TCE RoundtableWichita, KS

September 19, 2017

TCE• Carcinogen to humans by all routes of exposure

• Toxic; clear, colorless, sweet odor & evaporates quickly

• Estimated 250 millions pounds/year

• Intermediate for refrigerants (84% use)

• Solvent for metals degreasing (15% use)Source: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-trichloroethylene-tce

• Halogenated, aliphatic organic compound

• “Universal” degreaser

• Microorganisms can break it downSource: https://www.epa.gov/remedytech/tce-removal-contaminated-soil-and-ground-water

Physical/Chemical Properties

• VOC• moderate boiling point, 87.2°C

• high vapor pressure, 73.46 mm Hg at 25 °C

• Moderately water soluble (1.280 g/L at 25 °C)

• Denser than water, 1.46 g/cm3 at 20°C• About 12.11 lbs/gal at 70°F

TCE Regulatory ContextDue to its serious adverse effects on human and environmental health, TCE is subject to many regulations at the state and federal levels.

• Federal Environmental Regulations

• EPCRA: Reportable under Toxic Release Inventory, Subject to Tier II reporting requirements; Reportable Quantity = 100 lbs.

• CAA: Hazardous air pollutant; Vapor degreasers must meet the national emissions standards for halogenated solvents.

• RCRA: Land disposal of TCE and all chlorinated solvents banned. Waste must be destroyed in incinerators or cement kilns. Characteristic Toxic Hazardous Waste: TCLP Threshold = 0.5 mg/L. Listed Hazardous Waste: U228, F001, F002, F024, F025, K018, K019, K020.

• CWA - Water Quality Criteria: Based on fish/shellfish and water consumption = 2.5 μg/L; based on fish/shellfish consumption only = 30 μg/L.

• SDWA: The maximum contaminant limit set for drinking water is 0.005 mg/L.• Source: http://www.turi.org/TURI_Publications/TURI_Chemical_Fact_Sheets/Trichloroethylene_TCE_Fact_Sheet/TCE_Facts/Regulatory_Context

Wichita shallow groundwater contamination sitesSource: City of Wichita, NIC

Wichita deep groundwater contamination sitesSource: KDHE

Trichloroethylene and Tetrachloroethylene emitted to air in Wichita, KS 2015

REGULATORY REQUIREMENTS

FOR SOLVENTS

SOLVENT MACT STANDARD USES

TCE/PCE 40 CFR PART 63 SUBPART T

“National Emission Standards for

Halogenated Solvent Cleaning”

CLEANING

DEGREASING

AQUEOUS

HYDROCARBON BASED

HAP/VOC

40 CFR PART 63 SUBPART GG

“National Emission Standards for

Aerospace Manufacturing and

Rework Facilities

CLEANING

PRIMING

PAINTING

ONCE IN ALWAYS IN

EPA ActionsSpecifically requested comments, information, and data to assist in evaluating alternatives in vapor degreasinghttps://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-trichloroethylene-tce

• January 19, 2017Proposed ban in commercial vapor degreasing due to identified health risks (2014)Section 6(a) of the Toxic Substances Control Act, as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century ActComment period extended to May 19, 2017

• December 7, 2016Proposed ban on certain use due to health risks from aerosol degreasing and and for spot cleaning in dry cleaning facilitiesComment period to closed March 16, 2017

• November 29, 2016Included TCE on the list of the first 10 chemicals to be evaluated for risk under amended TSCA.Will allow EPA evaluation of the other remaining uses of the chemical.

• April 6, 2016 Issued a final Significant New Use Rule to require notification before certain new consumer uses begin or resumeFollowed July 2015 agreement with PLZ Aeroscience, of Addison, IL, to voluntarily phase-out TCE in aerosol arts and crafts spray fixative

• July 29-30, 2014 Experts workshop on TCE alternatives and risk reduction approaches

• In 2012, EPA identified TCE as one of its Work Plan Chemicals for assessment.

Solvent CleaningAre there safer chemical alternatives or technologies available to use instead of TCE as a vapor degreaser?

• Alternatives to TCE with similar performance characteristics are available• Different solvents

• Aqueous cleaners

• Different techniques (e.g ultrasonic)

• Equipment substitution.

• Most vapor degreasing machines can be used with other solvents, either as-is, or with minor modifications.However, there are significant hazards associated with these “drop-in alternatives.”

Source: https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-trichloroethylene-tce#q10

Case Studies• Shick

• “Wash boxes”

• Lightolier• Captures savings related to dedicated TCE labor, plus

• VH Blackinton & Co.• Aqueous

• Lockheed Martin Defense Systems• Turned into a middle school education outreach

Source: https://www.epa.gov/p2/case-studies-safer-alternatives-solvent-degreasing-applications

Newer alternatives

• Potential alternative research• EnTron – Aero: http://relspec.com/products/entron-aero/entron-aero-

overview.html (Potential nPB based solvent and no longer recommended)

• Novec fluids: https://www.3m.com/3M/en_US/novec-us/applications/solvent-cleaning-vapor-degreasing/?WT.mc_id=EEBG-EMSD-en_US-PP-adwords-solvent_cleaning_2017-001&src=PaidSearch• Site provides full comparison with aqueous cleaning

PPI Interns

Possible option to assist with on-site research

Since 2006, intern projects have identified the following potential savings:

• 73 million kWh of electricity and natural gas

• 310 million gallons of water

• 15,000 tons of solid and hazardous waste

• $9.5 million in operating/disposal costs

• 40,000 metric tons of CO2 equivalent

Needs, Interests?

• Next steps?

• Do industries want to learn more?