 

### Over the last few decades, California has adopted policies for restricting, 

### eliminating use of TCE  

### Safer viable and cost effective alternatives are available and used  

### Based on California’s actions and experience, EPA can phase out or restrict TCE use in the three applications 

### Intermediate in production of refrigerants  

### Vapor degreasing of fabricated metal 

### parts  

### Cold cleaning › Equipment › Handwipe › Spotting chemicals  

### Aerosol cleaning 

### No flash point  

### Fairly high boiling point  

### Aggressive solvent  

### Suitable for removing heavy oil, grease  

### High evaporation rate 

### Solvent heated to its boiling point in a vapor degreaser › stainless steel tank with a heater in the bottom and cooling coils around the inside perimeter › Liquid and vapor zone  

### Parts lowered into degreaser in basket › Hot solvent in vapor zone condenses on part carrying contaminants into liquid  

### Many types of vapor degreasers › Conveyorized › Batch open top › Airless/Airtight 

### Open tank or remote reservoir or flushing operation where solvent is at room 

### temperature  

### Small squeeze bottles or table containers › Solvent applied with rags or wipes  

### Exposure to workers higher than for vapor degreasers › Solvent not contained by cooling coils 

### Carrier solvent or cleaning solvent  

### Used in aerosol cans, generally with a 

### propellant  

### Exposure is higher than for other applications › TCE is in breathing zone Identify problem where safer alternative is needed in industrial or consumer product application  Work with several companies using the operation  Identify, develop, test and demonstrate alternatives that perform well and are cost effective  Work with regulatory agency to adopt/implement regulation  Anticipate what alternatives may be used and try to prevent adoption of regrettable substitutes  IRTA’s work has led to reduction in use of hazardous substances in California by more than 100 tons per day 

### TCE used extensively in vapor degreasing and cold cleaning in the 1960s and 70s  

### TCE designated as photochemically reactive (VOC)and carcinogen in early 70s  

### Most users in California used TCA or PERC  

### In 1990s, EPA adopted the NESHAP and production of TCA and CFC

- 113 was banned because of ozone depletion › Thousands of vapor degreasers using TCA Most users converted to water

- based cleaners and systems › Water

- based cleaning evolved and improved  Some users converted to regrettable substitutes › NPB began to be used  Local air districts adopted increasingly stringent VOC regulations on vapor degreasing and cold cleaning in 1990s  After 2000, local air districts and CARB continued to adopt VOC regulations and began banning the use of chlorinated solvents (PERC, TCE, methylene chloride) in many applications 

### SCAQMD regulations set 25 gram per liter VOC limit for open top vapor degreasers and cold cleaning units › Must use airless/airtight equipment with TCE › May be as few as 25 TCE degreasers statewide › Eliminated use of NPB  

### CARB banned use of chlorinated solvents in automotive aerosol cleaners › Initial conversion to hexane, other VOC solvents › CARB set low VOC limit so TCE, hexane cannot be used 

### IRTA worked with users to find alternatives for hundreds of vapor 

### degreasing applications › Virtually all converted to water

- based cleaning systems  

### Case study examples › Nameplate company (conveyor spray) › Contract cleaning company (ultrasonic) › Aerospace subcontractor (spray cabinet) 

### IRTA conducted EPA sponsored project to find alternatives to VOC solvents in 

### repair and maintenance cleaning › Used by auto repair and industrial facilities › Some used TCE › Remote reservoirs, batch systems  

### Worked with many facilities of both types › Found best way to optimize use of water

based cleaners for the application 

### SCAQMD passed regulation that became effective in 1999 › 40,000 operations converted › Reduced VOC emissions by 18 tons per day  

### Over next several years, other local air districts in California adopted similar 

### regulations › VOC reduction in state of 36 tons per day  

### Water

- based cleaners are now 

### institutionalized in this use 

### Case study examples › Aerospace subcontractor (water

- based cleaning) › Auto repair facilities (water

- based cleaning) › Silicone implantable medical devices (eliminated contaminants ) 

### IRTA conducted EPA/HESIS/CARB projects to find alternatives to VOC and 

### chlorinated solvents in automotive aerosol cleaning applications › Used by auto repair, industrial facilities and consumers › Included brake cleaners, general purpose degreasers, carburetor and fuel injection system cleaners, engine degreasers › Worked with about 25 auto repair facilities and some consumers 

### Developed and tested alternatives › Water

- based, acetone, soy  

### IRTA project led to CARB ban of chlorinated solvents and VOC content restrictions › Eliminated use of TCE and some regrettable substitutes › Reduced VOC emissions by 10 tons per day  

### CARB restricts TCE use in other aerosol applications › IRTA worked on alternatives in some other applications 

### Case study examples › Automotive dealership (water

- based brake cleaning systems) › Auto repair facility (water

- based spray bottles) › Energized electrical equipment cleaning (carbon dioxide pellet blasting/snow) 

### TCE poses high risk to workers and community members in vapor 

### degreasing, cold cleaning, aerosol applications  

### Alternatives available for all applications › Demonstrated in the California experience  

### Vapor degreasing › Safer alternatives have been demonstrated › EPA should ban TCE or restrict its use to airless/airtight systems 

### Cold cleaning applications › Dow Chemical, manufacturer of TCE, no longer recommends its use in cold cleaning › Cannot control exposure › Safer alternatives have been demonstrated › EPA should ban it  

### Aerosol applications › Can reformulate with safer alternatives in all cases › EPA should ban it

### Dr. Katy Wolf Institute for Research and Technical Assistance (IRTA) 8579 Skyline Drive Los Angeles, CA 90046 Phone (323)656

- 1121 Cell (818) 371

-9260 

### Fax (818) 656

- 1122 kwolf.irta@earthlink.net www.irta.us