße 22 79650 Schopfheim Germany T +49 7622 39 99 0 [email protected] Amtsgericht Mainz, commercial register no.: 22510, German tax no. 08 650 0152 2, USt-ID-Nr. DE 811 614 113 Managing Directors: Hendrik Alfter / Dr. Wolfgang J. Schmitz

Dr. Fabian Hoffmann Technical Sales Automotive Nitriding Oerlikon Metaplas GmbH Theodor-Heuss-Strasse 63 38228 Salzgitter Germany T: +49 5341 8587-0 www.oerlikon.com/balzers



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1. ALTERNATIVE ID AND PROPERTIES

Oerlikon Balzers has developed several technologies that could replace most applications of functional chrome plating. The two main technologies are called PPD and IONIT OX and are described below. TECHNICAL ALTERNATIVE PPD Technology Oerlikon Balzers has developed PPD (Pulsed-Plasma Diffusion), an innovative technology that uses a combination of hydrogen, nitrogen, and electricity to produce an environmentally friendly and cost-effective alternative to traditional hard chrome plating. Oerlikon Balzers has developed three surface treatment technologies on the basis of PPD:

BALITHERM™ PPD - For automotive stamping dies BALITHERM™ PRIMEFORM - For plastic moulds BALITHERM™ IONIT - For component parts PPD technology is designed to replace functional hard chrome plating and produces a wear-resistant hardened case to protect tools and surfaces from harsh production and working environments. However, BALITHERM™ PPD, PRIMEFORM and IONIT do not use hazardous chemicals and are thus significantly more sustainable. These technologies have the potential to increase material efficiency, eliminate worker exposure to hazardous chemicals, and limit safety and environmental consequences. PPD technology is already implemented as a standard surface treatment process on automotive stamping tools worldwide by nearly all of the large automotive OEMs including General Motors, Ford, Nissan, Mazda, Kia, Hyundai, BMW and many others. PPD technology is already installed and used by automotive OEMs in Germany (Europe) since 2004, the USA (North America) since 2006, as well as Korea, Japan and China (Asia) since 2014.



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PPD machine with a loading capacity of 40 metric tonnes

In the PPD process, energy from electricity is used to charge a gas mixture of nitrogen and hydrogen. Nitrogen is then diffused into the iron or steel producing a hard wear-resistant surface. The technology is based on plasma nitriding, in which nitrogen and hydrogen gas molecules become ionised in a vacuum and through the application of voltage between the chamber wall and the charged gas ions then react with the iron of the tool to develop a hard nitrided zone. Through BALITHERM™ PPD processing, a material with a diffusion depth of 0.1mm up to 0.7mm is created through finely dispersed precipitations, which strengthens the microstructure and increases the hardness of the iron or steel components. This creates an ideal foundation for a compound layer, which is an inter-metallic layer and a mixture of iron and nitrates (approx. 1000-1200HV) of approximately 8-30 microns. This compound layer has extremely high wear resistance properties. PPD technology differs from standard nitriding technology with its integrated cleaning cycle. This is important for automotive press tooling dies and other tools that are typically soaked in oil and lubricants used in the production process. Traditional nitriding processes require a separate "bake out" process to remove these lubricants before treatment. With the development of PPD, this “bake out” step is eliminated, which reduces the heat cycles required to treat the tools and allows a high degree of temperature control during the cleaning cycle as this process now takes place under vacuum in the PPD chamber. With a cleaning cycle in vacuum, the PPD process can produce exceptionally high surface qualities not previously possible with traditional nitriding technology. The PPD process uses only hydrogen and nitrogen gases combined with electricity. These gases are of no risk to the environment and in addition, all process cooling water runs on a closed system ensuring that no water wastage is produced. BALITHERM™ PPD BALITHERM™ PPD is designed to treat all dies used in the automotive stamping industry and BALITHERM™ PRIMEFORM is used to treat plastic injection moulds used for interior and exterior parts. An economical and short treatment turnaround time is offered due to the huge PPD vessel capacity of 40 tonnes and 10m length x 2.9m width.



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Automotive tooling to produce a hood panel treated with BALITHERM™ PPD

Once the BALITHERM™ PPD treatment is completed on automotive skin panel dies, the treatment will last for the life of the car model (5-7 years) without any need for retreatment. The BALITHERM™ PPD-treated surface can also be easily maintained and can be re-polished, stoned (a technique using an oil stone to modify the surface) or even welded to repair any damage occurred in the customer’s production process. This maintenance “friendliness” of PPD technology is an advantage over chrome plating which does not allow modifications to the die once it is chrome plated. This ability of PPD technology to maintain the dies without re-treatment saves the need for further chrome stripping and re-chroming of the tool, which is then necessary to repair any damage with a chrome plated surface. Once the car model production is finished (typically after 5-7 years of production), the dies remain in storage for 10 years to allow the production of any spare parts to repair crashed vehicles. After the 10-year die storage is over, the dies are melted down/scrapped, which poses no environmental problem as the PPD layer is composed of just nitrogen atoms. BALITHERM™ PRIMEFORM BALITHERM™ PRIMEFORM is a further process developed by Oerlikon Balzers that can be applied using PPD technology. PRIMEFORM is refined for large plastic injection moulds. It uses the same principal technology as PPD but the temperature, composition of hydrogen and nitrogen and gas flows are different, leading to a different final result in terms of wear-resistant layer.

Plastic injection parts produced with moulds treated with BALITHERM™ PRIMEFORM



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Plastic moulds are commonly used in the automotive industry to produce interior and exterior plastic parts. These plastic parts contain a high percentage of glass fibre for strength and are very abrasive to the mould surface. PRIMEFORM reduces the downtime in production associated with wear and once applied to the mould surface, eliminates the need for chrome plating of the mould. The BALITHERM™ PRIMEFORM-treated surface can also be easily maintained and can be re-polished or even welded to repair any damage occurred in the customer’s production process. It has the same maintenance “friendliness” as described for BALITHERM™ PPD above. BALITHERM™ IONIT The main application of BALITHERM™ IONIT is the treatment of large gears, bearings and stainless steel component parts. These parts are not typically chrome plated, but demonstrate the flexibility of the PPD technology and the product application range the PPD machine can handle. IONIT OX Technology Oerlikon Balzers has developed BALITHERM™ IONIT OX, an innovative thermochemical technology to surface treat components. It employs a combination of nitrogen, hydrogen and carbon to produce an environmentally friendly, cost-effective and corrosion-resistant alternative to traditional hard chrome plating. The IONIT OX technology combines the advantages of cost reduction with the fact that chromium VI is neither used during processing nor is found in the end product. IONIT OX uses no hazardous chemicals and offers a “suitable economically and technically viable alternative” under REACH. The patented BALITHERM™ IONIT OX process combines thermochemical processing — gas nitrocarburising, plasma activation (plasma nitrocarburising), and oxidation. Gas nitrocarburising uses ammonia and carbon dioxide process gases with a precisely controlled chemical decomposition for the formation of nitrogen and carbon. This forms a nitride compound layer and a diffusion layer with a defined structure and phase composition. The activation of the nitrided surface occurs in the plasma nitrocarburising process, during which the nitrided surface of the component is bombarded with nitrogen, hydrogen and carbon ions. The final oxidation step produces a closed oxidation layer approximately 2 µm thick, which is characterised by superior corrosion and wear protection as well as good friction properties. To achieve the desired corrosion and wear protection for the component, a conventional nitriding process – such as gas nitriding or gas nitrocarburising – is combined with a plasma process and a controlled oxidation process. During the gas nitrocarburising process, chemical reactions trigger the layer formation. A more pronounced porous zone is formed with this process compared to plasma nitrocarburising. The oxidation treatment forms a homogeneous layer of iron oxide. This combined treatment represents an environmentally friendly alternative to the typical corrosion protection processes. The surface of components treated with IONIT OX exhibits three distinct layers:

• the diffusion layer (200-500 µm thickness) - which provides excellent mechanical support as a result of the hardness gradient from the soft base material to the hard nitride compound layer;

• the compound layer (15-30 µm thickness) - with a hardness up to 1100 HV and; • the oxide layer (1-3 µm thickness) - with its unique surface morphology, it

provides very good corrosion properties and a low friction coefficient.



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This three-layered type of structure guarantees high levels of wear protection together with excellent corrosion resistance. IONIT OX can be applied on a number of metals such as construction steel, carbon steel, case hardened steel, tempering steel, nitrided steel and, in general, low-alloyed steels. The entire IONIT OX process takes place within a closed system, known as a furnace. The furnace is designed with a 3-zone heating mechanism that allows for excellent temperature distribution. Each of the 3 zones is controlled by a thermocouple (a sensor used to measure temperature), which restricts temperature deviation to +/-5°C throughout the whole production process. The process temperature never exceeds 580°C. Under this condition, the growth rate of the compound layer is very steady.

The production cycle of the BALITHERM™ IONIT OX treatment consists of 8 phases:

▪ heating ▪ evacuating/pumping ▪ nitriding ▪ evacuating ▪ plasma activation* ▪ pressurising ▪ oxidation ▪ cooling.



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*The plasma activation phase removes impurities from the components and increases the nitrogen concentration in the compound layer. This improves the corrosion resistance of the treated parts.

While the BALITHERM™ IONIT OX treatment process itself consists of the above 8 phases, there are additional steps that are needed to complete the entire case hardening treatment. However, in comparison to conventional hard chrome plating that has ten steps, the BALITHERM™ IONIT OX treatment has only 3 steps (please see table). Another advantage is that the process time for IONIT OX is 12-22hrs, which makes it a more straightforward and time-effective process. For hard chrome plating, the amount of time it takes depends on the production line, although it can also be done as a continuous process.



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APPLICATION PPD PPD technology can be used for a broad range of applications within the automotive industry, including: ▪ automotive stamping tools BALITHERM™ PPD ▪ draw dies for skin panels BALITHERM™ PPD ▪ draw dies for structural parts BALITHERM™ PPD ▪ re-strike die operations BALITHERM™ PPD ▪ plastic injection moulds BALITHERM™ PRIMEFORM

The applications that can be PPD treated are not limited to automotive tooling. Other components that can be treated in the renewable energy or aerospace sector include:

heavy machinery parts including gears BALITHERM™ IONIT crankshafts BALITHERM™ IONIT large rollers BALITHERM™ IONIT tools for the production of large plastic containers BALITHERM™ IONIT wind turbine gears BALITHERM™ IONIT ▪ wind turbine bearings BALITHERM™ IONIT ▪ stainless steel parts (e.g. for power  generation)  BALITHERM™ IONIT

IONIT OX The IONIT OX process represents an economically and environmentally friendly alternative, with high reproducibility for high-volume, mass-produced small components compared to partial or complete chromium plating. IONIT OX is designed to replace hard chrome plating by providing lifetime corrosion and wear protection for components used in the automotive, general engineering and chemical industries. The following are examples of components that can be treated: Automotive industry:

• ball pins • brakes • shift shafts • pistons • clutch components • gear shafts • differential axles • synchroniser rings • wiper axles • break disks • gas springs.

General engineering:

• construction components • tools • hydraulic components (e.g. hydraulic actuators for a mobile crane) • textile machine components • ship engines • agricultural machinery • components for the oil & gas industry.



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Chemical industry:

• ball valves • roller bodies • valves • hotplates • pump parts.

Aerospace industry While not currently applied to components used in the aerospace industry, the functional characteristics of IONIT OX treated components would suit well the demands of this sector. Thus, it could be conceivable that IONIT OX could be used on aerospace components in the future, for example on pistons for the carriage, gas springs in the cabins or hydraulic components. As the aviation industry uses more lightweight materials like aluminium, the variety of applications in aviation is much more limited than other industries. A leading provider of maintenance, repair and overhauls services for aircraft has asked Oerlikon Balzers for heat-treating components like bushes and trunnions. Therefore, IONIT OX can be applied to a large variety of applications. However, it is based on gas nitrocarburising and can therefore not be used on high-alloyed steels. The size of the furnace would currently also be a limiting factor, however, that can be adapted by engineering. Additionally, IONIT OX cannot only be applied to replace electroplating, but can be expanded beyond that to cover thermal degreasing/degassing. The CTAC consortium’s Analysis of Alternatives (AoA) states that the IONIT OX type of case hardening alternative cannot treat all types of components that electroplating currently treats. Due to the high temperatures used in the process, materials that cannot withstand the high temperatures of the heat treatment, such as plastics, are not treatable. However, Oerlikon Balzers has developed other technologies such as the PPD process that could treat these relevant parts. SUBSTANCES Substances in the PPD technology SDS is not required as only hydrogen, nitrogen and electricity are used. Substances in the IONIT OX technology Carbon*: CAS number - 630-08-0 Ammonia: CAS number - 7664-41-7 * While carbon monoxide is not directly used in the IONIT OX treatment process, it could be present as a result of the process’ chemical reaction. However, any carbon monoxide that may be produced in this manner is effectively negated, as it will be routed to the rooftop of the treatment centre and disposed of via a burn-off flame.



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RISK COMPARISON PPD

Substance Applies for: BALITHERM™ PPD BALITHERM™ PRIMEFORM BALITHERM™ IONIT

Physico-chemical properties

Hazard classification and labelling (hazard codes)

Hydrogen N/A N/A Nitrogen N/A N/A Electricity N/A N/A IONIT OX

Substance Physico-chemical properties Hazard classification and labelling (hazard codes)

Nitrogen N/A N/A Hydrogen N/A N/A Oxygen N/A N/A Iron N/A N/A Ammonia Gaseous, Odorous

Molecular weight: 17.03 g/mol H221 (flammable gas) H314 (causes severe skin burns and eye damage) H331 (toxic if inhaled) H400 (very toxic to aquatic life)

Carbon* Gaseous, Odourless Molecular weight: 28.01 g/mol

H220 (extremely flammable gas) H331 (toxic if inhaled) H360D (may damage the unborn child) H372 (causes damage to organs)

* While carbon monoxide is not directly used in the IONIT OX treatment process, it could be present as a result of the process’ chemical reaction. However, any carbon monoxide that may be produced in this manner is effectively negated, as it will be routed to the rooftop of the treatment centre and disposed of via a burn-off flame.

2. TECHNICAL FEASIBILITY

PPD PPD technology is a technically feasible alternative and compares well or even exceeds the performance of functional electroplating in:

wear resistance hardness low friction coefficient anti-stick properties supports lubrication flexibility to treat complex parts and forms

The AoA states that no alternative to functional chrome plating “providing all the required properties to the surfaces of all articles in the scope of this application, is industrially available”. The range of BALITHERM™ technologies provided by Oerlikon Balzers with



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BALITHERM™ PPD, BALITHERM™ PRIMEFORM and BALITHERM™ IONIT however, cover these and PPD technology is already industrially available in Germany (Europe) since 2004, the USA (North America) since 2006, as well as Japan, Korea and China (Asia) since 2014. The BALITHERM™ PPD and BALITHERM™ PRIMEFORM technologies BALITHERM™ PPD improves the quality and strength of stamping dies, tools and components with its hard wear-resistant case layer. BALITHERM™ PPD-treated surfaces are a direct replacement for chrome-plated surfaces in many applications including automotive stamping tooling and plastic injection moulds. The surface quality of BALITHERM™ PPD is designed to meet the tough requirements of automotive stamping tools. Due to the flexibility, durability and high quality surfaces produced by PPD technology, BALITHERM™ PPD is already implemented as a standard treatment process worldwide by nearly all of the large automotive OEMs. PPD is installed in 5 of Oerlikon Balzers’ network of coating centres in five different countries (Oerlikon Balzers operates in total over 100 coating centres in over 32 countries worldwide).

Worldwide production sites for PPD as of Sept 2015. When directly compared to chrome plating, BALITHERM™ PPD has proven time and time again in stamping shops worldwide, its superior performance in terms of productivity, wear resistance and reduction of costs and equals chrome plating in terms of surface quality and coefficient of friction. The BALITHERM™ PPD treatment provides exceptional durability in a production environment, allowing modification and repair of the tools directly on the BALITHERM™ PPD-treated surface. This flexibility to work with the tools’ surface after treatment allows minor repairs and modifications to the tool without the need for a further retreatment of the tool. Damage to the tool surface due to press line production accidents can quickly be repaired, allowing a more stable production process. With chrome-plated surfaces, most minor damage results in the chrome layer being stripped, the surface repaired and the tool re-chromed. This increases the total treatment cost, lowers productivity and increases the environmental impact of chrome plating through additional use of chemicals and transportation between factories. The BALITHERM™ PPD-treated surface shows a major advantage over chrome in that the surface:



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can be re-worked with a stone; can be welded; can be heat popped (heated to expand the material removing small dents) should

damage occur; maintains the exact same shape so tools can be used immediately in production; allows welded areas to be treated.

BALITHERM™ PPD only needs to be applied to the dies once in their lifetime, unlike chrome plating, which needs to be re-applied to the tool numerous times (up to 10 times over the life of the tool). In stamping environments a chrome plated tool surface can produce on average 100K-150K press parts before the chrome layer is worn and the chrome layer must be stripped and re-chrome plated. Once the BALITHERM™ PPD treatment is complete, the tool lasts for the production life of the car model (5-7 years) without requirement for any retreatment. The dies used then remain in storage for 10 years, to fulfil the requirement for any spare part production. After the 10-year storage period is over, the dies are scrapped (melted down). The equipment that is used to apply the BALITHERM™ PPD treatment has a 10m length and 40 metric tonne load capacity, allowing the treatment to be applied to even the largest stamping tools and plastic injection moulds in the industry. Corrosion resistance is of secondary importance for automotive stamping tooling as the oils and lubricants used in the process provide enough corrosion resistance to the die. Therefore any comparison between chrome plating and BALITHERM™ PPD in this application is not necessary. BALITHERM™ PPD does however increase the corrosion resistance of automotive stamping tooling as the compact compound layer of 8-30 microns formed in the BALITHERM™ PPD process provides a corrosion resistant layer. The topic of corrosion resistance is more important for plastic injection moulds, which use fewer lubricants and must retain a high mirror-polished finish to ensure part quality. Plastic injection moulds typically made of 1.2311 with a low content of chromium in the tool material benefit from the injection of nitrogen into the 1.2311 tool steel. The diffusion of nitrogen in the BALITHERM™ PRIMEFORM process increases the saturation of nitrogen in the surface structure providing an increase of corrosion resistance to the tool. This corrosion resistance is sufficient to protect the mirror-polished surface from corrosion in the production environment. Plastic injection moulds made of high content chromium steel (stainless) are treated in a special PRIMEFORM process. Here special attention is taken not to exceed a temperature of 380°C during BALITHERM™ PRIMEFORM processing. At this lower temperature, the nitrogen forms no bonds to the chromium in the tool steel and the corrosion resistance of these already high corrosion resistant steels is not affected. This ability to successfully treat high chromium content steel substrates has been proven in salt bath and corrosion tests. Layer and functional geometry With Oerlikon Balzers' PPD technology, no layer is applied to the substrate because diffusion into the substrate takes place. For metallic chrome coatings, layers tend to have a “thickness between 15 and 500µm although the potential thickness of a metallic chrome coating is unlimited”. On automotive stamping tools, the chrome layer thickness actually can cause problems. As the tolerance of these tools is very limited, any change in the shape of the tool form can result in production issues and lead to scrap parts being produced. The chrome layer changes the gap between the working faces of the tool, increasing the force on the sheet metal leading to cracks and splits in the produced part.



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Diagram showing the difference in form change between Chrome Plating and PPD

technology

Automotive tools need to be readjusted after chrome plating to take into account the change in dimensions of the tools. As the chrome layer thickness cannot be precisely controlled, each new re-chroming of the tools is followed by a re-adjustment of the tool to counteract the changes in dimensions on the quality of the produced part. With BALITHERM™ PPD this adjustment is all but eliminated as the BALITHERM™ PPD process diffuses into the tool substrate with no change to the delicate form of the tool. A significant decrease in the time taken to prepare the tool for production is then achieved, leading to cost savings by the stamping plant. Long-term performance PPD has been commercially available since 2004 in Europe, and is applied on well over 5 000 stamping tools in the European market alone. These BALITHERM™ PPD-treated stamping tools have been running successfully for many years at OEMs and 1st tier stamping companies such as GM, Ford, BMW, KIA, Hyundai, Nissan to name just a few. Worldwide BALITHERM™ PPD is applied to well over 10 000 stamping tools and this number is increasing. The BALITHERM™ PPD performance has been proven in countless automotive vehicle projects showing tool life performance (1 BALITHERM™ PPD treatment) on production volumes of over 1.5 million vehicles. Many of these vehicle projects have since finished mass production and are since transferred to the 10-year die storage cycle. The follow up projects (new model variant) have again been BALITHERM™ PPD treated and are in mass production. For this reason, the major OEMs and first tier suppliers already implement PPD technology as a standard surface treatment process on automotive stamping tools worldwide. Legislation compliance The BALITHERM™ PPD process also complies with the relevant approvals mentioned in the AoA by the EU and UN and has been approved by third parties. Conclusion For the automotive sector the AoA provides a performance summary for BALITHERM™ PPD:



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Whereas the real performance of BALITHERM™ PPD according to Oerlikon Balzers' findings are:

Assessment overview for Case hardening (automotive and general engineering)

Industry sector

Corrosion resistance

Hardness Rebuilding of parts

Friction coefficient

Anti-stick properties

Automotive and general engineering

Good

Excellent

1200HV compound layer

and 58HRC base material

Good

Maintenance friendly and can be easily re-worked without need for re-treatment

Good

Excellent

IONIT OX

BALITHERM™ IONIT OX is a technically feasible alternative to functional hard chrome plating and it can provide certain advantages to the treated component, including:

• enhances surface hardness; • significantly improves wear protection; • offers superior corrosion resistance, even in applications with biodiesel or in a

marine environment; • outstanding abrasion and sliding properties; • high growth rate of the compound layer; • improves fatigue resistance; • good tribiological properties; • no galvanic corrosion with aluminium; • dense crack-free coatings; • excellent bond strength; • no spallation; • little edge growth; • no hydrogen embrittlement; • low surface roughness; • low friction coefficient; • inert coating behaviour; • due to low treatment temperature, there is no right of distortion for IONIT OX-

treated components. Practical examples of how BALITHERM™ IONIT OX’s functional capacities are applied to automotive components include:



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• clutch bells for the gear box with high wear resistance; • shift shafts with low sliding values and high wear resistance; • ball pins that are resistant against salt water; • pump covers that are resistant to RME diesel; • high precision pinion shafts installed in differential gears.

Pre-treatment Unlike conventional chrome plating, components treated with the IONIT OX process do not require any pre-treatment. However, a clean, grease-free and bare metallic surface on the components is important for ensuring the quality of the finished product. Functional requirements – general case hardening BALITHERM™ IONIT OX is unique in that it includes a plasma activation stage within its treatment process. Reasons for including plasma activation in the treatment of components include:

better cleaning of the gas nitro-carburised surface; optimising of crystallisation conditions of Fe3O4-oxide layer; compensation of N- and C- (nitrides) losses during cooling.

The benefit of this additional phase of plasma activation is that it results in a higher corrosion resistance of the treated component. This is a particularly useful characteristic for automotive components, as they are often subjected to corrosive environments. A typical test in the automotive industry, the salt spray test (SST), indicates surface treatments’ resistance to corrosion. The process includes blasting a treated component with salt water to see how many hours it can resist corrosion under such conditions. BALITHERM™ IONIT OX tests very well in SSTs, surpassing the performance of conventional chrome plating technologies. For example, when components with the same treatment thickness undergo a salt spray test, the component treated with IONIT OX resists corrosion for over 500hrs, while the component treated with conventional hard chrome plating succumbs after only 300hrs (see below graph).



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As the process uses atmospheric gas, the treatment is applied uniformly, which considerably expands the range of components that can be treated. Whether you treat a gear shaft or a ball pin, the uniformity of the treatment on the component will be the same. Thus, the process is irrespective to geometry, which considerably expands the type of component that can be treated using IONIT OX.

The life cycle of IONIT OX-treated components is at least 15 years, which is longer than conventional hard chrome plated components. This results in a long-lasting guarantee of high corrosion resistance, without multiple re-treatments. IONIT OX meets the 6 requirements that the AoA lists: Quantifiable key functionality IONIT OX Wear resistance Not generally defined (automotive

industry has different engine test stands)

Hardness >1000HV Layer thickness >200 µm Corrosion resistance >900hrs in SST Coefficient of friction < 0.15 dry / < 0.1 lubricated Effect on surface morphology Increase of the roughness from 1 to

2 µm in Rz* is measured. A polishing may be necessary for special applications.

*Rz = Average Roughness Depth The AoA states, “Without a well-developed chromium trioxide-free alternative, corrosion will certainly increase, as these coatings do not offer all the crucial properties of chromium trioxide coating systems”1. However, IONIT OX-treated components have been shown (through SSTs) to actually provide greater corrosion resistance than hard chrome-treated components, even in demanding environments such as marine

1 Analysis of Alternatives (AoA), p. 14.



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applications. As shown above, it is also able to fulfil the other functional requirements noted in the AoA. The process chain of IONIT OX is not critical, as only ammonia, nitrogen gas and carbon gas are used. Any necessary cleaning before starting the IONIT OX treatment can be done with alkaline water-based cleaners and components can be re-melted in blast furnaces without the need for additional processing steps. It has been shown that IONIT OX is an excellent solution for the replacement of chrome plating in the automotive industry. Its lifetime is more than 15 years and inspection intervals are longer compared with chrome-plated parts (e.g. ball pins, gas springs, shift shafts, etc.). The lifetime of IONIT OX-treated components is long enough that car manufacturers do not need to keep spare components in stock. Leading European car manufacturers have also tested IONIT OX-treated components and have given type approval, which are documented in many technical drawings. Layer As the Analysis of Alternatives states, “the layer thickness depends on the sector specific applications and requirements and may vary significantly between different applications. The layer thickness has a high impact on the properties of the final metallic chrome coating”2. The thickness of the IONIT OX layers, primarily the diffusion zone, leads to key functionalities such as increased wear and corrosion resistance and increased fatigue strength.

Long-term performance With regards to long-term performance of components treated with IONIT OX, the additional oxidation layer provides superior corrosion resistance in the long term without any negative effect on the hardness of the component surface. The treatment has been in use since 1996 by a German gas springs manufacturer. Furthermore, it is stated in the Analysis of Alternatives that the part life of IONIT OX-treated components can be up to three times that of functional chrome plated parts3. Functional requirements – automotive sector Oerlikon Balzers' IONIT OX technology can adequately meet the functional requirements of components for the automotive industry where it has been used since 1996. The technology has been tested, evaluated and approved4 for its superior performance in terms of corrosion resistance, hardness, layer thickness, adhesive strength, coefficient of friction and wear resistance. The Analysis of Alternatives states, “in general, the automotive sector requires for metallic chrome coatings a Vickers Hardness (ISO 6507-1) of 1 000-1 200 HV”5. IONIT OX can achieve a surface hardness of >1 000 HV, which adequately satisfies this functional requirement.

2 Analysis of Alternatives (AoA), p. 13. 3 Analysis of Alternatives (AoA), p. 75. 4 All required specifications in automotive technical drawings are met by Oerlikon Balzers' IONIT OX technology. 5 Analysis of Alternatives (AoA), p. 76.



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With regards to the testing and evaluation of IONIT OX-treated components used in the automotive industry, IONIT OX-treated ball pins have been embedded in cars for over 15 years and have been tested on the road in summer and winter conditions. IONIT OX-treated components can also be tested on a large scale, as demanded in the AoA6, due to the fact that Oerlikon Balzers produces more than 40 million IONIT OX-treated automotive components in Germany and China. The automotive industry, especially three leading European car companies, uses IONIT OX-treated components, meaning they have already sufficiently validated use of these components in their vehicles. A primary developer and producer of active and passive safety systems, has also validated the use of IONIT OX-treated components that are used in French cars. When assessing the suitability7 of case hardening as an alternative to hard chrome plating for the automotive sector, the Analysis of Alternatives states:

However, based on our evidence, IONIT OX (which falls into the case hardening category) should be assessed as the following table states:

Assessment overview for IONIT OX (Automotive and General engineering) Industry sector

Corrosion resistance

Hardness Rebuilding of parts

Friction coefficient

Anti-stick properties

Automotive and General engineering

Excellent >900hrs in SST

Excellent >1000HV

Good

Excellent < 0.15 dry / < 0.1 lubricated

Good

General engineering, steel and metal precision parts Oerlikon Balzers' IONIT OX technology is currently being used to treat different complex equipment, vehicles and machines within the scope of general engineering. This includes agricultural machinery as well as trucks and forklifts. Hydraulic cylinders, for example, are parts used in many different applications and environments, such as agricultural equipment, ship engines and oil platforms. These parts must be able to perform in a range of challenging environments, including in maritime applications. Oerlikon Balzers produces components such as crankshafts and valves that are used on marine ships. The company also treats hydraulic piston rods used on cranes. Oerlikon Balzers has customers in the automotive, oil and hydraulic industries. The Analysis of Alternatives has voiced concern that case hardening as an alternative in the general engineering sector is not suitable because of “high friction coefficients and 6 Analysis of Alternatives (AoA), p. 4. 7 Legend of colour-coding, Analysis of Alternatives, p. 54: -Red: not sufficient: the parameters/assessment criteria do not fulfil the requirements of the respective sector. -Green: sufficient: the parameters/assessment criteria do fulfil the requirements of the respective sector. -Yellow: the parameters/assessment criteria fulfil some requirements for some but not all applications/sectors.



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insufficient anti-stick properties”8 of components. It also claims that case hardening is currently only applied on “small components and that the industrial application for large parts with a length of up to 6m still needs to be investigated and proper functionality needs to be proven”9. However, Oerlikon Balzers has built furnaces that can run the BALITHERM™ IONIT OX treatment that are 10m in length or 10m in depth10. As can be shown, the consortia’s Analysis of Alternatives does not accurately portray the functionalities of case hardening (and specifically IONIT OX) as a suitable alternative to hard chrome plating. To conclude, the AoA states that while some alternatives “are qualified for specific applications, none of them are able to meet all the performance requirements of functional chrome plating”11. We have now shown that, in fact, Oerlikon Balzers’ IONIT OX technology can fill this gap because it has been active in the industry for almost 20 years and is performed on a number of different components used in the automotive, hydraulic and chemical industries.

3. ECONOMIC FEASIBILITY

The AoA states that no economic feasibility study was conducted as they think case hardening is not technically feasible. As seen above however, case hardening can be technically feasible with Oerlikon Balzers' alternatives as well as economically feasible. PPD PPD technology offers significant economic benefits. BALITHERM™ PPD only needs to be applied to the die or component once in their lifetime, unlike chrome plating, which needs to be done numerous times (up to 10 times over the life of the tool). Below are typical examples of the economic benefit of BALITHERM™ PPD.

• A car vehicle production volume is 100 000 vehicles per year x 5 years production giving a total requirement of 0.5 million vehicles.

• 0.5 million press parts of all variants (door, roof, hood, tailgate, fender etc….) will need to be produced in the stamping plant.

• Chrome plating needs to be stripped and replaced every 100K-150K parts produced due to wear of the chrome surface in production. (This number does not including any maintenance requirements due to production mistakes which can damage the chrome layer enough to require a re-treatment of chrome).

• The chrome layer will therefore be replaced 3-5 times over the model life of the vehicle production per die.

• The total cost of chrome is 3-5 times the initial cost per die plus the transportation required by heavy truck to bring the die to and from the chrome plating facility.

In comparison, BALITHERM™ PPD requires only 1 treatment for the model life (0.5 million) of the vehicle.

8 Analysis of Alternatives (AoA), pp. 42-43,. 9 Ibid. 10 A German manufacturer of high-end injection moulding machines for plastics processing, can attest to this claim. 11 Analysis of Alternatives (AoA), p. 7.



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As this example shows, although the initial costs for BALITHERM™ PPD treatment might be slightly higher, the overall costs are lower than for traditional functional chrome plating. The technology is cost-efficient due to the elimination of re-chroming cycles associated with chrome plating. BALITHERM™ PPD will last for the life of the car model (5-7 years) without any need for retreatment. Once a car model is finished the dies remain in storage for 10 years, in case spare parts run out and another batch needs to be produced e.g. doors. BALITHERM™ PPD does not use any substances of very high concern (SVHCs), which are subject to authorisation under the European chemicals regulation REACH; the technology is therefore also a viable long-term option. There are no switching costs for the original equipment manufacturer (OEM)12 to treat a tool with BALITHERM™ PPD versus chrome. The standard materials and die construction methods are suitable for the BALITHERM™ PPD process. In fact, the BALITHERM™ PPD technology is already implemented as a standard treatment process worldwide by nearly all of the large automotive OEMs. BALITHERM™ PPD technology is already installed and used by automotive OEMs in Germany, USA, Japan, China and Korea. If the tool is already chrome plated it only needs to be stripped of the chrome before PPD technology can be applied. PPD offers a faster turnaround of projects due to the huge BALITHERM™ PPD vessel capacity of 40 tonne and 10m length x 2.9m width. PPD is a European innovation and a breakthrough technology. The use of BALITHERM™ PPD would give the EU automotive industry, other EU industries using surface treatments as well as the surface treatment industries a competitive advantage on the global market. The hard chrome plating industry may be at risk of severe job losses, which could be compensated through the use of PPD technology. PPD will help to increase European competitiveness globally in a fast-developing technology landscape.

12 OEMs are companies that make parts or subsystems that another company uses in its end product



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IONIT OX

IONIT OX is a European innovation and a breakthrough technology. The use of BALITHERM™ IONIT OX would give the EU automotive industry, other EU industries using surface treatments and surface coating industries a competitive advantage on the global market due to its superior corrosion resistance. IONIT OX does not use chromium VI, which may be banned in the near future due to its toxicity. The hard chrome plating industry may therefore be at risk of severe job losses that could be compensated through the use of the IONIT OX technology. With regards to manufacturers and end users of components treated with the BALITHERM™ IONIT OX treatment, the consideration of cost is complex. In each case, the specific requirements of each industry have to be taken into account with differentiation between the manufacturer and the user. Generally, the manufacturing costs are the critical issue for the original equipment manufacturer; whereas, the total lifetime process costs are important for the user. In terms of manufacturing, IONIT OX has lower manufacturing costs because there are less machining steps in the process than in conventional hard chrome plating processes. There are also lower costs and risks in the area of legal conformity. When considering the total lifetime costs of the process, BALITHERM™ IONIT OX has a shorter turnaround time than conventional hard chrome plating, which is particularly important for airlines and complex machinery and components (in terms of downtime and spare parts logistics). Due to the near net shape13 behaviour of IONIT OX, the number of process steps is reduced, which means that the customer can manufacture their parts to final dimensions before the IONIT OX treatment is applied. This shortens the process chain and automatically reduces the manufacturing costs. The large reduction in the number of processing steps amounts to a cost reduction of at least 20%, and also produces improved corrosion resistance, increased fatigue strength and lower wear rates. Human resources PPD The PPD production setup and process requires the same number of employees as a hard chrome plating facility. Employees who have worked in the chrome plating industry can readily be trained to use BALITHERM™ PPD systems. IONIT OX To operate one IONIT OX furnace takes three employees. One employee must act as an operator, one must perform maintenance and one must ensure quality control. While the operation of the process itself is automatic, the operator is responsible for tasks such as cleaning the furnace, loading and unloading the components. If there is more than one furnace in the same treatment centre, these same three employees can also take responsibility for the other furnaces. The IONIT OX production setup and process requires the same number of employees as hard chrome plating facility. Employees who have worked in the chrome plating industry can be easily trained to use IONIT OX systems. 13 To be near net shape means that the surface treatment has no major influence on the geometry and dimensions of the part. Even complicated structures and patterns on the surface of the part will still be there after the treatment. So, one can use the part immediately after the IONIT OX treatment without any further machining. This saves process steps and therefore time and money.



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Volumes PPD PPD technology can be applied to all major cast iron and cast steel variants used in automotive tooling including the largest body side tools due to the system’s 40 tonne capacity. 99.9% of all automotive stamping tools fit into the equipment's vacuum chamber. IONIT OX Today, more than 40 million parts are treated with IONIT OX for the automotive industry in Germany and China each year. IONIT OX technology can be applied to small and medium metal components in batches of ca. 10 000 per treatment in each furnace. Each treatment has a cycle time between 12 and 22 hours, depending on the specifications. For hard chrome plating the amount of time it takes depends on the production line although it can also be done as a continuous process. At present, Oerlikon Balzers can build 10 IONIT OX furnaces per year. Investment costs PPD Oerlikon Balzers operates BALITHERM™ PPD treatment factories around the world in Germany, USA, Japan, Korea and China. Customers can send tools and dies to Oerlikon Balzers for job coating in each of these regions. Oerlikon Balzers offers job coating services in over 30 countries worldwide at over 100 coating service centres. This worldwide footprint can easily be used to rapidly expand the use of PPD technology should it be required. If the future customer requires a dedicated PPD facility, Oerlikon Balzers can offer an on-site facility or sell a PPD machine to customers to operate themselves. Oerlikon Balzers designs, engineers, manufactures and further develops the PPD technology from its plant in Schopfheim Germany. As no retreatment of stamping dies is necessary with BALITHERM™ PPD, a single PPD machine can equal the capacity of 3-5 chrome plating lines. The production setup cost for PPD is therefore equivalent as with chrome plating, due to the increased performance provided in the technology. IONIT OX The sales price for one IONIT OX furnace is approximately EUR 700 000 (Base 2015). Supply chain PPD AoA: “Furthermore, due to the high complexity of the supply chain in the automotive industry, tracking down chromium trioxide dependant parts is a time-consuming and complicated task.” IONIT OX Oerlikon Balzers has experience providing treated components to the automotive industry for more than 20 years, replacing chrome plating components previously used by leading car manufacturers and safety testing companies in Europe.



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Spare parts PPD The BALITHERM™ PPD treatment is required to be applied only once to the tool. Should the tool require a further treatment due to extreme modification of the tool's surface, a second BALITHERM™ PPD treatment can easily be applied to the tool. As BALITHERM™ PPD concentrates on the tooling requirements and not on parts being produced, there is no effect on spare part requirement and no adaptation required by suppliers. Tools that have already been chrome plated simply need the chrome to be stripped and a BALITHERM™ PPD process applied to it. No adjustment in the production setup is required and there are no modifications (except chrome stripping) to be done to the tools. IONIT OX IONIT OX-treated components have a longer life than most of the automotives in which they are used. This drastically reduces the need to pool spare parts, as the car will likely be off the road by the time it could need a spare part. Methodology Oerlikon Balzers has already set up systems such as the ones in its treatment centres worldwide, which give a good indication of investment costs, volumes, and manpower needed to operate the IONIT OX technology. The above claims are supported by the success of its technology being used by leading component manufacturers in Europe and around the world.

4. HAZARDS AND RISKS OF THE ALTERNATIVE

PPD

Overall PPD is a safer alternative to human health and the environment as no hazardous chemicals are used in PPD technology. Again the AoA has not looked into this technology in detail, as they believe it is not technically feasible. The information that they do provide though on substances used does not correspond to those used in Oerlikon Balzers’ technology. PPD technology is significantly more environmentally sustainable than the traditional chrome plating technology it is designed to replace. The BALITHERM™ PPD process uses hydrogen, nitrogen and electricity. There are no harmful waste gases or chemicals created or used in the process. A small amount of ammonia is produced at low volumes that do not require an environmental permit. BALITHERM™ PPD-treated tools are highly recyclable because they do not contain any harmful substances such as lead, mercury, cadmium or hexavalent chromium. BALITHERM™ PPD-treated tools last longer, require less maintenance, and result in fewer scrap parts than conventional chrome-plated tools. No re-treatment is required with BALITHERM™ PPD. Traditionally chrome-plated tools require retreatment up to ten times over their lifetime. CO2 emissions from transporting parts to and from the chrome-plater are eliminated with BALITHERM™ PPD.



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After the ten-year die storage period is over (see section above), the dies are melted down for scrap, but this causes no environmental hazard as BALITHERM™ PPD-treated dies only contain some nitrogen. The BALITHERM™ PPD system, which is made of steel, has a life expectancy of 20-30 years. After its use, the system can be melted down and recycled. Health The PPD process gases consist of nitrogen and hydrogen, which are harmless to human health. The PPD process does not use any substances classified as SVHCs under EU legislation. BALITHERM™ PPD eliminates worker exposure to potential inhalation risks from the materials and substances used in conventional chrome plating. BALITHERM™ PPD is a closed system, which ensures workers’ safety and protects human health. All cleaning of the stamping tools, which can be soaked in oils and lubricants from the stamping process, takes place inside the vacuum chamber. As the system is closed and precautionary measures are taken, the exposure to electromagnetic fields is within the limits set by the relevant EU legislation. The system is easily maintained at no risk to workers. Other risks The BALITHERM™ PPD treatment system offers a fully automatic process that employs automatic fail-safe mechanisms, should a problem occur. If the system enters a fail-safe, it goes into standby mode and informs the operator on his/her cell phone. All systems can be monitored from the headquarters via a secure Internet connection. The diffusion of nitrogen into the substrate occurs at approx. 500°c, a precise control mechanism, which uses thermocouples placed directly into the tools being treated, ensures that the temperature of the system is automatically managed. PPD technology is fully in line with the technological trend towards cleaner and leaner production, and the EU innovation strategy, as it offers an integrated solution consisting of the technology, the equipment, the materials, and the training for use and maintenance. It thus promotes a more holistic life cycle approach across the value chain from the raw materials stage to the end of life options for the parts.

IONIT OX

Oerlikon Balzers completed hazard and risk analyses of the IONIT OX treatment in 2001, which uses an internal scoring system to rate the hazards and risks associated with using the nitriding system, IONIT OX machines and the workspace surrounding the machines. To operate the machines, no additional approval is required, which shows that the legislators do not believe the risk of the machine is high. The overall hazards and risks of using the BALITHERM™ IONIT OX treatment are very low, and Oerlikon Balzers complies with all relevant EU Directives, including the Directive on electromagnetic fields14. The BALITHERM™ IONIT OX treatment produces a component that contains only carbon, nitrogen and oxygen in the substrate of the component. Ammonia is used within the

14 Directive 2013/35/EU



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treatment process but there is no residue leftover on the treated component when the treatment is finished. Environment The most notable environmental advantage of this new technology over functional hard chrome plating that uses chromium trioxide is that IONIT OX contains no substances that are harmful to the environment. It uses nitrogen, hydrogen, carbon and ammonia and there are no harmful waste gases or chemicals created or used in the entire process.

BALITHERM™ IONIT OX offers an integrated cleaning cycle, and all cooling water used on the furnace runs on a closed system. Unlike functional chrome plating that uses chromium trioxide, the use of IONIT OX technology eliminates the chance of hazardous chemicals leaking into the ground or water reservoirs surrounding industrial processing sites.

Since BALITHERM™ IONIT OX-treated components do not contain any harmful substances such as lead, mercury, cadmium or hexavalent chromium, there is no adverse effect on their recyclability. Treated components can be re-melted together with other scrap metal, without the need for additional processing steps.

In terms of energy consumption, BALITHERM™ IONIT OX systems use up to 800 kWh per treatment batch. In terms of energy savings, an advantage of BALITHERM™ IONIT OX is that the treatment of the component lasts for a lifetime, whereas hard chrome plated components must be renewed multiple times throughout the life of the component. This then saves energy, not only on the actual operation of the machine itself, but also any fuel used/CO2 produced transporting the component back and forth between the OEM and the hard chrome-plating machine.

Assessing the amount of energy used by BALITHERM™ IONIT OX systems is important when considering the technology as a suitable alternative to hard chrome plating because of the EU’s policy goals in the field of energy. The EU is striving towards increasing its energy efficiency and energy security, in order to cut down its carbon emissions and reduce climate change15. It is also important for the EU to ensure affordable energy to consumers, businesses and industries. By using a less energy-intensive technology such as Oerlikon Balzers' IONIT OX, OEMs and consumers throughout the components supply chain could benefit from financial savings compared to hard chrome plating.

Health The substances used in the BALITHERM™ IONIT OX process are nitrogen, hydrogen, carbon and ammonia. Nitrogen, hydrogen and carbon are harmless for human health in the quantities present in the BALITHERM™ IONIT OX treatment process. The process also does not use any substances classified as SVHCs under EU legislation.

The amount of ammonia used in the BALITHERM™ IONIT OX process is equal to 15 m3/h during the treatment. The duration of the treatment is between 3-5 hours, depending on specifications of the customer. In the reaction chamber, some of the ammonia dissipates into the nitrogen and hydrogen. The BALITHERM™ IONIT OX system then eliminates any potential worker exposure to inhalation risks by using a closed burn-off system to burn off any residual ammonia. The residual ammonia (that has not dissipated) and hydrogen used in the BALITHERM™ IONIT OX process is then piped out of the furnace to a flame

15 European Commission, 2010, Energy 2020: A strategy for competitive, secure, and sustainable energy [COM(2010)639]; European Commission, 2014, A policy framework for climate and energy in the period from 2020 to 2030 [COM(2014)15].



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where it is burned off and eliminated. Oerlikon Balzers is familiar with and complies with the German laws for safe handling of ammonia.

Electromagnetic fields (EMF) The overall risk of exposure to electromagnetic fields linked to operation of IONIT OX furnaces is very low and does not present any risk to human health. Please see below for a table (in German) of specific values of the presence of EMF linked to IONIT OX. For people who wear a pacemaker, it is advised that they take precaution when standing within 0.2-0.5m of an IONIT OX furnace.

Reference: German employers' liability insurance association for precision mechanics and electrical engineering, 2001, Report of measurements Other risks The BALITHERM™ IONIT OX system offers a fully automatic process that employs automatic fail-safe mechanisms, should a problem occur. If the system enters a fail-safe, it goes into standby mode and informs the operator on his/her cell phone. All systems can be monitored from the headquarters via a secure Internet connection.

Temperature regulators within the furnace monitor if the temperature rises above the maximum 580°C, which then triggers an alarm and an automatic shutdown of the system.



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Data and methodology To determine the potential hazards and risks of IONIT OX as a suitable alternative to hard chrome plating, Oerlikon Balzers drew its claims from third-party reports such as the German employers' liability insurance association for precision mechanics and electrical engineering, (2001) Report of measurements.

5. AVAILABILITY

PPD PPD is a validated technology that has proven its application on an industrial scale worldwide. PPD technology is already implemented as a standard treatment process worldwide by nearly all of the large automotive OEMs including General Motors, Ford, Nissan, Mazda, Kia, Hyundai, BMW and many others. Oerlikon Balzers operates its own PPD centres worldwide, working directly with the OEM to provide a full service solution. However, a licensing module also exists, whereby others can acquire the technology. The worldwide market for BALITHERM™ PPD is about EUR 45-65 million, of which Oerlikon Balzers already has a 20% market share (and growing). The AoA states, “the shortest time of a complete introduction of a new coating is 10 to 15 years for the general engineering sector due to inherent high risks and the wide variety of products.” However, given that the PPD technology has already been applied since 2004, the long-term performance of the technology can be guaranteed.

IONIT OX

The AoA states that no alternative to functional chrome plating “providing all the required properties to the surfaces of all articles in the scope of this application, is industrially available”. It also states that at least 12 years time is needed to industrialise a technical and feasible alternative to conventional chrome plating. However, IONIT OX demonstrates the required functional properties and is already available industrially. IONIT OX is currently commercially available for industrial application in Europe, Asia and North America (Mexico). IONIT OX’s centres worldwide, work directly with the OEM to provide a full service solution. There are three centres operating in Germany (Salzgitter, Bergisch-Gladbach and Niederwürschnitz), various centres in Spain and Mexico and two centres in China (Changchun and Shanghai). There are plans to open treatment centres in India and the United States within the next two years. IONIT OX’s system has been licenced worldwide to German, Spanish, Korean, Swedish, Japanese, Polish, Norwegian and British OEMs, all of which produce components for the automotive industry. Currently, the breakdown of furnace capacity in each country that operates IONIT OX furnaces is as follows:

• Germany - 41 furnaces • China - 10 furnaces • Spain - 6 furnaces • Mexico - 6 furnaces • Korea - 2 furnaces



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• Sweden – 2 furnaces • Poland – 1 furnace • Norway – 1 furnace • Japan – 4 furnaces • England – 1 furnace

Automotive components have been treated with the IONIT OX process for nearly 20 years. For example, the replacement of chrome plating with BALITHERM™ IONIT OX for treating gas springs began in 1996. Today, 90% of all gas springs installed in European cars (used for lifting the trunk door or engine hood) were treated with BALITHERM™ IONIT OX. Another example is that in the year 2000, a leading European car manufacturer started using BALITHERM™ IONIT OX-treated ball pins in their cars. In conclusion, it has been shown that Oerlikon Balzers has established industrial operations worldwide and has the possibility to further expand its operations in the future. Its production capacity reaches a share of 15% for automotive nitriding and 20 million units for certain automotive components manufactured in Germany, thus establishing itself and the IONIT OX technology as an available alternative to hard chrome plating.

6. CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE

To conclude, Both PPD and IONIT OX are technically and economically feasible alternatives to functional chrome plating. Both technologies do not use any hazardous substances, are well secured in terms of environmental and health risks and are widely available in Europe as well as having a track record for performance. IONIT OX technology does not use any hazardous substances and is a technically and economically feasible alternative for the specific application of automotive and general engineering components. BALITHERM™ IONIT OX successfully fulfils all of the above-mentioned functional characteristics that conventional chrome plating provides. It provides a high surface hardness of >1000HV, thick layers of >200µm on the substrate of the component, low sliding values and excellent corrosion resistance (>900hrs of resistance to salt spray can be achieved). Components treated with BALITHERM™ IONIT OX typically have a longer life than those treated with conventional chrome plating and a longer life than automotives, which means the pooling of spare parts is unnecessary. IONIT OX and PPD are a European innovation and a breakthrough technology. The use of either would give the EU automotive industry and other EU industries a competitive advantage on the global market due to the superior corrosion resistance it can give components and dies. The use of the treatment could be expanded further than the above locations by distributing IONIT OX furnaces and PPD machines to Oerlikon Balzers' additional sites throughout the EU. BALITHERM™ IONIT OX and PPD do not use chromium VI, which may be banned in the near future due to its toxicity. The hard chrome plating industry may therefore be at risk of severe job losses that could be compensated through the use of IONIT OX and PPD. In conclusion, BALITHERM™ IONIT OX and PPD have proven themselves to be suitable alternatives to hard chrome plating based on the information provided throughout this document. They not only meet the functional requirements listed in the Analysis of Alternatives, they are also industrially available from several treatment centres



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worldwide. Most importantly, they do not include harmful substances that can negatively effect the environment or human health. A regulatory push in the form of a ban or shorter authorization period for the use of chromium VI would reduce the time needed to switch from chromium VI-based solutions to alternatives such as BALITHERM™ IONIT OX and PPD, particularly in the automotive sector where OEMs can exert substantial pressure on suppliers. This would not have a negative impact on jobs in the EU. BORIC ACID In addition to being a feasible alternative to chromium trioxide, both technologies also do not use boric acid, which is very close to being placed on REACH’s ANNEX XIV. Boric acid is currently used in the functional chrome plating process. If the current time schedule from ECHA is realised, the sunset date is May 2020. This will have huge implications on electroplating and many potential alternative technologies that have been developed so far, as they represent no real or long-term option after 2020. Therefore Oerlikon Balzers' technologies are not only a viable alternative for chromium trioxide in functional chrome plating but also for boric acid in the future.

7. OTHER COMMENTS

N/A

REFERENCES

IONIT OX G. Werner at al., (1984) “Anwendung physikalischer Oberflächenmethoden an gegosssenen Nockenwellen mit dem Ziel durch definiertes Nitrieren und Oxidieren die Lebnsdauer zu erhöhen”, HTM Härterei-Techn. Mitt. 39 4, S. pp.156-164. Universität Gesamthochschule Siegen, Report No OT13/97 TD, W.

German employers' liability insurance association for precision mechanics and electrical engineering, (2001), Report of measurements.

ANNEXES

Annex 1 - BALITHERM® PPD A Worldwide standard for Automotive stamping Tools designed in Europe Annex 2 - IONIT OX customer endorsement from Layer Magazine (January 2014)

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BALITHERM® PPD A Worldwide standard for Automotive stamping Tools designed in Europe

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Die Standards for major OEM’s

!  BALITHERM® PPD treatment (Pulsed Plasma Diffusion / Plasma Nitriding / Ion Nitriding) is a recognised global standard in the Automotive OEM’s

!  The following are just a few samples of OEM standards and success stories of the BALITHERM® PPD treatment.

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Ford Global Die Standards

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!  Ford Motor Company specifies BALITHERM® PPD as a global standard for all stamping tools

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! Renault/Dacia successfully used BALITHERM® PPD and improved quality and productivity

! Story published in the Oerlikon Annual Report

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GM Global Die Standards 2013

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! General Motors specifies Ion Nitriding / BALITHERM® PPD as a global standard for all stamping tools since 2013

! An alternative of chrome is given if Ion-Nitriding cannot be sourced.

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! BMW/Mini Group specifies BALITHERM® PPD and Nitriding on its press tooling

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Successful use of BALITHERM® PPD at BMW

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Nissan North America

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! Nissan North America specifies Pulse Plasma Nitriding / BALITHERM® PPD on its press tooling

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! KIA Motors successfully used BALITHERM® PPD and improved quality and productivity

! Story published in the Oerlikon Annual Report

Annex 1

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Thank You.

R. Rachbauer, PSE 2014, Garmisch-Partenkirchen Page 10

Close to you – Anywhere in the world

Annex 1

Sulzer Metco

1/2014 The Magazine of Sulzer Metco Thin Film

Big Things in MindCustomer Portrait Enerpac

Higher, Longer, Wider –Coating Long and Large Volume Parts

Enabling Globally High Performance –from Salzgitter to Shanghai

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1/2014CUSTOMER PORTRAIT

4

Big Things in Mind

Bridges, stadiums, ferris wheels – Enerpac offers the technique and competence to manage special challenges. With hydraulic tools and engineering knowledge, the company contributes a significant part into the success of construction projects.

The ancient Romans would have been glad: How much easier and faster it would have been in the building of aqueducts or bridges, if they had the state-of-the-art hydraulic tools we have today? For example, the Millau Viaduct in south France (picture on page 7), designed by the English architect Lord Norman Foster is one of the highest bridges in the world with a height of 343 meters (1,125 ft.). The construct con-sists of seven piers and high masts, as well as, a very light bridge deck.

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Cooperating with the building com-pany Eiffage, Enerpac played an instru-mental role in this ambitious infrastruc-tural project. The experts of Enerpac provided the engineering knowledge and die hydraulic solutions to lift the temporary masts, which are neces-sary for additional stability in order for the steel deck with a length of 2.5 kilo-meters to be pushed forward. In 2004, after 32 months of construction time, the final process step was carried out by the employees with a hydraulic feed. In this step, the last remaining gap of the Viaduct was closed. Enerpac, which started out as a simple supplier of hydraulic elements, became a co-designer of the project planning.

Starting signal for Integrated SolutionsThe success of this project was the starting signal for Enerpac’s new busi-ness division “Integrated Solutions” which targets the heavy lifting segment. For ten years, the company has been offering high pressure system solutions that meet the customer demand for safer, precise movement and position-ing control. In addition to these prod-ucts, customers benefit from the com-petence in heavy lifting that has been growing for more than half a century.

Throughout the development process, Enerpac always works in close coop-eration with the customer. Technical drawings explain the concept to the customers before the solution is pro-duced. Afterwards, Enerpac offers sup-port and special training programs for the customers – for error-free and effi-cient usage.

Growing demands – increasing businessSince the Millau Viaduct project, the business area Integrated Solutions has grown constantly. Customers are from different industries, such as mining, skyscraper construction or petrochemi-cal (image on the left). Development of competencies is the result of every new tasks – engineering expertise is a trait that is indispensable, especially on huge

infrastructural projects. Quality, safety and reliability are the fundamental char-acteristics Enerpac stands for.

With the right conditions and the right partner, the work in ancient Rome would have been easier back then. The high complexity of today’s projects requires the fine-tuned cooperation of specialized companies, to guarantee short construction periods, operational safety and a high-class result. One of these companies is Enerpac – no mat-ter how big the task is.

Enerpac - Facts and Figures Enerpac is one of the worldwide leaders in the area of high-pres-sure and hydraulic tools. The his-tory of Enerpac dates back to 1910, when the original company produced water pumps for the Ford’s legendary ‘Model T’ motor car.

More than 50 years ago, an Industrial Products Division was formed and along with it, the new brand name Enerpac. Today, Enerpac operates from 28 facilities in 22 countries with over 1,000 employees. Hydrau-lic tools, from small cylinders up to computer based lifting and positioning systems are offered. Additionally, Integrated Solu-tions for large infrastructural proj-ects have been incorporated into the portfolio. Repair and mainte-nance work of existing buildings are also part of the service.

Enerpac is a division of Actu-ant Corporation, a $ 1.6 billion diversified global manufactur-ing company, headquartered in Menomonee Falls, Wisconsin, USA.

This free-standing gantry solution can lift up to 1,400-ton loads as high as 75 meters with minimized footprint. It is suitbale for a variety of applications, such as the erec-tion of reactor vessels in petrochemical plants, assembly of jackets for offshore wind mill applications and lifting shipyard cranes. Compared to the larger ringer cranes, the ESET offers faster mobilization time and lower transportation costs.

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CUSTOMER PORTRAIT

IONIT OX® and the Gondolas of VeniceInterview with Managing Director Jeroen Naalden, and Project Coordinator Richard Wolters, of Enerpac Integrated Solutions.

LAYER: Mr. Naalden, Mr. Wolters you are using surface solutions for special components of your hydraulic prod-ucts. What are your benefits? How did you become aware specifically of Sulzer Metco Thin Film?

Jeroen Naalden: Surface solutions increase the lifetime of our products

and open up new application areas. We can enhance the efficiency of our solutions and offer them for application areas where we could not operate with-out surface treatments.

Richard Wolters: Some years ago, Enerpac realized special cylinders for a sub-sea project. To fulfil the requirements

of operating in maritime environment, the cylinders have to resist corrosion due to the aggressive, salty seawater. Regardless of how good a product is technically elaborated and constructed, in such an environment the protection against outside impacts is decisive. The engineers have opted for the IONIT OX® process at that time. In the meantime, it has proven successful in practice and we found new areas where the applica-tion is useful.

LAYER: Could you tell us about a proj-ect in the past were you have managed similar challenges with the help of Sulzer Metco Thin Film solutions?

Richard Wolters: An impressive exam-ple is the flood prevention in Venice. Caissons have been installed on the sea ground. Hydraulic cylinders positioning the caissons are standing permanently in the saltwater and therefore are vulner-able for corrosion. Here IONIT OX® was also used. The caissons in this installa-tion are the baseplate for barriers of a water-retaining structure in the lagoon access.

The barriers protect Venice in case of floodwater. They are pulled up and hold back the water like a dam. In total 78 of these barriers are installed in the cais-sons. They are fully filled with water in their passive state. If the water level rises to a certain height, compressed air presses out the water inside the barriers and they rise up. This way they can com-pensate an increased water level of up to two meters – and the gondoliers can do their job as usual.

LAYER: To what extent did you benefit from the consulting of the Sulzer Metco Thin Film experts for this project?

Jeroen Naalden: We have excellently used the know-how of our partner Sulzer Metco Thin Film. The consulting started directly after the requirements for the projects had been finalized. We had to specially treat the cylinders due to the salt water to improve their durability. Our partner helped us at the project start and

Because of the maritime environment, the corrosion protection of IONIT OX® is very valuable to the Enerpac components.

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recommended an IONIT OX® treatment. We both were involved with our exper-tise for a common solution.

LAYER: For which future projects will you use such or other surface solutions?

Jeroen Naalden: Besides our current or just completed projects, like the 80 meters high high-speed installation gantry crane ESET, cooperation is also planned for future orders. Sulzer Metco Thin Film has suitable solutions to meet our versatile

requirements. For us, the benefit to our customer is critical in the end. To have a supplier that supports us is worth a lot.

LAYER: Mr. Naalden, Mr. Wolters thank you for the interview.

Richard Wolters (left) and Jeroen Naalden in the LAYER interview.

The Millau-Viaduct was the starting point for Enerpac‘s “Integrated Solutions”.

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