The

Alternative

IRTA Newsletter Volume XVIII Number 3 Summer 2009

Institute for Research and Technical Assistance

Stuart Pressman of Economy Cleaners in Sand

City, California is a third generation dry cleaner

who has worked in the industry for more than

40 years. Last June, he decided to use npropyl bromide (nPB) in one of his two PERC

machines. The supplier designated the cleaner as a California Beta Testing Site. The

California Air Resources Board (CARB) adopted a regulation that will phase out the use of

perchloroethylene (PERC) dry cleaning by

2023. To comply with this regulation, cleaners

must convert to alternative processes. All of

the alternatives to PERC require different

equipment. To avoid making this purchase, Mr.

Pressman decided to use n-propyl bromide.

The supplier indicated that he could use it in his

existing PERC machine.

Mr. Pressman used the nPB, which is

sold under the tradename of DrySolv, for about

six months and was pleased with its aggressive

cleaning capability. Within about six months, in

December, he began to notice a problem. On

January 4, 2009, he asked for help from the

suppliers of the solvent but the supplier put him

off month after month and never actually visited the facility.

nPB must be used with stabilizers

because the chemical is unstable when water

is present. nPB reacts with the water to form

hydrogen bromide, a very corrosive and toxic

gas. The stabilizer takes up the water and prevents the nPB from "going acid." Several companies using the solvent have depleted their

n-Propyl Bromide Destroys Equipment in 

Dry Cleaning Plant

(see n-Propyl Bromide page 6)

IRTA to Hold Laser Stripping Conference With Edison,

Laser Strip and CARB

IRTA is planning a conference for interested

potential users of a laser technology that can

be used for stripping paint from various surfaces. The conference will be co-sponsored by

Southern California Edison, Laser Strip, the

company that owns the rights to a portable

laser stripping prototype, and the California Air

Resources Board (CARB). It will be held on

October 21 at Edison's Customer Technology

Applications Center (CTAC) in Irwindale, CA.

IRTA is conducting a project, sponsored

by CARB, in partnership with Edison and Laser

Strip, to test and demonstrate a small portable

hand-held laser stripping prototype (see article

in last issue of The Alternative). The partners

have conducted four demonstrations of the

technology that is designed to substitute for

methylene chloride and VOC chemical strippers and various media stripping systems like

sand, plastic media or garnet blasting. The

demonstrations involved stripping part of a

water storage tank at the San Bernardino airport, stripping portions of aircraft parts, stripping portions of Navy ship parts and panels

containing ship hull paint and stripping ground

vehicles at the Barstow Marine Base. 

IRTA is conducting cost analysis of the

technologies used currently in the four stripping

applications and is comparing the cost to the

cost of using a laser stripping device for the

stripping. Laser Strip is currently building a

(see Laser Conference page 5)
Institute for Research and Technical Assistance Page 2

Small Business Corner

Illustration by Todd Schmid

BAAQMD Considering Earlier

Phaseout of PERC in Dry Cleaning

The Bay Area Air Quality

Management District (BAAQMD) held

a workshop on June 10 to discuss options

for accelerating the phaseout of perchloroethylene (PERC) in dry cleaning. The

California Air Resources Board (CARB)

adopted a regulation on PERC dry cleaning

that calls for a complete phaseout of PERC

dry cleaning in 2023. The BAAQMD recently adopted a regulation, Regulation 11, Rule

16 "Perchloroethylene and Synthetic

Solvent Dry Cleaning Operations," that

implements the CARB regulation provisions

in the Bay Area. 

The current BAAQMD regulation

requires cleaners to adopt alternatives to

PERC when their machine is 15 years of

age or older, beginning in July 2010. When

the Bay Area Board adopted this regulation,

the Board asked the staff to evaluate

options to phase out PERC earlier. At the

June 10 workshop, the staff presented three

alternative options. Instead of waiting until

the machine is 15 years old, the options

would phase out PERC when the equipment

is eight years old, 10 years old or 12 years

old. These would lead to PERC phaseout

dates of July 1, 2016, 2018 or 2020 respectively. The BAAQMD is planning to present

the three options to their Board in the future

and the regulation will be amended.

The South Coast Air Quality

Management District (SCAQMD) adopted a

regulation several years ago with a final

phaseout date for PERC of December 31,

2020. The Bay Area proposed acceleration

would phase out PERC at least six months

sooner than the SCAQMD regulation,

depending on which of the equipment ages

is adopted. 

The SCAQMD regulation is based on

a different metric than the CARB and

BAAQMD regulations. SCAQMD adopted a

risk based method of determining when a

cleaner must phase out their PERC equipment. SCAQMD has asked CARB to deem

their regulation equivalent to the state regulation because of SCAQMD's earlier phaseout date of 2020. The District must obtain

equivalency or they will have to modify their

regulation. At this stage, since CARB has

not ruled the SCAQMD regulation is equivalent, SCAQMD will likely have to modify their

regulation to make it consistent with the

state regulation. 

The best thing for cleaners to do in

any location is to convert to a non-PERC

alternative. One alternative, n-propyl bromide (nPB), is not a good choice (see article

in this issue of the newsletter) because of

toxicity and technical problems in dry cleaning equipment. Another alternative,

GreenEarth, has caused cancer in laboratory animals so it is not a good alternative

either. For more information on the alternatives, access IRTA's website at www.irta.us.

The website includes several reports on dry

cleaning alternatives and spotting chemical

alternatives.

For more information on the

BAAQMD regulation, contact Marc Nash at

(415) 749-4677. To discuss PERC dry

cleaning and spotting chemical alternatives, contact Katy Wolf at IRTA at

(818) 244-0300.
Institute for Research and Technical Assistance Page 3

IRTA Investigates Dry Ice Blasting 

Technology for Cleaning Insulators

IRTA is conducting a project, sponsored by

EPA Region IX, to identify, develop, test and

demonstrate safer alternative methods for

cleaning energized electrical equipment. For

many years, companies used aerosol cleaners

or larger bulk cleaners for this purpose. Many

of these cleaners contribute to stratospheric

ozone depletion and/or global warming.

Supplies of one of these chemicals,

HCFC141b, are almost depleted and utilities

and industrial firms that have their own generating capability must find alternatives. 

It is challenging to find suitable cleaning

alternatives for energized equipment, which is

equipment through which electricity is flowing.

The alternatives must not be conductive and

they must not have a flash point. One technology IRTA investigated for cleaning energized

insulators is dry ice blasting. Insulators can

become very dirty and often they cannot be

cleaned adequately with plain deionized water,

another technology that can be used for cleaning energized equipment. The dry ice technology uses carbon dioxide pellets to blast the

contamination from the surface of the insulators. The carbon dioxide sublimes or forms a

gas and there is no residue from the operation

apart from the dirt that has been removed from

the insulators. A picture of a supplier demonstrating the use of the pellet blasting for cleaning an insulator is shown below.

The supplier has developed a portable

system for cleaning contaminated surfaces.

The user fills it with dry ice and directs the

spray to the contaminated part with a wand.

The system is compact and fits easily in the

back of a pickup truck. The technology is also

a good option for cleaning other surfaces

where blasting with

media of various types

is currently used.

IRTA is also investigating corn cob blasting for cleaning insulators as part of the EPA

project. The corn cobs

are directed to the part

with a wand and the

corn cobs absorb the

contamination. 

IRTA is currently

performing cost analysis of various methods

of cleaning energized

electrical equipment.

The final project report

should be completed

in the next few

months.

For more information on energized electrical equipment cleaning, contact Katy Wolf

at IRTA at (818) 244-

0300.
Institute for Research and Technical Assistance Page 4

DTSC Begins Developing Green Chemistry Regulations

On September 29, 2008, Governor

Schwarzenegger signed AB 1879 which is

designed to implement a Green Chemistry

Program and a related bill SB 509. AB 1879

establishes authority for Cal/EPA's Department

of Toxic Substances Control (DTSC) to develop

regulations that create a process for identifying

and prioritizing chemicals of concern and to

create methods for analyzing alternatives to

existing hazardous chemicals. It allows DTSC

to take various actions following an assessment that range from no action at all to restrictions or bans. AB 1879 also establishes a

Green Ribbon Science Panel made up of

experts to provide advice on scientific matters,

chemical policy recommendations and implementation strategies. SB 509 requires that an

online Toxics Information Clearinghouse be

established to provide public access to information on the toxicity of chemicals.

DTSC convened the first meeting of the

Green Ribbon Science Panel and has held

several Green Chemistry regulations workshops throughout the state. Two workshops on

safer alternatives regulations are planned for

July or August in Los Angeles and Berkeley.

On April 21st, DTSC issued a Draft

Straw Proposal which reflects the staff's thinking. It is intended to be a plain english outline

of a "Safer Alternatives for Consumer

Products" rule. DTSC is developing a "candidate" list of chemicals of concern. This list will

be used and, based on criteria laid out in the

regulation, a prioritized list of chemicals will be

developed. An alternatives analysis will be

required for consumer products that contain

one or more high priority chemicals of concern.

This analysis will be conducted by manufacturers, importers, suppliers or retailers and will be

submitted to DTSC. The analysis will consider

health impacts, ecological impacts and lifecycle

impacts of the chemicals and the identified

alternatives. At that stage, DTSC may require

additional information, labeling, restrictions,

prohibitions or engineered safety measures if

the company decides to market the chemical in

the consumer product.

Presently, it is not clear how DTSC is

defining consumer products. Some consumer

products, like toys, more heavily expose children to possible harm. Other consumer products, like products used widely in industry and

by consumers, expose thousands of people to

potentially toxic ingredients.

IRTA has conducted projects in three

major areas where consumer products are

used. First, IRTA worked with the Hazard

Evaluation System And Information Service

(HESIS) and the California Air Resources

Board (CARB) to find, develop, test and

demonstrate alternative low-VOC, low toxicity

alternatives to automotive aerosol cleaners.

These cleaners are used by auto repair facilities and they are also used by consumers who

purchase them in stores like Pep Boys.

Solvents used in these cleaners included

toluene, xylene, hexane and MEK, which are

toxic. Alternatives that were demonstrated

included water-based, soy based and acetone

based cleaners that were much safer. CARB

passed a regulation that reduced the use of

VOC solvents by 10 tons per day in California.

Suppliers are converting to low-VOC, safer

alternatives. 

Second, IRTA worked with DTSC on a

project designed to develop, test and demonstrate alternatives to methylene chloride consumer product paint strippers. Methylene chloride is a carcinogen and paint strippers based

on the chemical are sold in hardware and

home improvement stores. The strippers are

used by businesses and consumers. IRTA

tested alternatives based on benzyl alcohol

which is less toxic than methylene chloride.

CARB is planning to develop a regulation on

this category of consumer products.

Third, IRTA worked with DTSC on a projuct designed to develop, test and demonstrate

safer, low-VOC alternatives to paint and lacquer thinner. These products contain various

VOC and toxic solvents including toluene,

xylene, mineral spirits and MEK and they are

sold in hardware and home improvement

stores. They are used by consumers, contractors and other businesses. The South Coast

(see Green Chemistry Regulations page 6)
Institute for Research and Technical Assistance Page 5

more powerful portable device and a much

larger stationary stripping system. The results

of the cost analysis and the new devices

should be available for the conference. The

small and more powerful portable devices will

be on display for demonstrations at the conference.

Conference attendees will include government agency representatives and potential

military and commercial users of the laser stripping device. Breakfast and lunch will be provided. 

For more information or to make

arrangements to attend the conference, contact Katy Wolf at IRTA at (818) 244-0300.

Laser Conference 

(Continued from front Page)

District Moves Forward with Regulation on Lubricants

and Metal Working Fluids

On March 6, the South Coast Air Quality

Management District (SCAQMD) adopted a

new regulation that restricts the VOC limits of

vanishing oils and rust inhibitors. Rule 1144

"Vanishing Oils and Rust Inhibitors," applies to

industrial facilities which use vanishing oils and

rust inhibitors that come into direct contact with

products and parts during manufacture and

assembly. It also affects suppliers of these

materials.

The rule specifies that on January 1,

2010, the VOC content of vanishing oil must be

50 grams per liter or less. On that date, rust

inhibitors must have a VOC content of 300

grams per liter or less. By January 1, 2012,

rust inhibitors must have a much lower VOC

content of 50 grams per liter or less. The rule

also contains a prohibition of sale for these

products. The vanishing oils and rust inhibitors

regulated in the rule are essentially solvents

with a very high VOC content. The provisions

will phase out these high VOC solvents over

the next few years. The test method used to

determine the VOC content of these materials

is EPA Test Method 24 which is appropriate for

high VOC materials.

The District did not regulate the VOC

content of direct contact lubricants or metal

working fluids in the rule because some of

these materials have a lower VOC content

and/or are water-based. The District has historically used a test method called SCAQMD

Method 313L, a method based on gas chromatography/flame ionization detection

(GC/FID), which seeks to accomodate lower

vapor pressure and water containing products.

This method has been used for several years

in the Clean Air Solvent Certification Program

at the District. The industry asked the District

to consider other VOC content test methods

and the District is currently working with the

industry on this evaluation.

Over the next few months, the District

and the industry plan to conduct Method 313L

robustness testing with eight different laboratories. Round robin testing with several labs will

be conducted for Method 313L after the robustness testing is completed. The workgroup will

also conduct round robin testing of an alternative method called Thermogravimetric Analysis

or TGA. All of the testing should be completed

by August. In September, the District will report

the results of the test method analysis to their

Governing Board.

Once a test method or methods are

accepted, the VOC content of several different

types of products will be determined. This will

allow the District to estimate the inventory

emissions of direct contact lubricants and

metal working fluids in the Basin. At that stage,

the District plans to begin a rulemaking to

cover the new categories and extend the prohibition of sale and labeling in Rule 1144 to the

new product types.

For information on the regulation, call

Mike Morris at SCAQMD at (909) 396-3282
stabilizer and the nPB has gone acid with very

bad results. The dry cleaning process has a lot

of water in it and, as IRTA has indicated in

many earlier newsletter articles, it is very likely

that any cleaner using the solvent in an existing PERC machine would see it go acid eventually.

The DrySolv in Mr. Pressman's machine

went acid and a lab test verified it was nPB. It

created a cloud of acid which was very corrosive. The acid ate a hole in his boiler, completely destroyed the PERC machine and also

corroded a laundry dryer in the facility beyond

repair. Much of the facility's pressing equipment is rusted out. Mr. Pressman

was present in the facility during

the acid formation and may have

impaired health as a result.

Mr. Pressman is very

unhappy with the results of his

conversion to nPB and would

caution other cleaners about

adopting the solvent. "No cleaner

should use this solvent," says Mr.

pressman. Since the incident, Mr.

Pressman has called other cleaners all over the country who are

using the solvent. The other

cleaners he has spoken to have

experienced similar problems.

n-Propyl Bromide 

(Continued from front Page)

Institute for Research and Technical Assistance Page 6

Air Quality Management District (SCAQMD)

recently passed a regulation for these products

that will reduce VOC emissions (and use) of

these materials by almost 10 tons per day.

CARB is developing a regulation scheduled for

adoption in September for these products.

It is not clear how the DTSC green

chemistry regulations will work. It is a poor

choice to require the suppliers of prioritized

chemicals to perform complex analyses of

alternatives for or in the products they market.

In the IRTA projects noted above, the suppliers

would not or could not identify lower VOC, low

toxicity alternatives until after a regulation was

adopted requiring them to find the alternatives.

Before the regulation could be adopted, an

independent organization, IRTA, developed

and demonstrated alternatives. This helps the

regulatory agencies see that alternatives are

viable so the regulation can be adopted. It may

be better for DTSC to rely on independent

organizations to find and/or develop alternatives and perform the alternatives analysis in

the green chemistry program. 

For information on DTSC's Green

Chemistry efforts, access DTSC's website at

www.dtsc.ca.gov.

Green Chemistry Regulations 

(Continued from Page4)

(see n-Propyl Bromide page 7)
Institute for Research and Technical Assistance Page 7

According to Mr. Pressman,

"DrySolv is not a drop-in solvent. In any PERC machine, it

is only a matter of time before

the solvent causes a problem."

The supplier has so far

refused to pay for the damage

in the shop even though it is

obvious the solvent caused

the problem. It will be very

costly for Mr. Pressman to

replace the equipment and his

health could suffer in the

future.

Apart from being unstable in the presence of water,

nPB is a reproductive toxin

and it also causes nerve damage. It causes sterility in both

male and female test animals

and harms the developing

fetus when tested in pregnant

animals. It damages the nervous system and can cause

weakness, pain, numbness

and paralysis. nPB is listed on

Proposition 65 but is not classified by CARB as a Toxic Air

Contaminant or by EPA as a

Hazardous Air Pollutant.

Unless nPB is more heavily

regulated, it is likely that other

dry cleaners will convert to the

solvent to avoid purchasing

new equipment for use with

the other alternatives. Next

July, cleaners must start

replacing their PERC

machines as soon as they are

15 years old so it is a critical

time to find a way to more

stringently control the use of

nPB.

In the last issue of this

newsletter, IRTA included an

article about Cal/OSHA's proposal to establish a

Permissible Exposure Limit

(PEL) for nPB in California.

The proposed limit is 5 ppm. If

this limit is adopted, cleaners

would not be able to meet it,

even in secondary controlled

PERC machines.

For more information

on nPB, contact Katy Wolf at

IRTA at (818) 244-0300. Mr.

Pressman is available to talk

to dry cleaners using DrySolv

about what to look for in the

plant to determine if the solvent is causing problems.

Please contact Stuart

Pressman at (831) 394-3161.

“nPB causes health problems and it destoys all the

equipment, but it cleans well!”
nstitute for Research and Technical Assistance I

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industry and government towards a

common goal -- implementing

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allow businesses to remain

competitive while protecting and

improving our environment. IRTA

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Institute for Research and 

Technical Assistance

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website: www.irta.us

In This Issue

n-Propyl Bromide Destroys Equipment

1 in Dry Cleaning Plant......................................

IRTA to Hold Laser Stripping Conference

..............1 With Edison, Laser Strip, and CARB

BAAQMD Small Business Corner: 

Considering Earlier Phaseout of 

PERC in Dry Cleaning....................................2

IRTA Investigates Dry Ice Blasting

Technology for Cleaning Insulators ................3

DTSC Begins Developing 

Green Chemistry Regulations ........................4

District Moves Forward with Regulation

on Lubricants and Metal Working Fluids ........5

Calendar .........................................................8

July 15-18

AWFS Fair, Las Vegas Convention Center. For

Information, access www.awfsfair.org

September 21-27

Pollution Prevention Week 2009. Various state and

local programs. 

October 21

A Portable Hand-Held Laser Stripping Technology Conference, 

Southern California Edison’s CTAC Facility, Irwindale, CA. For

Information, call Katy Wolf at IRTA at 818-244-0300

October 28-29

Western U.S. Sustainability & Pollution Prevention Conference,

Bahia Resort Hotel, San Diego, CA. For information, acces

www.wsppn.org