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SEPA

United States

Environmental Protection Agency

EPA Document #740R18008
February 21,2020
Office of Chemical Safety and
Pollution Prevention

Risk Evaluation for
T richloroethylene
CASRN: 79-01-6

CI. H

CI CI

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14 TABLE OF CONTENTS

15	ACKNOWLEDGEMENTS	23

16	ABBREVIATIONS	24

17	EXECUTIVE SUMMARY	28

18	1 INTRODUCTION	39

19	1.1 Physical and Chemical Properties	41

20	1.2 Uses and Production Volume	42

21	1.2.1 Data and Information Sources	42

22	1.2,2 Domestic Manufacture of Trichloroethylene	42

23	1.3 Regulatory and Assessment History	44

24	1.4 Scope of the Evaluation	46

25	1.4.1 Conditions of Use Included in the Risk Evaluation	46

26	1.4.2 Conceptual Models	56

27	1.5 Systematic Review	60

28	1.5.1 Data and Information Collection	60

29	1.5.2 Data Evaluation	66

30	1.5.3 Data Integration	67

31	2 EXPOSURES	68

32	2.1 Fate and Transport	68

33	2.1.1 Fate and Transport Approach and Methodology	69

34	2.1.2 Summary of Fate and Transport	69

35	2.1,3 Assumptions and Key Sources of Uncertainty for Fate and Transport	71

36	2.2 Environmental Exposures	71

37	2.2.1 Environmental Exposures Overview	71

38	2.2.2 Environmental Releases to Water	72

39	2.2.2.1 Results for Daily Release Estimate	72

40	2.2,2,2 Approach and Methodology	74

41	2,2.2.2.1 Water Release Estimates	74

42	2.2,2,2.2 Estimates of Number of Facilities	74

43	2,2.2.2,3 Estimates of Release Days	76

44	2,2.2.3 Assumptions and Key Sources of Uncertainty for Environmental Releases	77

45	2.2.2.3.1 Summary of Overall Confidence in Release Estimates	78

46	2.2.3 Aquatic Exposure Modeling Approach	84

47	2.2.3.1 Exposure and Fate Assessment Screening (E-FAST) Tool 2014 Inputs	85

48	2.2.3.2 E-FAST 2014 Equations	86

49	2.2.3,3 E-FAST 2014 Outputs	87

50	2.2.4 Surface Water Monitoring Data Gathering Approach	88

51	2.2.4.1 Method for Systematic Review of Surface Water Monitoring Data	88

52	2.2.4,2 Method for Obtaining Surface Water Monitoring Data from WQX/WQP	88

53	2.2,5 Geospatial Analysis Approach	89

54	2.2.6 Environmental Exposure Results	90

55	2.2.6.1 Terrestrial Environmental Exposures	90

56	2.2.6,2 Aquatic Environmental Exposures	91

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2.2.6.2.1	Predicted Surface Water Concentrations: E-FAST 2014 Modeling

2.2.6.2.2	Monitored Surface Water Concentrations	

2.2.6.2.3 Geospatial Analysis Comparing Predicted and Measured Surface Water
Concentrations	

2.2.6.3	Assumptions and Key Sources of Uncertainty for Environmental Exposures..

2.2.6.4	Confidence in Aquatic Exposure Scenarios	

2.3 Human Exposures	

2,3.1 Occupational Exposures	

2.3.1.1

2.3.1.2
2.3

2.3

2.3

2.3

2.3

2.3

2.3

2.3.1.3
2.3

2.3
2.3
2.3
2.3

Results for Occupational Assessment	

Approach and Methodology	

1.2.1	General	

1.2.2	Inhalation Exposure Monitoring Data	

1.2.3	Inhalation Exposure Modeling	

1.2.4	Acute and Chronic Inhalation Exposure Estimates	

2.5	Dermal Exposure Modeling	

2.6	Consideration of Engineering Controls and Personal Protective Equipment

2.7	Number of Workers and Occupational Non-Users Exposed	

Assumptions and Key Sources of Uncertainty for Occupational Exposures	

3.1

3.2

Number of Workers	

Analysis of Exposure Monitoring Data	

.3,3 Near-Field/Far-Field Model Framework	

,3.4 Modeled Dermal Exposures	

Summary of Overall Confidence in Inhalation Exposure Estimates

2.3.2 Consumer Exposures	

2.3.2.1	Consumer Conditions of Use Evaluated	

2.3.2.2	Consumer Exposure Routes Evaluated	

2.3.2.2.1	Inhalation	

2.3.2.2.2	Dermal	

2.3.2.3	Potentially Exposed or Susceptible Subpopulations	

2.3.2.4	Consumer Exposures Approach and Methodology	

2.3.2.4.1 Modeling Approach	

2.3.2.5	Consumer Exposure Scenarios and Modeling Inputs	

2.3.2.5.1 Consumer Exposure Model Inputs	

2.3.2.6	Consumer Exposure Results	

2.3.2.6.1	Characterization of Exposure Results	

2.3.2.6.2	Consumer Exposure Estimates	

2.3.2.6.3	Summary of Consumer Exposure Assessment	

2.3.2.7	Assumptions and Key Sources of Uncertainty for Consumer Exposures .

2.3.2.7.1	Modeling Approach Uncertainties	

2.3.2.7.2	Data Uncertainties	

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97	2.3,2,8 Confidence in Consumer Exposure Scenarios	180

98	2.3,3 Potentially Exposed or Susceptible Subpopulations	185

99	3 HAZARDS	189

100	3.1 Environmental Hazards	189

101	3,1.1 Approach and Methodology	189

102	3.1,2 Hazard Identification	189

103	3.1,3 Species Sensitivity Distributions (SSDs)	194

104	3.1.4 Weight of the Scientific Evidence	197

105	3.1,5 Concentrations of Concern	198

106	3.1.6 Summary of Environmental Hazard	199

107	3,1.7 Assumptions and Key Uncertainities for Environmental Hazard Data	200

108	3.2 Human Health Hazards	201

109	3.2.1 Approach and Methodology	201

110	3.2,2 Toxicokinetics	203

111	3,2.2,1 Physiologically-Based Pharmacokinetic (PBPK) Modeling Approach	206

112	3.2.3 Hazard Identification	210

113	3,2.3.1 Non-Cancer Hazards	210

114	3,2.3.1.1 Liver toxicity	210

115	3,2,3.1,2 Kidney toxicity	211

116	3,2.3,1,3 Neurotoxicity	211

117	3.2.3.1.4 Immunotoxicity (including sensitization)	212

118	3.2,3.1.5 Reproductive toxicity	214

119	3.2,3,1.6 Developmental Toxicity	215

120	3,2.3,1.7 Overt Toxicity Following Acute/Short Term Exposure	217

121	3.2.3.2 Genotoxicity and Cancer Hazards	218

122	3,2,3.2.1 Kidney cancer	218

123	3,2,3,2,2 Liver cancer	218

124	3,2.3,2.3 Cancer of the immune system	219

125	3.2,3.2.4 Other cancers	219

126	3.2,4 Weight of Scientific Evidence	219

127	3,2.4.1 Non-Cancer Hazards	219

128	3.2.4.1.1 Liver toxicity	219

129	3,2,4,1,2 Kidney toxicity	220

130	3,2.4,1,3 Neurotoxicity	220

131	3.2.4.1.4 Immunotoxicity	220

132	3,2,4.1.5 Reproductive toxicity	220

133	3.2.4,1,6 Developmental Toxicity	221

134	3.2.4.1,7 Overt Toxicity Following Acute/Short Term Exposure	225

135	3,2,4,2 Cancer Hazards	225

136	3.2.4.2.1 Meta-Analysis Results	226

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137	3,2,4,2.2 Mode of Action	227

138	3,2.5 Dose-Response Assessment	229

139	3,2.5.1 Selection of Studies for Dose-Response Assessment	229

140	3,2.5.1.1 Liver toxicity	230

141	3.2.5.1.2 Kidney toxicity	230

142	3.2.5.1.3 Neurotoxicity	230

143	3.2.5.1.4 Immunotoxicity	230

144	3.2.5.1.5 Reproductive toxicity	231

145	3.2.5.1.6 Developmental toxicity	231

146	3.2.5.1.7 Cancer	233

147	3,2.5.2 Potentially Exposed and Susceptible Subpopulations (PESS)	233

148	3.2.5,3 Derivation of Points of Departure (PODs)	234

149	3.2.5.3.1 Non-Cancer PODs for Acute Exposure	235

150	3,2,5,3,2 Non-Cancer PODs for Chronic Exposures	239

151	3.2.5.3.3 Cancer POD for Lifetime Exposures	249

152	3,2,5.4 Selected PODs for Human Health Hazard Domains	251

153	3,2,6 Assumptions and Key Sources of Uncertainty for Human Health Hazard	254

154	3.2.6.1 Confidence in Hazard Identification and Weight of Evidence	254

155	3.2,6.2 Derivation of PODs, UFs, and PBPK Results	254

156	3.2.6.3 Cancer Dose Response	256

157	3.2.6.4 Confidence in Human Health Hazard Data Integration and Representative Endpoints256

158	4 RISK CHARACTERIZATION	259

159	4.1 Environmental Risk	259

160	4.1.1 Risk Estimation Approach	259

161	4.1.2 Risk Estimation for Aquatic	260

162	4.1.3 Risk Estimation for Sediment	275

163	4.1.4 Risk Estimation for Terrestrial	275

164	4,2 Human Health Risk	277

165	4.2.1 Risk Estimation Approach	277

166	4.2.1.1 Representative Points of Departure for Use in Risk Estimation	280

167	4.2,2 Risk Estimation for Occupational Exposures by Exposure Scenario	281

168	4.2.3 Risk Estimation for Consumer Exposures by Exposure Scenario	322

169	4.3 Assumptions and Key Sources of Uncertainty for Risk Characterization	347

170	4.3.1 Environmental Risk Characterization	347

171	4.3,2 Human Health Risk Characterization	347

172	4.3.2.1 Occupational Exposure Considerations	347

173	4.3.2.2 Consumer/Bystander Exposure Considerations	348

174	4.3.2.3 Dermal Absorption Considerations	349

175	4.3.2.4 Confidence in Risk Estimates	349

176	4.4 Other Risk Related Considerations	352

177	4.4.1 Potentially Exposed or Susceptible Populations	352

178	4.4.2 Aggregate and Sentinel Exposures	352

179	4.5 Risk Conclusions	354

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4.5.1	Environmental Risk Conclusions	354

4.5.2	Human Health Risk Conclusions	356

4.5.2.1	Summary of Risk Estimates for Workers and ONUs	356

4.5.2.2	Summary of Risk Estimates for Consumers and Bystanders	370

RISK DETERMINATION	374

5.1	Unreasonable Risk	374

5.1.1	Overview	374

5.1.2	Risks to Human Health	375

5.1.2.1	Determining Non-Cancer Risks	375

5.1.2.2	Determining Cancer Risks	376

5.1.3	Determining Environmental Risk	376

5.2	Risk Determinations for TCE	377

5.3	Detailed Risk Determinations by Condition of Use	383

5.3.1	Manufacture - Domestic manufacture	383

5.3.2	Manufacture - Import (includes repackaging and loading/unloading)	384

5.3.3	Processing - Processing as a reactant/intermediate in industrial gas manufacturing (e.g.,
manufacture of fluorinated gases used as refrigerants, foam blowing agents and solvents)385

5.3.4	Processing - Incorporation into formulation, mixture or reaction product - Solvents (for
cleaning or degreasing); adhesives and sealant chemicals; solvents (which become part of
product formulation or mixture) (e.g., lubricants and greases, paints and coatings, other
uses)	387

5.3.5	Processing - Incorporation into articles - Solvents (becomes an integral components of
articles)	388

5.3.6	Processing - Repackaging - Solvents (for cleaning or degreasing)	389

5.3.7	Processing - Recycling	390

5.3.8	Distribution in Commerce	391

5.3.9	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Batch vapor degreaser
(open-top)	391

5.3.10	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Batch vapor degreaser
(closed-loop)	393

5.3.11	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - In-line vapor degreaser
(convey orized)	394

5.3.12	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - In-line vapor degreaser
(web cleaner)	396

5.3.13	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Cold cleaner	397

5.3.14	Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Aerosol spray
degreaser/cleaner; mold release	398

5.3.15	Industrial/Commercial Use - Lubricants and greases/lubricants and lubricant additives - Tap
and die fluid	400

5.3.16	Industrial/Commercial Use - Lubricants and greases/lubricants and lubricant additives -
Penetrating lubricant	401

5.3.17	Industrial/Commercial Use - Adhesives and sealants - Solvent-based adhesives and
sealants; tire repair cement/sealer; mirror edge sealant	402

5.3.18	Industrial/Commercial Use - Functional fluids (closed systems) - Heat exchange fluid... 404

5.3.19	Industrial/Commercial Use - Paints and coatings - Diluent in solvent-based paints and
coatings	405

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5.3.20	Industrial/Commercial Use - Cleaning and furniture care products - Carpet cleaner; wipe
cleaning	407

5.3.21	Industrial/Commercial Use - Laundry and dishwashing products - Spot remover	408

5.3.22	Industrial/Commercial Use - Arts, crafts and hobby materials - Fixatives and finishing
spray coatings	409

5.3.23	Industrial/Commercial Use - Corrosion inhibitors and anti-scaling agents - Corrosion
inhibitors and anti-scaling agents	411

5.3.24	Industrial/Commercial Use - Processing aids - Process solvent used in battery manufacture;
process solvent used in polymer fiber spinning, fluoroelastomer manufacture, and Alcantara
manufacture; extraction solvent used in caprolactam manufacture; precipitant used in beta-
cyclodextrin manufacture	412

5.3.25	Industrial/Commercial Use - Ink, toner, and colorant products - Toner aid	414

5.3.26	Industrial/Commercial Use - Automotive care products - Brake and parts cleaners	415

5.3.27	Industrial/Commercial Use - Apparel and footwear care products - Shoe polish	416

5.3.28	Industrial/Commercial Use - Hoof polishes; gun scrubber; pepper spray; other
miscellaneous industrial and commercial uses	418

5.3.29	Disposal	419

5.3.30	Consumer Use - Solvents (for cleaning or degreasing) - Brake and parts cleaner	420

5.3.31	Consumer Use - Solvents (for cleaning or degreasing) - Aerosol electronic
degreaser/cleaner	421

5.3.32	Consumer Use - Solvents (for cleaning or degreasing) - Liquid electronic degreaser/cleaner
	422

5.3.33	Consumer Use - Solvents (for cleaning or degreasing) - Aerosol spray degreaser/cleaner423

3.34	Consumer Use - Solvents (for cleaning or degreasing) - Liquid degreaser/cleaner	424

3.35	Consumer Use - Solvents (for cleaning or degreasing) - Aerosol gun scrubber	425

3.36	Consumer Use - Solvents (for cleaning or degreasing) - Liquid gun scrubber	425

3.37	Consumer Use - Solvents (for cleaning or degreasing) - Mold release	426

3.38	Consumer Use - Solvents (for cleaning or degreasing) - Aerosol tire cleaner	427

3.39	Consumer Use - Solvents (for cleaning or degreasing) - Liquid tire cleaner	428

3.40	Consumer Use - Lubricants and greases - Tap and die fluid	429

3.41	Consumer Use - Lubricants and greases - Penetrating lubricant	430

3.42	Consumer Use - Adhesives and sealants - Solvent-based adhesive and sealant	430

3.43	Consumer Use - Adhesives and sealants - Mirror edge sealant	431

3.44	Consumer Use - Adhesives and sealants - Tire repair cement/sealer	432

3.45	Consumer Use - Cleaning and furniture care products - Carpet cleaner	433

3.46	Consumer Use - Cleaning and furniture care products - Aerosol spot remover	434

3.47	Consumer Use - Cleaning and furniture care products - Liquid spot remover	435

3.48	Consumer Use - Arts, crafts, and hobby materials - Fixatives and finishing spray coatings
	436

3.49	Consumer Use - Apparel and footwear care products - Shoe polish	436

3.50	Consumer Use - Other consumer uses - Fabric spray	437

3.51	Consumer Use - Other consumer uses - Film cleaner	438

3.52	Consumer Use - Other consumer uses - Hoof polish	439

3.53	Consumer Use - Other consumer uses - Pepper spray	440

3.54	Consumer Use - Other consumer uses - Toner aid	440

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271	REFERENCES	442

272	APPENDICES	463

273	Appendix A REGULATORY HISTORY	463

274	A.l Federal Laws and Regulations									...............463

275	A.2 State 'Laws and Regulations									....469

276	A.3 International Laws and Regulations.....................											470

277	Appendix B LIST OF SUPPLEMENTAL DOCUMENTS	472

278	Appendix C ENVIRONMENTAL EXPOSURES	474

279	Appendix D CONSUMER EXPOSURES	516

280	D.l Model Sensitivity																		.....516

281	D.l.l Continuous Variables	516

282	D.1.2 Categorical Variables	519

283	D.l Monitoring Data....																			.....519

284	D.2.1 Indoor Air Monitoring	519

285	D.2.2 Personal breathing Zone Monitoring Data	521

286	Appendix E ENVIRONMENTAL HAZARDS	523

287	E.l Species Sensitivity Distribution (SSD) Methodology....							......523

288	E,2 Environmental Risk Quotients (RQs) for Facilities Releasing TCE to Surface Water as

289	Modeled in E-FAST....													......530

290	Appendix F BENCHMARK DOSE ANALYSIS FOR (Selgrade and Gilmour, 2010)	590

291	F.l BMDS Wizard Output Report - Mortality											590

292	F.l.l BMDS Summary of Mortality-BMR 10%	590

293	F.l.2 BMDS Summary of Mortality - BMR: 5%	593

294	F.l.3 BMDS Summary of Mortality-BMR: 1%	595

295	F.2 BMDS Wizard Output Report - Number of Mice Infected							..............598

296	F.2.1 BMDS Summary of Infected at 72 hours - BMR - 10%	598

297	Appendix G WEIGHT OF EVIDENCE FOR CONGENITAL HEART DEFECTS	600

298	G.l EPA Review of the Charles River (2019) Study											.......600

299	G. 1.1 Study Methodology and Results	600

300	G.1.2 EPA Review	601

301	G. 1.2.1 Comparing Results Between Charles River and Johnson Studies	601

302	G. 1.2.2 Differences in Types of Malformations Observed	603

303	G. 1.2.3 Methodology Differences	607

304	G. 1.2.4 Adversity of Small VSDs	609

305	G.l WOE Analysis for Congenital Cardiac Defects...							........610

306	G.2.1 Methodology	610

307	G.2.2 WOE Results By Study Type	614

308	Appendix H META-ANALYSIS FOR CANCER	622

309	H. 1 Study Screening and Selection												622

310	H. 1.1 Data Quality and Inclusion/Exclusion Criteria Screening	622

311	H.1.2 Screening results	623

312	11.1.3 Pooled Cohorts	624

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H.2 Mela-Analysis Methods and Results													625

II.2.1 Methods	625

H.2.2 Results	627

H.2.2.1 Initial Meta-Analyses	627

H.2.2.2 Sensitivity analyses	633

H.2.3 Selected RR estimates and confidence intervals by study and cancer type	641

H.2.4 Sample Stata commands for meta-analysis	647

Appendix I APPROACH FOR ESTIMATING WATER RELEASES FROM
MANUFACTURING SITES USING EFFLUENT GUIDELINES	648

Appendix J SAMPLE CALCULATIONS FOR CALCULATING ACUTE AND CHRONIC
(NON-CANCER AND CANCER) INHALATION EXPOSURE	652

J.l Example High-End AC, ADC, and LADC									.652

J.2 Example Central Tendency AEG, ADC, and LADC												653

Appendix K VAPOR DEGREASING AND COLD CLEANING NEAR-FIELD/FAR-FIELD
INHALATION EXPOSURE MODELS APPROACH AND PARAMETERS	654

K.l Model Design Equations													...655

K.2 Model Parameters									...............659

K.2.1 Far-Field Volume	664

K.2.2 Air Exchange Rate	664

K.2.3 Near-Field Indoor Air Speed	664

K.2.4 Near-Field Volume	665

K.2.5 Exposure Duration	665

K.2.6 Averaging Time	665

K.2.7 Vapor Generation Rate	665

K.2.8 Operating Hours	668

Appendix L BRAKE SERVICING NEAR-FIELD/FAR-FIELD INHALATION EXPOSURE
MODEL APPROACH AND PARAMETERS	670

L.l Model Design Equations...........................									......670

L.2 Model Parameters..........															.................675

L.2.1 Far-Field Volume	678

L.2.2 Air Exchange Rate	678

L.2.3 Near-Field Indoor Air Speed	678

L.2.4 Near-Field Volume	679

L.2.5 Application Time	679

L.2.6 Averaging Time	679

L.2.7 Trichloroethylene Weight Fraction	679

L.2.8 Volume of Degreaser Used per Brake Job	680

L.2.9 Number of Applications per Brake Job	680

L.2.10 Amount of Trichloroethylene Used per Application	681

L.2.11 Operating Hours per Week	681

L.2.12 Number of Brake Jobs per Work Shift	681

Appendix M SPOT CLEANING NEAR-FIELD/FAR-FIELD INHALATION EXPOSURE
MODEL APPROACH AND PARAMETERS	682

M.l Model Design Equations.......											.682

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357	M.2 Model Parameters.													..686

358	VI.2.1 Far-Field Volume	690

359	M.2.2 Near-Field Volume	690

360	M.2.3 Air Exchange Rate	690

361	M.2.4 Near-Field Indoor Wind Speed	690

362	M.2.5 Averaging Time	691

363	VI.2.6 Use Rate	691

364	M.2.7 Vapor Generation Rate	691

365	M.2.8 Operating Hours	691

366	M.2.9 Operating Days	692

367	M.2. lOFractional Number of Operating Days that a Worker Works	692

368	Appendix N BENCHMARK DOSE MODELING UPDATE FOR NESTED FETAL DATA

369	FROM (Johnson et al., 2003)	693

370	Appendix O CONSIDERATIONS FOR BMD MODELING AND APPLICATION OF

371	UNCERTAINTY FACTORS	695

372	O.l Selecting the BMD model to use for POD computation...					..............695

373	0.2 Uncertainty Factor Selection...																					......696

374	Appendix P OCCUPATIONAL INHALATION EXPOSURE AND WATER RELEASE

375	ASSESSMENT	698

376	P.l Manufacturing................															.....698

377	P. 1.1 Exposure Assessment	698

378	P. 1.2 Water Release Assessment	698

379	P.l Processing as a Reactant																		...701

380	P.2.1 Exposure Assessment	701

381	P.2.2 Water Release Assessment	702

382	P.3 Formulation of Aerosol and Non-Aerosol Products							703

383	P.3.1 Exposure Assessment	703

384	P.3.2 Water Release Assessment	703

385	P.4 Repackaging											704

386	P.4.1 Exposure Assessment	704

387	P.4.2 Water Release Assessment	704

388	P.5 Batch Open Top Vapor Degreasing										...705

389	P.5.1 Exposure Assessment	705

390	P.5.2 Water Release Assessment	708

391	P.6 Batch Closed-Loop Vapor Degreasing							...........712

392	P.6.1 Exposure Assessment	712

393	P.6.2 Water Release Assessment	712

394	P.7 Conveyorized Vapor Degreasing.									.713

395	P.7.1 Exposure Assessment	713

396	P.7.2 Water Release Assessment	715

397	P.8 Web Vapor Degreasing..																					716

398	P.8.1 Exposure Assessment	716

399	P.8.2 Water Release Assessment	717

400	P.9 Cold Cleaning...........										...........718

401	P.9.1 Exposure Assessment	718

402	P.9.2 Water Release Assessment	720

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P. 10 Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts Cleaners,

Penetrating Lubricants, and Mold Releases............							

P.10.1 Exposure Assessment	

P. 10.2 Water Release Assessment	

P. 11 Metalworking Fluids													

P. 11.1 Exposure Assessment	

P. 11.2 Water Release Assessment	

P.12 Adhesives, Sealants, Paints, and Coatings......................................							

P. 12.1 Exposure Assessment	

P. 12.2 Water Release Assessment	

P. 13 Other Industrial Uses.....												

P.13.1 Exposure Assessment	

P.13.2 Water Release Assessment	

P. 14 Spot Cleaning, Wipe Cleaning and. Carpet Cleaning.					

P. 14.1 Exposure Assessment	

P. 14.2 Water Release Assessment	

P. 15 Industrial Processing Aid													

P.15.1 Exposure Assessment	

P.15.2 Water Release Assessment	

P. 16 Commercial Printing and Copying.................									

P.16.1 Exposure Assessment	

P. 16.2 Water Release Assessment	

P.17 Other Commercial Uses					

P.17.1 Exposure Assessment	

P. 17.2 Water Release Assessment	

P.l 8 Process Solvent Recycling and Worker Handling of Wastes 			

P.18.1 Exposure Assessment	

P.18.2 Water Release Assessment	

P.l9 Appendix P References													

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LIST OF TABLES

Table 1-1 Physical and Chemical Properties of TCE	41

Table 1-2 Production Volume of TCE in CDR Reporting Period (2012 to 2015) a	42

Table 1-3. Assessment History of TCE	45

Table 1-4. Categories and Subcategories of Occupational Conditions of Use and Corresponding

Occupational Exposure Scenario	47

Table 1-5. Categories and Subcategories of Consumer Conditions of Use	53

Table 2-1 Environmental Fate Characteristic of TCE	68

Table 2-2: Summary of EPA's daily water release estimates for each OES and also EPA's Overall

Confidence in these estimates	73

Table 2-3: Summary of EPA's estimates for the number of facilities for each OES	75

Table 2-4: Summary of EPA's estimates for release days expected for each OES	76

Table 2-5: Summary of Overall Confidence in Release Estimates by OES	78

Table 2-6 Industry Sector Modeled for Facilities without Site-Specific Flow Data in E-FAST 2014	86

Table 2-7. Summary of Surface Water Concentrations by OES for Maximum Days of Release Scenario

	91

Table 2-8. Summary of Surface Water Concentrations by OES for 20 Days of Release Scenario	91

Table 2-9. Summary of Surface Water Concentrations by OES for 20 Days of Release Scenario for

Indirect Releases to a non-POTW WWTP	92

Table 2-10. Measured Concentrations of TCE in Surface Water Obtained from the Water Quality Portal:

2013-2017'	94

Table 2-11. Ambient Levels of TCE in U.S. Surface Water from Published Literature	95

Table 2-12: A summary for each of the 18 occupational exposure scenarios (OESs)	103

Table 2-13: Summary of inhalation exposure results for Workers based on monitoring data and

exposure modeling for each OES	104

Table 2-14: Summary of inhalation exposure results for ONUs based on monitoring data and exposure

modeling for each OES	105

Table 2-15: A summary of dermal retained dose for Workers based on exposure modeling for each OES

	106

Table 2-16: Summary of the total number of workers and ONUs potentially exposed to TCE for each

OES	107

Table 2-17: Parameter Values for Calculating Inhalation Exposure Estimates	112

Table 2-18: Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)	114

Table 2-19: Median Year of Tenure with Current Employer by Age Group	115

Table 2-20: Glove Protection Factors for Different Dermal Protection Strategies	117

Table 2-21: EPA grouped dermal exposures associated with the various OESs into four bins	118

Table 2-22: Assigned Protection Factors for Respirators in OSHA Standard 29 CFR § 1910.134	120

Table 2-23: SOCs with Worker and ONU Designations for All Conditions of Use Except	121

Table 2-24: SOCs with Worker and ONU Designations for Dry Cleaning Facilities	122

Table 2-25: Estimated Number of Potentially Exposed Workers and ONUs under NAICS 812320.... 123

Table 2-26: Summary of overall confidence in inhalation exposure estimates by OES	128

Table 2-27. Evaluated Consumer Conditions of Use and Products for TCE	135

Table 2-28. Default Modeling Input Parameters	143

Table 2-29. Consumer Product Modeling Scenarios and Varied Input Parameters	145

Table 2-30. Consumer Product Modeling Scenarios and Additional Scenario-Specific Input Parameters

	149

Table 2-31. Surface Area and Body Weight Values for Different Consumer and Bystander

Subpopulations	152

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Table 2-32. Acute Inhalation Exposure Summary: Brake & Parts Cleaner	

Table 2-33. Acute Dermal Exposure Summary: Brake & Parts Cleaner	

Table 2-34. Acute Inhalation Exposure Summary: Aerosol Electronic Degreaser/Cleaner	

Table 2-35. Acute Inhalation Exposure Summary: Liquid Electronic Degreaser/Cleaner	

Table 2-36. Acute Dermal Exposure Summary: Liquid Electronic Degreaser/Cleaner	

Table 2-37. Acute Inhalation Exposure Summary: Aerosol Spray Degreaser/Cleaner	

Table 2-38. Acute Dermal Exposure Summary: Aerosol Spray Degreaser/Cleaner	

Table 2-39. Acute Inhalation Exposure Summary: Liquid Degreaser/Cleaner	

Table 2-40. Acute Dermal Exposure Summary: Liquid Degreaser/Cleaner	

Table 2-41. Acute Inhalation Exposure Summary: Aerosol Gun Scrubber	

Table 2-42. Acute Dermal Exposure Summary: Aerosol Gun Scrubber	

Table 2-43. Acute Inhalation Exposure Summary: Liquid Gun Scrubber	

Table 2-44. Acute Dermal Exposure Summary: Liquid Gun Scrubber	

Table 2-45. Acute Inhalation Exposure Summary: Mold Release	

Table 2-46. Acute Inhalation Exposure Summary: Aerosol Tire Cleaner	

Table 2-47. Acute Dermal Exposure Summary: Aerosol Tire Cleaner	

Table 2-48. Acute Inhalation Exposure Summary: Liquid Tire Cleaner	

Table 2-49. Acute Dermal Exposure Summary: Liquid Tire Cleaner	

Table 2-50. Acute Inhalation Exposure Summary: Tap & Die Fluid	

Table 2-51. Acute Inhalation Exposure Summary: Penetrating Lubricant	

Table 2-52. Acute Inhalation Exposure Summary: Solvent-based Adhesive & Sealant	

Table 2-53. Acute Inhalation Exposure Summary: Mirror-Edge Sealant	

Table 2-54. Acute Inhalation Exposure Summary: Tire Repair cement/Sealer	

Table 2-55. Acute Inhalation Exposure Summary: Carpet Cleaner	

Table 2-56. Acute Dermal Exposure Summary: Carpet Cleaner	

Table 2-57. Acute Inhalation Exposure Summary: Aerosol Spot Remover	

Table 2-58. Acute Dermal Exposure Summary: Aerosol Spot Remover	

Table 2-59. Acute Inhalation Exposure Summary: Liquid Spot Remover	

Table 2-60. Acute Dermal Exposure Summary: Liquid Spot Remover	

Table 2-61. Acute Inhalation Exposure Summary: Fixatives & Finishing Spray Coatings	

Table 2-62. Acute Inhalation Exposure Summary: Shoe Polish	

Table 2-63. Acute Dermal Exposure Summary: Shoe Polish	

Table 2-64. Acute Inhalation Exposure Summary: Fabric Spray	

Table 2-65. Acute Inhalation Exposure Summary: Film Cleaner	

Table 2-66. Acute Inhalation Exposure Summary: Hoof Polish	

Table 2-67. Acute Inhalation Exposure Summary: Pepper Spray	

Table 2-68. Acute Inhalation Exposure Summary: Toner Aid	

Table 2-69. Evaluated Pathways for Consumer Conditions of Use	

Table 2-70. Summary of Consumer Exposure Levels by Category	

Table 2-71. Confidence Ratings for Acute Inhalation Consumer Exposure Modeling Scenarios .

Table 2-72. Confidence Ratings for Acute Dermal Consumer Exposure Modeling Scenarios	

Table 2-73. Percentage of Employed Persons by Age, Sex, and Industry Sector	

Table 2-74. Percentage of Employed Adolescent by Detailed Industry Sector	

Table 3-1 Ecological Hazard Data used Quantitatively to Characterize TCE Hazard for Aquatic

Organisms	

Table 3-2 Concentrations of Concern (COCs) for Environmental Toxicity	

Table 3-3 TCE Metabolites Identified by Pathway	

Table 3-4 Common Metabolites of TCE and Related Compounds	

Page 13 of 748


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Table 3-5 List of All of the PBPK-Modeled Dose Metrics Used in the TCE IRIS Assessment	206

Table 3-6. Overall Summary Scores by Line of Evidence for Cardiac Defects from TCE	224

Table 3-7: Dose-response analysis of selected studies considered for acute exposure scenarios	238

Table 3-8: Dose-response analysis of selected studies considered for evaluation of liver toxicity	240

Table 3-9: Dose-response analysis of selected studies considered for evaluation of kidney toxicity.... 241
Table 3-10: Dose-response analysis of selected studies considered for evaluation of neurological effects

	243

Table 3-11: Dose-response analysis of selected studies considered for evaluation of immune effects . 245
Table 3-12: Dose-response analysis of selected studies considered for evaluation of reproductive effects

	248

Table 3-13: Dose-response analysis of selected studies considered for acute exposure scenarios	252

Table 3-14: Dose-response analysis of selected studies considered for chronic exposure scenarios	253

Table 3-15: Cancer Points of Departure for Lifetime Exposure Scenarios	254

Table 4-1. Environmental Risk Quotients for Facilities Releasing TCE to Surface Water as Modeled in

E-FAST (RQs > 1 in bold)	264

Table 4-2. RQs Calculated using Monitored Environmental Concentrations from WQX/WQP	268

Table 4-3. RQs Calculated using Monitored Environmental Concentrations from Published Literature

	269

Table 4-4. Use Scenarios, Populations of Interest and Toxicological Endpoints Used for Acute and

Chronic Exposures	277

Table 4-5: Most Sensitive Endpoints from Each Health Domain for Risk Estimation	280

Table 4-6. Occupational Risk Estimation - Manufacturing	282

Table 4-7. Occupational Risk Estimation - Processing as a Reactant	284

Table 4-8. Occupational Risk Estimation - Batch Open Top Vapor Degreasing - Inhalation Monitoring

Data	286

Table 4-9. Occupational Risk Estimation - Batch Open Top Vapor Degreasing - Inhalation Modeling

Data	287

Table 4-10. Occupational Risk Estimation - Batch Closed-Loop Vapor Degreasing	289

Table 4-11. Occupational Risk Estimation - Conveyorized Vapor Degreasing - Inhalation Monitoring

Data	291

Table 4-12. Occupational Risk Estimation - Conveyorized Vapor Degreasing - Inhalation Modeling

Data	292

Table 4-13. Occupational Risk Estimation - Web Vapor Degreasing	294

Table 4-14. Occupational Risk Estimation - Cold Cleaning	296

Table 4-15. Occupational Risk Estimation - Aerosol Applications	298

Table 4-16. Occupational Risk Estimation - Spot Cleaning and Wipe Cleaning (and Other Commercial

Uses) - Inhalation Monitoring Data	300

Table 4-17. Occupational Risk Estimation - Spot Cleaning and Wipe Cleaning (and Other Commercial

Uses) - Inhalation Modeling Data	301

Table 4-18. Occupational Risk Estimation - Formulation of Aerosol and Non-Aerosol Products	303

Table 4-19. Occupational Risk Estimation - Repackaging	305

Table 4-20. Occupational Risk Estimation - Metalworking Fluids - Inhalation Monitoring Data	307

Table 4-21. Occupational Risk Estimation - Metalworking Fluids - Inhalation Modeling Data	308

Table 4-22. Occupational Risk Estimation - Adhesives, Sealants, Paints, and Coatings (Industrial

Setting)	310

Table 4-23. Occupational Risk Estimation - Adhesives, Sealants, Paints, and Coatings (Commercial

Setting)	312

Table 4-24. Occupational Risk Estimation - Industrial Processing Aid (12 hr)	314

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Table 4-
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25.	Occupational Risk Estimation

26.	Occupational Risk Estimation

27.	Occupational Risk Estimation

Commercial Printing and Copying	316

Other Industrial Uses	318

Process Solvent Recycling and Worker Handling of Wastes
	320

28.	Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Brake and Parts

Cleaner	323

29.	Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol Electronic

Degreaser/Cleaner	324

30.	Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid Electronic

Degreaser/Cleaner	325

31.	Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol Spray

Degreaser/Cleaner	326

32.	Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid

Degreaser/Cleaner	327

33.	Consumer Risk Estimati

Table 4-34. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid Gun Scrubber

	329

Table 4-35. Consumer Risk Estimati
Table 4-36. Consumer Risk Estimati

Table 4-
Table 4-
Table 4-
Table 4-

Table 4-
Table 4-
Table 4-
Table 4-

37.	Consumer Risk Esti

38.	Consumer Risk Esti

39.	Consumer Risk Esti

40.	Consumer Risk Esti

41.	Consumer Risk Esti

42.	Consumer Risk Esti

43.	Consumer Risk Esti

44.	Consumer Risk Esti

Table 4-45. Consumer Risk Estimati
Table 4

-48. Consumer Risk Estimation - Other Consumer Uses
-49. Consumer Risk Estimation - Other Consumer Uses
-50. Consumer Risk Estimation - Other Consumer Uses
-51. Consumer Risk Estimation - Other Consumer Uses

on - Solvents for Cleaning and Degreasing - Aerosol Gun Scrubber
	328

on - Solvents for Cleaning and Degreasing - Mold Release	330

on - Solvents for Cleaning and Degreasing - Aerosol Tire Cleaner
	331

mation - Solvents for Cleaning and Degreasing - Liquid Tire Cleaner332

mation - Lubricants and Greases - Tap and Die Fluid	333

mation - Lubricants and Greases - Penetrating Lubricant	334

mation - Adhesives and Sealants - Solvent-Based Adhesive and Sealant
	335

mation - Adhesives and Sealants - Mirror Edge Sealant	336

mation - Adhesives and Sealants - Tire Repair Cement / Sealer	337

mation - Cleaning and Furniture Care Products - Carpet Cleaner	338

mation - Cleaning and Furniture Care Products - Aerosol Spot Remover
	339

on - Cleaning and Furniture Care Products - Liquid Spot Remover
	340

46.	Consumer Risk Estimation - Arts, Crafts, and Hobby Materials - Fixatives and Finishing

Spray Coatings	341

47.	Consumer Risk Estimation - Apparel and Footwear Care Products - Shoe Polish	342

Fabric Spray	343

Table 4
Table 4
Table 4
Table 4
Table 4

Table 4-52. Consumer Risk Estimation - Other Consumer Uses
Table 4-53. Facilities with Acute or Chronic Risk Identified for Aquatic Organisms (RQs > 1 in bold)

	355

Table 4-54. Occupational Risk Summary Table	358

Table 4-55. Consumer Risk Summary Table	370

Table 5-1. Summary of Unreasonable Risk Determinations by Condition of Use	379

Film Cleaner	344

Hoof Polish	345

Pepper Spray	346

Toner Aid	346

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LIST OF FIGURES

Figure 1-1. TCE Life Cycle Diagram	55

Figure 1-2. TCE Conceptual Model for Industrial and Commercial Activities and Uses: Potential

Exposures and Hazards	57

Figure 1-3. TCE Conceptual Model for Consumer Activities and Uses: Potential Exposures and Hazards

	58

Figure 1-4. TCE Conceptual Model for Environmental Releases and Wastes: Potential Exposures and

Hazards	59

Figure 1-5. Literature Flow Diagram for Environmental Fate and Transport	62

Figure 1-6. Literature Flow Diagram for Engineering Releases and Occupational Exposure	63

Figure 1-7. Literature Flow Diagram for Consumer and Environmental Exposure Data Sources	64

Figure 1-8. Literature Flow Diagram for Environmental Hazard	65

Figure 1-9. Literature Flow Diagram for Human Health Hazard	66

Figure 2-1: An overview of how EPA estimated daily water releases for each OES	72

Figure 2-2. WQP Search Option. Surface water data were obtained from the WQP by querying the
Sampling Parameters search option for the characteristic (STORET data), Parameter

Code (NWIS data), and date range parameter	89

Figure 2-3. Distribution of Active Facility Releases Modeled	93

Figure 2-4. Modeled Release Characteristics (Percent Occurrence)	93

Figure 2-5: Components of an occupational assessment for each OES; please refer to Section 2.2.2.2.2
for additional details on the approach and methodology for estimating number of

facilities	100

Figure 2-6: Illustrative applications of the NF/FF model to various exposure scenarios	110

Figure 3-1. Species Sensitivity Distribution (SSD) for Algae Species Using EC50s (Etterson, 2019)... 195
Figure 3-2. Species Sensitivity Distributions (SSDs) for Acute Hazard Data Using LC50S or EC50S

(Etterson, 2019)	196

Figure 3-3. EPA Approach to Hazard Identification, Data Integration, and Dose-Response Analysis for

TCE	201

Figure 3-4 Dose-Response Analyses of Rodent Non-Cancer Effects Using the Rodent and Human PBPK

Models	208

Figure 3-5 Example of HEC99 Estimation through Interpecies, Intraspecies and Route-to- Route

Extrapolation from a Rodent Study LOAEL/NOAEL	209

Figure 4-1. Concentrations of Trichloroethylene from Releasing Facilities (Higher Release Frequency

Scenarios) and WQX Monitoring Stations: Year 2016, East US	270

Figure 4-2. Concentrations of Trichloroethylene from Releasing Facilities (Higher Release Frequency

Scenarios) and WQX Monitoring Stations: Year 2016, West US	271

Figure 4-3. Concentrations of Trichloroethylene from Releasing Facilities (20 Days of Release Scenario)

and WQX Monitoring Stations: Year 2016, East US	272

Figure 4-4. Concentrations of Trichloroethylene Releasing Facilities (20 Days of Release Scenario) and

WQX Monitoring Stations: Year 2016, West US	273

Figure 4-5. Co-location of Trichloroethylene-Releasing Facilities and WQX Monitoring Stations at the

IILC 8 Level in NC	274

Figure 4-6. Co-location of Trichloroethylene-Releasing Facilities and WQX Monitoring Stations at the
I ILC 8 Level in NM	275

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LIST OF APPENDIX TABLES

Table_Apx A-l. Federal Laws and Regulations	463

Table_Apx A-2. State Laws and Regulations	469

Table_Apx A-3. Regulatory Actions by Other Governments and Tribes	470

Table_Apx C-l. Facility-Specific Aquatic Exposure Modeling Results	474

TableApx D-l. TCE Residential Indoor Air Concentrations (|ig/m3) in the United States and Canada

	520

Table Apx D-2. Personal Breathing Zone Concentrations (|ig/m3) for TCE in the United States

(General/Residential)	522

Table Apx E-l. Standard Error for all dsitributions and fitting methods using TCE's algae hazard data

(Etterson, 2019)	 524

Table Apx E-2. Standard Error for all distributions and fitting methods using TCE's acute hazard data

(Etterson, 2019)	 527

Table Apx E-3. Environmental RQs by Facility (with RQs > 1 in bold)	530

Table Apx F-l. Summary of BMD Modeling Results for Mortality from Introduced Infection in Mice
Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 10% Extra

Risk	590

Table Apx F-2. Summary of BMD Modeling Results for Mortality from Introduced Infection in Mice
Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 5% Extra

Risk	593

Table Apx F-3. Summary of BMD Modeling Results for Mortality from Introduced Infection in Mice
Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 1% Extra

Risk	595

Table Apx F-4. Summary of BMD Modeling Results for Number of Mice Infected at 72 Hours after
Infection Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR =

10% Extra Risk	598

Table Apx F-5. Plot of Incidence by Dose (ppm) with Fitted Curve for Probit Model for Number of
Mice Infected at 72 Hours after Infection Following Inhalation Exposure to TCE

(Selgrade and Gilmour 2010); BMR = 10% Extra Risk	599

Table_Apx G-l. Experimental Design	600

Table_Apx G-2. Summary of Observed Interventricular Defects	601

TableApx G-3. Incidence of total heart malformations in Johnson and Charles River studies	601

Table Apx G-4. Incidence of VSDs in Johnson and Charles River studies	602

Table Apx G-5. Heart and Cardiovascular Defects Observed in Oral TCE studies	603

Table_Apx G-6. Cardiac Defects Observed in Literature	605

Table Apx G-l. Cardiac Defects Observed After Exposure to RA or TCE	606

Table Apx G-8. Weight-of-Evidence Table for Epidemiology Studies	614

Table Apx G-9. Weight-of-Evidence Table for In Vivo Animal Toxicity Studies	616

Table_Apx G-10. Weight-of-Evidence Table for Mechanistic Studies	619

Table Apx G-ll. Overall Weight-of-Evidence Table and Summary Scores	621

Table Apx H-l. Meta-Analysis Inclusion/Exclusion Criteria for Considering Cancer Studies Identified

in EPA's Literature Search	622

Table Apx H-2. Screening Results of Cancer Studies Identified in EPA's Literature Search Based on

Inclusion/Exclusion Criteria	623

Table Apx H-3. Cancer Studies Covering the Same Cohort as Previous Studies from either the 2011

IRIS Assessment or EPA Literature Search	624

Table_Apx H-4. Analysis of influential studies: NHL	633

Table_Apx H-5. Analysis of influential studies: Kidney cancer	633

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Table_Apx H-6. Analysis of influential studies: Liver cancer	634

TableApx H-7. Selected RR estimates for NHL associated with TCE exposure (overall effect) from

cohort studies published after U.S. EPA (2011)	641

Table Apx H-8. Selected RR estimates for NHL associated with TCE exposure (overall effect) from

case-control studies	642

Table Apx H-9. Selected RR estimates for NHL associated with TCE exposure (effect in the highest

exposure group) studies	642

Table Apx H-10. Selected RR estimates for kidney cancer associated with TCE exposure (overall

effect) from cohort studies	643

Table Apx H-l 1. Selected RR estimates for kidney cancer associated with TCE exposure (overall

effect) from case-control studies published after U.S. EPA (2011)	644

Table Apx H-12. Selected RR estimates for liver cancer associated with TCE exposure (overall effect)

from cohort studies	645

Table Apx H-13. Selected RR estimates for liver cancer associated with TCE exposure (overall effect)

from case-control studies published after U.S. EPA (2011)	646

Table Apx 1-1. Summary of OCPSF Effluent Guidelines for Trichloroethylene	648

Table Apx 1-2. Default Parameters for Estimating Water Releases of Trichloroethylene from

Manufacturing Sites	649

TableApx 1-3. Summary of Facility Trichloroethylene Production Volumes and Wastewater Flow

Rates	650

Table Apx K-l. Summary of Parameter Values and Distributions Used in the Open-Top Vapor

Degreasing Near-Field/Far-Field Inhalation Exposure Model	660

Table Apx K-2. Summary of Parameter Values and Distributions Used in the Conveyorized Degreasing

Near-Field/Far-Field Inhalation Exposure Model	661

Table Apx K-3. Summary of Parameter Values and Distributions Used in the Web Degreasing Near-

Field/Far-Field Inhalation Exposure Model	662

Table Apx K-4. Summary of Parameter Values and Distributions Used in the Cold Cleaning Near-

Field/Far-Field Inhalation Exposure Model	663

Table Apx K-5. Summary of Trichloroethylene Vapor Degreasing and Cold Cleaning Data from the

2014 NEI	665

Table Apx K-6. Distribution of Trichloroethylene Open-Top Vapor Degreasing Unit Emissions	666

Table Apx K-7. Distribution of Trichloroethylene Conveyorized Degreasing Unit Emissions	667

Table Apx K-8. Distribution of Trichloroethylene Web Degreasing Unit Emissions	668

Table Apx K-9. Distribution of Trichloroethylene Cold Cleaning Unit Emissions	668

Table Apx K-10. Distribution of Trichloroethylene Open-Top Vapor Degreasing Operating Hours... 668

Table Apx K-l 1. Distribution of Trichloroethylene Conveyorized Degreasing Operating Hours	668

Table Apx K-12. Distribution of Trichloroethylene Web Degreasing Operating Hours	669

Table Apx K-13. Distribution of Trichloroethylene Cold Cleaning Operating Hours	669

Table Apx L-l. Summary of Parameter Values and Distributions Used in the Brake Servicing Near-

Field/Far-Field Inhalation Exposure Model	676

Table Apx L-2. Summary of Trichloroethylene-Based Aerosol Degreaser Formulations	680

TableApx M-l. Summary of Parameter Values and Distributions Used in the Spot Cleaning Near-

Field/Far-Field Inhalation Exposure Model	687

Table Apx M-2. Composite Distribution of Dry Cleaning Facility Floor Areas	690

Table Apx N-l. Results for Best-Fitting Model in Comparison to Results	694

Table Apx P-l. Summary of Worker Inhalation Exposure Monitoring Data from TCE Manufacturing

	698

Table Apx P-2. Summary of OCPSF Effluent Limitations for Trichloroethylene	699

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TableApx P-3. Reported Water Releases of Trichloroethylene from Manufacturing Sites Reporting to

2016 TRI	700

Table Apx P-4. Estimated Water Releases of Trichloroethylene from Manufacturing Sites Not

Reporting to 2016 TRI	701

Table Apx P-5. Summary of Worker Inhalation Exposure Surrogate Monitoring Data from TCE Use as

a Reactant	702

Table Apx P-6. Water Release Estimates for Sites Using TCE as a Reactant	702

Table Apx P-7. Summary of Worker Inhalation Exposure Monitoring Data for Unloading TCE During

Formulation of Aerosol and Non-Aerosol Products	703

Table Apx P-8. Summary of Worker Inhalation Exposure Monitoring Data for Unloading/Loading TCE

from Bulk Containers	704

Table Apx P-9. Reported Water Releases of Trichloroethylene from Sites Repackaging TCE	705

Table Apx P-10. Summary of Worker Inhalation Exposure Monitoring Data for Batch Open-Top Vapor

Degreasing	706

Table Apx P-l 1. Summary of Exposure Modeling Results for TCE Degreasing in OTVDs	708

Table Apx P-12. Reported Water Releases of Trichloroethylene from Sites Using TCE in Open-Top

Vapor Degreasing	708

TableApx P-13. Summary of Worker Inhalation Exposure Monitoring Data for Batch Closed-Loop

Vapor Degreasing	712

Table Apx P-14. Summary of Worker Inhalation Exposure Monitoring Data for Conveyorized Vapor

Degreasing	713

Table Apx P-15. Summary of Exposure Modeling Results for TCE Degreasing in Conveyorized

Degreasers	715

TableApx P-16. Summary of Exposure Modeling Results for TCE Degreasing in Web Degreasers.. 717
Table Apx P-17. Summary of Exposure Modeling Results for Use of Trichloroethylene in Cold

Cleaning	719

Table Apx P-l 8. Summary of Worker and Occupational Non-User Inhalation Exposure Modeling

Results for Aerosol Degreasing	722

Table Apx P-19. Summary of Worker Inhalation Exposure Monitoring Data for TCE Use in

Metalworking Fluids	723

Table Apx P-20. ESD Exposure Estimates for Metalworking Fluids Based on Monitoring Data	723

Table Apx P-21. Summary of Exposure Results for Use of TCE in Metalworking Fluids Based on ESD

Estimates	724

Table Apx P-22. Summary of Worker Inhalation Exposure Monitoring Data for

Adhesives/Paints/Coatings	725

Table Apx P-23. Reported Water Releases of Trichloroethylene from Sites Using TCE in Adhesives,

Sealants, Paints and Coatings	726

Table Apx P-24 Summary of Occupational Exposure Surrogate Monitoring Data for Unloading TCE

During Other Industrial Uses	730

Table Apx P-25. Reported Water Releases of Trichloroethylene from Other Industrial Uses	731

Table Apx P-26. Summary of Worker Inhalation Exposure Monitoring Data for Spot Cleaning Using

TCE	732

Table Apx P-27. Summary of Exposure Modeling Results for Spot Cleaning Using TCE	734

Table Apx P-28. Reported Water Releases of Trichloroethylene from Sites Using TCE Spot Cleaning

	734

Table Apx P-29. Summary of Exposure Monitoring Data for Use as a Processing Aid	735

Table Apx P-30. Reported Water Releases of Trichloroethylene from Industrial Processing Aid Sites

Using TCE	736

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815	TableApx P-31. Summary of Worker Inhalation Exposure Monitoring Data for High Speed Printing

816	Presses	737

817	Table Apx P-32. Reported Water Releases of Trichloroethylene from Commercial Printing and Copying

818		737

819	Table Apx P-33. Reported Water Releases of Trichloroethylene from Other Commercial Uses in the

820	2016 DMR	738

821	Table Apx P-34. Estimated Water Releases of Trichloroethylene from Disposal/Recycling of TCE .. 739

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LIST OF APPENDIX FIGURES

Figure_Apx D-l. Elasticities (> 0.05) for Parameters Applied in El	517

Figure_Apx D-2. Elasticities (> 0.05) for Parameters Applied in E3	518

FigureApx D-3. Elasticities (> 0.05) for Parameters Applied in P_DER2b	519

FigureApx E-l. SSD Toolbox interface and list of HCoss for each distribution and fitting method using

TCE's algae hazard data (Etterson, 2019)	 523

Figure Apx E-2. All distributions and fitting methods in the SSD Toolbox for TCE's algae hazard data

(Etterson, 2019)	 524

Figure Apx E-3. TCE algae data fit with triangular distribution fit with graphical methods (Etterson,

2019)	 525

Figure Apx E-4. SSD Toolbox interface showing HCoss and P values for each distribution and fitting

method using TCE's acute hazard data (Etterson, 2019)	 526

Figure Apx E-5. AICc for the four distribution options in the SSD Toolbox for TCE's acute hazard data

(Etterson, 2019)	 527

Figure Apx E-6. All distributions and fitting methods in the SSD Toolbox for TCE's acute hazard data

(Etterson, 2019)	 528

Figure Apx E-7. TCE's acute hazard data fit with the normal, logistic, triangular, and Gumbel

distributions fit with maximum likelihood in the SSD Toolbox (Etterson, 2019)	 529

Figure Apx F-l. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit Model for Mortality
from Introduced Infection in Mice Following Inhalation Exposure to TCE (Selgrade and

Gilmour 2010); BMR= 10% Extra Risk	591

Figure Apx F-2. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit Model for Mortality
from Introduced Infection in Mice Following Inhalation Exposure to TCE (Selgrade and

Gilmour 2010); BMR = 5% Extra Risk	593

Figure Apx F-3. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit Model for Mortality
from Introduced Infection in Mice Following Inhalation Exposure to TCE (Selgrade and

Gilmour 2010); BMR = 1% Extra Risk	596

FigureApx H-l. Fixed-effects model, overall association of NHL and exposure to TCE	627

Figure Apx H-2. Random-effects model, overall association of NHL and exposure to TCE	628

Figure Apx H-3. Fixed-effects model, association of NHL and high exposure to TCE	628

Figure Apx H-4. Random-effects model, association of NHL and high exposure to TCE	629

Figure Apx H-5. Fixed-effects model, overall association of kidney cancer and	630

Figure Apx H-6. Random-effects model, overall association of kidney cancer and	630

Figure Apx H-7. Fixed-effects model, overall association of liver cancer and	631

Figure Apx H-8. Random-effects model, overall association of liver cancer and	632

Figure Apx H-9. Fixed-effects model, overall association of NHL and exposure to TCE, study of

Vlaanderen et al. (2013) omitted	635

Figure Apx H-10. Fixed-effects model, association of NHL and high exposure to TCE, study of

Vlaanderen et al. (2013) omitted	635

Figure Apx H-l 1. Fixed-effects model, overall association of kidney cancer and	636

Figure Apx H-12. Fixed-effects model, overall association of liver cancer and	636

FigureApx H-13. Fixed-effects model, overall association of NHL and	637

Figure Apx H-14. Fixed-effects model, overall association of kidney cancer and	638

Figure Apx H-l 5. Fixed-effects model, overall association of liver cancer and	638

Figure_Apx H-l6. Funnel plots for publication bias	640

Figure Apx K-l. The Near-Field/Far-Field Model as Applied to the Open-Top Vapor Degreasing Near-
Field/Far-Field Inhalation Exposure Model and the Cold Cleaning Near-Field/Far-Field

Inhalation Exposure Model	655

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FigureApx K-2. The Near-Field/Far-Field Model as Applied to the Conveyorized Degreasing Near-

Field/Far-Field Inhalation Exposure Model	656

Figure Apx K-3. The Near-Field/Far-Field Model as Applied to the Web Degreasing Near-Field/Far-

Field Inhalation Exposure Model	656

Figure Apx L-l. The Near-Field/Far-Field Model as Applied to the Brake Servicing Near-Field/Far-

Field Inhalation Exposure Model	671

Figure Apx M-l. The Near-Field/Far-Field Model as Applied to the Spot Cleaning Near-Field/Far-Field

Inhalation Exposure Model	683

Figure Apx P-l. Schematic of the Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation

Exposure Model	707

Figure Apx P-2. Belt/Strip Conveyorized Vapor Degreasing Schematic of the Conveyorized Degreasing

Near-Field/Far-Field Inhalation Exposure Model	714

FigureApx P-3. Schematic of the Web Degreasing Near-Field/Far-Field Inhalation Exposure Model716
Figure Apx P-4. Schematic of the Cold Cleaning Near-Field/Far-Field Inhalation Exposure Model ..718

Figure_Apx P-5. Schematic of the Near-Field/Far-Field Model for Aerosol Degreasing	721

Figure_Apx P-6. Schematic of the Near-Field/Far-Field Model for Spot Cleaning	733

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ACKNOWLEDGEMENTS

This report was developed by the United States Environmental Protection Agency (EPA), Office of
Chemical Safety and Pollution Prevention (OCSPP), Office of Pollution Prevention and Toxics (OPPT).

Acknowledgements

The EPA Assessment Team gratefully acknowledges participation and/or input from Intra-agency
reviewers that included multiple offices within EPA, Inter-agency reviewers that included multiple
Federal agencies, and assistance from EPA contractors: GDIT (Contract No. CIO-SP3,
HHSN316201200013W), ERG (Contract No. EP-W-12-006), Versar (Contract No. EP-W-17-006), ICF
(Contract No. EPC14001 and 68HERC19D0003), SRC (Contract No. EP-W-12-003 and
68HERH19D0022), and Abt Associates (Contract No. EPW-16-009).

EPA also acknowledges the contributions of Masashi Ando from the National Institute of Technology
and Evaluation (NITE) in Japan for his contribution to the systematic review of environmental exposure
data.

Docket

Supporting information can be found in public docket (Docket: EPA-HQ-OPPT-2019-0500).
Disclaimer

Reference herein to any specific commercial products, process or service by trade name, trademark,
manufacturer or otherwise does not constitute or imply its endorsement, recommendation or favoring by
the United States Government.

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ABBREVIATIONS

°c

80

ACGM

AEGL

ADD

AF

AQS

ATCM

atm

ATSDR

BAF

BCF

BIOWIN

BW34

CAA

CARB

CASRN

CBI

CCR

CDC

CDR

CEHD

CEM

CEPA

CERCLA

CFC

CFR

CH

CHIRP
ChV

cm3
CNS

coc
cou

CPCat

CSCL

CWA

CYP

DCA

DCVC

DCVG

DEVL

DIY

DMR

ECso

ECCC

ECHA

Degrees Celsius
Vacuum Permittivity

American Conference of Governmental Industrial Hygienists

Acute Exposure Guideline Level

Average Daily Dose

Assessment Factor

Air Quality System

Airborne Toxic Control Measure

Atmosphere(s)

Agency for Toxic Substances and Disease Registries
Bioaccumulation Factor
Bioconcentration Factor

The EPI Suite™ module that predicts biodegradation rates
body weight314
Clean Air Act

California Air Resources Board

Chemical Abstracts Service Registry Number

Confidential Business Information

California Code of Regulations

Centers for Disease Control and Prevention

Chemical Data Reporting

Chemical Exposure Health Data

Consumer Exposure Model

Canadian Environmental Protection Act

Comprehensive Environmental Response, Compensation, and Liability Act

Chi orofluorocarb on

Code of Federal Regulations

Chloral Hydrate

Chemical Risk Information Platform
Chronic Value
Cubic Centimeter(s)

Central Nervous System
Concentration of Concern
Conditions of Use
Chemical and Product Categories
Chemical Substances Control Law
Clean Water Act
Cytochrome P450
Dichloroacetic acid
S-dichlorovinyl-L-cysteine
S -di chl orovinyl -glutathi one
Dermal Exposure to Volatile Liquids
Do-It-Yourself
Discharge Monitoring Report

Effect concentration at which 50% of test organisms exhibit an effect
Environment and Climate Change Canada
European Chemicals Agency

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967

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969

970

971

972

973

974

975

976

977

978

979

980

981

982

983

984

985

986

987

988

989

990

991

992

993

994

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996

997

998

999

1000

1001

1002

1003

1004

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EDC

Ethylene Dichloride

E-FAST

Exposure and Fate Assessment Screening Tool

EG

Effluent Guidelines

EPA

Environmental Protection Agency

EPCRA

Emergency Planning and Community Right-to-Know Act

EPI Suite™

Estimation Program Interface Suite™

ESD

Emission Scenario Document

EU

European Union

FDA

Food and Drug Administration

FFDCA

Federal Food, Drug, and Cosmetic Act

FIFRA

Federal Insecticide, Fungicide, and Rodenticide Act

FR

Federal Register

g

Gram(s)

GACT

Generally Available Control Technology

GS

Generic Scenario

GSH

Glutathione

GST

Glutathione-S-transferase

HAP

Hazardous Air Pollutant

HCFC

Hy drochl orofluorocarb on

HC1

Hydrochloric Acid

HC05

Hazardous Concentration threshold for 5% of species in a Species Sensitivity Distribution

HEC

Human Equivalent Concentration

HED

Human Equivalent Dose

HFC

Hydrofluorocarbon

HHE

Health Hazard Evaluation

HPV

High Production Volume

Hr

Hour

IARC

International Agency for Research on Cancer

ICIS

Integrated Compliance Information System

IDLH

Immediately Dangerous to Life and Health

IMIS

Integrated Management Information System

IRIS

Integrated Risk Information System

ISHA

Industrial Safety and Health Act

ISOR

Initial Statement of Reasons

IUR

Inhalation Unit Risk

Koc

Soil Organic Carbon-Water Partitioning Coefficient

Kow

Octanol/Water Partition Coefficient

kg

Kilogram(s)

L

Liter(s)

lb

Pound(s)

LCso

Lethal Concentration at which 50% of test organisms die

LOAEL

Lowest-observed-adverse-effect-level

LOEC

Lowest-observable-effect Concentration

3

m

Cubic Meter(s)

MACT

Maximum Achievable Control Technology

MATC

Maximum Acceptable Toxicant Concentration

MCCEM

Multi-Chamber Concentration and Exposure Model

MCL

Maximum Contaminant Level

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1015

1016

1017

1018

1019

1020

1021

1022

1023

1024

1025

1026

1027

1028

1029

1030

1031

1032

1033

1034

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1036

1037

1038

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MCLG

Maximum Contaminant Level Goal

mg

Milligram(s)

mmHg

Millimeter(s) of Mercury

MOA

Mode of Action

mPas

Millipascal(s)-Second

MSDS

Material Safety Data Sheet

MSW

Municipal Solid Waste

NAICS

North American Industry Classification System

NATA

National Scale Air-Toxics Assessment

NCEA

National Center for Environmental Assessment

NICNAS

Australia National Industrial Chemicals Notification and Assessment Scheme

NCP

National Contingency Plan

NEI

National Emissions Inventory

NESHAP

National Emission Standards for Hazardous Air Pollutants

NHANES

National Health and Nutrition Examination Survey

NICNAS

National Industrial Chemicals Notification and Assessment Scheme

NIH

National Institute of Health

NICNAS

National Industrial Chemicals Notification and Assessment Scheme

NIOSH

National Institute for Occupational Safety and Health

NITE

National Institute of Technology and Evaluation

NOAEL

No-Observed-Adverse-Effect-Level

NOEC

No-observable-effect Concentration

NPDES

National Pollutant Discharge Elimination System

NPDWR

National Primary Drinking Water Regulation

NRC

National Research Council

NTP

National Toxicology Program

NWIS

National Water Information System

OCPSF

Organic Chemicals, Plastics and Synthetic Fibers

OCSPP

Office of Chemical Safety and Pollution Prevention

OECD

Organization for Economic Co-operation and Development

OEHHA

Office of Environmental Health Hazard Assessment

OES

Occupational Exposure Scenario

OEL

Occupational Exposure Limits

ONU

Occupational Non-User

OPPT

Office of Pollution Prevention and Toxics

OR

Odds Ratio

OSHA

Occupational Safety and Health Administration

OSF

Oral Slope Factor

OST

Office of Science and Technology

OTVD

Open-Top Vapor Degreaser

OW

Office of Water

PBPK

Physiologically-Based Pharmacokinetic

PBZ

Personal Breathing Zone

PCE

Tetrachloroethylene

PECO

Population, Exposure, Comparator, and Outcome

PEL

Permissible Exposure Limit

PESS

Potentially Exposed or Susceptible Subpopulations

POD

Point of Departure

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POTW

Publicly Owned Treatment Works

ppb

Part(s) per Billion

PPE

Personal Protective Equipment

ppm

Part(s) per Million

PSD

Particle Size Distribution

PV

Production Volume

QC

Quality Control

QSAR

Quantitative Structure Activity Relationship

RCRA

Resource Conservation and Recovery Act

REACH

Registration, Evaluation, Authorisation and Restriction of Chemicals

REL

Relative Exposure Limit

RR

Relative Risk

RTR

Risk and Technology Review

SDS

Safety Data Sheet

SDWA

Safe Drinking Water Act

SIDS

Screening Information Dataset

SNUN

Significant New Use Notice

SNUR

Significant New Use Rule

SOCMI

Synthetic Organic Chemical Manufacturing Industry

SPARC

SPARC Performs Automated Reasoning in Chemistry

SpERC

Specific Environmental Release Categories

STEL

Short-Term Exposure Limit

STP model

Sewage Treatment Plant model

STORET

STOrage and RETrieval

SSD

Species Sensitivity Distribution

TCCR

Transparent, clear, consistent, and reasonable

TCA

Trichloroacetic acid

TCE

Trichl oroethyl ene

TCOH

Trichloroethanol

TCOG

Trichloroethanol, gluuronide conjugate

TNSSS

Targeted National Sewage Sludge Survey

TLV

Threshold Limit Value

TRI

Toxics Release Inventory

TSCA

Toxic Substances Control Act

TWA

Time Weighted Average

UIC

Underground Injection Control

U.S.

United States

UV

Ultraviolet

USGS

United States Geological Survey

VOC

Volatile Organic Compound

VP

Vapor Pressure

Yr

Year(s)

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EXECUTIVE SUMMARY

This draft risk evaluation for trichloroethylene was performed in accordance with the Frank R.
Lautenberg Chemical Safety for the 21st Century Act and is being disseminated for public comment
and peer review. The Frank R. Lautenberg Chemical Safety for the 21st Century Act amended the
Toxic Substances Control Act (TSCA), the Nation's primary chemicals management law, in June
2016. As per EPA's final rule, Procedures for Chemical Risk Evaluation Under the Amended Toxic
Substances Control Act (82 FR 33726). EPA is taking comment on this draft, and will also obtain peer
review on this draft risk evaluation for trichloroethylene. All conclusions, findings, and determinations
in this document are preliminary and subject to comment. The final risk evaluation may change in
response to public comments received on the draft risk evaluation and/or in response to peer review,
which itself may be informed by public comments. The preliminary conclusions, findings, and
determinations in this draft risk evaluation are for the purpose of identifying whether the chemical
substance presents unreasonable risk or no unreasonable risk under the conditions of use, in
accordance with TSCA section 6, and are not intended to represent any findings under TSCA
section 7.

TSCA § 26(h) and (i) require EPA to use scientific information, technical procedures, measures,
methods, protocols, methodologies and models consistent with the best available science and to base
its decisions on the weight of the scientific evidence. To meet these TSCA § 26 science standards,
EPA used the TSCA systematic review process described in the Application of Systematic Review in
TSCA Risk Evaluations document (	0- The data collection, evaluation, and integration

stages of the systematic review process are used to develop the exposure, fate, and hazard assessments
for risk evaluations.

Trichloroethylene has a wide-range of uses in consumer and commercial products and in industry. An
estimated 83.6% of TCE's annual production volume is used as an intermediate in the manufacture of
the hydrofluorocarbon, HFC-134a, an alternative to the refrigerant chlorofluorocarbon, CFC-12.
Another 14.7% of TCE production volume is used as a degreasing solvent, leaving approximately 1.7%
for other uses. The total aggregate production volume decreased from 220.5 to 171.9 million pounds
between 2012 and 2015.

EPA evaluated TCE's conditions of use (COUs), including the following categories of use: solvent for
cleaning and degreasing, lubricants and greases, adhesives and sealants, functional fluids in a closed
system, paints and coatings, laundry and dishwashing products, arts, crafts and hobby materials, and
process solvent recycling and worker handling of wastes. Trichloroethylene is subject to federal and
state regulations and reporting requirements. Trichloroethylene has been a reportable Toxics Release
Inventory (TRI) chemical under Section 313 of the Emergency Planning and Community Right-to-
Know Act (EPCRA) since 1987. It is designated as a Hazardous Air Pollutant (HAP) under the Clean
Air Act (CAA), is a hazardous substance under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), and is regulated as a hazardous waste under the Resource
Conservation and Recovery Act (RCRA). It is subject to National Primary Drinking Water Regulations
(NPDWR) under the Safe Drinking Water Act (SDWA) and designated as a toxic pollutant under the
Clean Water Act (CWA) and as such is subject to effluent limitations. Under TSCA, EPA previously
assessed risks from use of trichloroethylene in commercial solvent degreasing (aerosol and vapor),
consumer use as a spray applied protective coating for arts and crafts and commercial use as a spot
remover at dry cleaning facilities (	).

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Approach

EPA used reasonably available information (defined in 40 Code of Federal Regulations (CFR) 702.33
as "information that EPA possesses, or can reasonably obtain and synthesize for use in risk
evaluations, considering the deadlines for completing the evaluation "), in a fit-for-purpose approach,
to develop a risk evaluation that relies on the best available science and is based on the weight of the
scientific evidence. EPA used previous analyses as a starting point for identifying key and supporting
studies to inform the exposure, fate, and hazard assessments. EPA also evaluated other studies
published since the publication of previous analyses. EPA reviewed the information and evaluated the
quality of the methods and reporting of results of the individual studies using the evaluation strategies
described in Application of Systematic Review in TSCA Risk Evaluations (	18b).

In the scope document and problem formulation, EPA identified the conditions of use and presented
three conceptual models and an analysis plan for this draft risk evaluation. These have been carried into
the draft risk evaluation where EPA has evaluated the risk to the environment and human health, using
both monitoring data and modeling approaches, for the conditions of use (identified in Section 1.4.1 of
this draft risk evaluation). EPA quantitatively evaluated the risk to aquatic species from exposure to
surface water. EPA evaluated the risk to workers, from inhalation and dermal exposures, and
occupational non-users (ONUs)1, from inhalation exposures, by comparing the estimated exposures to
acute and chronic human health hazards. EPA also evaluated the risk to consumers, from inhalation and
dermal exposures, and bystanders, from inhalation exposures, by comparing the estimated exposures to
acute human health hazards.

EPA used environmental fate parameters, physical-chemical properties, modeling, and monitoring data
to assess ambient water exposure to aquatic organisms. While trichloroethylene is present in various
environmental media, such as groundwater, surface water, and air, EPA determined during problem
formulation that no further analysis beyond what was presented in the problem formulation document
(Section 2.5.3.3 in (U .S. EPA. 2018dV) would be done for environmental exposure pathways for land
application of biosolids and sediment, and water or soil pathways for terrestrial organisms, in this draft
risk evaluation because TCE is not anticipated to partition to biosolids during wastewater treatment. It
is expected to primarily volatilize. However, exposures to aquatic organisms from ambient surface
water, are assessed and presented in this draft risk evaluation. These analyses are described in Sections
2.1 and 2.2.

EPA reviewed the environmental hazard data using the data quality review evaluation metrics and the
rating criteria described in the Application of Systematic Review in TSCA Risk Evaluations (
2018b). As stated in Section 3.1, the reasonably available environmental hazard data indicate that TCE
presents hazard to aquatic organisms. For acute exposures, aquatic invertebrates are the most sensitive
species with toxicity values ranging from 7.8 mg/L to 33.85 mg/L (resulting in a geometric mean of 16
mg/L). For chronic exposures, toxicity values for fish and aquatic invertebrates are as low as 7.88 mg/L
and 9.2 mg/L, respectively. The data also indicated that TCE presents hazard for aquatic plants, with
toxicity values in algae as low as 0.03 mg/L, and a wide range in toxicity between algae species. TCE is
not expected to accumulate in aquatic organisms.

EPA evaluated exposures to trichloroethylene in occupational and consumer settings for the conditions
of use included in the scope of the risk evaluation, listed in Section 1.4. In occupational settings, EPA
evaluated acute and chronic inhalation exposures to workers and ONUs, and acute and chronic dermal

1 ONUs are workers who do not directly handle trichloroethylene but perform work in an area where trichloroethylene is
present.

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exposures to workers. EPA used inhalation monitoring data from literature sources, where reasonably
available and that met data evaluation criteria, as well as, modeling approaches, where reasonably
available, to estimate potential inhalation exposures. Dermal doses for workers were estimated in these
scenarios since dermal monitoring data was not reasonably available. In consumer settings, EPA
evaluated acute inhalation exposures to both consumers and bystanders, and acute dermal exposures to
consumers. Inhalation exposures and dermal doses for consumers and bystanders in these scenarios were
estimated since inhalation and dermal monitoring data were not reasonably available. These analyses are
described in Section 2.3 of this draft risk evaluation.

EPA evaluated reasonably available information for human health hazards and identified hazard
endpoints including acute and chronic toxicity for non-cancer effects and cancer, as described in Section
3.2. EPA used the Framework for Human Health Risk Assessment to Inform Decision Making (U.S.
E 14a) to evaluate, extract, and integrate trichloroethylene's human health hazard and dose-
response information. EPA reviewed key and supporting information from previous hazard assessments
ITSCA Work Plan Chemical Risk Assessment 1'ix'liloroethylene: Decreasing. Spot Cleaning am! \&
Cuff; 1 ^ (1 c. ! 1* \ JO I lb), < < sicological Review o! < i i.-liloroethyten^ 0 v >1 P \ . and other
national and international assessments listed in Table 1-3], (however all data sources from prior
assessments were independently reviewed for this risk evaluation). EPA also screened and evaluated
studies that were published since these reviews (i.e., from 2010 - 2017, in addition to select studies
published after completion of the literature search).

EPA developed a hazard and dose-response analysis using endpoints observed in inhalation and oral
hazard studies, evaluated the weight of the scientific evidence considering EPA and National Research
Council (NRC) risk assessment guidance, and selected the points of departure (POD) for acute, chronic
and non-cancer endpoints, and inhalation unit risk (IUR) and cancer slope factors (CSF) for cancer risk
estimates. Health hazards of TCE described and reviewed in this risk evaluation include: acute overt
toxicity, liver toxicity, kidney toxicity, neurotoxicity, immunotoxicity (including sensitization),
reproductive toxicity, developmental toxicity, and cancer. Following dose-response analysis,
representative PODs were identified for multiple non-cancer endpoints within the domains of liver
toxicity, kidney toxicity, neurotoxicity, immunotoxicity, reproductive toxicity, and developmental
toxicity.

For cancer, EPA performed meta-analyses in order to statistically evaluate the epidemiological data for
non-Hodgkin Lymphoma (NHL), kidney cancer, and liver cancer. EPA utilized similar methodology as
was employed in the 201 1 EPA TCE IRIS Assessment (	) and included sensitivity

analyses, as needed, to partition the results based on both heterogeneity and study quality. See Appendix
H for full details and results. The 2019 meta-analysis of all relevant studies examining kidney cancer,
liver cancer, or NHL (Appendix H) concluded that there is a statistical significant association between
TCE exposure and increased incidence of all three cancers. For context, this was the same conclusion as
the previous EPA meta-analysis in the 2011 IRIS Assessment (	), which evaluated older

literature than the current assessment. Therefore, EPA utilized the same inhalation unit risk and oral
slope factor estimates as were derived in (	) and cited in the 2014 TSCA Work Plan

Chemical Risk Assessment (	j). A linear non-threshold assumption was applied to the

TCE cancer dose-response analysis because there is sufficient evidence that TCE-induced kidney cancer
operates primarily through a mutagenic mode of action while it cannot be ruled out for the other two
cancer types.

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Risk Characterization

Environmental Risk: For environmental risk, EPA utilized a risk quotient (RQ) to compare the
environmental concentration to the effect level to characterize the risk to aquatic organisms. EPA
included a qualitive assessment describing trichloroethylene exposure from sediments for aquatic
organisms, and land-applied biosolids, water, and soil for terrestrial organisms. Trichloroethylene is not
expected to accumulate in sediments, and is expected to be mobile in soil, and migrate to water or
volatilize to air. The results of the risk characterization are in Section 4.1, including a table (Table 4-1).
that summarizes the RQs for acute and chronic risks. Surface water concentrations of TCE were
modeled for 214 releases.

EPA identified the expected environmental exposures for aquatic species under the conditions of use in
the scope of the risk evaluation. Estimated releases from specific facilities result in modeled surface
water concentrations that exceed the aquatic benchmark (RQ > 1) for either chronic, acute, and/ or
algae concentrations of concern for the following conditions of use in various locations (see Table
4-1): processing as a reactant; open top vapor degreasing; repackaging; adhesives; sealants; paints and
coatings; industrial processing aid; other industrial uses; other commercial uses; process solvent
recycling and worker handling of wastes; and waste water treatment plants. Details of these estimates
are in Section 4.1.2.

Qualitative consideration of the physical-chemical and fate characteristics, as well as consideration of
the conditions of use for TCE indicated limited presence in terrestrial environments and aquatic
sediments (Section 4.1.3 and 4.1.4). Therefore EPA did not find risks for sediment or terrestrial
organisms.

Human Health Risks: Risks were estimated following both acute and chronic exposure for
representative endpoints from every hazard domain.

For workers and ONUs, EPA estimated potential cancer risk from chronic exposures to
trichloroethylene using inhalation unit risk or dermal cancer slope factor values multiplied by the
chronic exposure for each COU. For workers and ONUs, EPA also estimated potential non-cancer
risks resulting from acute and chronic inhalation and dermal exposures using a Margin of Exposure
(MOE) approach. For workers, EPA estimated risks using several occupational exposure scenarios,
with scenario-specific assumptions regarding the expected use of personal protective equipment (PPE)
for respiratory and dermal exposures for workers directly handling trichloroethylene. More
information on respiratory and dermal protection, including EPA's approach regarding the
occupational exposure scenarios for trichloroethylene, is in Section 2.3.1.

For the majority of exposure scenarios, risks to workers were identified for multiple endpoints in both
acute and chronic exposure scenarios. Based on the most robust and well-supported PODs selected from
among the most sensitive acute and chronic endpoints, acute and chronic non-cancer and cancer risks
were indicated for all exposure scenarios and occupational conditions of use under high-end2 inhalation
exposure levels. Non-cancer risks following chronic exposure were also identified for all exposure
scenarios at high-end exposure levels with expected use of respiratory protection up to APF = 50. When

2 A high-end is assumed to be representative of occupational exposures that occur at probabilities above the 90th percentile
but below the exposure of the individual with the highest exposure. EPA provided results at the 95th percentile when
available.

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only considering the central tendency3 inhalation exposure level, risks were not identified for three out
of 18 occupational exposure scenarios. Acute and chronic non-cancer and cancer risks were indicated
for all exposure scenarios and occupational conditions of use under both high-end and central tendency
dermal exposure levels. Risks are still identified for all exposure scenarios (at high-end exposure levels
following acute exposure and at both exposure levels following chronic exposure) when gloves are worn
even when assuming the maximum applicable glove protection (either PF 10 or 20).

ONUs are expected to have lower exposure levels than workers in most instances but exposures could
not always be quantified based on reasonably available data and risk estimates for ONUs may be similar
to workers in some settings. Therefore, for those instances where monitoring data or modeling did not
distinguish between worker and far-field ONU inhalation exposure estimates, EPA considered the
worker risk estimates when determining far-field ONU risk. There is significant uncertainty in these
ONU inhalation risk estimates. While the difference between the exposures of ONUs and the exposures
of workers directly handling TCE generally cannot be quantified, ONU inhalation exposures are
expected to be lower than inhalation exposures for workers directly handling the chemical. In these
instances, EPA considered the ONU exposures to be equal to the central tendency risk estimates for
workers when determining ONU risk attributable to inhalation. While this is likely health protective as it
assumes ONU exposure is as high as it is for the majority of workers (greater numbers are likely to be
exposed near the middle of the distribution), this is uncertain. Dermal exposures are not expected
because ONUs do not typically directly handle TCE, nor they are in the immediate proximity of TCE.

Based on central-tendency exposure levels, acute and chronic non-cancer risks to ONUs were indicated
for the majority of exposure scenarios. ONUs are not assumed to be using PPE to reduce exposures to
trichloroethylene used in their vicinity. ONUs are not expected to be dermally exposed to
trichloroethylene and therefore dermal risks to ONUs were not assessed. EPA's estimates for ONU risks
for each occupational exposure scenario are presented alongside worker risk estimates in Section 4.2.2
and Table 4-54 in Section 4.5.1.0.

For consumers and bystanders for consumer use, EPA estimated non-cancer risks resulting from acute
inhalation or dermal exposures (applicable to consumers only) that were modeled with a range of user
intensities, described in detail in Section 2.3.2. Bystanders are assumed to not have direct dermal
contact with TCE. Based on reasonably available information, EPA determined that consumers or
bystanders would not use PPE and that all exposures would be acute, rather than chronic.

For consumers, risks were identified for multiple acute endpoints acute risks were indicated for all
consumer conditions of use except Pepper Spray at both medium and high-intensity acute inhalation
and dermal consumer exposure scenarios. Acute risks were also indicated for most conditions of use
for bystanders at both medium and high-intensity acute inhalation levels. EPA's estimates for
consumer and bystander risks for each consumer use exposure scenario are presented in Section 4.2.3
and summarized in Table 4-55 in Section 4.5.2.2.

Uncertainties: Key assumptions and uncertainties in the environmental risk estimation include
uncertainties regarding the hazard data for aquatic species and surface water concentrations.

Additionally the reasonably available environmental monitoring data was limited temporally and

3 A central tendency is assumed to be representative of occupational exposures in the center of the distribution for a given
condition of use. For risk evaluation, EPA used the 50th percentile (median), mean (arithmetic or geometric), mode, or
midpoint values of a distribution as representative of the central tendency scenario.

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geographically.

For the human health risk estimation, key assumptions and uncertainties are related to data on
exposures, exposure model input parameters, and the estimates for ONU inhalation exposures for COUs
in which monitoring data or probabilistic modeling data was not reasonably available. Additional
sources of uncertainty related to human health hazard include selection of the appropriate
Physiologically-Based Pharmacokinetic (PBPK) dose-metric for each endpoint, the dose-response for
the congenital heart defect endpoint, and the adjustment of the cancer PODs to account for cancer at
multiple sites. Assumptions and key sources of uncertainty in the risk characterization are detailed in
Section 4.3.

Potentially Exposed or Susceptible Subpopulations (PESS): TSCA § 6(b)(4) requires that EPA conduct
a risk evaluation to "determine whether a chemical substance presents an unreasonable risk of injury to
health or the environment, without consideration of cost or other non-risk factors, including an
unreasonable risk to a potentially exposed or susceptible subpopulation identified as relevant to the risk
evaluation by the Administrator, under the conditions of use'' TSCA § 3(12) states that "the term
'potentially exposed or susceptible subpopulation' means a group of individuals within the general
population identified by the Administrator who, due to either greater susceptibility or greater exposure,
may be at greater risk than the general population of adverse health effects from exposure to a chemical
substance or mixture, such as infants, children, pregnant women, workers, or the elderly."

In developing the risk evaluation, EPA analyzed the reasonably available information to ascertain
whether some human receptor groups may have greater exposure or greater susceptibility than the
general population to the hazard posed by a chemical. For consideration of the potentially exposed
groups, EPA considered trichloroethylene exposures to be higher among workers using
trichloroethylene and ONUs in the vicinity of trichloroethylene use than the exposures experienced by
the general population. Risk estimates were also provided separately for ONUs when sufficient data
were reasonably available. EPA was unable to provide separate risk estimates when insufficient
information was reasonably available for quantifying ONU exposure. EPA considered the central
tendency risk estimate when determining ONU risk for those conditions of use for which ONU
exposures were not separately estimated. Consumer risk estimates were provided for low, medium, and
high intensities of use, accounting for differences in duration, weight fraction, and mass used. Dermal
risk estimates were calculated for both average adult workers and women of childbearing age. The use
of the 99th percentile Human Equivalent Concentration/Dose (HEC/HED)99 POD values derived from
relevant (PBPK) dose metrics also account for the vast majority of toxicokinetic variation across the
population. By relying on the 99th percentile output of the PBPK model, these values are expected to
be protective of particularly susceptible subpopulations, including those with genetic polymorphisms
resulting in increased activity of bioactivating enzymes. While there may not be a risk for all endpoints
to all individuals or to an individual at all times, assessment of risks for all relevant endpoints using
toxicokinetic values for the most sensitive 1% of the population is expected to sufficiently cover any
particularly susceptible subpopulations.

Aggregate and Sentinel Exposures Section 2605(b)(4)(F)(ii) of TSCA requires the EPA, as a part of the
risk evaluation, to describe whether aggregate or sentinel exposures under the conditions of use were
considered and the basis for their consideration. The EPA has defined aggregate exposure as "the
combined exposures to an individual from a single chemical substance across multiple routes and
across multiple pathways (40 CFR § 702.33)." Exposures to trichloroethylene were evaluated by
inhalation and dermal routes separately. Inhalation and dermal exposures are assumed to occur
simultaneously for workers and consumers. EPA chose not to employ simple additivity of exposure

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pathways at this time within a condition of use because of the uncertainties present in the current
exposure estimation procedures, which may may lead to an underestimate or overestimate of the actual
total exposure.

The EPA defines sentinel exposure as "the exposure to a single chemical substance that represents the
plausible upper bound of exposure relative to all other exposures within a broad category of similar or
related exposures (40 CFR § 702.33)." In this risk evaluation, the EPA considered sentinel exposure the
highest exposure given the details of the conditions of use and the potential exposure scenarios. EPA
considered sentinel exposures by considering risks to populations who may have upper bound (e.g.,
high-end, high intensities of use) exposures.

Risk Determination

In each risk evaluation under TSCA section 6(b), EPA determines whether a chemical substance
presents an unreasonable risk of injury to health or the environment, under the conditions of use. The
determination does not consider costs or other non-risk factors. In making this determination, EPA
considers relevant risk-related factors, including, but not limited to: the effects of the chemical substance
on health and human exposure to such substance under the conditions of use (including cancer and non-
cancer risks); the effects of the chemical substance on the environment and environmental exposure
under the conditions of use; the population exposed (including any potentially exposed or susceptible
subpopulations); the severity of hazard (including the nature of the hazard, the irreversibility of the
hazard); and uncertainties. EPA also takes into consideration the Agency's confidence in the data used
in the risk estimate. This includes an evaluation of the strengths, limitations, and uncertainties associated
with the information used to inform the risk estimate and the risk characterization. The rationale for the
risk determination is discussed in Section 5.1.

Environmental Risks: EPA identified risks from acute and chronic exposures for aquatic organisms (e.g.,
aquatic invertebrates and fish) near two facilities releasing TCE to surface water. One facility had an
acute RQ greater than 1 (RQ = 3.11), exceeding the acute COC of 3,200 ppb and indicating risk to
aquatic organisms from acute exposures. This facility is one of 59 facilities modeled by EPA that use
TCE for open-top vapor degreasing (see Section 4.5.1). This facility and one other facility (one of 11
facilities that process TCE as a reactant) had chronic RQs greater than 1, exceeding the chronic COC of
788 ppb for 20 days (see Section 4.5.1). Monitored data from the Water Quality Portal and grey
literature show no exceedances of the acute COC and the chronic COC in ambient water. Monitored
data from literature showed some exceedances of the algae COC of 3 ppb in ambient water; however,
the data show no exceedances of the algae COC of 52,000 ppb. Therefore, EPA did not identify risks for
acute or chronic exposure durations in ambient water for areas where monitored data were reasonably
available. Given the uncertainties in the modeling data and exceedance of the acute RQ for only one data
point and of the chronic RQ for only two data points out of 70 facilities modeled, EPA does not consider
these risks unreasonable (see Section 5.1).

Risks of Injury to Health: EPA's determination of unreasonable risk for specific conditions of use of
TCE listed below are based on health risks to workers, occupational non-users, consumers, or bystanders
from consumer use. As described below, risks to general population were not relevant for these
conditions of use. TCE has a large database of human health toxicity data. For each hazard domain there
are several endpoints, and often a single endpoint was examined by multiple studies. Risks from acute
exposures include developmental toxicity and pulmonary immunotoxicity. For chronic exposures, EPA
identified risks of non-cancer effects (liver toxicity, kidney toxicity, neurotoxicity, immunotoxicity,

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reproductive toxicity, and developmental toxicity) as well as cancers of liver, kidney, and non-Hodgkin
Lymphoma.

Risk to the General Population: General population exposures to TCE may occur from industrial and/ or
commercial uses; industrial releases to air, water or land; and other conditions of use. As part of the
problem formulation for TCE, EPA found those exposure pathways are covered under the jurisdiction of
other environmental statutes, administered by EPA, which adequately assess and effectively manage
those exposures, i.e., CAA, SDWA, CWA, and RCRA. EPA believes this TSCA risk evaluation should
focus on those exposure pathways associated with TSCA conditions of use that are not subject to the
regulatory regimes discussed above because those pathways are likely to represent the greatest areas of
concern to EPA. Therefore, EPA did not evaluate hazards or exposures to the general population in this
risk evaluation, and there is no risk determination for the general population (	).

Risk to Workers: EPA evaluated workers' acute and chronic inhalation and dermal occupational
exposures for cancer and non-cancer risks and determined whether any risks are unreasonable. The
drivers for EPA's determination of unreasonable risk for workers are immunosuppression resulting from
acute inhalation and dermal exposures, autoimmunity resulting from chronic inhalation and dermal
exposures, and cancer resulting from chronic inhalation and dermal exposures. For workers, EPA
determined that all applicable conditions of use for TCE presented unreasonable risks. The
determinations reflect the severity of the effects associated with the occupational exposures to TCE and
incorporate consideration of expected PPE (frequently estimated to be a respirator of APF 10 or 50 and
gloves with PF 5 - 20). A full description of EPA's determination for each condition of use is in Section
5.3.

Risk to Occupational Non-Users (ONUs): EPA evaluated ONU acute and chronic inhalation
occupational exposures for cancer and non-cancer risks and determined whether any risks are
unreasonable. The drivers for EPA's determination of unreasonable risks to ONUs are
immunosuppression resulting from acute inhalation exposures, autoimmunity resulting from chronic
inhalation exposures, and cancer resulting from chronic inhalation exposures. The determinations reflect
the severity of the effects associated with the occupational exposures to TCE and the expected absence
of PPE for ONUs. For dermal exposures, because ONUs are not expected to be dermally exposed to
TCE, dermal risks to ONUs generally were not evaluated. For inhalation exposures, EPA, where
possible, used monitoring or modeling information to estimate ONU exposures and to describe the risks
separately from directly exposed workers. For some conditions of use, EPA did not separately calculate
risk estimates for ONUs and workers. For these conditions of use, there is uncertainty in the ONU risk
estimates since the data or modeling did not distinguish between worker and ONU inhalation exposure
estimates. ONU inhalation exposures are expected to be lower than inhalation exposures for workers
directly handling the chemical substance; however, the relative exposure of ONUs to workers in these
cases cannot be quantified. To account for this uncertainty, EPA considered the central tendency risk
estimate when determining ONU risk for those conditions of use for which ONU exposures were not
separately estimated, and determined that most of applicable conditions of use present unreasonable
risks. Estimated numbers of occupational non-users are in Section 2.3.1.2.7.

Risk to Consumers: EPA evaluated consumer acute inhalation and dermal exposures for non-cancer
risks and determined whether any risks are unreasonable. The driver for EPA's determination of
unreasonable risk is immunosuppression from acute inhalation and dermal exposures. Generally, risks
for consumers were indicated by acute inhalation and dermal exposure at low, medium, and high
intensity use. For consumers, EPA determined that consumer conditions of use present unreasonable

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risks, except for pepper spray. A full description of EPA's determination for each condition of use is in
Section 5.1.

Risk to Bystanders (from consumer uses): EPA evaluated bystander acute inhalation exposures for non-
cancer risks and determined whether any risks are unreasonable. The driver for EPA's determination of
unreasonable risk is immunosuppression from acute inhalation exposures. Generally, risks for
bystanders were indicated by acute inhalation exposure scenarios at low, medium, and high intensity
use. Because bystanders are not expected to be dermally exposed to TCE, dermal non-cancer risks to
bystanders were not identified. For bystanders, EPA determined that consumer conditions of use present
unreasonable risks, except for pepper spray. A full description of EPA's determination for each
condition of use is in Section 5.1.

Summary of risk determinations:

EPA's preliminary determination regarding environmental risks are summarized above and presented in
more detail in Section 5.1.

EPA has preliminarily determined that the following condition of use of TCE does not present an
unreasonable risk of injury under any scenarios. The details of this determination are presented in Table
5-1 in Section 5.2.

Conditions of Use that Do Not Present an Unreasonable Risk

• Pepper Spray (consumers and bystanders)

EPA has preliminarily determined that the following conditions of use of TCE present an unreasonable
risk of injury to health to workers (including, in some cases, occupational non-users) or to consumers
(including, in some cases, bystanders). The details of these determinations are presented in Table 5-1 in
Section 5.2.

Manufacturing that Presents an Unreasonable Risk

•	Domestic manufacture

•	Import (including repackaging and loading/unloading)

Processing that Presents an Unreasonable Risk

•	Processing as a reactant/intermediate

•	Incorporation into a formulation, mixture or reaction product (solvents for cleaning or
degreasing)

•	Incorporation into a formulation, mixture or reaction product (adhesives and sealant chemicals)

•	Incorporation into a formulation, mixture or reaction product (solvents which become part of
product formulation or mixture)

•	Incorporation into articles

•	Repackaging

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•	Recycling

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Distribution that Presents an Unreasonable Risk

•	Distribution

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Industrial/Commercial Uses that Present an Unreasonable Risk

•	As a solvent for batch vapor degreasing (open-top)

•	As a solvent for batch vapor degreasing (closed-loop)

•	As a solvent for in-line vapor degreasing (conveyorized)

•	As a solvent for in-line vapor degreasing (web-cleaner)

•	As a solvent for cold cleaning

•	As a solvent for aerosol spray degreaser/cleaner

•	As a solvent for mold release

•	As a lubricant and grease in tap and die fluid

•	As a lubricant and grease in penetrating lubricant

•	As an adhesive and sealant in solvent-based adhesives and sealants

•	As an adhesive and sealant in solvent in tire repair cement/sealer

•	As an adhesive and sealant in solvent in mirror edge sealant

•	As a functional fluid in heat exchange fluid

•	In paints and coatings as a diluent in solvent-based paints and coatings

•	In cleaning and furniture care products as carpet cleaner

•	In cleaning and furniture care products as wipe cleaning

•	In laundry and dishwashing products as spot remover

•	In arts, crafts, and hobby materials as fixatives and finishing spray coatings

•	As corrosion inhibitors and anti-scaling agents

•	As processing aids in process solvent use in battery manufacture

•	As processing aids in process solvent used in polymer fiber spinning, fluoroelastomer
manufacture and Alcantara manufacture

•	As processing aids in extraction solvent used in caprolactam manufacture

•	As processing aids in precipitant used in beta-cyclodextrin manufacture

•	As ink, toner and colorant products in toner aid

•	In automotive care products as brake parts cleaner

•	In apparel and footwear care products as shoe polish

•	As hoof polish

•	As gun scrubber

•	As pepper spray

•	Other miscellaneous industrial and commercial uses

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Disposal that Presents an Unreasonable Risk

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•	Disposal

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Consumer I ses Unit Present ;i 11 I nrensonnhle Kisk

•	As a solvent in brake and parts cleaner

•	As a solvent in aerosol electronic degreaser/cleaner

•	As a solvent in liquid electronic degreaser/cleaner

•	As a solvent in aerosol spray degreaser/cleaner

•	As a solvent in liquid degreaser/cleaner

•	As a solvent in aerosol gun scrubber

•	As a solvent in liquid gun scrubber

•	As a solvent in mold release

•	As a solvent in aerosol tire cleaner

•	As a solvent in liquid tire cleaner

•	As a lubricant and grease (tap and die fluid)

•	As a lubricant and grease (penetrating lubricant)

•	As an adhesive and sealant (solvent-based adhesive and sealant)

•	As an adhesive and sealant (mirror edge sealant)

•	As an adhesive and sealant (tire repair cement/sealer)

•	As a cleaning and furniture care product (carpet cleaner)

•	As a cleaning and furniture care product (aerosol spot remover)

•	As a cleaning and furniture care product (liquid spot remover)

•	In arts, crafts, and hobby materials as fixative and finishing spray coating

•	In apparel and footwear products as shoe polish

•	As fabric spray

•	As film cleaner

•	As hoof polish

•	As toner aid

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1 INTRODUCTION

This document presents the draft risk evaluation for trichloroethylene (TCE) under the Frank R.
Lautenberg Chemical Safety for the 21st Century Act which amended the Toxic Substances Control Act,
the Nation's primary chemicals management law, in June 2016.

The EPA published the scope of the risk evaluation for TCE (U.S. EPA. 20171) in June 2017, and the
problem formulation in May, 2018 (	d), which represented the analytical phase of risk

evaluation in which "the purpose for the assessment is articulated, the problem is defined, and a plan for
analyzing and characterizing risk is determined" as described in Section 2.2 of the Framework for
Human Health Risk Assessment to Inform Decision Making. The problem formulation (U.S. EPA.
2018d) presented three conceptual models and an analysis plan. Based on EPA's analysis of the
conditions of use, physical-chemical and fate properties, environmental releases, and exposure
pathways, the problem formulation preliminarily concluded that further analysis was necessary for
exposure pathways to ecological receptors exposed via surface water along with human workers and
consumers. The conclusions of the problem formulation were that no further analysis was necessary in
the risk evaluation for sediment, soil and land-applied biosolid pathways leading to exposure to
terrestrial and aquatic organisms and for water pathways leading to exposure to terrestrial organisms.
Further analysis was not conducted for biosolid, soil and sediment pathways, and for water pathways of
exposure to terrestrial organisms, based on a qualitative assessment of the physical-chemical properties
and fate of trichloroethylene in the environment and a quantitative comparison of hazards and exposures
for aquatic and terrestrial organisms. The qualitative assessment for trichloroethylene is presented in
Appendix E. EPA also excluded from risk evaluation ambient air, drinking water, land disposal, ambient
water, and waste incineration pathways leading to exposures to the general population and terrestrial
organisms since those pathways are regulated under other environmental statutes administered by EPA
which adequately assess and effectively manage exposures. EPA received comments on the published
problem formulation for trichloroethylene and has considered the comments specific to
trichloroethylene, as well as more general comments regarding EPA's chemical risk evaluation approach
for developing the draft risk evaluations for the first 10 chemicals EPA is evaluating.

The EPA indicated in the analysis plan of the problem formulation that it would review the full study
reports obtained for physical and chemical properties, environmental fate properties, environmental
hazard and human health hazard studies. For human exposure pathways, the EPA further analyzed
inhalation exposures to vapors and mists for workers, occupational non-users consumers, and
bystanders. Dermal exposures were analyzed for skin contact with liquids for workers and consumers.
For environmental release pathways, the EPA further analyzed surface water exposure to aquatic
vertebrates, invertebrates, and plants.

In this draft risk evaluation, Section 1.1 presents the basic physical-chemical characteristics of
trichloroethylene, as well as a background on regulatory history, conditions of use, and conceptual
models, with particular emphasis on any changes since the publication of the problem formulation. This
section also includes a discussion of the systematic review process utilized in this draft risk evaluation.
Section 1 provides a discussion and analysis of the exposures, both health and environmental, that can
be expected based on the conditions of use for trichloroethylene. Section 3 discusses environmental and
health hazards of trichloroethylene. Section 4 presents the risk characterization, where EPA integrates
and assesses reasonably available information on health and environmental hazards and exposures, as
required by TSCA (15 U.S.C. 2605(b)(4)(F)). This section also includes a discussion of any
uncertainties and how they impact the draft risk evaluation. Section 5 presents EPA's proposed

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determination of whether the chemical presents an unreasonable risk under the conditions of use, as
required under TSCA (15 U.S.C. 2605(b)(4)).

As per EPA's final rule, Procedures for Chemical Risk Evaluation Under the Amend {c
Substances Control Act (82 FR 33726 (July 20, 2017)), this draft risk evaluation will be subject to both
public comment and peer review, which are distinct but related processes. EPA is providing 60 days for
public comment on any and all aspects of this draft risk evaluation, including the submission of any
additional information that might be relevant to the science underlying the risk evaluation and the
outcome of the systematic review associated with trichloroethylene. This satisfies TSCA (15 U.S.C.
2605(b)(4)(H)), which requires EPA to provide public notice and an opportunity for comment on a draft
risk evaluation prior to publishing a final risk evaluation.

Peer review will be conducted in accordance with EPA's regulatory procedures for chemical risk
evaluations, including using the EPA Peer Review Handbook and other methods consistent with section
26 of TSCA (See 40 CFR 702.45). As explained in the Risk Evaluation Rule (82 FR 33726 (July 20,
2017)), the purpose of peer review is for the independent review of the science underlying the risk
assessment. Peer review will therefore address aspects of the underlying science as outlined in the
charge to the peer review panel such as hazard assessment, assessment of dose-response, exposure
assessment, and risk characterization.

As EPA explained in the Risk Evaluation Rule (82 FR 33726 (July 20, 2017)), it is important for peer
reviewers to consider how the underlying risk evaluation analyses fit together to produce an integrated
risk characterization, which forms the basis of an unreasonable risk determination. EPA believes peer
reviewers will be most effective in this role if they receive the benefit of public comments on draft risk
evaluations prior to peer review. For this reason, and consistent with standard Agency practice, the
public comment period will precede peer review on this draft risk evaluation. The final risk evaluation
may change in response to public comments received on the draft risk evaluation and/or in response to
peer review, which itself may be informed by public comments. EPA will respond to public and peer
review comments received on the draft risk evaluation and will explain changes made to the draft risk
evaluation for trichloroethylene in response to those comments in the final risk evaluation.

EPA solicited input on the first 10 chemicals as it developed use documents, scope documents, and
problem formulations. At each step, EPA has received information and comments specific to individual
chemicals and of a more general nature relating to various aspects of the risk evaluation process,
technical issues, and the regulatory and statutory requirements. EPA has considered comments and
information received at each step in the process and factored in the information and comments as the
Agency deemed appropriate and relevant including comments on the published problem formulation of
trichloroethylene. Thus, in addition to any new comments on the draft risk evaluation, the public should
re-submit or clearly identify at this point any previously filed comments, modified as appropriate, that
are relevant to this risk evaluation and that the submitter feels have not been addressed. EPA does not
intend to further respond to comments submitted prior to the publication of this draft risk evaluation
unless they are clearly identified in comments on this draft risk evaluation.

EPA continues to review the recent court decision in Safer Chemicals Healthy Families v. EPA, Nos.
17-72260 et al. (9th Cir. 2019). This draft risk evaluation does not reflect any changes that may occur as
a result of that decision. EPA is still seeking public comment on and peer review of this version,
however. EPA will communicate the Agency's plans, including the possibility of supplemental versions,
in response to the court decision as appropriate.

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1.1 Physical and Chemical Properties

Physical-chemical properties influence the environmental behavior and the toxic properties of a
chemical, thereby informing the potential conditions of use, exposure pathways and routes and hazards
that EPA considered. For scope development, EPA considered the measured or estimated physical-
chemical properties set forth in

Table 1-1 and found no additional information during problem formulation or the draft risk evaluation
that would change these values.

TCE is a colorless liquid with a pleasant, sweet odor resembling that of chloroform. It is considered a
volatile organic compound (VOC) because of its moderate boiling point, 87.2°C, and high vapor
pressure, 73.46 mm Hg at 25°C. TCE is moderately water soluble (1.280 g/L at 25°C) and has a log
octanol/water partition coefficient (Kow) of 2.42. The density of TCE, 1.46 g/m3 at 20°C, is greater than
that of water.

Table 1-1. Physical and Chemical

'roperties of TCE

Property

Value a

References

Molecular Formula

C2HCI3



Molecular Weight

131.39 g/mole



Physical Form

Colorless, liquid, sweet,
pleasant odor, resembles
chloroform

CO'Neil et al. 2006)

Melting Point

-84.7°C

aide. 2007)

Boiling Point

87.2°C

aide. 2007)

Density

1.46 g/cm3 at 20°C

( 1000)

Vapor Pressure

73.72 mmHg at 25°Cb

( ibert and Danner.

Vapor Density

4.53

( Jeil et al. 2006)

Water Solubility

1,280 mg/L at 25°C

(Horvath et al.. 1999)

Octanol/W ater Partition
Coefficient (Log K0W)

2.42

( leiiee et al. 1980)

Henry's Law Constant

9.85E-03 atmm3/mole

aeighton and Calo.
1)

Flash Point

90°C (closed cup)

ffiCB. 2000)

Auto Flammability

410°C (Estimated)

(wt ;5)

Viscosity

0.545 mPas at 25°C

aide. 2007)

Refractive Index

1.4775 at 20°C

CO'Neil et al. 2001)

Dielectric Constant

3.4 80 at 16°C

(Weast and Selbv.
r\ 5)

a Measured unless otherwise noted

b This value was updated based on systematic review re-analysis of original values. The original value of 73.46
niniHu. from (Daubert and Banner. 1989). was used for occupational and consumer modelins of inhalation
exposures. The effect of this small difference is expected to be negligible for associated exposure estimates.

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1.2 Uses and Production Volume

This section contains use and production volume information for TCE.

1.2.1	Data and Information Sources

The summary of use and production volume information for TCE that is presented below is based on
research conducted for the Problem Formulation Document Trichloroethylene (EP A-740-R1 -7014) and
any additional information that was learned since the publication of that document. The previous
research was based on reasonably available information, including the Use and Market Profile for
Trichloroethylene, (EPA-HQ-QPPT-2016-073 7-0056). public meetings, and meetings with companies,
industry groups, chemical users and other stakeholders to aid in identifying conditions of use and
verifying conditions of use identified by the EPA. The information and input received from the public,
stakeholder meetings and the additional contacts was incorporated into this section to the extent
appropriate. Thus, EPA believes the manufacture, processing, distribution, use and disposal activities
constitute the conditions of use within the scope of the risk evaluation for trichloroethylene, based on
reasonably available information.

1.2.2	Domestic Manufacture of Trichloroethylene

A life cycle diagram is provided (Figure 1-1) depicting the conditions of use that are within the scope of
the risk evaluation during various life cycle stages including manufacturing, processing, use (industrial,
commercial, consumer; when distinguishable), distribution and disposal. The information is grouped
according to Chemical Data Reporting (CDR) processing codes and use categories (including functional
use codes for industrial uses and product categories for industrial, commercial and consumer uses), in
combination with other data sources (e.g., published literature and consultation with stakeholders), to
provide an overview of conditions of use. The EPA notes that some subcategories of use may be
grouped under multiple CDR categories.

For the purposes of this risk evaluation, CDR definitions were used. CDR use categories include the
following: "industrial use" means use at a site at which one or more chemicals or mixtures are
manufactured (including imported) or processed. "Commercial use" means the use of a chemical or a
mixture containing a chemical (including as part of an article) in a commercial enterprise providing
saleable goods or services. "Consumer use" means the use of a chemical or a mixture containing a
chemical (including as part of an article, such as furniture or clothing) when sold to or made available to
consumers for their use (U.S. EPA. 2016d).

To understand conditions of use relative to one another and associated potential exposures under those
conditions of use, the life cycle diagram includes the production volume associated with each stage of
the life cycle, as reported in the 2016 CDR reporting (U.S. EPA. 2016d) when the volume was not
claimed confidential business information (CBI). The 2016 CDR reporting data for TCE are provided in
Table 1-2 for TCE from the EPA's CDR database (U.S. EPA. 2016d). For the 2016 CDR reporting
period, non-confidential data indicate a total of 13 manufacturers and importers of TCE in the United
States.

Table 1-2 Production Volume of TCE in CDR Reporting Period (2012 to 2015) a

Reporting Year

2012

2013

2014

2015

Total Aggregate
Production Volume (lbs)

220,536,812

198,987,532

191,996,578

171,929,400

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Reporting Year

2012

2013

2014

2015

aThe CDR data for the 2016 reporting period is available via ChemView (httos://iava.epa. gov/chemview'). Because of an
ongoing CBI substantiation process required by amended TSCA, the CDR data available in the risk evaluation is more
specific than currently in ChemView.

As reported in the Use Document [EPA-IK * < I .01 0 0003 (\ > H \ < i )], as well as in
the 2014 TCE risk assessment (	»), an estimated 83.6% of TCE's annual production

volume is used as an intermediate in the manufacture of the hydrofluorocarbon, HFC-134a, an
alternative to the refrigerant chlorofluorocarbon, CFC-12. Another 14.7% of TCE production volume is
used as a degreasing solvent, leaving approximately 1.7% for other uses. Also reflected in the life cycle
diagram is the fact that TCE, as a widely used solvent, has numerous applications across industrial,
commercial and consumer settings.

Descriptions of the industrial, commercial and consumer use categories identified from the 2016 CDR
and included in the life cycle diagram (Figure 1-1) are summarized below (	1). The

descriptions provide a brief overview of the use category; the [.Environmental Releases and
Occupational Exposure Assessment. Docket: EPA-HQ-OPPT-2019-0500)J contains more detailed
descriptions (e.g., process descriptions, worker activities, process flow diagrams, equipment
illustrations) for each manufacture, processing, use and disposal category. The descriptions provided
below are primarily based on the corresponding industrial function category and/or commercial and
consumer product category descriptions from the 2016 CDR and can be found in the EPA's Instructions
for Reporting 2016 TSCA. Chemical Data Reporting (	b).

The following describes several industrial/commercial CDR use categories where TCE has been used;
the [.Environmental Releases and Occupational Exposure Assessment. Docket: EPA-HQ-OPPT-2019-
0500)] provides additional process-related information on the remaining categories and life cycle stages.

The "Solvents for Cleaning and Degreasing" category encompasses chemical substances used to
dissolve oils, greases and similar materials from a variety of substrates including metal surfaces,
glassware and textiles. This category includes the use of TCE in vapor degreasing, cold cleaning and in
industrial and commercial aerosol degreasing products.

The "Lubricants and Greases" category encompasses chemical substances contained in products used
to reduce friction, heat generation and wear between solid surfaces. This category includes the use of
TCE in penetrating lubricants, and tap and die fluids for industrial, commercial and consumer uses.

The "Adhesives and Sealants" category encompasses chemical substances contained in adhesive and
sealant products used to fasten other materials together. This category includes the use of TCE in mirror-
edge sealants and other adhesive products.

The "Functional Fluids (closed system)" category encompasses liquid or gaseous chemical substances
used for one or more operational properties in a closed system. Examples are heat transfer agents (e.g.,
coolants and refrigerants).

The "Paints and Coatings" category encompasses chemical substances contained in paints, lacquers,
varnishes and other coating products that are applied as a thin continuous layer to a surface. Coating
may provide protection to surfaces from a variety of effects such as corrosion and ultraviolet (UV)
degradation; may be purely decorative; or may provide other functions. The EPA anticipates that the

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primary subcategory to be the use of TCE in solvent-based coatings. This category covers industrial,
commercial and consumer uses of paints and coatings.

The "Cleaning and Furniture Care Products" category encompasses chemical substances contained
in products that are used to remove dirt, grease, stains and foreign matter from furniture and furnishings,
or to cleanse, sanitize, bleach, scour, polish, protect or improve the appearance of surfaces. This
category includes the use of TCE for spot cleaning and carpet cleaning.

The "Laundry and Dishwashing Products" category encompasses chemical substances contained in
laundry and dishwashing products and aids formulated as a liquid, granular, powder, gel, cakes, and
flakes that are intended for consumer or commercial use.

The "Arts, Crafts and Hobby Materials" category encompasses chemical substances contained in arts,
crafts, and hobby materials that are intended for consumer or commercial use.

1.3 Regulatory and Assessment History

The EPA conducted a search of existing domestic and international laws, regulations and assessments
pertaining to TCE. The EPA compiled this summary from data available from federal, state,
international and other government sources, as cited in Appendix A.

Federal Laws and Regulations

TCE is subject to federal statutes or regulations, other than TSCA, that are implemented by other offices
within the EPA and/or other federal agencies/departments. A summary of federal laws, regulations and
implementing authorities is provided in Appendix A.l.

State Laws and Regulations

TCE is subject to state statutes or regulations implemented by state agencies or departments. A summary
of state laws, regulations and implementing authorities is provided in Appendix A.2

Laws and Regulations in Other Countries and International Treaties or Agreements
TCE is subject to statutes or regulations in countries other than the United States and/or international
treaties and/or agreements. A summary of these laws, regulations, treaties and/or agreements is provided
in Appendix A. 3

The EPA has identified assessments conducted by other agency programs and organizations (see Table
1-3). Depending on the source, these assessments may include information on conditions of use,
hazards, exposures, and potentially exposed or susceptible subpopulations (PESS)—information useful
to the EPA in preparing this risk evaluation. Table 1-3 shows the assessments that have been conducted.
In addition to using this information, EPA conducted a full review of the data collected [see
Trichloroethylene (CASRN 79-01-6) Bibliography: Supplemental File for the TSCA Scope Document,
EP A-HQ-QPPT-2016-0737) using the literature search strategy (see Strategy for Conducting Literature
Searches for Trichloroethylene: Supplemental File for the TSCA Scope Document, EP A-HQ-OPPT -
2(	] to ensure that the EPA is considering information that has been made available since these

assessments were conducted.

In its previous TCE Risk Assessment (	>), risks from use of TCE in commercial and

consumer solvent degreasing (aerosol and vapor), consumer use as a spray-applied protective coating for
arts and crafts and commercial use as a spot remover at dry-cleaning facilities were assessed. The TCE
Risk Assessment was used to support two proposed rules under TSCA section 6 (-1 t ^ I

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1750	December 12, 2016; 82 FR 7432; January 19, 2017) to address risks from use of TCE. Along with other

1751	reasonably available information, the EPA used the existing TSCA risk assessments to inform its

1752	development of the TCE risk evaluation.

1753

1754	Table 1-3. Assessment History of TCE	

Authoring Organization

Assessment

EPA Assessments

Office of Chemical Safety
and Pollution Prevention
(OCSPP)/ Office of
Pollution Prevention and
Toxics (OPPT)

TSCA Work Plan Chemical Risk Assessment Trichloroethvlene: Decreasing. Spot Cleaning

and Arts & Crafts Use (U.S. EPA. 2014b)

OCSPP/OPPT

Supplemental Occupational Exposure and Risk Reduction Technical Report in Support of

Risk Management Options for Trichloroethvlene (TCE) Use in Aerosol Degreasing (U.S.

EPA. 2016f)

OCSPP/OPPT

Supplemental Exposure and Risk Reduction Technical Report in Support of Risk

Management Options for Trichloroethvlene (TCE) Use in Consumer Aerosol Degreasing

(U.S. EPA. 2016e)

OCSPP/OPPT

Supplemental Occupational Exposure and Risk Reduction Technical Report in Support of

Risk Management Options for Trichloroethvlene (TCE) Use in Spot Cleaning (U.S. EPA.

2016g)

OCSPP/OPPT

Supplemental Occupational Exposure and Risk Reduction Technical Report in Support of

Risk Management Options for Trichloroethvlene (TCE) Use in Vapor Degreasing 1RIN

2070-AK111 (U.S. EPA. 2016h)

Integrated Risk Information
System (IRIS)

Toxicological Review of Trichloroethvlene (U.S. EPA. 201 le)

National Center for
Environmental Assessment
(NCEA)

Sources. Emission and Exposure for Trichloroethvlene (TCE) and Related Chemicals (U.S.

EPA. 2001)

Office of Water (OW)/
Office of Science and
Technology (OST)

Update of Human Health Ambient Water Oualitv Criteria: Trichloroethvlene (TCE) 79-01-6

(U.S. EPA. 2015b)

Other U.S.-Based Organizations

Agency for Toxic
Substances and Disease
Registries (ATSDR)

Final Toxicological Profile for Trichloroethvlene
(ATSDR 2019)

National Research Council
(NRC)

Assessing the Human Health Risks of Trichloroethvlene: Kev Scientific Issues (NRC. 2006)



Office of Environmental
Health Hazard Assessment
(OEHHA), Pesticide and
Environmental Toxicology
Section

Public Heath Goal for Trichloroethvlene in Drinking Water (CalEPA. 2009)

International

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Authoring Organization

Assessment

Institute i'or Health uiid
Consumer Protection,
European Chemicals
Bureau





Australia National
Industrial Chemicals
Notification and
Assessment Scheme
(NICNAS)

Trichloroethvlene: Priority Existing Chemical Assessment Report No. 8 (NICNAS. 2000)



1755	1,4 Scope of the Evaluation

1756	1.4.1 Conditions of Use Included in the Risk Evaluation

1757	TSCA § 3(4) defines the conditions of use (COUs) as "the circumstances, as determined by the

1758	Administrator, under which a chemical substance is intended, known, or reasonably foreseen to be

1759	manufactured, processed, distributed in commerce, used, or disposed of." The conditions of use are

1760	described below in Table 1-4 and Table 1-5. No additional information was received by the EPA

1761	following the publication of the problem formulation (U.S. EPA. 2018d) that would update or otherwise

1762	require changes to the life cycle diagram (Figure 1-1) as presented in the problem formulation (U.S.

1763	EPA. 2018d). Nonetheless, EPA decided to reorganize the conditions of use for this risk evaluation. In

1764	this risk evaluation, the COUs as described in (I v H	) were evaluated for occupational

1765	scenarios based on corresponding occupational exposure scenarios (OES) (Table 1-4). The occupational

1766	COUs are also applicable to environmental receptors based on water releases from these activities.

1767

1768	"Lace wig and hair extension glues" have been eliminated as a COU since the publication of the

1769	problem formulation (	18d). EPA, after consultation with the FDA, has determined that this

1770	use, previously identified in the problem formulation as a conditions of use, is not a condition of use

1771	because it falls outside the scope of EPA's jurisdiction. TSCA sec. 3(2) excludes from the definition of

1772	"chemical substance" cosmetics as they are defined in the Federal Food, Drug and Cosmetic Act

1773	(FFDCA) when manufactured, processed, or distributed in commerce for use as a cosmetic. Because the

1774	glue for lace wigs and hair extensions is a cosmetic within section 201(i) of the FFDCA, any TCE used

1775	for these purposes is exempted from TSCA.

1776

1777	Consumer scenarios were evaluated separately from occupational scenarios, and EPA re-categorized

1778	certain COUs based on product function. None of these changes resulted in any difference in how these

1779	products are or would have been assessed, they simply reflect a recategorization in order to improve

1780	clarity. Additionally, subcategories were added based on availability of differing forms of a product

1781	(e.g., aerosol vs liquid). The updated consumer conditions of use and explanations for the changes are

1782	presented in Table 1-5.

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Table 1-4. Categories and Subcategories of Occu

pational Conditions of Use and <

Corresponding Occupational Exposure Scenario

Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References

Manufacture

Domestic manufacture

Domestic manufacture

Manufacturing

20

16d)

Import

Import

Repackaging

20

16d)

Processing

Processing as a

reactant/

intermediate

Intermediate in industrial gas
manufacturing (e.g.,
manufacture of fluorinated
gases used as refrigerants, foam
blowing agents and solvents)

Processing as a reactant

20

16d); EPA-

OOl \l p \ (t'M M'PT-

.oi o ; ooi< r \

HO-OPPT-2016-0737-
0026; EPA-HO-OPPT-

Processing -
Incorporation into
formulation, mixture
or reaction product

Solvents (for cleaning or
degreasing)

Formulation of Aerosol
and Non-Aerosol
Products

2016d)

Adhesives and sealant
chemicals

2016d)

Solvents (which become part of
product formulation or mixture)
(e.g., lubricants and greases,
paints and coatings, other uses)

2016d); EPA-
HO-OPPT-2016-073 7-
0003; EPA-HO-OPPT-

Processing -
incorporated into
articles

Solvents (becomes an integral
components of articles)

2016d)

Repackaging

Solvents (for cleaning or
degreasing)

Repackaging

2016d)

Recycling

Recycling

Process Solvent
Recycling and Worker
Handling of Wastes

2017f)

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Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References

Distribution in commerce

Distribution

Distribution

Not assessed as a
separate operation;
exposures/releases from
distribution are
considered within each
condition of use.

EP A-HG-GPPT-2016-

Industrial/commercial use

Solvents (for cleaning
or degreasing)

Batch vapor degreaser (e.g.,
open-top, closed-loop)0

Batch Open-Top Vapor
Degreasing;

Batch Closed-Loop
Vapor Degreasing

FP

20
20
20

A-HO-OPPT-2016-
37-00

i * < r \
16ill { P \ U'O-OPPT-

In-line vapor degreaser (e.g.,
conveyorized, web cleaner)c

Conveyorized Vapor

Degreasing;

Web Vapor Degreasing

EP

20
20
20

A-HO-OPPT-2016-
37-00

1 H.), * < r \

16ill i P \ U'O-OPPT-

37-0056

Cold cleaner

Cold Cleaning

EP A-HG-GPPT-2016-

o ; ooo;, ^ * i r \

H < r \ < MT i

Aerosol spray degreaser/
cleanerc

Aerosol Applications:
Spray

Degreasing/Cleaning,
Automotive Brake and
Parts Cleaners,
Penetrating Lubricants,
and Mold Releases

EP

20
20
20
20

A-HO-OPPT-2016-
37-00

1 H>1 * < r \
160, * < r \
l Hfl' \ U'O-OPPT-

Mold release

EP A-HO-OPPT-2016-

o ; ooo;, < r \ .[(^

5

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Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References



Lubricants and
greases/lubricants and
lubricant additives

Tap and die fluid

Metalworking Fluids

2016d); EPA-
HO-OPPT-2016-0737-
0003; EPA-HO-OPPT-

.01 0 ; 00.8, EPA-

HO-OPPT-2016-073 7-
0056





Penetrating lubricant

Aerosol Applications:
Spray

Degreasing/Cleaning,
Automotive Brake and
Parts Cleaners,
Penetrating Lubricants,
and Mold Releases;
Metalworking Fluids

2016d). EPA-
HO-OPPT-2016-073 7-
0056; EPA-HO-OPPT-

-0i o ; ooo;, \ r \

HO-OPPT-2016-0737-
0028



Adhesives and sealants

Solvent-based adhesives and
sealants

Adhesives, Sealants,
Paints, and Coatings

2016d). EPA-
HO-OPPT-2016-073 7-
0056; EPA-HO-OPPT-





Tire repair cement/sealer



2016d). EPA-
HO-OPPT-2016-073 7-
0056; EPA-HO-OPPT-





Mirror edge sealant



EP A-HO-OPPT-2016-

o ; ooo^ * i r \
im, < r \ *
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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References



Paints and coatings

Diluent in solvent-based paints
and coatings

Adhesives, Sealants,
Paints, and Coatings

(TJ.S. EPA. 2016d\ EPA-
HO-OPPT-2016-073 7-
0056; EPA-HO-OPPT-
2016-0737-0003; EPA-
HO-OPPT-2016-073 7-
0010; EPA-HO-OPPT-
2016-0737-0015; EPA-
HO-OPPT-2016-073 7-
0027;



Cleaning and furniture
care products

Carpet cleaner

Spot Cleaning, Wipe
Cleaning and Carpet
Cleaning

EP A-HO-OPPT-2016-
0737-0056; EPA-HO-
OPPT-2016-073 7-0003





Wipe cleaning d



EP A-HO-OPPT-2016-
0737-0056; EPA-HO-
OPPT-2016-073 7-0003



Laundry and
dishwashing products

Spot removerc



EP A-HO-OPPT-2016-

0737-0003. (U.S. EPA.
2014b\ (U.S. EPA.
2016a). EPA-HO-OPPT-
2016-0737-0056



Arts, crafts and hobby
materials

Fixatives and finishing spray
coatings 0

Adhesives, Sealants,
Paints, and Coatings

(U.S. EPA. 2014b)



Corrosion inhibitors
and anti-scaling agents

Corrosion inhibitors and anti-
scaling agents

Industrial Processing Aid

(U.S. EPA. 2016d)



Processing aids

Process solvent used in battery
manufacture



(U.S. EPA. 2017h)





Process solvent used in polymer
fiber spinning, fluoroelastomer
manufacture and Alcantara
manufacture



(U.S. EPA. 2017h)

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Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References





Extraction solvent used in
caprolactam manufacture



* n \ :0i h)

Precipitant used in beta-
cyclodextrin manufacture

* n \ :0i h)

Ink, toner and colorant
products

Toner aid

Commercial Printing and
Copying

EP A-HG-GPPT-2016-

o ; oo¦> ,ir\ ^

3

Automotive care
products

Brake and parts cleaner

Aerosol Applications:
Spray

Degreasing/Cleaning,
Automotive Brake and
Parts Cleaners,
Penetrating Lubricants,
and Mold Releases

EP A-HG-GPPT-2016-
0 ; 00 ¦> , i V \ iKt

3



Apparel and footwear
care products

Shoe polish

Other Commercial Uses

* n \ :0i h)

Other uses

Hoof polishes 6

EP A-HO-OPPT-2016-
0 ; 00 ¦> , i V \ iKt

3

Pepper spray

EP A-HO-OPPT-2016-
0 ; 00 ¦> , i V \ iKt

3

Gun scrubber

EP A-HO-OPPT-2016-
0 ; 00¦> ,H'\ ^[Q;

3

Other miscellaneous industrial
and commercial uses

2017h)

Disposal

Disposal

Industrial pre-treatment



2017f)

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Life Cycle Stage

Category a

Subcategory b

Occupational Exposure
Scenario (OES)

References





Industrial wastewater treatment

Process Solvent
Recycling and Worker
Handling of Wastes



Publicly owned treatment works
(POTW)

a These categories of conditions of use appear in the Life Cycle Diagram, reflect CDR codes, and broadly represent conditions of use of TCE in industrial and/or
commercial settings.

b These subcategories reflect more specific uses of TCE.

0 This includes uses assessed in the (U.S. EPA. 20Mb) risk assessment.

d This condition of use involves wipe cleaning. Note that the problem formulation described "cleaning wipes" as a condition of use. This referred to the application of a

product that is then wiped off, rather than a pre-wet towelette.
e "Hoof polish" would remain within EPA's jurisdiction unless the article in question was also intended for the diagnosis, cure, mitigation, treatment, of disease or
intended to affect the structure or function of the body of animals, as described in the FFDCA. EPA identified a single product for hoof polish containing TCE (U.S.
EPA. 2017h). and this product is intended for onlv cosmetic and not medical use. Therefore, "hoof polish" was evaluated as a COU. applicable onlv to products
restricted to cosmetic function.

1784

1785

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Table 1-5. Categories and Subcategories of Consumer Conditions of Use

Life
Cycle
Stage

Category

Subcategory

Use

Solvents for Cleaning and

Brake & Parts Cleaner2



Degreasing

Aerosol Electronic Degreaser/Cleaner1





Liquid Electronic Degreaser/Cleaner1





Aerosol Spray Degreaser/Cleaner1





Liquid Degreaser/Cleaner1





Aerosol Gun Scrubber1-3





Liquid Gun Scrubber1,3





Mold Release





Aerosol Tire Cleaner1,4





Liquid Tire Cleaner1,4



Lubricants and Greases

Tap & Die Fluid





Penetrating Lubricant5



Adhesives and Sealants

Solvent-based Adhesive & Sealant





Mirror-edge Sealant





Tire Repair Cement/Sealer



Cleaning and Furniture Care
Products10

Carpet Cleaner



Aerosol Spot Remover1,6





Liquid Spot Remover1,6



Arts, Crafts, and Hobby Materials

Fixatives & Finishing Spray Coatings7



Apparel and Footwear Care Products

Shoe Polish



Other Consumer Uses

Fabric Spray8





Film Cleaner





Hoof Polish





Pepper Spray





Toner Aid9

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Life
Cycle
Stage

Category

Subcategory

1	Form was determined based on the specific products identified as representative of the associated product
subcategories. Distinct subcategories based on differing forms (aerosol and liquid) were not specifically
defined in the Problem Formulation. They were added due to product availability based on additional
research that helped to differentiate specific product forms (i.e., liquid or aerosol) and types.

2	The brake cleaner subcategory was listed in Table 2-3 of the Problem Formulation as being associated
with the automotive care products category; however, the same brake cleaning conditions of use are now
associated with the broader solvents for cleaning and degreasing category. This change does not impact
evaluated conditions of use, as the evaluated product scenarios are based on the brake cleaner product(s)
and not a broader category of use.

3	The gun scrubber subcategory was listed in Table 2-3 of the Problem Formulation as being associated
with the other consumer uses category; however, the same gun scrubber conditions of use are now
associated with the broader solvents for cleaning and degreasing category. This change does not impact
evaluated conditions of use, as the evaluated product scenarios are based on the gun scrubber product(s)
and not a broader category of use.

4	Tire cleaner products / subcategories of use were not specifically called out in the Problem Formulation;
however, such products were identified in the 2017 Use and Market Report (U.S. EPA. 2017f) and
Preliminary Information on Manufacturing. Processing, Distribution. Use, and Disposal: TCE (U.S. EPA.
20.1.7c) and fit within the broader Solvents for Cleaning and Degreasing category.

5	Based on additional research into the specific product(s) associated with the broader lubricants and
greases category, the subcategory name was updated from penetrating lubricant to lubricant.

6	The spot remover subcategory was listed in Table 2-3 of the Problem Formulation as being associated
with the laundry and dishwashing products category; however, the same spot remover conditions of use are
now associated with the cleaning and furniture care products category. This change does not impact
evaluated conditions of use, as the evaluated product scenarios are based on the spot remover product(s)
and not a broader category of use.

7	Note that this subcategory is referred to as "clear protective coating spray" in U.S. EPA (20.1.4b) and as
"spray fixative" in the TCE Significant New Use Rule (80 FR 47441).

8	Fabric spray (specifically an anti-fray spray) was added following Problem Formulation based on
identification in the final 2014 TCE Work Plan Chemical Risk Assessment (U.S. EPA. 2014b).

9	The toner aid subcategory was listed in Table 2-3 of the Problem Formulation as being associated with
the Ink, toner, and colorant products category; however, the toner aid use is not like use of a toner or
pigment; therefore, the same toner aid condition of use is now associated with the other consumer use
category. This change does not impact evaluated conditions of use, as the evaluated product scenarios are
based on the toner aid product(s) and not a broader category of use.

10	Note that the problem formulation described "cleaning wipes" as a condition of use for this category.
However, that referred to the application of a product that is then wiped off, rather than a pre-wet
towelette. A number of consumer conditions of use involve wipe cleaning and are described in detail in
Section 2.3.2.6.2 as leading to dermal contact with impeded evaporation.

1787

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MFG/ IMPORT

PROCESSING

INDUSTRIAL, COMMERCIAL, CONSUMER USES

WASTE DISPOSAL

Manufacture
(Includes Import)

(171.9 million lbs.)

Processing as a
Reactant/lntermediate

(Volume CBI)
e.g., intermediate for
refrigerant manufacture

Incorporated into
Formulation, Mixture,
or Reaction Products

(Volume CBI)

Repackaging

(Volume CBI)



Recycling

Solvents for Cleaning and Degreasing

(Volume CBI)
e.g., vapor degreasing, cold cleaning,
aerosol degreasing, mold release

Lubricants and Greases

(185,000 lbs.)
e.g., lubricant, tap and die fluid

Adhesives and Sealants

(Volume CBI)
e.g., mirror-edge sealant

Functional Fluids (closed system)

(Volume CBI)
e.g., refrigerant

Paints and Coatings

(Volume CBI)

Cleaning and Furniture Care Products

(Volume CBI)
e.g., carpet cleaner

Laundry and Dishwashing Products

e.g., spot remover

Arts, Crafts, and Hobby Materials

e.g., spray-applied protective coating

Apparel and Footwear Care Products

e.g., shoe polish

Other Uses, Incl. Corrosion Inhibitors and

Anti-Scaling Agents (Volume CBI);
Processing Aids; Ink, Toner and Colorant
Products; Automotive Care Products;
Miscellaneous (e.g., hoof polish, pepper
spray)

1788

1789

1790

1791

1792

1793

1794

~ Manufacture (Includes Import) ~ Processing

~

Category of Conditions of Use. The majority of conditions of use were evaluated for both occupational and
consumer scenarios, however there are some differences based on re-categorization of consumer uses.

Figure 1-1. TCE Life Cycle Diagram

The life cycle diagram depicts the conditions of use that are within the scope of the risk eval uation during various life cycle stages including
manufacturing, processing, use (industrial, commercial, consumer), distribution and disposal. The production volumes shown are for
reporting year 2015 from the 2016 CDR reporting period ( J.S. EPA. 2016d). Activities related to distribution (e.g., loading and unloading)
will be considered throughout the TCE life cycle, rather than using a single distribution scenario.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1.4.2 Conceptual Models

The conceptual models for this draft risk evaluation are shown in Figure 1-2,

Figure 1-3, and

Figure 1-4. The EPA considered the potential for hazards to human health and the environment resulting
from exposure pathways outlined in the preliminary conceptual models of the TCE scope document
(I	). These conceptual models considered potential exposures resulting from consumer

activities and uses, industrial/ commercial activities, and environmental releases and wastes. The
problem formulation documents refined the initial conceptual models and analysis plans that were
provided in the scope documents (	).

For the purpose of this evaluation, EPA considered workers and occupational non-users, which includes
men and women of reproductive age (Figure 1-2). Consumer exposure was assessed for various
pathways for users age 11 and older along with bystanders of all ages (

Figure 1-3).

The potential pathways that were determined to be included in the risk evaluation but not to warrant
further analysis in this draft risk evaluation were: exposure to both humans and ecological organisms
due to land application of biosolids following wastewater treatment, exposure to organisms through the
sediment compartment, and exposure to terrestrial organisms. In the problem formulation, the EPA
determined that no further evaluation of these pathways is needed due to the physical/chemical
properties associated with TCE (high vapor pressure) and its rapid volatilization to air from soil and
water or rapid migration through soil into groundwater. Due to TCE's fate properties, a significant
portion of TCE would not be available to enter the sediment compartment.

The potential pathways that were determined to be included in the risk evaluation and further analyzed
include:

•	Exposure to aquatic species (i.e. aquatic plants) via contaminated surface water.

•	Inhalation and dermal exposures to workers and consumers, and inhalation exposures to ONUs
and bystanders, from industrial/commercial activities and consumer activities.

•	Inhalation and dermal exposures to workers and inhalation exposures to ONUs from waste
handling, treatment and disposal.

Review and evaluation of reasonably available information on TCE confirmed the preliminary
conclusions in the problem formulation (	2018d) and as a result, the EPA confirms further

analysis of the pathways outlined in the conceptual models. The conceptual models from the problem
formulation are shown below in Figure 1-2,

Figure 1-3, and
Figure 1-4.

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1842

1843

1844

1845

INDUSTRIAL AND COMMERCIAL

ACTIVITIES / USES	EXPOSURE PATHWAY	EXPOSURE ROUTE	RECEPTORSc	HAZARDS

Figure 1-2. TCE Conceptual Model for Industrial and Commercial Activities and Uses: Potential Exposures and Hazards

The conceptual model presents the exposure pathways, exposure routes and hazards to human receptors from industrial and commercial
activities and uses of TCE.

a Some products are used in both commercial and consumer applications. Additional uses of TCE are included in Table 1-4.
b Fugitive air emissions are those that are not stack emissions, and include fugitive equipment leaks from valves, pump seals, flanges,
compressors, sampling connections and open-ended lines; evaporative losses from surface impoundment and spills; and releases from
building ventilation systems.

0 Receptors include Potentially Exposed or Susceptible Subpopulations (PESS) including women of childbearing age and their children and
genetically susceptible populations.

d When data and information are reasonably available to support the analysis, EPA also considers the effect that engineering controls and/or
personal protective equipment have on occupational exposure levels.

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1855

1856

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CONSUMER

ACTIVITIES / USES	EXPOSURE PATHWAY	EXPOSURE ROUTE	RECEPTORS c	HAZARDS

Figure 1-3. TCE Conceptual Model for Consumer Activities and Uses: Potential Exposures and Hazards

The conceptual model presents the exposure pathways, exposure routes and hazards to human receptors from consumer activities and uses of
TCE.

a Some products are used in both commercial and consumer applications. Additional uses of TCE are included in Table 1-4.
b Exposure may occur through mists that deposit in the upper respiratory tract however, based on physical chemical properties, mists of TCE
will likely be rapidly absorbed in the respiratory tract or evaporate and not result in an oral exposure. Although less likely given the physical-
chemical properties, oral exposure may also occur from incidental ingestion of residue on hand/body.

0 Receptors include Potentially Exposed or Susceptible Subpopulations (PESS).

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RELEASES AND WASTES FROM	EXPOSURE PATHWAY

INDUSTRIAL / COMMERCIAL / CONSUMER USES

RECEPTORS

HAZARDS

KEY:



Grey Text

Pathways and receptors that were not

further analyzed

	f

Pathways that were further analyzed.

	~

Pathways that were notfurther analyzed.

1860	Figure 1-4. TCE Conceptual Model for Environmental Releases and Wastes: Potential Exposures and Hazards

1861	The conceptual model presents the exposure pathways, exposure routes and hazards to human and environmental receptors from

1862	environmental releases and wastes of TCE.

1863	a Industrial wastewater or liquid wastes may be treated on-site and then released to surface water (direct discharge), or pre-treated and released

1864	to POTW (indirect discharge).

1865

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1.5 Systematic Review

TSCA requires the EPA to use scientific information, technical procedures, measures, methods,
protocols, methodologies and models consistent with the best available science and base decisions under
section 6 on the weight of scientific evidence. Within the TSCA risk evaluation context, the weight of
the scientific evidence is defined as "a systematic review method, applied in a manner suited to the
nature of the evidence or decision, that uses a pre-established protocol to comprehensively, objectively,
transparently, and consistently identify and evaluate each stream of evidence, including strengths,
limitations, and relevance of each study and to integrate evidence as necessary and appropriate based
upon strengths, limitations, and relevance". (40 CFR 702.33).

To meet the TSCA § 26(h) science standards, EPA used the TSCA systematic review process described
in the Application of Systematic Review in TSCA Risk Evaluations document (	)). The

process complements the risk evaluation process in that the data collection, data evaluation and data
integration stages of the systematic review process are used to develop the exposure and hazard
assessments based on reasonably available information. EPA defines "reasonably available
information" to mean information that EPA possesses, or can reasonably obtain and synthesize for use in
risk evaluations, considering the deadlines for completing the evaluation (40 CFR 702.33).

EPA is implementing systematic review methods and approaches within the regulatory context of the
amended TSCA. Although EPA will make an effort to adopt as many best practices as practicable from
the systematic review community, EPA expects modifications to the process to ensure that the
identification, screening, evaluation and integration of data and information can support timely
regulatory decision making under the aggressive timelines of the statute.

1.5.1 Data and Information Collection

EPA planned and conducted a comprehensive literature search based on key words related to the
different discipline-specific evidence supporting the risk evaluation (e.g., environmental fate and
transport; engineering releases and occupational exposure; consumers and environmental exposure; and
environmental and human health hazard). EPA then developed and applied inclusion and exclusion
criteria during the title and abstract screening to identify information potentially relevant for the risk
evaluation process. The literature and screening strategy as specifically applied to TCE is described in
the Strategy for Conducting Literature Searches for Trichloroethylene (TCE): Supplemental File for the
TSCA Scope Document (	) and the results of the title and abstract screening process

were published in the [Trichloroethylene (CASRN 79-01-6) Bibliography: Supplemental File for the
TSCA Scope Document; (	7i)].

For studies determined to be on-topic (or relevant) after title and abstract screening, EPA conducted a
full text screening to further exclude references that were not relevant to the risk evaluation. Screening
decisions were made based on eligibility criteria documented in the form of the populations, exposures,
comparators, and outcomes (PECO) framework or a modified framework.4 Data sources that met the
criteria were carried forward to the data evaluation stage. The inclusion and exclusion criteria for full
text screening for TCE are available in Appendix F of the Problem Formulation of the Risk Evaluation
for Trichloroethylene (U.S. EPA. 2018d)

4 A PESO statement was used during the full text screening of environmental fate and transport data sources. PESO stands
for Pathways and Processes, Exposure, Setting or Scenario, and Outcomes. A RESO statement was used during the full text
screening of the engineering and occupational exposure literature. RESO stands for Receptors, Exposure, Setting or
Scenario, and Outcomes.

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1947

Although EPA conducted a comprehensive search and screening process as described above, EPA made
the decision to leverage the literature published in previous assessments5 when identifying relevant key
and supporting data6 and information for developing the TCE risk evaluation. This is discussed in the
Strategy for Conducting Literature Searches for Trichloroethylene: Supplemental Document to the
TSCA Scope Document (	). In general, many of the key and supporting data sources

were identified in the comprehensive Trichloroethylene (CASRN 79-01-6) Bibliography: Supplemental
File for the TSCA Scope Document; (	). However, there were instances that EPA missed

relevant references that were not captured in the initial categorization of the on-topic references. EPA
found additional relevant data and information using backward reference searching, which was a
technique that will be included in future search strategies. This issue was discussed in Section 4 of the
Application of Systematic Review for TSCA Risk Evaluations (U.S. EPA. 2018b). Other relevant key
and supporting references were identified through targeted supplemental searches to support the
analytical approaches and methods in the trichloroethylene risk evaluation (e.g., to locate specific
information for exposure modeling) or to identify new data and information published after the date
limits of the initial search.

EPA used previous chemical assessments to quickly identify relevant key and supporting information as
a pragmatic approach to expedite the quality evaluation of the data sources, but many of those data
sources were already captured in the comprehensive literature as explained above. EPA also considered
newer information not taken into account by previous chemical assessments as described in the Strategy
for Conducting Literature Searches for Trichloroethylene: Supplemental Document to the TSCA Scope
Document (\ v « « \ JO I ^). EPA then evaluated the confidence of the key and supporting data
sources as well as newer information instead of evaluating the confidence of all the underlying evidence
ever published on a chemical substance's fate and transport, environmental releases, environmental and
human exposure and hazards. All other literature from previous authoritative assessments were
considered as supplemental information. A comprehensive evaluation of all of the data and information
ever published for a chemical substance would be extremely labor intensive and could not be achieved
considering the deadlines specified in TSCA section 6(b)(4)(G) for completing such evaluation for most
chemical substances especially those that have a data rich database such as TCE. Furthermore, EPA
evaluated how EPA's evaluation of the key and supporting data and information and newer information
would change the previous conclusions presented in the previous assessments.

This pragmatic approach allowed EPA to maximize the scientific and analytical efforts of other
regulatory and non-regulatory agencies by accepting for the most part the relevant scientific knowledge
gathered and analyzed by others except for influential information sources that may have an impact on
the weight of the scientific evidence and ultimately the risk findings. The influential information (i.e.,
key/supporting) came from a smaller pool of sources subject to the rigor of the TSCA systematic review
process to ensure that the risk evaluation uses the best available science and the weight of the scientific
evidence.

5	Examples of existing assessments are EPA's chemical assessments (e.g., previous work plan risk assessments, problem
formulation documents), ATSDR's Toxicological Profiles, EPA's IRIS assessments and ECHA's dossiers. This is described
in more detail in the Strategy for Conducting Literature Searches for Trichloroethylene: Supplemental Document to the
TSCA Scope Document (U.S. EPA. 2017e).

6	Key and supporting data and information are those that support key analyses, arguments, and/or conclusions in the risk
evaluation.

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Figures 1-5 to 1-9 below depict the literature flow diagrams illustrating the results of this process for
each scientific discipline-specific evidence supporting the draft risk evaluation. Each diagram provides
the total number of references at the start of each systematic review stage (i.e., data search, data
screening, data evaluation, data extraction/data integration) and those excluded based on criteria guiding
the screening and data quality evaluation decisions.

EPA made the decision to bypass the data screening step for data sources that were highly relevant to the
draft risk evaluation as described above. These data sources are depicted as "key/supporting data
sources" in the literature flow diagrams. Note that the number of "key/supporting data sources" were
excluded from the total count during the data screening stage and added, for the most part, to the data
evaluation stage depending on the discipline-specific evidence. The exception was the engineering
environmental releases and occupational exposure data sources that were subject to a combined data
extraction and evaluation step (Figure 1-6).

*This is a key and supporting source from existing assessments, the EPI Suite™ set of models, that was highly relevant
for the TSCA risk evaluation. This source bypassed the data screening step and moved directly to the data evaluation
step.

Figure 1-5. Literature Flow Diagram for Environmental Fate and Transport

Note: Literature search results for the environmental fate and transport of TCE yielded 10,040 studies. During problem
formulation, following data screening, most enviromnental exposure pathways were removed from the conceptual models.
As a result, 9,979 studies were deemed off-topic and excluded. One key source (U.S. EPA. 2012b) and the remaining 61
studies related to enviromnental exposure pathways retained in the conceptual models entered data evaluation, where 9
studies were deemed unacceptable and 52 moved into data extraction and integration. Note: Data sources identified relevant
to physical-chemical properties were not included in this literature flow diagram. The data quality evaluation of physical-
chemical properties studies can be found in the supplemental document, [Data Quality Evaluation of Physical-Chemical
Properties Studies. Docket: EPA-HO-OPPT-2019-0500] and the extracted data are presented in
Table 1-1.

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Figure 1-6. Literature Flow Diagram for Engineering Releases and Occupational Exposure

Note: Literature search results for environmental release and occupational exposure yielded 10,132 data sources. Of these data
sources, 159 were determined to be relevant for the risk evaluation through the data screening process. These relevant data
sources were entered into the data extraction/evaluation phase. After data extraction/evaluation, EPA identified several data
gaps and performed a supplemental, targeted search to fill these gaps (e.g., to locate information needed for exposure modeling).
The supplemental search yielded 8 relevant data sources that bypassed the data screening step [List of Key and Supporting
Studies for Environmental Releases and Occupational Exposure. Docket: EPA-HQ-OPPT-2019-0500)] and were evaluated
and extracted in accordance with Appendix D: Data Quality Criteria for Occupational Exposure and Release Data of the
Application of Systematic Review for TSCA Risk Evaluations document (U.S. EPA, 2018b'). Of the 152 sources from which
data were extracted and evaluated, 43 sources only contained data that were rated as unacceptable based on serious flaws
detected during the evaluation. Of the 124 sources forwarded for data integration, data from 36 sources were integrated, and
73 sources contained data that were not integrated (e.g., lower quality data that were not needed due to the existence of higher
quality data, data for release media that were removed from scope after data collection).

*The quality of data in these sources (n=73) were acceptable for risk assessment purposes, but they were ultimately excluded
from further consideration based on EPA's integration approach for environmental release and occupational exposure
data/information. EPA's approach uses a hierarchy of preferences that guide decisions about what types of data/information
are included for further analysis, synthesis and integration into the environmental release and occupational exposure
assessments. EPA prefers using data with the highest rated quality among those in the higher level of the hierarchy of
preferences (i.e., data > modeling > occupational exposure limits or release limits). If warranted, EPA may use data/information
of lower rated quality as supportive evidence in the environmental release and occupational exposure assessments.

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2018

'The quality of data in these sources were acceptable for risk assessment purposes and considered for
integration. The sources; however, were not extracted for a variety of reasons, such as they contained only
secondary source data, duplicate data, or n on-extracts ble data (i.e., charts or figures). Additionally, some
data sources were not as relevant to the PECO as other data sources which were extracted.

Figure 1-7. Literature Flow Diagram for Consumer and Environmental Exposure Data Sources

Note: EPA conducted a literature search to determine relevant data sources for assessing exposures for trichloroethylene
within the scope of the risk evaluation. This search identified 1149 data sources including relevant supplemental documents.
Of these, 998 were excluded during the screening of the title, abstract, and/or full text and 151 data sources were
recommended for data evaluation across up to five major study types in accordance with Appendix E:Data Quality Criteria
for Studies on Consumer, General Population and Environmental Exposure of the Application of Systematic Review for
TSCA Risk Evaluations document (U.S. EPA. 2018b). Following the evaluation process, 79 references were forwarded for
further extraction and data integration. EPA lias not developed data quality criteria for all types of exposure information
some of which may be relevant when estimating consumer exposures. This is the case for absorption and permeability data
and some product-specific data such as density and weight fraction often reported in Safety Data Sheets. As appropriate, EPA
evaluated and summarized these data to determine their utility with supporting the risk evaluation.

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Figure 1-8. Literature Flow Diagram for Environmental Hazard

Note: The environmental hazard data sources were identified through literature searches and screening strategies using the
ECOTOXicology Knowledgebase System (ECOTOX) Standing Operating Procedures. For studies determined to be on-topic
after title and abstract screening, EPA conducted a full text screening to further exclude references that were not relevant to
the risk evaluation. Screening decisions were made based on eligibility criteria as documented in the ECOTOX User Guide
(U.S. EPA. 2018c). Additional details can be found in the Strategy for Conducting Literature Searches for Trichloroethvlene
Supplemental Document to the TSCA Scope Document (U.S. EPA. 2017e).

The "Key/Supporting Studies" box represents data sources cited in an existing assessment (Enviromnent Canada and Health
Canada. 1993) that were considered highly relevant for the TSCA risk evaluation because they were used as key and
supporting information by another regulatory organization to support their chemical hazard and risk assessment. These
citations were found independently from the ECOTOX process. These studies bypassed the data screening step and moved
directly to the data evaluation step. These two studies were ultimately excluded because they examined hazard to terrestrial
species and the relevant exposure pathway of air releases has since been determined to be out of scope.

The literature search process for enviromnental hazard data found 8,565 citations for TCE. At the title and abstract screening
phase, 8,144 citations were excluded as off-topic using ECOTOXicology knowledgebase criteria. The remaining 419
citations underwent a more thorough full text screening using the same criteria to determine which citations should undergo
data evaluation. For data evaluation, EPA developed data quality evaluation (DQE) criteria to evaluate the data under TSCA,
based on a combination of EPA's ECOTOXicology knowledgebase (ECOTOX) criteria and the Criteria for Reporting and
Evaluating ecotoxicity Data (CRED). There were 71 citations that went to data evaluation for TCE, which included the
above-mentioned two additional citations gathered from (Environment Canada and Health Canada. 1993) that were later
excluded as out of scope. EPA analyzed each of these studies using the DQE results to determine overall study quality.
Twenty-five studies were considered acceptable and were rated high, medium or low quality during this analysis. The
extracted data from these 25 studies were used during data integration for TCE.

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Data Extraction/Data Integration (n = 170)

Figure 1-9. Literature Flow Diagram for Human Health Hazard

Note: The literature search results for human health hazard of TCE yielded 6,049 studies. This included 95 key and
supporting studies identified from previous EPA assessments. Of the 5,954 new studies screened for relevance, 5,869 were
excluded as off topic. The remaining 85 new studies together with the 95 key and supporting studies entered data evaluation.
Ten studies were deemed unacceptable based on the evaluation criteria for human health hazard data sources and the
remaining 170 studies were carried forward to data extraction/data integration. Additional details can be found in the Strategy
for Conducting Literature Searches for Trichloroethylene Supplemental Document to the TSCA Scope Document (U.S. EPA,
20.1.761,

The "Key/Supporting Studies" box represents data sources cited in an existing assessment (U.S. EPA. 201.1.el that were
considered highly relevant for the TSCA risk evaluation because they were used as key and supporting information by
another regulatory organization to support their chemical hazard and risk assessment. For a list of the key and supporting
studies, see [List of Key and Supporting Studies for Human Health Hazard. Docket # EPA-HQ-OPPT-2019-0500],

1,5.2 Data Evaluation

During the data evaluation stage, the EPA assesses the quality of the methods and reporting of results of
the individual studies identified during problem formulation using the evaluation strategies described in
Application of Systematic Review in TSCA Risk Evaluations (	!b). The EPA evaluated the

quality of the on-topic TCE study reports identified in [Trichloroethylene (CASRN 79-01-6)
Bibliography: Supplemental File for the TSCA Scope Document; (	)], and gave all

studies an overall high, medium, low or unacceptable confidence rating during data evaluation.

The results of the data quality evaluations for key studies are summarized in Section 2.1 (Fate and
Transport), Section 2.2.2 (Releases to the Environment), Section 2.2.6 (Environmental Exposures),
Section 2.3 (Human Exposures), Section 3.1 (Environmental Hazards) and Section 3.2 (Human Health
Hazards). Supplemental files7 also provide details of the data evaluations including individual metric
scores and the overall study score for each data source (Docket: EPA-HQ-OPPT-2019-0500).

7 See Appendix B for the list of all supplemental files.

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1.5.3 Data Integration

Data integration includes analysis, synthesis and integration of information for the risk evaluation.
During data integration, the EPA considers quality, consistency, relevancy, coherence and biological
plausibility to make final conclusions regarding the weight of the scientific evidence. As stated in
Application of Systematic Review in TSCA Risk Evaluations (	018b), data integration

involves transparently discussing the significant issues, strengths, and limitations as well as the
uncertainties of the reasonably available information and the major points of interpretation (U.S. EPA.
2018e). EPA defines "reasonably available information" to mean information that EPA possesses, or can
reasonably obtain and synthesize for use in risk evaluations, considering the deadlines for completing
the evaluation (Procedures for Chemical Risk Evaluation Under the Amended Toxic Substances Control
Act (82 FR 33726).

EPA used previous assessments (see Table 1-3) to identify key and supporting information and then
analyzed and synthesized available evidence regarding TCE's chemical properties, environmental fate
and transport properties and its potential for exposure and hazard. EPA's analysis also considered recent
data sources that were not considered in the previous assessments (Section 1.5.1) as well as reasonably
available information on potentially exposed or susceptible subpopulations.

The exposures and hazards sections describe EPA's analysis of the influential information (i.e., key and
supporting data) that were found acceptable based on the data quality reviews as well as discussion of
other scientific knowledge using the approach described in Section 1.5.1. The exposure section also
describes whether aggregate or sentinel exposures to a chemical substance were considered under the
conditions of use within the scope of the risk evaluation, and the basis for that consideration.

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1	2 EXPOSURES

2	For TSCA exposure assessments, EPA evaluated exposures and releases to the environment resulting

3	from the conditions of use applicable to TCE. Post-release pathways and routes were described to

4	characterize the relationship or connection between the conditions of use for TCE (Section 1.4.1) and

5	the exposure to human receptors, including potentially exposed or susceptible subpopulations (PESS)

6	and ecological receptors. EPA considered, where relevant, the duration, intensity (concentration),

7	frequency and number of exposures in characterizing exposures to TCE.

8

9	2.1 Fate and Transport

10	Environmental fate includes both transport and transformation processes. Environmental transport is the

11	movement of the chemical within and between environmental media. Transformation occurs through the

12	degradation or reaction of the chemical with other species in the environment. Hence, knowledge of the

13	environmental fate of the chemical informs the determination of the specific exposure pathways and

14	potential human and environmental receptors EPA expects to consider in the risk evaluation. Table 2-1

15	presents environmental fate data that EPA identified and considered in the Scoping and Problem

16	Formulation documents as well as additional data extracted form the systematic review process.

17

18	Table 2-1 Environmental Fate Characteristic of TCE

Property or
Endpoint

Value a

References

Data Quality
Rating

Indirect

photodegradation

1-11 days (atmospheric oxidation based on
measured hydroxyl radical oxidation)

( 2014b")

High

Hydrolysis half-life

10.7 months (average; decomposition in aerated
water in the dark; part of the reaction may have
occurred in the vapor phase)

(Billing et al.„ 1975)

High

Biodegradation

38.9% after 28 days (aerobic OECD 302B
Inherent biodegradability test)

(Tobaias et al„ 2016)

High



100% degradation after 60 days (anaerobic
serum bottle test)

(Long et al„ 1993)

High



100%) degradation after 40 days (anaerobic
groundwater microcosms with added
hydrogen/acetate)

(Schmidt and Tiehm.
2008)

High



TCE removed slowly with a reduction of 40%
after 8 weeks (TCE (200 (J,g/L) incubated with
batch bacterial cultures under methanogenic
conditions)

(Bouwer and
McCartv. 1983)

High

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Property or
Endpoint

Value a

References

Data Quality
Rating



99.98% degradation after 2 or 4 days (anaerobic
continuous flow)

100% degradation after 20 days (aerobic with
Methane culture, aerobic with phenol culture)

(Vogel and McCartv.

1985)

(Long et al.„ 1993)

High
High

Bi oconcentrati on
factor (BCF)

17 (Bluegill)

(Barrows et al.„ 1980)

High

Bioaccumulation
factor (BAF)

24 (estimated)

( 2012b)

High

Organic
carbon: water
partition coefficient
(Log Koc)

1.8 (estimated)

( 2012b)

High

a Measured unless otherwise noted

19

20	2.1.1 Fate and Transport Approach and Methodology

21	EPA gathered and evaluated environmental fate information according to the process described in the

22	Application of Systematic Review in TSCA Risk Evaluations (	b). Reasonable available

23	environmental fate data, including biotic and abiotic degradation rates, removal during wastewater

24	treatment, volatilization from lakes and rivers, and organic carbon:water partition coefficient (Koc) were

25	selected for use in this assessment document.

26

27	Other fate estimates were based on modeling results from EPI (Estimation Programs Interface) Suite™

28	(U .S. EPA. 2012b). a predictive tool for physical/chemical and environmental fate properties

29	(https://www.epa.gov/tsca-screening-tools/epi-suitetm-estimation-program-interface). EPI Suite™ was

30	reviewed by the EPA Science Advisory Board

31	(http://YOsemite.epa.eov/sab/sabprodiict.nsf/02ad90bl36fc21eS5256eba00436459/CCF982BA.9816

32	F9CFCFA8525735200739805/$File/si	pdf) and the individual models have been peer

33	reviewed in numerous articles published in technical journals. Citations for such articles are available in

34	the EPI Suite™ help files. Table 2-1 provides environmental fate data that EPA considered while
3 5	assessing the fate of TCE.

36	2.1.2 Summary of Fate and Transport

37	The EPI Suite™ (	) STP model was run using default settings (set biodegradation half-

38	life to 10,000 hours) to evaluate the potential for TCE to volatilize to air or adsorb to sludge during

39	wastewater treatment. In order to improve the accuracy of the EPI Suite™ estimations, physical and

40	chemical properties (Log Kow, Boiling point, Melting point, Vapor Pressure, Water solubility, Henry's

41	Law Constant) from Table 1-1 were entered into EPI Suite along with TCE's SMILES notation entry

42	(C(=CCL)(CL)CL) before running the module.

43

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If TCE is released to the air, TCE does not absorb radiation well at wavelengths that are present in the
lower atmosphere (>290 nm) so direct photolysis is not a main degradation process. Degradation by
reactants in the atmosphere has a half-life of several days meaning that long range transport is possible.

If TCE is released to water, sediment or soil, the fate of TCE is influenced by volatilization from the
water surface or from soil as indicated by its physical chemical properties (e.g., Henry's law constant)
and by microbial biodegradation under some conditions. The EPI Suite™ model that estimates
volatilization from lakes and rivers ("Volatilization" model) was run using default settings to evaluate
the volatilization half-life of TCE in surface water. The volatilization model estimates that the half-life
of TCE in a model river is 1.2 hours and the half-life in a model lake is 110 hours. Therefore, the
volatilization is likely to be a significant removal process.

If TCE is released to wastewater treatment, the removal percentage of TCE is estimted by using the STP
model in EPI Suite™ as 81%, including 80% removal via volatilization and 1% removal via adsorption.
This value (81%) is used for the calculation of exposure assement in this document. Therefore, TCE is
not anticipated to partition to biosolids during wastewater treatment. Any TCE present in the water
portion of biosolids following wastewater treatment and land application would be expected to rapidly
volatilize into air. To further support this analysis, TCE was not detected in EPA's Targeted National
Sewage Sludge Survey (TNSSS) nor was it reported in biosolids during EPA's Biennial Reviews for
Biosolids, a robust biennial literature review conducted by EPA's Office of Water (	).

Furthermore, TCE is not anticipated to remain in soil, as it is expected to either volatilize into air or
migrate through soil into groundwater.

The biodegradation of TCE in the environment is dependent on a variety of factors and thus, a wide
range of degradation rates have been reported (ranging from days to years). The BIOWIN module in the
EPI Suite™ was run using default settings to estimate biodegradation rates of TCE in soil and sediment.
Three out of the four models built in the BIOWIN module (BIOWIN 1, 2, and 5) estimate that TCE will
not rapidly biodegrade in aerobic environments, while a fourth (BIOWIN 6) estimates that TCE will
rapidly biodegrade in aerobic environments. The weight of the scientific evidence from these estimates
suggests that TCE does not biodegrade quickly under aerobic condition. This conclusion is supported by
test results in a frequently cited publication (Rott et at.. 1982) which indicates 19% aerobic
biodegradation in 28 days (OECD 301D) and 2.4% aerobic biodegradation in 14 days (OECD 301C),
respectively. The data was also cited in the 2004 Ell TCE Risk Assessment (ECB. 2004).

During the systematic review process, a high-quality aerobic serum bottle biodegradation study, in
which 100%) degradation occurred in 20 days was reported in methane and phenol cultures. The result
indicates that the aerobic degradation rate with either methane or phenol culture is "fast", is different
from the BIOWIN predictions. However, the "fast" aerobic biodegradation with special cultures cannot
represent general environmental conditions, so the "slow aerobic biodegradation" considered in the
scoping and problem formulation documents was not changed in this risk evaluation document.

During the systematic review for fate endpoints, several high-quality anaerobic biodegradation test data
were identified and inserted into the original fate table summarized in the Problem Formulation
document (	!c). The added anaerobic biodegradation data confirms that TCE anaerobic

biodegradation rate is "fast".

The systematic review did not identify any additional studies for sorption coefficient to soil and
sediments, therefore, the log Koc value was estimated with EPI Suite™ as 1.8, which is close to the
measured values ranged from 1.86 to 2.17 with different soils in the previous TCE assessments (U.S.

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). These log Koc values (1.8-2.17) suggest that the sorption of TCE to soil and sediment is
low and TCE is mobile in soil and sediment.

The systematic review identified a high quality bioconcentration data with low BCF ( BCF=17;

Barrows. 1980). The BAF of TCE is also low (BAF=24) based on EP1 Suite™ estimation. Therefore,
TCE is not expected to accumulate in aquatic organisms due to low BCF and BAF.

2.1.3 Assumptions and Key Sources of Uncertainty for Fate and Transport

A range of biodegradation rates have been reported for TCE. The range of degradation rates reported
were measured in laboratory studies for biodegradation in water, soil and sediment. These studies are
subject to several sources of variability including variability inherent in the methodology,
interlaboratory variability and variability due to factors such as the specific microbial populations used,
water, soil and sediment chemistry, oxygen concentration/redox potential, of the collected samples used
in the study, temperature and test substance concentration. No single value is universally applicable as it
is influenced by these variables and possibly others. However, the weight of evidence shows the aerobic
biodegradation of TCE is slow and the anerobic biodegradation in anaerobic condition is fast.

That range of Log Koc values (1.8-2.17) is supported by the basic principles of environmental chemistry
which states that the Koc is typically within one order of magnitude (one log unit) of the octanol: water
partition coefficient (Kow).

2.2 Environmental Exposures

2.2.1 Environmental Exposures Overview

In this section, EPA presents environmental exposures to TCE for aquatic organisms. Exposure to
terrestrial organisms is expected to be low since physical chemical properties do not support an exposure
pathway through water and soil pathways to these organisms. To characterize environmental exposure,
EPA assessed exposures derived from both predicted and measured concentrations of TCE in surface
water in the U.S.

Aquatic exposures associated with the industrial and commercial conditions of use evaluated were
predicted through modeling. Predicted surface water concentrations resulting from facility releases in
the EPA Lifecycle Release Analysis were generated for reporting year 2016. Release estimates were
based on loading and/or production volume information obtained from TRI, DMR, and CDR (See
Section 2.2.2). The surface water modeling was conducted with EPA's Exposure and Fate Assessment
Screening Tool, version 2014 (E-FAST 20141 using reported annual release/loading amounts (kg/yr)
and estimates of the number of days per year that the annual load is released. The Probabilistic Dilution
Model (PDM), a module of E-FAST 2014, was run to predict the number of days per year predicted
stream concentrations are expected to exceed the designated chronic aquatic concentration of concern
(COC) value.

The aquatic exposure assessment also includes an analysis of collected measured surface water
concentrations from monitoring data in EPA's Water Quality Exchange (WQX) using the online Water
Quality Portal (WQP) tool and published literature obtained and evaluated through a systematic review
process. WQX is the nation's largest source of water quality monitoring data and includes results from
EPA's STORage and RETrieval (STORET) Data Warehouse, the United States Geological Service
(USGS) National Water Information System (NWIS), and other federal, state, and tribal sources. A
literature search was also conducted to identify other peer-reviewed or gray sources of measured surface
water concentrations in the US. The measured concentrations reflect ambient surface water

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concentrations at the monitoring sites but cannot be directly attributed to specific industrial or
commercial conditions of use. A geospatial analysis at the watershed level was conducted to compare
the measured and predicted surface water concentrations and investigate whether modeled facility
releases may be located within the same watershed as observed concentrations in surface water.

2.2.2 Environmental Releases to Water

EPA categorized the conditions of use (COUs) listed in Table 1-4 into 18 Occupational Exposure
Scenarios (OES). For each OES, a daily water release was estimated based on annual releases, release
days, and the number of facilities (Figure 2-1). In this section, EPA describes its approach and
methodology for estimating daily water releases, and for each OES, provides a summary of release days,
number of facilities, and daily water releases. For detailed facility level results, see Appendix P of this
document and the "Water Release Assessment" section for each OES in [.Environmental Releases and
Occupational Exposure Assessment. Docket: EPA-HO-OPPT-2019-0500)\.

Figure 2-1: An overview of how EPA estimated daily water releases for each OES.8

2.2.2.1 Results for Daily Release Estimate

EPA combined its estimates for annual releases, release days, and number of facilities to estimate a
range for daily water releases for each OES. A summary of these ranges across facilities is presented in
Table 2-2. See Table 2-5 for more details on deriving the overall confidence score for each OES. For
some OES, EPA was not able to estimate or did not expect water releases. For example:

•	OES Aerosol Application: Water releases were not expected due to the volatile nature of TCE;
releases from this OES are expected to be to air.

•	OES Formulation of Aerosol and Non-Aerosol Products: All releases reported in TRI were
to off-site land, incineration, or recycling.

8 TRI = Toxics Release Inventory; DMR = Discharge Monitoring Report; NEI = National Emissions Inventory; CDR =
Chemical Data Reporting; ELG = Effluent Limitation Guidelines; ESD = Emission Scenario Document

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169	Table 2-2: Summary of EPA's daily water release estimates for each OES and also EPA's Overall

170	Confidence in these estimates.

Occupational Exposure
Scenario (OES)

Estimat
Release
Acros
(kg/sil

ed Daily
; Range
s Sites
e-day)

Overall
Confidence

Source and Notes

Minimum

Maximum

Manufacturing

0

1.27

M

From TRI, DMR

Processing as a Reactant

1.7E-03

0.02

M

From TRI, DMR

Formulation of Aerosol and
Non-Aerosol Products







No information
identified to estimate
water releases

Repackaging

6.8E-06

1.1

M

From TRI, DMR

Batch Open-Top Vapor
Degreasing

2.53E-07

1.96

M

From TRI, DMR

Batch Closed-Loop Vapor
Degreasing

2.53E-07

1.96

M

Same as Batch Open-
Top Vapor Degreasing3

Conveyorized Vapor
Degreasing

2.53E-07

1.96

M

Same as Batch Open-
Top Vapor Degreasing3

Web Vapor Degreasing

2.53E-07

1.96

M

Same as Batch Open-
Top Vapor Degreasing3

Cold Cleaning

2.53E-07

1.96

M

Same as Batch Open-
Top Vapor Degreasing3

Aerosol Applications: Spray
Degreasing/Cleaning,
Automotive Brake and Parts
Cleaners, Penetrating
Lubricants, and Mold Releases





H

EPA expects releases of
TCE to be to air for this
OES

Metalworking Fluids

2.53E-07

1.96

M

Same as Batch Open-
Top Vapor Degreasing3

Adhesives, Sealants, Paints,
and Coatings

3.68E-06

0.30

M

From TRI, DMR

Other Industrial Uses

9.2E-06

1.6

M

From DMR

Spot Cleaning and Wipe
Cleaning

2.9E-05

8.0E-05

M

From DMR

Industrial Processing Aid

5.5E-04

0.4

M

From TRI, DMR

Commercial Printing and
Copying

2.0E-04

2.0E-04

-

Based on only one
reported release in DMR

Other Commercial Uses

1.9E-06

0.013

M

From DMR

Process Solvent Recycling and
Worker Handling of Wastes

1.6E-06

24.1

M

From TRI, DMR

171	a Water releases from OTVD were repeated for other degreasing operations and for MWF because the releases were

172	estimated using TRI and DMR data. Due to the limited information in these reporting programs, these sites may in fact not

173	operate OTVDs, but may operate other solvent cleaning machines or perform metalworking activities (e.g., closed-loop

174	degreasing, conveyorized degreasing, web cleaning, or cold cleaning) or use of TCE as a metalworking fluid. They are

175	included in the OTVD assessment as EPA expects OTVDs to be the most likely condition of use. EPA assessed annual

176	releases as reported in the 2016 TRI or 2016 DMR and assessed daily releases by assuming 260 days of operation per year, as

177	recommended in the 2017 ESD on Use of Vapor Degreasers, and averaging the annual releases over the operating days.

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2.2,2.2 Approach and Methodology

2.2.2.2.1	Water Release Estimates

Where available, EPA used 2016 TR1 (	) and 2016 DMR (	i) data to

provide a basis for estimating releases. Facilities are only required to report to TRI if the facility has 10
or more full-time employees, is included in an applicable NAICS code, and manufactures, processes, or
uses the chemical in quantities greater than a certain threshold (25,000 pounds for manufacturers and
processors of TCE and 10,000 pounds for users of TCE). Due to these limitations, some sites that
manufacture, process, or use TCE may not report to TRI and are therefore not included in these datasets.

For the 2016 DMR (	), EPA used the Water Pollutant Loading Tool within EPA's

Enforcement and Compliance History Online (ECHO) to query all TCE point source water discharges in
2016. DMR data are submitted by National Pollutant Discharge Elimination System (NPDES) permit
holders to states or directly to the EPA according to the monitoring requirements of the facility's permit.
States are only required to load major discharger data into DMR and may or may not load minor
discharger data. The definition of major vs. minor discharger is set by each state and could be based on
discharge volume or facility size. Due to these limitations, some sites that discharge TCE may not be
included in the DMR dataset.

Where releases are expected but TRI and DMR data were not available or where EPA determined TRI
and DMR data did not sufficiently represent releases of TCE to water for a condition of use, releases
were estimated using data from literature, relevant Emission Scenario Documents (ESDs) or Generic
Scenarios (GSs), existing EPA models (e.g., EPA Water Saturation Loss Model), and/or relevant
Effluent Limitation Guidelines (ELG). ELG are national regulatory standards set forth by EPA for
wastewater discharges to surface water and municipal sewage treatment plants. For more details, please
refer to Appendix I.

2.2.2.2.2	Estimates of Number of Facilities

Where available, EPA used 2016 CDR (	), 2016 TRI (	), 2016

Discharge Monitoring Report (DMR) (I v 
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•	Information obtained from public comments and/or industry meetings with EPA that provided
specific information on the site.

In DMR, the only information reported on condition of use is each site's Standard Industrial
Classification (SIC) code. EPA could not determine each reporting site's condition of use based on SIC
code alone; therefore, EPA supplemented the SIC code information with the same supplementary
information used for the TRI sites (market data, public comments, and industry meetings).

The National Emissions Inventory (NEI) is a comprehensive and detailed estimate of air emissions of
criteria pollutants, criteria precursors, and hazardous air pollutants from air emissions sources. The NEI
is released every three years based primarily upon data provided by State, Local, and Tribal air agencies
for sources in their jurisdictions and supplemented by data developed by the US EPA. The inventory
includes emissions estimates for larger sources that are located at a fixed, stationary location (point
sources) and emissions estimates for sources which individually are too small in magnitude to report as
point sources (nonpoint sources). In NEI, facilities report on the equipment or process sources for their
facility emissions. Based on these reported point sources for TCE emissions, EPA could generally
determine which condition of use the facility fell in.

Where the number of sites could not be determined using CDR/TRI/DMR/NEI or where these data
sources were determined to insufficiently capture the number of sites within a condition of use, EPA
supplemented the reasonably available information with U.S. economic data using the following
method:

•	Identify the North American Industry Classification System (NAICS) codes for the industry
sectors associated with these uses.

•	Estimate total number of sites using the U.S. Census' Statistics of US Businesses (SUSB) (U.S.
Census Bureau. 2015) data on total establishments by 6-digit NAICS.

•	Use market penetration data to estimate the percentage of establishments likely to be using TCE
instead of other chemicals.

•	Combine the data generated in Steps 1 through 3 to produce an estimate of the number of sites
using TCE in each 6-digit NAICS code, and sum across all applicable NAICS codes for the
condition of use to arrive at a total estimate of the number of sites within the condition of use.

Table 2-3: Summary of EPA's estimates for the number of facilities for each PES.

Occupational Exposure
Scenario (OES)

Number of
Facilities

Notes

Manufacturing

5

Based on CDR reporting

Processing as a Reactant

5 to 440

Based on TRI and DMR reporting, and Census data for
NAICS 325120 (Industrial Gas Manufacturing)

Formulation of Aerosol and
Non-Aerosol Products

19

Based on TRI reporting

Repackaging

22

Based on TRI and DMR reporting

Batch Open-Top Vapor
Degreasing

194

Based on NEI and TRI reporting

Batch Closed-Loop Vapor
Degreasing

4

Based on NEI reporting

Conveyorized Vapor
Degreasing

8

Based on NEI reporting

Web Vapor Degreasing

1

Based on NEI reporting

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Occupational Exposure
Scenario (OES)

N il in her of
l-'acilities

Notes

Cold Cleaning

13

Based on NEI reporting

Aerosol Applications: Spray
Degreasing/Cleaning,
Automotive Brake and Parts
Cleaners, Penetrating
Lubricants, and Mold Releases

4,366

Based on Census data and market penetration estimates
based on California Air Resources Board (CARB) survey
of automotive maintenance and repair facilities

Metalworking Fluids

-

No information identified to estimate number of facilities

Adhesives, Sealants, Paints, and
Coatings

70

Based on NEI, TRI, and DMR reporting

Other Industrial Uses

49

Based on TRI and DMR reporting

Spot Cleaning and Wipe
Cleaning

63,748

Based on Census data for NAICS codes 812300, 812320,
561740; assumed 100% market penetration for TCE.

Industrial Processing Aid

18

Based on TRI and DMR reporting

Commercial Printing and
Copying

-

No information identified to estimate number of facilities

Other Commercial Uses

-

No information identified to estimate number of facilities

Process Solvent Recycling and
Worker Handling of Wastes

30

Based on TRI and DMR reporting

257

258

259

260

261

262

2,2.2,2,3 Estimates of Release Days

EPA referenced Emission Scenario Documents (ESDs) or needed to make assumptions when estimating
release days for each OES. A summary along with a brief explanation is presented in Table 2-4 below.

Table 2-4: Summary of EPA's estimates for

release days expected for each OES.

Occupational Exposure
Scenario (OES)

Release
Davs

Notes

Manufacturing

350

Assumed seven days per week and 50 weeks per year with
two weeks per year for shutdown activities.

Processing as a Reactant

350

Assumed seven days per week and 50 weeks per year with
two weeks per year for shutdown activities.

Formulation of Aerosol and
Non-Aerosol Products

-

Water releases not estimated for this OES.

Repackaging

250

Assumed 5 days per week and 50 weeks per year.

Batch Open-Top Vapor
Degreasing

260

2017 ESD on Use of Vapor Degreasing

Batch Closed-Loop Vapor
Degreasing

260

2017 ESD on Use of Vapor Degreasing

Conveyorized Vapor
Degreasing

260

2017 ESD on Use of Vapor Degreasing

Web Vapor Degreasing

260

2017 ESD on Use of Vapor Degreasing

Cold Cleaning

260

2017 ESD on Use of Vapor Degreasing

Aerosol Applications: Spray
Degreasing/Cleaning,
Automotive Brake and Parts
Cleaners, Penetrating
Lubricants, and Mold Releases



Water releases not expected from this OES.

Metalworking Fluids

260

2017 ESD on Use of Vapor Degreasing

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Occupational Exposure
Scenario (OES)

Release
Days

Notes

Adhesives, Sealants, Paints, and
Coatings

250

2011 ESD on the Application of Radiation Curable
Coatings, Inks, and Adhesives via Spray, Vacuum, Roll
and Curtain Coating

Other Industrial Uses

250

Assumed 5 days per week and 50 weeks per year.

Spot Cleaning and Wipe
Cleaning

300

Assumed 6 days per week and 50 weeks per year.

Industrial Processing Aid

300

Assumed 6 days per week and 50 weeks per year.

Commercial Printing and
Copying

250

Assumed 5 days per week and 50 weeks per year.

Other Commercial Uses

250

Assumed 5 days per week and 50 weeks per year.

Process Solvent Recycling and
Worker Handling of Wastes

250

Assumed 5 days per week and 50 weeks per year.

2.2.2.3 Assumptions and Key Sources of Uncertainty for Environmental
Releases

EPA estimated water releases using reported discharges from the 2016 TRI and the 2016 DMR. TRI and
DMR data were determined to have a "medium" confidence rating through EPA's systematic review
process. Due to reporting requirements for TRI and DMR, the number of sites for a given OES may be
underestimated. It is uncertain, the extent to which, sites not captured in these databases discharge
wastewater containing TCE and whether any such discharges would be to surface water, POTW, or non-
POTW WWT.

In addition, information on the use of TCE at facilities in TRI and DMR is limited; therefore, there is
some uncertainty as to whether the number of facilities estimated for a given OES do in fact represent
that specific OES. If sites were categorized under a different OES, the annual wastewater discharges for
each site would remain unchanged; however, average daily discharges may change depending on the
release days expected for the different OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess daily discharges, EPA
estimated the release days and averaged the annual releases over these days. There is some uncertainty
that all sites for a given OES operate for the assumed duration; therefore, the average daily discharges
may be higher if sites have fewer release days or lower if they have greater release days. TRI-reporting
facilities are required to submit their "best available data" to EPA for TRI reporting purposes. Some
facilities are required to measure or monitor emission or other waste management quantities due to
regulations unrelated to the TRI Program (e.g., permitting requirements), or due to company policies.
These existing, reasonably available data are often used by facilities for TRI reporting purposes, as they
represent the best available data. When monitoring or direct measurement data are not reasonably
available, or are known to be non-representative for TRI reporting purposes, the TRI regulations require
that facilities determine release and other waste management quantities of TRI-listed chemicals by
making reasonable estimates. These reasonable estimates may be obtained through various Release
Estimation Techniques, including mass-balance calculations, the use of emission factors, and
engineering calculations. There may be greater uncertainty in data resulting from estimates compared to
monitoring measurements. However, available monitored data that showed ambient water
concentrations were not useful in corroborating the modeling approach because most of them were far
downstream from the near-facility modeled concentration estimates.

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Furthermore, TCE concentrations in wastewater discharges at each site may vary from day-to-day such
that on any given day the actual daily discharges may be higher or lower than the estimated average
daily discharge.

In some cases, the number of facilities for a given OES was estimated using data from the U.S. Census.
In such cases, the average daily release calculated from sites reporting to TRI or DMR was applied to
the total number of sites reported in (U.S. Census Bureau. 2015). It is uncertain how accurate this
average release is to actual releases at these sites; therefore, releases may be higher or lower than the
calculated amount.

The 2014 NEI was also used to estimate the number of facilities for various OES. NEI does not report
water release information, therefore, an average release was calculated from the sites reporting water
releases to TRI and DMR and applied to sites reported in NEI. It is uncertain how accurate this average
release is to actual releases at these sites; therefore, releases may be higher or lower than the calculated
amount.

2.2.2.3.1^ Summary of Overall Confidence in Release Estimates

Table 2-5 provides a summary of EPA's overall confidence in its release estimates for each of the
Occupational Exposure Scenarios assessed.

Table 2-5: Summary of Overall Confidence in Release Estimates by OES.

Occupational Exposure
Scenario (OES)

Overall Confidence in Release Estimates

Manufacturing

Wastewater discharges are assessed using reported discharges from the 2016
TRI for three sites. TRI data were determined to have a "medium"' confidence
rating through EPA's systematic review process. Facilities reporting to TRI
only report annual discharges; to assess daily discharges, EPA assumed 350
days/yr of operation and averaged the annual discharges over the operating
days. There is some uncertainty that all sites manufacturing TCE will operate
for this duration; therefore, the average daily discharges may be higher if sites
operate for fewer than 350 days/yr or lower if they operate for greater than 350
days/yr. Furthermore, TCE concentrations in wastewater discharges at each
site may vary from day-to-day such that on any given day the actual daily
discharges may be higher or lower than the estimated average daily discharge.
One of the three sites reporting to TRI also reported to DMR. This information
was also assessed. The same uncertainties discussed above for TRI releases
also apply to the DMR data. Based on this information, EPA has a medium
confidence in the wastewater discharge estimates for the four sites in the 2016
TRI and 2016 DMR.

Water discharges from the remaining two sites were estimated using the
maximum daily and monthly discharge limits in the OCPSF EG and the
estimated volume of wastewater produced per pound of TCE production from
the Specific Environmental Release Category (SpERC) developed by the
European Solvent Industry Group for the manufacture of a substance. The
estimates assume the sites operate at the limits set by the EG; actual releases
may be lower for sites operating below the limits or higher for sites not in
compliance with the OCPSF EG. Based on this information EPA has a
medium confidence in the wastewater discharge estimates for these two sites.

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Occupational Exposure
Scenario (OES)

Overall Confidence in Release Estimates

Processing as a Reactant

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.
Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are processing TCE as a reactant rather than a
different OES. If the sites were categorized under a different OES, the annual
wastewater discharges for each site would remain unchanged; however,
average daily discharges may change depending on the number of operating
days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 350 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites processing TCE as a reactant will operate for this duration; therefore, the
average daily discharges may be higher if sites operate for fewer than 350
days/yr or lower if they operate for greater than 350 days/yr. Furthermore,
TCE concentrations in wastewater discharges at each site may vary from day-
to-day such that on any given day the actual daily discharges may be higher or
lower than the estimated average daily discharge. Based on this information,
EPA has a medium confidence in the wastewater discharge estimates.

Formulation of Aerosol and
Non-Aerosol Products

All sites reporting in TRI show zero water releases; EPA does not expect
water releases from this OES.

Repackaging

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.
Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are performing repackaging activities rather than
a different OES. If the sites were categorized under a different OES, the
annual wastewater discharges for each site would remain unchanged; however,
average daily discharges may change depending on the number of operating
days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 250 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites repackaging TCE will operate for this duration; therefore, the average
daily discharges may be higher if sites operate for fewer than 250 days/yr or
lower if they operate for greater than 250 days/yr. Furthermore, TCE

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Omipsilioiiiil Kxposurc
Sronsirio (OKS)

Ovcrsill ( onfklciKT in Uclcsisc Kslimsilcs



concentrations in wastewater discharges at each site may vary from day-to-day
such that on any given day the actual daily discharges may be higher or lower
than the estimated average daily discharge. Based on this information, EPA
has a medium confidence in the wastewater discharge estimates.

Batch Open-Top Vapor
Degreasing

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR EPA does not expect all sites using
TCE in OTVD to be captured in the databases. It is uncertain the extent that
sites not captured in these databases discharge wastewater containing TCE and
whether any such discharges would be to surface water, POTW, or non-POTW
WWT; however, the sites may be required to comply with an EG depending
on the industry in which the OTVD is being used. Additionally, information
on the conditions of use of TCE at facilities in TRI and DMR is limited;
therefore, there is some uncertainty as to whether all of the sites assessed in
this section are using TCE in OTVD rather than a different OES (including
other vapor degreasing and cold cleaning operations and use of TCE in
metalworking fluids). If the sites were categorized under a different OES, the
annual wastewater discharges for each site would remain unchanged; however,
average daily discharges may change depending on the number of operating
days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 260 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites using TCE in OTVDs will operate for this duration; therefore, the
average daily discharges may be higher if sites operate for fewer than 260
days/yr or lower if they operate for greater than 260 days/yr. Furthermore,
TCE concentrations in wastewater discharges at each site may vary from day-
to-day such that on any given day the actual daily discharges may be higher or
lower than the estimated average daily discharge. Based on this information,
EPA has a medium confidence in the wastewater discharge estimates.

Batch Closed-Loop Vapor
Degreasing

Same as the Open-Top Vapor Degreasing (OTVD) OES.

Conveyorized Vapor
Degreasing

Same as the Open-Top Vapor Degreasing (OTVD) OES.

Web Vapor Degreasing

Same as the Open-Top Vapor Degreasing (OTVD) OES.

Cold Cleaning

Same as the Open-Top Vapor Degreasing (OTVD) OES.

Aerosol Applications:

Spray Degreasing/Cleaning,
Automotive Brake and
Parts Cleaners, Penetrating
Lubricants, and Mold
Releases

EPA assessed no wastewater discharges for this OES. There is some
uncertainty as to whether and how much TCE may deposit on shop floors.
However, due to the volatility of TCE, EPA expects TCE to evaporate from
any such deposit prior to it being discharged; thus, limiting any potential
discharges to surface water, POTW, or non-POTW WWT from this source.
Based on this information, EPA has a high confidence in the release
assessment.

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Occupational Exposure
Scenario (OES)

Overall Confidence in Release Estimates

Metalworking Fluids

Same as the Open-Top Vapor Degreasing (OTVD) OES.

Adhesives, Sealants, Paints,
and Coatings

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR, the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.
Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are performing adhesive, sealant, paint or coating
activities rather than a different OES. If the sites were categorized under a
different OES, the annual wastewater discharges for each site would remain
unchanged; however, average daily discharges may change depending on the
number of operating days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 250 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites using TCE in adhesives, sealants, paints and coatings will operate for this
duration; therefore, the average daily discharges may be higher if sites operate
for fewer than 250 days/yr or lower if they operate for greater than 250
days/yr. Furthermore, TCE concentrations in wastewater discharges at each
site may vary from day-to-day such that on any given day the actual daily
discharges may be higher or lower than the estimated average daily discharge.

There is further uncertainty that the number of sites obtained from the 2014
NEI represent the total number of sites using adhesives, sealants, paints or
coatings containing TCE. NEI data only covers specific industries which may
not capture the entirety of industries using these products and NEI does not
include operations that are classified as area sources because area sources are
reported at the county level and do not include site-specific information. It is
uncertain the extent that sites not captured in this assessment discharge
wastewater containing TCE and whether any such discharges would be to
surface water, POTW, or non-POTW WWT. Also, NEI do not report water
release information, therefore, an average release was calculated from the sites
reporting water releases to TRI and DMR and applied to sites reported in NEI.
It is uncertain how accurate this average release is to actual releases as these
sites; therefore, releases may be higher or lower than the calculated amount.
Based on this information, EPA has a medium confidence in the wastewater
discharge estimates.

Other Industrial Uses

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR, the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.

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Occupational Exposure
Scenario (OES)

Overall Confidence in Release Estimates



Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are performing other industrial uses rather than a
different OES. If the sites were categorized under a different OES, the annual
wastewater discharges for each site would remain unchanged; however,
average daily discharges may change depending on the number of operating
days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 250 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites using TCE for other industrial uses will operate for this duration;
therefore, the average daily discharges may be higher if sites operate for fewer
than 250 days/yr or lower if they operate for greater than 250 days/yr.
Furthermore, TCE concentrations in wastewater discharges at each site may
vary from day-to-day such that on any given day the actual daily discharges
may be higher or lower than the estimated average daily discharge. Based on
this information, EPA has a medium confidence in the wastewater discharge
estimates.

Spot Cleaning and Wipe
Cleaning

Wastewater discharges from spot cleaning facilities at industrial launderers are
assessed using reported discharges from the 2016 DMR. DMR data were
determined to have a "medium" confidence rating through EPA's systematic
review process. DMR only contains information for 2 sites. Additional sites
may not be in DMR because they may have no water discharges or because
they discharge to sewer rather than surface water (sewer discharges not
reported in DMR). Facilities reporting to DMR only report annual discharges;
to assess daily discharges, EPA assumed annual days of operation and
averaged the annual discharges over the operating days. There is some
uncertainty that all industrial launderers using TCE will operate for this
duration; therefore, the average daily discharges may be higher if sites operate
for fewer than the operating days or lower if they operate for greater than the
operating days. Furthermore, TCE concentrations in wastewater discharges at
each site may vary from day-to-day such that on any given day the actual daily
discharges may be higher or lower than the estimated average daily discharge.
Based on this information, EPA has a medium confidence in the wastewater
discharge estimates at industrial launderers.

There is further uncertainty that the releases estimated for the total number of
sites obtained from the U.S. Census" Bureau for spot, carpet and wipe cleaning
accurately reflect releases from these sites. An average release was calculated
from the sites reporting water releases to DMR and applied to the total number
of sites rcoortcd in (U.S. Census Bureau. 2015). It is uncertain how accurate this
average release is to actual releases as these sites; therefore, releases may be higher or
lower than the calculated amount. It is also uncertain the extent that sites not captured
in this assessment discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT. Based on
this information, EPA has a medium confidence in the wastewater discharge
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Occupational Exposure
Scenario (OES)

Overall Confidence in Release Estimates

Industrial Processing Aid

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR, the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.
Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are using TCE as an industrial processing aid
rather than a different OES. If the sites were categorized under a different
OES, the annual wastewater discharges for each site would remain unchanged;
however, average daily discharges may change depending on the number of
operating days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 300 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites using TCE as an industrial processing aid will operate for this duration;
therefore, the average daily discharges may be higher if sites operate for fewer
than 300 days/yr or lower if they operate for greater than 300 days/yr.
Furthermore, TCE concentrations in wastewater discharges at each site may
vary from day-to-day such that on any given day the actual daily discharges
may be higher or lower than the estimated average daily discharge. Based on
this information, EPA has a medium confidence in the wastewater discharge
estimates.

Commercial Printing and
Copying

Wastewater discharges from one commercial printing and copying site was
found in the 2016 DMR. DMR data were determined to have a "medium"
confidence rating through EPA's systematic review process. However, EPA
acknowledges this site does not represent the entirety of commercial printing
and copying sites using TCE; data was not reasonably available to estimate
water releases from additional sites.

Other Commercial Uses

Wastewater discharges are assessed using reported discharges from the 2016
DMR. DMR data were determined to have a "medium" confidence rating
through EPA's systematic review process. Due to reporting requirements for
DMR, these sites are not expected to capture the entirety of water releases
from this OES. It is uncertain the extent that sites not captured in DMR
discharge wastewater containing TCE and whether any such discharges would
be to surface water, POTW, or non-POTW WWT. Additionally, information
on the conditions of use of TCE at facilities in DMR is limited; therefore, there
is some uncertainty as to whether all the sites assessed in this section are
performing other commercial uses rather than a different OES. If the sites
were categorized under a different OES, the annual wastewater discharges for
each site would remain unchanged; however, average daily discharges may
change depending on the number of operating days expected for the OES.

Facilities reporting to DMR only report annual discharges; to assess daily
discharges, EPA assumed 250 days/yr of operation and averaged the annual

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Occupational Kxposure
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Overall Confidence in Release Ksliniales



discharges over the operating days. There is some uncertainty that all sites
using TCE in other commercial uses will operate for this duration; therefore,
the average daily discharges may be higher if sites operate for fewer than 250
days/yr or lower if they operate for greater than 250 days/yr. Furthermore,
TCE concentrations in wastewater discharges at each site may vary from day-
to-day such that on any given day the actual daily discharges may be higher or
lower than the estimated average daily discharge. Based on this information,
EPA has a medium confidence in the wastewater discharge estimates.

Process Solvent Recycling
and Worker Handling of
Wastes

Wastewater discharges are assessed using reported discharges from the 2016
TRI and the 2016 DMR. TRI and DMR data were determined to have a
"medium" confidence rating through EPA's systematic review process. Due to
reporting requirements for TRI and DMR, the number of sites in this OES may
be underestimated. It is uncertain the extent that sites not captured in these
databases discharge wastewater containing TCE and whether any such
discharges would be to surface water, POTW, or non-POTW WWT.
Additionally, information on the conditions of use of TCE at facilities in TRI
and DMR is limited; therefore, there is some uncertainty as to whether all the
sites assessed in this section are recycling/disposing of TCE rather than a
different OES. If the sites were categorized under a different OES, the annual
wastewater discharges for each site would remain unchanged; however,
average daily discharges may change depending on the number of operating
days expected for the OES.

Facilities reporting to TRI and DMR only report annual discharges; to assess
daily discharges, EPA assumed 250 days/yr of operation and averaged the
annual discharges over the operating days. There is some uncertainty that all
sites recycling/disposing of TCE will operate for this duration; therefore, the
average daily discharges may be higher if sites operate for fewer than 250
days/yr or lower if they operate for greater than 250 days/yr. Furthermore,
TCE concentrations in wastewater discharges at each site may vary from day-
to-day such that on any given day the actual daily discharges may be higher or
lower than the estimated average daily discharge. Based on this information,
EPA has a medium confidence in the wastewater discharge estimates.

2.2,3 Aquatic Exposure Modeling Approach

Surface water concentrations resulting from wastewater releases of TCE from facilities that use,
manufacture, or process TCE related to the evaluated industrial and commercial conditions of use were
modeled using EPA's Exposure and Fate Assessment Screening Tool, Version 2014 (	;).

E-FAST 2014 estimates chemical concentrations in surface water resulting from releases to surface
water, resulting in exposure estimates at the point of release. Advantages to this model are that it
requires minimal input parameters and it has undergone extensive peer review by experts outside of
EPA. A brief description of the calculations performed within the tool, as well as a description of
required inputs and the methodology to obtain and use inputs specific to this assessment is described
below. To obtain more detailed information on the E-FAST 2014 tool from the model documentation
(I	£007). as well as to download the tool, visit this web address: https://www.epa. gov/tsca-

screening-tools/e-fast-exposure-and-fate-assessment-screening-tool-version-2014/.

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2.2.3.1 Exposure and Fate Assessment Screening (E-FAST) Tool 2014 Inputs

The required modeling inputs are discussed below.

Chemical release to wastewater (WWR)

Annual wastewater loading estimates (kg/site/year or lb/site/year) were predicted in Section 2.2.2 and based on
reported production loading or production volume estimates. To model these releases within Exposure and Fate
Assessment Screening Tool 2014, the annual release is converted to a daily release using an estimated days of
release per year. Below is an example calculation:

WWR (kg/site/day) = Annual loading (kg/site/year) / Days released per year (days/year)

In cases where the total annual release amount from one facility is discharged via multiple mechanisms (i.e.,
direct to surface water and/or indirectly through one or more WWTPs), the annual release amount was divided
accordingly based on reported information in TRI (Form R).

Release Days (days/year)

The number of days per year that the chemical is discharged is used to calculate a daily release amount from
annual loading estimates (see Eq. 3). Current regulations do not require facilities to report the number of days
associated with reported releases. Therefore, two release scenarios were modeled for direct discharging facilities
to provide a range of surface water concentrations predicted by E-FAST 2014. The two scenarios modeled are a
higher release frequency (200 to 365 days) based on release estimates in Section 2.2.2 and a low-end release
frequency of 20 days of release per year as an estimate of releases that could lead to chronic risk for aquatic
organisms. The 20-day chronic risk criterion is derived from partial life cycle tests (e.g., daphnid chronic
and fish early life stage tests) that typically range from 21 to 28 days in duration. For discharges from
water treatment facilities (e.g., POTWs, STPs, WWTPs), only the higher release frequency was modeled
because such treatment sites are anticipated to discharge more frequently than non-treatment facilities.

Removalfrom wastewater treatment (WWR%)

The WWR% is the percentage of the chemical removed from wastewater during treatment before
discharge to a body of water. As discussed in Section 2.1.1, the WWR% for TCE is estimated as 81%.
The WWR% of 81% was applied, when appropriate, to volumes characterized as being transferred off-
site for treatment at a water treatment facility prior to discharge to surface water. A WWR% of zero was
used for direct releases to surface water because the release estimates are based on estimated release
(post-treatment). In cases where it wasn't clear whether the release was direct or indirect, both possible
scenarios were modeled.

Facility or Industry Sector

The required site-specific stream flow or dilution factor information is contained in the E-FAST 2014
database, which is accessed by querying a facility National Pollutant Discharge Elimination System
(NPDES) number, facility name, or reach code. For facilities that directly discharge to surface water (i.e.,

"direct dischargers"), the NPDES of the direct discharger is selected from the database. For facilities that
indirectly discharge to surface water (i.e., "indirect dischargers" because the release is sent to a water treatment
facility prior to discharge to surface water), the NPDES of the receiving treatment facility is selected. The
receiving facility name and location was obtained from the TRI database (Form R), if available. As TRI does not
contain the NPDES of receiving facilities, the NPDES was obtained using EPA's Envirofacts search tool. If a
facility NPDES was not available in the E-FAST-2014 database, the release was modeled using water body data
for a surrogate NPDES (preferred) or an industry sector, as described below.

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Surrogate NPDES: In cases where the site-specific NPDES was not available in the E-FAST 2014
database, the preferred alternative was to select the NPDES for a nearby facility that discharges to the
same waterbody. Nearby facilities were identified using the Chemical Safety Mapper within IGEMS
and/or search of the E-FAST 2014 by reach code.

Industry Sector (SIC Code Option): If the NPDES is unknown, no close analog could be identified,
or the exact location of a chemical loading is unknown, surface water concentrations were modeled
using the "SIC Code Option" within E-FAST 2014. This option uses the 10th and 50th percentile
receiving stream flows for dischargers in a given industry sector, as defined by the Standard Industrial
Classification (SIC) codes of the industry. Table 2-6 below provides the industrial sectors that were
applied as needed for each condition of use category.

Table 2-6 Industry Sector Modeled for Facilities without Site-Specific Flow Data in E-FAST 2014

Condition of Use

Industry Sector in E-FAST 2014 for
Stream Flow Data1

OES: Adhesives, Sealants, Paints, and Coatings

Adhesives and Sealants Manufacture

OES: Commercial Printing and Copying

Printing

OES: Industrial Processing Aid

POTW2 (Industrial)

OES: Manufacturing

Organic Chemicals Manufacture

OES: N/A Water Treatment Facility

POTW2 (Industrial)

OES: Other Commercial Uses

POTW2 (Industrial)

OES: Other Industrial Uses

POTW2 (Industrial)

OES: OTVD (Includes releases for Closed-Loop Degreasing,
Conveyorized Degreasing, Web Degreasing, Cold Cleaning, and
Metalworking Fluids)

Primary Metal Forming Manufacture

OES: Process Solvent Recycling and Worker Handling of Wastes

POTW2 (Industrial)

OES: Processing as a Reactant

Organic Chemicals Manufacture

OES: Repackaging

n/a

OES: Spot Cleaning and Carpet Cleaning

n/a

1	n/a = Not applicable because a NPDES or surrogate NPDES was available in E-FAST 2014 to obtain a site-specific stream
flow for all facilities within the OES.

2	POTW = Publicly Owned Treatment Works

Concentration of Concern

Concentrations of Concern (COCs) are threshold concentrations below which adverse effects on aquatic
life are expected to be minimal. See Section 3.1.5 for a full discussion of acute and chronic COCs for
TCE. For E-FAST modeling, only the chronic COCs are entered for use in PDM runs, which compare
estimated stream concentrations calculated based on an annual stream flow distribution to the chronic
COCs and return the number of days per year the selected COCs are exceeded. The COCs used in the
PDM module of E-FAST 2014 for TCE were 3, 788, and 52,000 ppb.

2,2.3.2 E-FAST 2014 Equations

Surface Water Concentrations

E-FAST 2014 estimates site-specific surface water concentrations for discharges to both free-flowing
water bodies (i.e., rivers and streams) and for still water bodies (i.e., bays, lakes, and estuaries).

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For free-flowing water body assessments, E-FAST 2014 can calculate surface water concentrations for
four streamflow conditions (7Q10, harmonic mean, 30Q5, and 1Q10 flows) using the following equation:

where:

SWC

WWR

WWT

SF

CF1

CF2

WWR xCFl X

SWC =	^	i22-

SFXCF2

Surface water concentration (parts per billion (ppb) or |ig/L)
Chemical release to wastewater (kg/day)

Removal from wastewater treatment (%)

Estimated flow of the receiving stream (MLD)

9

Conversion factor (10 |ig/kg)

6

Conversion factor (10 L/day/MLD)

(Eq. 1)

For still water body assessments, no simple streamflow value represents dilution in these types of water
bodies. As such, E-FAST 2014 accounts for dilution by incorporating an acute or chronic dilution factor
for the water body of interest instead of streamflows. Dilution factors in E-FAST 2014 are typically 1
(representing no dilution) to 200. The following equation is used to calculate surface water
concentrations in still water bodies:

SWC =

where:

SWC

WWR

WWT

PF

DF

CF1

CF2

PFxCF2xDF

(Eq. 2)

Surface water concentration (ppb or |ig/L)

Chemical release to wastewater (kg/day)

Removal from wastewater treatment (%)

Effluent flow of the discharging facility (MLD)

Acute or chronic dilution factor used for the water body (typically between 1 and 200)

9

Conversion factor (10 |ig/kg)

6

Conversion factor (10 L/day/MLD)

Days of COC Exceedance

The Probabilistic Dilution Model (PDM) portion of E-FAST 2014 was also run for free-flowing water
bodies, which predicts the number of days per year a chemical's concentration of concern (COC) in an
ambient water body will be exceeded. The model is based on a simple mass balance approach presented
by (Pi Toro. 1984) that uses probability distributions as inputs to reflect that streams follow a highly
variable seasonal flow pattern and there are numerous variables in a manufacturing process that can
affect the chemical concentration and flow rate of the effluent. PDM does not estimate exceedances for
chemicals discharged to still waters, such as lakes, bays, or estuaries. For these water bodies, the days of
exceedance is assumed be zero unless the predicted surface water concentration exceeds the COC. In
these cases, the days of exceedance is set to the number of release days per year (see required inputs
below).

2.2.3.3 E-FAST 2014 Outputs

E-FAST 2014 provides esitmates of surface water concentration for multiple stream flow parameters. The
concentrations reflect predicted levels of TCE in the receiving water body at the point of release and do not
incorporate downstream transport or post-release chemical fate processes. For this aquatic exposure
assessment, site-specific surface water concentration estimates for free-flowing water bodies are reported for
both the 7Q10 and harmonic mean stream flows. The 7Q10 stream flow is the lowest consecutive 7-day
average flow during any 10-year period. The harmonic mean stream flow is the inverse mean of
reciprocal daily arithmetic mean flow values. Site-specific surface water concentration estimates for still
water bodies are reported for calculations using the acute dilution factors. In cases where site-specific

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flow/dilution data were not reasonably available, the releases were modeled using stream flows of a
representative industry sector, as calculated from all facilities assigned to the industry sector in the E-
FAST database. Estimates from this calculation method are reported for the 10th Percentile harmonic mean
and 10th Percentile 7Q10 stream flows.

2,2.4 Surface Water Monitoring Data Gathering Approach

2.2.4.1	Method for Systematic Review of Surface Water Monitoring Data

EPA conducted a full systematic review of published literature to identify studies reporting
concentrations of TCE in surface water in the United States. Studies clearly associated with releases
from Superfund sites, improper disposal methods, and landfills were considered not to meet the PECO
statement and excluded from data evaluation and extraction. The systematic review process is described
in detail in Section 1.5. A total of 28 surface water studies were extracted and the results are summarized
in Section 2.2.6.2.2. No concentration data from the US were identified prior to 2000.

2.2.4.2	Method for Obtaining Surface Water Monitoring Data from

WQX/WQP

For this aquatic exposure assessment, the primary source for the occurrence of TCE in surface water is
monitoring data retrieved from the Water Quality Portal (WQP), which integrates publicly available US
water quality data from multiple databases: 1) the United States Geological Survey National Water
Information System (USGS NWIS); 2) EPA's STOrage and RETrieval (STORET); and 3) the United
States Department of Agriculture Agricultural Research Service (USDA ARS) Sustaining The Earth's
Watersheds - Agricultural Research Database System (STEWARDS). NWIS is the Nation's principal
repository of water resources data USGS collects from over 1.5 million sites, including sites from the
National Water-Quality Assessment (NAWQA). STORET refers to an electronic data system originally
created by EPA in the 1960's to compile water quality monitoring data. NWIS and STORET now use
common web services, allowing data to be published through the WQP tool. The WQP tool and User
Guide is accessed from the following website: (http://www.waterqiialitYdata.iis/portal.isp).

Data Retrieval from WQP

Surface water data for TCE were downloaded from the WQP on October 3, 2018. The WQP can be
searched through three different search options: Location Parameters, Site Parameters, and Sampling
Parameters. Three queries were performed using the Sampling Parameters search, as shown in Figure
2-2. One query obtained STORET data using the Characteristics parameter (selected "Trichl or ethylene
(STORET)" and two queries obtained NWIS data using the Parameter Codes (34485 for
"Trichloroethene, water, filtered, recoverable, micrograms per liter" and 39180 for "Trichloroethene,
water, unfiltered, recoverable, micrograms per liter"). Parameters codes were obtained from the USGS
website https://nwis.waterdata.iises.eov/usa/nwis/pmcodes using the chemical CASRN. All queries were
performed using a Date Range of 01-01-2013 to 12-31-2017. Both the "Site data only" and "Sample
results (physical/chemical metadata)" were selected for download in "MS Excel 2007+" format. The
"Site data only" file contains monitoring site information (i.e., location in hydrologic cycle, HUC and
geographic coordinates); whereas the "Sample result" file contains the sample collection data and
analytical results for individual samples.

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SAMPLING PARAMETERS

Sample Media;

Characteristic All
Group:

Characteristics:

« Trichtoroethylene

Project ID: All
Parameter Code:

WWISONLYJ

Minimum results
per site:

Date range- 01-01-2013

from:

Biological sampling parameters: ?
Assemblage: All
Taxonomic Name: All

SAMPLING PARAMETERS

Sample Media: All

Characteristic All
Group:

Characteristics: All

Project ID: All

Parameter Code: 34485

4NWIS ONLY)

Minimum results
per site:

Date range - 01-01-2013
from:

Biological sampling parameters: ?
Assemblage; All
Taxonomic Name: All

to: 12-31-2017

SAMPLING PARAMETERS

Sample Media: All

Characteristic All
Group:

Characteristics: All

Project ID: All

Parameter Code: 39

[NW1S ONLY)

Minimum results
per site:

Date range ¦
from:

01-01-2013

Biological sampling parameters: ?
Assemblage: All
Taxonomic Name: All

Figure 2-2. WQP Search Option. Surface water data were obtained from the WQP by querying
the Sampling Parameters search option for the characteristic (STORET data), Parameter Code
(NWIS data), and date range parameter

Data Filtering and Cleansing

The "Site data only" and "Sample results (physical/chemical metadata)" files were linked together using
the common field "Monitoring Location Identifier" and then filtered and cleansed. Specifically,
cleansing focused on obtaining samples were only for the media of interest (i.e., surface water), were not
quality control samples (i.e., field blanks), were of high analytical quality (i.e., no quality control issues,
sample contamination, or estimated values), and were not associated with contaminated sites (i.e.,
Superfund).

Following filtering to obtain the final dataset, the domains "ResultDetectionConditionText,"
"ResultCommentText," and "MeasureQualifierCode" were examined to identify samples with non-
detect concentrations. All non-detect samples were tagged and the concentrations were converted to %
the reported detection limit for summary calculation purposes. If a detection limit was not provided,
calculations were performed using the average of the reported detection limits in all samples (calculated
as 0.3 |ig/L).

2.2.5 Geospatial Analysis Approach

Using 2016 data, the measured surface water concentrations from the WQP and predicted concentrations
from the modeled facility releases were mapped in ArcGIS to conduct a watershed analysis at the
Hydrologic Unit Code (HUC) 8 and HUC 12 level. The purpose of the analysis is to identify if any the
observed surface water concentrations could be associated with the modeled facility releases. In
addition, the analysis included a search for Superfund sites within 1 to 5 miles of the surface water
monitoring stations to possible exclude these monitoring sites from the analysis. A U.S. map was
developed to provide a spatial representation of the measured and predicted concentrations. HUCs with
co-located monitoring stations and facility releases were identified and examined further. Maps were
developed on a U.S. scale to provide a spatial display of the concentrations, as well as at the HUC scale
to focus on co4ocated monitoring stations and facility releases.

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Geographic Coordinates

The location of the monitoring stations was determined from the geographic coordinates (latitude and
longitude) provided in WQP. Releases from facilities were located based on the geographic coordinates
for the NPDES, TRI, and/or FRS of the mapped facility, as provided by FRS. For indirect dischargers,
the location of the receiving facility was mapped if known. If not known, the location of the indirect
discharger was mapped. Superfund sites in 2016 were identified and mapped using geographic
coordinates of the "front door," as reported in the Superfund Enterprise Management System (SEMS)
database in Envirofacts.

Surface Water Concentrations

The surface water concentrations associated with the monitoring stations and facility releases are
denoted on the maps using COCs to determine the concentration thresholds:

>52,000 |i/L (exceeds all COC for algae, aquatic invertebrate, and fish

orange

788-51,999 |i/L (exceeds the COC for algae and aquatic invertebrate, but not for fish)

green

3-787 |i/L (exceeds the COC for algae, but not for aquatic invertebrate or fish)

blue

Detected, but less than 3 |i/L (less than all COC)

purple Not Detected (applies only to measured concentrations; detection limits vary)

For the predicted concentrations, the concentrations represent conditions under low flow conditions (i.e.,
7Q10 flows). The harmonic mean concentrations were not mapped, but are presented in the detailed
summary tables.

Symbols and Layering

Due to the scale of the maps, some symbols may overlap each other if the monitoring stations and
facilities are near each other or there are multiple releases modeled for the same facility (i.e., one facility
is both a direct discharger and a receiving facility). As such, the maps are layered to make sure that the
most important information is always be visible. The following rules were applied:

monitoring stations (small circles) are always on top of indirect discharge releases (medium triangles),
which are always on top of direct discharge releases (large squares), and

within each symbol type (monitoring station, direct release, and indirect release), a higher concentration
level is always on top of a lower concentration level (i.e., from top to bottom: >52,000 |i/L (red), 788-
51,999 |i/L (orange), 3-787 |i/L (green), <3|i/L (blue), and not detected (purple).

2.2,6 Environmental Exposure Results

2,2.6.1 Terrestrial Environmental Exposures

Exposure to terrestrial organisms is expected to be low since physical chemical properties do not support
an exposure pathway through water, biosolids, and soil pathways to these organisms. The partition of
TCE into sediments is very low. Furthermore, the primary fate of TCE released to surface waters or
surface soils is volatilization.

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2.2.6.2 Aquatic Environmental Exposures

To characterize environmental exposure, EPA assessed surface water concentrations derived from both
predicted concentrations of TCE in surface water (using E-FAST modeling results) and measured
concentrations (using monitored data from WQP and the published literature). Generally, the modeled
concentrations reflect near-site estimates at the point of release, and the measured concentrations reflect
localized ambient water concentrations at the monitoring sites. However, there were several sources in
the published literature that represent near facility concentrations and are labeled as such.

2.2.6.2.1 Predicted Surface Water Concentrations: E-FAST 2014 Modeling

A summary of the surface water concentration estimates modeled using E-FAST 2014, based on the
lifecycle release analysis for the year 2016, is summarized by OES category in Table 2-7 through Table
2-9. A break-out of facility-specific modeling results organized per OES, with predicted surface water
concentrations and associated days of COC exceedance, are included in Appendix C. These facility-
specific modeling results are utilized and discussed in environmental risk characterization presented in
Section 4.1.2.

For the higher release frequency scenarios (250-365 days of release/year), predicted surface water
concentrations under 7Q10 flow conditions ranged from 1.27E-5 to 765.63 ppb (Table 2-7). For the 20
days of release/year scenario for direct dischargers, predicted surface water concentrations under 7Q10
flow conditions ranged from 0.00019 to 9,937.5 ppb (Table 2-8). For comparison purposes, indirect
releases to non-POTW WWTPs were also modeled for the 20 days of release/year scenario, resulting in
surface water concentrations of 0.2 to 339.11 ppb (Table 2-9).

Table 2-7. Summary of Surface Water Concentrations by OES for Maximum Days of Release
Scenario

OES

No. of Releases
Modeled

Surface Water Concentration
(7Q10) (ppb)

Min Max

Manufacturing

6

0.00514

2.77

Processing as a Reactant (low-end # of sites)

3

0.0000518

169

Processing as a Reactant

4

0.18

0.92

Repackaging

4

0.0000189

27.18

OTVD

51

0.0000822

765.63

Adhesives, Sealants, Paints, and Coatings

104

0.000818

10.83

Other Industrial Uses

16

0.0000941

9.5

Spot Cleaning and Carpet Cleaning

1

0.00388

0.00388

Industrial Processing Aid

6

0.000419

9.3

Commercial Printing and Copying

1

0.00292

0.00292

Other Commercial Uses

5

0.00564

9

Process Solvent Recycling and Worker Handling of Wastes

4

0.98

11.76

N/A (WWTP)

9

0.0000127

0.7

Grand Total

214

1.27E-5

765.63

Table 2-8. Summary of Surface Water Concentrations by OES for 20 Days of Release Scenario
For Direct Releases

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OES

No. of Releases
Modeled

Surface Water Concentration
(7Q10) (ppb)





Min

Max

Manufacturing

3

0.0897

49.91

Processing as a Reactant (low-end # of sites)

3

0.000907

3000

Processing as a Reactant

2

16.45

16.45

Repackaging

3

0.000235

89.13

OTVD

51

0.00103

9937.5

Adhesives, Sealants, Paints, and Coatings

52

0.0101

133.33

Other Industrial Uses

16

0.00154

200

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1

0.0485

0.0485

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3

0.00335

2.2

Commercial Printing and Copying

1

0.0365

0.0365

Other Commercial Uses

5

0.0658

110

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1

138.24

138.24

N/A (WWTP)

9

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12.79

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150

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9,937.5

Table 2-9. Summary of Surface Water Concentrations by OES for 20 Days of Release Scenario for

Indirect Releases to a non-POTW WWTP







OES

No. of Releases
Modeled

Surface Water Concentration
(7Q10) (ppb)





Min

Max

Manufacturing

3

9.48

42.14

Processing as a Reactant

1

3.13

3.13

Repackaging

1

339.11

339.11

Industrial Processing Aid

3

0.2

138.34

Process Solvent Recycling and Worker Handling of Wastes

3

11.26

106.75

Grand Total

11

0.2

339.11

On a site-specific basis, the predicted surface water concentrations did not exceed the highest COC
(52,000 ppb) for any facility and only exceeded the COC of 788 ppb for two releasing facilities (US
Nasa Michoud Assembly Facility in New Orleans, LA and Praxair Technology Center in Tonawanda,
NY). These release scenarios were 20-day scenarios involving release to a still water body, which
applied no additional dilution. There were 102 modeled releases that exceeded the lowest COC of 3 ppb.
A detailed summary table by facility is provided in Appendix C.

Characterization of Modeled Releases

As discussed in Section 2.2.2, releases of TCE were estimated based on data from TRI, DMRs, and
CDR (primarily TRI and DMR) for the 2016 calendar year. Release estimates were generally facility-
specific and releasing facilities were assigned to one of 13 occupational exposure scenarios (OES).
Overall, modeling was conducted on 157 unique active releasing facilities plus one OES with sites
nationwide (440 unknown sites in OES Processing as a Reactant). As shown in Figure 2-3., the releases
occurred in 39 states. With respect to watersheds, the releases occurred across 122 HUC-8 areas and
144-HUC 12 areas.

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NC
TX
OH

IL, Ml, PA

sc

KS, KY, LA, MN, TN
CA, FL, IN, WV
MA, NE, WA
AL, AR, CO, CT, MD, NJ, N M, Rl, Wl
AZ, DE, ID, ME, MO, MS, NH, OK, OR, VA

0 2	4 6 8 10 12 14 16 18

Number of Unique Facilities Releasing TRICHLOROETHYLENE Per State

Figure 2-3. Distribution of Active Facility Releases Modeled

As shown in Figure 2-4, direct and indirect dischargers accounted for 70% and 30% of the total releases
modeled, respectively. Site-specific waterbody flow/dilution data (identified viaNPDES) were available
in E-FAST 2014 for the majority of the releases (58%); surrogate waterbody flow/dilution data were
used in only 15% of the cases, with the remaining cases (26%) run using a representative industry sector
SIC code. For releases modeled with a NPDES (including a surrogate NPDES), surface water
concentrations were calculated for free-flowing water bodies in 86% of the cases, and still water bodies
for the remaining cases (14%).

Direct Releaser

70%

Indirect Releaser
Industry Sector



Site-Specific NPDES



Surrogate NPDES



Free-Flowing

86% 1

Still Water

14%

Figure 2-4. Modeled Release Characteristics (Percent Occurrence)

2,2.6.2.2 Monitored Surface Water Concentrations

Measured Concentrations ofTCE from WQX/WQP

A summary of the WQX data obtained from the WQP is provided in Table 2-10 below for years 2013-
2017. Per year, the cleansed datasets evaluated contained between 46 and 793 surface water samples
collected from 89 to 193 unique monitoring stations. Detection frequencies were low, ranging from 0 to

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8.7%. Concentrations ranged from not detected (ND; <0.022-5) to 0.11 |ig/L in 2013, ND (<0.022-5) to
1.86 |ig/L in 2014, ND (<0.025-2.4) to 0.011 |ig/L in 2015, all ND (<0.025-5) in 2016, and ND (<0.025-
5) to 2.0 |ig/L in 2017. Peaks were observed in 2014 and 2017; however, caution should be used in
interpreting trends with these data due to the small number of samples and the lack of samples collected
from the same sites over multiple years. The quantitative environmental assessment used the 2016 data
set only. For the 2016 data, concentrations in all samples were non-detect. No samples in the 2013-2017
dataset had concentrations exceeding the lowest COC of 3 |ig/L.

Table 2-10. Measured Concentrations of TCE in Surface Water Obtained from the Water Quality
Portal: 2013-20171

Year

Detection
Frequency

Concentration (|ig/L) in all samples

Concentrations (|ig/L) in only samples above the
detection limit

No. of
Samples
(No. of
Unique
Stations)

Range2

Average
(Standard
Deviation)3

No. of Samples
(No. of Unique
Stations)

Range

Average
(Standard
Deviation^

2013

4.67%

793 (164)

ND (<0.022-<5) to
0.11

0.21 (0.26)

37 (22)

0.008 to 0.11

0.051 (0.016)

2014

3.78%

609 (155)

ND (<0.022-<5) to
1.86

0.33 (0.31)

23 (13)

0.0055 to 1.86

0.17(0.41)

2015

1.42%

352 (91)

ND (<0.025-<2.4)
to 0.011

0.42 (0.16)

5(2)

0.0075 to 0.011

0.009 (0.001)

2016

0.0%

473 (109)

ND (<0.025-<5)

0.44 (0.27)

0(0)

NA

NA

2017

8.70%

46 (25)

ND (<0.025-<5) to
2.0

0.47 (0.53)

4(1)

1.0 to 2.0

1.5 (0.71)

All

Years

3.04%

2273 (384)

ND (<0.022-<5) to
2.0

0.33 (0.29)

69 (39)

0.0055 to 2.0

0.13 (0.35)

1 Data were downloaded from the Water Quality Portal (www.waterqualitvdata.us') on 10/3/2018. STORET surface water data
was obtained by selecting "TCE (STORET)" for the Characteristic. NWIS surface water data were obtained by selecting
"34485; 39180" for the Parameter Codes. Samples were filtered for surface water media and locations only. Results were
reviewed and cleansed (i.e., samples/sites were eliminated if identified as estimated, quality control, media type other than
surface water, Superfund, landfill, failed laboratory quality control, etc.).

2ND = Not Detected. Reported detection limits in all samples ranged from 0.022 to 5 |ig/L.

Calculations were performed using '/? the reported detection limit when results were reported as not detected. If a detection
limit was not provided, calculations were performed using the average of the reported detection limits in all samples (0.65
Hg/L).

Characterization of WOX Data

The original dataset downloaded contained 31,456 samples for years 2013 through 2017. Following the
filtering and cleansing procedure, only 7% of the samples remained (2,273 samples). The majority of the
samples were excluded because they were an off-topic media (i.e., groundwater, artificial, bulk
deposition, leachate, municipal waste, or stormwater) or location type (i.e., landfill, spring, or well). A
smaller number of samples were excluded because they were quality control samples, estimated values,
or had other quality control issues. Samples associated with one Superfund site (Palermo Wellfield
Superfund Site) were also excluded.

For the 2016 cleansed dataset (473 samples), observations were made in 10 states/territories (AZ, KS,
MN, MO, NJ, NM, NC, PA, TN, and TX) at 109 unique monitoring sites, with 1 to 13 samples collected
per sampling site.

Measured Concentrations of TCE from Published Literature

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Systematic review of published literature yielded only a minimal amount of surface water monitoring
data for TCE; a summary of the individual studies is provided in Table 2-11. In six U.S. studies
encompassing 1,177 surface water samples collected from river and oceans throughout the nation
between 1979 and 2001, reported concentrations of TCE ranged from below the detection limit (0.0001
to 0.08) to 17.3 |ig/L, with reported central tendency values ranging from 0.0002 to 1.17 |ig/L. The
maximum concentration was collected from the Charles River in Boston, Massachusetts (an urban area)
between 1998 and 2000 (Robinson et al. 2004). The next highest TCE concentration was 2.0 |ig/L,
collected during a large nationwide survey of surface water for drinking water sources (rivers and
reservoirs) between 1999 and 2000 (USGS. 2003). Robinson et al. (2004) reported the results of
sampling conducted between 1996 and 2000 from 26 urban sites nationwide (n=711 samples), as part of
the National Water-Quality Assessment (NAWQA) Program; the median TCE concentration was only
0.09 |ig/L (detection frequency of 41%). One US study (\ v << \ l ) reported much higher
concentrations of TCE in surface water, up to 447 |ig/L. These samples were collected in 1976/1977
from the vicinity of facilities producing and/or using methylchloroform, thus the concentrations reflect
historical levels of TCE and are not considered to be representative of current conditions. Not enough
information is reasonably available to provide a trend analysis of US surface water concentrations
identified in published literature.

Systematic review also identified data from various other countries and regions, including China, Korea,
United Kingdom, Russia, Portugal, Belgium, Greece, Japan, France, Italy, and Antarctica (see [Data
Extraction Tables for Environmental Monitoring Data. Docket: EPA-HQ-OPPT-2019-0500]).

Table 2-11. Ambient Levels of TCE in U.S. Surface Water from Published Literature









Concentration (jig/L)





Location
Type

Site Information

Dates
Sampled

N

(Det. Freq.)

Range

Central
Tendency
(Standard
Deviation)

Source

Data Quality
Score



Anchorage, AK;
Chester Creek (6 urban
sampling sites)

1998-2001

11(0)

All samples ND
(<0.08)

(USGS,
2006)

Medium



Nation-wide; Surface
water for drinking water
sources (rivers and
reservoirs)

1999-2000

375 (0.008)

ND
(<0.2) -
2.0

NR

(USGS,
2003)

Medium



Nation-wide; Urban
Rivers (26 sites, as part
of the NAWQA
Program)

1996-2000

711 (0.41)

NR

Median:
0.09

(Robinson
et al. 2004)

Medium

Ambient

Boston, MA; Charles
Rivers

1998-2000

29(1)

NR- 17.3

Median:
1.17

(Robinson
et al. 2004)

Medium



Gulf of Mexico, near

mouth of the
Mississippi River and
on the Louisiana Shelf
(11 stations in the open
ocean and coast
representing both
unpolluted and
anthropogenic
influences)

1980

11 (0.27)

ND -

0.05

NR

(Saner.
1981)

Medium

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Concentration (jig/L)





Location
Type

Site Information

Dates
Sampled

N

(Det. Freq.)

Range

Central
Tendency
(Standard
Deviation)

Source

Data Quality
Score



Two Bridges, NJ;
Passaic River

1996-1998

10 (0.4)

NR

Median: 0.1

(Robinson
et al. 2004)

Medium



Eastern Pacific Ocean
(California, US to
Valparaiso, Chile)

1979-1981

30 (0.9)

ND
(0.0001)
- 0.0007

Mean: 0.3
(0.002);
Median:
0.0002

(Singh et
al.. 1983)

Medium



Baton Rouge, LA (Ethyl
Corporation); Stream

samples (surface)
collected upstream and
downstream of the
outfall.

1976

2(1.0)

0.4-37

NR

(U.S. EPA.

1977)

High



Freeport, TX (Dow
Chemical Plant); Stream
samples (bottom and
surface) collected from
the receiving stream at
the plant outfall and

upstream and
downstream of the
outfall.

1976

6(1.0)

0.9-126

NR

(U.S. EPA.

1977)

High

Near
Facility
(methyl-
chloroform
producer
or user)

Geismar, LA (Vulcan

Materials Plant); 3
surface water samples

collected from the
receiving stream at the
plant outfall and

upstream and
downstream of the
outfall.

1976

3 (1.0)

5-74

NR

(U.S. EPA.

1977)

High



Lake Charles, LA (PPG
Industries); Stream
samples (bottom and
surface) collected from
the receiving stream at
the plant outfall and

upstream and
downstream of the
outfall.

1976

5 (1.0)

29 - 447

Mean: 282
(156);
Median:

353

(U.S. EPA.
1977)

High



Auburn, WA (Boeing
Company); Stream
samples (surface)
collected from the
receiving stream at
outfalls and/or upstream
and downstream of the
outfall.

1977

5 (1.0)

5-30

NR

(U.S. EPA.
1977)

High

NR = Not reported

ND = Not detected; detection limit reported in parethesis if reasonably available

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2.2.6.2.3 Geospatial Analysis Comparing Predicted and Measured Surface Water Concentrations

A geospatial analysis at the watershed level (HUC-8 and HUC-12) was conducted to compare the
measured and predicted surface water concentrations in 2016 and investigate if the facility releases may
be associated with the observed concentrations in surface water. Overall, there are 39 US
states/territories with either a measured concentration or a predicted concentration; at the watershed
level, there are 155 HUC-8 areas and 241 HUC-12 areas with either measured or predicted
concentrations.

The monitoring stations co-located with facilities in the same HUC in the 2016 set were assessed for
proximity to Superfund sites to determine if the Superfund sites could be contributing to TCE releases,
and thus would not fall under the scope of this evaluation. No Superfund sites were identified within 5
miles of these sites.

Co-location of releasing facilities and monitoring sampling locations was examined for presence in the
same watershed (HUC-8 and HUC-12). Co-location does not mean there is an upstream/downstream
connection between release and sampling sites.

2.2.6.3 Assumptions and Key Sources of Uncertainty for Environmental
Exposures

E-FAST 2014 estimates surface water concentrations at the point of release, without post-release
accounting for environmental fate or degradation such as volatilization, biodegradation, photolysis,
hydrolysis, or partitioning. Additionally, E-FAST does not estimate stream concentrations based on the
potential for downstream transport and dilution. These considerations tend to lead to higher predicted
surface water concentrations. Dilution is incorporated, but it is based on the stream flow applied.
Therefore, there is uncertainty regarding the level of TCE that would be predicted downstream of a
releasing facility or after accounting for potential volatilization from the water surface, which is
dependent on the degree of mixing in a receiving water body. Despite these uncertainties, E-FAST is
considered an appropriate screening model for near-field environmental concentrations.

Releases modeled using E-FAST 2014 were predicted based on engineering site-specific estimates, as
based on DMR, TRI, and/or CDR databases. These data that form the basis for engineering estimates are
self-reported by facilities subject to minimum reporting thresholds; therefore, they may not capture
releases from certain facilities not meeting reporting thresholds (i.e., environmental releases may be
underestimated).

The days of release applied in modeling have a direct impact on predicting surface water concentrations.
The greater the number of release days assumed, the more the per-day release is diluted (assuming the
same overall annual loading estimate). Both the higher release frequency and lower release frequency
scenarios were based on estimates and were not based on actual facility reporting. Therefore, there is
uncertainty regarding which release scenario is more likely, although the determination was made to
consider only the higher release frequency for scenarios involving water treatment facilities.

Another key parameter in modeling is the applied stream flow distribution, which provides for the
immediate dilution of the release estimate. The flow distributions are applied by selecting a facility-
specific NPDES code in E-FAST. When site-specific or surrogate site-specific stream flow data were
not reasonably available, flow data based on a representative industry sector were used in the
assessment. This includes cases where a receiving facility for an indirect release could not be
determined. In such cases, it is likely that the stream concentration estimates are higher than they would
be if a facility-specific NPDES code was able to be applied, except in certain cases (e.g., NODES

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associated with low-flow or intermittent streams or bays). Additionally, the stream flow data currently
available in E-FAST 2014 are 15 to 30 years old. More recent flow data are available through the
National Hydrological Dataset (NHD) but are not available within the E-FAST model.

With respect to the geospatial comparison of modeled estimates with ambient data obtained from WQX,
one limitation is the accuracy of the latitudes and longitudes. The geographic coordinates for facilities
were obtained from the FRS Interests geodatabase, which are assigned through various methods
including photo-interpretation, address matching, and GPS. These are considered "Best Pick"
coordinates. While EPA does assign accuracy values for each record based on the method used, the true
accuracy of any individual point is unknown. Also, in some cases the receiving facilities for indirect
releases could not be determined. In these cases, the location of the active releaser was mapped. As
such, the co-location of facilities and monitoring sites may have been missed. As the number of
unknown receiving facilities was small and most monitoring sites had samples with concentrations
below the detection limit, this would have minimal impact on the watershed analysis. It is also important
to note that only a few USGS-NWIS and STORET monitoring station locations aligned with the
watersheds of the TCE -releasing facilities identified under the scope of this assessment, and the two co-
located monitoring stations had samples with concentrations below the detection limit; therefore, no
direct correlation can be made between them. While these data reflect low levels of trichl or ethylene in
ambient surface water samples, they cannot be interpreted as reflecting concentrations downstream of
direct release sites, which could be higher than reported measured levels.

The WQP Tool contains data from USGS-NWIS and STORET databases, and is one of the largest
environmental monitoring databases in the US; however, comprehensive information needed for data
interpretation is not always reasonably available. For example, specific details regarding analytical
techniques may be unclear, or not reported at all. As a result, there are uncertainties in the reported data
that are difficult to quantify with regard to impacts on exposure estimates.

The quality of the data provided in the USGS-NWIS and STORET datasets varies, and some of the
information provided is non-quantitative. While many individual sampling results were obtained from
these datasets, the monitoring studies used to collect the data were not specifically designed to evaluate
TCE distribution across the US. The reasonably available data represent a variety of discrete locations
and time periods; therefore, it is unclear whether the data are representative of other locations in the US.
While these data reflect low levels of trichl or ethylene in ambient surface water samples, they directly
reflect sampling done in specific states.

2,2.6.4 Confidence in Aquatic Exposure Scenarios

Confidence ratings for aquatic exposure scenarios are informed by uncertainties surrounding inputs and
approaches used in modeling surface water concentrations. In Section 2.2.2.1, confidence ratings are
assigned to these estimated daily releases (kg/site-day) on a per occupational exposure scenario (OES)
basis and primarily reflect moderate confidence (one OES shows high confidence for this estimate). As
these release estimates serve as the key inputs into the exposure mode and are therefore a key
component of the overall aquatic exposure scenario confidence.

Other considerations that impact confidence in the aquatic exposure scenarios include the model used
(E-FAST 2014) and its associated default and user-selected values and related uncertainties. As
described in Section 2.2.6.3, there are uncertainties related to the ability of E-FAST 2014 to incorporate
downstream fate and transport; the likely number of release days from given discharging facilities; and,
in some cases (i.e., when the NPDES for the discharging facility cannot be found within the E-FAST
database), the applied stream flow distribution. Of note, as stated on the EPA website, "modeled

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estimates of concentrations and doses are designed to reasonably overestimate exposures, for use in an
exposure assessment in the absence of or with reliable monitoring data".

There are monitoring data available in surface water that reflect both near-facility and ambient (i.e.,
background) exposure levels in this media in the United States (see Table 2-10 and Table 2-11).

Samples characterizing background levels in surface water ranged from non-detect (ND) to 17.3 |ig/L,
from both literature and the Water Quality Portal database. However, based on the modeling approach
using site-specific releases and considering that the predicted concentrations reflect near-site
concentrations prior to any additional fate and transport processes, these background exposure levels are
not as useful in corroborating the modeling approach. Near-facility monitoring data collected between
1976 and 1977 show levels of TCE ranging from 0.4 to 447 |ig/L, which encompasses the range of the
modeled estimates across all OES (with the exception of two sites, which are associated with releases
into a still water body) (see [.Aquatic Exposure Modeling Outputs from E-FAST. Docket: EPA-HQ-
OPPT-2019-0500]). However, these data are not attributable to any of the specific sites modeled, nor are
they reflective of ongoing TCE use or release patterns.

Based on the above considerations, the aquatic exposure assessment scenarios have an overall moderate
confidence.

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2.3 Human Exposures

2.3,1 Occupational Exposures

EPA categorized the conditions of use (COUs) listed in Table 1-4 into 18 Occupational Exposure
Scenarios (OES). In this section, EPA describes its approach and methodology to estimating
occupational exposures and provides a summary of results by OES for inhalation and dermal exposure,
and also the number of workers and occupational non-users (ONUs) potentially exposed (Figure 2-5).
ONUs include employees that work at the site where TCE is manufactured, processed, used, recycled, or
disposed of,9 but these employees do not directly handle the chemical and are therefore expected to have
lower inhalation exposures and are not expected to have dermal exposures. For detailed occupational
exposure results, see Appendix P of this document and the (i) "Exposure Assessment" section for each
OES and (ii) "Dermal Exposure Assessment" section in [.Environmental Releases and Occupational
Exposure Assessment. Docket: EPA-HO-OPPT-2019-0500\. An occupational exposure assessment
includes the following components:

•	Inhalation Exposure: Central tendency and high-end estimates of inhalation exposure to
workers and occupational non-users by OES.

•	Dermal Exposure: Occupational exposure scenarios were grouped into bins based on common
characteristics and dermal exposure was estimated for workers for each of these bins

•	Number of Workers and Occupational Non-Users: An estimate of the number of workers and
occupational non-users (ONUs) potentially exposed to the chemical for each OES.

Figure 2-5: Components of an occupational assessment for each OES;10 please refer to Section
2.2.2.2.2 for additional details on the approach and methodology for estimating number of facilities.

9 Occupational exposures from distribution are considered within each condition of use.

111TRI = Toxics Release Inventory; DMR = Discharge Monitoring Report; NEI = National Emissions Inventory; CDR =
Chemical Data Reporting; ELG = Effluent Limitation Guidelines; ESD = Emission Scenario Document; BLS = Bureau of
Labor Statistics; NIOSH = National Institute of Occupational Safey and Health; OSHA = Occupational Safety and Health
Administration; HSIA = Hallogenated Solvent Industry Alliance; NF/FF = Near-Field/Far-Field; DEVL = Dermal Exposure
to Volatile Liquids.

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844

845

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2.3.1.1 Results for Occupational Assessment

In some cases, EPA identified relevant inhalation exposure monitoring data for a given OES. The
quality of this monitoring data was assessed and EPA established an overall confidence for the data
when integrated into the occupational exposure assessment.

Where monitoring data was reasonably available, EPA used this data to characterize central tendency
and high end inhalation exposures. Where no inhalation monitoring data was identified, but inhalation
exposure models were reasonably available, EPA estimated central tendency and high end exposures
using only modeling approaches. If both, inhalation monitoring data and exposure models were
reasonably available, where applicable, EPA presented central tendency and high end exposures using
both. EPA did not identify any measured dermal exposure estimates. In all cases, the Dermal Exposure
to Volatile Liquids (DEVL) model was used to estimate high-end and central tendency dermal exposures
for workers in each OES.

In Table 2-12, EPA provides a summary for each of the 18 occupational exposure scenarios (OESs) by
indicating whether monitoring data was reasonably available, how many data points were identified, the
quality of the data, EPA's overall confidence in the data, whether the data was used to estimate
inhalation exposures for workers and ONUs, and also whether EPA used modeling to estimate
inhalation and dermal exposures for workers and ONUs.

In many cases, EPA did not have monitoring data to estimate inhalation exposure for ONUs. In some
cases, this was addressed with the use of exposure models. However, approximately 50% of OESs do
not contain inhalation exposure estimates for ONUs. In addition, EPA expects ONU exposures to be less
than worker exposures. Dermal exposure for ONUs was not evaluated because these employees are not
expected to be in direct contact with TCE.

A summary of inhalation exposure results based on monitoring data and exposure modeling for each
OES is presented for workers in Table 2-13 and ONUs in Table 2-14. These tables provide a summary
of time weighted average (TWA) inhalation exposure estimates as well as Acute Exposure
Concentrations (AC), Average Daily Concentrations (ADC), and Lifetime Average Daily
Concentrations (LADC). The ADC is used to characterize risks for chronic non-cancer health effects
whereas the LADC is used for chronic cancer health effects. Additional details regarding AC, ADC,
and LADC calculations are available in section 2.3.1.2.4, while EPA's approach and methodology for
modeling inhalation exposure using the Near-Field/Far-Field mass balance model can be found in
2.3.1.2.3.

Table 2-15 includes a summary of central tendency and high-end dermal exposure results based on
exposure modeling for workers in each OES. Occluded dermal exposures may occur when liquid
becomes trapped between the skin and protective clothing (e.g., gloves). This may result in the liquid
being unable to evaporate from the skin surface which may increase the quantity of liquid absorbed.
Where applicable, both non-occluded and occluded exposure scenarios are assessed and the impact of
various glove protection factors (PFs) are also estimated. EPA estimated the dermal retained dose for
workers for each OES. These dose estimates assume one exposure event (applied dose) per work day
and that approximately eight to thirteen percent11 of the applied dose is absorbed through the skin.
Central tendency and high-end dermal estimates also factor in ranged values for two variables, the
surface area of contact, and the quantity remaining on the skin. Additional information on these
variables can be found in section 2.3.1.2.5.

11 The absorbed fraction is a function of indoor air speed, which differs for industrial and commercial settings.

Page 101 of 748


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EPA also estimated central tendency and high-end dermal retained doses for occluded scenarios for
OESs where occlusion was reasonably expected to occur. Occluded scenarios are generally expected
where workers come into contact with bulk liquid TCE during use in open systems (e.g., during solvent
changeout in vapor degreasing) and not expected in closed-type systems (e.g., during connection/
disconnection of hoses used in loading of bulk containers in manufacturing).

Dermal exposure estimates are provided for each OES, where the OESs are "binned" based on the
maximum possible exposure concentration (Yderm), the likely level of exposure, and potential for
occlusion. The exposure concentration is determined based on EPA's review of currently available
products and formulations containing TCE. For example, EPA found that TCE concentration in
degreasing formulations such as C-60 Solvent Degreaser can be as high as 100 percent. The calculated
absorbed dose is low for all non-occluded scenarios since TCE evaporates quickly after exposure.
Dermal exposure to liquid is not expected for occupational non-users, since they do not directly handle
TCE. Additional details on EPA's approach and methodology for estimating dermal exposures for
workers can be found in section 2.3.1.2.5.

Table 2-16 provides a summary of EPA's estimates for the total exposed workers and ONUs for each
OES. In order to prepare these estimates, EPA first attempted to identify North American Industrial
Classification (NAICS) codes associated with each OES. For these NAICS codes, EPA then reviewed
Standard Occupational Classification (SOC) codes from the Bureau of Labor Statistics (BLS) and
classified relevant SOC codes as workers or ONUs. All other SOC codes were assumed to represent
occupations where exposure is unlikely.

Based on this combination of NAICS and SOC codes, EPA estimated the total number of workers and
ONUs potentially exposed for the various OES. EPA also estimated the total number facilities
associated with the NAICS codes previously identified based on data from the U.S. Census Bureau.

EPA then estimated the average number of workers and ONUs potentially exposed per site by dividing
the total number of workers and ONUs by the total number of facilities. Finally, using EPA's estimates
for the number of facilities using TCE, EPA was able to estimate the total number of workers and ONUs
potentially exposed to TCE for reach OES.

Additional details on EPA's approach and methodology for estimating the number of facilities using
TCE and the number of workers and ONUs potentially exposed to TCE can be found in sections
2.2.2.2.2 and 2.3.1.2.7, respectively.

Page 102 of 748


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905

906

907

908

Table 2-12: A summary for each of the 18 occupational exposure scenarios (OESs).

Note: where EPA was not able to estimate ONU inhalation exposure from monitoring data or models, this was assumed equivalent to the
central tendency experienced by workers for the corresponding OES; dermal exposure for ONUs was not evaluated because they are not







Inhalation Exposure







Dermal Exposure
Modeling0

Occupational Exposure .
Scenario TOES) 1



Monitoring





Modeling

Ovei
Confit

'all 1

ence J



Monitoring
Data

# Data
Points

Data Quality
Rating

Worker

ONU

Worker

ONU

Worker

ONU j

Worker

ONU

Manufacturing j



16

H



3C

3c

3C

M to H

L j



-

Processing as a Reactant |

S

16

M



3C

3c

3C

L to M

L |

S

-

Formulation of Aerosol and Non- '
Aerosol Products ¦

S

33

H



3C

3c

3C

M

L |

S

-

Repackaging |

S

33

H



3C

3C

3C

M to H

L |

S

-

Batch Open-Top Vapor Degreasing J

S

123

M









M

M j

S

-

Batch Closed-Loop Vapor |
Degreasing I

S

19

H



3C

3C

3C

M to H

L j

S

-

Conveyorized Vapor Degreasing '

S

18

M



3C





L to M

Lto M j

S

-

Web Vapor Degreasing |

3c

-

-

3C

3C





L to M

Lto M|

S

-

Cold Cleaning j

3C

-

-

3C

3C





L to M

Lto Mj

S

-

Aerosol Applications3 |

3C

-

-

3C

3C





M

M |

S

-

Metalworking Fluids '

s

3

H



3C



3C

L to M

L J

S

-

Adhesives, Sealants, Paints, and |
Coatings 1

s

24

M to H; Mb





3C

3C

L to M

Lto m!

S

-

Other Industrial Uses j

s

16

M



3C

3C

3C

L to M

L j

S

-

Spot Cleaning and Wipe Cleaning |

s

8

M



3C





M

M |

S

-

Industrial Processing Aid j

s

34

H





3C

3C

M to H

Lto Mj

S

-

Commercial Printing and Copying |

s

20

M



3C

3C

3C

L to M

L 1

S

-

Other Commercial Uses j

s

8

M



3C





M

M |

S

-

Process Solvent Recycling and I
Worker Handling of Wastes 1

s

33

H



3C

3C

3C

M to H

L |

S

-

909

910

911

a.	Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts Cleaners, Penetrating Lubricants, and

b.	For Workers, data quality is M to H; For ONUs, data quality is is M.

c.	EPA lias a medium level of confidence in its dermal exposure estimates which are based on high-end/central tendency

Mold Releases

parameters and commercial/industrial settings.

Page 103 of 748


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Occupational Exposure

i

1
1

Inhalation Monitoring (Worker, ppm) j

Inhalation Modeling (Worker, ppm)



Scenario (OES)

| TWA

AC

ADC

LADC i

TWA

AC

ADC

LADC



1 HE

CT

HE

CT

HE

CT

HE

CT 1

HE

CT

HE

CT

HE

CT

HE

CT

Manufacturing

j 2.6

0.38

0.86

0.13

0.59

8.6E-02

0.30

3.4E-02' -

-

-

-

-

-

-

-

Processing as a Reactant

| 2.6

0.38

0.86

0.13

0.59

8.6E-02

0.30

3.4E-02| -

-

-

-

-

-

-

-

Formulation of Aerosol and Non-
Aerosol Products

11.14
1

4.9E-04

0.38

1.6E-04

0.26

1.1E-04

0.13

4.5E-05I -
1

-

-

-

-

-

-

-

Repackaging

j 1.14

4.9E-04

0.38

1.6E-04

0.26

1.1E-04

0.13

4.5E-05'

-

-

-

-

-

-

-

-

Batch Open-Top Vapor Degreasing

177.8

13.8

25.9

4.6

17.8

3.2

9.1

1.3 |

388.0

34.8

129.3

11.6

88.5

8.0

35.3

3.0

Batch Closed-Loop Vapor Degreasing

11.45

0.46

0.48

0.15

0.33

0.10

0.17

4.2E-02I

-

-

-

-

-

-

-

-

Conveyorized Vapor Degreasing

! 48.3

32.4

16.1

10.8

11.0

7.4

5.7

2.9 !

3043.0

40.8

1014.3

13.6

694.8

9.3

275.2

5.3

Web Vapor Degreasing ( -

-

-

-

-

-

-

- j 14.1

5.9

4.7

2.0

3.2

1.4

1.3

0.51

Cold Cleaning | -

-

-

-

-

-

-

- | 57.2

3.3

19.1

1.1

13.1

0.76

5.2

0.28

Aerosol Applications3



-

-

-

-

-

-

1

24.0

7.6

8.0

2.5

5.5

1.7

2.2

0.65

Metalworking Fluids

175.4

69.7

25.1

23.2

17.2

15.9

OO
00

6.3 !

0.26

0.07

0.09

0.02

0.06

0.02

0.03

0.01

Adhesives, Sealants, Paints, and
Coatings

139.5
1

4.6

13.2

1.5

9.0

1.1

4.6

0.42 | -
1

-

-

-

-

-

-

-

Other Industrial Uses

1 2.6

0.38

0.86

0.13

0.59

0.09

0.30

3.4E-02I -

-

-

-

-

-

-

-

Spot Cleaning and Wipe Cleaning

j 2.9

0.38

0.95

0.13

0.67

0.09

0.34

3.6E-02!

2.8

0.96

0.92

0.32

0.65

0.23

0.26

0.08

Industrial Processing Aidb

112.8

4.3

6.4

2.13

4.39

1.5

2.2

0.58 j -

-

-

-

-

-

-

-

Commercial Printing and Copying

1 2.1

8.5E-02

0.70

0.03

0.48

0.02

0.25

7.7E-03I -

-

-

-

-

-

-

-

Other Commercial Uses

j 2.9
¦

0.38

0.95

0.13

0.67

0.09

0.34

3.6E-02J

2.8

0.96

0.92

0.32

0.65

0.23

0.26

8.4E-
02

Process Solvent Recycling and Worker
Handling of Wastes

i11

4.9E-04

0.38

1.6E-04

0.26

1.1E-04

0.13

4.5E-05j -

-

-

-

-

-

-

-

a.	Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts Cleaners, Penetrating Lubricants, and Mold Releases

b.	Exposure for this OES is based on a 12 lir TWA; all other exposures based on 8 lir TWAs

Page 104 of 748


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Table 2-14: Summary of inhalation exposure results for ONUs based on monitoring data and exposure modeling for each OES.

[Note: for many cases EPA was not able to estimate inhalation exposure for ONUs, but EPA expects these to be lower than inhalation
exposure for Workers. 1	

Occupational Exposure

1
1
1

Inhalation Monitoring (ONU, ppm) 1



Inhalation Modeling (ONU, ppm)



Scenario (OES)

! TWA

AC

ADC

LADC !

TWA

AC

A]

DC

LADC



HE

CT

HE

CT

HE

CT

HE

CT !

HE

CT

HE

CT

HE

CT

HE

CT

Manufacturing 1 -

-

-

-

-

-

-

1

-

-

-

-

-

-

-

¦

Processing as a Reactant ¦ -

-

-

-

-

-

-

1

-

-

-

-

-

-

-

Formulation of Aerosol and Non- J -
Aerosol Products i

-

-

-

-

-

-

1
1

1

-

-

-

-

-

-

-

Repackaging

| -

-

-

-

-

-

-

1

-

-

-

-

-

-

-

-

Batch Open-Top Vapor Degreasing

19.1

1.1

3.0

0.37

2.1

0.25

1.06

0.10 1

237.0

18.1

79.0

6.0

54.0

4.1

21.1

1.5

Batch Closed-Loop Vapor Degreasing [ -

-

-

-

-

-

-

¦

-

-

-

-

-

-

-

Conveyorized Vapor Degreasing ¦ -

1

-

-

-

-

-

-

- j 1878.

1 o

23.3

626.0

7.8

428.8

5.3

168.
3

3.6

Web Vapor Degreasing I -

-

-

-

-

-

-

- I 9.6

3.1

3.2

1.0

2.2

0.71

0.87

0.27

Cold Cleaning [ -

-

-

-

-

-

-

- 1 34.7

1.8

11.6

0.61

7.9

0.42

3.1

0.15

Aerosol Applicationsa ! -

-

-

-

-

-

-

- ! 1.0

0.14

0.35

4.7E-02

0.24

3.2E-02

0.09

1.2E-02

Metalworking Fluids

¦

-

-

-

-

-

-

1

-

-

-

-

-

-

-

Adhesives, Sealants, Paints, and
Coatings

| 1.0
1

0.94

0.33

0.31

0.23

0.21

0.12

8.5E-02| -

-

-

-

-

-

-

-

Other Industrial Uses ! -

-

-

-

-

-

-



-

-

-

-

-

-

-

Spot Cleaning and Wipe Cleaning

1
¦

-

-

-

-

-

-

J

1.8

0.48

0.58

0.16

0.41

0.11

0.16

4.2E-02

Industrial Processing Aidb

2.9

1.3

1.5

0.66

0.99

0.45

0.51

0.18 j -

-

-

-

-

-

-

-

Commercial Printing and Copying | -

-

-

-

-

-

-

1

-

-

-

-

-

-

-

Other Commercial Uses 1 -

-

-

-

-

-

-

- 1 1.8

0.48

0.58

0.16

0.41

0.11

0.16

4.2E-02

Process Solvent Recycling and Worker
Handling of Wastes

1
¦

-

-

-

-

-

-

1
¦

-

-

-

-

-

-

-

a.	Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts Cleaners, Penetrating Lubricants, and Mold Releases

b.	Exposure for this OES is based on a 12 lir TWA; all other exposures based on 8 lir TWAs

Page 105 of 748


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940

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Table 2-15: A summary of dermal retained dose for Workers based on exposure modeling for each OES

[Note: an explanation of each Bin is provided in Table 2-21; where applicable, both non-occluded and occluded exposure scenarios are
assessed and the impact of various glove protection factors (PFs) are also estimated; estimates assume one exposure event per work day and



¦
1
1

I

¦

1

1
¦

Max TCE

¦ ¦

| Non-Occluded Worker Dermal Retained Dose |

j (mg/day) \

Occluded Worker
Dermal Retained

Occupational Exposure j

Bin 1
1

Weight

j No

Protective

Protective

Protective ¦

Dnsp



Scenario (OES)

1

Fraction

j Gloves

Gloves

Gloves

Gloves j

(mg/day)



1

1

(Max Yderm)

1 (PF

= D

(PF

= 5)

(PF =

10)

(PF

= 20) |



1
"

1
«

! HE

CT

HE

CT

HE

CT

HE

CT !

HE 1
«

CT

Manufacturing

1

1 |

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 I - I -

Processing as a Reactant 1

1 1

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 1 - 1 -

Formulation of Aerosol and Non- '

1 ¦

1.0

' 184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 '



-

Aerosol Products

l
¦

I



¦













¦

I



Repackaging

I
1

i ;

1.0

j 184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 j

i

-

Batch Open-Top Vapor Degreasing |

2 I

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 |

2,247 |

749

Batch Closed-Loop Vapor Degreasing {

2 1

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 1

2,247 1

749

Conveyorized Vapor Degreasing !

2 !

1.0

j 184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 j

2,247 j

749

Web Vapor Degreasing |

2 !

1.0

j 184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 j

2,247 j

749

Cold Cleaning

1

2 I

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 |

2,247 |

749

Aerosol Applications3

1

3 1

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

-

1

1

-

Metalworking Fluids

1

4 !

0.8

j 147.49

49.16

29.50

9.83

14.75

4.92

-



1,798 !

599

Adhesives, Sealants,

Industrial ¦

3 !

0.9

165.92

55.31

33.18

11.06

16.59

5.53

-

I I

Paints, and Coatings

Commercial |

3 1

0.9

1260.50

86.83

52.10

17.37

26.05

8.68

-



Other Industrial Uses

1

1 |

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 |

|

-

Spot Cleaning and Wipe Cleaning '

4 1

1.0

1289.44

96.48

57.89

19.30

28.94

9.65

-

1

2,247 1

749

Industrial Processing Aid !

i !

1.0

j 184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 '

1
¦

-

Commercial Printing and Copying ¦

4 !

0.35

j 101.30

33.77

20.26

6.75

10.13

3.38

-

1

786 j

262

Other Commercial Uses |

4 I

1.0

|289.44

96.48

57.89

19.30

28.94

9.65

-



2,247 |

749

Process Solvent Recycling and Worker 1

1 1

1.0

1184.36

61.45

36.87

12.29

18.44

6.15

9.22

3.07 1

1

-

Handling of Wastes

1

1



1













1

1



a. Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts Cleaners, Penetrating Lubricants, and Mold Releases

Page 106 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

945

946

947

Table 2-16: Summary of the total number of workers and ONUs potentially exposed to TCE for each OES

[Note: EPA's approach and methodology for estimating the number of facilities using TCE and the number of workers and ONUs potentially

Occupational Exposure j
Scenario (OES) 1

Total
Exposed
Workers

Total
Exposed
ONUs

Total
Exposed

Number of
Facilitiesb

Notes

Manufacturing 1

350

170

530

5



Processing as a Reactant J

120 to 6,100

55 to 2,900

180 to 9,000

5 to 440



Formulation of Aerosol and Non- ¦

306

99

405

19



Aerosol Products 1











Repackaging I

36

12

48

22



Batch Open-Top Vapor Degreasing 1

4,922

2,889

7,810

194



Batch Closed-Loop Vapor Degreasing '

50

18

68

4



Conveyorized Vapor Degreasing ¦

92

32

130

8



Web Vapor Degreasing |

-

-

-

1

EPA does not have data to estimate the total
workers and ONUs exposed to TCE.

Cold Cleaning 1

660

400

1,100

13



Aerosol Applications3 !

14,200

1,690

15,900

4,366



Metalworking Fluids ¦









Based on ESD on the Use of Metalworking
Fluids, EPA estimates 46 Workers and 2 ONUs
per site; the number of sites that use TCE-based
metalworking fluids is unknown to EPA.

Adhesives, Sealants, Paints, and J

3,000

1,400

4,400

70



Coatings ¦











Other Industrial Uses |

2,300

1,000

3,300

49



Spot Cleaning and Wipe Cleaning 1

244,000

25,300

269,000

63,748

Based on assumption of 100% market
penetration.

Industrial Processing Aid J

310

140

450

18



Commercial Printing and Copying ¦









Based on NIOSH HHE, EPA estimates 44
Workers and 74 ONUs per site; EPA does not
have data to estimate total number of sites

Other Commercial Uses 1

-

-

-

-

EPA does not have data to estimate the total
workers and ONUs exposed to TCE

Process Solvent Recycling and ¦

380

140

520

30



Worker Handling of Wastes i











948

949

a.	Aerosol Applications: Spray Degreasing/Cleaning, Automotive Brake and Parts

b.	Please refer to Table 2-3 for notes related to estimates for Number of Facilities

Cleaners, Penetrating Lubricants, and Mold Releases
using TCE.

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2,3,1.2 Approach and Methodology
2.3.1^2.1^ General

EPA provided occupational exposure results representative of central tendency conditions and high-end
conditions. A central tendency is assumed to be representative of occupational exposures in the center of
the distribution for a given condition of use. For risk evaluation, EPA used the 50th percentile (median),
mean (arithmetic or geometric), mode, or midpoint values of a distribution as representative of the
central tendency scenario. EPA's preference is to provide the 50th percentile of the distribution.
However, if the full distribution is not known, EPA may assume that the mean, mode, or midpoint of the
distribution represents the central tendency depending on the statistics available for the distribution.

A high-end is assumed to be representative of occupational exposures that occur at probabilities above
the 90th percentile but below the exposure of the individual with the highest exposure (	2).

For risk evaluation, EPA provided high-end results at the 95th percentile. If the 95th percentile is not
reasonably available, EPA used a different percentile greater than or equal to the 90th percentile but less
than or equal to the 99.9th percentile, depending on the statistics available for the distribution. If the full
distribution is not known and the preferred statistics are not reasonably available, EPA estimated a
maximum or bounding estimate in lieu of the high-end.

For occupational exposures, EPA used measured or estimated air concentrations to calculate exposure
concentration metrics required for risk assessment, such as average daily concentration (ADC) and
lifetime average daily concentration (LADC). These calculations require additional parameter inputs,
such as years of exposure, exposure duration and frequency, and lifetime years. EPA estimated exposure
concentrations from monitoring data, modeling, or occupational exposure limits.

For the final exposure result metrics, each of the input parameters (e.g., air concentrations, working
years, exposure frequency, lifetime years) may be a point estimate (i.e., a single descriptor or statistic,
such as central tendency or high-end) or a full distribution. EPA considered three general approaches for
estimating the final exposure result metrics:

•	Deterministic calculations: EPA used combinations of point estimates of each parameter to
estimate a central tendency and high-end for each final exposure metric result.

•	Probabilistic (stochastic) calculations: EPA used Monte Carlo simulations using the full
distribution of each parameter to calculate a full distribution of the final exposure metric results
and selecting the 50th and 95th percentiles of this resulting distribution as the central tendency
and high-end, respectively.

•	Combination of deterministic and probabilistic calculations: EPA had full distributions for
some parameters but point estimates of the remaining parameters. For example, EPA used Monte
Carlo modeling to estimate exposure concentrations, but only had point estimates of exposure
duration and frequency, and lifetime years.

EPA follows the following hierarchy in selecting data and approaches for assessing inhalation
exposures:

1. Monitoring data:

a.	Personal and directly applicable

b.	Area and directly applicable

c.	Personal and potentially applicable or similar

d.	Area and potentially applicable or similar

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2.	Modeling approaches:

a.	Surrogate monitoring data

b.	Fundamental modeling approaches

c.	Statistical regression modeling approaches

3.	Occupational exposure limits:

a.	Company-specific OELs (for site-specific exposure assessments, e.g., there is only one
manufacturer who provides to EPA their internal OEL but does not provide monitoring data)

b.	OSHA PEL

c.	Voluntary limits (ACGIH TLV, NIOSH REL, Occupational Alliance for Risk Science
(OARS) workplace environmental exposure level (WEEL) [formerly by AIHA])

EPA assessed TCE occupational exposure of the following two receptor categories: male or female
workers who are >16 years or older; and, female workers of reproductive age (>16 years to less than 50
years).

2.3.1.2.2	Inhalation Exposure Monitoring Data

EPA reviewed workplace inhalation monitoring data collected by government agencies such as OSHA
and NIOSH, monitoring data found in published literature (i.e., personal exposure monitoring data and
area monitoring data), and monitoring data submitted via public comments. Studies were evaluated
using the evaluation strategies laid out in the Application of Systematic Review in TSCA Risk
Evaluations (U.S. EPA. 2018b).

Exposures are calculated from the datasets provided in the sources depending on the size of the dataset.
For datasets with six or more data points, central tendency and high-end exposures were estimated using
the 50th percentile and 95th percentile. For datasets with three to five data points, central tendency
exposure was calculated using the 50th percentile and the maximum was presented as the high-end
exposure estimate. For datasets with two data points, the midpoint was presented as a midpoint value
and the higher of the two values was presented as a higher value. Finally, data sets with only one data
point presented the value as a what-if exposure. For datasets including exposure data that were reported
as below the limit of detection (LOD), EPA estimated the exposure concentrations for these data,
following EPA's Guidelines for Statistical Analysis of Occupational Exposure Data (	94a)

which recommends using the LOD/V2 if the geometric standard deviation of the data is less than 3.0 and
LOD/2 if the geometric standard deviation is 3.0 or greater.

2.3.1.2.3	Inhalation Exposure Modeling

EPA's inhalation exposure modeling is based on a near-field/far-field approach (NF/FF) (Micas. 2009).
where a vapor generation source located inside the near-field diffuses into the surrounding environment.
The NF/FF model has been extensively peer-reviewed, it is extensively used, and results of the model
have been compared with measured data. The comparison indicated that the model and measured values
agreed to within a factor of about three (	).

EPA considers workers at the facility who neither directly perform activities near the TCE source area
nor regularly handle TCE to be occupational non-users (ONU). Workers that are directly handling TCE
and/or perform activities near sources of TCE are in the near field and are called workers throughout this
report. The near-field is reported to be conceptualized as a volume of air within one-meter in any
direction of the worker" s head and the far-field comprised the remainder of the room (Tielemans et ai.
2008). The source area/exposure zone could be judged by several factors such as the chemical inventory,
ventilation of the facility, vapor pressure and emission potential of the chemical, process temperature,
size of the room, job tasks, and modes of chemical dispersal from activities (Leblanc et ai. 2018).

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Esmen et al. (1979) indicated that the assignment of zones is a professional judgment and not a scientific
exercise. Applications of the NF/FF model are illustrated in Figure 2-6.

Open-Top Vapor Degreasing and Cold Cleaning

	 Far-Field 	

- Near-Field -

I®"

Ts) c,

R

W>

Conveyorized Degreasing

Q„,	~

Spot Cleaning

¦ Far-Field ¦

Brake Servicing



\



cff



i" /-



VcNk



* Volatile Source \<^ Qff

1

^m /*Qh'



MM



Web Degreasing

	Far-Field	





Figure 2-6: Illustrative applications of the NF/FF model to various exposure scenarios.

As the figures show, volatile TCE becomes airborne in the near-field, resulting in worker exposures at a
TCE concentration Cne- The concentration is directly proportional to the evaporation rate of TCE,
(denoted by G in Figure 2-6), into the near-field, whose volume is denoted by Vnp. In the case of brake
servicing, there is no evaporation rate. Rather, the aerosol degreaser is assumed to immediately become
airborne in the near-field zone upon application, resulting in a sudden rise in the near-field
concentration.

The ventilation rate for the near-field zone (Q\i) determines how quickly TCE dissipates into the far-

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field, resulting in occupational non-user exposures to TCE at a concentration Cff. Vff denotes the
volume of the far-field space into which the TCE dissipates out of the near-field. The ventilation rate for
the surroundings, denoted by Qff, determines how quickly TCE dissipates out of the surrounding space
and into the outside air. The NF/FF model design equations are presented below.

Near-Field Mass Balance

Vnf ^ = CffQnf ~ CNFQNF + G

Far-Field Mass Balance

dCFF

Vff ^ = CnfQnf ~ CFFQNF — CFFQFF

Where:

Vnf =

near-field volume;

Vff =

far-field volume;

Qnf =

near-field ventilation rate;

Qff =

far-field ventilation rate;

Cnf =

average near-field concentration;

Cff =

average far-field concentration;

G

average vapor generation rate; and

t

elapsed time.

For details on the modeling approach and model equations, please refer to Appendix K; Appendix L;
and Appendix M.

2.3.1.2.4 Acute and Chronic Inhalation Exposure Estimates

This report assesses TCE exposures to workers in occupational settings, presented as time weighted
average (TWA). The TWA exposures are then used to calculate acute exposure (AC), average daily
concentration (ADC) for chronic, non-cancer risks, and lifetime average daily concentration (LADC) for
chronic, cancer risks.

Acute workplace exposures are assumed to be equal to the contaminant concentration in air (TWA):

AC =

C x ED

AT,

acute

Where:

AC
C

ED

AT acute

= acute exposure concentration
= contaminant concentration in air (TWA)
= exposure duration (hr/day)

= acute averaging time (24 hrs)

ADC and LADC are used to estimate workplace exposures for non-cancer and cancer risks, respectively.
These exposures are estimated as follows:

CxEDxEFxWY

ADC or LADC =	

AT or ATC

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day hr
AT = WYx 365 —x 24—
yr day

day hr
ATC = LTx 365—x 24 —
yr day

Where:

ADC = Average daily concentration used for chronic non-cancer risk calculations

LADC = Lifetime average daily concentration used for chronic cancer risk calculations

ED = Exposure duration (hr/day)

EF = Exposure frequency (day/yr)

WY = Working years per lifetime (yr)

AT = Averaging time (hr) for chronic, non-cancer risk

ATc = Averaging time (hr) for cancer risk

AWD = Annual working days (day/yr)

f = Fractional working days with exposure (unitless)

LT = Lifetime years (yr) for cancer risk

The parameter values in Table 2-17 are used to calculate each of the above acute or chronic exposure
estimates. Where exposure is calculated using probabilistic modeling, the AC, ADC, and LADC
calculations are integrated into the Monte Carlo simulation. Where multiple values are provided for ED
and EF, it indicates that EPA may have used different values for different conditions of use. The
rationale for these differences are described below in this section (also see Appendix J for example
calculations).

Table 2-17: Parameter Values for Calculating Inhalation Exposure Estimates

Parameter Name

Sy m hoi

Value

1 nil

Exposure Duration

ED

8 or 24

hr/day

Exposure Frequency

EF

250

days/yr

Working years

WY

31 (50th percentile)
40 (95th percentile)

years

Lifetime Years, cancer

LT

78

years

Averaging Time, non-
cancer

AT

271,560 (central tendency)51
350,400 (high-end)b

hr

Averaging Time, cancer

ATC

683,280

hr

a Calculated using the 50th percentile value for working years (WY)
b Calculated using the 95th percentile value for working years (WY)

Exposure Duration (ED)

EPA generally uses an exposure duration of 8 hours per day for averaging full-shift exposures with an
exception of spot-cleaning. Operating hours for spot cleaning were assessed as 2 to 5 hours/day.

Exposure Frequency (EF)

EPA generally uses an exposure frequency of 250 days per year with the following exception: spot

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cleaning. EPA assumed spot cleaners may operate between five and six days per week and 50 to 52
weeks per year resulting in a range of 250 to 312 annual working days per year (AWD). Taking into
account fractional days exposed (f) resulted in an exposure frequency (EF) of 249 at the 50th percentile
and 313 at the 95th percentile.

EF is expressed as the number of days per year a worker is exposed to the chemical being assessed. In
some cases, it may be reasonable to assume a worker is exposed to the chemical on each working day. In
other cases, it may be more appropriate to estimate a worker's exposure to the chemical occurs during a
subset of the worker's annual working days. The relationship between exposure frequency and annual
working days can be described mathematically as follows:

EF = fx AWD

Where:

EF = exposure frequency, the number of days per year a worker is exposed to the chemical
(day/yr)

f = fractional number of annual working days during which a worker is exposed to the
chemical (unitless)

AWD = annual working days, the number of days per year a worker works (day/yr)

BLS (2016) provides data on the total number of hours worked and total number of employees by each
industry NAICS code. These data are available from the 3- to 6-digit NAICS level (where 3-digit
NAICS are less granular and 6-digit NAICS are the most granular). Dividing the total, annual hours
worked by the number of employees yields the average number of hours worked per employee per year
for each NAICS.

EPA has identified approximately 140 NAICS codes applicable to the multiple conditions of use for the
ten chemicals undergoing risk evaluation. For each NAICS code of interest, EPA looked up the average
hours worked per employee per year at the most granular NAICS level available (i.e., 4-digit, 5-digit, or
6-digit). EPA converted the working hours per employee to working days per year per employee
assuming employees work an average of eight hours per day. The average number of days per year
worked, or AWD, ranges from 169 to 282 days per year, with a 50th percentile value of 250 days per
year. EPA repeated this analysis for all NAICS codes at the 4-digit level. The average AWD for all 4-
digit NAICS codes ranges from 111 to 282 days per year, with a 50th percentile value of 228 days per
year. 250 days per year is approximately the 75th percentile. In the absence of industry- and TCE-
specific data, EPA assumes the parameter/is equal to one for all conditions of use.

Working Years (WY)

EPA has developed a triangular distribution for working years. EPA has defined the parameters of the
triangular distribution as follows:

•	Minimum value: BLS CPS tenure data with current employer as a low-end estimate of the
number of lifetime working years: 10.4 years;

•	Mode value: The 50th percentile tenure data with all employers from SIPP as a mode value for
the number of lifetime working years: 31 years; and

•	Maximum value: The maximum average tenure data with all employers from SIPP as a high-end
estimate on the number of lifetime working years: 40 years.

This triangular distribution has a 50th percentile value of 31 years and a 95th percentile value of 40 years.

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EPA uses these values for central tendency and high-end ADC and LADC calculations, respectively.

The BLS (	i. 2014) provides information on employee tenure with current employer obtained

from the Current Population Survey (CPS). CPS is a monthly sample survey of about 60,000 households
that provides information on the labor force status of the civilian non-institutional population age 16 and
over; CPS data are released every two years. The data are available by demographics and by generic
industry sectors but are not available by NAICS codes.

The U.S. Census' (	nsus Bureau. 2019) Survey of Income and Program Participation (S1PP)

provides information on lifetime tenure with all employers. SIPP is a household survey that collects data
on income, labor force participation, social program participation and eligibility, and general
demographic characteristics through a continuous series of national panel surveys of between 14,000
and 52,000 households (U.S. Census Bureau. 2019). EPA analyzed the 2008 SIPP Panel Wave 1, a panel
that began in 2008 and covers the interview months of September 2008 through December 2008 Qj.S.
Census Bureau. ). For this panel, lifetime tenure data are available by Census Industry Codes,
which can be cross-walked with NAICS codes.

SIPP data include fields for the industry in which each surveyed, employed individual works
(TJBIND1), worker age (TAGE), and years of work experience with all employers over the surveyed
individual's lifetime.12 Census household surveys use different industry codes than the NAICS codes
used in its firm surveys, so these were converted to NAICS using a published crosswalk (U.S. Census
Bure*	). EPA calculated the average tenure for the following age groups: 1) workers age 50 and

older; 2) workers age 60 and older; and 3) workers of all ages employed at time of survey. EPA used
tenure data for age group "50 and older" to determine the high-end lifetime working years, because the
sample size in this age group is often substantially higher than the sample size for age group "60 and
older". For some industries, the number of workers surveyed, or the sample size, was too small to
provide a reliable representation of the worker tenure in that industry. Therefore, EPA excluded data
where the sample size is less than five from our analysis.

Table 2-18 summarizes the average tenure for workers age 50 and older from SIPP data. Although the
tenure may differ for any given industry sector, there is no significant variability between the 50th and
95th percentile values of average tenure across manufacturing and non-manufacturing sectors.

Table 2-18: Overview of Average Worker Tenure from U.S. Census SIPP (Age Group 50+)

Industry Sectors

Average

\Yorkii
50,h Percentile

lg Years
95"' Percentile

Maxim ii in

All industry sectors relevant to the 10
chemicals undergoing risk evaluation

35.9

36

39

44

Manufacturing sectors (NAICS 31-33)

35.7

36

39

40

Non-manufacturing sectors (NAICS 42-81)

36.1

36

39

44

Source: (U.S. Census Bureau. 20.1.9')

Note: Industries where sample size is less than five are excluded from this analysis.

12 To calculate the number of years of work experience EPA took the difference between the year first worked
(TMAKMNYR) and the current data year (i.e., 2008). EPA then subtracted any intervening months when not working
(ETIMEOFF).

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BLS CPS data provides the median years of tenure that wage and salary workers had been with their
current employer. Table 2-19 presents CPS data for all demographics (men and women) by age group
from 2008 to 2012. To estimate the low-end value on number of working years, EPA uses the most
recent (2014) CPS data for workers age 55 to 64 years, which indicates a median tenure of 10.4 years
with their current employer. The use of this low-end value represents a scenario where workers are only
exposed to the chemical of interest for a portion of their lifetime working years, as they may change jobs
or move from one industry to another throughout their career.

Table 2-19: Median Year of Tenure wii

th Current Employer by Age Group.

Age

January 2008

January 2010

January 2012

January 2014

16 years and over

4.1

4.4

4.6

4.6

16 to 17 years

0.7

0.7

0.7

0.7

18 to 19 years

0.8

1.0

0.8

0.8

20 to 24 years

1.3

1.5

1.3

1.3

25 years and over

5.1

5.2

5.4

5.5

25 to 34 years

2.7

3.1

3.2

3.0

35 to 44 years

4.9

5.1

5.3

5.2

45 to 54 years

7.6

7.8

7.8

7.9

55 to 64 years

9.9

10.0

10.3

10.4

65 years and over

10.2

9.9

10.3

10.3

Source: (U.S. BLS. 2014).

Lifetime Years (LT)

EPA assumes a lifetime of 78 years for all worker demographics.

2.3.1.2.5 Dermal Exposure Modeling

Dermal exposure data was not reasonably available for the OESs in the assessment. Because TCE is a
volatile liquid that readily evaporates from the skin, EPA estimated dermal exposures using the Dermal
Exposure to Volatile Liquids (DEVL) Model. See Appendix H of the [.Environmental Releases and
Occupational Exposure Assessment. Docket: EPA-HO-OPPT-2019-0500)\ for the development and
underlying research of this model. This model determines a dermal potential dose rate based on an
assumed amount of liquid on skin during one contact event per day and the steady-state fractional
absorption for TCE based on a theoretical framework provided by Kasting (Kasting and Miller. 2006).
The amount of liquid on the skin is adjusted by the weight fraction of TCE in the liquid to which the
worker is exposed.

The DEVL is used to assess occupational dermal exposure scenarios because the exposure duration is
typically not known across a wide variety of worker activities, and the model's event-based approach
allows exposure estimation using the number of exposure events, rather than exposure duration. Further,
the model can account for the impact of glove use in occupational settings.

EPA estimated workers' dermal exposure to TCE for the industrial and commercial occupational
exposure scenarios (OESs) considering evaporation of liquid from the surface of the hands and use with
and without gloves. The OSHA recommends employers utilize the hierarchy of controls for reducing or

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removing hazardous exposures. The most effective controls are elimination, substitution, or engineering
controls. Gloves are the last course of worker protection in the hierarchy of controls and should only be
considered when process design and engineering controls cannot reduce workplace exposure to an
acceptable level.

Vapor absorption during dermal exposure requires that TCE be capable of achieving a sufficient
concentration in the media at the temperature and atmospheric pressure of the scenario under
evaluation to provide a significant driving force for skin penetration. Because TCE is a volatile liquid (VP
= 73.46 mmHg and 25°C), the dermal absorption of TCE depends on the type and duration of exposure.
Where exposure is not occluded, only a fraction of TCE that comes into contact with the skin will be
absorbed as the chemical readily evaporates from the skin. Dermal exposure may be significant in cases of
occluded exposure, repeated contacts, or dermal immersion. For example, work activities with a high degree
of splash potential may result in TCE liquids trapped inside the gloves, inhibiting the evaporation of TCE
and increasing the exposure duration. EPA collected and reviewed available SDSs (Safety Data Sheets)
to inform the evaluation of gloves used with TCE in liquid and aerosol form at varying concentrations.

Trichloroethylene in liquid form at 99-100% concentration is expected to be used in both industrial and
commercial settings. For industrial scenarios using this form of TCE, the following OESs are expected;
Manufacture of TCE, Processing as a Reactant, Industrial Processing Aid, Formulation of Aerosol and
Non Aerosol Products, Repackaging, Process Solvent Recycling, Batch Open Top Vapor Degreasing,
Batch Closed-Loop Vapor Degreasing, Conveyorized Vapor Degreasing, and Web Vapor Degreasing.

For trichl or ethylene in liquid form at 99-100% concentration an SDS from Mallinckrodt Baker Inc.
recommended neoprene gloves and an SDS from Solvents Australia PTY. LTD. recommended the use
of gloves made from rubber, PVC, or nitrile (	).

Commercial OESs where TCE in liquid form at 99-100% concentration is expected includes Spot
Cleaning, Wipe Cleaning, and Carpet Cleaning. An SDS for an R.R. Street & Co. cleaning agent
recommended wearing Viton ® [Butyl-rubber], PVA, or Barrier ™ gloves. Two gun wipe cleaning
agent manufacturers A.V.W. Inc. and G.B. Distributors recommend Viton or Neoprene gloves and
polyethylene, neoprene, or PVA gloves, respectively (	).

For Aerosol Degreasing and Aerosol Lubricants applications, TCE is used in a range of concentrations
in aerosol form. An SDS for a 90-100% TCE aerosol degreasing agent from Brownells, Inc.
recommended using PVA gloves and an SDS for a 45-55% TCE aerosol brake parts cleaner from Zep
Manufacturing Co. recommended using Viton® gloves (	).

Metalworking Fluids and Adhesives, Sealants, Paints, and Coatings typically contain a maximum TCE
concentration of 80-90%. An SDS from LPS Laboratories presented a tap and die fluid at 80-90% TCE
concentration and recommended using Viton® [Butyl-rubber], Silver Shield®[PE and EVOH laminate]
and PVA gloves. An SDS for a 15-90% TCE adhesive from Rema Tip Top recommended using
Neoprene, Butyl-rubber, or nitrile rubber (	).

EPA did not find any SDSs with applicable use towards commercial printing and copying applications.

To assess exposure, EPA used the Dermal Exposure to Volatile Liquids Model to calculate the dermal
retained dose for both non-occluded and occluded scenarios. The equation modifies the EPA 2-Hand
Dermal Exposure to Liquids Model by incorporating a "fraction absorbed (fabs)" parameter to account
for the evaporation of volatile chemicals and a "protection factor (PF)" to account for glove use. Default

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PF values, which vary depending on the type of glove used and the presence of employee training
program, are shown in Table 2-20:

( Qu Xfabs)

n 	 C v	uusj y	j-,j,

uexp	pp	^ 1derm ^ 1 1

Where:

•	S is the surface area of contact: 535 cm2 (central tendency) and 1,070 cm2 (high end),
representing the total surface area of one and two hands, respectively.

•	Qu is the quantity remaining on the skin: 1.4 mg/cm2-event (central tendency) and 2.1 mg/cm2-
event (high-end). This is the high-end default value used in the EPA dermal models ((

2013a").

•	Yderm is the weight fraction of the chemical of interest in the liquid (0 < Yderm < 1)

•	FT is the frequency of events (1 event per day)

•	fabs is the fraction of applied mass that is absorbed (Default for TCE: 0.08 for industrial facilities
and 0.13 for commercial facilities)

•	PF is the glove protection factor (Table 2-20)

The steady state fractional absorption (fabs) for TCE is estimated to be 0.08 in industrial facilities with
higher indoor wind flows or 0.13 in commercial facilities with lower indoor wind speeds based on a
theoretical framework provided by Kasting and Miller (2006) (Kasting and Miller. 2006). meaning
approximately 8 or 13 percent of the applied dose is absorbed through the skin following exposure, from
industrial and commercial settings, respectively. However, there is a large standard deviation in the
experimental measurement, which is indicative of the difficulty in spreading a small, rapidly evaporating
dose of TCE evenly over the skin surface.

Table 2-20: Glove Protection Factors for Different Dermal Protection Strategies.

Dermal Protect ion Characteristics

Setting

Protection
l-'actor. PI-"

a. No gloves used, or any glove / gauntlet without permeation data
and without employee training

Industrial and

Commercial

Uses

1

b. Gloves with available permeation data indicating that the
material of construction offers good protection for the substance

5

c. Chemically resistant gloves (i.e., as b above) with "basic"
employee training

10

d. Chemically resistant gloves in combination with specific
activity training (e.g., procedure for glove removal and disposal)
for tasks where dermal exposure can be expected to occur

Industrial
Uses Only

20

Source: (Marquart et at.. 20.1.7')

To streamline the dermal exposure assessment, EPA grouped the various OESs based on characteristics
known to effect dermal exposure such as the maximum weight fraction of TCE could be present in that
scenario, open or closed system use of TCE, and large or small-scale use. Four different groups or
"bins" were created based on this analysis (Table 2-21).

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1335 Table 2-21: EPA grouped dermal exposures associated with the various OESs into four bins.

Bin #

Description

1

Bin 1 covers industrial uses that generally occur in closed systems. For these uses, dermal exposure is
likely limited to chemical loading/unloading activities (e.g., connecting hoses) and taking quality control
samples. EPA assesses the following glove use scenarios for Bin 1 conditions of use:

No gloves used: Operators in these industrial uses, while working around closed-system equipment, may
not wear gloves or may wear gloves for abrasion protection or gripping that are not chemical resistant.

Gloves used with a protection factor of 5, 10, and 20: Operators may wear chemical-resistant gloves
when taking quality control samples or when connecting and disconnecting hoses during
loading/unloading activities. EPA assumes gloves may offer a range of protection, depending on the
type of glove and employee training provided.

Scenarios not assessed: EPA does not assess occlusion as workers in these industries are not likely to
come into contact with bulk liquid TCE that could lead to chemical permeation under the cuff of the
glove or excessive liquid contact time leading to chemical permeation through the glove.

2

Bin 2 covers industrial degreasing uses, which are not closed systems. For these uses, there is greater
opportunity for dermal exposure during activities such as charging and draining degreasing equipment,
drumming waste solvent, and removing waste sludge. EPA assesses the following glove use scenarios
for Bin 2 conditions of use:

No gloves used: Due to the variety of shop types in these uses the actual use of gloves is uncertain. EPA
assumes workers may not wear gloves or may wear gloves for abrasion protection or gripping that are
not chemical resistant during routine operations such as adding and removing parts from degreasing
equipment.

Gloves used with a protection factor of 5, 10, and 20: Workers may wear chemical-resistant gloves when
charging and draining degreasing equipment, drumming waste solvent, and removing waste sludge. EPA
assumes gloves may offer a range of protection, depending on the type of glove and employee training
provided.

Occluded Exposure: Occlusion may occur when workers are handling bulk liquid TCE when charging
and draining degreasing equipment, drumming waste solvent, and removing waste sludge that could lead
to chemical permeation under the cuff of the glove or excessive liquid contact time leading to chemical
permeation through the glove.

3

Bin 3 covers aerosol uses, where workers are likely to have direct dermal contact with film applied to
substrate and incidental deposition of aerosol to skin. EPA assesses the following glove use scenarios for
Bin 3 conditions of use:

No gloves used: Actual use of gloves in this use is uncertain. EPA assumes workers may not wear
gloves or may wear gloves for abrasion protection or gripping that are not chemical resistant during
routine aerosol applications.

Gloves used with a protection factor of 5 and 10: Workers may wear chemical-resistant gloves when
applying aerosol products. EPA assumes the commercial facilities in Bin 3 do not offer activity-specific
training on donning and doffing gloves.

Scenarios not assessed: EPA does not assess glove use with protection factors of 20 as EPA assumes
chemical-resistant gloves used in these industries would either not be accompanied by training or be
accompanied by basic employee training, but not activity-specific training. EPA does not assess
occlusion for aerosol applications because TCE formulations are often supplied in an aerosol spray can
and contact with bulk liquid is unlikely. EPA also does not assess occlusion for non-aerosol niche uses
because the potential for occlusion is unknown

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Bin 4 covers commercial activities of similar maximum concentration. Most of these uses are uses as
spot cleaners or in wipe cleaning, and/or uses expected to have direct dermal contact with bulk liquids.
EPA assesses the following glove use scenarios for Bin 4 conditions of use:

No gloves used: Actual use of gloves in this use is uncertain. EPA assumes workers may not wear
gloves during routine operations (e.g., spot cleaning).

Gloves used with a protection factor of 5 and 10: Workers may wear chemical-resistant gloves when
charging and draining solvent to/from machines, removing and disposing sludge, and maintaining
equipment. EPA assumes the commercial facilities in Bin 4 do not offer activity-specific training on
donning and doffing gloves.

Occluded Exposure: Occlusion may occur when workers are handling bulk liquid TCE when charging
and draining solvent to/from machines, removing and disposing sludge, and maintaining equipment that
could lead to chemical permeation under the cuff of the glove or excessive liquid contact time leading to
chemical permeation through the glove.

Scenarios not assessed: EPA does not assess glove use with protection factors of 20 as EPA assumes
chemical-resistant gloves used in these industries would either not be accompanied by training or be
accompanied by basic employee training, but not activity-specific training.

2.3.1.2.6 Consideration of Engineering Controls and Personal Protective Equipment

OSHA and NIOSH recommend that employers utilize the hierarchy of controls to address hazardous
exposures in the workplace. The hierarchy of controls strategy outlines, in descending order of priority,
the use of elimination, substitution, engineering controls, administrative controls, and lastly personal
protective equipment (PPE). The hierarchy of controls prioritizes the most effective measures first which
is to eliminate or substitute the harmful chemical (e.g., use a different process, substitute with a less
hazardous material), thereby preventing or reducing exposure potential. Following elimination and
substitution, the hierarchy recommends engineering controls to isolate employees from the hazard,
followed by administrative controls, or changes in work practices to reduce exposure potential (e.g.,
source enclosure, local exhaust ventilation systems). Administrative controls are policies and procedures
instituted and overseen by the employer to protect worker exposures. As the last means of control, the
use of personal protective equipment (e.g., respirators, gloves) is recommended, when the other control
measures cannot reduce workplace exposure to an acceptable level. The National Institute for
Occupational Safety and Health (NIOSH) and the U.S. Department of Labor's Bureau of Labor
Statistics (BLS) conducted a voluntary survey of U.S. employers regarding the use of respiratory
protective devices between August 2001 and January 2002 (NIOSH. 2001). For additional information,
please also refer to [Memorandum NIOSH BLS Respirator Usage in Private Sector Firms. Docket #
EPA-HQ-OPPT-2019-0500].

Respiratory Protection

OSHA's Respiratory Protection Standard (29 CFR § 1910.134) requires employers in certain industries
to address workplace hazards by implementing engineering control measures and, if these are not
feasible, provide respirators that are applicable and suitable for the purpose intended.13 Respirator
selection provisions are provided in § 1910.134(d) and require that appropriate respirators are selected
based on the respiratory hazard(s) to which the worker will be exposed and workplace and user factors
that affect respirator performance and reliability. Assigned protection factors (APFs) are provided in
Table 1 under § 1910.134(d)(3)(i)(A) (see Table 2-22) and refer to the level of respiratory protection

13 OSHA does not require controls to be used unless a hazard assessment determines that the hazard is significant enough to
require mitigation.

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that a respirator or class of respirators is expected to provide to employees when the employer
implements a continuing, effective respiratory protection program.

The United States has several regulatory and non-regulatory exposure limits for TCE: an OSHA PEL of
100 ppm 8-hour TWA (OSHA.. 2019). a NIOSH Recommended Exposure Limit (REL) of 2 ppm (as a
60-minute ceiling for TCE usage as an anesthetic) and 25 ppm (as a 10-hour TWA for other exposures)
(NIOSH. 2019) and an American Conference of Government Industrial Hygienists (ACGIH) 8-hour
TLV of 10 ppm and a short-term limit of 25 ppm ( 3R. 2019). If respirators are necessary in
atmospheres that are not immediately dangerous to life or health, workers must use NIOSH-certified air-
purifying respirators or NIOSH-approved supplied-air respirators with the appropriate APF. Respirators
that meet these criteria include air-purifying respirators with organic vapor cartridges. Table 2-22 can be
used as a guide to show the protectiveness of each category of respirator. Based on the APF, inhalation
exposures may be reduced by a factor of 5 to 10,000, when workers and occupational non-users are
using respiratory protection.

The respirators should be used when effective engineering controls are not feasible as per OSHA's 29
CFR § 1910.132. The knowledge of the range of respirator APFs is intended to assist employers in
selecting the appropriate type of respirator that could provide a level of protection needed for a specific
exposure scenario. Table 2-22 lists the range of APFs for respirators. The complexity and burden of
wearing respirators increases with increasing APF. The APFs are not to be assumed to be
interchangeable for any conditions of use, any workplace, or any worker or ONU.

Table 2-22: Assigned Protection Factors for I

tespirators in OSHA Standard 29 CFR § 1910

Type of Uespiralor

Quarter

Mask

Half

Mask

I-Mil

Facepiece

1 lelmel/
Mood

Loose-
filling
l-'acepiece

1. Air-Purifying Respirator

5

10

50





2. Power Air-Purifying Respirator
(PAPR)



50

1,000

25/1,000

25

3. Supplied-Air Respirator (SAR) or Airline Respirator

Demand mode



10

50





Continuous flow mode



50

1,000

25/1,000

25

Pressure-demand or other positive-
pressure mode



50

1,000





4. Self-Contained Breathing Apparatus (SCBA)

Demand mode



10

50

50



Pressure-demand or other positive-
pressure mode (e.g., open/closed
circuit)





10,000

10,000



Source: 29 CFR § 1910.134(d)(3)(i)(A)

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2.3.1.2.7 Number of Workers and Occupational Non-Users Exposed

This section summarizes the methods that EPA used to estimate the number of workers who are
potentially exposed to TCE in each of its conditions of use. The method consists of the following steps:

1.	Identify the North American Industry Classification System (NAICS) codes for the industry
sectors associated with each condition of use.

2.	Estimate total employment by industry/occupation combination using the Bureau of Labor
Statistics' Occupational Employment Statistics data (U.S. BLS. 2016).

3.	Refine the estimates based on BLS Occupational Employment Statistics data where they are not
sufficiently granular by using the U.S. Census' (U.S. Census Bureau. 2015) Statistics of U.S.
Businesses (SUSB) data on total employment by 6-digit NAICS.

4.	Estimate the percentage of employees likely to be using TCE instead of other chemicals (i.e., the
market penetration of TCE in the condition of use).

5.	Estimate the number of sites and number of potentially exposed employees per site.

6.	Estimate the number of potentially exposed employees within the condition of use.

Step 1: Identifying Affected NAICS Codes

As a first step, EPA identified NAICS industry codes associated with each condition of use. EPA
generally identified NAICS industry codes for a condition of use by:

•	Querying the U.S. Census Bureau's NAICS Search tool using keywords associated with each
condition of use to identify NAICS codes with descriptions that match the condition of use.

•	Referencing EPA Generic Scenarios (GS's) and Organisation for Economic Co-operation and
Development (OECD) Emission Scenario Documents (ESDs) for a condition of use to identify
NAICS codes cited by the GS or ESD.

•	Reviewing Chemical Data Reporting (CDR) data for the chemical, identifying the industrial
sector codes reported for downstream industrial uses, and matching those industrial sector codes
to NAICS codes using Table D-2 provided in the CDR reporting instructions.

Each condition of use section in the main body of this report identifies the NAICS codes EPA identified
for the respective condition of use.

Step 2: Estimating Total Employment by Industry and Occupation

BLS's (U.S. BLS. 2016) Occupational Employement Statistics data provide employment data for
workers in specific industries and occupations. The industries are classified by NAICS codes (identified
previously), and occupations are classified by Standard Occupational Classification (SOC) codes.

Among the relevant NAICS codes (identified previously), EPA reviewed the occupation description and
identified those occupations (SOC codes) where workers are potentially exposed to TCE. Table 2-23
shows the SOC codes EPA classified as occupations potentially exposed to TCE. These occupations are
classified into workers (W) and occupational non-users (O). All other SOC codes are assumed to
represent occupations where exposure is unlikely.

Table 2-23: SOCs with Worker and ONU Designations for All Conditions of Use Except

SOC

Occupation

Designation

11-9020

Construction Managers

O

17-2000

Engineers

O

17-3000

Drafters, Engineering Technicians, and Mapping Technicians

0

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19-2031

Chemists

O

19-4000

Life, Physical, and Social Science Technicians

O

47-1000

Supervisors of Construction and Extraction Workers

O

47-2000

Construction Trades Workers

W

49-1000

Supervisors of Installation, Maintenance, and Repair Workers

0

49-2000

Electrical and Electronic Equipment Mechanics, Installers, and
Repairers

w

49-3000

Vehicle and Mobile Equipment Mechanics, Installers, and Repairers

w

49-9010

Control and Valve Installers and Repairers

w

49-9020

Heating, Air Conditioning, and Refrigeration Mechanics and Installers

w

49-9040

Industrial Machinery Installation, Repair, and Maintenance Workers

w

49-9060

Precision Instrument and Equipment Repairers

w

49-9070

Maintenance and Repair Workers, General

w

49-9090

Miscellaneous Installation, Maintenance, and Repair Workers

w

51-1000

Supervisors of Production Workers

0

51-2000

Assemblers and Fabricators

w

51-4020

Forming Machine Setters, Operators, and Tenders, Metal and Plastic

w

51-6010

Laundry and Dry-Cleaning Workers

w

51-6020

Pressers, Textile, Garment, and Related Materials

w

51-6030

Sewing Machine Operators

0

51-6040

Shoe and Leather Workers

0

51-6050

Tailors, Dressmakers, and Sewers

0

51-6090

Miscellaneous Textile, Apparel, and Furnishings Workers

0

51-8020

Stationary Engineers and Boiler Operators

w

51-8090

Miscellaneous Plant and System Operators

w

51-9000

Other Production Occupations

w

W = worker designation
O = ONU designation

For dry cleaning facilities, due to the unique nature of work expected at these facilities and that different
workers may be expected to share among activities with higher exposure potential (e.g., unloading the
dry cleaning machine, pressing/finishing a dry cleaned load), EPA made different SOC code worker and
ONU assignments for this condition of use. Table 2-24 summarizes the SOC codes with worker and
ONU designations used for dry cleaning facilities.

Table 2-24: SOCs with Worker and ONU Designations for Dry Cleaning Facilities

SOC

Occii pillion

IH'siuiiiilinn

41-2000

Retail Sales Workers

O

49-9040

Industrial Machinery Installation, Repair, and Maintenance Workers

w

49-9070

Maintenance and Repair Workers, General

w

49-9090

Miscellaneous Installation, Maintenance, and Repair Workers

w

51-6010

Laundry and Dry-Cleaning Workers

w

51-6020

Pressers, Textile, Garment, and Related Materials

w

51-6030

Sewing Machine Operators

0

51-6040

Shoe and Leather Workers

0

51-6050

Tailors, Dressmakers, and Sewers

0

51-6090

Miscellaneous Textile, Apparel, and Furnishings Workers

0

W = worker designation
O = ONU designation

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After identifying relevant NAICS and SOC codes, EPA used BLS data to determine total employment
by industry and by occupation based on the NAICS and SOC combinations. For example, there are
110,640 employees associated with 4-digit NAICS 8123 (Drycleaning and Laundry Services) and SOC
51-6010 (Laundry and Dry-Cleaning Workers).

Using a combination of NAICS and SOC codes to estimate total employment provides more accurate
estimates for the number of workers than using NAICS codes alone. Using only NAICS codes to
estimate number of workers typically result in an overestimate, because not all workers employed in that
industry sector will be exposed. However, in some cases, BLS only provide employment data at the 4-
digit or 5-digit NAICS level; therefore, further refinement of this approach may be needed (see next
step).

Step 3: Refining Employment Estimates to Account for lack of NAICS Granularity

The third step in EPA's methodology was to further refine the employment estimates by using total
employment data in the U.S. Census Bureau's (U.S. Census Bureau. 2015) SUSB. In some cases, BLS
OES's occupation-specific data are only available at the 4-digit or 5-digit NAICS level, whereas the
SUSB data are available at the 6-digit level (but are not occupation-specific). Identifying specific 6-digit
NAICS will ensure that only industries with potential TCE exposure are included. As an example, OES
data are available for the 4-digit NAIC S 8123 Drycleaning and Laundry Services, which includes the
following 6-digit NAICS:

•	NAICS 812310 Coin-Operated Laundries and Drycleaners;

•	NAICS 812320 Drycleaning and Laundry Services (except Coin-Operated);

•	NAICS 812331 Linen Supply; and

•	NAICS 812332 Industrial Launderers.

In this example, only NAICS 812320 is of interest. The Census data allow EPA to calculate employment
in the specific 6-digit NAICS of interest as a percentage of employment in the BLS 4-digit NAICS.

The 6-digit NAICS 812320 comprises 46 percent of total employment under the 4-digit NAICS 8123.
This percentage can be multiplied by the occupation-specific employment estimates given in the BLS
Occupational Employment Statistics data to further refine our estimates of the number of employees
with potential exposure.

Table 2-25 illustrates this granularity adjustment for NAICS 812320.

Table 2-25: Estimated Number of Potentia

ly Exposed Workers and O

NTJs under NAICS 812320.

NAICS

SOC
CODE

SOC Description

Occupation
Designation

Employment
by SOC at 4-
digit NAICS
level

% of Total
Employment

Estimated
Employment
by SOC at 6-
digit NAICS
level

8123

41-2000

Retail Sales Workers

O

44,500

46.0%

20,459

8123

49-9040

Industrial Machinery
Installation Repair, and
Maintenance Workers

w

1,790

46.0%

823

8123

49-9070

Maintenance and Repair
Workers, General

w

3,260

46.0%

1,499

8123

49-9090

Miscellaneous Installation,
Maintenance, and Repair
Workers

w

1,080

46.0%

497

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8123

51-6010

Laundry and Dry-Cleaning
Workers

W

110,640

46.0%

50,867

8123

51-6020

Pressers, Textile, Garment,
and Related Materials

W

40,250

46.0%

18,505

8123

51-6030

Sewing Machine Operators

O

1,660

46.0%

763

8123

51-6040

Shoe and Leather Workers

O

Not Reported for this NAICS Code

8123

51-6050

Tailors, Dressmakers, and
Sewers

0

2,890

46.0%

1,329

8123

51-6090

Miscellaneous Textile,
Apparel, and Furnishings
Workers

0

0

46.0%

0

Total Potentially Exposed Employees

206,070



94,740

Total Workers





72,190

Total Occupational Non-Users





22,551

Note: numbers may not sum exactly due to rounding.

W = worker

O = occupational non-user

Source: (U.S. Census Bureau. 20.1.5'): (U.S. BLS. 20.1.6')

Step 4: Estimating the Percentage of Workers Using TCE Instead of Other Chemicals

In the final step, EPA accounted for the market share by applying a factor to the number of workers
determined in Step 3. This accounts for the fact that TCE may be only one of multiple chemicals used
for the applications of interest. EPA did not identify market penetration data any conditions of use. In
the absence of market penetration data for a given condition of use, EPA assumed TCE may be used at
up to all sites and by up to all workers calculated in this method as a bounding estimate. This assumes a
market penetration of 100%. Market penetration is discussed for each condition of use in the main body
of this report.

Step 5: Estimating the Number of Workers per Site

EPA calculated the number of workers and occupational non-users in each industry/occupation
combination using the formula below (granularity adjustment is only applicable where SOC data are not
available at the 6-digit NAICS level):

Number of Workers or ONUs in NAICS/SOC (Step 2) x Granularity Adjustment Percentage (Step 3) =
Number of Workers or ONUs in the Industry/Occupation Combination

EPA then estimated the total number of establishments by obtaining the number of establishments
reported in the U.S. Census Bureau's SUSB (1; S Census Bureau. I ) data at the 6-digit NAICS
level.

EPA then summed the number of workers and occupational non-users over all occupations within a
NAICS code and divided these sums by the number of establishments in the NAICS code to calculate
the average number of workers and occupational non-users per site.

Step 6: Estimating the Number of Workers and Sites for a Condition of Use

EPA estimated the number of workers and occupational non-users potentially exposed to TCE and the
number of sites that use TCE in a given condition of use through the following steps:

1. Obtaining the total number of establishments by:

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a.	Obtaining the number of establishments from SUSB 0 ; S Census Bureau. 2015) at the 6-
digit NAICS level (Step 5) for each NAICS code in the condition of use and summing these
values; or

b.	Obtaining the number of establishments from the Toxics Release Inventory (TRI), Discharge
Monitoring Report (DMR) data, National Emissions Inventory (NEI), or literature for the
condition of use.

2.	Estimating the number of establishments that use TCE by taking the total number of
establishments from Item 1 and multiplying it by the market penetration factor from Step 4.

3.	Estimating the number of workers and occupational non-users potentially exposed to TCE by
taking the number of establishments calculated in Item 2 and multiplying it by the average
number of workers and occupational non-users per site from Step 5.

2.3.1.3 Assumptions and Key Sources of Uncertainty for Occupational
Exposures

2.3.1.3.1	Number of Workers

There are a number of uncertainties surrounding the estimated number of workers potentially exposed to
TCE, as outlined below. Most are unlikely to result in a systematic underestimate or overestimate, but
could result in an inaccurate estimate.

CDR data are used to estimate the number of workers associated with manufacturing. There are inherent
limitations to the use of CDR data as they are reported by manufacturers and importers of TCE.
Manufacturers and importers are only required to report if they manufactured or imported TCE in excess
of 25,000 pounds at a single site during any calendar year; as such, CDR may not capture all sites and
workers associated with any given chemical.

There are also uncertainties with BLS data, which are used to estimate the number of workers for the
remaining conditions of use. First, BLS' OES employment data for each industry/occupation
combination are only available at the 3-, 4-, or 5-digit NAICS level, rather than the full 6-digit NAICS
level. This lack of granularity could result in an overestimate of the number of exposed workers if some
6-digit NAICS are included in the less granular BLS estimates but are not, in reality, likely to use TCE
for the assessed applications. EPA addressed this issue by refining the OES estimates using total
employment data from the U.S. Census' SUSB. However, this approach assumes that the distribution of
occupation types (SOC codes) in each 6-digit NAICS is equal to the distribution of occupation types at
the parent 5-digit NAICS level. If the distribution of workers in occupations with TCE exposure differs
from the overall distribution of workers in each NAICS, then this approach will result in inaccuracy.

Second, EPA's judgments about which industries (represented by NAICS codes) and occupations
(represented by SOC codes) are associated with the uses assessed in this report are based on EPA's
understanding of how TCE is used in each industry. Designations of which industries and occupations
have potential exposures is nevertheless subjective, and some industries/occupations with few exposures
might erroneously be included, or some industries/occupations with exposures might erroneously be
excluded. This would result in inaccuracy but would be unlikely to systematically either overestimate or
underestimate the count of exposed workers.

2.3.1.3.2	Analysis of Exposure Monitoring Data

This report uses existing worker exposure monitoring data to assess exposure to TCE during several
conditions of use. To analyze the exposure data, EPA categorized each PBZ data point as either
"worker" or "occupational non-user". The categorizations are based on descriptions of worker job
activity as provided in literature and EPA's judgment. In general, samples for employees that are

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expected to have the highest exposure from direct handling of TCE are categorized as "worker" and
samples for employees that are expected to have the lower exposure and do not directly handle TCE are
categorized as "occupational non-user".

Exposures for occupational non-users can vary substantially. Most data sources do not sufficiently
describe the proximity of these employees to the TCE exposure source. As such, exposure levels for the
"occupational non-user" category will have high variability depending on the specific work activity
performed. It is possible that some employees categorized as "occupational non-user" have exposures
similar to those in the "worker" category depending on their specific work activity pattern.

Some data sources may be inherently biased. For example, bias may be present if exposure monitoring
was conducted to address concerns regarding adverse human health effects reported following exposures
during use. Similarly, OSHA CEHD are obtained from OSHA inspections, which may be the result of
worker complaints, and may provide exposure results that may generally exceed the industry average.

Some scenarios have limited exposure monitoring data in literature, if any. Where there are few data
points available, it is unlikely the results will be representative of worker exposure across the industry.
In cases where there was no exposure monitoring data, EPA may have used monitoring data from
similar conditions of use as surrogate. While these conditions of use have similar worker activities
contributing to exposures, it is unknown that the results will be fully representative of worker exposure
across different conditions of use.

Where sufficient data were reasonably available, the 95th and 50th percentile exposure concentrations
were calculated using reasonably available data. The 95th percentile exposure concentration is intended
to represent a high-end exposure level, while the 50th percentile exposure concentration represents
typical exposure level. The underlying distribution of the data, and the representativeness of the
reasonably available data, are not known. Where discrete data was not reasonably available, EPA used
reported statistics (i.e., median, mean, 90th percentile, etc.). Since EPA could not verify these values,
there is an added level of uncertainty.

EPA calculated ADC and LADC values assuming workers and ONUs are regularly exposed during their
entire working lifetime, which likely results in an overestimate. Individuals may change jobs during the
course of their career such that they are no longer exposed to TCE, and that actual ADC and LADC
values become lower than the estimates presented.

2.3.1.3.3 Near-Field/Far-Field Model Framework

The near-field/far-field approach is used as a framework to model inhalation exposure for many
conditions of use. The following describe uncertainties and simplifying assumptions generally
associated with this modeling approach:

•	There is some degree of uncertainty associated with each model input parameter. In general, the
model inputs were determined based on review of reasonably available literature. Where the
distribution of the input parameter is known, a distribution is assigned to capture uncertainty in
the Monte Carlo analysis. Where the distribution is unknown, a uniform distribution is often
used. The use of a uniform distribution will capture the low-end and high-end values but may not
accurately reflect actual distribution of the input parameters.

•	The model assumes the near-field and far-field are well mixed, such that each zone can be
approximated by a single, average concentration.

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•	All emissions from the facility are assumed to enter the near-field. This assumption will
overestimate exposures and risks in facilities where some emissions do not enter the airspaces
relevant to worker exposure modeling.

•	The exposure models estimate airborne concentrations. Exposures are calculated by assuming
workers spend the entire activity duration in their respective exposure zones (i.e., the worker in
the near-field and the occupational non-user in the far-field). Since vapor degreasing and cold
cleaning involve automated processes, a worker may actually walk away from the near-field
during part of the process and return when it is time to unload the degreaser. As such, assuming
the worker is exposed at the near-field concentration for the entire activity duration may
overestimate exposure.

•	For certain TCE applications (e.g., vapor degreasing and cold cleaning), TCE vapor is assumed
to emit continuously while the equipment operates (i.e. constant vapor generation rate). Actual
vapor generation rate may vary with time. However, small time variability in vapor generation is
unlikely to have a large impact in the exposure estimates as exposures are calculated as a time-
weighted average.

•	The exposure models represent model workplace settings for each TCE condition of use.

Each subsequent item below discusses uncertainties associated with the individual model.

Vapor Degreasing and Cold Cleaning Models

The OTVD, conveyorized vapor degreasing, and cold cleaning assessments use a near-field/far-field

approach to model worker exposure. In addition to the uncertainties described above, the vapor

degreasing and cold cleaning models have the following uncertainties:

•	To estimate vapor generation rate for each equipment type, EPA used a distribution of the
emission rates reported in the 2014 NEI for each degreasing/cold cleaning equipment type. NEI
only contains information on major sources not area sources. Therefore, the emission rate
distribution used in modeling may not be representative of degreasing/cold cleaning equipment
emission rates at area sources.

•	The emission rate for conveyorized vapor degreasing is based on equipment at eight sites. It is
uncertain how representative these data are of a "typical" site.

•	EPA assumes workers and occupational non-users remove themselves from the contaminated
near- and far-field zones at the conclusion of the task, such that they are no longer exposed to
any residual TCE in air.

Brake Servicing Model

The aerosol degreasing assessment also uses a near-field/far-field approach to model worker exposure.

Specific uncertainties associated with the aerosol degreasing scenario are presented below:

•	The model references a CARB study (	XX)) on brake servicing to estimate use rate and
application frequency of the degreasing product. The brake servicing scenario may not be
representative of the use rates for other aerosol degreasing applications involving TCE.

•	The TCE Use Dossier (	) presented 16 different aerosol degreasing formulations
containing TCE. For each Monte Carlo iteration, the model determines the TCE concentration in
product by selecting one of 16 possible formulations, assuming the distribution for each
formulation is equal to that found in a survey of brake cleaning shops in California. It is
uncertain if this distribution is representative of other geographic locations within the U.S.

•	Some of the aerosol formulations presented in the TCE Use Dossier (1 c. « ^ \ rV I . ) were
provided as ranges. For each Monte Carlo iteration the model selects a TCE concentration within

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the range of concentrations using a uniform distribution. In reality, the TCE concentration in the
formulation may be more consistent than the range provided.

Spot Cleaning Model

The multi-zone spot cleaning model also uses a near-field/far-field approach. Specific uncertainties
associated with the spot cleaning scenario are presented below:

•	The model assumes a use rate based on estimates of the amount of TCE-based spot cleaner sold
in California and the number of textile cleaning facilities in California (IRTA. 2007). It is
uncertain if this distribution is representative of other geographic locations in the U.S.

•	The model assumes a facility floor area based on data from (GARB. 2006) and King County
(Whittaker and Johanson.; ). It is unknown how representative the area is of "typical" spot
cleaning facilities. Therefore, these assumptions may result in an overestimate or underestimate
of worker exposure during spot cleaning.

•	Many of the model input parameters were obtained from (Von Grote et al. 2003). which is a
German study. Aspects of the U.S. spot cleaning facilities may differ from German facilities.
However, it is not known whether the use of German data will under- or over-estimate exposure.

2.3.1.3.4	Modeled Dermal Exposures

The Dermal Exposure to Volatile Liquids Model is used to estimate dermal exposure to TCE in
occupational settings. The model assumes a fixed fractional absorption of the applied dose; however,
fractional absorption may be dependent on skin loading conditions. The model also assumes a single
exposure event per day based on existing framework of the EPA/OPPT 2-Hand Dermal Exposure to
Liquids Model and does not address variability in exposure duration and frequency. Additionally, the
studies used to obtain the underlying values of the quantity remaing on the skin (Qu) did not take into
consideration the fact that liquid retention on the skin may vary with individuals and techniques of
application on and removal from the hands. Also the data used were developed from three kinds of oils;
therefore, the data may not be applicable to other liquids. Based on the uncertainties described above,
EPA has a medium level of confidence in the assessed baseline exposure. See Appendix H of the
[.Environmental Releases and Occupational Exposure Assessment. Docket: EPA-HQ-OPPT-2019-0500)\
for the development and underlying research of this model.

2.3.1.3.5	Summary of Overall Confidence in Inhalation Exposure Estimates

Table 2-26 provides a summary of EPA's overall confidence in its inhalation exposure estimates for
each of the Occupational Exposure Scenarios assessed.

Table 2-26: Summary of overall confidence in inhalation exposure estimates by PES.

Occupational Kxposure
Scenario (OKS)

Overall Confidence in Inhalation Kxposurc Kstimalcs

Manufacturing

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 16
data points from 1 source, and the data quality ratings from systematic review
for these data were high. The primary limitations of these data include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this

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scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to high.

Processing as a Reactant

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of surrogate monitoring data, in the
middle of the inhalation approach hierarchy. These monitoring data include 16
data points from 1 source, and the data quality ratings from systematic review
for these data were medium. The primary limitations of these data include the
uncertainty of the representativeness of these surrogate data toward the true
distribution of inhalation concentrations for the industries and sites covered by
this scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

Formulation of Aerosol and
Non-Aerosol Products

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of surrogate monitoring data, in the
middle of the inhalation approach hierarchy. These monitoring data include 33
data points from 1 source, and the data quality ratings from systematic review
for these data were high. The primary limitations of these data include the
uncertainty of the representativeness of these surrogate data toward the true
distribution of inhalation concentrations for the industries and sites covered by
this scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium.

Repackaging

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 33
data points from 1 source, and the data quality ratings from systematic review
for these data were high. The primary limitations of these data include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to high.

Batch Open-Top Vapor
Degreasing

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include
123 data points from 16 sources, and the data quality ratings from systematic
review for these data were medium. The primary limitations of these data

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include the uncertainty of the representativeness of these data toward the true
distribution of inhalation concentrations for the industries and sites covered by
this scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium.

EPA also considered the use of modeling, which is in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Vapor
generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of
the air concentration outputs from the model include the uncertainty of the
representativeness of these data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Added
uncertainties include that the underlying methodologies used to estimate these
emissions in the 2014 NEI are unknown. Based on these strengths and
limitations of the air concentrations, the overall confidence for these 8-hr
TWA data in this scenario is medium to low.

Batch Closed-Loop Vapor
Degreasing

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 19
data points from 1 source, and the data quality ratings from systematic review
for these data were high. The primary limitations of these data include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to high.

Conveyorized Vapor
Degreasing

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 18
data points from 2 sources, and the data quality ratings from systematic review
for these data were medium. The primary limitations of these data include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

EPA also considered the use of modeling, which is in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Vapor
generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of

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the air concentration outputs from the model include the uncertainty of the
representativeness of these data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Added
uncertainties include that emissions data available in the 2014 NEI were only
found for three total units, and the underlying methodologies used to estimate
these emissions are unknown. Based on these strengths and limitations of the
air concentrations, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

Web Vapor Degreasing

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of modeling, in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Vapor
generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of
the air concentration outputs from the model include the uncertainty of the
representativeness of these data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Added
uncertainties include that emissions data available in the 2011 NEI were only
found for one unit, and the underlying methodologies used to estimate the
emission is unknown. Based on these strengths and limitations of the air
concentrations, the overall confidence for these 8-hr TWA data in this scenario
is medium to low.

Cold Cleaning

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of modeling, in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Vapor
generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of
the air concentration outputs from the model include the uncertainty of the
representativeness of these data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Added
uncertainties include that emissions data available in the 2014 NEI were only
found for ten total units, and the underlying methodologies used to estimate
these emissions are unknown. Based on these strengths and limitations of the
air concentrations, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

Aerosol Applications:

Spray Degreasing/Cleaning,
Automotive Brake and
Parts Cleaners, Penetrating
Lubricants, and Mold
Releases

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of modeling, in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Various
model parameters were derived from a CARB brake service study and TCE

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concentration data for 16 products representative of the OES. The primary
limitations of the air concentration outputs from the model include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the air concentrations, the
overall confidence for these 8-hr TWA data in this scenario is medium.

Metalworking Fluids

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of monitoring data, the highest of the
inhalation approach hierarchy. These monitoring data include 3 data points
from 1 source, and the data quality ratings from systematic review for these
data were high. The primary limitations of these data include limited dataset (3
data points from 1 site), and the uncertainty of the representativeness of these
data toward the true distribution of inhalation concentrations for the industries
and sites covered by this scenario. Based on these strengths and limitations of
the inhalation air concentration data, the overall confidence for these 8-hr
TWA data in this scenario is low.

EPA also considered the use of modeling, which is in the middle of the
inhalation approach hierarchy. Data from the 2011 Emission Scenario
Document on the Use of Metalworking Fluids was used to estimate inhalation
exposures. The primary limitations of the exposure outputs from this model
include the uncertainty of the representativeness of these data toward the true
distribution of inhalation for all TCE uses for the industries and sites covered
by this scenario, and the difference between the modeling data and monitoring
data. Added uncertainties include that the underlying TCE concentration used
in the metalworking fluid was assumed from one metalworking fluid product.
Based on these strengths and limitations of the air concentrations, the overall
confidence for these 8-hr TWA data in this scenario is medium.

Adhesives, Sealants, Paints,
and Coatings

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 22
data points from 2 sources, and the data quality ratings from systematic review
for these data were medium to high. The primary limitations of these data
include the uncertainty of the representativeness of these data toward the true
distribution of inhalation concentrations for the industries and sites covered by
this scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to medium to low.

For the ONU inhalation air concentration data, the primary strengths include
the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 2 data points
from 1 source, and the data quality ratings from systematic review for the data
point was high. The primary limitations of this data is the limited dataset (two

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data points from 1 site), and the uncertainty of the representativeness of this
data toward the true distribution of inhalation concentrations for the industries
and sites covered by this scenario. Based on these strengths and limitations of
the inhalation air concentration data, the overall confidence for these 8-hr
TWA data in this scenario is medium to low.

Other Industrial Uses

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA inhalation air concentrations. The primary strengths include the
assessment approach, which is the use of surrogate monitoring data, in the
middle of the inhalation approach hierarchy. These monitoring data include 16
data points from 1 source, and the data quality ratings from systematic review
for these data were medium. The primary limitations of these data include the
uncertainty of the representativeness of these surrogate data toward the true
distribution of inhalation concentrations for the industries and sites covered by
this scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

Spot Cleaning and Wipe
Cleaning

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 8
data points from 2 sources, and the data quality ratings from systematic review
for these data were medium. The primary limitations of these data include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

EPA also considered the use of modeling, which is in the middle of the
inhalation approach hierarchy. A Monte Carlo simulation with 100,000
iterations was used to capture the range of potential input parameters. Various
model parameters were derived from a CARB study. The primary limitations
of the air concentration outputs from the model include the uncertainty of the
representativeness of these data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Added
uncertainties include that the underlying methodologies used to obtain the
values in the CARB study, as well as the assumed TCE concentration in the
spot cleaning product. Based on these strengths and limitations of the air
concentrations, the overall confidence for these 8-hr TWA data in this scenario
is medium to low.

Despite these limitations, the modeling and monitoring results match each
other very closely. Therefore, the overall confidence is medium.

Industrial Processing Aid

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the

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12-hr TWA data. For the inhalation air concentration data, the primary
strengths include the assessment approach, which is the use of monitoring
data, the highest of the inhalation approach hierarchy. These monitoring data
include 30 data points from 1 source, and the data quality ratings from
systematic review for these data were high. The primary limitations of these
data include the uncertainty of the representativeness of these data toward the
true distribution of inhalation concentrations for the industries and sites
covered by this scenario. Based on these strengths and limitations of the
inhalation air concentration data, the overall confidence for these 12-hr TWA
data in this scenario is medium to high.



For the ONU inhalation air concentration data, the primary strengths include
the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 4 data points
from 1 source, and the data quality ratings from systematic review for the data
point was high. The primary limitations of this single data point include the
uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air
concentration data, the overall confidence for these 12-hr TWA data in this
scenario is medium to low.

Commercial Printing and
Copying

EPA considered the assessment approach, the quality of the data, and
uncertainties in assessment results to determine a level of confidence for the 8-
hr TWA data. For the inhalation air concentration data, the primary strengths
include the assessment approach, which is the use of monitoring data, the
highest of the inhalation approach hierarchy. These monitoring data include 20
data points from 1 source, and the data quality ratings from systematic review
for these data were medium. The primary limitations of these data include a
limited dataset, and the uncertainty of the representativeness of these data
toward the true distribution of inhalation concentrations for the industries and
sites covered by this scenario. Based on these strengths and limitations of the
inhalation air concentration data, the overall confidence for these 8-hr TWA
data in this scenario is medium to low.

Other Commercial Uses

EPA did not identify any inhalation exposure monitoring data related to this
OES. EPA assumes the exposure sources, routes, and exposure levels are
similar to those for the Spot Cleaning and Wipe Cleaning OES.

Process Solvent Recycling
and Worker Handling of
Wastes

EPA did not identify any inhalation exposure monitoring data related to waste
handling/recycling. EPA assumes the exposure sources, routes, and exposure
levels are similar to those for the Repackaging OES.

1698

1699	2.3.2 Consumer Exposures

1700	TCE can be found in consumer and commercial products that are available for purchase at common

1701	retailers and can therefore result in exposures to household consumers (i.e., receptors who use a product

1702	directly) and bystanders (i.e., receptors who are a non-product users that are incidentally exposed to the

1703	product or article) (U.S. EPA. 2017c. h).

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2,3.2,1 Consumer Conditions of Use Evaluated

Conditions of use associated with consumer exposure were described in the Problem Formulation (U.S.

18d). The availability of TCE in consumer products was determined through the development of
EPA's 2017 Market and Use Report (	) and Preliminary Information on Manufacturing,

Processing, Distribution, Use, and Disposal: TCE (1 c. « ^ \ JO I . Additional online research was
undertaken following Problem Formulation to confirm TCE concentrations and compile a
comprehensive list of products that may be available to consumers for household use. These resources
were used to select the most appropriate product-specific inputs (e.g., weight fraction and formulation
type) associated with each consumer condition of use.

Table 2-27 lays out consumer condition of use categories and associated product subcategories
evaluated for TCE. Based on additional research, conditions of use may be described in more detail
(e.g., formulation type, specific product type) when compared to the tables presented in the Problem
Formulation (	|). Any differences between the displayed categories and those presented

in the Problem Formulation are described in the footnotes.

Table 2-27. Evaluated Consumer Conditions of Use and Products for T<

CE

Life
Cycle
Stage

Category

Product Subcategory

Form1

No. of
Products
Utilized in
Modeling1

Use

Solvents for Cleaning and
Degreasing

Brake & Parts Cleaner2

Aerosol

4

Electronic Degreaser/Cleaner3

Aerosol

9

Electronic Degreaser/Cleaner3

Liquid

1

Aerosol Spray Degreaser/Cleaner

Aerosol

8

Liquid Degreaser/Cleaner3

Liquid

2

Gun Scrubber4

Aerosol

2

Gun Scrubber4

Liquid

1

Mold Release

Aerosol

2

Tire Cleaner5

Aerosol

2

Tire Cleaner5

Liquid

1

Lubricants and Greases

Tap & Die Fluid

Aerosol

1

Penetrating Lubricant6

Aerosol

5

Adhesives and Sealants

Solvent-based Adhesive & Sealant

Liquid

3

Mirror-edge Sealant

Aerosol

1

Tire Repair Cement/Sealer

Liquid

5

Cleaning and Furniture Care
Products 11

Carpet Cleaner

Liquid

1

Spot Remover7

Aerosol

1

Spot Remover7

Liquid

4

Arts, Crafts, and Hobby Materials

Fixatives & Finishing Spray
Coatings8

Aerosol

1

Apparel and Footwear Care Products

Shoe Polish

Aerosol

1

Other Consumer Uses

Fabric Spray9

Aerosol

1

Film Cleaner

Aerosol

2

Hoof Polish

Aerosol

1

Pepper Spray

Aerosol

2

Toner Aid10

Aerosol

1

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Life
Cycle
Stage

Category

Product Subcategory

Form1

No. of
Products
Utilized in
Modeling1

1	Form was determined based on the specific products identified as representative of the associated product
subcategories. Please see Supplemental File [Consumer Exposure Assessment Model Input Parameters. Docket:
EPA-HQ-OPPT-2019-0500] for the full list of representative products.

2	The brake cleaner subcategory was listed in Table 2-3 of the Problem Formulation as being associated with the
automotive care products category; however, the same brake cleaning conditions of use are now associated with the
broader solvents for cleaning and degreasing category. This change does not impact evaluated conditions of use, as
the evaluated product scenarios are based on the brake cleaner product(s) and not a broader category of use.

3	Liquid degreaser/cleaner and electronic degreaser/cleaner (aerosol and liquid) were not specifically named in the
Problem Formulation as a potential consumer subcategories. They were added due to product availability based on
the additional research noted above that helped to differentiate specific product forms (i.e., liquid or aerosol) and
types.

4	The gun scrubber subcategory was listed in Table 2-3 of the Problem Formulation as being associated with the
other consumer uses category; however, the same gun scrubber conditions of use are now associated with the
broader solvents for cleaning and degreasing category. This change does not impact evaluated conditions of use, as
the evaluated product scenarios are based on the gun scrubber product(s) and not a broader category of use.

5	Tire cleaner products / subcategories of use were not specifically called out in the Problem Formulation; however,
such products were identified in the 2017 Use and Market Report and Preliminary Information on Manufacturing,
Processing, Distribution. Use, and Disposal: TCE (U.S. EPA. 20.1.7c) and fit within the broader Solvents for
Cleaning and Degreasing category.

6	Based on additional research into the specific product(s) associated with the broader lubricants and greases
category, the subcategory name was updated from penetrating lubricant to lubricant.

7	The spot remover subcategory was listed in Table 2-3 of the Problem Formulation as being associated with the
laundry and dishwashing products category; however, the same spot remover conditions of use are now associated
with the cleaning and furniture care products category. This change does not impact evaluated conditions of use, as
the evaluated product scenarios are based on the spot remover product(s) and not a broader category of use.

8	Note that this subcategory is referred to as "clear protective coating spray" in U.S. EPA (20.1.4b) and as "spray
fixative" in the TCE Significant New Use Rule (80 FR 47441).

9	Fabric spray (specifically an anti-fray spray) was added following Problem Formulation based on identification in
the final 2014 TCE Work Plan Chemical Risk Assessment (U.S. EPA. 2014b).

10	The toner aid subcategory was listed in Table 2-3 of the Problem Formulation as being associated with the Ink,
toner, and colorant products category; however, the toner aid use is not like use of a toner or pigment; therefore, the
same toner aid condition of use is now associated with the other consumer use category. This change does not
impact evaluated conditions of use, as the evaluated product scenarios are based on the toner aid product(s) and not
a broader category of use.

11	Note that the problem formulation described "cleaning wipes" as a condition of use for this category. However,
that referred to the application of a product that is then wiped off, rather than a pre-wet towelette. A number of
consumer conditions of use involve wipe cleaning and are described in detail in Section 2.3.2.6.2 as leading to
dermal contact with impeded evaporation.	

2.3.2.2 Consumer Exposure Routes Evaluated

Inhalation and dermal exposures are evaluated for acute exposure scenarios, i.e., those resulting from
short-term or daily exposures. Chronic exposure scenarios resulting from long-term use of household
consumer products were not evaluated. In general, the frequency of product use was considered to be too
low to create chronic risk concerns. Although high-end frequencies of consumer use are up to 50 times
per year, reasonably available toxicological data is based on either single or continuous TCE exposure
and it is unknown whether these use patterns are expected to be clustered or intermittent (e.g. one time
per week). There is uncertainty regarding the extrapolation from continuous studies in animals to the case
of repeated, intermittent human exposures. Therefore, EPA cannot fully rule out that consumers at the
high-end frequency of use could possibly be at risk for chronic hazard effects, however it is expected to
be unlikely.

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2.3.2.2.1	Inhalation

The acute exposure via inhalation is the most significant route of exposure for consumer exposure
scenarios for users and bystanders. This is in line with EPA's 2014 TSCA Work Plan Chemical Risk
Assessment, which evaluated acute inhalation exposure to consumers and bystanders from degreasing
and arts & crafts uses (	2014b). EPA evaluated inhalation exposures for consumers and

bystanders for all consumer conditions of use.

Background levels of TCE in indoor and outdoor air are not assessed in this assessment; therefore, there
is a potential for underestimating consumer inhalation exposures, particularly for populations living near
a facility emitting TCE or living in a home with other sources of TCE, such as TCE-containing products
stored in the home. Similarly, inhalation exposures were evaluated on a product-specific basis and are
based on use of a single product type within a day, not multiple products.

2.3.2.2.2	Dermal

EPA assessed dermal exposures to TCE from consumer uses. Instantaneous exposures to skin are
expected to evaporate before significant dermal absorption occurs based on TCE's physical chemical
properties which include the vapor pressure, water solubility and log Kow. The log Kow estimate is 0.8%
absorption and 99.2% volatilization and is derived from IHSkinPerm, a mathematical tool for estimating
dermal absorption. Exposure that occurs as a deposition over time or a repeated exposure that maintains
a thin layer of liquid TCE had greater absorption based on the estimate from IHSkinPerm for an 8-hr
exposure is 1.6% absorption and 98.4% volatilization. Dermal exposures to liquid TCE are expected to
be concurrent with inhalation exposures, which are anticipated to reflect the preponderance of overall
exposure from a use or activity for most consumer exposure scenarios. This agrees with the NIOSH skin
notation profile for TCE, which estimates a low hazard potential by dermal absorption for systemic
effects when inhalation and dermal exposures are concurrent (Hudson and Dotson. 2017). There may be
certain scenarios with higher dermal exposure potential - where liquid TCE is not able to evaporate
readily and volatilization is inhibited. An example of this is a user holding a rag soaked with TCE
against their palm during a cleaning activity. Therefore, dermal exposures are quantified and presented
for consumer use scenarios that may involve dermal contact with impeded evaporation.

Generally, individuals that have contact with liquid TCE would be users and not bystanders. Therefore,
dermal exposures to liquid TCE are not expected and inhalation is the primary route of exposure for
bystanders. There is potential for bystanders or users to have indirect dermal contact via contact with a
surface upon which TCE has been applied (e.g., counter, floor). Based on the expectation that TCE
would evaporate from the surface rapidly, with <1% dermal absorption predicted from instantaneous
contact, this route is unlikely to contribute significantly to overall exposure.

2.3.2.3 Potentially Exposed or Susceptible Subpopulations

As part of the Problem Formulation (	), EPA identified consumers and bystanders

associated with use of TCE-containing consumer products as a potentially exposed and susceptible
subpopulation due to greater exposure. Additionally, higher-intensity users (i.e., those using consumer
products for longer durations and in greater amounts) were considered and evaluated. Exposures and
risks for these subpopulations are considered and evaluated herein. Consumers are considered to include
children and adults age 11 and up, but bystanders in the home exposed via inhalation are considered to
include any age group, from infant to adult, including pregnant women. Highly exposed (high-intensity
users) and potentially exposed or susceptible subpopulations (PESS) within this overall schema as
receptor categories overlap, as individuals may belong to multiple receptor groups.

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2,3.2,4 Consumer Exposures Approach and Methodology

Modeling was conducted to estimate exposure from the identified consumer conditions of use.

Exposures via inhalation and dermal contact to TCE-containing consumer products were estimated using
EPA's Consumer Exposure Model (CEM) Version 2.1 (	), along with consumer

behavioral pattern data (i.e., use patterns) and product-specific characteristics.

Residential indoor air and personal breathing zone data were identified and evaluated during systematic
review. However, measured levels are not attributable to specific consumer products or conditions of use
and were therefore not compared to modeled estimates. For a summary of these data, see Appendix D.2.

2.3.2.4.1 Modeling Approach

Consumer Exposure Model (CEM) Version 2.1 was selected for the consumer exposure modeling as the
most appropriate model to use based on the type of input data available for TCE-containing consumer
products. Moreover, EPA did not have the input parameter data (i.e., product-specific chamber emission
data) required to run higher-tier indoor air models. The advantages of using CEM to assess exposures to
consumers and bystanders are the following:

•	CEM model has been peer-reviewed;

•	CEM accommodates the distinct inputs available for the products containing TCE; and

•	CEM uses the same calculation engine to compute indoor air concentrations from a source as the
higher-tier Multi-Chamber Concentration and Exposure Model (MCCEM) but does not require
measured chamber emission values.

For a characterization of model sensitivity, see Appendix D.l .

Modeling Air Concentrations and Inhalation Exposure

CEM predicts indoor air concentrations from consumer product use by implementing a deterministic,
mass-balance calculation utilizing an emission profile determined by implementing appropriate emission
scenarios. The model uses a two-zone representation of the building of use (e.g., residence, school,
office), with Zone 1 representing the room where the consumer product is used (e.g., a utility room) and
zone 2 being the remainder of the building. The product user is placed within Zone 1 for the duration of
use, while a bystander is placed in Zone 2 during product use. Otherwise, product users and bystanders
follow prescribed activity patterns throughout the simulated period. In some instances of product use, a
higher concentration of product is expected very near the product user; CEM addresses this by further
dividing Zone 1 into near-field, with a default volume of lm3, and far-field, which reflects the remainder
of Zone 1. Each zone is considered well-mixed. Product users are exposed to airborne concentrations
estimated within the near-field during the time of use and otherwise follow their prescribed activity
pattern. Bystanders follow their prescribed activity pattern and are exposed to far-field concentrations
when they are in Zone 1. Background concentrations can be set to a non-zero concentration if desired.

For acute exposure scenarios, emissions from each incidence of product usage are estimated over a
period of 72 hours using the following approach that account for how a product is used or applied, the
total applied mass of the product, the weight fraction of the chemical in the product, and the molecular
weight and vapor pressure of the chemical.

The general steps of the calculation engine within the CEM model include:

•	Introduction of the chemical (i.e., TCE) into the room of use (Zone 1) through two possible
pathways: (1) overspray of the product or (2) evaporation from a thin film;

•	Transfer of the chemical to the rest of the house (Zone 2) due to exchange of air between the
different rooms;

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•	Exchange of the house air with outdoor air; and

•	Compilation of estimated air concentrations in each zone as the modeled occupant (i.e., user or
bystander) moves about the house per prescribed activity patterns.

As receptors move between zones in the model, the associated zonal air concentrations at each 30-
second time step were compiled to reflect the air concentrations a user and bystander would be exposed
to throughout the simulation period. Time weighted averages (TWAs) were then computed based on
these user and bystander concentration time series per available human health hazard data. For TCE, 3-
and 24-hour TWAs were quantified for use in risk evaluation based on alignment relevant acute human
health hazard endpoints.

Emission Models

Based on the suite of product scenarios developed to evaluate the TCE consumer conditions of use, the
specific emission models applied for the purposes of modeling TCE products include: El: Emission
from Product Applied to a Surface Indoors Incremental Source Model and E3: Emission from Product
Sprayed.

El assumes a constant application rate over a user-specified duration of use and an emission rate that
declines exponentially over time, at a rate that depends on the chemical molecular weight and vapor
pressure. This emission model is generally applicable to liquid products applied to surfaces that
evaporate from those surfaces, such as cleaners. El was applied for all liquid formulations in the
modeling of TCE consumer inhalation exposures. E3 assumes a small percentage of product becomes
airborne rather than contacting the target surface and therefore immediately available for uptake via
inhalation. This is called "overspray" and is not well characterized, though default parameters ranging
from 4.5 to 6% overspray are based on a combination of modeled and empirical data from Jayjock
(2 ) and are said to reflect reasonable worst-case overspray potential (	). The

remainder of chemical is assumed to contact the target surface and volatilize at a rate that depends on the
chemical molecular weight and vapor pressure. The aerosolized portion is treated using a constant
emission rate model while the non-aerosolized mass is treated in the same manner as liquid products
applied to a surface, combining a constant application rate with an exponentially declining rate. In U.S.
EPA (2014b). modeled scenarios were found not to be sensitive to this parameter, with overspray
fractions of 1 and 25% producing nearly identical peak concentrations for TCE. Both El and E3 have a
near-field model option that is selected to capture the higher concentration in the breathing zone of a
product user during use.

For additional details on CEM 2.1's underlying emission models, assumptions, and algorithms, please
see the User Guide Section 3: Detailed Descriptions of Models within CEM (	). The

emission models used have been compared to other model results and measured data; see Appendix D:
Model Corroboration of the User Guide Appendices for the results of these analyses (	>).

Modeling Dermal Exposure

CEM also contains a dermal modeling component that estimates absorbed dermal doses resulting from
dermal contact with chemicals found in consumer products. Based on the described dermal exposure
conditions (i.e., dermal contact with impeded evaporation) and the chemical- and scenario-specific input
parameters available for use in modeling (e.g., scenario-specific use duration, measured dermal
permeability coefficient), "P_DER2b: Dermal Dose from Product Applied to Skin, Permeability Model"
was selected as the most appropriate model to estimate dermal exposures from consumer products
containing TCE. P_DER2b estimates dermal flux based on a permeability coefficient (Kp) and is based
on the ability of a chemical to penetrate the skin layer once contact occurs. It assumes a constant supply

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of chemical directly in contact with the skin throughout the exposure duration. The acute form of the
model is given below:

SA

K x Dac x p x w x FQac x Dil xWFx EDac x CF1
ADR = —	-

ATac X CF2

Where:

ADR

= Potential acute dose rate (mg/kg-day)

KP

= Permeability coefficient (cm/hr)

Dac

= Duration of use (min/event)

P

= Density of formulation (g/cm3)

SA/BW

= Surface area to body weight ratio (cm2/kg)

FQac

= Frequency of use (events/day, 1 for acute exposure scenarios)

Dil

= Product dilution fraction (unitless, 1 [no dilution] for all TCE scenarios)

WF

= Weight fraction of chemical in product (unitless)

EDac

= Exposure duration (days)

CF1

= Conversion factor (1,000 mg/g)

CF2

= Conversion factor (60 min/hr)

ATac

= Averaging time (days, 1 for acute exposure scenarios)

Kp is a measure of the rate of chemical flux through the skin. The parameter can either be specified by
the user (if measured data are reasonably available) or be estimated within CEM using a chemical's
molecular weight and octanol-water partition coefficient (Kow). Note the permeability model does not
inherently account for evaporative losses (unless the available flux or Kp values are based on non-
occluded, evaporative conditions), which can be considerable for volatile chemicals in scenarios where
evaporation is not impeded. While the permeability model does not explicitly represent exposures
involving such impeded evaporation, the model assumptions make it the preferred model for an such a
scenario (e.g., a scenario wherein dermal contact involved impeded evaporation, or where there is
potential for dermal immersion). Furthermore, it incorporates scenario-specific product use durations
and distinct surface area to body weight ratios for various user populations. For additional details on
P_DER2b, please see the CEM User Guide Section 3: Detailed Descriptions of Models within CEM

(I	M-

For TCE, a measured dermal permeability coefficient (Kp 0.019 cm/hr) is applied, based on findings
from Poet (2000). as summarized and presented in the 2017 NIOSH Skin Notation Profile for TCE
(Hudson andDotson. 2017). The permeability coefficient selected was based on a human water-patch
test and was within range of the estimated Kp values presented in the 2017 NIOSH Skin Notation Profile
(0.01197 cm/hr) (Hudson and Dotson. 2017) and within the CEM model (0.028 cm/hr), both predicted
using chemical properties.

Dermal exposure estimates are only quantified and presented for consumer exposure scenarios that
could involve such dermal contact with impeded evaporation (e.g., application or cleaning with a rag
pressed against user's hand), per the focus described in Section 2.3.2.2.2.

Variation

To capture a range of potential exposure levels associated with consumer conditions of use, three input
parameters were varied: mass of product used, weight fraction, and duration of use. Aside from these
three parameters, model inputs were held constant across a specific scenario or across all product
scenarios. For example, certain inputs such as the room of use (and associated room/Zone 1 volume),
overspray fraction, and surface area to body weight ratio exposed in dermal exposure scenarios were

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held constant across the multiple iterations of a single product scenario but differed across product
scenarios based on their scenario-specific nature. Other parameters such as chemical properties, building
volume, air exchange rate, and user and bystander activity patterns (i.e., movements around the home)
were held constant across all product scenarios and runs. The majority of the non-varied modeling
parameters reflect central tendency inputs (i.e., median or mean values; see Table 2-28); therefore, the
combination of high-end inputs for the three varied parameters do not reflect "worst-case" or bounding
estimates.

Varied Inputs:

Considering the model sensitivity analysis summarized in Appendix D.l and the availability of high-
quality use-pattern data, EPA varied three input parameters: chemical weight fraction (WF) in a
consumer product; mass of product used per use event; and duration of product use per event.

The low-, mid-, and/or high-end weight fractions were selected principally from MSDS/SDS forms. For
subcategories where there was only one product with a weight fraction range, only one weight fraction
was used for modeling. If there were two or more products with weight fraction ranges, the low-end of
lowest non-zero range and high-end of highest range were the bounding weight fractions. For a central
tendency weight fraction, the mid-point between bounding weight fractions was calculated. In the case
of unknown weight fractions, values were selected from the range of related products. Further detail is
provided in the Supplemental File, [Consumer Exposure Assessment Model Input Parameters. Docket:
EPA-HQ-OPPT-2019-0500].

Mass of product used and duration of use selections define user characteristics (e.g., high-intensity user,
moderate-intensity user, low-intensity user) and are based on the Household Solvent Products: A
National Usage Survey (U.S. EPA. 1987). referred to as the "Westat survey" or "Westat" herein, and
described further in section 2.3.2.5. The survey was rated as having "high" quality during the data
evaluation phase of systematic review. Weight fraction (i.e., the percentage of TCE in the product
formulation) represents the true range in the market based on manufacturer-developed Safety Data
Sheets (SDSs).

For each parameter varied, up to three distinct inputs were modeled to address known variability across
these three parameters. While this approach resulted in up to 27 distinct exposure results for each
product scenario/condition of use, this was a deterministic assessment and results reflect a range based
on variation of three key parameters, not a distribution. Unlike inhalation modeling, for dermal
modeling, only the weight fraction and duration of product use were varied because mass used is not a
parameter in the dermal exposure model P_DER2b.

In the model sensitivity analysis, summarized in Appendix D. 1 and shown in the user guide appendices
(	'019b). additional parameters are identified as highly sensitive, including the air exchange

rate and zone volume. However, the central tendency default modeling values were held constant for
these inputs. The inputs varied included those that characterize actual users and reflect levels of TCE in
actual products.

2.3.2.5 Consumer Exposure Scenarios and Modeling Inputs

Exposure modeling scenarios comprise information that characterizes chemical properties, products, and
use patterns, including:

•	Formulations (e.g., weight fraction, formulation type [aerosol, liquid]);

•	Chemical or product-specific properties (e.g., product density, vapor pressure, molecular weight
diffusion coefficient, overspray fraction, transfer coefficients, dilution factor);

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•	Use patterns (e.g., frequency, duration, and amount used);

•	Human exposure factors (e.g., body weight, inhalation rate); and

•	Environmental conditions (e.g., air exchange rates and room size).

Consumer exposure modeling scenarios based on the identified conditions of use were built based on
identified TCE products that may be available to consumers, including solvents for cleaning and
degreasing, lubricants and greases, adhesives and sealants, and other uses. The subcategories of use (i.e.,
consumer product types) cited in Table 2-27 were used to develop distinct consumer exposure modeling
scenarios for use in estimating inhalation and dermal exposure to consumers and bystanders. The
availability of TCE in consumer products was determined through the development of EPA's 2017
Market and Use Report and Preliminary Information on Manufacturing, Processing, Distribution, Use,
and Disposal: TCE. Additional online research was undertaken following Problem Formulation to
confirm TCE concentrations and compile a comprehensive list of products that may be available to
consumers for household use. Specific product characteristics obtained from manufacturer websites
and/or Safety Data Sheets (SDSs) such as form/formulation type, weight fraction and density, were used
to select the most appropriate product-specific inputs (e.g., weight fraction and formulation type)
associated with each consumer condition of use. Please see Supplemental File {Consumer Exposure
Assessment Model Input Parameters. Docket: EPA-HQ-OPPT-2019-0500]fov full product details,
including product-specific formulations, weight fractions, and densities.

CEM requires inputs governing chemical properties, product characteristics, use environment, and user
patterns (i.e., user behavior). These include inputs such as physical chemical properties, weight fraction,
formulation type, duration of product use, mass of product used, and Zone 1 (room of use) volume. To
determine relevance and appropriateness of the consumer use pattern parameters, EPA reviewed the
consumer product categories available in the Westat Survey (1987). Westat surveyed thousands of
American households via questionnaire or telephone from 4,920 respondents across the United States to
gather information on consumer behavior (i.e., use patterns) and product characteristics (e.g., product
formulation type) related to product categories that may contain halogenated solvents like TCE. The
Westat Survey was rated as a high quality study during data evaluation within the systematic review
process. It forms the basis for relevant chapters of EPA's Exposure Factors Handbook and was used to
derive certain default parameters in EPA's CEM 2.1. Westat ( ) includes survey response data on 30
distinct product categories and reports the following: numbers of respondents; percentage of respondents
reporting use; frequency of use; duration of use; time spent in the room of use; brand of product used;
form of product used; amount of product used; and room of use.

The room of use selected for this evaluation is based on the room in which the Westat Survey results
reported the highest percentage of respondents that last used a product within the room. When the
Westat Survey identified the room of use where the highest percentage of respondents last used the
product as "other inside room", the utility room was selected within CEM for modeling. The pre-defined
product scenarios within CEM were selected based on a cross-walk to similar product categories within
the Westat Survey.

In evaluating Westat survey data for appropriateness, EPA considered the similarity of product category,
as well as the similarity of reported product formulation type (i.e., aerosol, liquid). When a direct
alignment could not be found between the consumer product and Westat product category, EPA used
professional judgement in considering other Westat categories with reasonable ranges for use duration
and amount of product used. A crosswalk between TCE consumer use scenarios and Westat Product
Categories are listed in Table 2-30 and described in more detail in Section 2.3.2.6.2.

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2.3.2.5.1 Consumer Exposure Model Inputs

Chemical-specific inputs required to model consumer inhalation and dermal exposure included physical
and chemical properties (

Table 1-1), as well as a chemical-specific dermal permeability coefficient (0.019 cm/hr), which were
held constant across all modeling scenarios and iterations.

The consumer exposure model requires product-specific data based on product characteristics and use
patterns. It also requires fixed inputs to define the exposure zones (e.g., room and building volumes, air
exchange rates, interzonal ventilation rates); general use patterns defining the amount of time a receptor
is likely to be in the home; receptor characteristics (e.g., age, surface area to body weight ratios); and
emission characteristics (e.g., background air concentration, emission factor). These default inputs are
held constant for a given scenario but may vary across scenarios based on scenario-specific exposure
factors or assumptions. As such, these inputs were not altered to capture within-scenario variation. Table
2-28 shows these default parameters.

Table 2-29 displays TCE consumer product modeling scenarios and associated product-specific inputs
that were varied to capture within-scenario variation. These varied inputs include: weight fraction,
duration of use, and mass of product used. Westat (1987) is the basis for duration of use and mass of
product used and product SDSs are the basis for weight fraction and formulation type.

Table 2-30 presents the consumer product modeling scenarios and associated scenario-specific inputs
that were not varied within product modeling scenarios but did vary across scenarios. In modeling
exposures within and across all scenarios, parameters displayed in both below tables were utilized, along
with the general chemical-specific characteristics and other model defaults. Please see Supplemental
File [Consumer Exposure Assessment Model Input Parameters. Docket: EPA-HQ-OPPT-2019-0500] for
a spreadsheet summarizing all of the model inputs and product information.

For all scenarios, the consumer user was assumed to be an adult (age 21+) and two child age groups (16-
20 years and 11-15 years), while a non-user bystander can include individuals of any age. For the TCE
products identified, younger children would not be expected to be directly using these products.
Inhalation exposure results are presented as concentrations encountered by users and non-user bystanders
and are independent of age group. EPA presents all three evaluated user age groups for dermal exposures as
reported doses are age-group specific.

Table 2-28. Default Modeling Input Parameters

Parameter Type

Modeling
Parameter

Default Value
Modeled

Value
Characterization

Reference

Building
Characteristic1

Building Volume
(m3)

492

Central Tendency
(Mean)

(U.S. EPA. 2011c)

Air Exchange Rate
(hr1)

0.452

Central Tendency
(Median)

(U.S. EPA. 2011c)

Interzonal
Ventilation Rate
(m3/hr)3

Garage: 109

NA

Default (U.S. 1 1.9a, b)

All other rooms
modeled: 107

Emission
Characteristics

Background Air

Concentration

(mg/m3)

0

Minimum

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Gas Phase Mass
Transfer

Coefficient (m/hr)

Emission Factor
(ug/m2/hr)

Based on chemical properties and estimated
within CEM



Saturation
Concentration in
Air (mg/m3)

5.18E+05

Based on chemical
properties and
estimated within
CEM

Aerosol Fraction
(Spray Scenarios
Only)

0.06

High-end

Product Dilution
Fraction

1 (no dilution)

NA

Based on formulation and
intended use

Use Patterns and
Exposure Factors

Receptor Activity
Pattern

Stay at home4

NA

Default (U.S. 1 1.9a, b)

Use Start Time

9 AM5

NA

NA

Frequency of Use

1 event per day

NA

Default (U.S. 1 1.9a, b)

Acute Averaging
Time

1 day

NA

Surface Area to
Body Weight Ratio

Inside of One Hand

Adult (21+): 3.10
Children (16-20): 2.90
Children (11-15): 3.17

Central tendency
(mean)

10% of Hands

Adult (21+): 1.24
Children (16-20): 1.16
Children (11-15): 1.27

Central tendency
(mean)

1 An overall residential building volume of 492 m3 is used to calculate air concentrations in Zone 2 and room volume is
used to calculate air concentrations in Zone 1. The volume of the near-field bubble in Zone 1 was assumed to be 1 m3 in
all cases, with the remaining volume of Zone 1 comprising the far-field volume.

2Air exchange rates differed for two scenarios: pepper spray and hoof polish (see
Table 2-30).

3	The default interzonal air flows are a function of the overall air exchange rate and volume of the building, as well as the
"openness" of the room itself. Kitchens, living rooms, garages, schools, and offices are considered more open to the rest
of the home or building of use; bedrooms, bathrooms, laundry rooms, and utility rooms are usually accessed through one
door and are considered more closed.

4	The activity pattern (i.e., zone location throughout the simulated exposure period) for user and bystander was the
default "stay-at-home" resident, which assumes the receptors are primarily in the home (in either Zone 1 or 2)
throughout the day. These activity patterns in CEM were developed based on Consolidated Human Activity Database
(CHAD) data of activity patterns (Isaacs. 2014).

5	Product use was assumed to start at 9 AM in the morning; as such, the user was assumed to be in the room of use (Zone
1) at that time, regardless of the default activity pattern placement at 9 AM.

2054

2055

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Table 2-29 Consumer Product Modeling Scenarios and Varied Input Parameters



Product

Sub-
Categories

Form
(No. of
Pdts)1

Range
of

Weight Fractions
Selected for

Selected

Duration of Use

Range

of
Product
Density

(g/cm3)4

Mass [Volume] of
Product Used
(g, [oz])

Consumer
Category

Weight
Fraction

Modeling
(% TCE)

Westat
Survey



(min)



(%
TCE)2

Min2

Mid

Max

Scenario

10th
%ile3

50th
%ile

95th
%ile

10th
%ile

50th
%ile

95th
%ile

Solvents

Brake &

Aerosol

0 - 100

20

60

100

Brake

1

15

120

1.23-

47.9

191.6

766.5

for

Cleaning

Parts
Cleaner

(4)









Quieters /
Cleaners







1.62

[1]

[4]

[16]

and

Electronic

Aerosol

30 - 100

30

65

100

Specialized

0.17

2

30

1.25-

1.8

22.5

337.1

Degreasing

Degreaser/
Cleaner

(9)









Electronics
Cleaners
(for TV,
VCR,

Razor, etc.)







1.52

[0.04]

[0.5]

[7.5]



Electronic

Liquid

100

100





Specialized

0.17

2

30

1.46

1.7

21.6

323.8



Degreaser/
Cleaner

(1)









Electronics
Cleaners
(for TV,
VCR,

Razor, etc.)









[0.04]

[0.5]

[7.5]



Spray

Aerosol

60 - 100

60



100

Engine

5

15

120

1.46-

130.8

521.4

2157.4



Degreaser/
Cleaner

(8)









Degreasing5







1.52

[2.91]

[11.6]

[48]



Liquid

Liquid

90 - 100

100





Solvent-

2

15

120

1.456

24.1

139.9

1377.7



Degreaser/
Cleaner

(2)









Type
Cleaning
Fluids or
Degreasers









[0.56]

[3.25]

[32]



Gun

Aerosol

60 - 1006

60



100

Solvent-

2

15

120

1.36-

NA

0.7

NA



Scrubber

(2)









Type
Cleaning
Fluids or
Degreasers7







1.465



[0.45
mL]8





Gun

Liquid

1008

100





Solvent-

2

15

120

1.36

NA

0.6

NA



Scrubber

(1)









Type
Cleaning
Fluids or
Degreasers7











[0.45
mL]8



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Product

Sub-
Categories

Form
(No. of
Pdts)1

Range
of

Weight Fractions
Selected for

Selected

Duration of Use

Range

of
Product
Density

(g/cm3)4

Mass [Volume] of
Product Used
(g, [oz])

Consumer
Category

Weight
Fraction

Modeling
(% TCE)

Westat
Survey



(min)



(%
TCE)2

Min2

Mid

Max

Scenario

10th
%ile3

50th
%ile

95th
%ile

10th
%ile

50th
%ile

95th
%ile



Mold

Aerosol

40 -68.9

40



68.9

Other

0.08

2

30

0.77-

4.3

23.4

212.9



Release

(2)









Lubricants
(Excluding
Automotive)







1.44

[0.1]

[0.55]

[5]



Tire Cleaner

Aerosol
(2)

70 - 100

70



100

Tire /

Hubcap

Cleaner

5

15

60

0.67

10.5
[0.53]

52.9
[2.67]

317.0
[16]



Tire Cleaner

Liquid

(1)

80 - 100

100





Tire /

Hubcap

Cleaner

5

15

60

0.67-
1.493

23.4
[0.53]

117.9
[2.67]

706.4
[16]

Lubricants

Tap & Die

Aerosol

98

98





Other

0.08

2

30

0.9

2.7

14.8

134.5

and

Fluid

(1)









Lubricants









[0.1]

[0.55]

[5]

Greases













(Excluding
Automotive)

















Penetrating

Aerosol

5-50

5

27.5

50

Other

0.08

2

30

0.636-

4.2

23.1

209.9



Lubricant

(5)









Lubricants
(Excluding
Automotive)







1.42

[0.1]

[0.55]

[5]

Adhesives

Solvent-

Liquid

5 ->90

5

47.5

90

Contact

0.33

4.25

60

1.33-

1.3

10.7

185.2

and

Sealants

based

Adhesive &
Sealant

(3)









Cement,
Super
Glues, and
Spray
Adhesives







1.45

[0.03]

[0.25]

[4.32]



Mirror-edge

Aerosol

20-40

40





Contact

0.33

4.25

60

0.614

0.5

4.5

78.4



Sealant

(1)









Cement,
Super
Glues, and
Spray
Adhesives









[0.03]

[0.25]

[4.32]



Tire Repair

Liquid

65-95

65

80

95

Contact

0.33

4.25

60

1.45

1.3

10.7

185.2



Cement/
Sealer

(5)









Cement,
Super
Glues, and
Spray
Adhesives









[0.03]

[0.25]

[4.32]

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Product

Sub-
Categories

Form
(No. of
Pdts)1

Range
of

Weight Fractions
Selected for

Selected

Duration of Use

Range

of
Product
Density

(g/cm3)4

Mass [Volume] of
Product Used
(g, [oz])

Consumer
Category

Weight
Fraction

Modeling
(% TCE)

Westat
Survey



(min)



(%
TCE)2

Min2

Mid

Max

Scenario

10th
%ile3

50th
%ile

95th
%ile

10th
%ile

50th
%ile

95th
%ile

Cleaning
and

Carpet
Cleaner

Liquid

(1)

99

99





Spot

Removers

0.25

5

30

1.6

11.8
[0.25]

62.9
[1.33]

526.6
[11.13]

Furniture

Spot

Aerosol

20-30

30





Spot

0.25

5

30

1.562

11.5

61.4

514.1

Care
Products

Remover

(1)









Removers









[0.25]

[1.33]

[11.13]

Spot

Liquid

<50-

50



75

Spot

0.25

5

30

1.25-

10.7

57.0

477.2



Remover

(4)

>75







Removers







1.45

[0.25]

[1.33]

[11.13]

Arts,

Fixatives &

Aerosol

20-30

30





Aerosol

0.25

5

60

0.704

9.4

45.2

306.0

Crafts, and

Hobby

Materials

Finishing

Spray

Coatings

(1)









Rust

Removers9









[0.45]

[2.17]

[14.7]

Apparel

Shoe Polish

Aerosol

10-20

20





Spray Shoe

0.5

5

30

0.512

2.9

15.4

151.4

and



(1)









Polish









[0.19]

[1.02]

[10]

Footwear





























Care





























Products





























Other

Fabric Spray

Aerosol

20-40

40





Water

1.4

10

60

0.614

11.4

49.9

326.8

Consumer
Uses



(1)









Repellents /
Protectors
(for Suede,
Leather, and
Cloth)









[0.63]

[2.75]

[18]



Film

Aerosol

80 - 100

100





Aerosol

0.25

5

60

1.45-

19.4

93.4

632.9



Cleaner

(2)









Rust

Removers9







1.456

[0.45]

[2.17]

[14.7]



Hoof Polish

Aerosol
(1)

3010

30





Spray Shoe
Polish11

0.5

5

30

0.512-
0.704

4.0
[0.19]

21.2
[1.02]

208.2
[10]



Pepper

Aerosol

91.5

91.5





NA12

NA

0.0812

NA

1.25

NA

4.0

NA



Spray

(2)





















[0.108

l12





Toner Aid

Aerosol
(1)

10-20

20





Aerosol
Rust

Removers9

0.25

5

60

1

13.3
[0.45]

64.2
[2.17]

434.7
[14.7]

1 The number of products identified is based on the product lists in EPA's 2017 Market and Use Report and Preliminary Information on Manufacturing,
Processing, Distribution Use and Disposal: TCE, as well as the 2014 TSCA Work Plan Chemical Risk Assessment for TCE (U.S. EPA. 2017c. h). Please see
Supplemental File \Consumer Exposure Assessment Model Input Parameters. Docket: EPA-HQ-QPPT-2019-0500] for the full product list utilized.	

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Consumer
Category

Product

Sub-
Categories

Form
(No. of
Pdts)1

Range

of
Weight
Fraction

(%
TCE)2

Weight Fractions
Selected for
Modeling
(% TCE)

Min2

Mid

Max

Selected
Westat
Survey
Scenario

Duration of Use



(min)



10th

50th

95th

%ile3

%ile

%ile

Range

of
Product
Density

(g/cm3)4

Mass [Volume] of
Product Used
(g, [oz])

10th
%ile

50th
%ile

95th
%ile

2	Weight fractions were primarily sourced from product Safety Data Sheets (SDSs) or Material Safety Data Sheets (MSDSs), unless otherwise noted. Please
see Supplemental File [Consumer Exposure Assessment Model Input Parameters. Docket: EPA-HQ-OPPT-2019-0500] for more detailed information on
weight fraction sourcing and ranges. If a single weight fraction was used in modeling, it appears in the "Min" weight fraction column, but does not reflect a
minimum.

3	Low-end (10th percentile) durations reported by Westat that are less than 0.5 min (30 sec) are modeled as being equal to 0.5 min (smallest time-step modeled).

4	Product density ranges reflect identified products containing TCE and were sourced from product SDSs or MSDSs. The high end of the range identified was
used to convert reported ounces of product used from Westat (1987) to grams of product used, as required for model input.

5	Two Westat product categories were considered for use (engine degreasing and solvent-type cleaning fluids or degreasers); however, engine degreasing was
selected to source duration of use, room of use, and amount used parameters due to the high percentage of respondents (78.9%) reporting aerosol use.

6	No weight fraction was reasonably available for the aerosol and liquid gun scrubber formulations, so the weight fractions were based on the ranges reflected
by the aerosol and liquid degreasing products.

7	The solvent-type cleaning fluids or degreasers product category from Westat was used as a surrogate for gun scrubbers for the selection of use durations.
Product-specific literature was identified and applied for mass of product used.

8	Based on EPA/EPAB research and the Eezox Premium Gun Care testing results (ASTM B117-5 Salt Spray Fog Test), 0.42-0.45 mL of the product was used
to coat the firearm in a very thin film, which is in-line with use directions.

9	Three modeling scenarios (film cleaner, spray fixative/coating, and toner aid) had no directly-aligned Westat product categories. Therefore, a number of
Westat product categories and use pattern data were considered for appropriateness, with a focus on primary formulation type (aerosol or liquid), duration of
use, and amount used. The rust remover product category reflects 98% aerosol products and a lower use duration and amount used than many of the other
solvent degreasing-type uses.

111 Weight fraction and density were not reasonably available, so were based on the ranges reflected by the spray fixative/coating and aerosol shoe polish
products.

11 There were no reasonably available data sources for aerosol hoof polish use patterns; the Westat spray shoe polish product category was used for selection of
use duration and amount used.

12Based on EPA/EPAB research that found one spray from the most common civilian canister is estimated to be approximately 0.0216-0.108 ounces (based on
a pepper spray manufacturer's website). Spraying occurred between 3 and 5 seconds (converted to minutes for use in modeling) before obtaining desired effect
(Bertilsson et al.. 2017).	

2057

2058

2059

2060

2061

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Table 2-30. Consumer Product Modeling Scenarios and Additional Scenario-Specific Input Parameters

Consumer Category

Product Sub-
Categories

Form
(No. of
Pdts)1

Zone 1
Room of Use
(Volume m3)2

CEM
Emission
Model
Applied3

Air Exchange
Rate
(hr1)

Interzonal
Ventilation
Rate
(m3/hr)

CEM
Dermal
Exposure

Model
Applied4

Dermal
Surface Area
Exposed5

Solvents for Cleaning
and Degreasing

Brake & Parts
Cleaner

Aerosol (4)

Garage
(90)

E3

0.45

109

P_DER2b

10% of hands

Electronic Degreaser/
Cleaner

Aerosol (9)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Electronic
Degreaser/Cleaner

Liquid (1)

Utility
(20) '

El

0.45

107

P_DER2b

Inside of one
hand

Spray

Degreaser/Cleaner

Aerosol (8)

Garage
(90)

E3

0.45

109

P_DER2b

10% of hands

Liquid

Degreaser/Cleaner

Liquid (2)

Utility
(20) '

El

0.45

107

P_DER2b

Inside of one
hand

Gun Scrubber

Aerosol (2)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Gun Scrubber

Liquid (1)

Utility
(20) '

El

0.45

107

P_DER2b

Inside of one
hand

Mold Release

Aerosol (2)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Tire Cleaner

Aerosol (2)

Garage
(90)

E3

0.45

109

P_DER2b

10% of hands

Tire Cleaner

Liquid (1)

Garage
(90)

El

0.45

109

P_DER2b

Inside of one
hand

Lubricants and
Greases

Tap & Die Fluid

Aerosol (1)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Penetrating Lubricant

Aerosol (5)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Adhesives and
Sealants

Solvent-based
Adhesive & Sealant

Liquid (3)

Utility
(20) '

El

0.45

107

NA

Inside of one
hand

Mirror-edge Sealant

Aerosol (1)

Bathroom
(15)

E3

0.45

107

NA

10% of hands

Tire Repair Cement/
Sealer

Liquid (5)

Garage
(90)

El

0.45

109

NA

Inside of one
hand



Carpet Cleaner

Liquid (1)

Bedroom

(36)

El

0.45

107

P_DER2b

Inside of one
hand

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Consumer Category

Product Sub-
Categories

Form
(No. of
Pdts)1

Zone 1
Room of Use
(Volume m3)2

CEM
Emission
Model
Applied3

Air Exchange
Rate
(hr1)

Interzonal
Ventilation
Rate
(m3/hr)

CEM
Dermal
Exposure

Model
Applied4

Dermal
Surface Area
Exposed5

Cleaning and
Furniture Care
Products

Spot Remover

Aerosol (1)

Utility
(20) '

E3

0.45

107

P_DER2b

10% of hands

Spot Remover

Liquid (4)

Utility
(20) '

El

0.45

107

P_DER2b

Inside of one
hand

Arts, Crafts, and
Hobby Materials

Fixatives & Finishing
Spray Coatings

Aerosol (1)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Apparel and
Footwear care
products

Shoe Polish

Aerosol (1)

Utility
(20) '

E3

0.45

107

NA

Inside of one
hand

Other Consumer Uses

Fabric Spray

Aerosol (1)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Film Cleaner

Aerosol (2)

Utility
(20) '

E3

0.45

107

NA

10% of hands

Hoof Polish

Aerosol (1)

Barn6

E3

46

109

NA

10% of hands

Pepper Spray

Aerosol (2)

Outside7

E3

1007

0

NA

10% of hands

Toner Aid

Aerosol (1)

Utility
(20) '

E3

0.45

107

NA

10% of hands

'The number of products identified is based on the product lists in EPA's 2017 Market and Use Report and Preliminary Information on Manufacturing, Processing,
Distribution. Use and Disposal: TCE (U.S. EPA. 2017c. h). as well as the 2014 TSCA Work Plan Chemical Risk Assessment for TCE (U.S. EPA 2014b). It is possible
that specific products and/or formulations identified in those reports and used herein to select appropriate weight fractions, formulation types, and formulation densities
for use in modeling no longer contain TCE or are no longer reasonably available to consumers for purchase; however, they were still considered for sourcing such
information since they were identified as in these recent EPA publications and therefore represent reasonably-foreseen uses. Please see Supplemental File for the full
product list utilized.

2 The use enviromnent (room of use) was generally based on the Westat (1987) survey of consumer behavior patterns, w hich rcoortcd the percentages for the location
of last use of product. In cases where the room was identified as "other inside room," the utility room was selected based on professional judgment. Additionally,
professional judgment was applied to certain uses, such as those that could reasonably be used in a garage setting.

3Emission models used for TCE include El - Emission from Product Applied to a Surface Indoors Incremental Source Model and E3 - Emission from Product Sprayed.
4A11 scenarios utilized the P_DER2b model for dermal exposure - Dermal Dose from Product Applied to Skin, Permeability Model

5Surface area exposed only applied in dermal scenarios. The indicated surface areas are combined with mean receptor body weights to get surface area to body weight
ratios (SA:BW) that are used in estimating dermal dose.

6For the purposed of modeling typical aerosol hoof polish consumer exposure, a barn setting was approximated by selecting the garage as the room of use and changing
the default air exchange rate from 0.45 to 4 hr1. which more closelv aliens with recommended ventilation levels in a horse barn (Pennsylvania State University. 2016)
7The outdoor enviromnent was approximated by selecting the garage as the room of use and increasing the air exchange rate from 0.45 to 100. The "room of use" was
also edited to reflect a 16 m3 cloud around user (roughly 6.5-foot dome or cloud surrounding user).

2063

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The 2014 TCE TSCA Work Plan Chemical Risk Assessment included two consumer conditions of use:
aerosol degreaser and clear protective coating spray (referred to as "spray fixative" 80 FR 47441) (U.S.

14b). The inputs included in the 2014 assessment differed from those used in this assessment for
similar conditions of use, either due to updated parameter data (e.g., Zone 2 volume), or professional
judgment. The most notable difference between the 2014 scenarios related to the single mass used
parameter selected. In the 2014 assessment, aerosol degreaser was modeled assuming 24 g (0.85 oz) and
clear protecting coating spray was modeled assuming 1 lg (0.39 oz). These inputs were not based on user
survey data and were described in the 2014 assessment as "potentially on the low end" when compared
against the Westat survey data employed in this 2019 risk evaluation.

2.3.2.6 Consumer Exposure Results

Acute inhalation and dermal exposure results are presented below for each consumer condition of use.
Dermal exposure results are only presented for those scenarios deemed to have the potential for dermal
contact with impeded evaporation per the scope presented in the May 2018 Problem Formulation (U.S.

18d). These conditions of use are organized by product subcategories and are also referred to
herein as consumer modeling scenarios. Inhalation estimates are presented in terms of acute indoor air
concentrations (ppm) resulting from a single consumer use event within a one-day exposure period; they
are provided for users and bystanders. Acute dermal exposure estimates are presented as an acute dose
(mg/kg/day); they are provided for users only.

2.3.2.6.1 Characterization of Exposure Results

As described in Section 2.3.2.4.1, the consumer exposure modeling approach was deterministic, but a
range of exposure results were estimated based on varying three parameters: weight fraction, mass of
product used, and duration of use/exposure duration. While the exposure results are not reflective of a
probabilistic distribution of all possible exposure levels, the exposure scenarios modeled incorporated
low-end (10th percentile), central tendency (50th percentile), and high-end (95th percentile) inputs from
Westat (1987) for two of the three varied parameters: mass of product used and exposure duration. Since
these inputs primarily reflect user characterization, results are presented for "high-intensity users,"
"moderate-intensity users," and "low-intensity users." For example, the exposure scenario combining
high-end inputs for these three parameters is referred to as a "high-intensity user" scenario. Weight
fraction inputs cannot be described in the same terms, as they reflect the range of actual product weight
fractions, per associated SDSs, and do not reflect a distribution of user survey data.

Other modeling parameters that were not varied (e.g., room volume, air exchange rate, building volume)
reflect central tendency inputs. Therefore, these exposure scenarios and results are not bounding or
"worst-case" and may not capture the maximum or minimum of all possible exposure levels.

For TCE, 3- and 24-hr TWA air concentrations are provided for consumers and bystanders. These are
based on the relevant human health hazard metrics. The 3-hr TWA air concentrations are higher than the
24-hr air concentrations in all scenarios due to the shorter averaging time surrounding the use event.
Likewise, the air concentrations associated with the user are higher than those associated with the
bystander in all scenarios due to the higher concentration of chemical expected in the room of use (Zone
1) coupled with the greater amount of time a consumer is assumed to be in the room of use (during and
after use event) compared with the bystander. While it is assumed that a bystander of any age, including
pregnant women and children, could be exposed to the reported concentrations, the concentrations
themselves are not unique for specific subpopulations. The concentrations reported reflect the
concentration a consumer or bystander would be exposed to.

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Dermal exposure scenarios and results are presented for children and adult age groups, with the children
(age 11-15) resulting in the highest estimates dermal exposures due to differences in surface area to
body weight ratios in these groups. Results are not presented specifically for pregnant women or women
of reproductive age; however, the range of results presented for adults and children age groups are
expected to cover dermal exposures for pregnant women as well, with the children (11-15) providing the
highest surface area to body weight ratio, thereby providing the highest dermal exposure estimate (see
below table for rationale). All values below in Table 2-31 are sourced and/or derived from EPA's 2011
Exposure Factors Handbook (I v «« \

Table 2-31. Surface Area and Body Weight Values for Different Consumer and Bystander

Parameter

Adult

Children
(16-21)

Children
(11-15)

Pregnant
Women

Women
(21+)

Women
(16-21)

10% of Hands
Surface Area
(cm2)

99

83

72

891

891

832

Body Weight
(kg)

80

71.6

56.8

753

744

65.9s

SA:BW

1.24

1.16

1.27

1.19

1.20

1.26

1 Surface area based on women 21+

2Surface area based on combined male/female 16-21

3Body weight for all pregnant women

4Body weight for females 21+

5Body weight for females 16-21

2.3.2,6,2 Consumer Exposure Estimates
Solvents for Cleaning and Degreasing
Brake & Parts Cleaner

Exposure to TCE in brake & parts cleaner products was evaluated based on four aerosol products with
weight fractions ranging from 0-20% to 90-100% TCE.

Westat Survey data on brake quieters and cleaners were used as the basis for duration of use and mass of
product used. Survey responses indicate that 2.6% of respondents have used products in this category;
65.6% reported use of aerosol formulations. The room of use (Zone 1) was set to the garage (90 m3)
although the Westat survey data for this category indicate primarily outdoor use.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500\ for the full range of results based on all
iterations of this modeling scenario.

Table 2-32. Acute Inhalation Exposure Summary: Brake & Parts Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

3.97E+02

5.76E+01

(120)

(100)

(766.5)

Bystander

1.00E+02

1.67E+01

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Scenario Description

Duration of

Use
(min)

Weight
Fraction1

(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

Moderate-Intensity User

50th %ile

Mid

50th %ile

User

6.60E+01

9.06

(15)

(60)

(191.6)

Bystander

1.48E+01

2.26

Low-Intensity User

10th %ile

Min

10th %ile

User

5.16

7.09E-01

(1)

(20)

(47.9)

Bystander

1.19

1.81E-01

Actual product weight fractions were: 0-20%; 45-55%; 97.5%; 90-100%. 60% is a mathematically-derived mid-point (i.e.,
mean) for use in modeling, based on the minimum and maximum inputs.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-33. Acute Derma

Exposure Summary: Brake &

'arts Cleaner

Scenario
Description

Duration

of Use
(min)

Weight
Fraction1

(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(120)

Max
(100)

Adult (>21 years)

7.63E+01

Children (16-20 years)

7.14E+01

Children (11-15 years)

7.80E+01

Central
Tendency

50th %ile
(15)

Mid

(60)

Adult (>21 years)

5.72

Children (16-20 years)

5.35

Children (11-15 years)

5.85

Low-Intensity
User

10th %ile
(1)

Min

(20)

Adult (>21 years)

1.27E-01

Children (16-20 years)

1.19E-01

Children (11-15 years)

1.30E-01

1 Actual product weight fractions were: 0-20%; 45-55%; 97.5%; 90-100%. 60% is a mathematically-derived mid-point (i.e.,
mean) for use in modeling, based on the minimum and maximum inputs.

Aerosol Electronic Degreaser/Cleaner

Exposure to TCE in aerosol electronic degreasing/cleaning products was evaluated based on nine
aerosol products with weight fractions ranging from 30-100% TCE.

Westat Survey data on specialized electronics cleaners were used as the basis for duration of use and
mass of product used. Survey responses indicate 13.1% of respondents have used products in this
category; 34% reported use of aerosol formulations and 56% reported use of liquid formulations.
Therefore, these Westat data were applied to both aerosol and liquid product scenarios. The room of use
(Zone 1) was set to the utility room (20 m3) although the Westat survey data for this category indicate
living room and other inside room as the top two locations of reported use.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HO-OPPT-2019-0500\ for the full range of results based
on all iterations of this modeling scenario.

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Table 2-34. Acute Inhalation Exposure Summary: Aerosol E ectronic Degreaser/Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

2.81E+02

3.76E+01

(30)

(100)

(337.1)

Bystander

5.03E+01

7.56

Moderate-Intensity User

50th %ile

Mid

50th %ile

User

1.19E+01

1.58

(2)

(65)

(22.5)

Bystander

1.96

2.95E-01

Low-Intensity User

10th %ile

Min

10th %ile

User

4.15E-01

5.55E-02

(0.5)2

(30)

(1.8)

Bystander

7.21E-02

1.08E-02

Actual product weight fractions were: 30-50%; 30-60%; 97.2%; 98%; 60-100%; and 90-100%. 65% is a mathematically -
derived mid-point (i.e., mean) for use in modeling, based on the minimum and maximum inputs.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Liquid Electronic Degreaser/Cleaner

Exposure to TCE in liquid electronic degreasing/cleaning products was evaluated based on one liquid
product with a weight fraction of 100% TCE.

Westat Survey data on specialized electronics cleaners were used as the basis for duration of use and
mass of product used. Survey responses indicate 13.1% of respondents have used products in this
category; 34% reported use of aerosol formulations and 56% reported use of liquid formulations.
Therefore, these Westat data were applied to both aerosol and liquid product scenarios. The room of use
(Zone 1) was set to the utility room (20 m3) although the Westat survey data for this category indicate
living room and other inside room as the top two locations of reported use.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500\ for the full range of results based on all
iterations of this modeling scenario.

Table 2-35. Acute Inhalation Exposure Summary: Liquid Electronic Degreaser/Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(30)

(100)

95th %ile
(337.1)

User

2.70E+02

3.61E+01

Bystander

4.83E+01

7.26

Moderate-Intensity User

50th %ile
(2)

(100)

50th %ile
(22.5)

User

1.75E+01

2.33

Bystander

2.90

4.36E-01

Low-Intensity User

10th %ile
(0.5)2

(100)

10th %ile
(1.8)

User

1.30

1.74E-01

Bystander

2.27E-01

3.41E-02

1 Single weight fraction of 100% available.

2The 10th percentile duration from Westat was <0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

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Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-36. Acute Dermal Exposure Summary: Liquid Electronic Degreaser/Cleaner

Scenario
Description

Duration

of Use
(min)

Weight
Fraction1

(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(30)

(100)

Adult (>21 years)

4.30E+01

Children (16-20 years)

4.03E+01

Children (11-15 years)

4.39E+01

Moderate-
Intensity User

50th %ile
(2)

(100)

Adult (>21 years)

2.88

Children (16-20 years)

2.68

Children (11-15 years)

2.92

Low-Intensity
User

10th %ile
(0-5)2

(100)

Adult (>21 years)

7.15E-01

Children (16-20 years)

6.70E-01

Children (11-15 years)

7.31E-01

1	Single weight fraction of 100% available.

2	The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the
model, as it reflects the smallest timestep in the model run.

Aerosol Spray Degreaser/Cleaner

Exposure to TCE in aerosol spray degreaser/cleaner products was evaluated based on eight aerosol
products with weight fractions ranging from 60-100% TCE.

Westat Survey data on engine degreasing were used as the basis for duration of use and mass of product
used. Survey responses indicate that 17.2% of respondents have used products in this category; 78.9%
reported use of aerosol formulations. The room of use (Zone 1) was set to the garage (90 m3) although
the Westat survey data for this category indicate primarily outdoor use.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HO-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-37. Acute Inhalation Exposure Summary: Aerosol Spray Degreaser/Cleaner



Duration of

Weight

Mass Used
(g)

Product

3-hr Max

24-hr Max

Scenario Description

Use

Fraction1

User or

TWA

TWA



(min)

(%)

Bystander

(ppm)

(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

1.12E+03

1.62E+02

(120)

(100)

(2157.4)

Bystander

2.82E+02

4.71E+01

Moderate-Intensity User

50th %ile

Max

50th %ile

User

2.99E+02

4.11E+01

(15)

(100)

(521.4)

Bystander

6.70E+01

1.02E+01

Low-Intensity User

10th %ile

Min

10th %ile

User

4.54E+01

6.20

(5)

(60)

(130.8)

Bystander

9.83

1.50

Actual product weight fractions were: 60-100% and 90-100%.

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This condition of use was also assessed in the 2014 TSCA Work Plan Chemical Risk Assessment and
refined in the 2016 Supplemental Exposure and Risk Reduction Technical Report in Support of Risk
management Options for TCE (TCE) Use in Consumer Aerosol Degreasing. In these prior assessments,
different inputs were used for certain modeling parameters including mass used and duration of use.
Please see the referenced documents for full details. The amount used (24 g TCE - roughly 27 g
product) in the 2014 assessment is much lower than the 10th percentile input obtained from the Westat
survey engine degreasing scenario. The lower amount applied in 2014 more closely reflects an aerosol
electronic cleaning condition of use, which is characterized by a median mass used of 0.5 oz, or 22.5 g.
It is therefore unlikely that the previous assessment captured exposures for consumer involved in larger
degreasing efforts such as engine degreasing or brake cleaning.The inputs and associated 24-hr acute air
concentrations for users and bystanders from the 2014 assessment are shown below.

2014 Acute Inhalation Exposure Summary: Aerosol Spray Degreaser/Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction
(%)

Mass Used
(g)

Product
User or
Bystander

24-hr
TWA
(ppm)

2014 Work Plan
Chemical Risk
Assessment

60

90

(24)1

User

2.92

Bystander

0.8

'Note that this conversion assumes a formulation density of 1. Actual product densities range from 1.46-1.52 g/cm3. This
input is also provided in terms of mass of TCE per use, rather than mass of product per use, which is the actual model input.
24 g of TCE in this 90% formulation would equate to roughly 27 g of product per use.

2This user air concentration was shown in the 2014 assessment as 2 ppm; however, in the 2016 supplemental report, it was
corrected to 2.9 ppm due to an earlier rounding error or typo.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-38. Acute Dermal Exposure Summary: Aerosol Spray Degreaser/Cleaner

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)



95th %ile
(120)

Max
(100)

Adult (>21 years)

7.16E+01

High-Intensity
User

Children (16-20 years)

6.70E+01

Children (11-15 years)

7.32E+01

Moderate-
Intensity User

50th %ile

Max

Adult (>21 years)

8.94

(15)

(100)

Children (16-20 years)

8.37





Children (11-15 years)

9.15

Low-Intensity
User

10th %ile
(5)

Min
(60)

Adult (>21 years)

1.79

Children (16-20 years)

1.67

Children (11-15 years)

1.83

1 Actual product weight fractions were: 60-100% and 90-100%.

Liquid Degreaser/Cleaner

Exposure to TCE in liquid degreasing/cleaning products was evaluated based on two aerosol products
with weight fractions ranging from 90-100% TCE.

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Westat Survey data on solvent-type cleaning fluids or degreasers were used as the basis for room of use,
duration of use, and mass of product used. Survey responses indicate that 28.1% of respondents have
used products in this category; 74.4% reported use of liquid formulations. The room of use (Zone 1) was
set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HO-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-39. Acute Inhalation Exposure Summary: Liquid Degreaser/Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1

(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(120)

(100)

95th %ile
(1337.7)

User

1.05E+03

1.46E+02

Bystander

2.28E+02

3.61E+01

Moderate-Intensity User

50th %ile
(15)

(100)

50th %ile
(139.9)

User

1.17E+02

1.56E+01

Bystander

1.97E+01

2.96

Low-Intensity User

10th %ile
(2)

(100)

10th %ile
(24.1)

User

1.95E+01

2.60

Bystander

3.24

4.86E-01

Actual product weight fractions were: 90-100% and 100%.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-40. Acute Dermal Exposure Summary: Liquid Degreaser/Cleaner

Scenario
Description

Duration

of Use
(min)

Weight
Fraction1

(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(120)

(100)

Adult (>21 years)

1.71E+02

Children (16-20 years)

1.60E+02

Children (11-15 years)

1.75E+02

Moderate-
Intensity User

50th %ile
(15)

(100)

Adult (>21 years)

2.14E+01

Children (16-20 years)

2.01E+01

Children (11-15 years)

2.19E+01

Low-Intensity
User

10th %ile
(2)

(100)

Adult (>21 years)

2.85

Children (16-20 years)

2.68

Children (11-15 years)

2.92

Actual product weight fractions were: 90-100% and 100%.

Aerosol Gun Scrubber

Exposure to TCE in aerosol gun scrubber/cleaner products was evaluated based on two aerosol products.
Only one product had a reported weight fraction (97%), so modeling was based on the full range of
aerosol degreasing formulation weight fractions (60-100%).

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Westat Survey data on solvent-type cleaning fluids or degreasers were used as the basis for room of use
and duration, while manufacturer data on the amount of product required to coat a firearm in a very thin
film were used as the basis for the mass of product used. The Westat survey product category selected
was not aligned well with this specific use, but the duration data for the selected category was deemed
reasonable for use in modeling. The room of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HO-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-41. Acute Inhalation Exposure Summary: Aerosol Gun Scrubber

Scenario Description

Duration of

Use
(min)

Weight
Fraction1

(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

(0.7)

User

5.35E-01

7.44E-02

(120)

(100)

Bystander

1.16E-01

1.83E-02

Moderate-Intensity User

50th %ile

Max

(0.7)

User

5.87E-01

7.83E-02

(15)

(100)

Bystander

9.87E-02

1.48E-02

Low-Intensity User

10th %ile

Min

(0.7)

User

3.41E-01

4.55E-02

(2)

(60)

Bystander

5.64E-02

8.47E-03

'Only one product had a reported weight fraction (97%), so modeling was based on the full range of aerosol degreasing
formulation weight fractions (60-100%).

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-42. Acute Dermal Exposure Summary: Aerosol Gun Scrubber

Scenario
Description

Duration

of Use
(min)

Weight
Fraction

(%)

Receptor

Acute ADR

(mg/kg/day)



95th %ile
(120)

Max
(100)

Adult (>21 years)

6.90E+01

High-Intensity
User

Children (16-20 years)

6.45E+01

Children (11-15 years)

7.06E+01

Moderate-
Intensity User

50th %ile
(15)

Max

Adult (>21 years)

8.62

(100)

Children (16-20 years)

8.07



Children (11-15 years)

8.82

Low-Intensity
User

10th %ile
(2)

Min

(60)

Adult (>21 years)

6.90E-01

Children (16-20 years)

6.48E-01

Children (11-15 years)

7.08E-01

'Only one product had a reported weight fraction (97%), so modeling was based on the
full range of aerosol degreasing formulation weight fractions (60-100%).

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Liquid Gun Scrubber

Exposure to TCE in liquid gun scrubber/cleaner products was evaluated based on one liquid product
with an unreported weight fraction. Modeling was based on the upper-end of the narrow range of liquid
degreasing formulation weight fractions (90-100%).

Westat Survey data on solvent-type cleaning fluids or degreasers were used as the basis for room of use
and duration, while manufacturer data on the amount of product required to coat a firearm in a very thin
film were used as the basis for the mass of product used. The Westat survey product category selected
was not aligned well with this specific use, but the duration data for the selected category was deemed
reasonable for use in modeling. The room of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HO-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-43. Acute Inhalation Exposure Summary: Liquid Gun Scrubber

Scenario Description

Duration of

Use
(min)

Weight
Fraction1

(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(120)

(100)

(0.7)

User

4.58E-01

6.37E-02

Bystander

9.94E-02

1.57E-02

Moderate-Intensity User

50th %ile
(15)

(100)

(0.7)

User

5.03E-01

6.71E-02

Bystander

8.46E-02

1.27E-02

Low-Intensity User

10th %ile
(2)

(100)

(0.7)

User

4.65E-01

6.22E-02

Bystander

8.09E-02

1.22E-02

Modeling was based on the upper-end of the narrow range of liquid degreasing formulation weight fractions (90-100%).

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-44. Acute Dermal Exposure Summary: Liquid Gun Scrubber

Scenario
Description

Duration

of Use
(min)

Weight
Fraction1

(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(120)

(100)

Adult (>21 years)

1.60E+02

Children (16-20 years)

1.50E+02

Children (11-15 years)

1.63E+02

Moderate-
Intensity User

50th %ile
(15)

(100)

Adult (>21 years)

2.00E+01

Children (16-20 years)

1.87E+01

Children (11-15 years)

2.04E+01

Low-Intensity
User

10th %ile
(2)

(100)

Adult (>21 years)

2.68

Children (16-20 years)

2.50

Children (11-15 years)

2.72

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Modeling was based on the upper-end of the narrow range of liquid degreasing formulation weight fractions (90-100%).
Mold Release

Exposure to TCE in mold release products was evaluated based on two aerosol products with weight
fractions ranging from 40-68.9% TCE.

Westat Survey data on other lubricants (excluding automotive) were used as the basis for room of use,
duration of use, and mass of product used. For this product scenario, EPA believes that the selected
lubricant Westat scenario, although not a direct match with mold release products, better aligns with the
product use pattern when compared against other options, such as solvent-type cleaning fluid, which
conveys a much higher use duration and mass used. Survey responses indicate that 34.5% of
respondents have used products in this category; 32.5% reported use of aerosol formulations. The room
of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-45. Acute Inhalation Exposure Summary: Mold Release

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

1.22E+02

1.64E+01

(30)

(68.9)

(212.9)

Bystander

2.19E+01

3.29

Moderate-Intensity User

50th %ile

Max

50th %ile

User

1.31E+01

1.75

(2)

(68.9)

(23.4)

Bystander

2.16

3.25E-01

Low-Intensity User

10th %ile

Min

10th %ile

User

1.32

1.77E-01

(0.5)2

(40)

(4.3)

Bystander

2.30E-01

3.45E-02

Actual product weight fractions were: 40-50% and 68.9%.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Aerosol Tire Cleaner

Exposure to TCE in aerosol tire cleaning products was evaluated based on two aerosol products with
weight fractions ranging from 70-100% TCE.

Westat Survey data on tire and hubcap cleaners were used as the basis for duration of use and mass of
product used. Survey responses indicate that 15.9% of respondents have used products in this category;
29.5% reported use of aerosol formulations and 10.5% reported use of liquid formulations. Therefore,
these Westat data were applied to both aerosol and liquid product scenarios. The room of use (Zone 1)
was set to the garage (90 m3) although the Westat survey data for this category indicate primarily
outdoor use.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer

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Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-46. Acute Inhalation Exposure Summary: Aerosol Tire Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

1.04E+02

1.57E+01

(60)

(100)

(317)

Bystander

4.39E+01

6.84

Moderate-Intensity User

50th %ile

Max

50th %ile

User

3.04E+01

4.17

(15)

(100)

(52.9)

Bystander

6.80

1.04

Low-Intensity User

10th %ile

Min

10th %ile

User

4.25

5.81E-01

(5)

(70)

(10.5)

Bystander

9.21E-01

1.40E-01

Actual product weight fractions were: 70-90% and 80-100%.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-47. Acute Dermal Exposure Summary: Aerosol Tire Cleaner

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(60)

Max
(100)

Adult (>21 years)

1.58E+01

Children (16-20 years)

1.48E+01

Children (11-15 years)

1.61E+01

Moderate-
Intensity User

50th %ile
(15)

Max
(100)

Adult (>21 years)

3.94

Children (16-20 years)

3.69

Children (11-15 years)

4.03

Low-Intensity
User

10th %ile
(5)

Min
(70)

Adult (>21 years)

9.17E-01

Children (16-20 years)

8.61E-01

Children (11-15 years)

9.38E-01

Actual product weight fractions were: 70-90% and 80-100%.

Liquid Tire Cleaner

Exposure to TCE in liquid tire cleaning products was evaluated based on one liquid product with a
weight fractions ranging of 80-100% TCE.

Westat Survey data on tire and hubcap cleaners were used as the basis for duration of use and mass of
product used. Survey responses indicate that 15.9% of respondents have used products in this category;
29.5% reported use of aerosol formulations and 10.5% reported use of liquid formulations. Therefore,
these Westat data were applied to both aerosol and liquid product scenarios. The room of use (Zone 1)
was set to the garage (90 m3) although the Westat survey data for this category indicate primarily
outdoor use.

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Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500\ for the full range of results based on all
iterations of this modeling scenario.

Table 2-48. Acute Inhalation Exposure Summary: Liquid Tire Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(100)

95th %ile
(706.4)

User

3.33E+02

4.76E+01

Bystander

9.79E+01

1.52E+01

Moderate-Intensity User

50th %ile
(15)

(100)

50th %ile
(117.9)

User

6.77E+01

9.28

Bystander

1.52E+01

2.32

Low-Intensity User

10th %ile
(5)

(100)

10th %ile
(23.4)

User

1.35E+01

1.85

Bystander

2.93

4.47E-01

1 Single weight fraction of 80-100% available.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-49. Acute Dermal Exposure Summary: Liquid Tire Cleaner

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(60)

(100)

Adult (>21 years)

8.78E+01

Children (16-20 years)

8.23E+01

Children (11-15 years)

8.99E+01

Moderate-
Intensity User

50th %ile
(15)

(100)

Adult (>21 years)

2.20E+01

Children (16-20 years)

2.06E+01

Children (11-15 years)

2.24E+01

Low-Intensity
User

10th %ile
(5)

(100)

Adult (>21 years)

7.33

Children (16-20 years)

6.85

Children (11-15 years)

7.49

1 Single weight fraction of 80-100% available.

Lubricants and Greases
Tap & Die Fluid

Exposure to TCE in tap & die fluid was evaluated based on one aerosol product with a weight fraction
of 98% TCE.

Westat Survey data on other lubricants (excluding automotive) were used to select room of use, duration
of use, and mass of product used. Survey responses indicated that 34.5% of respondents have used

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products in this category; 32.5% reported use of aerosol formulations. The room of use (Zone 1) was set
to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-50. Acute Inhalation Exposure Summary: Tap & Die Fluid

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(30)

(98)

95th %ile
(134.5)

User

1.10E+02

1.47E+01

Bystander

1.97E+01

2.95

Moderate-Intensity User

50th %ile
(2)

(98)

50th %ile
(14.8)

User

1.18E+01

1.57

Bystander

1.95

2.93E-01

Low-Intensity User

10th %ile
(0.5)2

(98)

10th %ile
(2.7)

User

2.03

2.78E-01

Bystander

4.96E-01

8.53E-02

1 Single weight fraction of 98% available.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Penetrating Lubricant

Exposure to TCE in lubricant products was evaluated based on five aerosol products with weight
fractions ranging from 5-50 % TCE.

Westat Survey data on other lubricants (excluding automotive) were used as the basis for room of use,
duration of use, and mass of product used. Survey responses indicate that 34.5% of respondents have
used products in this category; 32.5% reported use of aerosol formulations. The room of use (Zone 1)
was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-51. Acute Inhalation Exposure Summary: Penetrating Lubricant

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

8.74E+01

1.17E+01

(30)

(50)

(209.9)

Bystander

1.56E+01

2.35

Moderate-Intensity User

50th %ile

Mid

50th %ile

User

5.16

6.88E-01

(2)

(27.5)

(23.1)

Bystander

8.53E-01

1.28E-01

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Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

Low-Intensity User

10th %ile

Min

10th %ile

User

1.62E-01

2.16E-02

(0.5)2

(5)

(4.2)

Bystander

2.80E-02

4.21E-03

Actual product weight fractions were: 5-10%; 10-20%; 30-40%; 48.8%; and 30-50%. 27.5% is a mathematically-derived
mid-point (i.e., mean) for use in modeling, based on the minimum and maximum inputs.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Adhesives and Sealants

Solvent-based Adhesive & Sealant

Exposure to TCE in solvent-based adhesive & sealant products was evaluated based on three liquid
products with weight fractions ranging from 5->90% TCE.

Westat Survey data on contact cement, superglue, and spray adhesive were used as the basis for room of
use, duration of use, and mass of product used. Survey responses indicate that 60.6% of respondents
have used products in this category; 97.1% reported use of liquid formulations. The room of use (Zone
1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-52. Acute Inhalation Exposure Summary: Solvent-based Adhesive & Sealant



Duration of

Weight

Mass Used
(g)

Product

3-hr Max

24-hr Max

Scenario Description

Use

Fraction1

User or

TWA

TWA



(min)

(%)

Bystander

(ppm)

(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

2.46E+02

3.22E+01

(60)

(90)

(185.2)

Bystander

2.68E+01

4.06

Moderate-Intensity User

50th %ile

Mid

50th %ile

User

7.76

1.00

(4.25)

(47.5)

(10.7)

Bystander

6.86E-01

1.03E-01

Low-Intensity User

10th %ile

Min

10th %ile

User

6.72E-02

8.83E-03

(0.5)2

(5)

(1.3)

Bystander

8.68E-03

1.30E-03

1 Actual product weight fractions were: 5-15%; 40-60; and >90%. 47.5% is a mathematically-derived mid-point (i.e., mean)
for use in modeling, based on the minimum and maximum inputs.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Mirror-edge Sealant

Exposure to TCE in mirror-edge sealant products was evaluated based on one aerosol product with a
weight fraction of 20-40% TCE.

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Westat Survey data on contact cement, superglue, and spray adhesive were used as the basis for duration
of use and mass of product used. While there was no Westat scenario that directly aligned with use as a
mirror-edge sealant, the selected category is believed to be the best fit based on the associated range of
use duration and mass used. Survey responses indicate that 60.6% of respondents have used products in
this category; 97.1% reported use of liquid formulations. While the formulation type used by the
majority of respondents for this category does not reflect the modeled use, which is an aerosol, it
represents the best fit category available. The room of use (Zone 1) was set to the bathroom (15 m3)
based on the product's apparent use on mirror edging.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-53. Acute Inhalation Exposure Summary: Mirror-Edge Sealant

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(40)

95th %ile
(78.4)

User

2.45E+01

3.33

Bystander

5.21

7.84E-01

Moderate-Intensity User

50th %ile
(4.25)

(40)

50th %ile
(4.5)

User

8.31

1.11

Bystander

1.34

2.01E-01

Low-Intensity User

10th %ile
(0.5)2

(40)

10th %ile
(0.5)

User

1.68E-01

2.24E-02

Bystander

2.71E-02

4.07E-03

1 Single weight fraction of 20-40% available.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Tire Repair Cement/Sealer

Exposure to TCE in tire repair products was evaluated based on five liquid products with weight
fractions ranging from 65-95% TCE.

Westat Survey data on contact cement, superglue, and spray adhesive were used as the basis for duration
of use and mass of product used. Survey responses indicate that 60.6% of respondents have used
products in this category; 97.1% reported use of liquid formulations. The room of use (Zone 1) was set
to the garage (90 m3) based on the product's apparent use on tires.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

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Table 2-54. Acute Inhalation Exposure Summary: Tire Repair cement/Sealer



Duration of

Weight

Mass Used
(g)

Product

3-hr Max

24-hr Max

Scenario Description

Use

Fraction1

User or

TWA

TWA



(min)

(%)

Bystander

(ppm)

(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

8.30E+01

1.18E+01

(60)

(95)

(185.2)

Bystander

2.44E+01

3.80

Moderate-Intensity User

50th %ile

Mid

50th %ile

User

4.85

6.64E-01

(4.25)

(80)

(10.7)

Bystander

1.07

1.63E-01

Low-Intensity User

10th %ile

Min

10th %ile

User

4.32E-01

5.97E-02

(0.5)2

(65)

(1.3)

Bystander

1.05E-01

1.59E-02

Actual product weight fractions were: 65-80%; 70-85%; 75-90%; and 80-95%. 80% is a mathematically-derived mid-point
(i.e., mean) for use in modeling, based on the minimum and maximum inputs.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Cleaning and Furniture Care Products

Carpet Cleaner

Exposure to TCE in carpet cleaner was evaluated based on a single liquid formulation with a weight
fraction of >99% TCE.

Westat Survey data on spot removers were used to select the duration of use and mass of product used.
Survey responses indicate that 39.1% of respondents have used products in this category; 43.9%
reported use of a liquid formulation. The room of use (Zone 1) was set to the bedroom (36 m3) based on
professional judgement. There are no data in the Westat Survey exactly matching a use as a carpet
cleaner; therefore, data reflecting spot cleaners were applied.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500\ for the full range of results based on all
iterations of this modeling scenario.

Table 2-55. Acute Inhalation Exposure Summary: Carpet Cleaner



Duration of

Weight

Mass Used
(g)

Product

3-hr Max

24-hr Max

Scenario Description

Use

Fraction1

User or

TWA

TWA



(min)

(%)

Bystander

(ppm)

(ppm)

High-Intensity User

95th %ile

(99)

95th %ile

User

3.90E+02

5.26E+01

(30)

(526.6)

Bystander

7.65E+01

1.15E+01

Moderate-Intensity User

50th %ile

(99)

50th %ile

User

4.75E+01

6.36

(5)

(62.9)

Bystander

8.39

1.26

Low-Intensity User

10th %ile

(99)

10th %ile

User

8.14

1.10

(0.5)2

(11.8)

Bystander

1.55

2.33E-01

1 Single weight fraction of >99% available.

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2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-56. Acute Dermal Exposure Summary: Carpet Cleaner

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(30)

(99)

Adult (>21 years)

4.65E+01

Children (16-20 years)

4.36E+01

Children (11-15 years)

4.77E+01

Central-
Tendency

50th %ile
(5)

(99)

Adult (>21 years)

7.77

Children (16-20 years)

7.28

Children (11-15 years)

7.93

Low-Intensity
User

10th %ile
(0.5)2

(99)

Adult (>21 years)

3.89E-01

Children (16-20 years)

3.64E-01

Children (11-15 years)

3.98E-01

1	Single weight fraction of >99% available.

2	The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the
model, as it reflects the smallest timestep in the model run.

Aerosol Spot Remover

Exposure to TCE in aerosol spot remover products was evaluated based on one aerosol product with a
weight fraction of 20-30% TCE.

Westat Survey data on spot removers were used as the basis for room of use, duration of use, and mass
of product used. Survey responses indicate that 39.1% of respondents have used products in this
category; 43.9% reported use of a liquid formulation and 56.1% reported use of an aerosol formulation.
Therefore, these Westat data were applied to both aerosol and liquid product scenarios. The room of use
(Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-57. Acute Inhalation Exposure Summary: Aerosol Spot Remover

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product
User or
Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(30)

(30)

95th %ile
(514.1)

User

2.50E+02

3.24E+01

Bystander

2.28E+01

3.43

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Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product
User or
Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

Moderate-Intensity User

50th %ile
(5)

(30)

50th %ile
(61.4)

User

2.93E+01

3.78

Bystander

2.49

3.75E-01

Low-Intensity User

10th %ile
(0.5)2

(30)

10th %ile
(11.15)

User

4.34

5.65E-01

Bystander

4.59E-01

6.90E-02

1 Single weight fraction of 20-30% available.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-58. Acute Derma

Exposure Summary: Aerosol S

pot Remover

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(30)

(30)

Adult (>21 years)

5.52

Children (16-20 years)

5.16

Children (11-15 years)

5.64

Moderate-
Intensity User

50th %ile
(5)

(30)

Adult (>21 years)

9.18E-01

Children (16-20 years)

8.61E-01

Children (11-15 years)

9.42E-01

Low-Intensity
User

10th %ile
(0.5)2

(30)

Adult (>21 years)

9.18E-02

Children (16-20 years)

8.61E-02

Children (11-15 years)

9.42E-02

1	Single weight fraction of 20-30% available.

2	The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the
model, as it reflects the smallest timestep in the model run.

Liquid Spot Remover

Exposure to TCE in liquid spot remover products was evaluated based on four liquid products with
weight fractions ranging from 50-75%.

Westat Survey data on spot removers were used as the basis for room of use, duration of use, and mass
of product used. Survey responses indicate that 39.1% of respondents have used products in this
category; 43.9% reported use of a liquid formulation and 56.1% reported use of an aerosol formulation.
Therefore, these Westat data were applied to both aerosol and liquid product scenarios. The room of use
(Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

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Table 2-59. Acute Inhalation Exposure Summary: Liquid Spot Remover



Duration of

Weight

Mass Used
(g)

Product

3-hr Max

24-hr Max

Scenario Description

Use

Fraction1

User or

TWA

TWA



(min)

(%)

Bystander

(ppm)

(ppm)

High-Intensity User

95th %ile

Max

95th %ile

User

2.98E+02

3.99E+01

(30)

(75)

(477.2)

Bystander

5.34E+01

8.02

Moderate-Intensity User

50th %ile

Max

50th %ile

User

3.55E+01

4.73

(5)

(75)

(57)

Bystander

5.80

8.72E-01

Low-Intensity User

10th %ile

Min

10th %ile

User

4.09

5.47E-01

(0.5)2

(50)

(10.7)

Bystander

7.14E-01

1.07E-01

Actual product weight fractions were: <50%; <75%; and >75%.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-60. Acute Dermal Exposure Summary: Liquid Spot Remover

Scenario
Description

Duration
of Use
(min)

Weight
Fraction
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(30)

Max
(75)

Adult (>21 years)

3.21E+01

Children (16-20 years)

3.00E+01

Children (11-15 years)

3.28E+01

Moderate-
Intensity User

50th %ile
(5)

Max
(75)

Adult (>21 years)

5.33

Children (16-20 years)

4.99

Children (11-15 years)

5.45

Low-Intensity
User

10th %ile
(0.5)2

Min
(50)

Adult (>21 years)

3.55E-01

Children (16-20 years)

3.33E-01

Children (11-15 years)

3.63E-01

1	Actual product weight fractions were: <50%; <75%; and >75%.

2	The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the
model, as it reflects the smallest timestep in the model run.

Arts, Crafts, and Hobby Materials

Fixatives & Finishing Spray Coating

Exposure to TCE in fixatives & finishing spray coating products was evaluated based on one aerosol
product with a weight fraction of 20-30% TCE.

Westat Survey data on aerosol rust removers were used as the basis for duration of use and mass of
product used. This Westat category was selected as a surrogate, as there were no well-aligned product
categories for this use. However, survey responses for the selected surrogate category reported 98.3%
use of aerosol formulations, which is supportive of its application to the modeled product scenario.
Duration of use and mass of product data were also reviewed for reasonableness and were considered

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more reasonable (i.e., lower) than the higher use patterns associated with most of the solvent degreasing
or cleaning categories. The room of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-61. Acute Inhalation Exposure Summary: Fixatives & Finishing Spray Coatings

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(30)

95th %ile
(306)

User

6.83E+01

9.31

Bystander

1.51E+01

2.28

Moderate-Intensity User

50th %ile
(5)

(30)

50th %ile
(45.2)

User

1.13E+01

1.50

Bystander

1.84

2.77E-01

Low-Intensity User

10th %ile
(0.5)2

(30)

10th %ile
(9.4)

User

2.17

2.90E-01

Bystander

3.76E-01

5.66E-02

1 Single product weight fraction of 20-30% available.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

This condition of use was also assessed in the 2014 TSCA. Work Plan Chemical Risk Assessment (U.S.
E 14b). In the prior assessment, different inputs were used for certain modeling parameters
including mass used and duration of use. The amount of TCE used (11 g - roughly 37 g of product) in
the 2014 assessment is roughly equivalent to the 50th percentile input obtained from the Westat survey
rust remover surrogate scenario applied in this latest evaluation. These inputs and associated 24-hr acute
air concentrations for users and bystandersare included below.

2014 Acute Inhalation Exposure Summary: Fixatives & Finis

Scenario Description

Duration of

Use
(min)

Weight
Fraction
(%)

Mass Used
(g)

Product
User or
Bystander

24-hr
TWA
(ppm)

2014 Chemical Work
Plan Risk Assessment

30

30

ll1

User

0.4

Bystander

0.1

ling Spray Coatings

'Note that this conversion assumes a formulation density of 1. Actual product densities range from 1.46-1.52 g/cm3.
This input is also provided in terms of mass of TCE per use, rather than mass of product per use, which is the actual
model input. 11 g of TCE in this 30% formulation would equate to roughly 37 g of product per use, which is similar to
the central tendency input used in the current evaluation.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Apparel and Footwear care Products
Shoe Polish

Exposure to TCE in shoe polish products was evaluated based on one aerosol product with a weight
fraction of 10-20% TCE.

Westat Survey data on spray shoe polish were used as the basis for room of use, duration of use, and
mass of product used. Survey responses indicate that 11.7% of respondents have used products in this

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category; 97.7% reported use of aerosol formulations. The room of use (Zone 1) was set to the utility
room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental Files [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures and Risk Exposure Modeling Results and Risk Estimates for Consumer
Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based on all
iterations of this modeling scenario.

Table 2-62. Acute Inhalation Exposure Summary: Shoe Polish

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(30)

(20)

95th %ile
(151.4)

User

2.52E+01

3.38

Bystander

4.52

6.79E-01

Moderate-Intensity User

50th %ile
(5)

(20)

50th %ile
(15.4)

User

2.56

3.41E-01

Bystander

4.18E-01

6.28E-02

Low-Intensity User

10th %ile
(0.5)

(20)

10th %ile
(2.9)

User

4.46E-01

5.96E-02

Bystander

7.74E-02

1.16E-02

Single weight fraction of 10-20% available.

Dermal exposures are also presented for this scenario, as it is assumed that the product could be applied
in a manner leading to dermal contact with impeded evaporation, thereby increasing the likelihood
and/or duration of dermal absorption. There is uncertainty surrounding the duration of dermal contact
with impeded evaporation. The exposure durations modeled could exceed the duration of such dermal
contact; therefore, the higher-end durations may result in an overestimation of dermal exposure.

Table 2-63. Acute E

~ermal Exposure Summary: Shoe Polish

Scenario
Description

Duration
of Use
(min)

Weight
Fraction1
(%)

Receptor

Acute ADR

(mg/kg/day)

High-Intensity
User

95th %ile
(30)

(20)

Adult (>21 years)

3.02

Children (16-20 years)

2.82

Children (11-15 years)

3.08

Moderate-
Intensity User

50th %ile
(5)

(20)

Adult (>21 years)

5.00E-01

Children (16-20 years)

4.70E-01

Children (11-15 years)

5.14E-01

Low-Intensity
User

10th %ile
(0.5)

(20)

Adult (>21 years)

5.00E-02

Children (16-20 years)

4.70E-02

Children (11-15 years)

5.14E-02

Single weight fraction of 10-20% available.

Other Consumer Uses
Fabric Spray

Exposure to TCE in fabric spray products was evaluated based on one aerosol product with a weight
fraction of 20-40% TCE. This use (i.e., no-fray fabric spray) was originally identified in the 2014 TSCA
Work Plan Chemical Risk Assessment of TCE (U.S. EPA. 2014b).

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Westat Survey data on water repellents/protectors for suede, leather, and cloth were used as the basis for
room of use, duration of use, and mass of product used. Survey responses indicate that 35.5% of
respondents have used products in this category; 72.1% reported use of aerosol formulations. The room
of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-64. Acute Inhalation Exposure Summary: Fabric Spray

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(40)

95th %ile
(326.8)

User

1.93E+02

2.53E+01

Bystander

2.10E+01

3.18

Moderate-Intensity User

50th %ile
(10)

(40)

50th %ile
(49.9)

User

3.24E+01

4.18

Bystander

2.75

4.13E-01

Low-Intensity User

10th %ile
(1.4)

(40)

10th %ile
(11.4)

User

5.64

7.35E-01

Bystander

6.09E-01

9.15E-02

1 Single product weight fraction of 20-40% available.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Film Cleaner

Exposure to TCE in film cleaner products was evaluated based on two aerosol products with weight
fractions ranging 80-100% TCE.

Westat Survey data on aerosol rust removers were used as the basis for duration of use and mass of
product used. This Westat category was selected as a surrogate, as there were no well-aligned product
categories for this use. However, survey responses for the selected surrogate category reported 98.3%
use of aerosol formulations, which is supportive of its application to the modeled product scenario.
Duration of use and mass of product data were also reviewed for reasonableness and were considered
more reasonable (i.e., lower) than the higher use patterns associated with most of the solvent degreasing
or cleaning categories. The room of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-65. Acute Inhalation Exposure Summary: Film Cleaner

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product
User or
Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(100)

95th %ile
(632.9)

User

4.71E+02

6.42E+01

Bystander

1.04E+02

1.57E+01

Moderate-Intensity User

50th %ile

(100)

50th %ile

User

7.77E+01

1.03E+01

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Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product
User or
Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)



(5)



(93.4)

Bystander

1.27E+01

1.91

Low-Intensity User

10th %ile
(0.5)2

(100)

10th %ile
(19.4)

User

1.49E+01

1.99

Bystander

2.59

3.89E-01

Actual product weight fractions were: 80-100% and 95%.

2The 10th percentile duration from Westat is < 0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest
timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Hoof Polish

Exposure to TCE in hoof polish products was evaluated based on one aerosol product with an
unreported weight fraction. Modeling was based on the upper-end of the narrow range of shoe polish
and spray fixative/coating formulation weight fractions (20-30%).

Westat Survey data on spray shoe polish were used as the basis for duration of use and mass of product
used. This Westat category was selected as a surrogate, as there were no well-aligned product categories
for this use. Survey data indicate that 11.7% of respondents used products in this category; 97.7%
reported use of aerosol formulations. The room of use (Zone 1) was set to approximate a barn
environment. This was done by using a garage (90 m3) but increasing the default air exchange rate of a
residential room from 0.45 to 4 air exchanged per hour, which was based on recommended ventilation
rates for a horse stable (Pennsylvania State University. 2016).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-66. Acute Inhalation Exposure Summary: Hoof Polish

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(30)

(30)

95th %ile
(208.2)

User

1.76E+01

2.21

Bystander

8.83E-02

1.10E-02

Moderate-Intensity User

50th %ile
(5)

(30)

50th %ile
(21.2)

User

1.73

2.16E-01

Bystander

3.81E-03

4.76E-04

Low-Intensity User

10th %ile
(0.5)

(30)

10th %ile
(4)

User

2.46E-01

3.08E-02

Bystander

6.23E-04

7.79E-05

1 Actual weight fraction is not reported; modeling was based on the upper-end of the narrow range of shoe polish and spray
fixative/coating formulation weight fractions (20-30%).

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Pepper Spray

Exposure to TCE in pepper spray products was evaluated based on two aerosol products with a single
reported weight fraction of 91.5% TCE.

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Internal research was the basis for duration of use and mass of product used. One spray from the most
common civilian canister is estimated to be approximately 0.0216-0.108 ounces, based on information
on a pepper spray manufacturer's website. Spraying occurred between 3 and 5 seconds (0.05-0.08 min)
before obtaining desired effect (Bertilsson et ai. ). The room of use (Zone 1) was set to
approximate a "cloud" around the user (16 m3) in an outdoor environment. This was done by increasing
the default air exchange rate of a residential room from 0.45 to 100 air exchanges per hour. Since the
interzonal ventilation rate for this "outdoor" scenario is held at 0, there are no bystander exposures
estimated. Based on the limited parameter data for this scenario, no inputs were varied.

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

Table 2-67. Acute Inhalation Exposure Summary: Pepper Spray

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

Single Scenario

(0.5)2

(91.5)

(4)

User

1.42E-01

1.77E-02

Bystander

1.42E-01

1.77E-02

Single weight fraction of 91.5% available.

2The selected <0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest timestep in the model run.
3Bystander in the home not modeled due to simulated outdoor scenario - can be considered equal to user.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

Toner Aid

Exposure to TCE in toner aid products was evaluated based on one aerosol product with a weight
fraction of 10-20% TCE.

Westat Survey data on aerosol rust removers were used as the basis for duration of use and mass of
product used. This Westat category was selected as a surrogate, as there were no well-aligned product
categories for this use. However, survey responses for the selected surrogate category reported 98.3%
use of aerosol formulations, which is supportive of its application to the modeled product scenario.
Duration of use and mass of product data were also reviewed for reasonableness and were considered
more reasonable (i.e., lower) than the higher use patterns associated with most of the solvent degreasing
or cleaning categories. The room of use (Zone 1) was set to the utility room (20 m3).

Inhalation exposures for users and bystanders are presented below reflecting high-, moderate-, and low-
intensity user scenarios. See Supplemental File [Exposure Modeling Results and Risk Estimates for
Consumer Inhalation Exposures. Docket: EPA-HQ-OPPT-2019-0500] for the full range of results based
on all iterations of this modeling scenario.

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Table 2-68. Acute Inhalation Exposure Summary: Toner Ait

Scenario Description

Duration of

Use
(min)

Weight
Fraction1
(%)

Mass Used
(g)

Product User
or Bystander

3-hr Max
TWA
(ppm)

24-hr Max
TWA
(ppm)

High-Intensity User

95th %ile
(60)

(20)

95th %ile
(434.7)

User

6.47E+01

8.82

Bystander

1.43E+01

2.16

Moderate-Intensity User

50th %ile
(5)

(20)

50th %ile
(64.2)

User

1.07E+01

1.42

Bystander

1.74

2.62E-01

Low-Intensity User

10th %ile
(0.5)2

(20)

10th %ile
(13.3)

User

2.05

2.73E-01

Bystander

3.55E-01

5.34E-02

Single weight fraction of 10-20% available.

2The selected <0.5 minutes, but 0.5 minutes was used in the model, as it reflects the smallest timestep in the model run.

There are no dermal exposures quantified for this scenario, as this use pattern is not expected to involve
dermal contact with impeded evaporation.

2.3.2.6.3 Summary of Consumer Exposure Assessment

Table 2-69 displays the consumer conditions of use evaluated for acute inhalation and/or dermal
exposures.

Table 2-69. Evaluated Pathways for Consumer Conditions of Use

Life
Cycle
Stage

Categories

Product Subcategories

Form

Acute
Inhalation
Exposure

Acute
Dermal
Exposure

Use

Solvents for
Cleaning and
Degreasing

Brake & Parts Cleaner

Aerosol





Electronic Degreaser/Cleaner

Aerosol





Electronic Degreaser/Cleaner

Liquid





Aerosol Spray Degreaser/Cleaner

Aerosol





Liquid Degreaser/Cleaner

Liquid





Gun Scrubber

Aerosol





Gun Scrubber

Liquid





Mold Release

Aerosol





Tire Cleaner

Aerosol





Tire Cleaner

Liquid





Lubricants and
Greases

Tap & Die Fluid

Aerosol





Penetrating Lubricant

Aerosol





Adhesives and
Sealants

Solvent-based Adhesive & Sealant

Liquid





Mirror-edge Sealant

Aerosol





Tire Repair Cement/Sealer

Liquid





Cleaning and
Furniture Care
Products

Carpet Cleaner

Liquid





Spot Remover

Aerosol





Spot Remover

Liquid





Arts, Crafts, and
Hobby Materials

Fixatives & Finishing Spray Coatings

Aerosol





Apparel and
Footwear Care
Products

Shoe Polish

Aerosol





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Life
Cycle
Stage

Categories

Product Subcategories

Form

Acute
Inhalation
Exposure

Acute
Dermal
Exposure



Other Consumer
Uses

Fabric Spray

Aerosol

V



Film Cleaner

Aerosol

V



Hoof Polish

Aerosol

V



Pepper Spray

Aerosol

V



Toner Aid

Aerosol

V



A range in acute inhalation and acute dermal exposures is provided in Table 2-70, summarized by the
consumer category. Ranges provided are based on the presented user scenario descriptions (high-,
moderate-, and low-intensity) and may not reflect overall minimum and maximum exposure levels from
all iterations of the modeling scenario, which can be seen in the Supplemental Files {Exposure Modeling
Results and Risk Estimates for Consumer Inhalation Exposures and Risk Exposure Modeling Results
and Risk Estimates for Consumer Dermal Exposures. Docket: EPA-HQ-OPPT-2019-0500\.

Table 2-70. Summary of Consumer Exposure Levels by Category

Consumer
Category

Acute Inhalation 24-hr TWA1
(ppm)

Acute Dermal
ADR2
(mg/kg/d)

Solvents for Cleaning
and Degreasing

User

4.55E-02 - 1.62E+02

1.19E-01 - 1.75E+02

Bystander

8.47E-03 - 4.71E+01

Lubricants and
Greases

User

2.16E-02 - 1.47E+01

NA

Bystander

4.21E-03 - 2.95

Adhesives and
Sealants

User

8.83E-03 - 3.22E+01

NA

Bystander

1.30E-03 - 4.06

Cleaning and
Furniture Care
Products

User

5.47E-01 - 5.26E+01

8.61E-02 - 4.77E+01

Bystander

6.90E-02 - 1.15E+01

Arts, Crafts, and
Hobby Materials

User

2.90E-01 - 9.31

NA

Bystander

5.66E-02 - 2.28

Apparel and Footwear
Care Products

User

5.96E-02 - 3.38

4.70E-02 - 3.08

Bystander

1.16E-02 - 6.79E-01

Other Consumer Uses

User

1.77E-02 - 6.42E+01

NA

Bystander

7.79E-05 - 1.57E+01

'The level of variation displayed in the ranges of consumer categories reflect multiple,
specific consumer conditions of use / subcategories and do not reflect the degree of
variation present within scenario-specific results. The displayed category ranges therefore
reflect a much broader spread of exposure estimates.

2The range in acute dermal ADRs reflect all age groups modeled (children and adult).

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2.3.2.7 Assumptions and Key Sources of Uncertainty for Consumer
Exposures

EPA's approach recognizes the need to include uncertainty analysis. One important distinction for such
an analysis is variability versus uncertainty - both aspects need to be addressed. Variability refers to the
inherent heterogeneity or diversity of data in an assessment. It is a quantitative description of the range
or spread of a set of values and is often expressed through statistical metrics, such as variance or
standard deviation, that reflect the underlying variability of the data. Uncertainty refers to a lack of data
or an incomplete understanding of the context of the risk evaluation decision.

Variability cannot be reduced, but it can be better characterized. Uncertainty can be reduced by
collecting more or better data. Quantitative methods to address uncertainty include non-probabilistic
approaches such as sensitivity analysis and probabilistic or stochastic methods. Uncertainty can also be
addressed qualitatively, by including a discussion of factors such as data gaps and subjective decisions
or instances where professional judgment was used.

Uncertainties associated with approaches and data used in the evaluation of consumer exposures are
described below.

2.3.2.7.1 Modeling Approach Uncertainties
Deterministic vs. Stochastic

With deterministic approaches like the one applied in this evaluation of consumer exposure, the output
of the model is fully determined by the choices of parameter values and initial conditions. Stochastic
approaches feature inherent randomness, such that a given set of parameter values and initial conditions
can lead to an ensemble of different model outputs. The overall approach to the CEM modeling is
intended to capture a range of low- to high-intensity User exposure estimates by varying only a limited
number of key parameters that represent the range of consumer product and use patterns for each
scenario. As previously mentioned the parameters selected were chemical weight fraction, product mass,
and duration of use. All other parameters remained constant between model runs. Since not all
parameters were varied, there is uncertainty regarding the full range of possible exposure estimates.
Although these estimates are thought to reflect the range in exposure estimates for the suite of possible
exposures based on the three varied parameters, the scenarios presented are not considered bounding or
"worst-case," as there are unvaried parameters that are also identified as sensitive inputs held constant at
a central tendency value. These include the room of use volume, residential building volume, and air
exchange rate. Because EPA's largely deterministic approach involves choices regarding highly
influential factors such as mass of product used and weight fraction, it likely captures the range of
potential exposure levels although it does not necessarily enable characterization of the full probabilistic
distribution of all possible outcomes.

Aggregate Exposure

Background levels of TCE in indoor and outdoor air are not considered or aggregated in this assessment;
therefore, there is a potential for underestimating consumer inhalation exposures, particularly for
populations living near a facility emitting TCE or living in a home with other sources of TCE, such as
TCE-containing products stored in the home. For example, the indoor air and personal breathing zone
monitoring values presented in Appendix D.2 were not considered for aggregation with modeled, use-
specific acute air concentrations. Similarly, inhalation exposures were evaluated on a product-specific
basis and are based on use of a single product type within a day, not multiple products.

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Acute Exposure

EPA assumes that a consumer product would be used only once per day. This is a reasonable assumption
for most scenarios, but a Do-It-Yourself- (DIY-) type user could potentially use the same product
multiple times in one day. Additionally, based on human health hazard considerations and typical use
patterns, chronic exposures were not evaluated for TCE-containing consumer products. However, it is
possible that there would be concern for chronic exposure effects for use frequencies greater than
intermittent. For example, daily or DIY-type uses of consumer products could constitute a short-term
chronic exposure scenario or repeated-acute exposure scenario that is not captured in this evaluation.
Identified chronic non-cancer and cancer hazard endpoints (Section 3.2) are unlikely to present for these
populations based on reasonably available information, however the possibility cannot be ruled out. For
the vast majority of the consumer population which are only exposed through short-term, occasional use
of TCE products, only acute exposure is applicable.

Dermal Exposure Approach

Dermal exposures are quantified and presented for scenarios that may involve dermal contact with
impeded evaporation based on professional considerations of the formulation type and likely use pattern.
However, there is uncertainty surrounding the assumption that such dermal contact with impeded
evaporation would occur for those scenarios. For example, for aerosol formulations, it is possible that
aerosol degreasing or cleaning products may be sprayed and left to drip or dry from the target surface. It
is also possible users would follow spraying with wiping, which could lead to some duration of dermal
contact with impeded evaporation.

There is related uncertainty surrounding the application of exposure durations for such scenarios. The
exposure durations modeled are based on reported durations of product use and may not reflect
reasonable durations of such dermal contact with impeded evaporation. In many cases, the exposure
duration modeled could exceed a reasonable duration of such dermal contact with a wet rag, for
example. Therefore, dermal exposure results based on the higher-end durations (i.e., those associated
with the moderate- and high-intensity user scenarios) may overestimate dermal exposure. Another
source of potential overestimation is the application of a single formulation density to scenarios covering
a range of specific TCE-containing products with a range of formulation densities. For such scenarios, a
single (highest) density was chosen to convert the mass used input obtained from the Westat (1987)
survey from ounces of product to grams of product. For some scenarios, this may have driven up the
mass used, though the degree of this impact is dependent on he broadness of the density range for that
condition of use.

In the evaluation of consumer dermal exposure, P_DER2b utilizes a measured dermal permeability
coefficient (Kp). EPA selected a Kp of 0.019 cm/hr from Poet (2000) obtained from a water patch test on
human skin using TCE in aqueous solution. While it is within range of other, predicted Kp values -
CEM predicts a Kp of 0.028 cm/hr and the NIOSH Skin Notation Profile for TCE calculates a Kp of
0.01197 cm/hr (Hudson and Dotson. , ) - it is a key parameter and there is some uncertainty
surrounding the impact of applying an aqueous Kp for the prediction of dermal flux for formulations of
TCE-containing consumer products, some of which contain nearly 100% TCE. While neat TCE would
be estimated to have a lower Kp based on relatively low water solubility (

Table 1-1) compared to its density, TCE is an irritant that would be expected to disrupt the stratum
corneum and lead to greatly increased absorption over time.

Inhalation Modeling for Outdoor Scenarios

The CEM model does not currently accommodate outdoor scenarios. For products that are intended to
be used outdoors, modifications to the CEM inputs were made to simulate an outdoor scenario by

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adjusting Zone 1 parameters (which represents the room of use or use environment). In modeling pepper
spray, the garage was selected as the room of use, but the room volume was changed to 16 m3 to
represent a half-dome chemical cloud around the person using the product. Additionally, the air
exchange rate for Zone 1 was set to 100 to reflect the high rate between the cloud and the rest of outside.
The interzonal ventilation rate was set to 0, which effectively blocks the exchange of air between Zone 1
and the rest of the house. Thus, the concentrations users are exposed to inside the home after product use
is zero. In the outside scenario, bystanders in the home are assumed to have zero exposures. However,
bystanders in the outdoor environment were not modeled, but could potentially be exposed to similar
levels as the user.

2.3.2.7.2 Data Uncertainties
Product Data

The products and articles assessed in this risk evaluation are largely based on EPA's 2017 Use and
Market Profile for TCE, as well as EPA's Use Report and Preliminary Information on Manufacturing,
Processing, Distribution, Use, and Disposal: TCE, which provide information on commercial and
consumer products available in the US marketplace at that time (\ c. < ^ \ •, h). While it is
possible that some products may have changed since 2017, EPA believes that the timeframe is recent
enough to represent the ongoing and reasonably foreseen consumer uses. Additional sources of product
information were evaluated, including the NIH Household Product Survey and EPA's Chemical and
Products Database (CPDat), as well as available product labels and safety data sheets (SDSs). However,
it is possible that the entire universe of products may not have been identified, or that certain changes in
the universe of products may not have been captured, due to market changes or research limitations.

Use Patterns

A comprehensive survey of consumer use patterns in the Westat Survey, was used to parameterize
critical consumer modeling inputs, based on applicable product and use categories. This large survey of
over 4,920 completed questionnaires, obtained through a randomized sampling technique, is highly
relevant because the primary purpose was to provide statistics on the use of solvent-containing consumer
products for the calculation of exposure estimates. The survey focused on 32 different common
household product categories, generally associated with cleaning, painting, lubricating, and automotive
care. Although there is uncertainty due to the age of the use pattern data, as specific products in the
household product categories have likely changed over time, EPA believes that the use pattern data
presented in the Westat survey reflect reasonable estimates for current use patterns of similar product
types.

A crosswalk was completed to select the most appropriate Westat survey category for each consumer
conditions of use in the current risk evaluation. Although detailed product descriptions were not
provided in the Westat survey, a list of product brands and formulation type in each category was useful
in pairing the Westat product categories to the scenarios being assessed. In most cases, the product
categories in the Westat survey aligned reasonably well with the products being assessed. Where Westat
survey product categories did not align well with consumer conditions of use, professional judgment
was used to select the most appropriate Westat category. This involved considering the reasonableness
of the duration and mass used, as well as comparing the primary formulation type. For a limited number
of scenarios, technical fact sheets or labels with information on product use amounts were available, and
this information was used in the assessment as needed.

Westat's overall respondent pool of the survey was large, but the number of users in each product
category was varied, with some product categories having a much smaller pool of respondents than
others. Product categories such as spot removers, cleaning fluids, glues and adhesives, lubricants, paints,

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paint strippers, fabric water repellents, wood stains, tire cleaners, engine degreasers, carburetor cleaners,
and specialized electronic cleaners had sample sizes ranging from roughly 500 to 2,000 users; whereas,
categories such as shoe polish, adhesive removers, rust removers, primers, outdoor water repellents,
gasket removers and brake cleaners had sample sizes of fewer than 500 users.

Emission Rate

The higher-tier Multi-Chamber Concentration and Exposure Model (MCCEM) was considered by EPA
for use in estimating inhalation exposures from consumer conditions of use; however, key data (i.e.,
chamber emission data) were not reasonably available. Therefore, the model used (CEM 2.1) estimates
emission rate based on chemical properties and emission profiles matching a spray or liquid application.

2,3,2,8 Confidence in Consumer Exposure Scenarios

The considerations and confidence ratings for the acute inhalation consumer exposure scenarios are
displayed in Table 2-71 with detailed explanations of rationale for the parameters in the footnotes.
Overall, there is moderate to high or high confidence in the consumer inhalation exposure modeling
approach and results. This is based on strength of the model employed, as well as the quality and
relevance of the default and user-selected/varied modeling inputs. CEM 2.1 is peer reviewed, publicly
available, and was designed to estimate inhalation and dermal exposures from household uses of
products and articles. CEM 2.1 uses central-tendency default values for sensitive inputs such as building
and room volumes, interzonal ventilation rate, and air exchange rates. These parameters were not varied
by EPA due to EPA having greater confidence in the central tendency inputs for such factors that are
outside of a user's control (unlike, e.g., mass used, use duration). These defaults are sourced from EPA's
exposure factors handbook (	). The one default value with a high-end input is the

overspray fraction, which is used in the aerosol or spray scenarios. It assumes a certain percentage is
immediately available for inhalation. However, due to TCE's physical chemical properties, this is a not a
sensitive parameter. In the 2014 TCE Risk Assessment, this parameter was varied from 1% to 25% and
resulted in almost no difference in the modeled peak air concentration (	2). The default

emission rate from a thin film is estimated within the model based on TCE's molecular weight and
vapor pressure, as described in the Chinn equation14 and is deemed appropriate given the lack of
consumer product chamber emission data. The confidence in the user-selected varied inputs (i.e., mass
used, use duration, and weight fraction) are moderate to high, depending on the condition of use; the
sources of these data include the Westat Survey (	87) and company-generated safety data

sheets (SDSs). The representativeness of the consumer use patterns (duration of use, amount used, room
of use, etc.) described in the Westat Survey (	[7) is believed to remain strong when

compared to present day consumer use patterns even though some aspects of the use may have changed.
However, ease of access to products on-line or in big box stores (like home improvement stores), readily
accessible how-to videos, and a consumer movement toward more do-it-yourself projects with products
containing the chemical of concern could impact the representativeness of the consumer use patterns
described within the Westat Survey and may lead to an underestimate of overall consumer exposure.
There is a medium uncertainty associated with the representativeness of the consumer use patterns
described within the Westat Survey and present day consumer use patterns. In some cases, professional
judgment was used in selection of room of use, which sets the volume for modeling zone 1.

The considerations and confidence ratings for the acute dermal consumer exposure scenarios are
displayed in Table 2-72 with detailed explanations of rationale for the parameters in the footnotes.

14 The value of k is determined from an empirical relationship, developed by (Chinn. .1.98.1.1. between the time required for
90% of a pure chemical film to evaporate (EvapTime) and the chemical's molecular weight (MW) and vapor
pressure (VP): EvapTime = 145 / (MW x VP) 0.9546, k = ln(10) / (EvapTime x 60), where k = first-order rate
constant for emission decline (min-1), MW = molecular weight, VP = vapor pressure.

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Overall, there is a low to moderate confidence in the consumer dermal exposure modeling approach and
results. The same model is employed to estimate dermal exposures; however, there is greater uncertainty
related to the potential for dermal contact with impeded evaporation (i.e., dermal exposure scenarios
wherein volatilization from the skin surface is inhibited); this contributes to the lower overall confidence
in the dermal results. The dermal permeability approach was selected for modeling instead of the
fraction absorbed method. Based on rationale provided in the problem formulation, EPA determined that
only dermal exposures with impeded evaporation would be evaluated for consumer conditions of use.
This is based on the expectation that, if not inhibited from volatilizing, inhalation exposure would
account for the preponderance of exposure from consumer uses. An example of dermal contact with
impeded evaporation for consumer applications would be having a TCE-soaked rag pressed firmly
against a user's fingers or hands for a period of time. Therefore, the permeability approach was deemed
more reflective of this type of dermal exposure scenario, as it does not account for losses due to
volatilization and assumes a constant flux of TCE for the duration of the use event. In modeling these
scenarios, the same use durations sourced from the Westat survey (	87) are applied;

however, in doing so, the model assumes that there are no losses throughout the entire use duration. It is
unlikely that dermal contact would involve impeded evaporation for the entire use duration, particularly
for central-tendency and high-end use durations. It is more likely that such contact would be intermittent
throughout longer use durations and not constant. This leads to an overall low confidence in that input;
however, there would be greater confidence in the results obtained from the low-end use duration inputs
for any weight fraction modeled.

An additional point of confidence in the consumer modeling approach related to capturing variation and
estimating results for a range of exposure levels. Although a probabilistic assessment was not employed,
EPA did use up to three inputs for three key modeling parameters: mass used, use duration, and weight
fraction. The first two parameters are based on the Westat survey data, which presented a distribution of
responses. For these parameters, a low-end (10th percentile), central tendency (50th percentile), and high-
end (95th percentile) was used in modeling. Weight fraction inputs were based on product SDSs, so the
full range of reported weight fractions was reflected in the modeling inputs using either minimum and
maximum weight fractions or using minimum and maximum weight fractions along with a mid-point
weight fraction. For subcategories with only one product, only one weight fraction was used in the
modeling. Otherwise, these varied parameters were varied in all possible combinations, resulting in up
to 27 iterations for a given modeling scenario.

Consumer exposure monitoring studies associated with conditions of use are not reasonably available
for direct comparison with modeled results. Indoor air monitoring data are available but are not
associated with specific conditions of use or TCE-containing consumer products and are therefore only
relevant for considerations of background levels of TCE in homes.

While there were certain scenarios that have moderate confidence ratings rather than high confidence for
user-selected varied inputs, there are not reasonably available alternative inputs that would serve to
increase confidence in the modeling estimates. For example, in modeling film cleaner, the alternative to
applying mass used and use duration from the rust remover Westat survey scenario is professional
judgment, which is unlikely to decrease uncertainty.

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3080

Table 2-71. Confidence Ratings for Acute Inhalation Consumer Exposure Modeling Scenarios

Consumer
Condition of User

Confidence
in Model
Used1

Confidence
in Model

Confidence in User-Selected Varied Inputs3

Overall

Category

Subcategory

Form

Default
Values2

Mass
Used4

Use
Duration5

Weight
Fraction6

Room of

Use7

Confidence

Solvents for

Cleaning

and

Brake &

Parts

Cleaner

Aerosol

High

High

High

High

High

High

High

Decreasing



















Solvents for

Cleaning

and

Electronic
Degreaser/
Cleaner

Aerosol

High

High

High

High

High

High

High

Degreasing



















Solvents for

Cleaning

and

Electronic
Degreaser/
Cleaner

Liquid

High

High

High

High

High

High

High

Degreasing



















Solvents for

Cleaning

and

Spray

Degreaser/

Cleaner

Aerosol

High

High

High

High

High

High

High

Degreasing



















Solvents for

Cleaning

and

Liquid

Degreaser/

Cleaner

Liquid

High

High

High

High

High

High

High

Degreasing



















Solvents for

Gun

Aerosol

High

High

High

Moderate

High

Moderate

Moderate

Cleaning
and

Scrubber















to High

Degreasing



















Solvents for

Gun

Liquid

High

High

High

Moderate

High

Moderate

Moderate

Cleaning
and

Scrubber















to High

Degreasing



















Solvents for

Mold

Aerosol

High

High

Moderate

High

High

High

Moderate

Cleaning
and

Release















to High

Degreasing



















Solvents for

Cleaning

and

Tire Cleaner

Aerosol

High

High

High

High

High

High

High

Degreasing



















Solvents for

Cleaning

and

Tire Cleaner

Liquid

High

High

High

High

High

High

High

Degreasing



















Lubricants
and Greases

Tap & Die
Fluid

Aerosol

High

High

High

High

High

High

High

Lubricants
and Greases

Penetrating
Lubricant

Aerosol

High

High

High

High

High

High

High

Adhesives
and Sealants

Solvent-
based

Adhesive &
Sealant

Liquid

High

High

High

High

High

High

High

Adhesives
and Sealants

Mirror-edge
Sealant

Aerosol

High

High

Moderate

Moderate

High

High

High

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Consumer
Condition of User

Confidence
in Model
Used1

Confidence
in Model

Confidence in User-Selected Varied Inputs3

Overall

Category

Subcategory

Form

Default
Values2

Mass
Used4

Use
Duration5

Weight
Fraction6

Room of

Use7

Confidence

Adhesives
and Sealants

Tire Repair

Cement/

Sealer

Liquid

High

High

High

High

High

High

High

Cleaning
and

Carpet
Cleaner

Liquid

High

High

Moderate

Moderate

High

Moderate

Moderate
to High

Furniture



















Care



















Products



















Cleaning
and

Spot

Remover

Aerosol

High

High

High

High

High

High

High

Furniture



















Care



















Products



















Cleaning
and

Spot

Remover

Liquid

High

High

High

High

High

High

High

Furniture



















Care



















Products



















Arts, Crafts,

Fixatives &

Aerosol

High

High

Moderate

Moderate

High

Moderate

Moderate

and Hobby
Materials

Finishing

Spray

Coatings















to High

Apparel and
Footwear

Shoe Polish

Aerosol

High

High

High

High

High

High

High

Care



















Products



















Other
Consumer

Fabric Spray

Aerosol

High

High

High

High

High

High

High

Uses



















Other

Film Cleaner

Aerosol

High

High

Moderate

Moderate

High

Moderate

Moderate

Consumer

















to High

Uses



















Other

Hoof Polish

Aerosol

High

NA

Moderate

Moderate

High

High

Moderate

Consumer

















to High

Uses



















Other

Pepper

Aerosol

High

NA

High

High

High

Moderate

Moderate

Consumer

Spray















to High

Uses



















Other

Toner Aid

Aerosol

High

High

Moderate

Moderate

High

Moderate

Moderate

Consumer

















to High

Uses



















Confidence in Model Used considers whether model has been peer reviewed, as well as whether it is being applied in a manner
appropriate to its design and objective. The model used (CEM 2.1) has been peer reviewed, is publicly available, and has been
applied in a manner intended - to exposures associated with uses of household products and/or articles.

Confidence in Model Default Values considers default value data source(s) such as building and room volumes, interzonal
ventilation rates, and air exchange rates. These default values are all central tendency values (i.e., mean or median values) sourced
from EPA's Exposure Factors Handbook (U.S. EPA. 2011c'). The one default value with a high-end input is the overspray fraction,
which is used in the aerosol or spray scenarios. It assumes a certain percentage is immediately available for inhalation. However,
due to TCE's physical chemical properties, this is a not a sensitive parameter. In the 2014 TSCA Work Plan Chemical Risk
Assessment for TCE (U.S. EPA. 2014b'). this parameter was varied from 1% to 25% and resulted in almost no difference in the
modeled peak air concentration.

Confidence in User-Selected Varied Inputs considers the quality of their data sources, as well as relevance of the inputs for the
selected consumer condition of use.

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Consumer
Condition of User

Confidence
in Model
Used1

Confidence
in Model
Default
Values2

Confidence in User-Selected Varied Inputs3

Overall
Confidence

Category

Subcategory

Form

Mass
Used4

Use
Duration5

Weight
Fraction6

Room of

Use7

'Mass Used is primarily sourced from the Westat (.1.9871 survey, which received a high-quality rating during data evaluation and has
been applied in previous agency assessments. Two conditions of use had product information that was used instead of Westat (gun
scrubber and pepper spray).

5Use Duration is primarily sourced from the Westat (.1.9871 survey, which received a high-quality rating during data evaluation and
has been applied in previous agency assessments. One condition of use had product information that was used instead of Westat
(pepper spray). Relevance of these inputs from the Westat survey to the specific consumer condition of use they were applied to is
considered in the reported confidence ratings.

6Weight fraction of TCE in products is sourced from product Safety Data Sheets (SDSs), which were not reviewed as part of
systematic review but were taken as authoritative sources on a product's ingredients.

Room of use (zone 1 in modeling) is informed by responses in the Westat (.1.987) survey, which received a high-quality rating
during data evaluation, although professional judgment is also applied for some scenarios. The reasonableness of these judgements
is considered in the reported confidence ratings.	

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Table 2-72. Confidence Ratings for Acute Dermal Consumer Exposure Modeling Scenarios

Consumer
Condition of User

Confidence
in Model
Used1

Confidence
in Model
Default
Values2

Confidence in
Assumption of

Dermal
Contact with

Impeded
Evaporation3

Confidence in User-Selected
Varied Inputs4

Overall
Confidence

Category

Subcategory

Form

Kp5

Use
Duration6

Weight
Fraction7

Solvents for
Cleaning and
Degreasing

Brake & Parts
Cleaner

Aerosol

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Electronic
Degreaser/
Cleaner

Liquid

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Spray

Degreaser/

Cleaner

Aerosol

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Liquid

Degreaser/

Cleaner

Liquid

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Gun Scrubber

Aerosol

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Gun Scrubber

Liquid

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Tire Cleaner

Aerosol

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

Solvents for
Cleaning and
Degreasing

Tire Cleaner

Liquid

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Cleaning and
Furniture Care
Products

Carpet
Cleaner

Liquid

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Cleaning and
Furniture Care
Products

Spot Remover

Aerosol

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

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Consumer
Condition of User

Confidence
in Model
Used1

Confidence
in Model
Default
Values2

Confidence in
Assumption of

Dermal
Contact with

Impeded
Evaporation3

Confidence in User-Selected
Varied Inputs4

Overall
Confidence

Category

Subcategory

Form

Kp5

Use
Duration6

Weight
Fraction7

Cleaning and
Furniture Care
Products

Spot Remover

Liquid

Low to
Moderate

High

Moderate

Moderate

Low

High

Low to
Moderate

Apparel and
Footwear Care
Products

Shoe Polish

Aerosol

Low to
Moderate

High

Low

Moderate

Low

High

Low to
Moderate

Confidence in Model Used considers whether model has been peer reviewed, as well as whether it is being applied in a
manner appropriate to its design and objective. The model used (CEM 2.1) has been peer reviewed, is publicly available, and
has been applied in a manner intended - to estimate exposures associated with uses of household products and/or articles. For
the purposes of dermal exposure, this confidence rating also considers the appropriateness of the dermal permeability model
within CEM 2.1 for estimating dermal exposures with impeded evaporation and known sources of uncertainty.

Confidence in Model Default Values considers default value data source(s) such as surface area to body weight ratios for the
dermal contact area. These default values are all central tendency values (i.e., mean or median values) sourced from EPA's
Exposure Factors Handbook (U.S. EPA. 2011c').

Confidence in Assumption of Dermal Contact with Impeded Evaporation characterizes the uncertainty surrounding whether
or not occluded contact is even possible or likely. Certain conditions of use have greater uncertainty over whether or not any
occluded contact is expected, i.e., the spray scenarios. The liquid formulations are likely to result in some dermal contact with
a rag; however, there remains uncertainty related to the degree to which such contact would be occluded.

Confidence in User-Selected Varied Inputs considers the quality of their data sources, as well as relevance of the inputs for
the selected consumer condition of use.

5The dermal permeability coefficient (Kp) used (0.019 cm/hr) from Poet (2000) came from a water patch test on human skin
using TCE in an aqueous solution. While it is within range of other, predicted Kp values (CEM 2.1 predicts 0.028 cm/hr and
NIOSH calculates 0.01197 cm/hr), it is a key parameter and there is uncertainty surrounding the impact of applying an
aqueous Kp for prediction of dermal flux for formulations of TCE-containing consumer products with nearly 100% TCE.
6Use Duration is primarily sourced from the Westat (.1.987) survey, which received a high-quality rating during data evaluation
and has been applied in previous agency assessments. The dermal modeling receives a "low" confidence for this criterion due
to the uncertainty associated with the period of time during which a dermal exposure duration is likely to be occluded, not due
to relevance or data source.

'Weight fraction of TCE in products is sourced from product Safety Data Sheets (SDSs) and were taken as authoritative
sources on a product's ingredients.

2.3.3 Potentially Exposed or Susceptible Subpopulations

TSCA requires that a risk evaluation "determine whether at chemical substance presents an
unreasonable risk of injury to health or the environment, without consideration of cost or other non-risk
factors, including an unreasonable risk to a potentially exposed or susceptible subpopulation identified
as relevant to the risk evaluation by the Administrator, under the conditions of use." TSCA § 3(12)
states that "the term 'potentially exposed or susceptible subpopulation' means a group of individuals
within the general population identified by the Administrator who, due to either greater susceptibility or
greater exposure, may be at greater risk than the general population of adverse health effects from
exposure to a chemical substance or mixture, such as infants, children, pregnant women, workers, or the
elderly."

During problem formulation (	2018d\ EPA identified potentially exposed or susceptible

subpopulations for further analysis during the development and refinement of the life cycle, conceptual
models, exposure scenarios, and analysis plan. In this section, EPA addresses the potentially exposed or
susceptible subpopulations identified as relevant based on greater exposure. EPA addresses the
subpopulations identified as relevant based on greater susceptibility in Section 3.2.5.2.

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In developing the draft risk evaluation, the EPA analyzed the reasonably available information to
ascertain whether some human receptor groups may have greater exposure than the general population
to the hazard posed by TCE. Exposures of TCE would be expected to be higher amongst groups living
near industrial facilities, groups with TCE containing products in their homes, workers who use TCE as
part of typical processes, and groups who have higher age and route specific intake rates compared to
the general population.

Of the human receptors identified in the previous sections, EPA identifies the following as potentially
exposed or susceptible subpopulations due to their greater exposure to TCE and considered them in the
risk evaluation:

Workers and occupational non-users (ONUs). EPA reviewed monitoring data found in published
literature including both personal exposure monitoring data (direct exposure) and area monitoring data
(indirect exposures) and identified data sources that contain measured monitoring data and or/estimated
data for the various conditions of use (including import and processing of TCE). Exposure estimates
were developed for users (males and female workers of reproductive age) exposed to TCE as well as
non-users or workers exposed to TCE indirectly by being in the same work area of the building. Also,
adolescents and female workers of reproductive age (>16 to less than 50 years old) were also considered
as a potentially exposed or susceptible subpopulations

Consumers/product users and bystanders associated with consumer use. TCE has been identified as
being used in products available to consumers. Sections 2.3.2.1 and 2.3.2.2 provide an overview of
exposure pathways considered for the consumer assessment. Furthermore, EPA identified consumers
and bystanders associated with use of TCE-containing consumer products as a potentially exposed and
susceptible subpopulation due to greater exposure as described in Section 2.3.2.3. For example, higher-
intensity users (i.e., those using consumer products for longer durations and in greater amounts) were
considered and evaluated. In addition, consumers are considered to include children and adults over age
11, but bystanders in the home exposed via inhalation are considered to include any age group, from
infant to adult, including pregnant women and/or women of reproductive age. However, only some
individuals within the general population may use these products. Therefore, those who do use these
products are a potentially exposed or susceptible subpopulation due to greater exposure. Exposures for
these subpopulations are considered and/or evaluated in Section 2.3.2.6 (Table 2-32 through Table
2-68).

In developing dermal exposure scenarios, EPA quantified age and gender-specific differences. For TCE,
exposure scenarios that involve potentially exposed or susceptible subpopulations considered age-
specific behaviors, activity patterns, and exposure factors unique to those subpopulations. EPA used the
Exposure Factors Handbook (\ c. « ^ \ 101 I. ) to inform body weights, intake rates, and body surface
areas for children and adults. Distinct dermal exposure estimates are provided for for adults (including
women of reproductive age) and children (Section 2.3.2.6.1).

For occupational exposures, EPA assessed exposures to workers and ONUs from all TCE conditions of
use. Table 2-73 presents the percentage of employed workers and ONUs whom may experience either
greater exposure or biological susceptibility within select industry sectors relevant to TCE conditions of
use. The percentages were calculated using Current Population Survey (CPS) data for 2017 (115 JILL
2017). CPS is a monthly survey of households conducted by the Bureau of Census for the Bureau of
Labor Statistics and provides a comprehensive body of data on the labor force characteristics. Statistics

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for the following subpopulations of workers and ONUs are provided: adolescents, men and women of
reproductive age, and the elderly. For the purpose of this assessment, EPA considers "reproductive age"
as age >16 to less than 50 years old.

As shown in Table 2-73, men make up the majority of the workforce in manufacturing sectors. In other
sectors, women (including those of reproductive age and elderly women) make up nearly half of the
workforce. Adolescents are generally a small part of the total workforce. Table 2-74 presents further
breakdown on the percentage of employed adolescents by industry subsectors. As shown in the tables,
they comprise only 1.2% percent of the manufacturing workforce, and only as high as 3.7% for other
services such as dry cleaning that fall under a COU for TCE.

Table 2-73. Percentage of Employed Persons by Age, Sex, and Industry Sector

Age group

Sex

Manufacturing

Wholesale and
Retail Trade

Professional and
Business Services

Other Services

Adolescent
(16-19 years)

Male

0.8%

3.0%

0.7%

1.4%

Female

0.4%

3.2%

0.5%

1.7%

Reproductive age
(16-54 years)

Male

52.9%

42.8%

44.4%

35.2%

Female

22.2%

35.4%

32.8%

38.4%

Elderly (55+)

Male

17.5%

12.3%

13.4%

13.1%

Female

7.3%

9.6%

9.4%

13.3%

Source: (U.S. BLS. 2017). While statistics on pregnant women are not reasonably available, CPS provides data on the
number of employed female workers by age group, which allows for determination of the number of employed women of
reproductive age. Percentage calculated using CPS Table 14, "Employed persons in nonagricultural industries by age, sex,
race, and Hispanic or Latino ethnicity."

Table 2-74. Percentage o

' Employed Adolescent by Detailed Industry Sector

Sector

Subsector

Adolescent
(16-19 years)

Manufacturing

All

1.2%

Wholesale and retail trade

Wholesale trade

1.4%

Professional and business
services

Waste management and
remediation services

0.9%

Other services

Repair and maintenance

3.1%

Dry cleaning and laundry services

3.7%

Source: (U.S. BLS. 2017). Percentage of adolescent calculated using CPS table 18b, "Employed persons by detailed industry
and age."

The CPS uses 2012 Census industry classification, which was derived from the 2012 NAICS. The
Census classification uses the same basic structure as NAICS but is generally less detailed. TCE
conditions of use fall under the following Census industry sectors:

Manufacturing - The Manufacturing sector comprises establishments engaged in the mechanical,
physical, or chemical transformation of materials, substances, or components into new products.
Establishments in the sector are often described as plants, factories, or mills. For TCE, this sector covers
most conditions of use that occur in an industrial setting, including: Manufacturing, Processing as a
Reactant, Formulation of Aerosol and Non-Aerosol Products, the vast majority of facilities likely

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engaged in Vapor Degreasing (all degreaser types), Cold Cleaning, Metalworking Fluids, Adhesives,
Sealants, Paints and Coatings, Other Industrial Uses, Industrial Processing Aids and Printing and
Copying. This sector also covers cement manufacturing facilities that may burn waste containing TCE
for energy recovery. Also - Printing and Copying worker information may also be captured under the
Information sector (see below).

Wholesale and retail trade - The wholesale trade sector comprises establishments engaged in
wholesaling merchandise, generally without transformation, and rendering services incidental to the sale
of merchandise. Wholesalers normally operate from a warehouse or office. This sector likely covers
facilities that are engaged in the repackaging TCE or products and formulations containing TCE. The
retail trade sector comprises establishments engaged in retailing merchandise and rendering services
incidental to the sale of merchandise.

Professional and business services - This sector comprises establishments that specialize in a
wide range of services. This sector covers waste management and remediation services, which includes
establishments that may handle, dispose, treat, and recycle wastes containing TCE.

Other services - This sector comprises establishments engaged in providing services not
specifically provided for elsewhere in the classification system. For TCE, this sector covers the vast
majority of commercial repair and maintenance facilities that are likely to use TCE for Aerosol
Applications (spray degreasing). The sector also covers the use of TCE in spot cleaning.

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3 HAZARDS

3.1 Environmental Hazards

3.1.1	Approach and Methodology

During scoping and problem formulation (	|), EPA reviewed potential environmental

health hazards associated with TCE. EPA identified the following sources of environmental hazard data:
European Chemicals Agency (ECHA) Database (EC	), European Union (EU) environmental

risk assessment on TCE (ECHA.. 2004) EPA Chemical Test Rule Data (	) Environment

and Climate Change Canada (ECCC) Risk Assessment for Trichloroethylene (Environment Canada and
Health Can a 2) and Ecological Hazard Literature Search Results in Trichloroethylene (CASRN
79-01-6) Bibliography: Supplemental File for the TSCA Scope Document (U.S. EPA. 20171).

EPA completed the review of environmental hazard data/information sources during risk evaluation
using the data quality review evaluation metrics and the rating criteria described in the Application of
Systematic Review in TSCA Risk Evaluations (	2018b). Studies were rated high, medium, or

low for quality. The data quality evaluation results are outlined in the [Data Quality Evaluation of
Environmental Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and indicate that most of the
acceptable studies for TCE were rated high and moderate for quality. With the reasonably available data,
EPA used studies rated high or medium for quantitative analysis during data integration, and used
studies rated low qualitatively to characterize the environmental hazards of trichloroethylene. Any study
assigned an overall quality level of unacceptable was not used for data integration. Mechanistsic studies
were used qualitatively, because toxicity values measuring a population-level effect (e.g. mortality,
development, growth) were available to use quantitatively.

3.1.2	Hazard Identification

Toxicity to Aquatic Organisms

EPA identified 25 acceptable studies that contained aquatic toxicity data, including data for fish,
amphibians, aquatic invertebrates, and algae. Aquatic toxicity studies considered in this assessment are
summarized in the text below, and the data EPA used quantitatively are displayed in Table 3-1. As
stated in Section 2.1, TCE is not expected to accumulate in aquatic organisms due to low measured
BCFs and an estimated BAF.

Fish Toxicity

Acute fish data for TCE were identified in six acceptable studies representing four different species,
including fresh and saltwater species (fathead minnows [Pimephalespromelas\ American flagfish
\Jordanella floridae\ bluegill \Lepomis macrochirus\ and sheepshead minnow \Cyprinodon
variegatus]). In these studies, all used quantitatively in this assessment, the lethal concentrations at
which 50% of test organisms die (LCsos) ranged from 28.28 mg/L to 66.8 mg/L (Geiger	5);

(Broderius et al. 2005: Smith et al. 1991; Ward	5; Buccafusco et ai. 1981; Alexander et al..

1978). Ward et al. (1986) tested a saltwater species, sheepshead minnow, and derived an LCso of 52
mg/L. Because this value is within the of the range of values for freshwater species, and because
baseline narcosis is the expected mode of action for TCE in both freshwater and saltwater fish
( \lc\ander et al rs \); (Ward et al.. 1986); (Broderius et al.. 2005). freshwater and saltwater LCso
values were assessed together during data integration. EPA calculated a geometric mean of 42 mg/L
using LCsos from high and medium quality studies. Acute fish data for TCE also included a 96-hour
EC50 (the concentration at which 50% of test organisms exhibit an effect) of 21.9 mg/L for loss of

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equilibrium in a freshwater species, fathead minnows ( Ucwider et al r" \). This study was rated high
for quality.

Subchronic fish data were also identified in two acceptable studies representing two species. Smith et al.
(1991) established a 10-day NOEC of 5.758 mg/L and a LOEC of 21.233 mg/L resulting in a chronic
value (ChV) of 1 1 mg/L for fry survival in American flagfish {Jordanellafloridae). Schell (1987)
established a 10-day LCso of 82 mg/L in Japanese medaka (Oryzias latipes) embryos. The author found
that lethality occurred at every stage of development for embryos. Schell also observed lesion
development in the embryos after exposure in a dose-dependent pattern, with higher test concentrations
resulting in earlier formation of lesions. Both abovementioned sub-chronic studies received a high rating
for quality during data evaluation, and EPA used the data quanitatively.

Chronic fish data for TCE were identified in two acceptable studies representing two freshwater species,
American flagfish (,Jordanella floridae) and fathead minnows (Pimephales promelas). In addition to the
subchronic value mentioned above, Smith et al. (1991) established a 28-day NOEC of 10.568 mg/L and
a LOEC of 20.915 mg/L for fry survival in American flagfish. This allowed the authors to establish a
28-day ChV of 14.85 for fry survival. Broderius et al. (2005) established an ECso for growth of 11.8
mg/L and an EC20 for growth of 7.88 mg/L in a 32-day fathead minnow study. Both studies were rated
high for quality during data evaluation. EPA used the chronic data in these studies quantitiatively.

Broderius et al. (2005) reported baseline narcosis as TCE's expected mode of action in fish. This is
corroborated by other studies, including Ward, et al. (1986), which observed signs of narcosis in
sheepshead minnows, a saltwater species, with observations of fish spinning at 357 mg/L. EPA used this
information qualitatilvey in this assessment. Alexander et al. ( 5) reported signs of narcosis in fathead
minnows, a freshwater species, with a 96-hour EC10 of 13.7 mg/L, EC50 of 21.9 mg/L, and EC90 of 34.9
mg/L. The effect reported was loss of equilibrium. EPA used the 96-hour EC50 from Alexander et al.
(1978) quantitatively in this assessment.

Two mechanistic studies were also available for fish. Hayashi et al. (1998) examined genotoxicity in
rose bitterling (Rhodeus ocellatus) embryos using a new assay developed by the authors. The authors
found an increase in structural chromosomal aberrations and micronuclei in cells from embryos,
establishing a NOEC of 300 mg/L and a LOEC of 3,000 mg/L. The authors noted the low sensitivity of
the assay and suggested using more embryos in the future. This study was rated medium for quality.
Another in vitro study, rated low for quality, derived an EC50 of 11.6 mg/L for the inhibition of total
protein content in a fathead minnow cell line (Dierickx. 1993). Because this cellular effect is not directly
tied to a population effect, and because of the low-quality rating, this study was not used with the other
acute data to calculate a geometric mean of EC50S during data integration; however, the results
contribute to the qualitative description of mechanistic effects of TCE exposure in fish.

Amphibian Toxicity

For amphibians, acute data were available from three acceptable studies, representing one species,
African clawed frogs (Xenopus laevis). All three studies were rated either high or medium for quality
during data evaluation. The studies included 96-hour LC50 values ranging from 412.0 mg/L to 490.0
mg/L (McDamiel et al.. ,\V I; h 
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[Xenopus laevis], American toad \Bufo americanus], and spotted salamander [Ambystoma maculatum]).
These studies reported 96-hr EC so values for developmental effects ranging from 22 mg/L to > 85 mg/L
(McDaniel et al. 2004; Fort et al. 2001; Fort et al. 199 etal C'M). EPA used these data
quantitatively, and during data integration, a geometric mean of all definitive ECsos for developmental
effects was calculated at 34 mg/L. These developmental effects are irreversible and would result in
effects that last throughout the animals' lifetime. Developmental effects described included gut
miscoiling and microphthalmia, muscular kinking, incomplete development of the mouth, and severe
hypognathia in African clawed frogs, and edema and dorsal flexure of the tail and notochord in tadpoles
of green frogs, wood frogs, American toads, and spotted salamanders (McDaniel et al.. 2004; Fort et al..
1993; Fort et al.. 1991). As stated previously, McDaniel et al. (2004) reported signs of narcosis in green
and wood frog tadpoles.

Limited chronic data were also available for amphibians. McDaniel et al., (2004) included a chronic
toxicity test for amphibians on American toad tadpoles. However, chronic toxicity values for deformities
were not established, because more than 25% of control animals exhibited deformities. Mortality,
however, was below 25% in controls, and authors saw no significant difference in mortality between test
concentrations (4 mg/L and 1 mg/L) and controls. This suggests that survival rates for American toad
tadpoles would not be affected by 4 mg/L of TCE. It should be noted that acute exposure data show
American toads are less sensitive to TCE than other amphibian species, so they may also be less
sensitive to chronic exposures. EPA used this information qualitatively.

McDaniel et al. (2004) reported signs of narcosis in green and wood frog tadpoles.

Aquatic Invertebrate Toxicity

For aquatic invertebrates, acute data were found in seven acceptable studies representing five different
species, including fresh and saltwater species. Five of these studies included LCso or ECso values rated
high or medium for quality; these values ranged from 7.75 mg/L to 43.14 mg/L for Daphnia magna,
Ceriodaphnia dubia, andMysidopsis bahia (Dobaradaran et al.. 2012; Niederlehner et al.. 1998;
Abernethy et al.. 1986; Ward et al.. 1986; LeBlanc. 1980). The only saltwater species tested, Mysidopsis
bahia, had an LCso of 14 mg/L, which is within the of the range of values for freshwater species. EPA
used these data quantitatively. Additionally, Ward et al. (1986) and Niederlehner et al. (1998) reported
baseline narcosis as the mode of action for TCE in freshwater and saltwater invertebrates. Therefore,
freshwater and saltwater values were integrated together. The geometric mean of the EC so and LCsos
from high and medium quality studies is 16 mg/L. EPA used these data quantitatively. Another study,
Sanchez-Fortun et al. (1997). rated low for quality, established LCsos in Artemia salina larvae at three
different ages; however, this study was not used quantitatively during data integration, given that
medium and high-quality studies were available for invertebrates.

One sub chronic study found an LCso of 1.7 mg/L in planarian (Dugesia japonica) over 7 days (Yoshioka
et al.. 1986). This study was rated low for quality. Because other higher quality studies were available
for aquatic invertebrates, this study was not used quantitatively during data integration.

Chronic data for aquatic invertebrates were identified in two acceptable studies, both rated high for
quality. One study established toxicity values for reproduction, an effect that is relevant at the
population level. Niederlehner et al. (1998) established a NOEC of 7.1 mg/L and a LOEC of 12 mg/L
for reproduction in Ceriodaphnia dubia, resulting in a ChV of 9.2 mg/L. Niederlehner et al. (1998)
established a 7-day reproductive inhibitory concentration (ICso) of 11 mg/L, the concentration at which
the mean number of young decreased by 50%. EPA used these data quantitatively.

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Two studies reported baseline narcosis as the mode of action for TCE in invertebrates. Ward et al.
(1986) observed mild intoxication in Mysidopsis bahia, a saltwater species, and Niederlehner et al.
(1998) observed behavioral changes, including narcosis and abnormal movement in Ceriodaphnia
dubia, a freshwater species. EPA used this information qualitatively.

Two studies provided mechanistic data for invertebrates. Vidal et al. (2001). rated high for quality,
examined mechanistic effects of an acute exposure to a freshwater clam species, Corbicula fluminea. A
one-time exposure over five days resulted a significant change in protein activity related to phase I
metabolism. Results indicated a NOEC of 1.2 mg/L and a LOEC of 3.6 mg/L for significantly increasing
cytochrome P-450 levels, and a NOEC of 3.6 mg/L and LOEC of 14 mg/L for significantly decreasing
NADPH cytochrome C reductase activity (Vidal et al.. 2001). Houde et al. (2015). also rated high for
quality, examined the effects of TCE on Daphnia magna at the cellular and life-stage levels. The authors
found a significant increase in chitinase production over 10 days, with a NOEC of 0.001 mg/L and a
LOEC of 0.01 mg/L. Chitinase is an enzyme involved in molting and therefore development in Daphnia
magna. While the study did not find a significant change in the total number of molts for the
concentrations tested, the results were very close to significant with a p = 0.051 (assuming significance
at p < 0.05), suggesting more tests are necessary to determine the impact of increased chitinase at the
life-stage level. Because this mechanistic data is not directly linked to a population-level response, this
data was used qualitatively rather than quantitiatively.

Aquatic Plant Toxicity

For aquatic plants hazard studies, algae are the common test species. Algae are cellular organisms which
will cycle through several generations in hours to days; therefore the data for algae was assessed
together regardless of duration rather than being categorized as acute or chronic.

There were six acceptable studies reported data on 11 species of algae, including fresh and saltwater
species, and cyanobacteria and eukaryotes. There was a wide range of toxicity values reported in the
literature for algae exposed to TCE. ECsos measuring growth represent nine species and range from
26.24 mg/L to 820 mg/L (Lukavsky et al.. 2011; Labra et al.. 2010; Tsai and Chen. 2007; An do et al..
2003; Brack and Rottler. 1994; Ward et al.. 1986). Ward et al. (1986) reported results on the only
saltwater species found in the acceptable studies, Skeletonema costatum, with an EC so of 95 mg/L. This
value is within the of the range of values for freshwater species, so saltwater and freshwater species
were integrated together. EPA derived a geometric mean of 242 mg/L from the high and medium quality
ECsos. A 72-hour EC 10 of 12.3 mg/L was also established by Brack and Rottler (1994) measuring
biomass (a measure of growth) in Chlamydomonas reinbardtii, a freshwater eukaryotic green algae.
Additionally, several NOECs and LOECs were established. Labra et al. Q ) found a 72-hour NOEC
of 0.02 mg/L and a LOEC of 0.05 mg/L for cell count (a measure of growth) in Raphidocelis
subcapitata. This study also assessed the integrity of algal cell membranes and found a dose-dependent
increase in membrane damage starting at 0.05 mg/L. EPA used the abovementioned algae data
quantitatively.

Ando et al. (2003) measured relative absorbance of chlorophyll a (an indirect measure of algal growth)
in three species of algae, Selenastrum capricornutum, Chlorella vulgaris, and Volvulina steinii. They
found no significant change in the relative absorbance of chlorophyll a for S. capricornutum or C.
vulgaris during the 10-day test; however, they established a 10-day LOEC of 0.003 mg/L for V. steinii, a
flagellar algae. The authors attributed the variation in algal species sensitivity to methylene chloride to
V. steinii1 s high metabolism. For several reasons explained in Section 3.1.4 Weight of the Scientific
Evidence, these data were considered less biologically relevant than values from other studies and were
not used quantitatively during data integration.

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Table 3-1 Ecological Hazard Data used Quantitatively to Characterize TCE Hazard for Aquatic

Duration

Test
organism

Endpoint

Hazard
value
(mg/L)1

Geometric
Mean2
(mg/L)

Effect Endpoint

Citation
(Study Quality)

Acute3

Fish

LC50
(freshwater)

28.28-66.8

42

Mortality

(Geieeret al. 1985) (hieh);
(Alexander et al. 1978)
(hiah): (Smith et al. 1991)
(hiuh): (Broderius et al.
2005) (hieh); (Buccafiisco et
al. 1981) (medium)

LC50
(saltwater)

52

(Ward et al. 1986) (medium)

EC50
(freshwater)

21.9



Immobilization

(Alexander et al, 1978)
(high)

Amphibian

LC50

412.0-
490.0

436

Mortality

(
(
(

Fort et al. 2001) (medium);
Fort et al.. 1991) (medium);
Fort et al.. 1993) (high)

Aquatic
Invertebrates

EC50/LC50
(freshwater)

7.8-33.85

16

Mortality and
Immobilization

(
(
(

(
(

LeBlanc. 1980) (hieh);
Niederlehneret al, 1998)
high); (Abernethv et al,
986) (medium);
Dobaradaran et al. 2012)
medium)

LC50
(saltwater)

14

(Ward et al. 1986) (medium)

Subchronic
/Chronic3

Fish

EC20

7.88



Growth

(B rode rius et al, 2005)
(high)

EC50

11.8



Growth

NOEC
LOEC
ChV

10.568
20.915
14.87



Fry Survival

(Smith et al. 1991) (hieh)

NOEC
LOEC
ChV
(subchronic)

5.758
21.233
11



Fry Survival

LC50
(subchronic)

82



Mortality

CSchell. 1987) (hiah)

Amphibians

NOEC

4



Tadpole
Survival

(McDaniel et al, 2004)
(medium)

EC50
(subchronic)

22 - >85

34

Deformities

(
(
(
(
a

Fort et al. 2001) (medium);
Fort et al.. 1991) (medium);
Fort et al.. 1993) (hieh);

McDaniel et al, 2004) (high
ind medium)

Aquatic
invertebrates

NOEC
LOEC
ChV

7.1
12

9.2



Reproduction

(Niederlehneret al.. 1998)
(high)

IC50

11



Algae4

EC50
(freshwater)

26.24 - 820

242

Growth

(Brack and Rottler. 1994)
(high); (Tsai and Chen, 2007)
(hieh); (Labra et al. 2010)
(medium); (Ando et al.
2003) (medium); (Lukavskv
et al. 2011) (medium)

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EC50
(saltwater)

95





(Ward et al.. 1986) (medium)

EC10

12.3



Growth

(Brack and Rottler. 1994)
(high)

NOEC
LOEC
ChV

0.02
0.05
0.03



Growth

(Labra et al.. 2010) (medium)

'Values in the table are presented in the number of significant figures reported by the study authors.

2	Geometric mean of definitive values only (i.e., > 85 mg/L was not used in the calculation).

3	Acute and chronic hazard data include fish, invertebrates, or amphibian data

4	Because algae can cycle through several generations in hours to days, the data for algae was assessed together regardless of duration (i.e.,
48-lirs to 96-lirs).

Note: Values in bold were used to derive Concentrations of Concern (COC) as described in Section 3.1.5 of this document. All values are
listed individually with study quality in [Data Quality Evaluation of Environmental Hazard Studies and Data Extraction for Environmental
Hazard Studies. Docket: EPA-HO-OPPT-2019-0500],

3.1.3 Species Sensitivity Distributions (SSDs)

A Species Sensitivity Distribution (SSD) is a type of probability distribution of toxicity values from
multiple species. It can be used to visualize which species are most sensitive to a toxic chemical
exposure, and to predict a concentration of a toxic chemical that is hazardous to a percentage of species.
This hazardous concentration is represented as an HCP, where p is the percent of species.

As stated previously, there were a wide range of toxicity values reported in the literature for algae
exposed to TCE. EC50s were as low as 26.24 mg/L and as high as 820 mg/L, representing nine different
species. With such a wide range of sensitivities, it is helpful to show how TCE could be affecting algae
species as a whole. Therefore, EPA generated an SSD to help interpret the data. Figure 3-1 shows the
SSD for algae created using EPA's SSD Toolbox (Etterson. 2019). The data used in the SSD includes
ECsos measuring growth from freshwater species, a saltwater species, cyanobacteria, eukaryotes, a
diatom, and a colonizing species. As stated in Section 3.1.2, saltwater and freshwater species were
assessed together, because the only saltwater species, Skeletonemci costatum, had an EC50 within that of
the range of values for freshwater species.

An HC05 (Hazardous Concentration threshold for 5% of species) for algae of 52 mg/L was derived from
this SSD.

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Figure 3-1. Species Sensitivity Distribution (SSD) for Algae Species Using ECsos (Etterson, 2019)

Toxicity Value (Log 10[EC50]) mg/L

Note: The data in this figure includes ECsos measuring growth from medium- or high-quality studies. A black dot indicates
the toxicity value used for that species. The red diamond indicates an HCos. The SSD was created using a triangular
distribution and fit using graphical methods (Appendix E. 1).

Given these data, certain algae species may be more sensitive than others; however, there is not enough
data to make definitive conclusions. The three cyanobacteria, Mycrocystis aeruginosa, Synechococcus
leopoliensis, and Synechococcus elongatus, are distributed throughout the curve and as a group do not
appear to be more or less sensitive than the eukaryotic species. The saltwater species, Skeletonema
costatum, also the only diatom, is one of the more sensitive species on the distribution. The species that
organizes into colonies, Mycrocystis aeruginosa, is also one of the more sensitive species represented on
the curve. However, with only one saltwater species, diatom, and colonizing species represented,
generalizations about the sensitivity of these types of algae could not be made.

It is important note that, for consistency, this distribution only includes ECsos to compare between
studies and species. Therefore, it does not capture some of the lowest toxicity values reported, including
LOECs and NOECs. For example, the ChV of 0.03 mg/L for algae derived from Labra et al. (2010) is
not included in the algae SSD.

An SSD was also created using the acute hazard data, including LCso and ECso data for fish, amphibians,
and invertebrates (Figure 3-2) (Etterson. 2019). The input data for Figure 3-2 included ECsos and LCsos
available in the literature representing four species of fish (LCsos), one species of amphibian (LCsos),
and three species of invertebrates (LCsos/ECsos). As stated previously, freshwater and saltwater species
were assessed together, because the saltwater values were within the of the range freshwater species in

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the same taxonomic group. Additionally, for fish and invertebrates, the mode of action for freshwater
and saltwater species expected to be the same (Broderius et al.. 2005; Ward et al.. 1986; Alexander et
al.. 1978V

For the HCos for acute hazard data, EPA used a model average of the Gumbel, triangular, normal, and
logistic distributions (Figure 3-2). The model-averaged HCos from all three distributions was 9.9 mg/L,
which estimates a concentration that is hazardous for 5% of aquatic species. The SSDs showed aquatic
invertebrates were the most sensitive species.

Figure 3-2. Species Sensitivity Distributions (SSDs) for Acute Hazard Data Using LCsos or ECsos

Note: The data in this figure includes LCsoS and ECsoS measuring mortality and immobilization from medium- or high-quality
studies. A black dot indicates the toxicity value used for that species. The red diamonds indicate HCoss for the normal,
logistic, triangular, and Gumble distributions using the maximum likelihood fitting method (Appendix E.l).

This SSD shows that generally, invertebrates are the most sensitive taxonomic group to short-term (48-
96 hour) exposure to TCE. Amphibians and fish were distributed throughout the center of the
distribution, with the two frog species being the most sensitive amphibians, and American flagfish
(Jordcmellafloridae) the most sensitive fish.

A chronic SSD for aquatic species was not created due to insufficient data.

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3,1,4 Weight of the Scientific Evidence

During the data integration stage of systematic review EPA analyzed, synthesized, and integrated the
data/information. This involved weighing the scientific evidence for quality and relevance, using a
weight-of-evidence approach (U.S. EPA. 2018b).

During data evaluation, EPA assigned studies an overall quality level of high, medium, or low for
quality based on the TSCA criteria described in the Application of Systematic Review in TSCA Risk
Evaluations (U, S. EPA. 2018b). While integrating environmental hazard data for TCE, EPA gave more
weight to relevant data/information rated high or medium for quality than to data/information rated low.
Only data/information rated as high, medium, or low for quality was considered for the environmental
risk assessment. Any information rated as unacceptable was not considered. EPA also considered
relevance in selecting data/information for this risk evaluation, specifically biological,
physical/chemical, and environmental relevance (	):

-	Biological relevance: correspondence among the taxa, life stages, and processes measured or
observed and the assessment endpoint.

-	Physical/chemical relevance: correspondence between the chemical or physical agent tested and
the chemical or physical agent constituting the stressor of concern.

-	Environmental relevance: correspondence between test conditions and conditions in the region of
concern. (	)

EPA used this weight-of-evidence approach to assess hazard data and develop concentrations of concern
(COCs) and HCoss. Given the reasonably available data, EPA only used studies assigned an overall
quality level of high or medium to derive COCs or HCoss for each taxonomic group. EPA derived
geometric means for each trophic level that had comparable toxicity values (e.g., multiple ECsos
measuring the same or comparable effects from various species within a trophic level). To calculate
HCoss, EPA created SSDs for algae species using comparable data (e.g., ECsos measuring growth) and
for all species (e.g., ECsos and LCsos measuring population effect measures, like growth, mortality,
immobilization, and deformities). Non-definitive toxicity values (e.g., ECso >85 mg/L) were not used to
derive geometric means or HCoss.

To assess aquatic toxicity from acute exposures, data for three taxonomic groups were reasonably
available: fish, amphibians, and aquatic invertebrates. For each taxonomic group, data were available for
multiple species, and geometric means were calculated as shown in Table 3-1. The geometric mean for
aquatic invertebrates, 16 mg/L, represented the lowest toxicity value derived from each of the four
taxonomic groups. The SSD in Figure 3-2 shows that the three most sensitive species in the distribution
are aquatic invertebrates, further substantiating that this is the most sensitive taxonomic group to acute
exposures.

To assess aquatic toxicity from chronic exposures, data for three taxonomic groups were described in the
acceptable literature: fish, amphibians, and aquatic invertebrates. However, for amphibians, only a
NOEC was established. Therefore, the endpoints for fish and aquatic invertebrates (ChVs, an EC20, and
an ECso) were more biologically relevant, because they measured a toxic effect. Of these values, the
most sensitive was the EC20 measuring growth in fish at 7.88 mg/L.

To assess the toxicity of TCE to algae, data for 11 species were reasonably available from studies rated
high and medium for quality. The most sensitive endpoint reported for algae was a 10-day LOEC of
0.003 mg/L from Ando et al. (2003). rated medium for quality. However, the study did not include
critical details, such as analytical measurement of test concentrations, or chemical substance source or
purity, and the authors were not able to establish a NOEC. Therefore, these data were considered less

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biologically relevant than values from other studies, and not used quantitatively during data integration.
The ChV of 0.03 from Labra et al. (2010) was the most sensitive endpoint from the more relevant
studies. Labra et al. (2010) was rated medium for quality. An EC in of 12.3 mg/L from a high-quality
study, Brack et al. (1994). was also available; however, taking biological relevance into consideration,
EPA used the ChV derived from Labra et al. (2010). because there was a wide range in toxicity values
reported in the literature between algae species. Therefore, EPA used the value from Raphidocelis
subcapitata (formerly known as Pseudokirchneriella subcapitata) from Labra et al. ( ) to represent
the more sensitive algae species in the COCs. (According to the algae SSD, Raphidocelis subcapitata is
generally more sensitive to TCE exposure than Chlamydomonas reinhartdtii, the species used in Brack
et al. (1994).) In addition to this ChV, EPA considered the results from the SSD for algae in assessing
toxicity to algae. The SSD represented toxicity values for nine species of algae and provided an
additional line of evidence for how TCE exposure could affect this taxonomic group.

3,1,5 Concentrations of Concern

The concentrations of concern (COCs) for aquatic species were calculated based on the environmental
hazard data for TCE, using the weight of evidence approach described above and EPA methods (H.S.
B1 \ Av16i, JO I .V). For TCE, EPA derived an acute COC, a chronic COC, and an algal COC. Algae
was assessed separately and not incorporated into acute or chronic COCs, because durations normally
considered acute for other species (e.g., 48, 72 hours) can encompass several generations of algae.

After weighing the evidence and selecting the appropriate toxicity values from the integrated data to
calculate an acute, chronic, and algal COC, an assessment factor (AF) is applied according to EPA
methods (	, 2012c). The application of AFs provides a lower bound effect level that

would likely encompass more sensitive species not specifically represented by the available
experimental data. AFs also account for differences in inter- and intra-species variability, as well as
laboratory-to-field variability. These AFs are dependent on the availability of datasets that can be used
to characterize relative sensitivities across multiple species within a given taxa or species group.
However, they are often standardized in risk assessments conducted under TSCA, since the data
reasonably available for most industrial chemicals are limited. For fish and aquatic invertebrates (e.g.,
daphnia) the acute COC values are divided by an AF of 5. For chronic COCs, an AF of 10 is used (U.S.
EPA. 2012c).

To derive an acute COC for TCE, EPA used the geometric mean of the EC so and LCsos for aquatic
invertebrates from five different studies, all rated high or medium for quality (Dobaradaran et al.. 2012;
Niederlehner et al.. 1998; Abernethy et al.. 1986; Ward et al.. 1986; LeBlanc. 1980). The geometric
mean for aquatic invertebrates represented the lowest acute value from all four taxonomic groups of
aquatic species from the integrated data for TCE. The data used to calculate the geometric mean
represent toxicity data for three species, Daphnia magna, Ceriodaphnia dubia, and Mysidopsis bahia.
To calculate an acute COC, the geometric mean, 16 mg/L, was divided by the AF of 5 for aquatic
invertebrates and multiplied by 1,000 to convert mg/L to |ig/L (or ppb).

Therefore, the acute COC = (16 mg/L) / AF of 5 = 3.2 x 1,000 = 3,200 |ig/L or ppb.

The acute COC for TCE is 3,200 ppb.

To derive a chronic COC, EPA used the lowest chronic toxicity value from the integrated data, an EC20
for growth in fish (fathead minnows) from a study rated high for quality (Broderius et al.. 2005). This
value, 7.88 mg/L was divided by an assessment factor of 10, and then multiplied by 1,000 to convert
from mg/L to |ig/L (or ppb).

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Therefore, the chronic COC = (7.88 mg/L) / AF of 10 = 0.788 x 1,000 = 788 |ig/L or ppb.

The chronic COC for TCE is 788 ppb.

To derive an algal COC, EPA used a geometric mean of a LOEC and a NOEC for growth in
Raphidocelis subcapitata (Labra et ai. 2010). This value, 0.03 mg/L was divided by an assessment
factor of 10, and then multiplied by 1,000 to convert mg/L to |ig/L (or ppb).

Therefore, the algal COC = (0.03 mg/L) / AF of 10 = 0.003 x 1,000 = 3 |ig/L or ppb.

The algal COC for TCE is 3 ppb.

Additionally, EPA used algae data representing nine species to produce an SSD, which was used to
calculate an HCos of 52 mg/L (or 52,000 ppb). As stated previously, this HCos estimates a concentration
that is hazardous for 5% of species. The HCos can be used in addition to the COC for algae, estimating
the concentration of TCE that is expected to protect 95% of algae species.

The algal HCos for TCE is 52,000 ppb.

3.1.6 Summary of Environmental Hazard

The reasonably available environmental hazard data indicate that TCE presents hazard to aquatic
organisms. For acute exposures to invertebrates, toxicity values ranged from 7.8 to 33.85 mg/L
(integrated into a geometric mean of 16 mg/L). For chronic exposures, toxicity values for fish and
aquatic invertebrates were as low as 7.88 mg/L and 9.2 mg/L, respectively. The data also indicated that
TCE presents hazard for aquatic plants, with toxicity values in algae as low as 0.03 mg/L (geometric
mean between a NOEC and a LOEC), and a wide range in toxicity between algae species (ECsos ranging
from 26.24 - 820 mg/L).

The COCs derived for aquatic organisms are summarized in Table 3-2. EPA calculated the acute COC
for TCE at 3,200 ppb, based on the geometric mean of LCsos and ECsos for aquatic invertebrates, from
five studies rated either high or medium for quality (Dobaradaran et at.. 2012; Niederlehner ci M h">l>8;
Abernethy et at.. 1986; Ward et at.. 1986; LeBlanc. 1980). EPA calculated the chronic COC for TCE at
788 ppb, based on an EC20 for fathead minnows from Broderius et al. (2005). rated high for quality.

As stated previously, algae were assessed separately from other aquatic organisms, because durations
normally considered acute for other species (e.g., 96 hours) can encompass several generations of algae.
EPA calculated an algal COC for TCE at 3 ppb, based on a geometric mean of a LOEC and NOEC for
growth in Raphidocelis subcapitata from Labra et al. (2010). a study rated medium for quality. EPA also
calculated an HCos of 52,000 ppb for algae based on the ECsos for nine species, from studies rated
medium and high for quality.

Table 3-2 Concentrations of Concern (COCs) for Environmental Toxicity

1 ji\iionmcntal Aquatic Toxicity

Concent rati 011 of Concern

Toxicity from Acute Exposure

3,200 ppb

Toxicity from Chronic Exposure

788 ppb

Toxicity for Algae: COC based on the lowest toxicity value
HCos based on ECsos

3 ppb

52,000 ppb

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3.1.7 Assumptions and Key Uncertainties for Environmental Hazard Data

While EPA determined that there was sufficient environmental hazard data to characterize
environmental hazards of TCE, there are uncertainties. First, assessment factors (AFs) were used to
calculate the acute and chronic concentrations of concern for TCE. As described in Section 3.1.5, AFs
account for differences in inter- and intra-species variability, as well as laboratory-to-field variability
and are routinely used within TSCA for assessing the hazard of new industrial chemicals. Some
uncertainty may be associated with the use of the specific AFs used in the hazard assessment.

Second, there was more acute duration data reasonably available in the literature than chronic duration
data. Therefore, EPA is less certain of chronic hazard values, which are based on one fish species, than
the acute hazard values, which are based on data from multiple species of aquatic invertebrates.
However, a few lines of evidence mitigate the uncertainty in the chronic data. For example, the fish
toxicity value on which the chronic COC is based, is from a high-quality, relevant study. Additionally,
the acute data show aquatic invertebrates are the most sensitive taxonomic group, and they are
represented in chronic duration data. Also, the other chronic fish toxicity values as well as the chronic
aquatic invertebrate values were very close to the fish value used to derive the chronic COC. Therefore,
some of the uncertainties EPA had around the chronic COC were mitigated.

Third, while the toxicity values for fish, amphibians, and invertebrates are relatively consistent, there
was wide variation in the toxicity values for different species of algae. One study, Lukavsky et al. ( )
examined several species of algae using standardized methods within the same lab to determine whether
the variation seen in the literature was due to differences in laboratory practices, methodology used, or
species studied. They found that conducting the tests with standard methods in the same lab reduced the
variation seen in toxicity levels between species; however, ECsos were still as low as 130 mg/L and as
high as 820 mg/L for the eight species of algae tested (compared to a range of 26.24 - 820 mg/L from
the entire body of literature), indicating there is in fact a wide range in species sensitivities. Taking this
range of sensitivies into consideration, EPA used two approaches to characterize hazard in algae. EPA
developed an algae COC, using a toxicity value of 0.03 mg/L, which represents one species. The data
show that there are other species that are less sensitive to TCE exposure. To provide more context for
this taxonomic group, EPA also used algae data from nine species to create an SSD and derive an HCos.
EPA considered the HCos analogous to a COC. However there are pros and cons to each approach. For
example, the COC incorporates the most sensitive endpoint in a geometric mean of a NOEC and LOEC
for growth, while the HCos does not consider the most sensitive endpoints reported in the data. However,
the HCos is derived using data from nine species rather than just one, and is therefore representative of a
larger portion species in the environment.

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3.2 Human Health Hazards

3.2.1	 Approach and Methodology

EPA used the approach described in Section 1.5 to evaluate, extract and integrate TCE's human health
hazard and dose-response information.

Figure 3-3. EPA Approach to Hazard Identification, Data Integration, and Dose-Response

Analysis for TCE

Specifically, EPA reviewed key and supporting information from previous hazard assessments as well as
the existing body of knowledge on TCE's human health hazards. These data sources included an EPA
IRIS Assessment ( J.S. EPA 201 le) and an ATSDR Toxicological Profile ((AT SDR. 2019). data
sources originally obtained from the 2014 Draft Toxicological Profile); hence, many of the hazards of
TCE have been previously compiled and systematically reviewed. Furthermore, EPA previously
reviewed data/information on health effects endpoints, identified hazards and conducted dose-response
analysis in the 2014 TSCA Work Plan Chemical Risk Assessment for TCE (U.S. EPA. 2014b) but did
not exclusively rely on this assessment.

All health hazards of TCE previously identified in these reviews were described and reviewed in this
risk evaluation, including: acute overt toxicity, liver toxicity, kidney toxicity, neurotoxicity,
immunotoxicity (including sensitization), reproductive toxicity, developmental toxicity, and cancer.
EPA relied heavily on the aforementioned existing reviews along with scientific support from the Office
of Research and Development in preparing this risk evaluation. Development of the TCE hazard and
dose-response assessments considered EPA and National Research Council (NRC) risk assessment
guidance.

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The new literature was screened against inclusion criteria in the PECO statement and the relevant
studies (e.g., useful for dose-response)15 were further evaluated using the data quality criteria for human,
animal, and in vitro studies described in the Application of Systematic Review in TSCA Risk Evaluations
(U.S. EPA. 2018b) (see Section 1.5). EPA skipped the screening step (for relevance to TCE) of the key
and supporting studies identified in previous assessments and entered them directly into the data
evaluation step based on their previously identified relevance to the chemical.

EPA considered studies of low, medium, or high confidence for hazard identification and dose-response
analysis. Information from studies that were rated unacceptable were only discussed on a case-by-case
basis for hazard ID and weight-of-scientific-evidence assessment but were not considered for dose-
response analysis.

EPA has not developed data quality criteria for all types of hazard information. This is the case for
toxicokinetics and many types of mechanistic data which EPA typically uses for qualitative support
when synthesizing evidence. As appropriate, EPA evaluated and summarized these data to determine
their utility with supporting the risk evaluation.

Following the data quality evaluation, EPA extracted the toxicological information from each relevant
study. In the last step, the strengths and limitations of the data were evaluated for each endpoint and a
weight-of-the-scientific evidence narrative was developed. Data for each selected hazard endpoint
underwent dose-response analysis. Finally, the results were summarized, and the uncertainties were
presented. The process is described in Figure 3-3. The weight of evidence analysis included integrating
information from toxicokinetics, toxicodynamics in relation to the key hazard endpoints: acute overt
toxicity, liver toxicity, kidney toxicity, neurotoxicity, immunotoxicity (including sensitization),
reproductive toxicity, developmental toxicity, and cancer. EPA selected human health studies that were
of high quality and relevance to move forward for dose-response analysis in order to quantitatively
assess each key hazard endpoint.

Tables summarizing all studies considered for this assessment, including the reported no-observed- or
lowest-observed-adverse-effect levels (NOAEL and LOAEL) for non-cancer health endpoints by target
organ/system and the incidence for cancer endpoints, along with the results of the data quality
evaluation, are provided in [Data Quality Evaluation of Human Health Hazard Studies and Data
Extraction for Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500].

EPA considered points of departure (POD) from studies that were PECO relevant, scored acceptable in
the data quality evaluation, and contained adequate dose-response information. The POD is a dose or
concentration near the lower end of the observed range without significant extrapolation to lower doses.
It is used as the starting point for subsequent dose-response (or concentration-response) extrapolations
and analyses. PODs can be a no-observed-adverse-effect level (NOAEL), a lowest-observed-adverse-
effect level (LOAEL) for an observed incidence, or change in level of response, or the lower confidence
limit on the dose at the benchmark dose (BMDL).16 PODs were adjusted as appropriate to conform to
the specific exposure scenarios evaluated.

15	Some of the studies that were excluded based on the PECO statement were considered later during the systematic review
process as needed. For example, EPA reviewed mode of action information to qualitatively support the health hazard
assessment.

16	The benchmark dose (BMD) is a dose or concentration that produces a predetermined change in response range or rate of
an adverse effect (called the benchmark response or BMR) compared to baseline.

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Human equivalent concentrations (HECs) and human equivalent doses (HEDs) were obtained via EPA's
previously published and peer-reviewed Physiologically-Based Pharmacokinetic (PBPK) model (

), which accounts for both extrapolation from rodents to humans and human variability (see
Section 3.2.2.1 and [PBPKModelandReadMe (zipped). Docket: EPA-HQ-OPPT-2019-0500]). The
PBPK model also allows data-based route-to-route extrapolation between oral and inhalation studies.
For HEC calculations, these values were adjusted based on 24-hr exposure durations unless otherwise
noted. Limited toxicological data are reasonably available by the dermal route for TCE and a PBPK
model that would facilitate route-to-route extrapolation has not been developed for the dermal exposure
route. Therefore, oral HEDs were also utilized for risk estimation following dermal exposure, consistent
with the analysis plan as described in the Problem Formulation (	1).

Section 3.2.5 describes the dose-response assessment guiding the selection of PODs for non-cancer
endpoints. The BMD modeling results for pulmonary immunotoxicity (Setgrade and Gilmour. 2010).
which was not included in the 2014 TCE Risk Assessment (	2014b). are presented in Appendix

F. The full description of the PBPK and BMD model outputs for all other endpoints can be found in (U.S.
).

3.2.2 Toxicokinetics

The toxicokinetics and PBPK modeling of TCE were thoroughly discussed in the 2014 Risk Assessment
(I	£014b). This discussion is summarized below.

TCE is fat soluble (lipophilic) and easily crosses biological membranes. Though there are
quantitative differences across species and routes, TCE is readily absorbed into the body
following oral, dermal, or inhalation exposure. Because of its lipophilicity, TCE can cross the
placenta and also passes into breast milk (	).

Absorption following inhalation of TCE is rapid and the inhaled absorbed dose is proportional to the
exposure concentration, duration of exposure, and lung ventilation rate. Therefore, for this risk
evaluation absorption of TCE is assumed to be 100% via inhalation. Likewise, TCE is
rapidly absorbed from the gastrointestinal tract into the systemic circulation (i.e., blood)
following oral ingestion. Oral absorption of TCE has been shown to be influenced by dose of the
chemical, the dosing vehicle and stomach contents. Absorbed TCE is first transported to the
liver where it is metabolized for eventual elimination (i.e., "first-pass effect") (	).

Rapid absorption through the skin has been shown by both vapor and liquid TCE contact with
the skin. In several human volunteer studies, both TCE liquid and vapors were shown to be well
absorbed in humans via the dermal route. Dermal absorption was rapid following exposures of between
20 and 30 minutes, with peak TCE levels in expired air occurring within 15 minutes (liquid) and 30
minutes (vapor) (	). Dermal exposure to TCE disrupts the stratum corneum, impacting

the barrier function of skin and promoting its own absorption. Therefore, absorption may increase at a
greater than linear rate due to increasing epidermal disruption over time (ATSDR. 2019). Based on this
information, this risk evaluation assumes that TCE dermal absorption under occluded (or impeded
evaporation) scenarios is 100%. Dermal absorption under non-occluded occupational exposure scenarios
was evaluated by the Dermal Exposure to Volatile Liquids Model in order to account for evaporation of
TCE deposited on skin (Section 2.3.1). Consumer exposure was only evaluated for scenarios that may
involve dermal contact with impeded evaporation using a skin permeability model with a dermal
permeability coefficient of 0.019 cm/hr (Section 2.3.2.4.1).

Regardless of the route of exposure, TCE is widely distributed throughout the body. TCE levels
can be found in many different human and rodent tissues including: brain, muscle, heart,

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kidney, lung, liver, and adipose tissues. It can also be found in human maternal and fetal blood
and in the breast milk of lactating women (U.S. EPA. 201 le).

The metabolism of TCE has been extensively studied in humans and rodents (U.S. EPA. 201 le).

Animals and humans metabolize TCE to metabolites to varying degrees. These metabolites are known to
play a key role in causing TCE-associated toxic effects. TCE metabolites are known to target the liver
and kidney. The two major metabolic pathways are (1) oxidative metabolism via the cytochrome P450
(CYP) mixed function oxidase system and (2) glutathione (GSH) conjugation followed by further
biotransformations and processing with other enzymes. The liver is the major tissue for the oxidative
and GSH conjugation metabolic pathways. Both pathways are saturable, and above the saturable
concentration/dose, TCE is excreted unchanged in expired air. Table 3-3 presents the important
metabolites formed following both the CYP (oxidation) and GSH (conjugation) pathways in humans and
animals. The amount and types of metabolites formed are important for understanding the toxicity of
TCE in both animals and humans.

These major TCE metabolites as well as a number of minor metabolites are also observed in the

metabolic pathway of TCE-related compounds (Table 3-4). This may be important in

determining exposures because people may be co-exposed to many of these solvents at the

same time. Concomitant exposures to TCE and its related compounds can affect TCE's metabolism and

increase toxicity by generating higher internal metabolite concentrations than those resulting from TCE

exposure only (U.S. EPA. 201 le).

Table 3-3 TCE Metabolites Identified by Pathwa'

Oxidative Metabolites

GSH Conjugation Metabolites

Chloral

(metabolized to TCOHa)

DCVGe

(,metabolized to DCVCi isomers)

Trichloroethylene oxide

(re-arranged to DCACb)

Trichloroethanol or TCOH

(metabolized to TCOGc)

Trichloroacetic acid or TCA

(may lead to DC Ad)

Abbreviations: a TCOH = trichloroethanol; bDCAC= dichloroacetyl chloride; cTCOG= trichloroethanol,
glucuronide conjugate; dDCA=dichloroacetic acid; eDCVG= S-dichlorovinyl-glutathione (collectively, the 1,2-
and 2,2- isomers); fDCVC= S-dichlorovinyl-L-cysteine (collectively, the 1,2- and 2,2- isomers)

A review of in vitro metabolism data in the liver suggested that rodents (i.e., especially mice)
have greater capacity to metabolize TCE via the oxidation pathway (U.S. EPA. 201 le). In vitro data
have also reported modest sex- and age-dependent differences in the oxidative TCE metabolism in
humans and animals. Significant variability may exist in human susceptibility to TCE toxicity given the
existence of CYP isoforms and the variability in CYP-mediated TCE oxidation (U.S. EPA. 201 le).

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Metabolites^^^



Tetrachloro-
ethane



Trichloro-
ethane

Dichloro-
ethylene

Dichloro-
ethane

Oxalic acid



X

X



X



Chloral

X



X







Chloral hydrate
(CH)

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X







Monochloroacetic
acid

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Dichloro acetic
acid (DCA)

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Dichloro acetic
acid (TCA)

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Trichloroethanol
(TCOH)

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Trichloroethanol-
glucuronide

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X





Note: Table is the same as Table 2-21 in (U.S. EPA. 2014b).

Conjugation is a process that generally leads to detoxification. However, this is not the case for
TCE and many other halogenated alkanes and alkenes because they are biotransformed into
reactive metabolites. The eventual metabolite(s) of concern for TCE are formed several steps
from the initial GSH conjugate formed in the liver, which ultimately results in toxicity or
carcinogenicity in the kidney (U.S. EPA. 201 le).

Compared to the CYP oxidation pathway, there appear to be more significant sex and species
differences in TCE metabolism via the GSH pathway (U.S. EPA. 201 le). Animal data show that rates of
TCE GSH conjugation in male rats/mice are higher than females. According to some in vitro data, the
rates of DCVG production in liver/kidney cytosol are highest in humans, followed by mice, and then
rats. In vitro data also suggest that y-glutamyl transpeptidase (i.e., GGT, an enzyme involved in DCVC
production) activity in kidneys seems to be highest in rats, then humans, and then mice (U.S. EPA.
201 le). Furthermore, species-dependent enzymatic activities have been reported for the P-lyase and
FM03 enzymes (U.S. EPA. 201 leV

The majority of TCE absorbed into the body is eliminated by the metabolic pathways discussed
above. With the exception of unchanged TCE and CO2, which are excreted by exhalation, most
TCE metabolites (i.e., TCA, TCOH, GSH metabolites) are primarily excreted in urine and feces.
Elimination of TCE metabolites can also occur through the sweat and saliva, but these excretion routes
are likely to be relatively minor (U.S. EPA. 201 le).

Varying rates of TCE pulmonary excretion in humans have been observed in different studies (Chiu et
al.. 2007; Opdam. 1989; Sato et al.. 1977). The relatively long terminal half4ives observed (up to 44
hours) suggest that the lungs require considerable time to completely eliminate TCE, primarily due to
high partitioning to adipose tissues (U.S. EPA. 201 le). Various laboratories have studied the urinary
elimination kinetics of TCE and its major metabolites in humans and rodents. Animal studies have
shown that rodents exhibit faster urinary elimination kinetics than humans, with demonstrated

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elimination half-lives of just over 50 hours in humans and only approximately 16 hours in rats (Ikeda
and Imarrmra. 1973).

3,2,2,1 Physiologically-Based Pharmacokinetic (PBPK) Modeling Approach

Given the complicated metabolic profile of TCE, understanding the relationship between the external
dose/concentration (i.e., exposure) and internal dose at the target organ of interest is critical to
quantifying potential risk(s) because internal dose is more closely associated with toxicity at the target
tissue (	006). Predictions of internal dose in chemical risk assessments are achieved by

employing PBPK modeling.

PBPK models use a series of mathematical representations to describe the absorption, distribution,
metabolism and excretion of a chemical and its metabolites. Because PBPK modeling assumes that the
toxic effects in the target tissue are closely related to the internal dose of the biologically active form of
the chemical, knowledge about the chemical's mode of action guides the selection of the appropriate
dose metric. Traditional risk estimates based on applied dose carry higher uncertainties than those based
on PBPK-derived internal dose metrics. This reduction in uncertainty and the versatility of PBPK
approaches have resulted in a growing interest to use these models in risk assessment products (U.S.

06).

U.S. EPA developed a peer-reviewed comprehensive Bayesian PBPK model-based analysis of TCE and
its metabolites in mice, rats and humans (	). This model is briefly discussed below to

provide clarity on how the PBPK modeling was used to estimate the PBPK-derived HECs. For all PBPK
model files, including inputs and outputs of all model runs, see [PBPKModel andReadMe (zipped).
Docket: EPA-HQ-OPPT-2019-0500].

Physiological, chemical, in vitro and in vivo data were considered when building the PBPK model,
including many studies in animals and humans that quantified TCE levels in various tissues following
oral and inhalation exposures. Some of these studies provided key data/ parameters for the calibration of
the PBPK model used in the IRIS assessment (	). All of this information was used to

build a model that was able to predict different dose metrics as measures of potential TCE toxicity. Each
dose-metric was developed to evaluate a different metabolic pathway/target organ effect based on the
dose-response analysis and understanding of metabolism (Table 3-5 and Figure 3-4).

In general, an attempt was made to use tissue-specific dose-metrics representing particular pathways or
metabolites identified from reasonably available data on the role of metabolism in toxicity for each
endpoint (discussed in more detail below). The selection was limited to dose metrics for which
uncertainty and variability could be adequately characterized by the PBPK model. For most endpoints,
sufficient information on the role of metabolites or mode of action was not available to identify likely
relevant dose metrics, and more upstream metrics representing either parent compound or total
metabolism had to be used.

Table 3-5 List of All of the PBPK-Modeled Dose Metrics Used in the TCE IRIS Assessment

Dose-Metric
Identifier

Dose-Metric Definition

ABioactDCVCBW34

Amount of DCVC bioactivated in the kidney per unit adjusted body weight

ABioactDCVCKid

Amount of DCVC bioactivated in the kidney per unit kidney mass

AMetGSHBW34

Amount of TCE conjugated with GSH per unit adjusted body weight

AMetLivlBW34

Amount of TCE oxidized in liver per unit adjusted body weight

AMetLivOtherB W34

Amount of TCE oxidized to metabolites other than TCA or TCOH per unit adjusted body weight

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AMetLivOtherLiv

Amount of TCE oxidized to metabolites other than TCA or TCOH per unit liver weight

AMetLngBW34

Amount of TCE oxidized in respiratory tract per unit adjusted body weight

AMetLngResp

Amount of TCE oxidized in respiratory tract per unit respiratory tract tissue

AUCCBld

Area under the curve of venous blood concentration of TCE

AUCCTCOH

Area under the curve of blood concentration of TCOH

AUCLivTCA

Area under the curve of the liver concentration of TCA

TotMetabBW34

Total amount of TCE metabolized per unit adjusted body weight

T otOxMetabB W3 4

Total amount of TCE oxidized per unit adjusted body weight

TotTCAInBW

Total amount of TCA produced

For developmental toxicity endpoints, the TCE PBPK model did not incorporate a pregnancy model to
estimate the internal dose of TCE in the developing fetus. In this case, the maternal dose-metric was
used as the surrogate measure of target tissue dose in the developing fetus. A complete description of the
TCE PBPK model, including the rationale for parameter choices in animals and humans, choice of dose
metric, and experimental information used to calibrate and optimize the model is found in the TCE IRIS
assessment (	).

As shown in Figure 3-4 and Figure 3-5, several steps were needed to derive the PBPK-derived HECs
used in this assessment. First, the rodent PBPK model was run to estimate rodent internal dose Points of
Departure (idPODs) for the applied dose PODs (i.e., LOAEL, NOAEL, or BMDL) that were identified
in the TCE IRIS assessment. Separately, the human PBPK model was run for a range of continuous
exposures from 0.1 to 2,000 ppm or 0.1 to 2,000 mg/kg-bw/day to establish the relationship between
human exposure air levels and internal dose for the same dose-metric evaluated in the rodent PBPK
model. This relationship was used to derive Human Equivalent Concentrations (HECs) and Human
Equivalent Doses (HEDs) corresponding to the idPOD by interpolation (	).

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Distribution (separate
uncertainty and variability)

Figure 3-4 Dose-Response Analyses of Rodent Non-Cancer Effects Using the Rodent and Human
PBPK Models

Notes: Figure adapted from Figure 5-2 (Chapter 5, TCE IRIS assessment) ( IS. EPA. 201 le). Square nodes indicate point
values, circle nodes indicate distributions and the inverted triangle indicates a (deterministic) functional relationship.

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Rodent internal
dose

Uncertain *
variant*
¦ d,sW^llon

Human internal
dose'

Uncertainty &

variability

distribution

id POD J

Human inhalation
^exposure (ppm)

, Lower 99*
percentile

=HECc

Study dose groups

LOAEL /
NOAEL

Figure adapted from Figure 5-3 (Chapter 5,
TCE IRIS assessment)

Notes: When using benchmark dose estimates,
the idPOD is the modeled BMDL in
internal dose units.

Figure 3-5 Example of HEC99 Estimation through Interpecies, Intraspecies and Route-to- Route
Extrapolation from a Rodent Study LQAEL/NOAEL

The rodent population model was designed to characterize study-to-study variation and used median
values of dose-metrics to generate idPODs. The rodent PBPK model did not characterize variation
within studies and assumed that the rodent idPODs were for pharmacokinetically identical animals. The
basis of that assumption was that animals with the same sex/species/strain combination were considered
pharmacokinetically identical and represented by the group average. In practice, the use of median or
mean internal doses for rodents did not make much difference except when the uncertainty in the rodent
dose-metric was high ( J.S. EPA. 2011 e).

On the other hand, the human population model characterizes toxicokinetic uncertainty and individual-
to-individual variation and used median, 95th and 99th percentile values of dose- metrics to general
human idPODs. The 50th, 95th, or 99th percentile of the combined uncertainty and variability distribution
of human internal doses was used to derive the HEC/HED50, HEC/HED95 or ITEC/HED99 estimates,
respectively. The HEC95 and HEC99 were interpreted as being the concentrations of TCE in air for which
there is 95% and 99% likelihood, respectively, that a randomly selected individual will have an internal
dose less than or equal to the idPOD derived from the rodent study. HED values represent the same
likelihood forgiven administered doses of TCE. This risk evaluation presents both HEC/HED50 and
HEC/HED99 POD values.

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3.2.3 Hazard Identification

3.2.3.1 Non-Cancer Hazards

EPA previously identified human health hazard for the below endpoints in (	) and (

E	). Key and supporting studies from those publications that were used for derivation of tissue-

specific PODs were reviewed along with any newer studies identified through EPA's updated literature
search beginning with studies published after the TCE IRIS assessment (	). A short

summary of the overall database and short details on any older key studies or relevant new studies are
provided here; details on all reviewed studies can be found in [Data Extraction for Human Health
Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500],

3,2,3.1.1 Liver toxicity

Animals and humans exposed to TCE consistently experience liver toxicity. Specific effects include
the following structural changes: increased liver weight, increase in deoxyribonucleic acid (DNA)
synthesis (transient), enlarged hepatocytes, enlarged nuclei, and peroxisome proliferation.

The role of metabolites is important but not well understood. Many investigators have dosed animals
with TCE, as well as with many of its metabolites to determine the role and potency of each in terms
of target organ toxicity. It appears that the oxidation pathway is important for the development of liver
toxicity, but the specific role of each metabolite (i.e., that of TCA, DCA, and chloral hydrate), as well
as the parent TCE, is unclear.

EPA did not identify any new repeat-dose experimental studies in animals or human epidemiological
studies that would contribute significant additional hazard information for this endpoint. Therefore,
EPA relied primarily on conclusions from the 2014 TSCA Work Plan Chemical Risk Assessment (U.S.
1	).

Human Data

Several human studies (including those in TCE degreaser operations) reported an association between
TCE exposure and significant changes in serum liver function tests used in diagnosing liver disease,
or changes in plasma or serum bile acids. There was also human evidence for hepatitis accompanying
immune-related generalized skin diseases, jaundice, hepatomegaly, hepatosplenomegaly, and liver
failure in TCE-exposed workers (\ v < < \ IVI 1^). Cohort studies examining cirrhosis and either
TCE exposure or solvent exposure did not generally identify a statistically significant association, but
due to limitations in this database these studies do not rule out an association between TCE and liver
disorders/toxicity (	). A case study published after the 2011 IRIS Assessment reported

TCE hypersensitivity-induced liver damage (Jung et ai.! ).

Animal Data

The 2014 TSCA Work Plan Chemical Risk Assessment (	>) reviewed many oral and

inhalation studies in rats and mice. Studies in animals exposed to TCE reported increased liver weight, a
small, transient increase in DNA synthesis, enlarged hepatocytes, increased size of nuclei of liver cells,
and proliferation of peroxisomes (	). Dose-responsive increases in relative liver weight

(compared to body weight) were observed both following administration of TCE for 6 weeks via
gavage (Buben and O'Flaht 85) and for up to 120 days via inhalation (Woolhiser et ai. 2006;
Kiellstrand et ai. 1983). Hypertrophy, histopathology, cytotoxicity, and altered serum biochemistry
were also observed in mice in (Buben and O'Flal 985) and (Kiellstrand et ai. 1983). Increased
liver weight was additionally observed in (Boverhof et ai. 2013). identified in the EPA literature

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search, following 6hr/day inhalation exposure to a single concentration level (lOOOppm) of TCE for 4
weeks.

3.2.3.1.2	Kidney toxicity

Studies in both humans and animals have shown changes in the proximal tubules of the kidney
following exposure to TCE. DCVC (and to a lesser extent other metabolites) appears to be responsible
for kidney damage and kidney cancer following TCE exposure (	). Toxicokinetic

data suggest that the TCE metabolites derived from GSH conjugation (in particular DCVC) can be
systemically delivered or formed in the kidney. Importantly, DCVC-treated animals showed the same
type of kidney damage as those treated with TCE (	).

EPA did not identify new any repeat-dose experimental studies in animals or human epidemiological
studies that would contribute significant additional hazard information for this endpoint. Therefore,
EPA relied primarily on conclusions from the 2014 TSCA Work Plan Chemical Risk Assessment (U.S.

E 14b).

Human Data

Occupational studies showed increased levels of kidney damage (proximal tubules) and end-stage
renal disease in TCE-exposed workers. Human studies reported increased excretion of urinary proteins
among TCE-exposed workers when compared to unexposed controls. While some of these studies
included subjects previously diagnosed with kidney cancer, other studies report similar results in
subjects who are disease free (	)

Animal Data

In animal studies, renal toxicity was evident in both rats and mice following inhalation or gavage
exposures. Maltoni and Cotti (1986) identified pathological changes in the renal tubule of rats following 1-
2 years of either oral or inhalation exposure. Similar changes were also observed in a chronic gavage study
in female mice conducted by NCI, (NCI. 1976). however that study scored Unacceptable in EPA data
quality evaluation due to confounding mortality. The toxicity included damage to the renal tubules (e.g.,
both cytomegaly and karyomegaly). In a chronic gavage study, kidney toxicity was observed in almost
100 percent of rodents at high doses (NTP. 1988). Under inhalation exposure scenarios, male rats were
more susceptible than female rats or mice to kidney toxicity. As noted earlier, this toxicity is likely
caused by DCVC formation, with possible roles for TCOH and TCA (I v H \ JO I I ^). Increased
relative kidney weight compared to body weight was also observed in both mice and rats following
inhalation exposure over several weeks to months (Boverhof et al. JO I Woolhiser et ai. 2006;
Kiellstrand et al.. 1983).

3.2.3.1.3	Neurotoxicity

Neurotoxicity has been demonstrated in animal and human studies under both acute and chronic
exposure conditions (	). Due to the effects on the nervous system, TCE was initially

synthesized for use as an anesthetic in humans in the early part of the 20th century.These anesthetic-like
effects occurred at high concentrations. CNS depression has been consistently observed following
acute exposure of humans to TCE (see Section 3.2.3.1.7).

Among newer studies not previously discussed in (	), a single repeat-dose

experimental study in rats (Liu et al. ^ ) along with a few epidemiological studies that identified
specific neurological outcomes were identified in EPA's literature search. These studies only add to
and do not contradict the hazard conclusions from the 2014 TSCA Work Plan Chemical Risk
Assessment (	14b). Therefore, EPA primarily relied on the previous hazard conclusions.

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Human Data

Evaluation of the human studies has reported the following TCE-induced neurotoxic effects:
alterations in trigeminal nerve and vestibular function, auditory effects, changes in vision, alterations
in cognitive function, changes in psychomotor effects, and neurodevelopmental outcomes (

201leV

Multiple epidemiological studies in different populations have reported TCE-induced abnormalities in
trigeminal nerve function in humans, with a few studies not reporting any association (U.S. EPA.
201 le). The strongest evidence of human neurological hazard is for observed changes in trigeminal
nerve function or morphology and impairment of vestibular function in a High quality study on workers
exposed to TCE for a mean of 16 years (Ruiiten et al. 1991). Fewer and more limited epidemiological
studies are suggestive of TCE exposure being associated with delayed motor function, and changes in
auditory, visual, and cognitive function or performance, and neurodevelopmental abnormalities (U.S.
* * \

Human studies have consistently reported vestibular system-related symptoms such as headaches,
dizziness, and nausea following TCE exposure. Although these symptoms are subjective and self-
reported, these effects have been reported extensively in human chamber, occupational, and
geographic-based/drinking water studies (	). Additionally, several newer

epidemiological studies have found an association between TCE exposure and neurodegenerative
disorders such as Amyotrophic Lateral Sclerosis (Bove et al.. 2014a) and Parkinson's disease (Bove et
al.. 2014b; Goldman et al.. ).

Animal Data

The 2014 TSCA Work Plan Chemical Risk Assessment (	i) reviewed many animal

studies reporting a variety of neurotoxic effects under different exposure conditions. Animal studies
have reported the following TCE-induced neurotoxic effects: morphological changes in the trigeminal
nerve, disruption of the auditory system, visual changes, structural or functional changes in the
hippocampus, sleep disturbances and changes in psychomotor effects (	). Key and

supporting studies considered in this risk evaluation identified significant decreases in wakefulness
following 6 weeks of TCE inhalation exposure (Arito et al.. 1994) and demyelination of the
hippocampus following 8 weeks of drinking water exposure (Isaacson et z 3) in rats. Neuronal
degeneration (Gash et al.. 2008) and diminished sciatic nerve regeneration (Kiellstrand et al.. 1987)
were also observed following TCE exposure in rodents, however those studies scored Low and
Unacceptable, respectively in data quality evaluation. More recent studies have observed both sedative
(Wilmer et al.. 2014) and stimulatory effects (Shelton and Nicholson. 2014) of TCE via inhalation at
doses at or above 5000 ppm. Rats administered TCE via gavage for 6 weeks demonstrated loss of
dopaminergic neurons at 500 and 1000 mg/kg-day, with changes in behavior and reduced
mitochondrial activity with increased oxidative stress observed at 1000 mg/kg-day (Liu et al.. 2010).

3.2.3.1.4 Immunotoxicity (including sensitization)

Immune-related effects following TCE exposures have been observed in both animal and human
studies. In general, these effects were associated with inducing enhanced immune responses as
opposed to immunosuppressive effects. Of concern are the immune-related and inflammatory effects
reported in TCE-exposed animals and humans. These effects may influence a variety of other
conditions of considerable public health importance, such as cancer and atherosclerosis (U.S. EPA.
201 le).

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EPA's literature search identified a single acute inhalation study in rats that identified a novel endpoint
for impaired response to infection (Selerade and Gilmour. 2010). This study was discussed in the TCE
IRIS assessment (	) but was not included in the 2014 TSCA Work Plan Chemical

Risk Assessment (	014b). All other studies supported the hazard conclusions of the 2014

TCE Risk Assessment (	). Therefore, EPA primarily relied on the previous hazard

conclusions for all other endpoints.

Human Studies

Studies have reported a relationship between systemic autoimmune diseases, such as scleroderma, and
occupational exposure to TCE. The TCE IRIS assessment (\ v < < \ JO I I performed a meta-
analysis of a number of human studies evaluating a possible connection between scleroderma and TCE
exposure. Results indicated a significant odds ratio (OR) in men, whereas women showed a lower but
not significant OR. These results may not reflect a true gender difference because the incidence of this
disease is very low in men (approximately one per 100,000 per yr) and somewhat higher in women
(approximately one per 10,000 per yr). In addition, these results may be affected by gender-related
differences in exposure prevalence, the reliability of the exposure assessment, gender-related
differences in susceptibility to TCE toxicity or chance (\ c. < ^ \ JO i I ^).

Increased levels of human inflammatory cytokines have been observed in both workers exposed
occupationally to TCE and infants exposed to TCE via indoor air. (U.S. EPA. 201 le). These findings
were supported by studies in mice (described below) in which short exposures to TCE resulted in
increased levels of inflammatory cytokines.

The epidemiological database also provides evidence of immunosuppression based on reduced IgG
antibody levels in TCE-exposed workers (Zhang et at.. 2013).

Animal Data

Numerous studies have shown increased autoimmune responses in autoimmune-prone mice, including
changes in cytokine levels similar to those reported in human studies, with more severe effects,
including autoimmune hepatitis, inflammatory skin lesions, and alopecia, manifesting at longer
exposure periods (	). Key studies identified evidence of autoimmunity from chronic

TCE exposure in both non-autoimmune prone (Keil et at.. 2009) and autoimmune prone (Kaneko et at..
2000) mice. Evidence of localized immunosuppression has also been reported in mice and rats
(Boverhof et at.. 2013; Woolhiser et at.. 2006; Sanders et at.. 1982). Support for immunotoxicity
hazard is further supported by decreased thymus weight and cellularity in the non-autoimmune prone
mice following up to 30 weeks of drinking water exposure (Kelt et at.. 2009).

Inhalation exposure to TCE has been shown to suppress pulmonary host defenses and enhance
susceptibility to respiratory infection in mice co-exposed to aerosolized pathogenic bacteria. Increased
mortality was observed post-infection following exposure to TCE concentrations of 50ppm or greater,
with corresponding dose-dependent effects on bacterial clearance, percentage of infected mice, and
alveolar phagocytosis (S el grade and Gitmour. 2010).

Sensitization / Hypersensitivity

Limited epidemiological data do not support an association between TCE exposure and allergic
respiratory sensitization or asthma. However, there have been a large number of case reports in TCE-
exposed workers developing a severe hypersensitivity skin disorder, distinct from contact dermatitis,
and often accompanied by systemic effects (e.g., hepatitis, lymph node changes, and other organ

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effects). These effects appeared after inhalation exposures ranging from less than 9 to greater than 700
ppm TCE. Similar sensitization/hypersensitivity effects have been observed in guinea pigs and mice
following TCE exposure via drinking water (U.S. EPA. ).

3.2.3.1.5 Reproductive toxicity

Both the epidemiological and animal studies provide suggestive, but limited, evidence of adverse
outcomes to female reproductive outcomes. However, much more extensive evidence exists in support
of an association between TCE exposures and male reproductive toxicity (	).

The reasonably available human data that associate TCE with adverse effects on male reproductive
function are limited in sample size and provide little quantitative dose data. However, the animal data
provide strong and compelling evidence for TCE-related male reproductive toxicity. Strengths of the
animal database include the presence of both functional and structural outcomes, similarities in adverse
treatment-related effects observed in multiple species, and evidence that metabolism of TCE in male
reproductive tract tissues is associated with adverse effects on sperm measures in both humans and
animals. Additionally, some aspects of a putative mode of action (e.g., perturbations in testosterone
biosynthesis) appear to have some commonalities between humans and animals (	).

EPA did not identify any new repeat-dose experimental studies in animals or human epidemiological
studies that would contribute significant additional hazard information for this endpoint. Therefore,
EPA relied primarily on conclusions from the 2014 TSCA Work Plan Chemical Risk Assessment (U.S.
).

Human Data

Most human studies support an association between TCE exposure and alterations in sperm density
and quality, as well as changes in sexual drive or function and serum endocrine levels. Chia et al.
(1996) observed decreased normal sperm morphology along with hyperzoospermia in male workers
averaging over five years occupational exposure. Fewer epidemiological studies exist linking decreased
incidence of fecundability (time-to-pregnancy) and menstrual cycle disturbances in women with TCE
exposures (I v << \ JO lie).

Animal Data

Laboratory animal studies provide evidence for similar effects, particularly for male reproductive
toxicity. These animal studies have reported effects on sperm, libido/copulatory behavior, and serum
hormone levels, although some studies that assessed sperm measures did not report treatment-related
alterations (I v << \	). Identified key and supporting studies have observed TCE-related

histopathological lesions in the testes or epididymides, altered in vitro sperm-oocyte binding, and
increased incidence of irregular sperm in rodents (Kan et al.. 2007; Xu et al.. 2004; Kumar et al.. 2001;
Kumar et al.. 2000). Forkert et al. (2002) also observed effects on the epididymis, however that study
was Unacceptable in data quality evaluation. Similarly, decreased in vitro fertilization resulted from
exposure of male rats to TCE in drinking water in one study (Puteaux et al.. 2004). however that
study scored a Low in data quality evaluation.

Fewer animal studies are reasonably available for the female reproductive toxicity endpoint. While in
vitro oocyte fertilizability has been reported to be reduced as a result of TCE exposure in rats, a
number of other laboratory animal studies did not report adverse effects on female reproductive
function effects (	). The key study Narotsky et al. (1995) observed delayed parturition

in female rats. Exposure of either males or females to TCE in feed resulted in reduced successful
copulation and an associated decrease in the number of live pups and litters (George et al.. 1986).

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3.2.3.1.6 Developmental Toxicity

An evaluation of the human and animal developmental toxicity data suggests an association between
pre- and/or postnatal TCE or TCE metabolite exposures and potential developmental adverse
outcomes. Heart malformations observed after developmental TCE exposure in animal studies were
identified in the 2014 TSCA Work Plan Chemical Risk Assessment (U.S. EPA. 2014b) as the most
sensitive developmental toxicity endpoint for dose-response analysis. The developmental toxicity
information is briefly described below, including information from the 2014 assessment and more
recent studies.

For developmental toxicity other than congenital heart defects EPA did not identify any repeat-dose
experimental studies in animals or human epidemiological studies that would contribute significant
additional information for this hazard. Therefore, EPA relied primarily on conclusions from the 2014
TSCA Work Plan Chemical Risk Assessment (	b) for these other endpoints. For

congenital heart defects, EPA evaluated more recent epidemiological studies, mechanistic studies, and
a single experimental animal study that provide conflicting evidence for this endpoint.

Human Data

The 2014 TSCA Work Plan Chemical Risk Assessment (	•) evaluated numerous human

studies that examined the possible association of TCE with various developmental outcomes, including
prenatal (e.g., spontaneous abortion and perinatal death, decreased birth weight, and congenital
malformations) and postnatal (e.g., growth, survival, developmental neurotoxicity, developmental
immunotoxicity, and childhood cancers) health outcomes. Most of these were occupational
epidemiology studies. In addition, geographically-based epidemiological studies have been conducted
in various parts of the United States, including Arizona (Tucson Valley), Colorado (Rocky Mountain
Arsenal), Massachusetts, New York (Endicott), Camp Lejeune, North Carolina and Milwaukee,
Wisconsin (\ ^ \ 1:0 i 1^).

The Endicott, New York, and the Camp Lejeune studies focused on reproductive and developmental
outcomes. Some of these studies have reported associations between parental exposure to TCE and
spontaneous abortion or perinatal death, and decreased birth weight. However, other occupational and
geographically-based studies have failed to detect a positive association between TCE exposure and
developmental toxicity in humans (	).

There have been some epidemiological studies that have consistently reported an increased incidence of
birth defects in TCE-exposed populations. For instance, ATSDR has conducted studies at Camp
Lejeune, North Carolina, where individuals were exposed to VOC-contaminated drinking water
(Ruckart et ai. 2014. 2013). TCE was one of the main contaminants found in the drinking water.
Ruckart et al. found an association between neural tube defects and TCE exposure above 5 ppb during
the first trimester of pregnancy, however either negative or null associations were identified between
TCE exposure and other developmental effects (e.g., reduced birth weight, oral cleft defects). Yauck et
al. (2004) observed a strong relative risk estimate for cardiac malformations in infants from Milwaukee,
Wisconsin born to TCE-exposed mothers aged 38 years or older. In addition to older age, increased risk
was also independently associated with other confounders including alcohol use, hypertension, and
diabetes. Forand et al., ( ) (an update for the Endicott, NY community) reported significant relative
risk estimates for low birth weight, small for gestational age, and cardiac defects. See the below section
for further discussion of congenital heart defects.

Other studies have also identified an association between exposure to TCE exposure and

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developmental effects. One study reported increased risk of spina bifida to offspring of TCE-exposed
mothers (Swartz et al. 2015). and both statistically significant and non-significant associations have
been observed between exposure to the TCE metabolites trichloracetic acid and trichloroethanol with
various outcomes including oral clefts, urinary tract malformations, and limb defects (Cordier et al..
2012). In contrast, (Brender et al.. 2014) found no statistically significant association with neural tube
defects, spina bifida, anenocephaly, any oral cleft, cleft palate, cleft lip with or without cleft palate, any
limb deficiency, or longitudinal or transverse limb deficiencies. The study did identify an increased risk
of septal heart defects (see below section) in older mothers, however. As for human developmental
neurotoxicity, the available studies collectively suggest that the developing brain is susceptible to TCE
toxicity. These studies have reported an association with TCE exposure and CNS birth defects and
postnatal effects such as delayed newborn reflexes, impaired learning or memory, aggressive behavior,
hearing impairment, speech impairment, encephalopathy, impaired executive and motor function and
attention deficit (	'1 le).

Animal Data

Many of the TCE-related developmental effects reported in humans have been observed in key and
supporting animal studies: increased fetal resorptions (Narotsky et al.. 1995). developmental
neurotoxicity (Fredriksson et al.. 1993; Taylor et al.. 1985). developmental immunotoxicity (Peden-
Adams et al.. 2006). and congenital heart defects anomalies (Johnson et al.. 200.'; Riwsom et al..
1993). Healy et al. (1982) observed increased resorptions, skeletal abnormalities, and decreased fetal
weight, but the study scored Unacceptable in data quality evaluation. Some of the observed effects
appear to be strain-specific (	). Among newer studies identified in the EPA literature

search, increased locomotor and exploratory activities were observed following drinking water
exposures to mice during nervous system development (Blossom et al.. 2013). however these effects
were not consistently dose-responsive.

Congenital Heart Defects

In vivo animal studies in rats and chicks have identified an association between TCE exposures and
cardiac defects17 in the developing embryo and/or fetus (	). The 2014 TSCA Work

Plan Chemical Risk Assessment (U.S. EPA. 2014b) identified congenital heart defects following TCE
exposure via drinking water as the most sensitive human health endpoint for dose-response analysis
and risk evaluation based on data from (Johnson et al.. 2003) and (Dawson et al.. 1993). despite public
criticisms of insufficient data reporting and other issues in these studies. Mechanistic studies have also
examined various aspects of the induction of cardiac malformations. Human studies have also
identified statistically significant increased risk of developmental cardiac defects following TCE
exposure (Brender et al JO I I; I < irand et al.. 2012; Goldberg et al.. 1990). The critical window for
cardiac development is 1-2 weeks for rodents, 1-2 weeks for chickens, and from the 3rd to the 8th week
for the human fetus.

The scientific literature also has examples of relatively well-conducted studies in rats and mice that did
not observe an increase in TCE-induced cardiac malformations. Most prominent among these include an
inhalation study in rats (Carney et al.. 2006) and an oral gavage study in rats (Fisher et al.. 2001). Of
note however, while (Fisher et al.. 2001) did not report statistically-significant increases in combined

17 "Cardiac" (or "heart") "defects," "malformations," and "abnormalities" are used throughout this risk evaluation to refer to
adverse findings in the developing heart. These terms, in addition to "congenital heart defects" (CHD), are used in
experimental animal, epidemiological, and/or clinical studies to characterize or categorize various morphological
cardiovascular outcomes in the fetus or neonate. For the purpose of this risk evaluation, they are used interchangeably.

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cardiac and cardiovascular effects, there was a very high background incidence of cardiovascular defects
in soybean oil-control rats and the authors did observe a 19% increase in cardiac-specific defects (per-
litter, significance not calculated) following TCE treatment compared to controls. During the
development of this risk evaluation, a study was completed that also did not identify a statistically
significant increase in cardiac defects following TCE exposure via drinking water (Charles River
Laboratories. 2019). Several epidemiological studies also report either negative (Lagakos et ai. 1986) or
equivocal (Yauck et al. 200 i; Hove et al. 1995) statistical associations between TCE exposure and
heart defects. Gilboa et al. (2012) identified a statistically significant association of perimembranous
ventricular septal defects with exposure to chlorinated solvents as a class, but not to TCE alone.

In previous assessments EPA concluded that the weight of evidence supports TCE exposure posing a
potential hazard for congenital malformations, including cardiac defects in offspring (Makris et al.. 2016;
I v i i \ ^ n lb, 201 I ^). Given both the conflicting results and the publication of newer animal,
epidemiological, and in vitro studies since the completion of the 2014 TCE Risk Evaluation, EPA re-
evaluated the weight of evidence for congenital heart defects (see Section 3.2.4.1.6 and Appendix G).

3.2.3.1.7 Overt Toxicity Following Acute/Short Term Exposure

Acute studies in animals consist of single exposures at high doses specifically designed for assessing
the dose at which lethality occurs or for examining overt toxicity. The interim acute exposure
guideline levels (AEGLs) document for TCE was consulted and used in this assessment to briefly
summarize the acute toxicity data (NAC/AEGL. 2009).

In humans, TCE odors can be detected at concentrations of >50 ppm. It was once commonly used as
an anesthetic agent with concentrations ranging from 5,000 to 15,000 ppm for light anesthetic use and
from 3,500 to 5,000 ppm for use as an analgesic. Information on the toxicity of TCE in humans comes
from either case reports in the medical/occupational literature or experimental human inhalation
studies. Lethality data in humans have been reported following accidental exposure to TCE. However,
there is insufficient information about the exposure characterization of these incidents (NAC/AEGL.
2009).

Human inhalation studies have shown that acute exposure to TCE results in irritation and central
nervous system (CNS) effects in humans. Mild subjective symptoms and nose and throat irritation
were reported by human volunteers exposed to 200 ppm TCE for 7 hrs/day on the first day of exposure
during a 5-day exposure regimen. The study also reported minimal CNS depression following TCE
exposure (NAC/AEGL. 2009). Laboratory studies have additionally demonstrated acute effects of
TCE on the respiratory tract in the form of both localized irritation and broad fibrosis, likely
dependent on oxidative metabolism. (	).

CNS depression and effects on neurobehavioral functions were seen in human volunteers exposed to
1,000 ppm TCE for a 2-hr period. In the same studies, volunteers were also exposed to 100 or 300
ppm TCE for 2 hrs. Some subjects had similar CNS effects at the middle concentration (300 ppm),
with no such effects observed at the 100 ppm. A different study reported slight to marginal
neurobehavioral effects after exposure to 300 ppm TCE for 2.5 hrs. Cardiac arrhythmias have also
been reported in humans exposed to high concentration of TCE. Several animal studies have reported
neurobehavioral effects and the potential for inducing cardiac sensitization following acute inhalation
exposure to TCE (NAC/AEGL. 2009).

The NIOSH Skin Notation Profile for TCE (Hudson and Dotson. 2017) summarizes data providing
evidence for skin irritation and/or corrosion from dermal TCE exposure, with effects including rashes,

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blistering, and burning sensations. Eye effects and CNS effects also resulted following simultaneous
vapor inhalation along with percutaneous penetration. Skin irritation potential varied greatly among
individuals in volunteer studies, with some exhibiting extreme pain and others hardly reporting any
effects. Studies on both humans and animals demonstrate that TCE is a moderate skin sensitizer, with
hypersensitivity reactions observed following exposure to both TCE and various metabolites.

3.2,3.2 Genotoxicity and Cancer Hazards

3.2.3.2.1	Kidney cancer

The TCE IRIS assessment concluded that TCE is "carcinogenic to humans" based on convincing
evidence of a causal relationship between TCE exposure in humans and kidney cancer. A review of
TCE by the International Agency for Research on Cancer (IARC) also supported this conclusion
(IARC. 2014). The carcinogenic classification was based on a review of more than 30 human studies,
including studies in TCE degreasing operations, and meta-analyses of the cohort and case- control
studies. Relative risk estimates for increased kidney cancer were consistent across a large number of
epidemiological studies of different designs and populations from different countries and industries
(Appendix C,(	). This strong consistency of the epidemiologic data on TCE and

kidney cancer argues against chance, bias, and confounding as explanations for the elevated kidney
cancer risks (	).

Cancer bioassays with TCE in animals (i.e., both gavage and inhalation exposure routes) did not show
increased kidney tumors in mice, hamsters, or female rats, but did show a slight increase in male rats.
Kidney tumors in rats are relatively rare (\ v < < \ JO I I ^).

The toxicokinetic data and the genotoxicity of DCVC further suggest that a mutagenic mode of action
is involved in TCE-induced kidney tumors, although cytotoxicity followed by compensatory cellular
proliferation cannot be ruled out. As for the mutagenic mode of action, both genetic polymorphisms
(GST pathway) and mutations to tumor suppressor genes have been hypothesized as possible
mechanistic key events in the formation of kidney cancers in humans (	)

3.2.3.2.2	Liver cancer

U.S. EPA concluded that TCE exposure causes liver tumors in mice but not rats and the meta-analysis
of human data on liver and gallbladder/biliary passages indicated "...a small, statistically significant
increase in risk". Multiple TCE metabolites (i.e., and thus pathways) likely contribute to TCE-induced
liver tumors (	).

Previous meta-analyses of the cohort, case-control, and community (geographic) studies reporting liver
and biliary tract cancer, primary liver cancer, and gallbladder and extra-hepatic bile duct cancer (see
Appendix C in (	)) reported a small, statistically significant summary relative risk

(RRm, overall RR from meta-analysis) for liver and gallbladder/biliary cancer with overall TCE
exposure. However, the meta-analyses reported a lower, nonstatistically significant RRm for primary
liver cancer when using the highest exposure groups (	).

With respect to liver carcinogenicity, TCE and its oxidative metabolites TCA, DCA, and CH are
clearly carcinogenic in mice, with strain and sex differences in potency. Data in other laboratory animal
species are limited; thus, except for DCA which is carcinogenic in rats, inadequate evidence exists to
evaluate the hepatocarcinogenicity of TCE and its metabolites in rats or hamsters (	).

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3.2.3.2.3	Cancer of the immune system

Human studies have reported cancers of the immune system resulting from TCE exposure. Lymphoid
tissue neoplasms arise in the immune system and result from events that occur within immature
lymphoid cells in the bone marrow or peripheral blood (leukemias), or more mature cells in the
peripheral organs (non-Hodgkin's lymphoma). The broad category of lymphomas can be divided into
specific types of cancers, including non-Hodgkin's lymphoma, Hodgkin lymphoma, multiple
myeloma, and various types of leukemia (e.g., acute and chronic forms of lymphoblastic and myeloid
leukemia). Leukemia during childhood has been observed in a number of studies in children exposed
to TCE, however this association has not been confirmed (I v < < \ 201 I e).

One of the three cancers for which the TCE IRIS assessment based its cancer findings was non-
Hodgkin's lymphoma (NHL) (the other two being kidney and liver cancer) (	). The

human epidemiological database identifies a statistically significant association between TCE exposure
and NHL (Appendix C, (	). Further support comes from animal studies reporting rates

of lymphomas and/or leukemias following TCE exposure (I. c. < ^ \ 201 I ^).

3.2.3.2.4	Other cancers

Reproductive System

The effects of TCE on cancers of the reproductive system have been examined for males
and females in both epidemiological and experimental animal studies. The epidemiological
literature includes data on prostate in males and cancers of the breast and cervix in females. The
experimental animal literature includes data on prostate and testes in male rodents; and uterus,
ovary, mammary gland, vulva, and genital tract in female rodents. The evidence for these cancers is
generally not robust (	).

Other cancers

There is limited evidence of increased risk for esophageal cancer following TCE exposure in males only.
The reasonably available evidence is not statistically sensitive enough for informing quantitative
evaluations of esophageal cancer risk from TCE. There is some evidence of association for bladder or
urothelial cancer and high cumulative TCE exposure, however the reasonably available studies examine
multiple sites and do not completely account for potential confounding factors. In several studies
examining the relationship between TCE exposure and cancer of the brain or central nervous system
(CNS), the data does not provide strong evidence in either direction, although there is some association
of TCE exposure with CNS cancers in children (	).

3.2.4 Weight of Scientific Evidence

3.2.4.1 Non-Cancer Hazards

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of scientific evidence (WOE) conclusions
for all non-cancer endpoints other than congenital heart defects. For the previous WOE evaluations of all
other endpoints, see the 2011 EPA IRIS Assessment (	) and the 2014 TSCA Work Plan

Chemical Risk Assessment (	3).

3.2.4.1.1 Liver toxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) for this hazard.

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Animal data demonstrating increased liver weight, cytotoxicity, hypertrophy, and peroxisome
proliferation is supported by human data demonstrating changes in plasma or bile acid liver enzyme
levels and hypersensitivity-induced liver damage. Overall, liver toxicity following TCE exposure is
supported by the weight of evidence. Therefore, this hazard was carried forward for dose-response
analysis.

3.2.4.1.2	Kidney toxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) for this hazard.

The kidney is one of the more sensitive targets of TCE, with toxicity resulting from conjugative
metabolites such as DCVC. Both animal and human studies consistently observe induction of kidney
toxicity (e.g., damage to renal tubules and nephropathy) and progression of existing kidney disease.
Overall, kidney toxicity following TCE exposure is supported by the weight of evidence. Therefore, this
hazard was carried forward for dose-response analysis.

3.2.4.1.3	Neurotoxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) for this hazard.

In addition to anesthetic effects at high concentrations, human evidence concludes that TCE exposure
induces abnormalities in trigeminal nerve function, and TCE exposure has also been associated with
neurodegenerative disorders. These effects have been confirmed in animal studies which additionally
demonstrate a variety of neurological effects from TCE exposure. Overall, neurotoxicity following TCE
exposure is supported by the weight of evidence. Therefore, this hazard was carried forward for dose-
response analysis.

3.2.4.1.4	Immunotoxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) for this hazard.

Both animal and human studies demonstrate that TCE exposure can result in either autoimmune
responses or immunosuppression. There is also evidence of both systemic and localized hypersensitivity
resulting in skin sensitization and autoimmune hepatitis. Selgrade et al (2010) demonstrated reduced
response to respiratory infection. There are no other reasonably available studies that examined respiratory
immunotoxicity, however this endpoint is consistent with other data on immunosuppression. Overall,
immunotoxicity following TCE exposure is supported by the weight of evidence. Therefore, this hazard
was carried forward for dose-response analysis, including both systemic and respiratory endpoints.

There is only qualitative information available for sensitization and hypersensitivity, so this hazard was
not carried forward for dose-response analysis.

3.2.4.1.5	Reproductive toxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) for this hazard.

Both human and animal data provide strong evidence for male reproductive effects from TCE. Effects
observed include effects on sperm, male reproductive organs, hormone levels, and sexual behavior.
There is insufficient evidence for determining whether TCE contributes to female reproductive toxicity.

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Overall, male reproductive toxicity following TCE exposure is supported by the weight of evidence.
Therefore, this hazard was carried forward for dose-response analysis.

3.2.4.1.6 Developmental Toxicity

The EPA literature search (	) did not identify any new evidence that significantly

contributes to or challenges the previously established weight of evidence (WOE) conclusions for this
hazard other than for congenital heart defects.

There is substantial evidence from both animal and human studies that TCE exposure is associated with
various developmental outcomes, ranging from decreased birth weight to pre- and postnatal mortality.
Other hazards also present following developmental exposure, including developmental immunotoxicity
and developmental neurotoxicity. While the epidemiological literature does not consistently observe
developmental effects, effects that have been observed in multiple human studies have been
corroborated by animal data.

Overall, based on suggestive epidemiologic data and fairly consistent laboratory animal data,
developmental toxicity following TCE exposure is supported by the weight of evidence. Therefore, this
hazard was carried forward for dose-response analysis.

Developmental toxicity endpoints will be considered for both acute and chronic scenarios. Although
developmental studies typically involve multiple exposures, they are considered relevant for evaluating
single exposures because evidence indicates that certain developmental effects may result from a single
exposure during a critical window of development (Davis et ai. 2009; Van Raaii et ai. 2003). This is
consistent with EPA's Guidelines for Reproductive Toxicity Risk Assessment (	96) and

Guidelines for Developmental Toxicity Risk Assessment (	), which state that repeated

exposure is not a necessary prerequisite for the manifestation of developmental toxicity. This is a health
protective assumption.

Congenital Heart Defects

The congenital heart defects endpoint for TCE has been widely discussed since the release of the 2011
IRIS Assessment (	). The primary basis for this endpoint was a developmental drinking

water study in rats, (Johnson et. ai.. 2003). that has been the source of extensive controversy. The study
administered 0 ppb, 2.5 ppb, 250 ppb, 1.5 ppm, and 1100 ppm to pregnant Sprague-Dawley rats via
drinking water for the entire duration of pregnancy. On the last day of pregnancy, dams were
euthanized, and the heart and great vessels of fetuses were examined for abnormalities. The study
reported statistically significant increases in variety of cardiac defects at multiple dose levels in the
incidence of a broad array of cardiac defects. EPA considered the constellation of observed effects in
totality, as opposed to any particular individual defects.

The authors reported (Johnson et. ai.. 2005) that the study data were derived from a 6-year academic
research program and consolidated data from several cohorts. Control data were combined from 6
independent cohort experiments; the data from the highest two TCE doses had been previously
published by the laboratory (Dawson et. ai.. 1993). Although study methods were generally consistent
throughout the research program, there are potential concerns of genetic drift due to the TCE dose
groups being administered up to 6 years apart, and the control vehicle used in the Dawson et al., 1993
study was filtered tap water while distilled water was used in all subsequent study cohorts. Both
(Dawson et. al. 1993) and (Johnson et. ai.. 2003) were deficient in adequate reporting of methods and

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raw scoring data; however, many of those concerns have been alleviated by subsequent communications
to EPA (Johnsoi	08). The positive findings reported in (Dawson etal.. 1993) and (Johnson et.

al.. 2003) have not been confirmed by another laboratory, so controversy over the results remains. When
considering the totality of information provided (not only what was in the initial publications), both
(Dawson etal.. 1993) and (Johnson et. al.. 2003) received a Medium in data quality evaluation.

EPA previously published weight of evidence (WOE) analyses both as part of the 2014 TCE Risk
Assessment and as a peer-reviewed journal article (Makris et al. 2016). which concluded that the
totality of data does support congenital heart defects as a human health hazard for TCE. These WOE
analyses utilized modified Bradford-Hill criteria (Hill. 1965) to evaluate the overall evidence for
causality following study quality review. Recently, (Wikoff et al.. 2018) published a WOE analysis
focusing only on animal and epidemiological data that came to the opposite conclusion using a Risk of
Bias assessment for internal study validity. During the development of this risk evaluation, EPA
received a study sponsored by the Halogenated Solvents Industry Alliance (HSIA) (Charles River
Laboratories. 2019) that attempted to replicate the (Johnson et al.. 2003) study, examining the incidence
of developmental cardiac defects following administration of TCE to rats via drinking water. This study
was subsequently peer reviewed and published in the scientific literature.

Charles River Study

Charles River Laboratories (2019) performed a developmental toxicity study according to principles of
Good Laboratory Practice. The study authors administered TCE to pregnant Sprague-Dawley rats via
drinking water at concentrations of 0 ppm, 0.25 ppm, 1.5 ppm, 500 ppm, and 1000 ppm in reverse
osmosis-filtered water from gestation day 1 through 21. Retinoic acid (RA) served as the positive
control and was administered via gavage (3mg/ml, 5mg/kg-bw) on gestation days 6-15. The study
authors did not observe a statistically significant increase of interventricular septal defects in TCE-
treated fetuses (2.4% in negative control, 3.7% at highest dose) or any other types of cardiac defects
identified in the study.

While the results of the Charles River study ( ) results appear to contradict the results observed by
(Johnson et al.. 2003) and (Dawson et al.. 1993). EPA concludes that the Charles River study
methodology was likely of reduced sensitivity and therefore does not entirely replicate the study
conditions of those earlier studies. In short, the methodology and positive control data indicate that the
Charles River study (2019) was primarily focused on ventricular septal defects (VSDs) and therefore did
not sufficiently examine the complete range of potential cardiac defects. The Johnson study (2003)
specifically described assessment of valves and observed both valve and atrial septal defects using their
laboratory dissection and examination methodology. In contrast, while the Stuckhardt and Poppe
dissection method (1984) used by the Charles River study should allow visualization of valves, the
Charles River study did not report valve defects in any TCE group or the RA positive control group even
though many other published reports have identified valve defects following administration of TCE or
RA. Additionally, the Stuckhardt and Poppe method (1984) does not include examination of the heart
for atrial septal defects, and the Charles River study did not report any atrial septal defects in either the
RA positive control group or the TCE groups. In fact, the Charles River study (2019) observed a similar
percentage of VSDs as (Johnson et al.. 2003). Considering total VSDs, 3.5% of fetuses showed a VSD in
Charles River vs 3.8% in Johnson at the highest dose, with 1.5% in Charles River vs 2.2% in Johnson at
1.5ppm. When considering only membranous VSDs (the only type observed in the Charles River study),
observed incidences were actually higher in Charles River at the highest dose (3.5% vs 2.86%).
Meanwhile, a substantial percentage of the total cardiac defects observed in (Johnson et al.. 2003) were
valvular or atrial.

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As further indication of the potentially limited sensitivity of (Charles River Laboratories. 2019). the
defects observed from exposure to the retinoic acid (RA) positive control were also somewhat limited
compared to the broader RA literature (which did identify atrial septal defects). Additionally, the other
oral TCE study (Fisher et ai. 2001). which did not identify a statistically significant increase in cardiac
defects following TCE administration at a high dose via gavage, identified a significant number of
additional defects that match those identified in (Johnson et at.. 2003) and (Dawson etai. 1993)
(including atrial septal and valve defects). Therefore, (Charles River Laboratories. 2019) insufficiently
replicates the methodology of (Johnson et ai. 2003). and the results do not entirely contradict the
conclusions of that study. Based on these considerations along with some data reporting errors, (Charles
River Laboratories. ) received a Medium in data quality evaluation, the same as (Dawson et ai.
1993) and (Johnson et ai. 2003). For a more detailed analysis of the (Charles River Laboratories. 2019)
study, see Appendix G. 1.

While (Charles River Laboratories. 2019) was not considered a close enough replication to (Johnson et
ai. 2003) to sway the weight of evidence for the endpoint on it's own, EPA did consider (Charles River
Laboratories. 2019) to be an overall well-conducted study, and it was incorporated into the WOE
analysis for the cardiac defects endpoint along with all other relevant studies identified in the literature.

WOE Analysis

In order to address the conflicting results of the previous WOE assessments (	Jkris

et ai. 2016; Wikoff et ai. 2018). in support of this risk evaluation EPA performed another WOE
analysis. This analysis included all relevant primary literature cited in (Makris et ai. 2016). the 2014
TCE Risk Assessment (U.S. EPA. 2014b). and any additional on-topic studies identified in the
systematic review literature search (	i). Additionally, EPA also incorporated any newer

studies published after the end date of the literature search, including an in vitro mechanistic study
(Harris et ai. 2018) and the recently completed in vivo drinking water study (Charles River
Laboratories. 2019). comprising 45 studies in total (42 scoring Acceptable). After reviewing a sampling
of recent literature on systematic approaches to performing weight-of-evidence evaluation, EPA adopted
the methodology described in [Weight of Evidence in Ecological Assessment. Risk Assessment Forum.
EPA/100/R16/00. (	2016i)1. which advocates presenting evidence on a semiqualitative scale

on the basis of three evidence areas: reliability, outcome/strength, and relevance (see Appendix G.2.1 for
more details on selection of approach and methodological details).

In short, the overall grade for each study was defined by the lowest-amplitude score of each evidence
area, and those overall study grades were integrated to select a representative overall summary score for
each line of evidence (epidemiological, in vivo, or mechanistic). Independently, the area scores of each
study were averaged to obtain integrated areas scores for each line of evidence, however these were not
used to determine the overall summary score. Functionally, this scoring methodology is similar to that
used by (Wikoff et ai. 2018). although that analysis focused on data quality reliability through a risk of
bias assessment. Importantly, (Wikoff et ai. 2018) did not evaluate any mechanistic data, which may
explain the different overall conclusions between that study and this analysis. Importantly, this WOE
assessment also incorporated data on TCE metabolites, which are believed to be the toxicologically
active agent for many of the observed cardiac effects as well as other developmental outcomes.

The overall weight-of-evidence for TCE-induced congenital cardiac defects is presented in Table 3-6.
Epidemiological, toxicological and mechanistic studies were available. The epidemiology studies as a
group provide suggestive evidence for an effect of TCE on cardiac defects in humans (summary score of
+). Oral in vivo studies provided ambiguous to weakly positive (0/+) results for TCE itself, but positive
results for its TCA and DCA metabolites (+), while inhalation studies contributed negative evidence (-).

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Overall, the in vivo animal toxicity studies provided mixed, ambiguous evidence for an effect of TCE
(summary score of 0). Mechanistic studies provided strong and consistent supporting information for
effects of TCE and metabolites on cardiac development and precursor effects (summary score of ++).

The database overall was determined to be both reliable and relevant. Integration of the three evidence
areas resulted in an overall summary score of (+), demonstrating positive overall evidence that TCE may
produce cardiac defects in humans (based on positive evidence from epidemiology studies, mixed
evidence from animal toxicity studies, and stronger positive evidence from mechanistic studies).

See Appendix G.2 for the complete WOE narrative and methodology. The complete scoring table and
detailed evaluation of all studies is presented in [Data Table for Congenital Heart Defects Weight of
Evidence Analysis. Docket: EPA-HO-OPPT-2019-0500].

Table 3-6. Overall Summary Scores by Line of Evidence for Cart

Evidence Area

Summary
Score

Epidemiology studies

+

In vivo animal toxicity studies

0

Mechanistic studies

++

Overall

+

iac Defects from TCE

The differences in observed responses across studies may be partially attributed to experimental design
differences. These differential responses may also represent varying susceptibility among mammalian
species, strains, and populations. It is possible that animals showing a greater incidence of defects
following TCE exposure represent an especially susceptible population, and genetic drift may preclude a
true replication of previous study conditions (Makris et al.. 2016).

Mode of Action

A number of studies have been conducted to elucidate the mode of action for TCE-related cardiac
teratogenicity. During early cardiac morphogenesis, outflow tract and atrioventricular endothelial cells
differentiate into mesenchymal cells. These mesenchymal cells have characteristics of smooth muscle-
like myofibroblasts and form endocardial cushion tissue, which is the primordia of septa and valves in
the adult heart. Many of the cardiac defects observed in humans and laboratory species involved septal
and valvular structures. Thus, a major research area has focused on the disruptions in cardiac valve
formation in avian in ovo and in vitro studies following TCE treatment. These mechanistic studies
have revealed TCE's ability to alter the endothelial cushion development, which could be a possible
mode of action underlying the cardiac defects involving septal and valvular morphogenesis in rodents
and chickens. Other modes of actions may also be involved in the induction of cardiac malformation

2+

following TCE exposure. For example, studies have reported TCE-related alterations in cellular Ca
fluxes during cardiac development (Caldwell et al.. 2008; Selmin et al.. 2008; Collier et al.. 2003).
Of note, early stages of cardiac development are quite similar across various species (Makris et al.. 2016).
Therefore, these mechanistic data provide support to the plausibility of TCE-related cardiac effects in
humans (U.S. EPA. 201 le). EPA also notes that teratogens may function through a multitude of
pathways, often resulting in a constellation of effects. Therefore, evidence of a single dominant MOA is
not required in order for the data to support a plausible mechanism of TCE-induced congenital heart
defects.

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Several in vitro studies have observed non-monotonic dose responses in gene activation and other
molecular changes following TCE exposure at varying concentrations (Palbykin et al. 2011; Makwana
et ai. 2010). Specifically, TCE exposure induced expression of oxidative stress genes (Makwana et al..
2010) and increased DNA hypermethylation of a calcium-ATP pump promoter in developing cardiac
tissue (Palbykin et al.. 2011) only at lower and not higher doses, resulting in multimodal calcium
responses (Caldwell et al.. 2008). TCE also increased significantly increased gene expression of the
oxidative metabolism enzyme CYP2H1 specifically in cardiac tissue only at the lower dose ((Makwana
et al.. 2013)). In (Harris et al.. 2018). expression of genes involved in cardiac development and
metabolism were either reduced (low dose) or increased (high dose), depending on the administered
concentration. These results may explain the non-monotonic polynomial dose-response observed in
(Johnson et al.. 2003). whereby toxicological outcomes present at different doses equating to either
inhibition or activation of particular gene expression (Harris et al.. ). This differential gene
expression would in turn lead to dose-specific downstream metabolic and phenotypic effects.

Overall, an association between increased congenital cardiac defects and TCE exposure is supported by
the weight of evidence, in agreement with previous EPA analyses (	14b; Makris et al..

2016). Therefore, this endpoint was carried forward for dose-response analysis.

3.2.4.1.7 Overt Toxicity Following Acute/Short Term Exposure

There is strong evidence for overt toxicity in humans following acute exposure to high concentrations of
TCE. AEGL guidelines indicate the concentrations at which increasing levels of toxicity are established
following acute inhalation exposure to TCE. High concentrations of TCE have been shown to result in
respiratory and dermal irritation, CNS depression, cardiac arrhythmia, and even death.

While overt toxicity following acute or short term exposure to TCE is supported by the weight of
evidence, studies examining the acute outcomes described above were not selected for assessing acute
risks due to a lack of sufficient dose-response information. EPA considered more sensitive endpoints for
estimation of risks following acute TCE exposure, namely all developmental toxicity endpoints and
reduced response to respiratory infection (Selgrade and Gilmour. 2010). Other acute studies described
above were not selected for assessing acute risks due to a lack of sufficient dose-response information.

3.2.4.2 Cancer Hazards

Meta-analyses were performed in the 2011 EPA TCE IRIS Assessment (Appendix C, (

2( )) in order to statistically evaluate the epidemiological data for NHL, kidney cancer, and liver
cancer. The IRIS Assessment also investigated the association of TCE with lung cancer, primarily as a
means to examine smoking as a potential confounder for the kidney cancer studies (Appendix C, (U.S.

)). In that assessment EPA identified a statistically significant association between TCE
exposure and NHL, kidney cancer, and liver cancer. An association was not identified for lung cancer,
suggesting that there was no confounding from smoking. That assessment concluded that TCE is
carcinogenic to humans by all routes of exposures, most strongly supported by the data on kidney
cancer. The consistency of increased kidney cancer relative risk (RR) estimates across a large number of
independent studies of different designs and populations from different countries and industries provided
compelling evidence given the difficulty, a priori, in detecting effects in epidemiologic studies when the
RRs were modest and the cancers were relatively rare, indicating that individual studies had limited
statistical power. This strong consistency of the epidemiologic data on TCE and kidney cancer argued
against chance, bias, and confounding as explanations for the elevated kidney cancer risks.

The IRIS Toxicological Review of TCE (	) also cited other lines of supporting evidence

for TCE carcinogenicity in humans by all routes of exposure:

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"First, multiple chronic bioassays in rats and mice have reported increased incidences of tumors with
TCE treatment via inhalation and gavage, including tumors in the kidney, liver, and lymphoid tissues -
target tissues of TCE carcinogenicity also seen in epidemiological studies. "

"A second line of supporting evidence for TCE carcinogenicity in humans consists of toxicokinetic data
indicating that TCE is well absorbed by all routes of exposure, and that TCE absorption, distribution,
metabolism, and excretion are qualitatively similar in humans and rodents. "

"Finally, available mechanistic data do not suggest a lack of human carcinogenic hazardfrom TCE
exposure."

A statistically significant association was not identified for lung cancer and it was not considered as
contributing to the overall oral slope factor or inhalation unit risk. However, the results of the lung
cancer meta-analysis were interpreted to minimize any concern for confounding effects of smoking on
the other cancers.

For this risk evaluation, EPA performed new meta-analyses incorporating both the initial group of
studies assessed in the 2011 EPA TCE IRIS Assessment and any newer, on-topic studies of Acceptable
data quality identified in the literature search performed according to the Application of Systematic
Review in TSCA Risk Evaluations (	>). EPA utilized similar methodology as was

employed in the 2011 EPA TCE IRIS Assessment (	) while also incorporating

consideration of data quality evaluation as described in (	). Additionally, EPA included

sensitivity analyses as needed to partition the results based on both heterogeneity and data quality score.
When more than one report was available for a single study population, only the most recent publication
or the publication reporting the most informative data for TCE was selected for inclusion in the meta-
analysis. While the updated meta-analysis builds off of (	), the results presented below
represent a standalone, new analysis. See Appendix H for full details and results.

3.2.4.2.1 Meta-Analysis Results

The initial results of meta-analyses for NHL, kidney cancer and liver cancer showed moderate
heterogeneity among studies, due largely to the influence of the study by Vlaanderen et al. ( ).
Random-effects models are consequently preferred to fixed-effects models due to the degree of
heterogeneity. These reduced the influence of the (Vlaanderen et al.. 2013) study and demonstrated
stronger positive associations (greater meta-RR value) of all cancers with exposure to TCE, although the
liver cancer meta-RR was not significant. The evidence for an association between TCE exposure and
NHL was further strengthened by a subsequent meta-analysis on studies reporting cohorts categorized as
experiencing "high" exposure to TCE, which demonstrated a greater meta-RR compared to "any"
exposure.

The study of Vlaanderen et al. (2013) carries very large statistical weight due to its large sample size,
but its sensitivity to detect any true effect of TCE is likely to be low. The study is based on a large
general population cohort with exposures estimated by linking job titles recorded in national census data
to a job-exposure matrix. The prevalence and average intensity of TCE exposure are low in the study
population and the indirect method of estimating exposures has significant potential to misclassify
exposure. Further, the study was not scored High for data quality in EPA's review (it scored Medium).
There was therefore reason to believe that omitting the Vlaanderen et al.Q ) study would improve the
sensitivity of meta-analytic results for all three cancers. In sensitivity analyses omitting the study of
(Vlaanderen et al.. 2013). between-study heterogeneity was significantly reduced or eliminated.

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Resulting meta-RRs for exposure to TCE were strengthened and were statistically significant for all
three cancers.

Analyses stratified by a data quality score also indicated stronger associations of all cancers with TCE
exposure in studies that scored High for data quality compared to studies that scored Medium or Low;
notably, the latter group included the influential study of (Vlaanderen et at.. 2013). Studies that scored
high showed no heterogeneity of effects for NHL and kidney cancer, but moderate heterogeneity
remained for liver cancer.

In summary, meta-analyses accounting for between-study heterogeneity, influential observations, and
data quality consistently indicate positive associations of NHL, kidney cancer and liver cancer with
exposure to TCE. This conclusion generally agrees with that of other governmental and international
organizations. The International Agency for Research on Cancer (IARC) (IARC. 2014) found sufficient
evidence for the carcinogenicity of TCE in humans. IARC definitively stated that TCE causes kidney
cancer and determined that a positive associated has been identified for NHL and liver cancer. Based on
the weight of evidence when accounting for both these authoritiative assessments and the results of
EPA's meta-analyses, cancer was carried forward for dose-response analysis, incorporating extra cancer
risk from all three cancer types.

3.2.4.2.2 Mode of Action
Kidney Cancer

Genotoxicitv

The predominant mode of action (MOA) for kidney carcinogenicity involves a genotoxic mechanism
through formation of reactive GSH metabolites (e.g., DCVC, DCVG). This MOA is well-supported, as
toxicokinetic data indicates that these metabolites are present in both human blood and urine, and these
metabolites have been shown to be genotoxic both in vitro and in animal studies demonstrating kidney-
specific genotoxicity (U.S. EPA. 2 ).

Cytotoxicity and other mechanisms

Observed nephrotoxicity in both human and animal studies, especially at elevated concentrations,
provides some evidence of a cytotoxic MOA. Data comparing relative dose-response analysis of
nephrotoxicity and kidney cancer incidence suggests that cytotoxicity can occur at doses below those
causing carcinogenicity in animal bioassays, however this data also indicates that nephrotoxicity is not
sufficient or rate-limiting for renal carcinogenesis. Therefore, a causal or predictive link between
cytotoxicity and carcinogenicity cannot be established. There is inadequate experimental support for
other potential MO As such as peroxisome proliferator activated receptor alpha (PPARa) induction, a2\i-
globulin nephropathy, and formic acid-related nephrotoxicity (\ c. < ^ \ JO I 1^).

Conclusion

There is clear evidence of a genotoxic MOA for kidney cancer, either on its own or in combination with
other mechanisms. While the kidney is highly sensitive to TCE-induced cytotoxicity, the contribution of
cytotoxicity toward kidney carcinogenesis cannot be determined. Renal cytotoxicity may instead serve
as a promoter step in tumorigenesis following genotoxic initiation, or it may merely represent an
independent pathway of toxicity (I v << \ _\"W 1^).

Liver Cancer

Genotoxicitv

The strongest data supporting mutagenic potential of TCE or potential liver metabolites comes from data
on the intermediate metabolite chloral hydrate (CH), which induces a variety of genotoxic effects both in

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vitro and in vivo. The peak in vivo concentrations of CH in tissue are substantially less than is required
for induction of genotoxicity in many in vitro assays, however there is some evidence of in vivo
genotoxicity at doses comparable to those inducing cancer in chronic bioassays. Overall, the data are
insufficient to conclude that a mutagenic MOA is operating, however it cannot be ruled out. (

201leV

PPARq receptor activation

While strong evidence exists for TCA-mediated PPARa receptor activation (resulting in downstream
perturbation of cell apoptosis and proliferation signaling) based on observed peroxisome proliferation
and increased marker activity in rodents treated with TCE, TCA, or DCA, this appears to occur at a
higher dose than what induces liver tumors in mice. TCE, TCA, and DCA have been found to be weak
peroxisome proliferators, and some data suggests that PPARa activation may not be sufficient for
carcinogenesis. The reasonably available data clearly supports a role of PPARa activation in liver
turn oogenesis, however any key causal effects are likely mediated by multiple mechanisms and neither
causality, sufficiency, or necessity of PPARa signaling in liver carcinogenicity can be established (U.S.
* * \ \^).

Other mechanisms

There is limited evidence for a tumorigenic role of increased liver weight, growth selection, cytotoxicity,
oxidative stress, and/or glycogen accumulation. Heritable epigenetic changes such as altered DNA
methylation patterns, which disrupt the balance of gene expression and may lead to over- or under-
expression of various tumor suppressors and promoters, have been associated with liver cancer and
other tumors in general. Additionally, TCE has been shown to promote hypomethylation (resulting in
increased gene expression) in vivo and ex vivo in liver tissue. DNA hypomethylation can be sufficient
for liver carcinogenesis based on choline/methionine deficiency studies, however the applicability of
this mechanism to TCE-induced carcinogenesis is unknown as these changes could either be causally or
consequentially related to carcinogenicity (U.S. EPA. 201 le).

Conclusions

The reasonably available data is inadequate to support any singular MOA. TCE-induced liver
carcinogenesis appears to be very complex and likely involves multiple contributing mechanisms. The
strongest evidence exists for involvement of both genotoxicity and PPARa activation, however a causal
relationship cannot be established because the dose levels required to elicit outcomes through both
MO As are higher than those demonstrating tumorigenic activity (	).

Non-Hodgkin Lymphoma

There is insufficient data reasonably available for suggesting any particular MOA for NHL.

Overall Conclusions

TCE is carcinogenic by a genotoxic mode of action at least for kidney cancer, while a predominant
mode of action cannot be determined for the other tumor types. Per EPA Guidelines for Carcinogen Risk
Assessment (	05), overall, the totality of the reasonably available data/information and the

WOE analysis for the cancer endpoint was sufficient to support a linear non-threshold model. The
application of a linear non-threshold model is justified based on the genotoxic MOA for kidney cancer,
the combined relative contributions of multiple tumor types, and the positive associations observed via
meta-analysis for all three cancers in epidemiological studies based on low-level, environmental
exposure levels (as opposed to relying on extrapolation from high doses in a rodent bioassay).

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3.2.5 Dose-Response Assessment

3.2.5.1 Selection of Studies for Dose-Response Assessment

The EPA evaluated data from studies described above (Section 3.2.3.1) to characterize the dose-
response relationships of TCE and selected studies and endpoints to quantify risks for specific exposure
scenarios. One of the additional considerations was that the selected key studies had adequate
information to perform dose-response analysis for the selected PODs. The EPA defines a POD as the
dose-response point that marks the beginning of a low-dose extrapolation. This point can be the lower
bound in the dose for an estimated incidence, or a change in response level from a dose-response model
(i.e., BMD), a NOAEL or a LOAEL for an observed incidence or change in the level of response.

Based on the weight of the evidence evaluation, six health effect domains were selected for non-cancer
dose-response analysis: (1) liver; (2) kidney; (3) neurological; (4) immunological; (5) reproductive; and
(6) developmental. Additionally, dose-response analysis was performed for cancer based on observed
incidences of kidney cancer, liver cancer, and non-Hodgkin lymphoma. These hazards have been carried
forward for dose-response analysis. While there is also evidence to support overt toxicity following
acute exposure, endpoints for these effects were not carried forward for dose-response analysis. For a
complete discussion, see Section 3.2.4.1.

Studies that evaluated each of the health effect domains were identified in Section 3.2.3, and are
considered in this section for dose-response analysis. In order to identify studies for dose-response
analysis, several attributes of the studies were reviewed. Preference was given to studies using designs
reasonably expected to detect a dose-related response. Chronic or subchronic studies are generally
preferred over studies of less-than-subchronic duration for deriving chronic and subchronic reference
values. Studies with a broad exposure range and multiple exposure levels are preferred to the extent that
they can provide information about the shape of the exposure-response relationship. Additionally, with
respect to measurement of the endpoint, studies that can reliably measure the magnitude and/or degree
of severity of the effect are preferred.

Experimental animal studies considered for each hazard and effect were evaluated using systematic
review quality considerations discussed in the Systematic Review Methods section. Only studies that
scored an acceptable rating in data evaluation were considered for use in dose-response assessment. In
addition to the data quality score, considerations for choosing from among these studies included study
duration, relevance of study design, and the strength of the toxicological response. Details on these
considerations for each endpoint are provided below.

Given the different TCE exposures scenarios considered (both acute and chronic), different endpoints
were used based on the expected exposure durations. For non-cancer effects and based on a weight-of-
evidence analysis of toxicity studies from rats, risks for developmental effects that may result from a
single exposure were considered for both acute (short-term) and chronic (long-term, continuous)
exposures, whereas risks for other adverse effects (e.g., liver toxicity, kidney toxicity, neurotoxicity,
immunotoxicity, and reproductive toxicity) were only considered for repeated (chronic) exposures to
TCE. Although developmental studies typically involve multiple exposures, they are considered relevant
for evaluating single exposures because evidence indicates that certain developmental effects may result
from a single exposure during a critical window of development (Davis et ai. 2009; Van Raaii et al.
2003; U.S. EPA. 1991). This is consistent with EPA's Guidelines for Reproductive Toxicity Risk
Assessment (	96) which state that repeated exposure is not a necessary prerequisite for the

manifestation of developmental toxicity. Consequently, in this risk evaluation EPA accepted the
Agency's default assumption and concluded that developmental endpoints are applicable when assessing

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acute exposures, where it is assumed that the risk of their occurrence depends on the timing and
magnitude of exposure. This is a health protective approach and assumes that a single acute exposure
could lead to the same effects if that exposure occurs during a critical window within the pregnancy
term. A single acute study examining pulmonary immunotoxicity following 3h TCE inhalation exposure
(Selerade and Gilmour. 2010) was also considered for acute exposure scenarios. Overt toxicity studies
(Section 3.2.3.1.7) were not used for the acute POD because they were often only single-dose studies
and the doses at which acute toxic effects or lethality were observed were significantly higher than those
that caused toxic effects in developmental studies.

3.2.5.1.1	Liver toxicity

The 2014 TSCA Work Plan Chemical Risk Assessment (	) determined that the studies

of (Woolhiser et ai. 2006; Bub en and O'Flaherty. 1985; Kiellstrand et al.. 1983) were suitable for the
dose-response assessment of the liver health effects domain. These three studies reported dose-
responsive increases in liver/body weight ratios. (Buben and O'Flal 985) and (Kiellstrand et al..
1983) also reported cytotoxicity and histopathology in mice. All three of these studies scored Medium
or High in EPA's data quality evaluation [Data Quality Evaluation of Human Health Hazard Studies.
Docket: EPA-HQ-OPPT-2019-0500] and were therefore utilized for dose-response analysis.

3.2.5.1.2	Kidney toxicity

The 2014 TSCA Work Plan Chemical Risk Assessment (	) considered five animal

studies reporting kidney toxicity for further non-cancer dose-response analysis. (Maltoni et al.. 1986).
(NCI. 1976) and (NTP. 1988) reported histological changes in the kidney, whereas (Kiellstrand et al..
1983) and (Woolhiser et al.. 2006) reported increased kidney/body weight ratios (\ c. \ 1* \ JO I I ^).
NCI (1976) scored Unacceptable in EPA's data quality evaluation [Data Quality Evaluation of Human
Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and therefore was excluded from dose-
response analysis. All of the other studies scored Medium in data quality and were therefore utilized for
dose-response analysis.

3.2.5.1.3	Neurotoxicity

Among the human studies, (Ruiiten et al.. 1991) was the only epidemiological study that the IRIS
program deemed suitable for further evaluation in the TCE's dose-response assessment for
neurotoxicity. Only the following four animal studies were considered suitable for dose-response
analysis for the neurotoxicity endpoint in the 2014 TSCA Work Plan Chemical Risk Assessment (U.S.
EP \ .014b): ( \iiio et al.. 1994). (Isaacson et al.. 1990). (Gash et al.. 2008). and (Kiellstrand et al..
1987). Kj ell strand (1987) scored Unacceptable in in EPA's data quality evaluation [Data Quality
Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and therefore was
excluded from dose-response analysis. Gash et al. (2008) scored a Low in data evaluation and was also
not carried forward to dose-response analysis given the other, higher quality studies available. Ruijten
et al. (1991). Arito et al. (1994). and Isaacson et al. (1990) all scored Medium or High for data quality
and were therefore utilized for dose-response analysis.

3.2.5.1.4	Inuminotoxicity

Only the following four animal studies were suitable for the 2014 TSCA Work Plan Chemical Risk
Assessment (	14b) non-cancer dose-response analysis for the immunotoxicity endpoint:

(Keil et al.. 2009). (Kaneko et al.. 2000). (Sanders et al.. 1982). and (Woolhiser et al.. 2006). For this
Risk Evaluation, EPA also assessed the endpoint of acute immunosuppression observed in (S el grade
and Gilmour. 2010). In Selgrade et al (2010). mice were infected via respiration with aerosolized S.
zooepidemicus bacteria following 3h TCE exposure. Mortality, bacterial, clearance from the lung,

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percent of mice infected, and phagocytic index were assessed following co-exposure. Mortality was
selected as the most statistically sensitive endpoint due to a larger numbers of mice per exposure group
and more dose groups, however "percent of mice infected" was also considered for dose-response
analysis (Appendix F.2). All of these studies scored Medium or High in EPA's data quality evaluation
[.Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and
were therefore utilized for dose-response analysis.

3.2.5.1.5	Reproductive toxicity

Among the human studies, (Chia et al. 1996) was the only epidemiological study that the 2014 TSCA
Work Plan Chemical Risk Assessment (U.S. EPA. 2014b) deemed suitable for further evaluation in the
TCE's dose-response assessment for reproductive toxicity. Only the following eight reproductive
animal toxicity studies were considered suitable for non-cancer dose-response analysis in the 2014
TSCA Work Plan Chemical Risk Assessment (	b): (Kumar et al.. 2000). (Kumar et al..

2001). (Kan et al.. 2007). (Xu et al.. 2004). (Narotskv et al.. 1995). (George et al.. 1986). (Duteaux et
al.. 2004). and (Forkert et al.. 2002). Forkert et al. (2002) scored Unacceptable in EPA's data quality
evaluation and therefore was excluded from dose-response analysis, however it had the same POD as
(Kan et al.. 2007). which scored Medium. Duteaux et al. (2004) scored a Low for data quality and was
not carried forward to dose-response analysis given the other, higher quality studies available. The
remaining studies all scored Medium or High for data quality [Data Quality Evaluation of Human
Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and were therefore utilized for dose-
response analysis.

3.2.5.1.6	Developmental toxicity

The 2014 TSCA Work Plan Chemical Risk Assessment (	) found 5 animal studies that

were suitable for non-cancer dose- response analysis for the following developmental outcomes: pre-
and postnatal mortality; pre- and postnatal growth; developmental neurotoxicity; and congenital heart
malformations (Appendix L of that document).

Although the focus of the discussion below is on these 5 studies and corresponding endpoints, it is
important to mention that developmental immunotoxicity has also been demonstrated in TCE-treated
animals. The most sensitive immune system response was reported by (Peden-Adams et al.. 2006). In
this study, B6C3F1 mice were exposed to TCE via drinking water. Treatment occurred during mating
and through gestation to TCE levels of 0, 1.4, or 14 ppm. After delivery, pups were further exposed for
either 3 or 8 more weeks at the same concentration levels that the dams received in drinking water.
Suppressed PFC response was seen in male pups after 3 and 8 weeks of exposure, whereas female pups
showed the suppression of PFC response and delayed hypersensitivity at 1.4 ppm following 8 weeks.
At the higher concentration (14 ppm), both of these effects were observed again in both males and
females following 3 or 8 weeks of postnatal exposure. A LOAEL of 0.37 mg/kg-bw/day served as a
POD for the decreased PFC and increased delayed hypersensitivity responses (	).

While this endpoint exhibits one of the lower PODs among developmental toxicity studies, the study
scored a "Low" in EPA's data quality evaluation [Data Quality Evaluation of Human Health Hazard
Studies. Docket: EPA-HQ-OPPT-2019-0500] due to concerns over statistical reliability and dose
precision (difficult to calculate precise dosage). Additionally, it could not be accurately PBPK modeled
because exposure occurred in utero, through nursing, and after weaning. Therefore, this study was not
considered further for dose-response assessment, although developmental immunotoxicity will still be
considered qualitatively.

Pre- and Postnatal Mortality and Growth

The following two studies were considered suitable for non-cancer dose-response analysis for pre- and

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postnatal mortality and growth effects in the 2014 TSCA Work Plan Chemical Risk Assessment (H.S.
B1 \ .014b): (Healv et ai. 1982) and (Narot> i v\ ^ rs°5). Healy et al. (1982) scored Unacceptable
in in EPA's data quality evaluation [Quality Evaluation of Human Health Hazard Studies. Docket:
EPA-HQ-OPPT-2019-0500] and therefore was excluded from dose-response analysis. (Narotsky et al..
1995) scored a High and was therefore utilized for dose-response analysis.

Developmental Neurotoxicity

There is evidence of alterations in animal brain development and in behavioral parameters (e.g.,
spontaneous motor activity and social behaviors) following TCE exposure during the development of
the nervous system. Among all of the reasonably available studies, there were two oral studies that
reported behavioral changes which were used in the dose-response evaluation for developmental
toxicity: (Fredriksson et al.. 1993) and (Taylor et al.. 1985). (Taylor et al.. 1985) scored a Low in
EPA's data quality evaluation due to the same issues as (Peden-Adams et al.. 2006) and was not
considered further for dose-response assessment. (Fredriksson et al.. 1993) scored a Medium despite
some uncertainty concerning the statistical validity of its sampling methodology [Data Quality
Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] and was therefore
utilized for dose-response analysis.

Congenital Heart Defects

The fetal cardiac defects reported in (Dawson et al.. 1993) and (Johnson et al.. 2003) were identified as
the most sensitive endpoint within the developmental toxicity domain and across all of the health
effects domains evaluated in the TCE IRIS assessment. Johnson et al. (Johnson et al.. 2003) reported
data from different experiments over a several-year period in which pregnant Sprague-Dawley rats (9-
13/group; 55 in control group) were exposed to TCE via drinking water. Treatment of pregnant rats
occurred during the entire gestational period (i.e., GD 0 to GD22). The study was a follow-up to
Dawson et al. (1993). which demonstrated increasing incidence of congenital heart defects at the
highest two dose groups that were later pooled and re-analyzed in (Johnson et al.. 2003).

Much of the controversy surrounding the reliability of the (Johnson et al.. 2003) study relates to the
pooling of control animals and data across several years, including the use of different vehicles (tap
water vs distilled water). EPA therefore compared the data from (Johnson et al.. 2003) and from
(Dawson et al.. 1993). the earlier study comprising the highest two doses of the (Johnson et al.. 2003)
study in which data was not pooled and only a single vehicle was used. Unfortunately, EPA was unable
to use a nested benchmark dose (BMD) model because individual pup data could not be easily tracked
to a particular dam, so this data is less statistically reliable. Both studies scored a "Medium" in in
EPA's data quality evaluation [Data Quality Evaluation of Human Health Hazard Studies. Docket:
EPA-HQ-OPPT-2019-0500], which incorporated all available information on the two studies,
including subsequent errata and communications to EPA (Johnson et al.. 2014: Johnson. 2014. 2008:
Johnson et al.. 2005). While the original publications had extensive data and methodology reporting
issues, many of the data quality concerns from the original study were mitigated by the information
provided in these updates. These updates provided the following information which was lacking in the
initial publications:

1)	Individual fetal cardiac malformation data for each litter

2)	Individual maternal terminal body weight data

3)	Detailed description of fetal evaluation procedures including:

-	methods used to blind fetal examiners to treatment group

-	protocol for unanimous confirmation of any observed cardiac defects by the three

principle investigators

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3)	Additional information on animal husbandry and randomized group assignment of dams to
study group

4)	Transparency regarding experimental variables across the dates of the experiments

Because both studies passed data evaluation with the same score and statistics could only be
performed using a pup as the statistical unit for (Dnwson et ai. 1993). EPA decided to utilize the
(Johnson et al. 2003) data for dose-response analysis, which has increased statistical sensitivity from
the additional two dose levels and allowed a nested design for BMD modeling analysis in order to
account for litter effects. Additionally, some defects originally identified in (Dawson et al.. 1993) were
later reclassified or recharacterized in (Johnson et al.. 2003). so (Johnson et al.. 2003) contains the
more updated analysis.

3.2.5.1.7 Cancer

The 2019 meta-analysis of all relevant studies examining kidney cancer, liver cancer, or NHL
(Appendix H) came to the same conclusion as the previous EPA meta-analysis in the 2011 IRIS
Assessment (U.S. EPA. 201 le). Therefore, EPA utilized the same inhalation unit risk and oral slope
factor estimates as were derived in ( v «« \ . ' i i ) and cited in the 2014 TSCA Work Plan Chemical
Risk Assessment (	014b). A linear non-threshold assumption was applied to the TCE cancer

dose-response analysis because there is sufficient evidence that TCE-induced kidney cancer operates
primarily through a mutagenic mode of action while it cannot be ruled out for the other two cancer types.

The 2011 IRIS Assessment (U.S. EPA. 201 le) selected the epidemiological kidney cancer data
Charbotel et al (2006) as the best representative dose-response data for derivation of an oral slope factor
and inhalation unit risk value as a case-control study with quantitative cumulative exposure estimates
based on a task-exposure matrix based on decades of measurement. Charbotel et al (2006) received a
High score for data quality both overall and for the exposure domain in EPA's data evaluation [Data
Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500]. Therefore,
EPA relied on its previous dose-response analysis from this study.

3.2.5.2 Potentially Exposed and Susceptible Subpopulations (PESS)

TSCA requires that a risk evaluation "determine whether at chemical substance presents an
unreasonable risk of injury to health or the environment, without consideration of cost or other non-risk
factors, including an unreasonable risk to a potentially exposed or susceptible subpopulation identified
as relevant to the risk evaluation by the Administrator, under the conditions of use." TSCA § 3(12)
states that "the term 'potentially exposed or susceptible subpopulation' means a group of individuals
within the general population identified by the Administrator who, due to either greater susceptibility or
greater exposure, may be at greater risk than the general population of adverse health effects from
exposure to a chemical substance or mixture, such as infants, children, pregnant women, workers, or the
elderly."

During problem formulation (	2018d). EPA identified potentially exposed or susceptible

subpopulations for further analysis during the development and refinement of the life cycle, conceptual
models, exposure scenarios, and analysis plan. In this section, EPA addresses the potentially exposed or
susceptible subpopulations identified as relevant based on greater susceptibility. EPA addresses the
subpopulations identified as relevant based on greater exposure in Section 2.3.3.

There is some evidence that certain populations may be more susceptible to exposure to TCE. Factors
affecting susceptibility examined in the available studies on TCE include lifestage, gender, genetic
polymorphisms, race/ethnicity, preexisting health status, lifestyle factors, and nutrition status. Factors

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that affect early lifestage susceptibility include exposures during gestation, such as transplacental
transfer, and during infancy, such as breast milk ingestion, early lifestage-specific toxicokinetics, and
early lifestage-specific health outcomes including developmental cardiac defects. Gender-specific
differences also exist in toxicokinetics (e.g., cardiac outputs, percent body fat, expression of
metabolizing enzymes) and susceptibility to toxic endpoints (e.g., gender-specific effects on the
reproductive system, gender differences in baseline risks to endpoints such as scleroderma or liver
cancer). Genetic variation likely has an effect on the toxicokinetics of TCE. Pre-existing diminished
health status may alter the response to TCE exposure. Individuals with increased body mass may have
an altered toxicokinetic response due to the increased uptake of TCE into fat. Other conditions that may
alter the response to TCE exposure include diabetes and hypertension, and lifestyle and nutrition factors
such as alcohol consumption, tobacco smoking, nutritional status, physical activity, and socioeconomic
status (	). Among life stages, the most susceptible is likely to be pregnant women and

their developing fetus based on the hazard findings from reviewing the reasonably available literature for
this assessment, which conclude that developmental toxicity is among the most sensitive acute health
effects associated with TCE exposure. Among pregnant women, older women may be especially
susceptible to TCE-induced cardiac defects in their offspring. Maternal age is known to have a large
influence on the incidence of congenital heart defects, and multiple studies cited in this Risk Evaluation
identified a significantly stronger association of TCE with developmental cardiac defects (Braider et at..
2014; Yauck et at.. 2004). Additional maternal risk factors for susceptibility to congenital cardiovascular
defects include diabetes, infection status, drug exposure, and stress, among others (Jenkins et at.. 2007).

Significant variability in human susceptibility to TCE toxicity may result from differences in
metabolic potential, given the existence of CYP isoforms and the variability in CYP-mediated TCE
oxidation (U.S. EPA. 201 le). Increased enzymatic activity of cytochrome P450 2E1 (CYP2E1) and
glutathione-S-transferase (GST) polymorphisms may influence TCE susceptibility due to effects on
the production of toxic metabolites (\ v < < \ _:01 I e). More specifically, there appears to be
greater susceptibility to TCE-induced kidney cancer in those individuals that carry an active
polymorphism in a gene associated with the GST metabolic pathway. Particularly, the gene is
associated with the P-lyase gene region which is responsible for converting DCVC to the unstable
intermediate DCVT. Also, there are some human studies suggesting a role for mutations to the tumor
suppressor gene, von Hippel Lindau (VHL gene). This tumor suppressor gene appears to be
inactivated in certain TCE-induced kidney cancers (	). In the 2014 TCE risk

evaluation (U.S. EPA. 2014b). EPA performed a population analysis to systematically estimate
uncertainty and variability across several metabolic factors, including human variability related to
oxidative metabolism and glutathione conjugation as a result of GST activity. Integration of these
factors into a probabilistic model resulted in a distribution of human equivalent concentrations/doses
(HECs/HEDs) for each endpoint. HEC99/HED99 values representing the most metabolically
sensitive 1% of the population, a susceptible subpopulation, were used for risk evaluation, and EPA
utilized the same analysis for this assessment.

3,2,5,3 Derivation of Points of Departure (PODs)

Point of departures (PODs) were identified for those studies that had suitable data for dose-response
analysis, described above. PODs can be a NOAEL or LOAEL for an observed incidence, or change in
level of response, or the lower confidence limit on the dose at the benchmark dose (BMDL). PBPK
modeling was used to estimate internal dose PODs (idPOD) and subsequently the human equivalent
concentrations/doses (HECs/HEDs) based on the oral and inhalation PODs identified in earlier steps.
The PBPK modeling integrated internal dose-metrics based on TCE's mode of action and the role of
different TCE metabolites in toxicity (	) Note that the effects within the same health

effect domain were generally assumed to have the same relevant internal dose-metrics, with some

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exceptions. Compared to the 2014 TSCA Work Plan Chemical Risk Assessment, an additional POD
from Selgrade (2010) has also been added for acute exposure scenarios.

For this assessment, when an endpoint can be BMD and PBPK modeled, default cumulative acute UF =
10 (UFa and UFh both = 3 based only on toxicodynamic uncertainty (UFtd); UFs and UFl =1) and
default cumulative chronic UF = 100 (UFs = 10 if the study covers less than 10% of lifetime). See
Appendix O for details on the criteria for selection of appropriate BMD models and UFs for each
endpoint.

POD Selection Metrics

The below sections present all studies considered for dose-response analysis. From this list, the studies
were selected from each health domain /organ system that best represent each available endpoint. For
some health domains with multiple endpoints this resulted in multiple studies being selected for
consideration in risk estimation. In selecting the most representative studies and PODs, EPA
considered the following factors:

•	Data quality evaluation score

•	Species (i.e. animal or human)

•	Exposure duration

•	Dose range

•	Cumulative uncertainty factor

•	Relevance to the endpoint of interest and human exposure scenarios

Dose metric selection is based on a determination of which toxicokinetic measure is most predictive of
localized effects from TCE exposure. These factors were evaluated for each independent endpoint, and
EPA considered use of the most health-protective POD only after first considering each of the above
factors. See the 2011 EPA TCE IRIS Assessment (U.S. EPA. 2 ) for more details on dose-metric and
benchmark response (BMR) determinations for all endpoints except that from Selgrade and Gilmour
(2010). BMD modeling results for (Selgrade and Gilmour. 2010) are presented in Appendix F.

3.2,5.3.1 Non-Cancer PODs for Acute Exposure

Acute exposure in humans is defined for occupational settings as exposure over the course of a single
work shift (8 hours) and for consumers as a single 24-hour day. Although developmental studies
typically involve multiple exposures, they are considered relevant for evaluating single exposures
because evidence indicates that certain developmental effects may result from a single exposure during
a critical window of development (Davis et at.. 2009; Van Raaii et at.. 2003;	) This is

consistent with EPA" s Guidelines for Reproductive Toxicity Risk Assessment (	96), which

state that repeated exposure is not a necessary prerequisite for the manifestation of developmental
toxicity. Therefore, developmental endpoints were considered relevant for calculating risks associated
with acute occupational or consumer exposure. Single-exposure studies identifying a dose-responsive
specific health outcome were also considered for deriving PODs representative of risks following acute
exposures.

HECs for developmental toxicity were adjusted to reflect a 24-hr value, consistent with both
occupational and consumer exposure values. The POD from Selgrade (2010). a 3hr acute inhalation
study, was adjusted to a 24hr HEC value for occupational risk estimates due to limited reasonably
available occupational exposure information below 8hr time periods. The 3hr POD was used without
adjustment for estimation of consumer risks due to available exposure estimates for 3hr time periods.

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Developmental Toxicity Endpoints

—	Prenatal Mortality

(Narotsky et al. 1995) was also discussed above in the reproductive toxicity section, but also
identified mortality to the developing fetus following in utero TCE exposure. F344 timed-pregnant
rats (8-12 dams/group) were treated with TCE by gavage during GD 6 to 15. The BMDLoi for
increased resorptions was 32.2 mg/kg-bw/day (	).

—	Developmental Neurotoxicity

(Fredriksson et al. 1993) treated male NMRI mouse pups (12/group, selected from 3-4 litters) with
TCE via gavage (0, 50, or 290 mg/kg-bw/day) during postnatal days (PND) 10 to 16. Locomotor
behavior was evaluated at PND 17 and 60. TCE-treated mice showed decreased rearing activity at both
dose levels on PND 60, but not PND 17, resulting in a LOAEL of 50 mg/kg-bw/day as a POD (U.S.

).

—	Congenital Heart Malformations

(Johnson et al.. 2003) reported a statistically and biologically significant increase in the formation of
heart defects at the 0.048 mg/kg-bw/day and higher dose levels (concentrations of 0, 0.00045, 0.048,
0.218 or 129 mg/kg-bw/day) measured on both an individual fetus basis and a litter basis. A BMDLoi
HEC99 of 0.0037 ppm and HED99 of 0.0052 mg/kg-bw/day were identified as the inhalation and oral
PODs, respectively, for heart malformations in the 2014 TSCA Work Plan Chemical Risk Assessment
(I	£014b). EPA quantified the totality of cardiac defects instead of any particular defect, as

cardiac teratogens can result in a diverse constellation of effects (e.g., retinoic acid, see Appendix
G. 1.2.2).

The BMR selection from the 2014 TSCA Work Plan Chemical Risk Assessment (	)

for (Johnson et al.. 2003) was also reassessed based on the non-monotonic dose-response, decreased
incidence from control at the 2.5ppb dose level, and reduced statistical power due to a less than
recommended number of litters assessed for each dose group. These concerns were discussed as part
of a re-analysis of the 2011 dose-response assessment in (Makris et al.. 2016). which acknowledged
the uncertainty inherent in a selection of a 1% BMR:

"BMD inference at the 1% extra-risk level is highly uncertain, because BMD and BMDL values vary
by several orders of magnitude depending on the modeling assumptions. This is attributed in part to
the lack of monotonicity at the lowest dose and the apparent supralinearity of the overall exposure-
response relationship. Additional doses would be required to better specify the curve shape in the low-
dose region. More reliable inference can be made for higher BMRs...

There is substantial model and parameter uncertainty at the 1% level of extra risk, although 1% is the
appropriate BMR based on severity of the effect (i.e., cardiac malformations). These uncertainties can
be attributed primarily to having too few data points in the low-dose range, where more data would be
required to adequately characterize the dose-response shape. Uncertainty decreases for higher BMR
levels (5% and 10% extra risk), although 10% exceeds the range of the data for some models

In reevaluating the BMR, EPA considered both biological and statistical factors:

1.	The biological severity of the effect

2.	The range of observable data relative to the BMR and resulting BMDL

3.	The influence of study design and sample size on statistical sensitivity

4.	Confidence in the model fit and variance

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After considering all these factors, EPA determined that the biological severity of the effect,
potentially lethal heart defects, strongly supported a BMR of 1%. For statistical considerations, EPA
referred to the nested BMD modeling results from Appendix F.4.2.1 in (	). In these

results, the BMDL for both a 1% and 5% BMR easily fall within the experimental dose range,
increasing confidence in the target BMRs. The observed incidence for the lowest dose in (Johnson et
ai. 2003) was reduced from controls, adding uncertainty to the modeling estimate, however the
difference was not statistically significant. A larger sample size for the treated groups may have
increased the statistical sensitivity at lower doses. The BMD model actually displays better visual fit at
the lower end of the dose range, near the control, suggesting that a lower BMR may actually represent
a more accurate model estimate.

In evaluating model fit, EPA determined that the BMD:BMDL ratio was adequate (3.1), indicating
reasonably small variance. The original reported p-value for the model fit was poor (p = 0.0129).
However, there were limitations in the way BMDS calculated p-values at that time (i.e., subgrouping
individual litter results) and limitations in the fitting of inter-litter correlations in the 2011 version of
BMDS. Accordingly, EPA conducted further modeling with this data in the original 2011 assessment
and with the latest version of BMDS:

•	2011 Re-analysis: An R program was applied which demonstrated an adequate model
fit (Appendix F in (	)). This approach still relied on the subgrouping of
individual litter results but regrouped the litter data 100 times and reported the
percentage of times the estimated p-value indicated appropriate model fit.

•	New BMDS Analysis (2019): BMD modeling was re-run on the (Johnson et ai. 2003)
dataset using the latest version of the BMDS nested models (v3.1.1), which no longer
requires subgrouping litter data to calculate p-values. The resulting BMDLs and AICs
agreed with results in the 201 1 IRIS Assessment (U.S. EPA. 2 ). However, the p-
value of = 0.661 from the updated BMDS nested model run (Appendix N) is
significantly improved, demonstrating strong model fit and confirming the 2011
conclusion that the modeling results for cardiac malformation data are appropriate for
reference value derivation.

Based on the above considerations and the improved model fit from the updated BMD modeling run,
EPA determined that use of a 1% BMR is most appropriate for risk estimation. The difference
between the 1% and 5% BMR POD values is 5.2-fold. Results for both 1% and 5% extra risk BMR
options (along with 10%) are presented in Appendix N.

Immunotoxicitv

— Immunosuppression (diminished response to infection)

In addition to the previously described developmental toxicity studies, (S el grade and Gilmour.: )
was deemed suitable for dose-response analysis of immunotoxicity based on observed decreased
response to infection. In Selgrade et al (2010). female CD-I mice were infected via respiration with
aerosolized S. zooepidemicus bacteria following 3h exposure to 0, 5, 10, 25, 50, 100, or 200 ppm of TCE.
Mortality was assessed for all dose groups, with statistically significant and dose-responsive increases
observed at 50 ppm and above. Bacterial clearance from the lung, percent of mice infected, and phagocytic
index were also assessed for 0, 50, 100, and 200ppm dose groups. This study examined pulmonary
immunological responses to respiratory infection following inhalation of TCE and is therefore only
applicable to inhalation exposure. The inclusion of the Selgrade and Gilmour (2010) study is an addition

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2014	to this risk evaluation and was not previously evaluated for dose-response analysis in the 2014 TSCA

2015	Work Plan Chemical Risk Assessment (U.S. EPA. 2014b). This study was discussed in the 201 1 IRIS

2016	Assessment (	) but was excluded from the 2014 Risk Assessment in an oversight.

2017

2018	For (S el grade and Gilmour. 20101 BMD modeling was performed on the endpoints of mortality and

2019	percentage of mice infected (see [Personal Communication to OPPT. Raw Data Values from Selgrade

2020	and Gilmour, 2010. Docket: EPA-HQ-OPPT-2019-0500]). A reliable BMDL could not be obtained from

2021	the percentage infected data because BMDs and BMDLs from all models were well below the lowest

2022	data point and cannot be considered reliable. For mortality, a BMR of 1% increase was selected due to

2023	the severity of the effect. Based on evidence of systemic chronic immunosuppression (Sanders et al.

2024	1982; Woolhiser et al.. 20061 this acute endpoint was applied to systemic exposure. Based on assumed

2025	ppm equivalence across species (	), the BMDLi also serves as the HEC for 3hr

2026	exposure, while 1.74 ppm is the HEC for 24hr exposure. Route-to-route extrapolation and allometric

2027	scaling based on values from (	;88) and subsequent allometric scaling results in a dermal

2028	HED of 2.74 mg/kg.

2029

2030	Table 3-7: Dose-response analysis of selected studies considered for acute exposure scenarios

Target
Organ/
System

Species

Duration

POD Type1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

HEC99
(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Develop-
mental
Effects

Rat
(female)

Gestational
days 6 to 15

BMDL01= 32.2
mg/kg-bw/day

Increased
resorptions

TotMetab
BW34

57

23

29

28

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Narotskv et

al, 1995)

High
(1.3)

Rat
(female)

22 days
throughout

gestation
(gestational
days 0 to 22)

BMDL01 =
0.0207 mg/kg-
bw/day

Congenital
heart defects

TotOx
Metab
BW34

0.012

0.0037

0.0058

0.0052

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Johnson et

al. 2003)

Medium
(1.9)

Rat
(male
pups)

Postnatal days
10 to 16

LOAEL = 50
mg/kg-bw/day

Decreased
rearing
activity

TotMetab
BW34

8

3

4.2

4.1

UFS=1;UFA=3;
UFh=3; UFl=10;
Total UF=100

(Fredriksson

et al, 1993)

Medium
(1.7)

Immune
System

Rat
(female)

3hr/day, single
dose; followed
by respiratory
infection

BMDL01 =
13.9 ppm

Immuno-
suppression

N/A4

N/A4

1.744

N/A4

2.744'5

UFS=1;UFA=3;
UFH=10; UFL=1;
Total UF=30

(Sekrade and
Gilmour,

2010)

High
(1.6)

1	POD type can be NOAEL, LOAEL, or BMDL. EPA adjusted all values to continuous exposure.

2	UFS=subchronic to chronic LTF; UFA=interspecies UF; UFH=intraspecies LTF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric.

4Data from Sekrade and Gilmour. 2010) was not subject to PBPK modeling due to uncertainty concerning the most appropriate dose metric. The BMDL value
adjusted for a 24hr exposure will be used as the POD for occupational risk estimates, while the 3hr value will be used for consumer risk estimates. This value is
presented in the HEC99 column but does not represent any particular percentile since it was not PBPK-modeled.

5 A dermal LIED was obtained through route-to-route extrapolation using breathing rate and body weight data on male CD-I mice (insufficient female data was
reasonably available) from ("U.S. EPA, 1988) and allometric scaling based on (U.S. EPA, 201 Id) using a dosimetric adjustment factor of 0.14 for mice.

2031

2032	Table 3-7 presents the derived PODs from all studies considered for dose-response analysis of acute

2033	exposure scenarios. EPA selected studies representative of the distinct endpoints of prenatal mortality,

2034	congenital defects, developmental neurotoxicity, and response to infection. Most of the developmental

2035	toxicity studies utilized the PBPK dose metric of TotMetabBW34, or the total amount TCE metabolized

2036	per unit adjusted body weight. This dose metric was selected because for these endpoints there is

2037	insufficient information for site-specific or mechanism-specific determinations of an appropriate dose-

2038	metric, however in general TCE toxicity is associated with metabolites rather than the parent compound.

2039	TotOxMetab34, or the total amount TCE oxidized per unit adjusted body weight, was used for deriving

2040	HEC/HED values for congenital heart defects because evidence demonstrating effects from TCA and

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2041

2042

2043

2044

2045

2046

2047

2048

2049

2050

2051

2052

2053

2054

2055

2056

2057

2058

2059

2060

2061

2062

2063

2064

2065

2066

2067

2068

2069

2070

2071

2072

2073

2074

2075

2076

2077

2078

2079

2080

2081

2082

2083

2084

2085

2086

2087

2088

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

DCA (see Section 3.2.4.1.6) suggests that oxidative metabolism is important for TCE-induced heart
malformations.

The LogProbit model was selected for BMD modeling results of (Selerade and Gilmour. 2010) data
because it was the model with the lowest AIC, using a BMR of 1% based on the endpoint of mortality.
Data from (Narotsky et al. 1995) and (Johnson et al. 2003) were also BMD modeled. A BMR of 1%
ER was selected for (Johnson et al.. 2003) based on the severity of the effect and absence of a strong
statistical justification for raising the value (see discussion above). A BMR of 1% was also selected for
(Narotsky et al. 1995) because of the severity of the effect (full-litter resorptions) and low background
response. A LOAEL was used as a POD for (Fredriksson et al.. 1993). which was not BMD modeled.
For acute exposures, subchronic-to-chronic UF does not apply, so UFs = 1 for all studies. See Section
3.2.2.1 and (U.S. EPA. ) for more details on TCE PBPK modeling, dose metric selection, and
BMR selection.

Differences from standard UF values are explained below:

A UFa value of 3 was applied to (S el grade and Gilmour. 2010) because cross-species scaling based on
blood:air partition coefficient or allometric scaling for body weight was used to adjust the HEC/HED as
necessary. A UFh of 10 was applied to that study because the data was not subject to PBPK modeling and
therefore a HEC99/HED99 value was not applied which would have accounted for human toxicokinetic
variability.

The selected studies are bold in the table above. The endpoints were each represented by a single study.
While there are some methodological and statistical concerns about (Johnson et al.. 2003) and
(Fredriksson et al.. 1993). based on the WOE for the endpoints and data quality scores of at least
Medium, all four of the studies will be utilized for quantitative risk estimation following acute
exposures. There is also some inherent uncertainty extrapolating from the response to pulmonary
infection observed in (Selerade and Gilmour. 2010) to a systemic response across multiple exposure
routes, but an acute systemic response to infection is likely based on the systemic immunosuppression
observed in a chronic study (Keil et al.. 2009).

3.2.5.3.2 Non-Cancer PODs for Chronic Exposures

Chronic exposure was defined for occupational settings as exposure reflecting a 40-hour work week.
Chronic exposure was not considered relevant to to consumers based on expected use patterns (Section
2.3.2.7.1). Non-cancer endpoints selected as most relevant for calculating risks associated with chronic
(repeated) occupational exposures to TCE included effects on the to the liver, kidney, nervous system,
immune system, reproductive system, and development, with all HECs adjusted to reflect a 24-hr value,
consistent with calculated occupational exposure values.

Liver toxicity

— Increased liver weight and cytotoxicity/hyper trophy

(Ki ell strand et al.. 1983) exposed NMRI male mice (10-20/group) with up to nine different TCE
concentrations. These concentrations ranged from 37 to 3,600 ppm and included an air control group.
Exposures were conducted for various durations (1, 2, 4, 8, 16, or 24 hrs/day) and for different time
frames (from 30 to 120 days). EPA calculated a benchmark concentration lower-bound confidence
limit of 21.6 ppm based on the 10% benchmark response (BMDLio) for increased liver/body weight
ratios, with cytotoxicity and histopathology also observed.

(Buben and O'Flahe 35) exposed Swiss-Cox male mice (12-15 group) to TCE by gavage. Mice
were exposed to a range of TCE doses (100 to 3,200 mg/kg-bw/day plus control) for 5 days/week for 6

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2089	weeks. A BMDLio of 82 mg/kg-bw/day was identified as the POD for increased liver/body weight

2090	ratios, with cytotoxicity and histopathology also observed.

2091

2092	In (Woolhiser et at.. 20061 Sprague-Dawley female rats (16/group) were exposed to TCE via

2093	inhalation at concentrations of 0, 100, 300, or 1,000 ppm for 6 hrs/day, 5 days/week for 4 weeks. A

2094	BMDLio of 25 ppm was estimated for increased liver/body weight ratio.

2095

5 Table 3-J

I: Dose-response analysis of select

ed studies considered for evalual

ion of liver toxicity

Target
Organ
System

Species

Duration

POD Type 1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

HEC99
(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Liver

Mouse
(male)

Continuous and
intermittent
exposures,
variable time
periods for 30-
120 days

BMDL10=21.6
ppm

Increased
liver/body
weight ratio

and
cytotoxicity/
hypertrophy

AMetLivl
BW34

25

9.1

9.0

7.9

UFS=1;UFA=3;
UFh=3; UFl=1;
Total UF=10

(Kiellstrand et

al. 1983)

Medium
(1.8)

Mouse
(male)

6 weeks

BMDLio= 82
mg/kg-bw/day

AmetLivl
BW34

32

11

12

10

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Buben and
O'Flahertv.

1985)

High
(1.3)

Rat
(female)

6 hr/day, 5
days/week for 4
weeks

BMDLio= 25
ppm

Increased
liver/body
weight ratio

AmetLivl
BW34

53

19

19

16

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Woolhiser et
al.2006)

Medium
(2)*

1	POD type can be NOAEL, LOAEL, or BMDL. EPA adjusted all values to continuous exposure.

2	UFS=subchronic to chronic UF; UFA=interspecies UF; UFLl=intraspecies UF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric. * Woolhiser 2006
was downgraded from a Fligh, with calculated score =1.3.

2097

2098	Table 3-8 presents the derived PODs from all studies considered for dose-response analysis. Increased

2099	liver/body weight ratio was the only endpoint modeled from all studies based on the dose metric

2100	AMetLivlBW34, or the amount of TCE oxidized in liver per unit adjusted body weight. This dose metric

2101	was selected because evidence suggests that hepatic oxidative metabolism is involved in TCE liver

2102	toxicity and dose-response relationships using this metric showed greater consistency than other

2103	considered metrics. All studies were BMDL modeled. A BMR of 10% RD was used to represent a

2104	minimal, biologically significant amount of change in relative liver weight. See Section 3.2.2.1 and (

2105	) for more details on TCE PBPK modeling, dose metric selection, and BMR selection.

2106

2107	Differences from standard UF values are explained below:

2108	All three studies were assigned UFs = 1 despite shorter exposure duration because although the studies

2109	were subchronic, hepatomegaly (enlarged liver) occurs rapidly with TCE exposure, and no differences

2110	were observed in severity of relative kidney weight increases between 30 and 120 days in (Kiellstrand et

2111	a I).

2112

2113	The data from (Kiellstrand et al.. 1983) was selected to represent the liver toxicity hazard. (Woolhiser et

2114	al.. 2006) was excluded from further consideration because additional signs of toxicity were not

2115	observed, indicating that the increased liver weight was likely merely adaptive. (Kiellstrand et al.. 1983)

2116	was selected over (Buben and O'Flah )85) because it covered up to 120 days exposure as opposed

2117	to only 42 days. Additionally, (Kiellstrand et al.. 1983) utilized the widest dose range of any study,

2118	imparting more precision in the POD estimate.

2119

2120	Kidney toxicity

2121	— Kidney Pathology

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2122

2123

2124

2125

2126

2127

2128

2129

2130

2131

2132

2133

2134

2135

2136

2137

2138

2139

2140

2141

2142

2143

2144

2145

2146

2147

2148

(Maltoni et ai. 1986) exposed Sprague-Dawley male rats (116-124/group) to TCE via inhalation (0,
100, 300, or 600 ppm) for 7 hrs/day, 5 days/week for 104 weeks (and allowed all rats to continue
unexposed until they died). The investigators also conducted an oral (gavage) study that dosed rats
with a range of TCE doses (50 to 250 mg/kg-bw/day) for 4-5 days/week for 52 weeks. BMDLio
values of 40.2 ppm and 34 mg/kg-bw/day were calculated for the inhalation and gavage studies,
respectively, based on renal tubular pathological changes (meganucleocytosis) observed in male rats
(	). These changes included dose-dependent enlargement of tubuli cells (cytomegaly)

and their nuclei (karyomegaly) leading to dysplasia, which may serve as a precursor to cancer and/or
morphological indicators of damaged kidney function (Maltoni et ai. 1986).

In another oral (gavage) study CNTP. 1988). the National Toxicology Program exposed Marshall female
rats (44-50/group) to TCE (i.e., 0, 500, or 1,000 mg/kg-bw/day) for 5 days/week for 104 weeks. Rats
developed toxic nephropathy following TCE exposure. A BMDLos of 9.45 mg/kg- bw/day was
calculated for the observed kidney effects (	).

— Increased Relative Kidney Weight

(Woolhiser et ai. 2006) conducted an inhalation study that exposed Sprague-Dawley female rats
(16/group) to 0, 100, 300 or 1,000 ppm TCE for 6 hrs/day for 5 days/weeks for 4 weeks. At the end of
the study, rats exhibited increased kidney/body weight ratios and a BMDLio of 15.7 ppm was estimated
for these effects (	).

Increased kidney/body weight ratios were also seen in (Kiellstrand et ai. 1983). NMRI male mice (10-
20/group) were exposed to a range of TCE concentrations (37 to 3,600 ppm) for 30 to 120 days on
continuous and intermittent exposure regimens. A BMDLio of 34.7 ppm was identified as the POD for
increased kidney/body weight ratios (	).

Table 3-9: Dose-response ana

ysis of selected studies considered for evaluation of kidney toxicity

Target
Organ
System

Species

Duration

POD Type 1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

HEC99
(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Kidney

Rat
(female)

5 days/week
for 104 weeks

BMDL05 = 9.45
mg/kg-bw/day

Toxic nephropathy

ABioact
DCVC
BW34

0.042

0.0056

0.033

0.0034

UFs=l;UFA= 3;
UFH=3;UFL=1;
Total UF=10

(NIP. 1988)

Medium
(2)*

Rat
(male)
- Oral

4-5 days/week
for 52 weeks

BMDL10 = 34
mg/kg-bw/day

Pathology
changes in renal
tubule

ABioact
DCVC
BW34

0.19

0.025

0.15

0.015

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Maltoni et
aL 19861

Medium
(2)*

Rat
(male)
- Inhal.

7 hrs/day, 5
days/week for
2 years

BMDL10= 40.2
ppm

Pathology changes
in renal tubule

ABioact
DCVC
BW34

0.28

0.038

0.22

0.023

UFs=l;UFA= 3;
UFH=3;UFL=1;
Total UF=10

(Maltoni et
aL 1986)

Medium
(2)*

Rat
(female)

6 hr/day, 5
days/week for
4 weeks

BMDL10= 15.7
ppm

Increased kidney
weight/body
weight ratio

ABioact
DCVC
BW34

0.099

0.013

0.078

0.0079

UFs=l;UFA= 3;
UFH=3;UFL=1;
Total UF=10

(Woolhiser

et aL. 2006)

Medium
(2)*

Mouse
(male)

Continuous

and
intermittent
exposures for
30-120 days

BMDL10 = 34.7
ppm

Increased kidney
weight/body
weight ratio

AMet
GSH
BW34

0.88

0.12

0.69

0.07

UFs=l;UFA= 3;
UFH=3;UFL=1;
Total UF=10

(Kiellstrand

et aL. 1983)

Medium
(1.8)

1	POD type can be NOAEL, LOAEL, or BMDL. EPA adjusted all values to continuous exposure.

2	UFS=subchronic to chronic UF; LTFA=interspecies UF; UFH=intraspecies UF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric. *NTP 1998 was
downgraded from a High, with calculated score = 1.2; Maltoni 1986 was downgraded from a High, with calculated scores =1.4 (oral) and 1.3 (inhalation);
Woolhiser 2006 was downgraded from a High, with calculated score =1.3.

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2149

2150

2151

2152

2153

2154

2155

2156

2157

2158

2159

2160

2161

2162

2163

2164

2165

2166

2167

2168

2169

2170

2171

2172

2173

2174

2175

2176

2177

2178

2179

2180

2181

2182

2183

2184

2185

2186

2187

2188

2189

2190

2191

2192

2193

2194

2195

2196

2197

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Table 3-9 presents the derived PODs from all studies considered for dose-response analysis. The studies
considered for dose-response analysis identified either indications of kidney pathology or increase
kidney/body weight ratio. All rat studies utilized ABioactDCVCBW34, or the amount of DCVC
bioactivated in the kidney per unit adjusted body weight, because GSH-conjugative bioactivation of
TCE into metabolites such as DCVC in the kidney is expected to be responsible for kidney toxicity.
AMetGSHBW34, or the amount of TCE conjugated with GSH per unit adjusted body weight, was
utilized for mice studies because PBPK information on DCVC activation in mice is not reasonably
available. All studies were BMDL modeled. A BMR of 5% ER was used for (	5) because toxic

nephropathy is a severe toxic effect. (Maltoni etai. 1986) used a BMR of 10% ER because
meganuclocytosis is considered minimally adverse, while both studies examining increased relative
kidney weight used a standard BMR of 10% RD. See Section 3.2.2.1 and (	) for more

details on TCE PBPK modeling, dose metric selection, and BMR selection.

Differences from standard UF values are explained below:

(Woolhiser et al. 2006) and (Kiellstrand et al.. 1983) were assigned UFs = 1 despite shorter exposure
duration because no differences were observed in severity of relative kidney weight increases between 30
and 120 days in (Kiellstrand et al.. 1983).

EPA determined that kidney pathology was a better indicator of adverse kidney effects than increased
relative organ weight and therefore only that endpoint was selected to represent kidney toxicity. While
there are concerns about the procedure of continuing observation until spontaneous death in (Maltoni et
al.. 1986) due to the potential for confounding effects from autophagy or infection, there are unlikely to
be significant artifacts from this methodology affecting the interpretation of kidney lesions. There was
random allocation to study groups and kidney lesions were not observed in the control or lowest dose
group. Therefore, background false positives were not an issue and the observed dose-response is
expected to be independent of this confounder. Additionally, a 2011 review of pathology results from
other cancer studies performed in this laboratory (Ramazzini Institute) by the NTP Pathology Working
Group (Malarkey and Bud	) found good agreement on the interpretation of most solid tumors

and only identified significant differences among inflammatory cancers of the blood and respiratory
tract.

Both (Maltoni et al.. 1986) and (N 38) scored a Medium in data quality, however (Maltoni et al..
1986) tested exposure over a sufficiently similar duration with a more appropriate dose range. The
elevated doses in (NTP. 1988) resulted in massive nephrotoxicity and introduce large uncertainty in
BMD modeling the effects at low doses well below the tested doses with a BMR well below the
observed effect incidence in the study. Therefore, the BMDL and resulting HEC/HED from (Maltoni et
al.. 1986) was considered more reliable. Among the inhalation and oral results from (Maltoni et al..
1986). with few other differences among the data the lower resulting oral POD was selected to represent
the endpoint in order to be health-protective. Of note, this represents a change from the 2014 TSCA Work
Plan Chemical Risk Assessment (	2014b). which selected the POD from (NTP. 1988) to

represent kidney toxicity.

Neurotoxicity

— CNS Depression

(Arito et al.. 1994) exposed Wistar male rats (5/group) to TCE via inhalation to concentrations of 0,
50, 100, or 300 ppm for 8 hrs/day, 5 days/week for 6 weeks. Exposure to all of the TCE concentrations
significantly decreased the amount of time spent in wakefulness during the exposure period. Some
carry over was observed in the 22 hr-post exposure period, with significant decreases in wakefulness
seen at 100 ppm TCE. Significant changes in wakefulness- sleep elicited by the long-term exposure

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2198	appeared at lower exposure levels. The LOAEL for sleep changes was 12 ppm (i.e., LOAEL, adjusted

2199	for continuous exposure) (U.S. EPA. 201 le).

2200

2201	— Trigeminal nerve effects

2202	(Ruiiten et at.. 1991) evaluated the TCE exposures and possible health effects of 31 male printing

2203	workers (mean age: 44 yrs) and 28 unexposed control subjects (mean age: 45 yrs). The exposure

2204	duration was expressed as "cumulative exposure" (concentration x time). Using historical monitoring

2205	data, mean exposures were calculated as 704 ppm x number of years worked, where the mean number

2206	of years was 16 (range: 160-2,150 ppm x yr) (	). The study measured the trigeminal

2207	nerve function by using the blink reflex, but no abnormal findings were observed. However, the study

2208	found a statistically significant average increase in the latency response time in TCE-exposed workers

2209	on the masseter reflex test, another test commonly used to measure the integrity of the trigeminal

2210	nerve. The POD derived from the dataset was a LOAEL of 14 ppm (U.S. EPA. ^ ).

2211

2212	— Neuronal demyelination

2213	(Isaacson etal. 1990) dosed weanling Sprague-Dawley male rats (12/dose group) via the oral route

2214	(drinking water) in an experimental protocol for an 8-week period. The control group had unexposed

2215	rats for 8 weeks. The experimental group#l exposed rats to 47 mg/kg-bw/day TCE for 4 weeks and

2216	then no TCE exposure for 4 weeks. The experimental group#2 exposed rats to 47 mg/kg-bw/day TCE

2217	for 4 weeks, no TCE exposure for the following 2 weeks, and then 24 mg/kg-bw/day TCE for the final

2218	2 weeks. Rats in group#2 reported a decreased latency to find the platform in the Morris water maze

2219	test. While these results actually suggest increased cognitive performance, all of the TCE-treated groups

2220	exhibited hippocampal demyelination, with effects more severe in the twice-exposed group. The

2221	LOAEL for neurodegenerative effects (i.e., demyelination in the hippocampus) was 47 mg/kg-bw/day

2222	(	).

2223

224 1

"able 2

i-10: Dose-response analysis of se

ected studies considered for evaluation of neurological ei

'fects

Target
Organ
System

Species

Duration

POD Type 1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

hec99

(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Nervous
system

Rat
(male)

8 hrs/day, 5
days/weeks
for 6 weeks

LOAEL=
12 ppm

Significant
decreases in
w akefulness

TotMetab
BW34

13

4.8

6.6

6.5

UFS=3;UFA=3;
UFh=3; UFL=10;
Total UF=300

(Arito et al,

1.994)

Medium
(2)"

Human
(both
sexes)

Mean of 16
years

LOAEL=
14 ppm

Trigeminal nerve
effects (increased

latency in
masseter reflex)

TotMetab
BW34

14

5.3

7.4

7.3

UFS=1; UFA= 1;
UFH=3; UFl=3;
Total UF=10

(Ruiiten et
al. 1991)

Medium
(1.7)

Rat
(male)

8 weeks
(intermittent)

LOAEL = 47
mg/kg-
bw/day

Demyelination of
hippocampus

TotMetab
BW34

18

7.1

9.4

9.2

UFS=10;UFA=3;
LTFH=3; UFL=10;
Total UF=1000

(Isaacson et

al. 1990)

Medium
(2)*

1	POD type can be NOAEL, LOAEL, or BMDL. EPA adjusted all values to continuous exposure.

2	LTFS=subchronic to chronic UF; UFA=interspecies UF; UFH=intraspecies UF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric. *Arito 1994 was
downgraded from a High, with calculated score =1.6; Isaacson 1990 was downgraded from a High, with calculated score =1.6

2225

2226	Table 3-10 presents the derived PODs from all studies considered for dose-response analysis. The

2227	reasonably available datasets for considering neurotoxicity included single studies for each of the three

2228	endpoints of central nervous system (CNS) depression, trigeminal nerve effects, and neuronal

2229	demyelination. The TotMetabBW34 dose metric, or the total amount TCE metabolized per unit adjusted

2230	body weight, was used for all three studies. Thise dose metric was selected because for these endpoints

2231	there is insufficient information for site-specific or mechanism-specific determinations of an appropriate

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2232

2233

2234

2235

2236

2237

2238

2239

2240

2241

2242

2243

2244

2245

2246

2247

2248

2249

2250

2251

2252

2253

2254

2255

2256

2257

2258

2259

2260

2261

2262

2263

2264

2265

2266

2267

2268

2269

2270

2271

2272

2273

2274

2275

2276

2277

2278

2279

2280

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

dose-metric, however in general TCE toxicity is associated with metabolites rather than the parent
compound. LOAELs were used as PODs for all studies, and none were BMD modeled. See Section
3.2.2.1 and (U.S. EPA. ) for more details on TCE PBPK modeling and dose metric selection.

Differences from standard UF values are explained below:

(Artto et al. 1994) was assigned UFs = 3 (instead of 10) despite being only a 6 week study because
effects observed at 6 weeks exposure were only minimally different than effects at 2 weeks (differences
observed post-exposure).

(Ruiiten et al.. 1991) was assigned UFs = 1 because the data was based on a mean of 16 years of human
exposure. UFl = 3 (instead of 10) due to the observed effect being an early marker and representing a
minimal degree of change.

EPA did not select (Isaacson et al.. 1990). demonstrating demyelination of the hippocampus, to
represent the neurotoxicity hazard because dosing during the study was not continuous and the resulting
POD was subject to a large cumulative uncertainty factor (1000). (Arito et al.. 1994) and (Ruiiten et al..
1991) were both considered for use in quantitative risk estimation as they were relatively well-conducted
studies examining independent endpoints within the hazard of neurological effects.

Immunotoxicitv

—	Thymus Effects / Autoimmunity

(Keil et al.. 2009) exposed B6C3F1 mice (10/group), a standard test strain not genetically prone to
develop autoimmune disease, to TCE via drinking water for 27 or 30 weeks at concentrations in water
of 0, 1.4, or 14 ppm (0.35 or 3.5 mg/kg-bw/day). The study reported a significant decrease in thymus
weight concentrations and thymic cellularity as well as an increase in autoantibodies to ssDNA and
dsDNA. A LOAEL of 0.35 mg/kg-bw/day was identified as the POD for the thymic and autoimmune
effects (	).

—	Autoimmunity

(Kaneko et al.. 2000) exposed auto-immune prone mice (5/group) to TCE via inhalation at
concentrations of 0, 500, 1,000, or 2,000 ppm for 4 hrs/day, 6 days/week, for 8 weeks. At
concentrations > 500 ppm, mice exhibited dose-related liver inflammation, splenomegaly and
hyperplasia of lymphatic follicles. Immunoblastic cell formation in lymphatic follicles was observed in
mice treated with 1,000 ppm TCE. The LOAEL of 70 ppm (adjusted for continuous 24hr exposure)
was identified for these effects (	).

—	Immunosuppression

In (Sanders et al.. 1982). male and female CD-1 mice (7-25/group) were given TCE in drinking water
concentrations of 0, 0.1, 1.0, 2.5, or 5.0 mg/mL (0, 18, 217, 393 or 660 mg/kg-bw/day) for 4 or 6
months. Female mice showed decreased humoral immunity at 2.5 and 5 mg/mL (393 or 660 mg/kg-
bw/day), whereas cell-mediated immunity and bone marrow stem cell colonization decreased at all four
concentrations. Male mice were relatively unaffected after both 4 and 6 months of exposure. A LOAEL
of 18 mg/kg-bw/day was identified as the POD for immunosuppressive effects " \ \ \ :0 lie).

Another study that was previously discussed for liver and kidney effects (Woolhiser et al.. 2006) also
reported immunosuppressive effects. Sprague-Dawley female rats (16/group) were treated with 0, 100,
300 or 1,000 ppm TCE for 6 hrs/day, 5 days/week for 4 weeks. Four days prior to study termination,
the rats were immunized with sheep red blood cells (SRBC), and within 24 hrs following the last
exposure to TCE, a plaque-forming cell (PFC) assay was conducted to determine effects on splenic
anti-SRBC IgM response. At 1,000 ppm, rats demonstrated a 64% decrease in the PFC assay response.

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2281	A BMDLisd of 24.9 ppm was identified for this immunosuppressive effect (\ v << \ _\"W 1^).

2282

2283	Table 3-11: Dose-response analysis of selected studies considered for evaluation of immune effects

Target
Organ
System

Species

Duration

POD Type 1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

hec99

(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Immune
system

Mouse
(female)

27-30 weeks

LOAEL = 0.35
mg/kg-bw/day

Decrease in
thymus weight
and thymus
cellularity

TotMetab
BW34

0.092

0.033

0.049

0.048

UFS=1;UFA=3;
UFh=3;UFl=10;
Total UF=100 4

(Keil et al.,

2009)

High
(1.6)

Mouse
(female)

27-30 weeks

LOAEL = 0.35
mg/kg-bw/day

Autoimmunity

(increased
anti- dsDNA
and ssDNA
antibodies)

TotMetab
BW34

0.092

0.033

0.049

0.048

UFS=1;UFA=3;
UFh=3; UFl=3;
Total UF=30 4

(Keil et al.,

2009)

High
(1.6)

Mouse
(males;
auto-
immune
prone
strain)

4 hrs/day, 6
days/week
for 8 weeks

LOAEL = 70
ppm

Autoimmunity

(changes in
immunoreactive
organs)

TotMetab
BW34

97

37

44

42

UFS=10; UFA= 3;
UFH=1;UFL=10;
Total UF=300

(Kaneko et

al. 2000)

High
(1.5)

Mouse
(female)

16 or 24
weeks (4 or
6 months)

LOAEL =18
mg/kg-bw/day

Immuno-
suppression

TotMetab
BW34

4.8

1.7

2.5

2.5

UFS=1;UFA=3;
UFh=3; UFl=10;
Total UF=100

(Sanders et
al, 1982)

High
(1.4)

Rat
(female)

6 hrs/day, 5
days/week
for 4 weeks

BMDL1sd=
24.9 ppm

Immuno-
suppression

TotMetab
BW34

29

11

14

14

UFS=10; UFA= 3;
UFH=3;UFL=1;
Total UF=100

fWoolliiser
et al, 2006)

High
(1.1)

1 POD type can be NOAEL, LOAEL, or BMDL. The IRIS program adjusted all values to continuous exposure.

2UFS=subchronic to chronic UF; UFA=interspecies UF; UFFI=intraspecies UF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric.

4	Two different effects were reported by Keil et al, (2009): decreased thymic weight and cellularity and autoimmunity. A total UF of 100 was used for the
thymus toxicity, whereas a total UF of 30 was used for the autoimmune effects. The TCE IRIS assessment allocated different LOAEL-to-NOAEL
uncertainty factors (UFL) based on the severity of the effects, which resulted in different total UF (U.S. EPA, 201 le).

2284

2285

2286

2287

2288

2289

2290

2291

2292

2293

2294

2295

2296

2297

2298

2299

2300

2301

2302

2303

2304

Table 3-11 presents the derived PODs from all studies considered for dose-response analysis. These
studies covered the endpoints of thyroid effects, autoimmunity, and immunosuppression. The
TotMetabBW34 dose metric, or the total amount TCE metabolized per unit adjusted body weight, was
used for all three studies. This dose metric was selected because for these endpoints there is insufficient
information for site-specific or mechanism-specific determinations of an appropriate dose-metric,
however in general TCE toxicity is associated with metabolites rather than the parent compound.
LOAELs were used as PODs for all studies except (Woolhiser et at.. 2006). which was BMD modeled
with a BMR of 1 SD because it was unclear what should constitute the cutoff point for a minimal,
biologically significant change. See Section 3.2.2.1 and (	) for more details on TCE

PBPK modeling, dose metric selection, and BMR selection.

Differences from standard UF values are explained below:

(Keil et at.. 2009) was assigned UFi = 3 (instead of 10) due to the observed effect being considered an
early, subclinical or pre-clinical early marker of disease.

Decreased thymus weight and eellularity as observed in (Kelt et at.. 2009) was not considered for use in
risk estimation because EPA determined that this effect is insufficiently adverse compared to the other
endpoints. Of note, elimination of this endpoint and corresponding change in total UF represents a change
from the 2014 TSCA. Work Plan Chemical Risk Assessment (	1014b). The data from (Keil et

at.. 2009) was selected to represent autoimmunity however, because the study was of longer duration than

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2306

2307

2308

2309

2310

2311

2312

2313

2314

2315

2316

2317

2318

2319

2320

2321

2322

2323

2324

2325

2326

2327

2328

2329

2330

2331

2332

2333

2334

2335

2336

2337

2338

2339

2340

2341

2342

2343

2344

2345

2346

2347

2348

2349

2350

2351

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

(Kaneko et ai. 2000) with a smaller cumulative uncertainty factor. (Sanders et ai. 1982) was selected to
represent immunosuppression because the study was of a much longer duration than (Woolhiser et al..
2006).

Reproductive toxicity

— Male Reproductive Effects

(Chia et al. 1996) examined a cohort of 85 workers in an electronics factory. The workers provided
urine, blood, and sperm samples. The mean urine TCA level was 22.4 mg/g creatinine (range: 0.8-
136.4 mg/g creatinine). In addition, 12 workers provided personal 8-hr air samples, which resulted in a
mean TCE exposure of 29.6 ppm (range: 9-131 ppm). There were no controls in the study. Males
experienced decreased percentage of normal sperm morphology and hyperzoospermia. A BMDLio of
1.4 ppm was identified as the POD for these effects (	).

(Xu et al.. 2004) exposed male CD-1 mice (27/group) to TCE at concentration of 0 or 1,000 ppm for 6
hrs/day, 5 days/week for 6 weeks. Inhalation exposure to TCE did not result in altered body weight,
testis and epididymis weights, sperm count, or sperm morphology or motility.

Percentages of acrosome-intact sperm populations were similar between treated and control animals.
However, decreased in vitro sperm-oocyte binding and reduced in vivo fertilization were observed in
TCE-treated male mice. A LOAEL of 180 ppm (adjusted for continuous 24hr exposure) was identified
as the POD for these effects (	).

(Kumar et al.. 2000) and (Kumar et al.. 2001) exposed male Wistar rats by inhalation at concentrations
of 0 or 376 ppm TCE. Both study protocols exposed rats for 4 hrs/day, 5 days/week, but had variable
duration scenarios. For instance, (Kumar et al.. 2000) treated rats for the following exposure durations:
2 weeks (to observe the effect on the epididymal sperm maturation phase), 10 weeks (to observe the
effect on the entire spermatogenic cycle), 5 weeks with 2 weeks of rest (to observe the effect on
primary spermatocytes differentiation to sperm), 8 weeks with 5 weeks of rest (to observe effects on an
intermediate stage of spermatogenesis), or 10 weeks with 8 weeks of rest (to observe the effect on
spermatogonia! differentiation to sperm). (Kumar et al.. 2001) exposed rats for either 12 or 24 weeks.

(Kumar et al.. 2000) reported altered testicular histopathology, increased sperm abnormalities, and
significantly increased pre- and/or postimplantation loss in litters in the groups with 2 or 10 weeks of
exposure, or 5 weeks of exposure with 2 of weeks rest. Multiple sperm effects were observed in another
study by Kumar (2001). After 12 weeks of TCE exposure, rats exhibited decreased number of
spermatogenic cells in the seminiferous tubules, fewer spermatids as compared to controls, and the
presence of necrotic spermatogenic cells. Following 24 weeks of exposure, male rates showed reduced
testes weights and epididymal sperm count and motility, testicular atrophy, smaller tubules,
hyperplastic Ley dig cells, and a lack of spermatocytes and spermatids in the tubules. Testicular marker
enzymes were altered at both 12 and 24 weeks of exposure. A LOAEL of 45 ppm was identified as the
POD for the sperm and male reproductive effects reported in both studies (	).

(Kan et al.. 2007) also provided evidence for the damage to the epididymis epithelium and sperm.
CD-I male mice (4/group) were exposure by inhalation to 0 or 1,000-ppm TCE for 6 hrs/day, 5
days/week for 1 to 4 weeks. As early as 1 week after TCE exposure, exposed mice showed
degeneration and sloughing of epithelial cells. These effects increased in severity at 4 weeks of
exposure. A LOAEL of 180 ppm (adjusted for continuous 24hr exposure) was identified as a POD for
the effects in the epididymis epithelium.

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2357

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—	Female Reproductive Effects

(Narotsky et al. 1995) administered TCE to F344 timed-pregnant rats (8-12 dams/group) by gavage.
Dams were exposed to TCE doses of 0, 10.1,32, 101, 320, 475, 633, 844 or 1125 mg/kg-bw/day during
gestational days (GD) 6 to 15. The study was a prequel to a complicated protocol with other chemicals
in a mixture study. Delayed parturition was observed at >475 mg/kg- bw/day. The LOAEL for female
reproductive effects was 475 mg/kg-bw/day (	)

—	Diminished Reproductive Behavior

George et al. (1986) administered TCE to both male and female F344 rats (20 each treated, 40 each
controls) in feed with estimated doses of 0, 72, 186, or 389 mg/kg-bw/day. Breeders were exposed for
one week premating and then for 13 weeks while cohabitating. Pregnant females were subsequently
exposed throughout gestation (an additional 4 weeks). Copulation was reduced equally following
either exposed males or exposed females cohabitating with control mates (highest dose only
examined). This corresponded with a dose-responsive decrease in the number of litters produced per
breeding pair and the number of live pups per litter.

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2370 Table 3-]

2: Dose-res

ponse analysis of selected studies consideret

for evaluation of reproductive effects

Target
Organ
System

Species

Duration

POD Type1
(applied dose)

Effect

Dose
Metric

HECS0
(ppm)

HEC99
(ppm)

HED50
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs) 2

Reference

Data
Quality 3

Reproductive
system

Human
(male)

Measured
values after an
8-hr work shift;
mean 5.1 years
on the job

BMDL10 =
1.4 ppm

Hyper-
zoospermia

TotMetab
BW34

1.4

0.5

0.74

0.73

UFS=10; UFA= 1;
UFH=3;UFL=1;
Total UF=30

(Chia et al,
1996)

Medium
(1.8)

Rat
(male)

4 hrs/day, 5
days/week, 2-10
weeks exposed,
2-8 weeks
unexposed

LOAEL = 45
ppm

Sperm effects and
male reproductive
tract effects

TotMetab
BW34

32

13

16

16

UFS=10; UFA= 3;
UFH=3; UFl=10;
Total UF=1000

(Kumar et

al.2000)

Medium
(1.7)

4 hrs/day, 5
days/week for
12 or 24 weeks

(Kumar et

al. 200D

High
(1.4)

Mouse
(male)

6 hrs/day, 5
days/week for 1 -
4 weeks

LOAEL = 180
ppm

Effects on
epididymis
epithelium

TotMetab
BW34

190

67

80

73

UFS=10; UFA= 3;
UFH=3; UFl=10;
Total UF=1000

(Kan et al.
2007)

Medium
(2)*

Mouse
(male)

6 hrs/day, 5
days/week for 6
weeks

LOAEL = 180
ppm

Sperm effects
(decreased in
vitro sperm-
oocyte binding
and in vivo
fertilization)

TotMetab
BW34

190

67

80

73

UFS=10; UFA= 3;
UFH=3; UFl=10;
Total UF=1000

(Xu et al.
2004)

High
(1.4)

Rat
(female
dams)

9 days (during
gestational days
6 to 15)

LOAEL=
475 mg/kg-
bw/day

Delayed
parturition

TotMetab
BW34

98

37

47

44

UFS=1;UFA=3;
UFh=3; UFL=10;
Total UF=100

(Narotskv
et al,
1995)

High
(1.3)

Rat
(male/
female)

Breeders
exposed 1 week
premating and
then for 13

weeks
cohabitating

LOAEL = 389
mg/kg-bw/day

Decreased
copulation;
reduced numbers
of live litters/pair
and pups/litter

TotMetab
BW34

204

71

85

77

UFS=1;UFA=3;
UFH=3; UFL=10;
UFD=1
Total UF=100

(George et

al. 1986)

High
(1.1)

1	POD type can be NOAEL, LOAEL, or BMDL. The IRIS program adjusted all values to continuous exposure.

2	UFS=subchronic to chronic UF; UFA=interspecies UF; LTFH=intraspecies UF; UFL=LOAEL to NOAEL UF.

3	See [Data Quality Evaluation of Human Health Hazard Studies. Docket: EPA-HQ-OPPT-2019-0500] for full evaluation by metric. *Kan 2007 was
downgraded from a High, with calculated score =1.6.

2371

2372	Table 3-12 presents the derived PODs from all studies considered for dose-response analysis. The

2373	majority of studies identified effects indicative of male reproductive toxicity, with one study

2374	demonstrating female reproductive toxicity. The TotMetabBW34 dose metric, or the total amount TCE

2375	metabolized per unit adjusted body weight, was used for all three studies. This dose metric was selected

2376	because for these endpoints there is insufficient information for site-specific or mechanism-specific

2377	determinations of an appropriate dose-metric, however in general TCE toxicity is associated with

2378	metabolites rather than the parent compound. For (Chia et at.. 1996). the 2011 IRIS Assessment (U.S.

2379	) notes some additional uncertainty in the dose estimate because exposure groups were

2380	defined by ranges and exposure was estimated by conversion of urinary TCA. LOAELs were used as

2381	PODs for all studies except (Chia et	6), which was BMD modeled with a standard BMR of 10%

2382	extra risk. The 2011 IRIS Assessment (1 c. 1 ^ \ JO I I e) indicates some uncertainty in the biological

2383	signficance of this BMR because the study used a lower cutoff to define hyperzoospermia than other

2384	studies. See Section 3.2.2.1 and (U.S. EPA. ) for more details on TCE PBPK modeling, dose

2385	metric selection, and BMR selection.

2386

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2400

2401

2402

2403

2404

2405

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2407

2408

2409

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For male reproductive toxicity, (Chia et ai. 1996) was selected over the other studies because it was a
human study over a mean 5.1 year period compared to the other studies which were in mice and all for
only a few weeks except for (Kumar et ai. 2001). Additionally, (Chia et ai. 1996) only has a
cumulative uncertainty factor of 30, compared to 1000 for the other three studies. (Narotsky et ai.
1995) received a High in data quality evaluation and was deemed suitable for quantitative assessment
of female reproductive toxicity based on delayed parturition (giving birth). While (George et ai. 1986)
received a High in data quality evaluation, it is unclear whether the observed effects are a result of true
reproductive toxicity or merely behavioral changes (i.e. unsuccessful copulation vs. reduced libido).
Effects on copulation are also likely downstream of any specific male or female reproductive
endpoints, which have more sensitive PODs than (George et ai. 1986). Therefore, the POD for
reduced copulation was not selected to represent the reproductive toxicity hazard.

Developmental toxicity

As described above in Section 3.2.5.3.1, developmental effects may result from single as well as
repeated exposures at a developmentally critical period; therefore the same endpoints are relevant for
both acute and chronic exposure scenarios. The only difference between acute and chronic exposure
scenarios in evaluating developmental toxicity is the benchmark MOE for (Fredriksson et ai. 1993). The
subchronic-to-chronic UFs = 3 for chronic exposure, because the study only exposed pups during
postnatal days 10-16, suggesting that exposure during a longer period of development may have
exacerbated the observed effects (UFs would not =10 because neurological development only occurs
over a portion of a lifetime). This results in a cumulative UF and benchmark MOE of 300. See Section
3.2.5.3.1 for a detailed description of the developmental toxicity endpoints.

3.2.5.3.3 Cancer POD for Lifetime Exposures

EPA utilized linear low-dose extrapolation for derivation of PODs accounting for all three cancer types.
Regarding low-dose extrapolation, a key consideration in determining what extrapolation approach to
use is the mode(s) of action. However, mode-of-action data are lacking or limited for each of the cancer
responses associated with TCE exposure, with the exception of the kidney tumors (see Section
3.2.4.2.2). For the other TCE-induced cancers, the mode(s) of action is unknown. When the mode(s) of
action is identified as genotoxic or cannot be clearly defined, EPA generally uses a linear approach to
estimate low-dose risk (	05), based on the following general principles:

1)	A chemical's carcinogenic effects may act additively to ongoing biological processes,
given that diverse human populations are already exposed to other agents and have
substantial background incidences of various cancers.

2)	A broadening of the dose-response curve (i.e., less rapid fall-off of response with decreasing dose) in
diverse human populations and, accordingly, a greater potential for risks from low-dose exposures (Lutz
et ai. 2005; Zeise et ai. 1987) is expected for two reasons: First, even if there is a threshold
concentration for effects at the cellular level, that threshold is expected to differ across individuals.
Second, greater variability in response to exposures would be anticipated in heterogeneous populations
than in inbred laboratory species under controlled conditions (due to, e.g., genetic variability, disease
status, age, nutrition, and smoking status).

3)	The general use of linear extrapolation provides reasonable upper-bound estimates that
are believed to be health-protective (	>) and also provides consistency
across assessments.

Dose-response analysis of kidney cancer utilized ABioactDCVCBW34, or the amount of DCVC
bioactivated in the kidney per unit adjusted body weight, for the same rationale as described above for

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kidney non-cancer effects. Dose-response modeling for kidney cancer from Charbotel et al. (2006) was
performed by linear regression weighted by the inverse of variances for RR estimates. Consistent with
EPA's Guidelines for Carcinogen Risk Assessment (	05), the same data and methodology

were also used to estimate the exposure level (ECx: —effective concentration corresponding to an extra
risk of x%) and the associated 95% lower confidence limit of the effective concentration corresponding
to an extra risk of 1% (LECx [lowest effective concentration], x = 0.01). A 1% extra risk level is
commonly used for the determination of the POD for epidemiological data. Use of a 1% extra risk level
for these data is supported by the fact that, based on the actuarial program, the risk ratio (i.e., Rx/Ro) for
an extra risk of 1% for kidney cancer incidence is 1.9, which is in the range of the ORs reported by
Charbotel et al (ORs range from 1.16-2.16 across exposure tertiles). Thus, 1% extra risk was selected
for determination of the POD, and, consistent with EPA's Guidelines for Carcinogen Risk Assessment
(I	|), the LEC value corresponding to that risk level was used as the actual POD. For more

details, see Section 5.2.2 in the 2011 IRIS Assessment (U.S. EPA. ). Based on the results of the
meta-analysis (Section 3.2.4.2.1 and Appendix H) confirming a positive association between TCE
exposure and all three cancer sites, the derived PODs will remain the same as for (	) and

(I	)•

The inhalation unit risk (IUR) for TCE is defined as a plausible upper bound lifetime extra risk
of cancer from chronic inhalation of TCE per unit of air concentration. The estimate of the inhalation
unit risk for TCE is 2.20 x 10"2 per ppm (2 x 10"2 per ppm [4 x 10"6 per [j,g/m3]) rounded to one
significant figure), based on human kidney cancer risks reported by Charbotel et al. (2006) and adjusted
4-fold upward for potential additional risk for NHL and liver cancer. This estimate is based on High-
quality human data, thus avoiding the uncertainties inherent in interspecies extrapolation. This value is
supported by inhalation unit risk estimates demonstrating multisite carcinogenicity in several rodent
bioassays, the most sensitive of which range from 1 x 10"2 to 2 x 10"1 per ppm [2 x 10"6 to 3 x 10"5 per
Hg/m3].

The IUR from Charbotel et al. (2006) (calculated as 5.49 x 10"3 per ppm) was adjusted by a factor of
four to account for estimating risk to all three cancer types combined (i.e., lifetime extra risk for
developing any of the three types of cancer) versus the extra risk for kidney cancer alone. Although only
the Charbotel et al. (2006) study was found adequate for direct estimation of inhalation unit risks, the
available epidemiologic data provide sufficient information for estimating the relative potency of TCE
across tumor sites. Section 5.2.2 of the 2011 IRIS Assessment (	) describes the process

for this adjustment. In short, extra lifetime cancer risks were summed across the three cancer types and
the ratio of the sum of the extra risks to the extra risk for kidney alone was derived. EPA calculated this
ratio using two sets of data: the summary RR estimates from the 2011 meta-analyses for NHL, kidney
cancer, and liver cancer, and the SIR estimates for all three cancer types from the Raaschou-Nielsen et
al. (2003) study. The value for the ratio of the sum of the extra risks to the extra risk for RCC alone was
3.28 from the first calculation (using meta-analysis results) and 4.36 from the second calculation (using
Raaschou-Nielsen et al. data). The geometric and arithmetic mean of these two values is 3.8, and EPA
decided to round up to 4 based on the imprecision of the adjustment factor.

The oral slope factor (OSF) for TCE is defined as a plausible upper bound lifetime extra risk of
cancer from chronic ingestion of TCE per mg/kg/day oral dose. The estimate of the oral slope factor is
4.64 x 10"2 per mg/kg/day (5 x 10"2 per mg/kg/day rounded to one significant figure), resulting from
PBPK model-based route-to-route extrapolation of the inhalation unit risk estimate based on the human
kidney cancer risks reported in Charbotel et al. (2006) and adjusted 5-fold upward for potential risk for
NHL and liver cancer. For this adjustment, individual IUR estimates were first obtained for each site
based on the ratios of extra risk relative to kidney. Those site-specific IUR estimates were then

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extrapolated to the equivalent OSFs using site-specific dose metrics,18 and those individual OSFs were
summed to obtain a ratio of 5.0 relative to kidney cancer alone. Uncertainty in the PBPK model-based
route-to-route extrapolation is relatively low, however variability stemming from the requirement of
using distinct dose-metrics for the different target tissues resulted in a larger 5-fold adjustment, as
opposed to the 4-fold adjustment calculated for the IUR. Extrapolation using different dose-metrics
yielded expected population mean risks within about a two-fold range, and, for any particular dose-
metric, the 95% CI for the extrapolated population mean risks for each site spanned a range of no more
than about threefold. The resulting combined OSF value is supported by oral slope factor estimates from
multiple rodent bioassays, the most sensitive of which range from 3 x 10"2 to 3 x 10"1 per mg/kg/day.

EPA decided not to use the IUR or OSF to calculate the theoretical cancer risk associated with a single
(acute) exposure to TCE. NRC (2001) published methodology for extrapolating cancer risks from
chronic to short-term exposures to mutagenic carcinogens, however these methods were published with
the caveat that extrapolation of lifetime theoretical excess cancer risks to single exposures has great
uncertainties. Thus, this risk evaluation plan risk assessment for TCE does not estimate excess cancer
risks for acute exposures because the relationship between a single short-term exposure to TCE and the
induction of cancer in humans has not been established in the current scientific literature. Risk estimates
for cancer will be based on lifetime exposure durations, represented as Lifetime Average Daily
Concentration/Dose (LADC/LADD).

3.2.5.4 Selected PODs for Human Health Hazard Domains

Table 3-13 and Table 3-14 list the studies and corresponding HECs, HEDs, and UFs that EPA is using
in the TCE Risk Evaluation following acute and chronic exposure. Table 3-15 provides the cancer
PODs for evaluating lifetime exposure. Key studies in Table 3-13 and Table 3-14 are briefly described
in Section 3.2.5.1. Presenting PODs for the HEC/HED50 and HEC/HED99 values is intended to provide
a sense of the difference between the median and 99% confidence bound for the combined uncertainty
and variability. Calculations of HEC50/99 and HED50/99 ratios generally showed a 2-3 fold difference
for the various studies described in Section 3.2.5.3. The exception was for studies reporting kidney
effects, which showed high HEC50/99 and HED50/99 ratios (7 to 10-fold) due to larger uncertainty in
the rodent internal dose estimates for the GSH metabolism dose metrics (e.g., ABioActDCVCBW34)
(I	) and greater influence of human variability. Confidence in these metrics was lower

for mouse data due to an absence of GSD-specific in vivo data, however uncertainty was similar as to
other metrics for rat and human data (	). The HEC/HED99 values represent the PODs

that are expected to be protective of sensitive subpopulations, accounting for the majority of identified
toxicokinetic human variability.

18 Kidney: ABioactDCVCBW34; NHL: TotMetabBW34; Liver: AMetLivlBW34

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i-13: Dose-response ana

ysis of selected stut

ies considered for acute exposure scenarios

()r»;ui/
S\ skill

Spwics

Duniliiin

POD T\ pi-

feipplkildiiM-)

I.IIWl

IW
Miirii'

II Ms.

(|>|>m>

MIX,.,
(ppm)

111:1).;.,

INI).'.

(m»/k»)

I luiThiiim
l-'iii'iiirs (I I s)

kll'l'IVIHl'

Diilii
Qu;ilil\

Develop-
mental
Effects

Rat
(female)

Gestational days
6 to 15

BMDL01= 32.2
mg/kg-bw/day

Increased
resorptions

TotMetab
BW34

57

23

29

28

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF= 10

(Narotskv et

al, 1995)

High

Rat
(female)

22 days
throughout
gestation
(gestational days
0 to 22)

BMDL01 =
0.0207 mg/kg-
bw/day

Congenital
heart defects

TotOx
Metab
BW34

0.012

0.0037

0.0058

0.0052

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF= 10

(Johnson et

al. 2003)

Medium

Rat
(male
pups)

Postnatal days
10 to 16

LOAEL = 50
mg/kg-bw/day

Decreased
rearing activity

TotMetab
BW34

8

3

4.2

4.1

UFs=l; UFa= 3;

UFH=3; UFL=10;
Total UF= 100

(Tredriksson

et al. 1993)

Medium

Immune
System

Rat
(female)

3hr/day, single
dose; followed
by respiratory
infection

BMDL01 =
13.9 ppm

Immuno-
suppression

N/A1

N/A1

1.74 1

N/A1

2.74 1'2

UFS=1;UFA=3;
UFH=10; UFL=1;
Total UF=30

(Selarade and
Gilmour,

2010)

High

1	Data from (Sel grade and Gilmour, 2010) was not subject to PBPK modeling due to uncertainty concerning the most appropriate dose metric. The BMDL value
adjusted for a 24hr exposure will be used as the POD for occupational risk estimates, while the 3hr value will be used for consumer risk estimates. This value is
presented in the HEC99 column but does not represent any particular percentile since it was not PBPK-modeled.

2	A dermal HED was obtained through route-to-route extrapolation using breathing rate and body weight data on male CD-1 mice (insufficient female data was
reasonably available) from ("U.S. EPA, 1988) and allometric scaling based on ("U.S. EPA, 201 Id) using a dosimetric adjustment factor of 0.14 for mice.

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able 3-14: Dose-response ana

Target
Organ
System

Species

Duration

POD Type
(applied dose)

Effect

Dose Metric

hec50

(ppm)

hec99

(ppm)

HEDso
(mg/kg)

HED99
(mg/kg)

Uncertainty
Factors (UFs)

Reference

Data
Quality

Liver

Mouse
(male)

Continuous and
intermittent
exposures, variable
time periods for 30-
120 days

BMDLio=
21.6 ppm

Increased liver/body
weight ratio and
cytotoxicity/
hypertrophy

AMetLivl
BW34

25

9.1

9.0

7.9

UFs=l;UFA= 3;
UFh=3; UFl=1;
Total UF=10

(Kiellstrand et
al., 1983)

Medium

Kidney

Rat
(male)
- Oral

4-5 days/week for
52 weeks

BMDL10 = 34
mg/kg-bw/day

Pathology changes in
renal tubule

ABioact
DCVCBW34

0.19

0.025

0.15

0.015

UFS=1;UFA=3;
UFh=3; UFl=1;
Total UF=10

(Maltoni et al..
1986)

Medium

Nervous
System

Rat
(male)

8 hrs/day, 5
days/weeks for 6
weeks

LOAEL =
12 ppm

Significant decreases
in wakefulness

TotMetab
BW34

13

4.8

6.6

6.5

UFS=3; UFA= 3;
UFH=3; UFL=10;
Total UF=300

(Arito et al..
1994)

Medium

Human
(bo tli

sexes)

Mean of 16 years

LOAEL=
14 ppm

Trigeminal nerve
effects (increased
latency in masseter
reflex)

TotMetab
BW34

14

5.3

7.4

7.3

UFS=1;UFA= 1;
UFH=3; UFL=3;
Total UF=10

(Ruiiten et al..
1991)

Medium

Immune
System

Mouse
(female)

27-30 weeks

LOAEL = 0.35
mg/kg-bw/day

Autoimmunity
(increased anti-
dsDNA and ssDNA
antibodies)

TotMetab
BW34

0.092

0.033

0.049

0.048

UFS=1;UFA=3;
UFH=3; UFL=3;
Total UF=30

(Keil et al..
2009)

High

Mouse
(female)

16 or 24 weeks
(4 or 6 months)

LOAEL= 18
mg/kg-bw/day

Immunosuppression

TotMetab
BW34

4.8

1.7

2.5

2.5

UFs=l;UFA= 3;
UFH=3; UFL=10;
Total UF=100

(Sanders et al..
1982)

High

Repro-
ductive
System

Human
(male)

Measured values
after an 8-hr work
shift; mean 5.1 years
on the job

BMDL10 =
1.4 ppm

Decreased normal
sperm morphology
and hyperzoospennia

TotMetab
BW34

1.4

0.5

0.74

0.73

UFS=10; UFA= 1;
UFH=3;UFL=1;
Total UF=30

(Chia et al.,
1996)

Medium

Rat
(female
dams)

9 days (during
gestational days 6-15)

LOAEL = 475
mg/kg-bw/day

Delayed parturition

TotMetab
BW34

98

37

47

44

UFS=1;UFA= 3;
UFH=3; UFL=10;
Total UF=100

(Narotskv et al..
1995)

High

Develop-
mental
Effects

Rat
(female)

Gestational days 6 to
15

BMDL01= 32.2
mg/kg-bw/day

Increased resorptions

TotMetab
BW34

57

23

29

28

UFs=l;UFA= 3;
UFh=3; UFl=1;
Total UF= 10

(Narotskv et al.,
1995)

High

Rat
(female)

22 days
(gestational days
0-22)

BMDLoi =
0.0207 mg/kg-
bw/day

Congenital heart
defects

TotOx Metab
BW34

0.012

0.0037

0.0058

0.0052

UFs=l;UFA= 3;
UFh=3; UFl=1;
Total UF= 10

(Johnson et al..
2003)

Medium

Rat
(male
pups)

Postnatal days
10-16

LOAEL = 50
mg/kg-bw/day

Decreased rearing
activity

TotMetab
BW34

8

3

4.2

4.1

UFS=3; UFA= 3;
UFH=3; UFL=10;
Total UF=300

(Fredriksson et
al.. 1993)

Medium

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Table 3-15: Cancer Points of Departure for Lifetime Exposure Scenarios

POD Type

Oral Slope I'aclor

Inhalation I nil Risk

1 Alia Risk Ik-nchmaik

POD (extra risk per
dose/concentration)

0.0464 per mg/kg

0.022 per ppm

1 x 10"4

As stated in Section 3.2.5.3.3, these PODs represent the plausible upper bound lifetime extra risk
of cancer per unit dose or air concentration. The linear non-threshold assumption underlying the
derivation of these values is appropriate based on the mutagenic mode of action for kidney cancer (with
an unclear mode of action for the other two cancer types). The PODs are derived from a single High
quality kidney cancer study (Charbotel et at.. 2006) and the combined estimates account for the
additional relative contribution from the other two cancers.

For TCE, EPA, consistent with OSHA (878 F.2d 389 (D.C. Cir. 1989) and 2016 NIOSH guidance
(Whittaker et at.. 2016). used 1 x 10"4 as the benchmark for the purposes of this risk determination for
individuals in industrial and commercial work environments subject to Occupational Safety and Health
Act (OSHA) requirements. It is important to note that lxlO"4 is not a bright line and EPA has discretion
to find unreasonable risks based on other benchmarks as appropriate based on analysis. It is important to
note that exposure related considerations (duration, magnitude, population exposed) can affect EPA's
estimates of the excess lifetime cancer risk (ELCR). Cancer assessment is only applicable to evaluation
of occupational exposure scenarios, because consumer exposures were only evaluated as acute scenarios
(Section 2.3.2.2).

3.2.6 Assumptions and Key Sources of Uncertainty for Human Health Hazard

3.2.6.1	Confidence in Hazard Identification and Weight of Evidence

There is high confidence in the database for human health hazard. All studies considered for dose-
response analysis scored either Medium or High in data quality evaluation and were determined to be
highly relevant to the pertinent health outcome. EPA selected the best representative study for each
identified endpoint from among a broad selection of studies, taking into account factors such as data
quality evaluation score, species, exposure duration, dose range, cumulative uncertainty factor, and
relevance. The only identified study that examined developmental immunotoxicity fPeden-Adams et at..
2006) scored a Low in data evaluation and a POD could not be sufficiently derived.

EPA has high confidence in the overall weight of scientific evidence. EPA did not identify any
information that would question the previous WOE regarding the evaluation of liver, kidney,
neurological, immunological, reproductive toxicity, and developmental toxicity (other than cardiac
malformations). For cancer, EPA performed an updated meta-analysis that found positive statistical
associations between human TCE exposure and cancer of kidney, liver, and NHL types, in agreement
with the previous meta-analyses performed in 2011 (Appendix C, (	). For congenital

heart defects, EPA performed a thorough WOE assessment (Appendix G.2), examining all pertinent
studies in the reasonably available literature. While some uncertainty remains in the dose-response
analysis of the (Johnson et at.. 2003) study and the resulting POD, there is medium confidence in the
qualitative relevance of the endpoint to human toxicity based on the results of the WOE.

3.2.6.2	Derivation of PODs, UFs, and PBPK Results

Conceptually, the POD should represent the maximum exposure level at which there is no appreciable
risk for an adverse effect in the study population under study conditions (i.e., the threshold in the dose-
response relationship). In fact, it is not possible to know that exact exposure level even for a laboratory

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study because of experimental limitations (e.g., the ability to detect an effect, the doses used and dose
spacing, measurement errors, etc.), and POD approximations like the doses used (i.e., a NOAEL) an
exposure level which is modeled from the reasonably available doses used (i.e., BMDL) are used. The
application of UFs is intended to account for this uncertainty/variability to allow for estimating risk for
sensitive human subgroups exposed continuously for a lifetime. While the selection of UFs is informed
by reasonably available data, the true necessary extent of adjustment most appropriate for capturing all
relevant uncertainty and variability is unknown.

If a BMDL is used as the POD, there are uncertainties regarding the appropriate dose-response model to
apply to the data, but these should be minimal if the modeling is in the observable range of the data.
There are also uncertainties about what BMR to use to best approximate the desired exposure level (i.e.
threshold, see above). For continuous endpoints, in particular, it is often difficult to identify the level of
change that constitutes the threshold for an adverse effect. While a 1% BMR is justified for many of the
PODs derived in this assessment based on the severity of the endpoint, it can potentially amplify BMD
model and parameter uncertainty. This is especially of concern for endpoints with greater uncertainties
in the dose-response assessment such as the congenital heart defects endpoint from (Johnson et ai.
2003). however a reanalysis of the BMR selection for this endpoint concluded that the 1% BMR was in
fact most appropriate (Section 3.2.5.3.1).

For each of these types of PODs, there are additional uncertainties pertaining to adjustments to the
administered exposures (doses). Typically, administered exposures (doses) are converted to equivalent
continuous exposures (daily doses) over the study exposure period under the assumption that the effects
are related to concentration x time, independent of the daily (or weekly) exposure regimen (i.e., a daily
exposure of 6 hours to 4 ppm is considered equivalent to 24 hours of exposure to 1 ppm). However, the
validity of this assumption is generally unknown, and, if there are dose-rate effects, the assumption of C
x t equivalence would tend to bias the POD downwards.

For the PBPK analyses in this assessment, the actual administered exposures are taken into account in
the PBPK modeling, and equivalent daily values (averaged over the study exposure period) for the dose-
metrics are obtained. EPA determined that the peer-reviewed PBPK model sufficiently accounted for
any variability and uncertainties in route-to-route extrapolation, and therefore inhalation and oral data
were considered equivalently relevant. Nonetheless, this PBPK model, like any model, does not
incorporate all possible sources of biological uncertainty or variability.

The PBPK-based POD estimates include uncertainties about the appropriate dose-metric for each effect,
although there was better information about relevant dose-metrics for some effects than for others (see
Section 3.2.5.3). The 2011 TCE IRIS Assessment determined that the PBPK model was most reliable
for dose metrics of oxidative metabolism flux .There remains substantial uncertainty in the extrapolation
of GSH conjugation from mice to humans due to limitations in the reasonably available data. This dose
metric is specifically applicable to kidney endpoints, which are believed to result from renal
bioactivation through GSH conjugation. In this manner, the HEC/HED99 values (which account for both
modeling uncertainty and interspecies/intraspecies toxicokinetic variability) may potentially
overestimate kidney toxicity for a proportion of the population, however use of these values are
expected to sufficiently account for the majority of human toxicokinetic variability, including increased
biological susceptibility (see Section 3.2.5.2). Of note, there was significantly less uncertainty for
extrapolation of rat GSH conjugation data, which was used for the selected kidney PODs, compared to
data from mice. Despite any limitations of the model, overall uncertainty for the selected PODs is
reduced by the use of a PBPK model. Use of the PBPK model resulted in data-derived HEC/HED99

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values replacing default assumptions and uncertainty factors that would have otherwise been used such
as allometric scaling and a UFtk of 3 in accounting for for both interspecies and intraspecies
toxicokinetic variability. Data-derived values are always preferred to default uncertainty adjustments
and improve confidence in the adjusted PODs.

3.2.6.3	Cancer Dose Response

Potential sources of uncertainty associated with Charbotel et al. (2006) include the modest sample size
of the study and localized population (86 kidney cancer cases, 37 associated with TCE exposure from a
specific region in France), the retrospective estimation of TCE in study subjects, and potential
confounding effects from exposure to other degreasing agents. These uncertainties do not significantly
affect confidence in the study results because Charbotel et al. (2006) was a well conducted. High quality
study that used a comprehensive exposure assessment with a detailed occupational questionnaire and
sensitivity and regression analyses found no statistical effect on the cancer POD from a sensitivity
analysis adjusting for exposure to other chemicals (I v << \ 1:011^).

The two major sources of uncertainty in quantitative cancer risk estimates are generally interspecies
extrapolation and high-dose to low-dose extrapolation. The unit risk estimate for kidney cancer
incidence derived from the Charbotel et al. (2006) results is not subject to interspecies uncertainty
because it is based on human data. A major uncertainty remains in the extrapolation from occupational
exposures to lower environmental exposures. There was some evidence of a contribution to increased
kidney cancer risk from peak exposures; however, there remained an apparent dose-response
relationship for RCC risk with increasing cumulative exposure without peaks, and the odds ratio (OR)
for exposure with peaks compared to exposure without peaks was not significantly elevated (Charbotel
et al.. 2006) Although the actual exposure-response relationship at low exposure levels is unknown, the
conclusion that a mutagenic mode of action is operative for TCE-induced kidney tumors supports the
linear low-dose extrapolation that was used (	2005). The weight of evidence also supports

involvement of processes of cytotoxicity and regenerative proliferation in the carcinogenicity of TCE,
although not with the extent of support as for a mutagenic mode of action. In particular, data linking
TCE-induced proliferation to increased mutation or clonal expansion are lacking, as are data informing
the quantitative contribution of cytotoxicity. Because any possible involvement of a cytotoxicity mode
of action would be additional to mutagenicity, the dose-response relationship would nonetheless be
expected to be linear at low doses. Therefore, the additional involvement of a cytotoxicity mode of
action does not provide evidence against the use of linear extrapolation from the POD.

The upward adjustment of the cancer PODs based on additional contributions from liver and NHL
cancer was based on peer-reviewed methodology as explained in the 2011 IRIS Assessment (
201 le). This approach is reasonable, however it is unknown whether these statistical methods resemble
the true combined extra risk from these three cancers. Additionally, the IUR adjustment was rounded up
to 4-fold from a mean of 3.8 and route-to-route extrapolation results in a 5-fold adjustment for the OSF.
When combined with the above factors and the fact that the cancer PODs represent upper-bound values,
these uncertainties may potentially lead to overestimation of risk, but any differences from the true
IUR/OSF values are unlikely to vary by more than ~2-fold.

3.2.6.4	Confidence in Human Health Hazard Data Integration and

Representative Endpoints

Acute Non-Cancer

There is medium overall confidence in the database, weight of evidence, and dose-response for acute
non-cancer endpoints. There are four endpoints relevent to acute exposure scenarios, covering three
distinct endpoints from developmental toxicity studies and an immunological endpoint from an acute co-

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infection study. Two of the four studies scored Medium in data quality, while one developmental
endpoint and the acute immunotoxicity study scored High. The PODs cover several orders of magnitude,
with benchmark MOEs of either 10 or 100. Confidence is reduced from a high due to the data quality
scores, the wide range of PODs, and controversy over the most sensitive POD, from (Johnson et at..
2003). For developmental endpoints, there is some uncertainty extrapolating from chronic
developmental toxicity studies to acute exposure, especially in assuming a consistent dose-response.

This is a health protective assumption consistent with EPA Guidance (	96: U.S. EPA.

1991). however this may possibly result in an overestimation of risk for some scenarios. For the acute
immunotoxicity study (Belgrade a a our. 2010) there is some inherent uncertainty extrapolating
from the observed responses to pulmonary infection to a systemic response across multiple exposure
routes, however an acute systemic response to infection is likely based on the systemic
immunosuppression observed in multiple chronic studies (Sanders	2; Woolhiser et ai. 2006).

Confidence is raised from the robust WOE analysis performed on the congenital heart defects endpoint
(see Appendix G), the presence of a variety of endpoints including a study using acute TCE
administration, and reduced uncertainty factors due to the use of a PBPK model or allometric scaling.

Representative Acute Non-Cancer Endpoint

Based on the following considerations, the POD for mortality due to immunosuppression from (S el grade
and Gilmour. 2010) is considered to be the most robust and best representative POD for acute non-
cancer scenarios. Confidence in the use of this study for evaluating acute exposure scenarios is High.
Considerations for selection of this study and the High confidence rating include the following:

1)	The study scored a High in data quality evaluation

2)	The study used a broad dose range, with several concentrations above and below the LOAEL

3)	The response data followed a consistent dose-response curve

4)	The data is based on an acute exposure study so there is no uncertainty resulting from
extrapolating from a repeated-dose study

5)	The study demonstrated multiple assays supporting the apical outcome

6)	The endpoint is severe

Chronic Non-Cancer

There is high overall confidence in the database, weight of evidence, and dose-response for chronic non-
cancer endpoints. There are eleven endpoints relevant to chronic exposure scenarios across six health
domains. Seven of the studies scored Medium in data quality, while the other four scored High. The
PODs cover several orders of magnitude with benchmark MOEs ranging from 10 to 300. Confidence is
high because there is strong WOE in support of all health effects, the PODs for three most sensitive
endpoints differ by within an order of magnitude from each other, and the majority of PODs and have
reduced uncertainty factors due to the use of a PBPK model.

Representative Chronic Non-Cancer Endpoint

Based on the following considerations, the POD for autoimmunity from (Keil et ai. 2009) is considered
to be the most robust and best representative POD for chronic non-cancer scenarios. Confidence in the
use of this study for evaluating acute exposure scenarios is High. Considerations for selection of this
study and the High confidence rating include the following:

1)	The study scored a High in data quality evaluation

2)	The study was of chronic duration (27-30 weeks) so uncertainty is reduced by not requiring a
subchronic-to-chronic UF

3)	The endpoint is associated with both functional immunological markers (increased anti-self
antibodies) and immunological organ changes (thymus weight and cellularity)

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4) The use of an early clinical marker as an endpoint and dose range are are expected to account
for susceptibilities of subpopulations in disease progression

Cancer

There is medium to high overall confidence in the database, weight of evidence, and dose-response for
cancer. Meta-analyses on the full database of relevant epidemiological studies confirm a statistically
significant association between human exposure to TCE and the incidence of kidney cancer, liver
cancer, or NHL. The IUR/OSF is derived from a High quality study (Charbotel et al. 2006) on kidney
cancer, with the PODs adjusted upward to account for the additional two cancer sites. Confidence is
slightly reduced due to some uncertainty over the precision of the dose-response estimate in accounting
for all three cancer sites and in the GSH metabolism dose metrics but remains medium-high due to
strong evidence for a mutagenic mode of action.

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4 RISK CHARACTERIZATION

4.1 Environmental Risk

EPA took fate, exposure, and environmental hazard into consideration to characterize environmental risk
of TCE. EPA determined that no further analysis beyond what was presented in the problem formulation
document would be done for environmental exposure pathways for sediment for aquatic and terrestrial
organisms, or land application of biosolids, water, or soil pathways for terrestrial organisms, in this risk
evaluation. As stated in Section 2.1 Fate and Transport, TCE is not expected to accumulate in
wastewater biosolids, soil, sediment, or biota. TCE is expected to volatilize from the water surface or
from moist soil as indicated by its physical chemical properties (e.g., Henry's law constant) and by
microbial biodegradation under some conditions. The EPI Suite™ volatilization module estimates that
the half-life of TCE in a model river will be 1.2 hours and the half-life in a model lake will be 110 hours.
Biodegradation of TCE in the environment is dependent on a variety of factors and thus, a wide range of
degradation rates have been reported (ranging from days to years). TCE is not expected to accumulate in
aquatic organisms due to low measured BCFs and estimated BAF.

Environmental exposure pathways for surface water for aquatic organisms are assessed and presented in
this draft risk evaluation. As stated in Section 2.2 Environmental Exposures, modeled surface water
concentrations of TCE ranged from 1.27E-5 ppb to 9,937.5 ppb from facilities releasing the chemical to
surface water. Measured surface water concentrations near facilities range from 0.4 ppb to 447 ppb from
published literature (1976-1977). Measured surface water concentrations in ambient water range from
below the detection limit to 2.0 ppb in the Water Quality Portal (2013-2017) and from below the
detection limit to 17 ppb in the published literature (1996-2001).

As stated in Section 3.1 Environmental Hazards, the reasonably available environmental hazard data
indicate that TCE presents hazard to aquatic organisms. For acute exposures to invertebrates, toxicity
values ranged from 7.8 to 33.85 mg/L (integrated into a geometric mean of 16 mg/L). For chronic
exposures, toxicity values for fish and aquatic invertebrates were as low as 7.88 mg/L and 9.2 mg/L,
respectively. These data also indicated that TCE presents hazard for aquatic plants, with toxicity values
in algae as low as 0.03 mg/L (geometric mean between a NOEC and a LOEC), and a wide range in
toxicity between algae species (ECsos ranging from 26.24 - 820 mg/L).

A total of 25 aquatic environmental hazard studies were identified for TCE as acceptable. They were
given mostly high and medium quality ratings during data evaluation (See [Data Quality Evaluation of
Environmental Hazard Studies and Environmental Hazard Data Extraction Table. Docket: EPA-HQ-
OPPT-2019-0500]). The [Data Quality Evaluation of Environmental Hazard Studies. Docket: EPA-HQ-
OPPT-2019-0500] document presents details of the data evaluations for each study, including scores for
each metric and the overall study score.

Given TCE's conditions of use under TSCA outlined in the problem formulation (	1),

EPA determined that environmental exposures are expected for aquatic species, and risk estimation is
discussed in Section 4.1.2 Risk Estimation for Aquatic.

4.1.1 Risk Estimation Approach

EPA used modeled exposure data from E-FAST, as well as monitored data from the Water Quality
Portal (www.waterqiialitydata.iis) and reasonably available literature, to characterize the risk of TCE to

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aquatic species. Risk quotients (RQs) were calculated using modeled surface water concentrations from
E-FAST, monitored data, reasonably available literature, and the COCs calculated in the hazard section
of this document (Section 3.1.5). An RQ is defined as:

RQ = Predicted Environmental Concentration / Effect Level or COC

An RQ equal to 1 indicates that environmental exposures are the same as the COC. If the RQ is above 1,
the exposure is greater than the COC. If the RQ is below 1, the exposure is less than the COC. The
COCs for aquatic organisms shown in Table 3-2 and the environmental concentrations shown in Section
2.2.6.2 were used to calculate RQs. (	0

EPA considered the biological relevance of the species that the COCs were based on when integrating
the COCs with surface water concentration data to produce RQs. For example, certain biological factors
affect the potential for adverse effects in aquatic organisms. Life-history and the habitat of aquatic
organisms influences the likelihood of exposure above the hazard benchmark in an aquatic environment.

Frequency and duration of exposure also affect potential for adverse effects in aquatic organisms,
especially for chronic exposures. Therefore, the number of days that a COC was exceeded was also
calculated using E-FAST. The days of exceedance modeled in E-FAST are not necessarily consecutive
and could occur sporadically throughout the year. For TCE, EPA assumed continuous aquatic exposure
for the longer exposure scenarios (i.e. 117-365 days per year of exceedance of a COC), and more of an
interval or pulse exposure for shorter exposure scenarios (i.e. 1-40 days per year of exceedances of a
COC). Due to the volatile properties of TCE, it is more likely that a chronic exposure duration will occur
when there are long-term consecutive days of release versus an interval or pulse exposure which would
more likely result in an acute exposure duration.

4,1.2 Risk Estimation for Aquatic

To characterize potential risk due to TCE exposure, RQs were calculated based on modeled data from E-
FAST for sites that had surface water discharges of TCE according to TRI and DMR data (see Table
4-1). Surface water concentrations of TCE were modeled for 214 releases. Direct releases from facilities
(releases from an active facility directly to surface water) were modeled with two scenarios based on
high-end and low-end days of release. Indirect facilities (transfer of wastewater from an active facility to
a receiving POTW or non-POTW WWTP) were only modeled with a high-end days of releases scenario.
As stated in Section 2.2.3, the maximum releases frequency (200 to 365 days) is based on release
estimates specific to the facility's condition of use and the low-end releases frequency (20 days) is an
estimate of releases that could lead to chronic risk for aquatic organisms.

These facilities were modeled in E-FAST and all RQs are listed in Appendix E.2. As stated previously,
the frequency and duration of exposure affects potential for adverse effects in aquatic organisms.
Therefore, the number of days a COC was exceeded was also calculated using E-FAST. Facilities with
RQs and days of exceedance that indicate risk for aquatic organisms (facilities with an acute RQ > 1, or
a chronic RQ > 1 and 20 days or more of exceedance for the chronic COC) are presented in Table 4-1.
All facilities were below these thresholds for manufacturing, spot cleaning and carpet cleaning, and
commercial printing and copying, indicating no risks to aquatic organisms for these conditions of use.

Processing as a Reactant:

Of the 443 facilities processing TCE as a reactant (including 440 unknown sites modeled in E-FAST),
one facility had acute RQs > 1, or chronic or algae RQs > 1 with 20 days or more of exceedances.
Assuming 20 days of releases, Praxair Technology Center in Tonawanda, NY had a chronic RQs of 3.81

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with 20 days of exceedance, and an algae COCs representing the most sensitive species of algae of
1,000 with 20 days of exceedance. In other words, the surface water concentration modeled for this
facility was 3.81 times higher than the COC for chronic exposures, and 1,000 times higher than the COC
for the most sensitive species of algae. Assuming 260 days of releases from the facility, the algae RQ
representing the most sensitive species was 56.33 with 350 days of exceedance. However, for algae
species as a whole, RQs for this site were 0.06 assuming 20 days of release and 0.00 assuming 350 days
of release, meaning the concentration did not exceed the COC of 52,000 ppb which represents nine
different species of algae. Therefore, there may be risk for some of the most sensitive species of algae at
this site, but not for algae species as a whole. Risks were identified at this site for other aquatic
organisms for chronic exposures, with a surface water concentration 3.81 times higher than the chronic
COC and 20 days of exceedance.

Repackaging:

Of the six facilities repackaging TCE, one had algae RQs > 1 with 20 days or more of exceedances.
Assuming 20 days of release per year, Hubbard-Hall Inc in Waterbury, CT had an RQ for the most
sensitive species of alge as high as 113.04 with 20 days of exceedance. Assuming this facility released
TCE for 250 days per year, the RQ is 9.06 with 194 days of exceedance. However, for algae species as a
whole, RQs for this site were 0.01 for 20 days of releases, and 0.00 for 250 days, meaning the
concentration did not exceed the COC of 52,000 ppb which represents nine different species of algae.
Therefore, there may be risk for some of the most sensitive species of algae at these sites, but not for
algae species as a whole. No risks were identifiedfor other aquatic organisms in this condition of use.

Open-top Vapor Degreasing:

Of the 64 open-top vapor degreasing facilities, three sites had acute RQs > 1, or chronic or algae RQs >
1 with 20 days or more of exceedances. Assuming 20 days of releases, US Nasa Michoud Assembly
Facility in New Orleans, LA had acute RQs of 3.11, a chronic RQs of 12.61 with 20 days of exceedance,
and an algae COCs representing the most sensitive species of algae of 3,312.50 with 20 days of
exceedance. Assuming 260 days of relese from the facility, the algae RQ representing the most sensitive
species was 255.21 with 260 days of exceedance. However, for algae species as a whole, RQs for this
site were 0.01 assuming 260 days of release, and 0.19 assuming 20 days of release, meaning the
concentration did not exceed the COC of 52,000 ppb which represents nine different species of algae.
Therefore, there may be risk for some of the most sensitive species of algae at this site, but not for algae
species as a whole. Risks were identified at this site for other aquatic organisms for acute and chronic
exposures, with a surface water concentration 3.11 times higher than the acute COC and 12.61 times
higher than the chronic COC and 20 days of exceedance.

GM Components Holdings LLC in Lockport, NY had an RQ for the most sensitive species of algae of
3.66 with 117 days of exceedance, assuming 260 days of release per year. Assuming 20 days of release,
this site has an RQ for the most sensitive species of algae of 48.16 with 20 days of exceedance.

However, for algae species as a whole, RQs for this facility were 0.00 for this site, meaning the
concentration did not exceed the COC of 52,000 ppb which represents nine different species of algae.
Therefore, there may be risk for some of the most sensitive species of algae at this site, but not for algae
species as a whole.

Akebono Elizabethtown Plant in Elizabethtown, KY had an RQ for the most sensitive species of algae
of 1.62 with 27 days of exceedance, assuming 260 days of release per year. However, for algae species
as a whole, RQs for this facility were 0.00 for this site, meaning the concentration did not exceed the

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COC of 52,000 ppb which represents nine different species of algae. Therefore, there may be risk for
some of the most sensitive species of algae at this site, but not for algae species as a whole.

Adhesives, Sealants, Paints, and Coatings:

Of the 54 facilities using TCE as adhesives, sealants, paints, and coatings, one site had algae RQs > 1
with 20 days or more of exceedances. Raytheon Company in Portsmouth, RI had an RQ for the most
sensitive species of alge as high as 44.44, assuming 20 days of release per year. In other words, the
surface water concentration modeled for this facility was 44.44 times higher than the COC for the most
sensitive species of algae (3 ppb). Additionally, this COC was exceeded for 20 days. Assuming this
facility released TCE for 250 days per year, the RQ is 3.61 with 250 days of exceedance. However, for
algae species as a whole, RQs for this facility were 0.00, meaning the concentration did not exceed the
COC of 52,000 ppb which represents nine different species of algae. Therefore, there may be risk for
some of the most sensitive species of algae at this site, but not for algae species as a whole. No risks
were identifiedfor other aquatic organisms for this condition of use.

Other Industrial Uses:

Of the 21 facilities with other industrial uses of TCE, three sites had algae RQs > 1 with 20 days or more
of exceedances. Eli Lilly And Company-Lilly Tech Ctr in Indianapolis, IN had an RQ for the most
sensitive species of alge of 3.01, assuming 250 days of release per year. In other words, the surface
water concentration modeled for this facility was 3.01 times higher than the COC for the most sensitive
species of algae (3 ppb). Additionally, this COC was exceeded for 35 days. Washington Penn Plastics in
Frankfort, KY had an RQ for the most sensitive species of alge of 2.51, assuming 250 days of release
per year. Additionally, this COC was exceeded for 22 days. Keeshan and Bost Chemical Co., Inc. in
Manvel, TX had an RQ for the most sensitive species of algae of 66.67 with 20 days of exceedance,
assuming 20 days of release per year. Assuming 350 days of release, this site has an RQ for the most
sensitive species of algae of 3.17 with 350 days of exceedance. However, for algae species as a whole,
RQs for these facilities were 0.00, meaning the concentration did not exceed the COC of 52,000 ppb
which represents nine different species of algae. Therefore, there may be risk for some of the most
sensitive species of algae at these sites, but not for algae species as a whole. No risks were identifiedfor
other aquatic organisms for this condition of use.

Industrial Processing Aid:

Of the six industrial processing aid facilities, one site had algae RQs > 1 with 20 days or more of
exceedances. Entek International LLC in Lebanon, OR had an RQ for the most sensitive species of algae
as high as 46.11, assuming 20 days of release per year. In other words, the surface water concentration
modeled for this facility was 46.11 times higher than the COC for the most sensitive species of algae (3
ppb). Additionally, this COC was exceeded for 20 days. Assuming this facility released TCE for 300
days per year, the RQ is 3.10 with 140 days of exceedance. However, for algae species as a whole, RQs
for this facility were 0.00, meaning the concentration did not exceed the COC of 52,000 ppb which
represents nine different species of algae. Therefore, there may be risk for some of the most sensitive
species of algae at this site, but not for algae species as a whole. No risks were identifiedfor other
aquatic organisms for this condition of use.

Other Commercial Uses:

Of the nine facilities with other commercial uses of TCE, one site had algae RQs > 1 with 20 days or
more of exceedances. Park Place Mixed Use Development in Annapolis, MD had an RQ for the most
sensitive species of algae as high as 36.67, assuming 20 days of release per year. In other words, the
surface water concentration modeled for this facility was 36.67 times higher than the COC for the most

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sensitive species of algae (3 ppb). Additionally, this COC was exceeded for 20 days. Assuming this
facility released TCE for 250 days per year, the RQ is 3.00 with 250 days of exceedance. However, for
algae species as a whole, RQs for this facility were 0.00, meaning the concentration did not exceed the
COC of 52,000 ppb which represents nine different species of algae. Therefore, there may be risk for
some of the most sensitive species of algae at this site, but not for algae species as a whole. No risks
were identifiedfor other aquatic organisms in this condition of use.

Process Solvent Recycling and Worker Handling of Wastes:

Of the five facilities with other commercial uses of TCE, three sites had algae RQs > 1 with 20 days or
more of exceedances. Assuming 20 days of release per year, Clean Water Of New York Inc in Staten
Island, NY had an RQ for the most sensitive species of alge as high as 46.08 with 20 days of
exceedance. Assuming this facility released TCE for 250 days per year, the RQ is 3.92 with 250 days of
exceedance. Assuming 20 days of release, Veolia Es Technical Solutions LLC in Middlesex, NJ had an
RQ for the most sensitive species of alge of 11.91 with 20 days of exceedance. And assuming 250 days
of releases, Clean Harbors Deer Park LLC in La Porte, TX had an RQ for the most sensitive species of
alge of 2.86 with 110 days of exceedance. However, for algae species as a whole, RQs for at all three
facilities were 0.00, meaning the concentration did not exceed the COC of 52,000 ppb which represents
nine different species of algae. Therefore, there may be risk for some of the most sensitive species of
algae at these sites, but not for algae species as a whole. No risks were identifiedfor other aquatic
organisms in this condition of use.

Wastewater Treatment Plants (WWTPs):

Of the nine WWTPs, one site had algae RQs > 1 with 20 days or more of exceedances. New Rochelle
STP in New Rochelle, NY had an RQ for the most sensitive species of alge of 4.26, assuming 20 days of
release per year. This means that the surface water concentration modeled for this facility was 4.26 times
higher than the COC for the most sensitive species of algae (3 ppb). Additionally, this COC was
exceeded for 20 days. Assuming this facility released TCE for 365 days per year, the RQ is only 0.23
with 0 days of exceedance. A WWTP is likely to be operating at greater than 20 days of release,
therefore the RQ associated with the high-end days of release scenario (365 days) is likely more
representative of actual conditions. Therefore, no risks to aquatic species were for this facility or
condition of use.

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220 Table 4-1. Environmental Risk Quotients for Facilities Releasing TCE to Surface Water as Modeled in E-FAST (RQs > 1 in bold)

Name, Location, and ID of
Active Releaser Facility a

Release
Media b

Modeled Facility or
Industry Sector in
EFAST c

EFAST
Waterbody
Type d

Days of
Release

e

Release
(kg/day)f

7Q10
SWC
(ppb)g

COC Type

COC
(ppb)

Days of
Exceedance
(days/year)

h~

Risk
Quotient

OES: Processing as a Reactant

Praxair Technology Center,
Tonawanda, NY
NPDES: NY0000281

Surface
Water

NPDES NY0000281

Still body

350

0.00169

169

Acute

3,200

NA

0.05

Chronic

788

0

0.21

Algae

3

350

56.33

Algae (HCos)

52,000

0

0.00

20

0.03

3000

Acute

3,200

NA

0.94

Chronic

788

20

3.81

Algae

3

20

1,000.00

Algae (HCos)

52,000

0

0.06

OES: Repackaging

Hubbard-Hall Inc,

Waterbury, CT
NPDES: Unknown

Off-site
Waste-
water
Treatme
nt

Receiving Facility:
Recycle Inc.; POTW
(Ind.)

Surface water

250

1.108

27.18

Acute

3,200

NA

0.01

Chronic

788

0

0.03

Algae

3

194

9.06

Algae (HCos)

52,000

0

0.00

20

13.85

339.11

Acute

3,200

NA

0.11

Chronic

788

1

0.43

Algae

3

20

113.04

Algae (HCos)

52,000

0

0.01

OES: OTVD (Includes releases for Closed-Loop Degreasing, Conveyorized Degreasing, Web Degreasing, and Metalworking Fluids)

US Nasa Michoud Assembly
Facility,
New Orleans, LA
NPDES: LA0052256

Surface
Water

Surrogate NPDES
LA0003280

Still body

260

1.96

765.63

Acute

3,200

NA

0.24

Chronic

788

0

0.97

Algae (COC)

3

260

255.21

Algae (HCos)

52,000

0

0.01

20

25.44

9937.5

Acute

3,200

NA

3.11

Chronic

788

20

12.61

Algae

3

20

3,312.50

Algae (HCos)

52,000

0

0.19

GM Components Holdings
LLC,

Lockport, NY
NPDES: NY0000558

Surface
Water

NPDES NY0000558

Surface water

260

0.13

10.97

Acute

3,200

NA

0.00

Chronic

788

0

0.01

Algae (COC)

3

117

3.66

Algae (HCos)

52,000

0

0.00

20

1.71

144.47

Acute

3,200

NA

0.05

Chronic

788

0

0.18

Algae

3

20

48.16

Algae (HCos)

52,000

0

0.00

Akebono Elizabethtown Plant,





Surface water

260

0.07

4.87

Acute

3,200

NA

0.00

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Name. 1 Av;ilkiii. and II) of
\cli\e Releaser l'acilil>

Release
Media

Modeled 1 aeilils or
liidiisii's Secloi'iii
1 1 \S 1

I I AST
\\aleihod>
T\ pe

1 )a> s of
Release

Release
(ku da>)

"Old
S\V(
ipph)

('()(' T\pe

COC
(pph)

1 )a\ s of
1 Aceedaiice
s \ean

Risk
Ouoiienl

Elizabethtown, KY













Chronic

788

0

0.01

NPDES: KY0089672













Algae (COC)

3

27

1.62



Surface
Water

Surrogate NPDES
KY0022039









Algae (HC05)

52,000

0

0.00











Acute

3,200

NA

0.02





20

0.897

62.38

Chronic

788

0

0.08









Algae

3

16

20.79















Algae (HC05)

52,000

0

0.00

OES: Adhesives, Sealants, Paints, and Coatings















Acute

3,200

NA

0.00









250

0.013

10.83

Chronic

788

0

0.01









Algae (COC)

3

250

3.61



Surface
Water











Algae (HC05)

52,000

0

0.00



NPDES RI0000281









Acute

3,200

NA

0.04

Raytheon Company,











Chronic

788

0

0.17

Portsmouth, RI





Still body

20

0.160

133.33

Algae (COC)

3

20

44.44

NPDES: RI0000281



































Algae (HC05)

52,000

0

0.00





No info on receiving
facility; Adhesives
and Sealants Manuf.









Acute

3,200

NA

0.00



POTW



250

0.013

0.32

Chronic

788

0

0.00





Algae (COC)

3

0

0.11













Algae (HC05)

52,000

0

0.00

OES: Other Industrial Uses















Acute

3,200

NA

0.00









250

1.553

9.03

Chronic

788

0

0.01

Eli Lilly And Company-







Algae (COC)

3

35

3.01

Lilly Tech Ctr,

Surface

NPDES IN0003310

Surface water







Algae (HC05)

52,000

0

0.00

Indianapolis, IN

Water







Acute

3,200

NA

0.04

NPDES: IN0003310







20

19.410

113.09

Chronic

788

0

0.14









Algae

3

17

37.70















Algae (HC05)

52,000

0

0.00















Acute

3,200

NA

0.00









250

0.032

7.53

Chronic

788

0

0.01

Washington Penn Plastics,

Surface
Water

Surrogate NPDES
KY0028410



Algae (COC)

3

22

2.51

Frankfort, KY

Surface water







Algae (HC05)

52,000

0

0.00

NPDES: KY0097497









Acute

3,200

NA

0.03









20

0.399

94.12

Chronic

788

0

0.12















Algae

3

13

31.37

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Name, Location, and ID of
Active Releaser Facility a

Release
Media b

Modeled Facility or
Industry Sector in
EFAST c

EFAST
Waterbody
Type d

Days of
Release

e

Release
(kg/day)f

7Q10
SWC
(ppb)g

COC Type

COC
(ppb)

Days of
Exceedance
(days/year)

h"

Risk
Quotient















Algae (HCos)

52,000

0

0.00















Acute

3,200

NA

0.00









350

0.000095

9.50

Chronic

788

0

0.01

Keeshan and Bost Chemical







Algae

3

350

3.17

Co., Inc.,

Surface

NPDES TX0072168

Still body







Algae (HCos)

52,000

0

0.00

Manvel, TX

Water







Acute

3,200

NA

0.06

NPDES: TX0072168







20

0.002

200.00

Chronic

788

0

0.25









Algae

3

20

66.67















Algae (HCos)

52,000

0

0.00

OES: Industrial Processing Aid















Acute

3,200

NA

0.00



Off-site
Waste-
water
Treatme
nt





300

0.38

9.3

Chronic

788

0

0.01

Entek International LLC,
Lebanon OR
NPDES: N/A





Algae (COC)

3

140

3.10

No info on receiving

Surface water







Algae (HCos)

52,000

0

0.00

facility; POTW (Ind.)







Acute

3,200

0

0.04





20

5.65

138.34

Chronic

788

0

0.18







Algae (COC)

3

20

46.11















Algae (HCos)

52,000

0

0.00

OES: Other Commercial Uses















Acute

3,200

NA

0.00









250

0.00027

9

Chronic

788

0

0.01

Park Place Mixed Use







Algae (COC)

3

250

3.00

Development,

Surface

Surrogate NPDES

Still body







Algae (HCos)

52,000

0

0.00

Annapolis, MD

Water

MD0052868







Acute

3,200

NA

0.03

NPDES: MD0068861







20

0.00334

110

Chronic

788

0

0.14









Algae (COC)

3

20

36.67















Algae (HCos)

52,000

0

0.00

OES: Process Solvent Recycling and Worker Handling of Wastes















Acute

3,200

NA

0.00









250

0.004

11.76

Chronic

788

0

0.01

Clean Water Of New York







Algae (COC)

3

250

3.92

Inc,

Surface

Surrogate NPDES

Still body







Algae (HCos)

52,000

0

0.00

Staten Island, NY

Water

NJ0000019







Acute

3,200

NA

0.04

NPDES: NY0200484







20

0.047

138.24

Chronic

788

0

0.18









Algae

3

20

46.08















Algae (HCos)

52,000

0

0.00







Still body

250

24.1

2.85

Acute

3,200

NA

0.00

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Name, Location, and ID of
Active Releaser Facility a

Release
Media b

Modeled Facility or
Industry Sector in
EFAST c

EFAST
Waterbody
Type d

Days of
Release

e

Release
(kg/day)f

7Q10
SWC
(ppb)g

COC Type

COC
(ppb)

Days of
Exceedance
(days/year)

h"

Risk
Quotient















Chronic

788

0

0.00

Veolia Es Technical Solutions
LLC,

Middlesex, NJ
NPDES: NJ0020141

Off-site











Algae (COC)

3

0

0.95

Waste-

Receiving Facility:









Algae (HCos)

52,000

0

0.00

water

Middlesex Cnty UA;









Acute

3,200

NA

0.01

Treatme

NPDES NJ0020141



20

301.78

35.72

Chronic

788

0

0.05

nt





Algae

3

20

11.91















Algae (HCos)

52,000

0

0.00















Acute

3,200

NA

0.00



Off-site
Waste-
water
Treatme
nt





250

0.35

8.57

Chronic

788

0

0.01

Clean Harbors Deer Park





Algae (COC)

3

110

2.86

LLC,

POTW (Ind.)

Surface water







Algae (HCos)

52,000

0

0.00

La Porte, TX







Acute

3,200

NA

0.03

NPDES: TX0005941





20

4.36

106.75

Chronic

788

0

0.14







Algae

3

19

35.58















Algae (HCos)

52,000

0

0.00

OES: Wastewater Treatment Plants (WWTP)















Acute

3,200

NA

0.00









365

0.043

0.7

Chronic

788

0

0.00

New Rochelle STP,
New Rochelle, NY
NPDES: NY0026697







Algae (COC)

3

0

0.23

Surface

NPDES NY0026697

Still body







Algae (HCos)

52,000

0

0.00

Water







Acute

3,200

NA

0.00







20

0.786

12.79

Chronic

788

0

0.02









Algae (COC)

3

20

4.26















Algae (HCos)

52,000

0

0.00

221	a. Facilities actively releasing tricliloroethylene were identified via DMR, TRI, and CDR databases for the 2016 reporting year.

222	b.Release media are either direct (release from active facility directly to surface water) or indirect (transfer of wastewater from active facility to a receiving POTW or

223	non-POTW WWTP facility). A wastewater treatment removal rate of 81% is applied to all indirect releases, as well as direct releases from WWTPs.

224	c. If a valid NPDES of the direct or indirect releaser was not available in EFAST, the release was modeled using either a surrogate representative facility in EFAST (based

225	on location) or a representative generic industry sector. The name of the indirect releaser is provided, as reported in TRI.

226	d.EFAST uses ether the "surface water" model, for rivers and streams, or the "still water" model, for lakes, bays, and oceans.

227	e. Modeling was conducted with the maximum days of release per year expected. For direct releasing facilities, a minimum of 20 days was also modeled.

228	f. The daily release amount was calculated from the reported annual release amount divided by the number of release days per year.

229	g.For releases discharging to lakes, bays, estuaries, and oceans, the acute scenario mixing zone water concentration was reported in place of the 7Q10 SWC.

230	h.To determine the PDM days of exceedance for still bodies of water, the release days provided by the EPA Engineers should become the days of exceedance only if the

231	predicted surface water concentration exceeds the COC. Otherwise, the days of exceedance can be assumed to be zero.

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EPA also used surface water monitoring data from the Water Quality Portal (WQP) and from the
published literature to characterize the risk of TCE to aquatic organisms. For the most part these
monitored surface water concentrations reflect concentrations of TCE in ambient water. There was one
US study (U.S. EPA. 1977) that had measurements reflecting near-facility monitoring data. The other
monitored data collected in the US reflect ambient concentrations.

Monitored data from one US study (U.S. EPA. 1977) in the published literature reporting near-facility
concentrations of TCE collected between 1976 and 1977 ranging from 0.4 to 447 |ig/L. While these data
reflect historical levels of TCE, they are helpful to compare measured near-facility concentrations to the
modeled near-facility concentrations from E-FAST. The measured concentrations in this study
encompases the range of the modeled estimates across all OES with the exception of two sites, that
release to still water bodies.

EPA also had monitored data reflecting ambient water concentrations. EPA's Storage and Retrieval
(STORET) data and USGS's National Water Information System (NWIS) data were extracted on Oct
3rd, 2018 from the WQX/WQP. These data show an average concentration for TCE of 0.33 ± 0.29 |ig/L
or ppb in surface water from 2,273 measurements taken throughout the US between 2013 and 2017. The
highest value recorded during these years was 2 |ig/L or ppb, which was measured in 2017. Table 4-2
shows that none of the RQs for aquatic species are greater than or equal to 1. The RQs for algae range
from 0 to 0.67. Acute and chronic RQs for other aquatic species are all very close to 0.

Table 4-2. RQs Calculated using Monitored Environmen

Monitored Surface Water
Concentrations (ppb) from
2013-2017

Algae RQ

RQ using Acute
COC of 3,200
ppb

RQ using
Chronic COC of
788 ppb

using COC
of 3 ppb

using HC05 of
52,000 ppb

Mean (Standard Deviation):
0.33 (0.29) ppb

0.11

0.0

0.0

0.0

Maximum: 2 ppb

0.67

0.0

0.0

0.0

al Concentrations from WQX/WQP

The published literature show monitored data in six U.S. studies encompassing 1,177 surface water
samples collected from river and oceans throughout the nation between 1979 and 2001. Reported
concentrations of TCE ranged from below the detection limit (0.0001 to 0.08) to 17.3 |ig/L or ppb, with
reported central tendency values ranging from 0.0002 to 1.17 |ig/L (USGS. 2006; Sauer. 1981; Singh et
al.. 1983; USGS. 2003; Robinson et al.. 2004). The maximum concentration was collected from the
Charles River in Boston, Massachusetts (an urban area) between 1998 and 2000 (Robinson et al.. 2004).
The next highest TCE concentration was 2.0 |ig/L, collected during a large nationwide survey of surface
water for drinking water sources (rivers and reservoirs) between 1999 and 2000 (USGS. 2003). Table
4-3 shows an RQs for algae range from 0 to 5.77 using monitored surface water concentrations from the
published literature. Acute RQs for other aquatic organisms range from 0 to 0.01, and chronic RQs
range from 0 to 0.02.

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Table 4-3. RQs Calculated using Monitored Environmental Concentrations from Published
Literature

Monitored Surface
Water Concentrations
(ppb) from 2013-2017

Algae RQ

RQ using Acute
COC of 3,200
ppb

RQ using
Chronic COC of
788 ppb

using COC of 3
ppb

using HC05 of
52,000 ppb

Central tendency values:
0.0002- 1.17 ppb

0.00-0.39

0.00

0.00

0.00

Maximum: 17.3 ppb

5.77

0.00

0.01

0.02

To compare the modeled data with the monitored data, EPA conducted a watershed analysis by
combining monitored data from WQX/WQP with predicted concentrations from E-FAST modeled
facility releases, using the geospatial analysis outlined in Section 2.2. A geographic distribution of the
concentrations is shown in Figure 4-1 and Figure 4-2 (east and west US) for the maximum days of
release scenario, and in Figure 4-3 and Figure 4-4 (east and west US) for the 20-days of release scenario.
The co-location of TCE releasing facilities and monitoring stations in a HUC is shown in Figure 4-5. for
HUCs in North Carolina and in Figure 4-5 for the HUC in New Mexico. The modeled estimates are only
shown in Figure 4-5 and Figure 4-6 for the higher release frequency scenarios, which are associated with
lower predicted surface water concentrations. The surface water concentrations were compared to the
COCs in these maps.

Figure 4-1 to Figure 4-6 compare WQX Monitoring Stations from 2016 to TCE-releasing facilities
modeled in E-FAST. The figures show that while some facilities releasing TCE to surface water were
co-located with monitoring locations in WQX, none were downstream from facilities. The monitored
data, which represents localized concentrations of TCE in ambient water, generally show lower
concentrations than the modeled surface water concentrations from E-FAST, which represents
concentrations near facilities releasing TCE. The modeled and monitored data together indicate that risk
to aquatic organisms from TCE exposure is more likely in areas near the facilities, rather than in ambient
water; however the monitored data was limited geographically and temporally.

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292	Figure 4-1. Concentrations of Trichloroethylene from Releasing Facilities (Higher Release

293	Frequency Scenarios) and WQX Monitoring Stations: Year 2016, East US.

294	[Note: All indirect releases are mapped at the receiving facility unless the receiving facility is unknown.]

3 - 787 jjg/L	~ Modeled - Direct Release (250 - 365 days/yr)

< 3 |jg/L (below all COCs) A Modeled - Indirect Release (250 - 365 days/yr)
Not detected	Measured - NWIS/STORET Monitoring Sites

El A Days of exceedance £ 20 days

States with no modeled or measured
concentrations

300

¦i Miles

295

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297

298

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300

301

Figure 4-2. Concentrations of Trichloroethylene from Releasing Facilities (Higher Release
Frequency Scenarios) and WQX Monitoring Stations: Year 2016, West US.

[Note: All indirect releases are mapped at the receiving facility unless the receiving facility is unknown.]

Jj

300
¦i Miles

Concentration Levels

Concentration Type

3 - 787 pg/L	~ Modeled - Direct Release (250 - 365 days/yr)

< 3 |jg/L (below all COCs) A Modeled - Indirect Release (250 - 365 days/yr)

Not detected	Measured - NWIS/STORET Monitoring Sites

~ A Days of exceedance 2 20 days

1/ > States with no modeled or measured
concentrations

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302	Figure 4-3. Concentrations of Trichloroethylene from Releasing Facilities (20 Days of Release

303	Scenario) and WQX Monitoring Stations: Year 2016, East US.

304	[Note: All indirect releases are mapped at the receiving facility unless the receiving facility is unknown.]

305

Concentration Levels	Concentration Type

¦	788 - 51.999 (jg/L	~ Modeled - Direct Release (20 days/yr)

¦	3 - 787 pg/L	o Measured - NWIS/STORET Monitoring Sites

¦	< 3 pg/L (below all COCs) 21 Days of exceedance 2 20 days

¦	Not detected	\y States with no modeled or measured

concentrations

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Figure 4-4. Concentrations of Trichloroethvlene Releasing Facilities (20 Days of Release Scenario)
and WQX Monitoring Stations: Year 2016, West US.

[Note: All indirect re

309

310

eases are mapped at the receiving facility unless the receiving facility is unknown.]

Concentration Levels	Concentration Type

¦	3 - 787 pg/L	~ Modeled - Direct Release (250 - 365 days/yr)

¦	< 3 yg/L (below all COCs) Measured - NWIS/STORET Monitoring Sites

¦	Not detected	~ Days of exceedance a 20 days

States with no modeled or measured
concentrations

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311	Figure 4-5. Co-location of Triehloroethylene-Releasing Facilities and WQX Monitoring Stations at

312	the HUC 8 Level in NC

313

Upper Dan
03010103

11(1000900446

110031424233

smith '¦¦;y
Mountain -¦ j
Late s /

II0001501492

110001489050

Haw
03030002

Upper Yadkin
03040101

110000345779

Upper Catawba
03050101

lohn hpKrlhteerfair Upper Tar

	JhW 03020101

II0001504747

1110031398707

I	

Upper Neuse
03020201

N( 0089494

Deep
03030003

Upper French Broad
06010105

Lower Yadkin
03040103

110007119974

110000345939

v , cm

Concentrations

Measured - NWIS/STORET Monitoring Sites

• Not detected

Modeled - Indirect Release (250 - 365 days/yr)

A Below all COC

Modeled - Direct Release (250 - 365 days/yr)

¦ Below all COC
L_JHUC-8 boundary

Northeast Cape Fear
03030007

100
i i Miles

\ i

3S TKej^ational Map: Najbnal Hydrography Dataset. Data refreshed October, 2018

Green
SiKrmn.

N( 00012281

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Figure 4-6. Co-location of Trichloroethylene-Releasing Facilities and WQX Monitoring Stations at

4.1.3	Risk Estimation for Sediment

EPA did not quantitatively assess exposure to sediment organisms, because TCE is not expected to
partition to sediment, based on physical-chemical properties. TCE is expected to remain in aqueous
phases and not adsorb to sediment due to its water solubility (> 1280 m g/L) and low partitioning to
organic matter (log Koc = 1.8-2.17). Limited sediment monitoring data for TCE that are available
suggest that TCE is present in sediments, but because TCE has relatively low partition to organic matter
(log Koc = 1.802.17) and biodegrades slowly [19% biodegradation in 28 days (ECB2004)],
TCE concentrations in sediment pore water are expected to be similar to the concentrations in the
overlying water or lower in the deeper part of sediment which anaerobic condition prevails. Thus, the
TCE detected in sediments is likely from the pore water.

4.1.4	Risk Estimation for Terrestrial

EPA did not quantitatively assess exposure to terrestrial organisms through soil, water, or biosolids.
TCE is not expected to partition to soil but is expected to volatilize to air, based on its physical-chemical
properties. Review of hazard data for terrestri al organisms shows potential hazard; however, physical-
chemical properties do not support an exposure pathway through water and soil pathways to terrestrial
organisms.

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TCE is not anticipated to partition to biosolids during wastewater treatment. TCE has a predicted 81%
wastewater treatment removal efficiency, predominately due to volatilization during aeration. Any TCE
present in the water portion of biosolids following wastewater treatment and land application would be
expected to rapidly volatilize into air. To further support this analysis, TCE was not detected in EPA's
Targeted National Sewage Sludge Survey (TNSSS) nor was it reported in biosolids during EPA's
Biennial Reviews for Biosolids, a robust biennial literature review conducted by EPA's Office of Water
{U.S. EPA, 2019, 5933985}. Furthermore, TCE is not anticipated to remain in soil, as it is expected to
either volatilize into air or migrate through soil into groundwater.

TCE is expected to volatilize to air, based on physicochemical properties. However, the emission
pathways to ambient air from commercial and industrial stationary sources or associated inhalation
exposure of terrestrial species were out of the scope of the risk evaluation because stationary source
releases of TCE to ambient air are adequately assessed and any risks effectively managed when under
the jurisdiction of the Clean Air Act (CAA).

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350 4.2 Human Health Risk

351

352

353

354

355

356

4.2.1 Risk Estimation Approach

The use scenarios, populations of interest and toxicological endpoints used for acute and chronic
exposures are are presented in Table 4-4.

Table 4-4. Use Scenarios, Populations of Interest and Toxicological Endpoints Used for Acute and
Chronic Exposures	

Population of Interest and
Exposure Scenario

Workers: 1

Acute- Adolescent (>16 years old) and adult workers exposed to TCE for
a single 8-hr exposure

Chronic- Adolescent (>16 years old) and adult workers exposed to TCE
for the entire 8-hr workday for 260 days per year for 40 working years
Occupational Non-User:

Acute or Chronic- Adolescent (>16 years old) and adult worker exposed
to TCE indirectly by being in the same work area of the building

Consumers 1

Acute- Children (>11 years old) and adult consumers exposed to TCE for

a short period of time during use 3

Bystanders:

Acute- Individuals of all ages exposed to TCE through consumer use of
another individual.

Health Effects,
Concentration and Time
Duration

Non-Cancer Point of Departures (POD):

HEC- ppm;

POD HECs represent 24hr values and exposure concentrations have been
adjusted to match the time duration for inhalation exposure.

Note: Selgrade 2010 POD is a 3h acute value that has been adjusted to
match the 24hr exposure value for workers (3h exposure values were
used for consumers to match available 3hr exposure estimates from
CEM).

HEP- mg/kg; for dermal risk estimates

Non-Cancer Health Effects: 4

Acute- Developmental effects and immunotoxicity

Chronic- Liver effects, kidney effects, neurological effects, immune
effects, reproductive effects, and developmental effects	

Uncertainty Factors (UF)
used in Non-Cancer Margin
of Exposure (MOE)
calculations

Benchmark MOEs: Vary by endpoint
Benchmark MOE = (UFS) x (UFA) x (UFH) x (UFL)5

1	Adult workers (>16 years old) include both healthy female and male workers.

2	EPA believes that the users of these products are generally adults, but young teenagers and even younger children may be
users or be in the same room with the user while engaging in various conditions of use. Since there are not survey data for
consumer behavior patterns or a way to create varying behavior patterns for different age groups, the indoor air concentrations
shown in Table 4-4. Use could be extended to all users.

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3	EPA believes that the users of these products are generally adults, but young teenagers and even younger children may be
users or be in the same room with the user while engaging in various conditions of use. Since there are not survey data for
consumer behavior patterns or a way to create varying behavior patterns for different age groups, the indoor air concentrations
shown in Table 4-5 could be extended to all users.

4	Female workers of childbearing age are the population of interest for reproductive and developmental effects. For other
health effects (e.g., liver, kidney, etc.), healthy female or male workers were assumed to be the population of interest.

5	UFs=subchronic to chronic UF; UFA=interspecies UF; UFH=intraspecies UF; UFl=LOAEL to NOAEL UF

The EPA uses a Margin of Exposure (MOE) approach to assessing non-cancer risk. The MOE is the
ratio of the point of departure (POD) dose divided by the human exposure dose. The MOE is compared
to the benchmark MOE. If the MOE exceeds the benchmark MOE, this indicates the potential for risk to
human health.

Acute or chronic MOEs (MOEaCute or MOEchronic) were used in this assessment to estimate non- cancer
risks using Equation 4-1.

Equation 4-1. Equation to Calculate Non-Cancer Risks Following Acute or Chronic Exposures
Using Margin of Exposures

Non — cancer Hazard value (POD)
MOEacuteorchronic=	Human Exposure

Where:

MOE

Hazard Value (POD)
Human Exposure

= Margin of exposure (unitless)

= HEC (ppm) or HED (mg/kg)

= Exposure estimate (in ppm or mg/kg) from occupational exposure
assessment

= Exposure estimate (in ppm or mg/kg) from consumer exposure
assessment

Acute Concentrations (ACs) in ppm and acute Average Daily Doses (ADDs) were used to calculate
occupational non-cancer risks following acute inhalation or dermal exposure, respectively. Average
Daily Concentrations (ADC) and non-cancer chronic ADDs were used for calculating occupational non-
cancer risks following inhalation or dermal chronic exposure, respectively. ADD values accounted for
modeled evaporation, representing an estimated absorbed dose. Lifetime Average Daily Concentrations
(LADC) and cancer Chronic Retained Doses (CRDs) were used for calculating occupational cancer
risks. See Appendix J for more details on the derivation of chronic exposure values from acute
concentrations/doses.

Consumer risks via inhalation were calculated based on maximum Time-Weighted Average (TWAs) for
either 3h or 24h periods and consumer risks via dermal exposure were calculated based on Acute Dose
Rate (ADR). See Section 2.3.1.3.1 for more details on consumer exposure).

EPA used margin of exposures (MOEs) to estimate acute or chronic risks for non-cancer based on the
following:

•	the most sensitive and robust HEDs within each health effects domain reported in the literature;

•	the endpoint/study-specific UFs applied to the HEDs per EPA RfD Guidance ("U.S. EPA. 2002); and

•	the exposure estimates calculated for TCE uses examined in this risk assessment (see Section 2.3 -
Human Exposures).

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MOEs allow for the presentation of a range of risk estimates. The occupational exposure scenarios
considered both acute and chronic exposures, while consumer exposure scenarios considered only acute
exposures. In general, the frequency of product use was considered to be too low to create chronic risk
concerns. Although Westat (1987) survey data indicate that use frequencies for high-end product users
(i.e., those reflecting 95th percentile annual use frequencies) may use products up to 50 times per year,
available toxicological data is based on either single or continuous TCE exposure and it is unknown
whether these use patterns are expected to be clustered or intermittent (e.g. one time per week). There is
uncertainty regarding the extrapolation from continuous studies in animals to the case of repeated
intermittent human exposures. Therefore, EPA cannot fully rule out that consumers at the high-end
frequency of use could possibly be at risk for chronic hazard effects (Section 3.2), however it is expected
to be unlikely.

Different adverse endpoints were used based on the expected exposure durations. For non-cancer
effects, risks for developmental effects were evaluated for acute (short-term) exposures, whereas risks
for other adverse effects (liver toxicity, kidney toxicity, neurotoxicity, immunotoxicity, reproductive
effects, and developmental effects) were evaluated for repeated (chronic) exposures to TCE.

The total UF for each non-cancer POD was the benchmark MOE used to interpret the MOE risk
estimates for each use scenario. The MOE estimate was interpreted as human health risk if the MOE
estimate was less than the benchmark MOE (i.e. the total cumulative UF). On the other hand, the MOE
estimate indicated negligible concerns for adverse human health effects if the MOE estimate exceeded
the benchmark MOE. Typically, the larger the MOE relative to the benchmark MOE for that endpoint,
the more unlikely it is that a non-cancer adverse effect would occur.

Extra cancer risks for chronic exposures to TCE were estimated using Equation 4-2. Estimates of extra
cancer risks should be interpreted as the incremental probability of an individual developing cancer over a
lifetime as a result of exposure to the potential carcinogen (i.e., incremental or extra individual lifetime
cancer risk). For purposes of this risk evaluation, EPA considers extra risk of 1 x 10"4 (or 1E-4 in shorthand)
to be the benchmark for occupational risk estimation.

Equation 4-2. Equation to Calculate Extra Cancer Risks

Risk = Human Exposure (LADC) X POD (IUR or OSF)

Where:

Risk = Extra cancer risk (unitless)

Human exposure = Exposure estimate (ppm or mg/kg/day) from occupational exposure
assessment

POD = Inhalation unit risk (0.022 per ppm) or oral slope factor (0.0464 per mg/kg-day)

Risk estimates were calculated for all of the studies per health effects domain that EPA considered
suitable for the risk evaluation of acute and chronic exposure scenarios in this risk evaluation for TCE.
EPA used a previously developed peer-reviewed PBPK model in order to obtain both HECs and HEDs
from animal toxicological studies involving either oral or inhalation administration of TCE. The PBPK
model does not account for dermal exposure, so EPA relied on traditional route-to-route extrapolation
from oral HED values. EPA conservatively assumes 100% absorption through all routes based on
reasonably available toxicokinetic data. EPA did not evaluate TCE exposure through the oral route
because the route is out of scope for this evaluation (	). The volatile properties of TCE

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suggest that the majority of dermally deposited TCE would quickly evaporate except in occluded
scenarios. Therefore, inhalation is expected to be the predominant route of human exposure for most
conditions of use. Dermal exposure was considered for occupational scenarios while accounting for
evaporation according to modeling from (Kasting and Miller. 2006) (see Section 2.3.1.2.5). For
consumers, dermal exposure was only considered for scenarios resulting in dermal contact with impeded
evaporation (See Section 2.3.2.2.2).

4.2.1.1 Representative Points of Departure for Use in Risk Estimation

All PODs listed in Table 3-13 will be used for risk estimation of acute exposure scenarios. For chronic
exposure scenarios, due to the large number of relevant endpoints, risks will be assessed using a single
endpoint representative of each health domain. EPA considers all of the endpoints identified in Table

3-14	to be similarly relevant to human health hazard from TCE exposure. Therefore risk estimates for
chronic exposure scenarios will be presented for only those endpoints representing the most sensitive and
robust data within each health domain, with the presumption that evaluation of risks for these endpoints
would also account for all other less sensitive yet relevant endpoints. These PODs are presented in Table

4-5.	For complete MOE tables displaying risk estimates for all chronic endpoints, see [Risk Calculator
for Occupational Exposures. Docket: EPA-HQ-OPPT-2019-0500].

As described in (Section 3.2.6.4), EPA considers the POD for immunosuppression from (S el grade and
Gitmouf. 2010) to be the best overall representative endpoint for acute scenarios and autoimmunity from
(Keil et at.. 2009) to be the best overall representative non-cancer endpoint for chronic scenarios.
However, EPA presents risk estimates for all acute endpoints and chronic health domains in Section 4.2.2
and 4.2.3 in order to more accurately describe the range of risk associated with TCE exposure.

Table 4-5: Most Sensitive Endpoints from Each Health Domain for Risk Estimation

of Chronic Exposure Scenarios

Target Organ/
System

POD Type

Effect

HEC99
(ppm)

HED99
(mg/kg)

Uncertainty
Factors (UFs)

Reference

Data
Quality

Developmental
Effects

BMDL01 —
0.0207mg/kg-
bw/day

Congenital heart defects

0.0037

0.0052

UFS=1;UFA=3;

UFh=3;UFl=1;

Total LTF= 10

(Johnson et aL,

2003)

Medium

Kidney

BMDL10 = 34
mg/kg-bw/day

Pathology changes in
renal tubule

0.025

0.015

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Maltoni et aL,

1986)

Medium

Immune System

LOAEL = 0.35
mg/kg-bw/day

Autoimmunity (increased
anti-dsDNA and -ssDNA
antibodies)

0.033

0.048

UFS=1;UFA=3;
LTFH=3; UFL=3;
Total UF=30

(Keil et aL,

2009)

High

Reproductive
System

BMDL10 = 1.4
ppm

Decreased normal sperm
morphology and hyper-
zoospermia

0.5

0.73

LTFS=10;LTFA= 1;
UFH=3;UFL=1;
Total UF=30

(Chia et aL,

1996)

Medium

Nervous System

LOAEL = 12
ppm

Significant decreases in
wakefulness

4.8

6.5

LTFS=3; IIFA= 3;
LTFH=3; UFL=10;
Total UF=300

(Arito et aL,

1994)

Medium

Liver

BMDLio= 21.6
ppm

Increased liver/body
weight ratio and
cytotoxicity/hypertrophy

9.1

7.9

UFS=1;UFA=3;

UFh=3;UFl=1;

Total UF=10

(Kiellstrand et

aL,1983)

Medium

HEC/HED99 values will be used for risk estimation. These upper-end outputs from the PBPK model are
expected to be protective of susceptible subpopulations, accounting for the majority of identified
toxicokinetic human variability. The toxicokinetic metric of the interspecies and intraspecies uncertainty

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factors has been eliminated based on the use of these data-derived values, resulting in a reduced UFa and
UFh of 3.

4.2.2 Risk Estimation for Occupational Exposures by Exposure Scenario

Risk estimates via inhalation and dermal exposure are provided below for workers and ONUs following
acute (single day), chronic (40-year), or lifetime (78 year) TCE exposure. Inhalation risk estimates are
based on either monitoring or modeling exposure data. Non-cancer endpoints were applied to acute and
chronic exposures while cancer risk estimates are provided for adjusted lifetime exposure. Both are
presented for exposure scenarios where both data types are reasonably available. All dermal risk
estimates are based on modeling data as discussed in Section 2.3.1.2.5. Although generally ONU
exposures are expected to be less than workers, when sufficient data was not reasonably available for
quantifying ONU exposures EPA provided risk estimates for ONUs based on assuming that ONU
exposure may be comparable to worker central-tendency values. This is a health-protective assumption.
When reasonably available, inhalation risk estimates are presented based on both monitoring and
modeling data. Otherwise, risk estimates are presented for the type of inhalation exposure data that was
reasonably available. All dermal risk estimates are based on exposure modeling data. For details on the
exposure estimates for each exposure scenario, see Section 2.3.1.

For occupational scenarios, EPA evaluated the impact of potential respirator use based on respirator
APF of 10 and 50 in the below tables. The calculated non-cancer MOE or extra cancer risk with
respirator use is then compared to the benchmark MOE to determine the level of APF required to
mitigate risk for all health domains. EPA does not evaluate respirator use for occupational non-users
because they do not directly handle TCE and EPA assumes that they are unlikely to consistently wear
respirators. In addition, EPA believes small commercial facilities performing spot cleaning, wipe
cleaning, and other related commercial uses as well as commercial printing and copying are unlikely to
have a respiratory protection program. For dermal protection, EPA evaluated the impact of glove use up
to the maximum possible PF of 20 for industrial scenarios and PF of 10 for commercial scenarios (see
Table 2-20). For complete MOE tables displaying risk estimates for all endpoints and all PPE options,
see [Risk Calculator for Occupational Exposures. Docket: EPA-HQ-OPPT-2019-0500].

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498

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE 1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.3E-03

4.3E-02

0.21

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.0E-02

0.30

1.5

3.0E-02

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.5

34.8

173.9

-

1.8

8.9

17.8

35.6

Central Tendency

24.0

239.9

1,199.4

24.0

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

26.7

266.6

1,333.0

-

12.2

60.8

121.5

243.0

Central Tendency

183.9

1,839.1

9,195.6

183.9

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

2.0

20.2

100.8

-

1.2

5.9

11.9

23.8

Central Tendency

13.9

139.1

695.7

13.9

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

15.4

154.0

770.0

-

5.0

25.0

50.1

100.1

Central Tendency

106.2

1,062.4

5,311.8

106.2

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

4.2E-02

0.42

2.1

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

0.29

2.9

14.6

0.29

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

8.1

81.2

406.2

-

4.1

20.6

41.2

82.4

Central Tendency

56.0

560.4

2,801.8

56.0

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

5.6E-02

0.56

2.8

-

3.0E-02

0.15

0.30

0.61

Central Tendency

0.39

3.9

19.3

0.39

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.85

8.5

42.3

-

0.46

2.3

4.6

9.2

Central Tendency

5.8

58.4

291.9

5.8

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

6.3E-03

6.3E-02

0.31

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.3E-02

0.43

2.2

4.3E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

6.7E-03

6.7E-04

1.3E-04

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

7.5E-04

7.5E-05

1.5E-05

7.5E-04

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are considered plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

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MOE results for Manufacturing utilized monitoring inhalation exposure data (with dermal modeling) and are presented in Table 4-6.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for congenital heart defects at both exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and
glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for multiple endpoints at high-end inhalation exposure and for multiple endpoints at both high-end and central tendency inhalation
exposure even when assuming the highest plausible APF. MOEs remained below the benchmark MOE for multiple endpoints at both dermal
exposure levels even when assuming the highest plausible glove PF.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. Risk estimates remained above the
benchmark for cancer at high-end inhalation exposure even when assuming the highest plausible APF. Risk estimates remained above the
benchmark for multiple endpoints at both dermal exposure levels even when assuming the highest plausible glove PF.

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521

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE 1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.3E-03

4.3E-02

0.21

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.0E-02

0.30

1.5

3.0E-02

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.5

34.8

173.9

-

1.8

8.9

17.8

35.6

Central Tendency

24.0

239.9

1,199.4

24.0

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

26.7

266.6

1,333.0

-

12.2

60.8

121.5

243.0

Central Tendency

183.9

1,839.1

9,195.6

183.9

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

2.0

20.2

100.8

-

1.2

5.9

11.9

23.8

Central Tendency

13.9

139.1

695.7

13.9

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

15.4

154.0

770.0

-

5.0

25.0

50.1

100.1

Central Tendency

106.2

1,062.4

5,311.8

106.2

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

4.2E-02

0.42

2.1

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

0.29

2.9

14.6

0.29

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

8.1

81.2

406.2

-

4.1

20.6

41.2

82.4

Central Tendency

56.0

560.4

2,801.8

56.0

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

5.6E-02

0.56

2.8

-

3.0E-02

0.15

0.30

0.61

Central Tendency

0.39

3.9

19.3

0.39

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.85

8.5

42.3

-

0.46

2.3

4.6

9.2

Central Tendency

5.8

58.4

291.9

5.8

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

6.3E-03

6.3E-02

0.31

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.3E-02

0.43

2.2

4.3E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

6.7E-03

6.7E-04

1.3E-04

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

7.5E-04

7.5E-05

1.5E-05

7.5E-04

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are considered plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

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MOE results for Processing as a Reactant utilized monitoring inhalation exposure data (with dermal modeling) and are presented in Table
4-7.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for congenital heart defects at both exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and
glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for multiple endpoints at high-end inhalation exposure and for multiple endpoints at both high-end and central tendency inhalation
exposure even when assuming the highest plausible APF. MOEs remained below the benchmark MOE for multiple endpoints at both dermal
exposure levels even when assuming the highest plausible glove PF.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. Risk estimates remained above the
benchmark for cancer at high-end inhalation exposure even when assuming the highest plausible APF. Risk estimates remained above the
benchmark for multiple endpoints at both dermal exposure levels even when assuming the highest plausible glove PF.

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Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

1.4E-04

1.4E-03

7.1E-03

1.2E-03

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

8.0E-04

8.0E-03

4.0E-02

1.0E-02

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.12

1.2

5.8

0.99

1.8

8.9

17.8

35.6

Central Tendency

0.65

6.5

32.6

8.1

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

0.89

8.9

44.4

7.6

12.2

60.8

121.5

243.0

Central Tendency

5.0

50.0

250.0

62.3

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

6.7E-02

0.67

3.4

0.57

1.2

5.9

11.9

23.8

Central Tendency

0.38

3.8

18.9

4.7

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

0.51

5.1

25.6

4.4

5.0

25.0

50.1

100.1

Central Tendency

2.9

28.9

144.4

36.0

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

1.4E-03

1.4E-02

7.0E-02

1.2E-02

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

7.9E-03

7.9E-02

0.40

9.9E-02

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.27

2.7

13.5

2.3

4.1

20.6

41.2

82.4

Central Tendency

1.5

15.2

76.2

19.0

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

1.9E-03

1.9E-02

9.3E-02

1.6E-02

3.0E-02

0.15

0.30

0.61

Central Tendency

1.0E-02

0.10

0.52

0.13

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

2.8E-02

0.28

1.4

0.24

0.46

2.3

4.6

9.2

Central Tendency

0.16

1.6

7.9

2.0

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

2.1E-04

2.1E-03

1.0E-02

1.8E-03

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

1.2E-03

1.2E-02

5.9E-02

1.5E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.20

2.0E-02

4.0E-03

2.3E-02

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

2.8E-02

2.8E-03

5.5E-04

2.2E-03

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

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546

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE 1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

2.9E-05

2.9E-04

1.4E-03

4.7E-05

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.2E-04

3.2E-03

1.6E-02

6.1E-04

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

2.3E-02

0.23

1.2

3.8E-02

1.8

8.9

17.8

35.6

Central Tendency

0.26

2.6

12.9

0.50

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

0.18

1.8

8.9

0.29

12.2

60.8

121.5

243.0

Central Tendency

2.0

19.8

99.1

3.8

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

1.3E-02

0.13

0.67

2.2E-02

1.2

5.9

11.9

23.8

Central Tendency

0.15

1.5

7.5

0.29

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

0.10

1.0

5.1

0.17

5.0

25.0

50.1

100.1

Central Tendency

1.1

11.4

57.2

2.2

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

2.8E-04

2.8E-03

1.4E-02

4.6E-04

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

3.1E-03

3.1E-02

0.16

6.0E-03

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

5.4E-02

0.54

2.7

8.9E-02

4.1

20.6

41.2

82.4

Central Tendency

0.60

6.0

30.2

1.2

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

3.7E-04

3.7E-03

1.9E-02

6.1E-04

3.0E-02

0.15

0.30

0.61

Central Tendency

4.1E-03

4.1E-02

0.21

8.0E-03

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

5.6E-03

5.6E-02

0.28

9.3E-03

0.46

2.3

4.6

9.2

Central Tendency

6.3E-02

0.63

3.1

0.12

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

4.2E-05

4.2E-04

2.1E-03

6.9E-05

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.6E-04

4.6E-03

2.3E-02

8.9E-04

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.78

7.8E-02

1.6E-02

0.46

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

6.5E-02

6.5E-03

1.3E-03

3.4E-02

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are considered plausible for this exposure scenario.

547

Page 287 of 748


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548

549

550

551

552

553

554

555

556

557

558

559

560

561

562

563

564

565

566

567

568

569

570

571

572

573

574

575

576

577

578

579

580

581

582

583

584

585

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Batch Open Top Vapor l)egreasing utilized both monitoring and modeling inhalation exposure data (with dermal modeling).
Results are presented in Table 4-8 and Table 4-9.

Acute Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for all endpoints at both high-end and
central tendency exposure levels via both inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple
endpoints based on monitoring and for all endpoints based on modeling at both high-end and central tendency inhalation exposure levels.
Based on both monitoring and modeling data, MOEs remained below the benchmark MOE for multiple endpoints at both inhalation exposure
levels even when assuming the highest plausible APF. MOEs remained below the benchmark MOE for congenital heart defects at both
dermal exposure levels even when assuming the highest plausible glove PF protection.

Chronic Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for all endpoints at both high-end and
central tendency exposure levels via both inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple
endpoints based on monitoring and for all endpoints based on modeling at both high-end and central tendency inhalation exposure levels.
Based on both monitoring and modeling data, MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via
dermal and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Based on both monitoring and modeling data, extra risk estimates for workers were above the benchmark level for cancer at both high-end
and central tendency exposure levels via both inhalation and dermal routes. Based on both monitoring and modeling data, risk estimates for
ONUs were also above the benchmark for cancer at both high-end and central tendency inhalation exposure levels. Based on both monitoring
and modeling data, risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes even
when assuming the highest plausible APF and glove PF protection.

OSHA PEL considerations

The OSHA PEL for TCE is 100 ppm (8hr TWA). The monitoring dataset for this OES included some data points above the PEL value. In an
alternative approach, EPA calculated central tendency and high end values for the measurements lower than the PEL. This resulted in a
reduction of the high-end acute exposure estimate from 25.92ppm to 19.23 ppm and the central tendency acute exposure estimate from 4.60
ppm to 4.26 ppm. Chronic high-end and central tendency exposures are reduced from 17.75 ppm and 3.15 ppm to 13.17 ppm and 2.92 ppm,
respectively. Lifetime exposures are reduced from 9.10 ppm and 1.25 ppm to 6.75 ppm and 1.15 ppm, respectively. The reduced exposures do
not significantly affect the risk estimates, since exposures were only reduced by up to -30%. Based on PEL-capped exposure estimates, the
acute and chronic central tendency MOEs for the congenital heart defects endpoint (with benchmark MOE = 10) are 8.7E-04 and 1.3E-03,
respectively. The central tendency cancer extra risk (benchmark = 1E-04) is 2.6E-02. Therefore, the MOEs remains orders of magnitude
below the benchmark MOE (or above the benchmark for cancer risk) when using only PEL-capped exposure estimates. Full details are
provided in [Occupational Risk Estimate Calculator. Docket # EPA-HQ-OPPT-2019-0500].

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586

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

7.6E-03

7.6E-02

0.38

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

2.4E-02

0.24

1.2

2.4E-02

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

6.2

61.9

309.5

-

1.8

8.9

17.8

35.6

Central Tendency

19.7

196.6

983.0

19.7

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

47.5

474.5

2,372.5

-

12.2

60.8

121.5

243.0

Central Tendency

150.7

1,507.3

7,536.5

150.7

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

3.6

35.9

179.5

-

1.2

5.9

11.9

23.8

Central Tendency

11.4

114.0

570.1

11.4

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

27.4

274.1

1,370.5

-

5.0

25.0

50.1

100.1

Central Tendency

87.1

870.7

4,353.5

87.1

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

7.5E-02

0.75

3.8

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

0.24

2.4

12.0

0.24

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

14.5

144.6

722.9

-

4.1

20.6

41.2

82.4

Central Tendency

45.9

459.3

2,296.3

45.9

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

9.9E-02

0.99

5.0

-

3.0E-02

0.15

0.30

0.61

Central Tendency

0.32

3.2

15.8

0.32

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

1.5

15.1

75.3

-

0.46

2.3

4.6

9.2

Central Tendency

4.8

47.8

239.2

4.8

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

1.1E-02

0.11

0.56

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

3.5E-02

0.35

1.8

3.5E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

3.7E-03

3.7E-04

7.5E-05

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

9.1E-04

9.1E-05

1.8E-05

9.1E-04

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

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587

588

589

590

591

592

593

594

595

596

597

598

599

600

601

602

603

604

605

606

607

608

609

610

611

612

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Batch Closed-Loop Vapor Degreasing utilized monitoring inhalation exposure data (with dermal modeling) and are
presented in Table 4-10.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for congenital heart defects at both exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and
glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for multiple endpoints at high-end inhalation exposure and for immunotoxicity at both high-end and central tendency inhalation
exposure even when assuming the highest plausible APF. MOEs remained below the benchmark MOE for multiple endpoints at both dermal
exposure levels even when assuming the highest plausible glove PF.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. Risk estimates were not above the
benchmark for high-end inhalation exposure when assuming APF = 50 or for central tendency inhalation exposure when assuming APF = 10.
Risk estimates remained above the benchmark for multiple endpoints at both dermal exposure levels even when assuming the highest
plausible glove PF.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

613 Table 4-11. Occupational I

lisk Estimation - Conveyorized Vapor Degreasing - Inhalation IV

onitoring Data

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

2.3E-04

2.3E-03

1.1E-02

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.4E-04

3.4E-03

1.7E-02

3.4E-04

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.19

1.9

9.3

-

1.8

8.9

17.8

35.6

Central Tendency

0.28

2.8

13.9

0.28

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

1.4

14.3

71.4

-

12.2

60.8

121.5

243.0

Central Tendency

2.1

21.3

106.5

2.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.11

1.1

5.4

-

1.2

5.9

11.9

23.8

Central Tendency

0.16

1.6

8.1

0.16

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

0.83

8.3

41.3

-

5.0

25.0

50.1

100.1

Central Tendency

1.2

12.3

61.5

1.2

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

2.3E-03

2.3E-02

0.11

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

3.4E-03

3.4E-02

0.17

3.4E-03

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.44

4.4

21.8

-

4.1

20.6

41.2

82.4

Central Tendency

0.65

6.5

32.5

0.65

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

3.0E-03

3.0E-02

0.15

-

3.0E-02

0.15

0.30

0.61

Central Tendency

4.5E-03

4.5E-02

0.22

4.5E-03

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Chiaetal.. 1996)

30

High End

4.5E-02

0.45

2.3

-

0.46

2.3

4.6

9.2

Central Tendency

6.8E-02

0.68

3.4

6.8E-02

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

3.4E-04

3.4E-03

1.7E-02

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

5.0E-04

5.0E-03

2.5E-02

5.0E-04

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.12

1.2E-02

2.5E-03

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

6.5E-02

6.5E-03

1.3E-03

6.5E-02

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

Page 291 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

614 Table 4-12. Occupational I

lisk Estimation - Conveyorized Vapor Degreasing - Inhalation IV

odeling Data

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

3.6E-06

3.6E-05

1.8E-04

5.9E-06

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

2.7E-04

2.7E-03

1.4E-02

4.8E-04

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.0E-03

3.0E-02

0.15

4.8E-03

1.8

8.9

17.8

35.6

Central Tendency

0.22

2.2

11.0

0.39

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

2.3E-02

0.23

1.1

3.7E-02

12.2

60.8

121.5

243.0

Central Tendency

1.7

16.9

84.6

3.0

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

1.7E-03

1.7E-02

8.6E-02

2.8E-03

1.2

5.9

11.9

23.8

Central Tendency

0.13

1.3

6.4

0.22

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

1.3E-02

0.13

0.65

2.1E-02

5.0

25.0

50.1

100.1

Central Tendency

0.98

9.8

48.8

1.7

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

3.6E-05

3.6E-04

1.8E-03

5.8E-05

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

2.7E-03

2.7E-02

0.13

4.7E-03

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

6.9E-03

6.9E-02

0.35

1.1E-02

4.1

20.6

41.2

82.4

Central Tendency

0.52

5.2

25.8

0.90

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

4.7E-05

4.7E-04

2.4E-03

7.7E-05

3.0E-02

0.15

0.30

0.61

Central Tendency

3.5E-03

3.5E-02

0.18

6.2E-03

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

7.2E-04

7.2E-03

3.6E-02

1.2E-03

0.46

2.3

4.6

9.2

Central Tendency

5.4E-02

0.54

2.7

9.4E-02

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

5.3E-06

5.3E-05

2.7E-04

8.6E-06

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.0E-04

4.0E-03

2.0E-02

6.9E-04

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

6.1

0.61

0.12

3.7

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

0.12

1.2E-02

2.3E-03

7.9E-02

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

615

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616

617

618

619

620

621

622

623

624

625

626

627

628

629

630

631

632

633

634

635

636

637

638

639

640

641

642

643

644

645

646

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Conveyorized Vapor Degreasing utilized both monitoring and modeling inhalation exposure data (with dermal modeling).
Results are presented in Table 4-11 and Table 4-12.

Acute Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for all endpoints at both high-end and
central tendency exposure levels via inhalation and for most endpoints via the dermal route. EPA is unable to estimate ONU exposures
separately from workers based on monitoring data. ONU risk estimates were below the benchmark MOE for all endpoints at both high-end
and central tendency inhalation exposure levels based on modeling data. Based on both monitoring and modeling data, MOEs remained
below the benchmark MOE for multiple endpoints at both inhalation exposure levels even when assuming the highest plausible APF. MOEs
remained below the benchmark MOE for congenital heart defects at both dermal exposure levels even when assuming the highest plausible
glove PF protection.

Chronic Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for all endpoints at both high-end and
central tendency exposure levels via both inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers
based on monitoring data. ONU risk estimates were below the benchmark MOE for all endpoints at both high-end and central tendency
inhalation exposure levels based on modeling data. Based on both monitoring and modeling data, MOEs remained below the benchmark
MOE for multiple endpoints at both exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and
glove PF protection.

Cancer Risk Estimates:

Based on both monitoring and modeling data, extra risk estimates for workers were above the benchmark level for cancer at both high-end
and central tendency exposure levels via both inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from
workers based on monitoring data. ONU risk estimates were above the benchmark at both high-end and central tendency inhalation exposure
levels based on modeling data. Based on both monitoring and modeling data, risk estimates remained above the benchmark for cancer at both
exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and glove PF protection.

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647

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

7.9E-04

7.9E-03

3.9E-02

1.2E-03

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

1.9E-03

1.9E-02

9.3E-02

3.5E-03

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.64

6.4

31.8

0.94

1.8

8.9

17.8

35.6

Central Tendency

1.5

15.1

75.7

2.9

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

4.9

48.8

244.0

7.2

12.2

60.8

121.5

243.0

Central Tendency

11.6

116.1

580.4

22.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.37

3.7

18.5

0.55

1.2

5.9

11.9

23.8

Central Tendency

0.88

8.8

43.9

1.7

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

2.8

28.2

140.9

4.2

5.0

25.0

50.1

100.1

Central Tendency

6.7

67.1

335.3

12.7

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

7.7E-03

7.7E-02

0.39

1.1E-02

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

1.8E-02

0.18

0.92

3.5E-02

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

1.5

14.9

74.3

2.2

4.1

20.6

41.2

82.4

Central Tendency

3.5

35.4

176.8

6.7

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

1.0E-02

0.10

0.51

1.5E-02

3.0E-02

0.15

0.30

0.61

Central Tendency

2.4E-02

0.24

1.2

4.6E-02

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.15

1.5

7.7

0.23

0.46

2.3

4.6

9.2

Central Tendency

0.37

3.7

18.4

0.70

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

1.1E-03

1.1E-02

5.7E-02

1.7E-03

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

2.7E-03

2.7E-02

0.14

5.2E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

2.9E-02

2.9E-03

5.8E-04

1.9E-02

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

1.1E-02

1.1E-03

2.3E-04

5.9E-03

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

648

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649

650

651

652

653

654

655

656

657

658

659

660

661

662

663

664

665

666

667

668

669

670

671

672

673

674

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Web Vapor I)egreasing utilized modeling inhalation exposure data (with dermal modeling) and are presented in Table 4-13.
Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via inhalation
and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at the central tendency inhalation exposure
level. MOEs remained below the benchmark MOE for multiple endpoints at both inhalation exposure levels even when assuming the highest
plausible APF. MOEs remained below the benchmark MOE for congenital heart defects at both dermal exposure levels even when assuming
the highest plausible glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at the central tendency inhalation
exposure level. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at the central tendency inhalation exposure
level. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes even when assuming
the highest plausible APF and glove PF protection.

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675

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

1.9E-04

1.9E-03

9.7E-03

3.2E-04

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.3E-03

3.3E-02

0.17

6.0E-03

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.16

1.6

7.9

0.26

1.8

8.9

17.8

35.6

Central Tendency

2.7

27.0

135.1

4.9

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

1.2

12.1

60.3

2.0

12.2

60.8

121.5

243.0

Central Tendency

20.7

207.2

1,036.0

37.5

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

9.1E-02

0.91

4.6

0.15

1.2

5.9

11.9

23.8

Central Tendency

1.6

15.7

78.4

2.8

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

0.69

6.9

34.7

1.2

5.0

25.0

50.1

100.1

Central Tendency

12.0

119.7

598.7

21.7

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

1.9E-03

1.9E-02

9.5E-02

3.2E-03

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

3.3E-02

0.33

1.6

6.0E-02

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.37

3.7

18.3

0.61

4.1

20.6

41.2

82.4

Central Tendency

6.3

63.2

315.8

11.4

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

2.5E-03

2.5E-02

0.13

4.2E-03

3.0E-02

0.15

0.30

0.61

Central Tendency

4.3E-02

0.43

2.2

7.9E-02

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

3.8E-02

0.38

1.9

6.3E-02

0.46

2.3

4.6

9.2

Central Tendency

0.66

6.6

32.9

1.2

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

2.8E-04

2.8E-03

1.4E-02

4.7E-04

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.9E-03

4.9E-02

0.24

8.8E-03

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.11

1.1E-02

2.3E-03

6.9E-02

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

6.2E-03

6.2E-04

1.2E-04

3.3E-03

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

676

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678

679

680

681

682

683

684

685

686

687

688

689

690

691

692

693

694

695

696

697

698

699

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Cold Cleaning utilized modeling inhalation exposure data (with dermal modeling) and are presented in Table 4-14.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via inhalation
and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central tendency
inhalation exposure levels. MOEs remained below the benchmark MOE for congenital heart defects at both exposure levels via dermal and
inhalation routes even when assuming the highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at both high-end and central tendency
inhalation exposure levels. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

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700

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.6E-04

4.6E-03

2.3E-02

1.1E-02

1.4E-03

7.2E-03

1.4E-02

2.9E-02

Central Tendency

1.5E-03

1.5E-02

7.3E-02

7.9E-02

4.3E-03

2.2E-02

4.3E-02

8.6E-02

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.38

3.8

18.8

8.7

1.1

5.7

11.3

22.7

Central Tendency

1.2

11.8

59.0

64.3

3.4

17.0

34.0

68.0

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

2.9

28.8

143.9

66.3

7.7

38.7

77.4

154.8

Central Tendency

9.0

90.4

452.2

492.9

23.2

116.1

232.2

464.3

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.22

2.2

10.9

5.0

0.76

3.8

7.6

15.1

Central Tendency

0.68

6.8

34.2

37.3

2.3

11.4

22.7

45.4

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

1.7

16.6

83.1

38.2

3.2

15.9

31.9

63.8

Central Tendency

5.2

52.3

261.3

284.4

9.6

47.8

95.6

191.3

Kidney

(Maltoni et al.. 1986)

10

High End

4.6E-03

4.6E-02

0.23

0.11

6.1E-03

3.0E-02

6.1E-02

0.12

Central Tendency

1.4E-02

0.14

0.72

0.78

1.8E-02

9.1E-02

0.18

0.36

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.88

8.8

43.8

20.2

2.6

13.1

26.2

52.5

Central Tendency

2.8

27.6

137.9

150.0

7.9

39.3

78.7

157.4

Immunotoxicity
(Keil et al.. 2009)

30

High End

6.0E-03

6.0E-02

0.30

0.14

1.9E-02

9.7E-02

0.19

0.39

Central Tendency

1.9E-02

0.19

0.95

1.0

5.8E-02

0.29

0.58

1.2

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

9.1E-02

0.91

4.6

2.1

0.29

1.5

2.9

5.9

Central Tendency

0.29

2.9

14.4

15.6

0.88

4.4

8.8

17.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

6.8E-04

6.8E-03

3.4E-02

1.6E-02

2.1E-03

1.0E-02

2.1E-02

4.2E-02

Central Tendency

2.1E-03

2.1E-02

0.11

0.12

6.3E-03

3.1E-02

6.3E-02

0.13

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

4.9E-02

4.9E-03

9.7E-04

2.0E-03

5.9E-02

1.2E-02

5.9E-03

2.9E-03

Central Tendency

1.4E-02

1.4E-03

2.9E-04

2.6E-04

1.5E-02

3.0E-03

1.5E-03

7.6E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

701

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703

704

705

706

707

708

709

710

711

712

713

714

715

716

111

718

719

720

721

722

723

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Aerosol Applications utilized modeling inhalation exposure data (with dermal modeling) and are presented in Table 4-15.
Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints at both high-end and central tendency exposure levels via inhalation
and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central tendency
inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal and
inhalation routes even when assuming the highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at both high-end and central tendency
inhalation exposure levels. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

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724

Uses) - Inhalation Monitoring Data

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

3.9E-03

3.9E-02

0.19

-

1.4E-03

7.2E-03

1.4E-02

N/A2

Central Tendency

2.9E-02

0.29

1.4

2.9E-02

4.3E-03

2.2E-02

4.3E-02

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.2

31.6

157.8

-

1.1

5.7

11.3

Central Tendency

23.5

235.1

1,175.3

23.5

3.4

17.0

34.0

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

24.2

242.0

1,210.1

-

7.7

38.7

77.4

Central Tendency

180.2

1,802.2

9,010.9

180.2

23.2

116.1

232.2

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

1.8

18.3

91.5

-

0.76

3.8

7.6

Central Tendency

13.6

136.3

681.7

13.6

2.3

11.4

22.7

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

13.5

135.5

677.3

-

2.7

13.6

27.2

N/A2

Central Tendency

100.9

1,008.7

5,043.7

100.9

9.3

46.3

92.7

Kidney

(Maltoni et al.. 1986)

10

High End

3.7E-02

0.37

1.9

-

5.2E-03

2.6E-02

5.2E-02

Central Tendency

0.28

2.8

13.9

0.28

1.8E-02

8.8E-02

0.18

Neurotoxicity
(Arito et al.. 1994)

300

High End

7.1

71.5

357.3

-

2.2

11.2

22.4

Central Tendency

53.2

532.1

2,660.4

53.2

7.6

38.1

76.3

Immunotoxicity
(Keil et al.. 2009)

30

High End

4.9E-02

0.49

2.5

-

1.7E-02

8.3E-02

0.17

Central Tendency

0.37

3.7

18.3

0.37

5.6E-02

0.28

0.56

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.74

7.4

37.2

-

0.25

1.3

2.5

Central Tendency

5.5

55.4

277.1

5.5

0.86

4.3

8.6

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

5.5E-03

5.5E-02

0.28

-

1.8E-03

9.0E-03

1.8E-02

Central Tendency

4.1E-02

0.41

2.1

4.1E-02

6.1E-03

3.1E-02

6.1E-02

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

7.6E-03

7.6E-04

1.5E-04

-

6.9E-02

1.4E-02

6.9E-03

N/A2

Central Tendency

7.9E-04

7.9E-05

1.6E-05

7.9E-04

1.6E-02

3.1E-03

1.6E-03

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

1	EPA is unable to estimate ONU exposures separately from workers.

2	Glove PF =20 is only applicable to industrial settings (See Section 2.3.1).

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

725

Uses) - Inhalation Modeling Data

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.0E-03

4.0E-02

0.20

6.3E-03

1.4E-03

7.2E-03

1.4E-02

N/A1

Central Tendency

1.2E-02

0.12

0.58

2.3E-02

4.3E-03

2.2E-02

4.3E-02

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.2

32.5

162.5

5.1

1.1

5.7

11.3

Central Tendency

9.4

93.7

468.3

18.8

3.4

17.0

34.0

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

24.9

249.1

1,245.5

39.4

7.7

38.7

77.4

Central Tendency

71.8

718.0

3,590.0

144.1

23.2

116.1

232.2

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

1.9

18.8

94.2

3.0

0.76

3.8

7.6

Central Tendency

5.4

54.3

271.6

10.9

2.3

11.4

22.7

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

14.0

139.6

697.9

22.1

2.7

13.6

27.2

N/A1

Central Tendency

40.3

402.7

2,013.3

80.5

9.3

46.3

92.7

Kidney

(Maltoni et al.. 1986)

10

High End

3.8E-02

0.38

1.9

6.1E-02

5.2E-03

2.6E-02

5.2E-02

Central Tendency

0.11

1.1

5.5

0.22

1.8E-02

8.8E-02

0.18

Neurotoxicity
(Arito et al.. 1994)

300

High End

7.4

73.6

368.1

11.7

2.2

11.2

22.4

Central Tendency

21.2

212.4

1,061.9

42.5

7.6

38.1

76.3

Immunotoxicity
(Keil et al.. 2009)

30

High End

5.1E-02

0.51

2.5

8.0E-02

1.7E-02

8.3E-02

0.17

Central Tendency

0.15

1.5

7.3

0.29

5.6E-02

0.28

0.56

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.77

7.7

38.3

1.2

0.25

1.3

2.5

Central Tendency

2.2

22.1

110.6

4.4

0.86

4.3

8.6

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

5.7E-03

5.7E-02

0.28

9.0E-03

1.8E-03

9.0E-03

1.8E-02

Central Tendency

1.6E-02

0.16

0.82

3.3E-02

6.1E-03

3.1E-02

6.1E-02

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

5.8E-03

5.8E-04

1.2E-04

3.6E-03

6.9E-02

1.4E-02

6.9E-03

N/A1

Central Tendency

1.8E-03

1.8E-04

3.7E-05

9.2E-04

1.6E-02

3.1E-03

1.6E-03

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 Glove PF =20 is only applicable to industrial settings (See Section 2.3.1).

726

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727

728

729

730

731

732

733

734

735

736

737

738

739

740

741

742

743

744

745

746

747

748

749

750

751

752

753

754

755

756

757

758

759

760

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE calculations for Spot Cleaning and Wipe Cleaning utilized both monitoring and modeling inhalation exposure data (with dermal
modeling). This data also applies to the exposure scenario of Other Commercial Uses. Results are presented in Table 4-16 and Table 4-17.

Acute Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end
and central tendency exposure levels via both inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from
workers based on monitoring data. ONU risk estimates were below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels based on modeling data. Based on both monitoring and modeling data, MOEs remained below the
benchmark MOE for congenital heart defects at both exposure levels via inhalation and for multiple endpoints via the dermal route even when
assuming the highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE for all endpoints at both high-end and
central tendency exposure levels via both inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers
based on monitoring data. ONU risk estimates were below the benchmark MOE for multiple endpoints at both high-end and central tendency
inhalation exposure levels based on modeling data. Based on both monitoring and modeling data, MOEs remained below the benchmark
MOE for multiple endpoints at both exposure levels via both inhalation and dermal routes even when assuming the highest plausible APF and
glove PF protection.

Cancer Risk Estimates:

Based on both monitoring and modeling data, extra risk estimates for workers were above the benchmark level for cancer at both high-end
and central tendency exposure levels via both inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from
workers based on monitoring data. ONU risk estimates were above the benchmark at both high-end and central tendency inhalation exposure
levels based on modeling data. Based on both monitoring and modeling data, risk estimates remained above the benchmark for cancer at high-
end inhalation exposure levels and both dermal exposure levels even when assuming the highest plausible APF and glove PF protection. Risk
estimates were not above the benchmark for central tendency inhalation exposure when assuming APF =10 based on monitoring data or
when assuming APF = 50 based on modeling data.

PPE Considerations

EPA is presenting risk estimates for respiratory protection up to APF = 50 as a what-if scenario, however EPA believes that small commercial
facilities performing spot cleaning, wipe cleaning, and other related commercial uses are unlikely to have a respiratory protection program.
Therefore, the use of respirators is unlikely for workers in these facilities.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

761

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

9.7E-03

9.7E-02

0.49

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

22.4

224.3

1,121.3

22.4

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

7.9

78.9

394.7

-

1.8

8.9

17.8

35.6

Central Tendency

18,182.7

181,827.5

909,137.3

18,182.7

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

60.5

605.3

3,026.3

-

12.2

60.8

121.5

243.0

Central Tendency

139,401.1

1,394,010.5

6,970,052.6

139,401.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

4.6

45.8

228.9

-

1.2

5.9

11.9

23.8

Central Tendency

10,546.0

105,459.9

527,299.6

10,546.0

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

35.0

349.6

1,748.2

-

5.0

25.0

50.1

100.1

Central Tendency

80,525.3

805,253.2

4,026,266.0

80,525.3

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

9.6E-02

0.96

4.8

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

221.2

2,212.2

11,061.2

221.2

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

18.4

184.4

922.1

-

4.1

20.6

41.2

82.4

Central Tendency

42,474.9

424,748.9

2,123,744.7

42,474.9

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

0.13

1.3

6.3

-

3.0E-02

0.15

0.30

0.61

Central Tendency

292.0

2,920.1

14,600.7

292.0

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

1.9

19.2

96.1

-

0.46

2.3

4.6

9.2

Central Tendency

4,424.5

44,244.7

221,223.4

4,424.5

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

1.4E-02

0.14

0.71

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

32.7

327.4

1,637.1

32.7

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

2.9E-03

2.9E-04

5.9E-05

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

9.9E-07

9.9E-08

2.0E-08

9.9E-07

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

762

Page 303 of 748


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763

764

765

766

767

768

769

770

111

772

773

774

775

776

777

778

779

780

781

782

783

784

785

786

787

788

789

790

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Formulation of Aerosol and Non-Aerosol Products utilized monitoring inhalation exposure data (with dermal modeling) and
are presented in Table 4-18.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for congenital heart defects at high-end inhalation exposure even when assuming the highest plausible APF. MOEs
remained below the benchmark MOE for congenital heart defects at both dermal exposure levels even when assuming the highest plausible
glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for multiple endpoints at high-end inhalation exposure and at both dermal exposure levels even when assuming the highest
plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at at high-end inhalation exposures, but risk estimates were below
the benchmark for cancer at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from workers. Risk
estimates were above the benchmark at both dermal exposure levels. Risk estimates were not above the benchmark for high-end inhalation
exposure when assuming APF = 50. Risk estimates remained above the benchmark for cancer at both dermal exposure levels even when
assuming the highest plausible glove PF protection.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

791

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

9.7E-03

9.7E-02

0.49

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

22.4

224.3

1,121.3

22.4

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

7.9

78.9

394.7

-

1.8

8.9

17.8

35.6

Central Tendency

18,182.7

181,827.5

909,137.3

18,182.7

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

60.5

605.3

3,026.3

-

12.2

60.8

121.5

243.0

Central Tendency

139,401.1

1,394,010.5

6,970,052.6

139,401.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

4.6

45.8

228.9

-

1.2

5.9

11.9

23.8

Central Tendency

10,546.0

105,459.9

527,299.6

10,546.0

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

35.0

349.6

1,748.2

-

5.0

25.0

50.1

100.1

Central Tendency

80,525.3

805,253.2

4,026,266.0

80,525.3

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

9.6E-02

0.96

4.8

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

221.2

2,212.2

11,061.2

221.2

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

18.4

184.4

922.1

-

4.1

20.6

41.2

82.4

Central Tendency

42,474.9

424,748.9

2,123,744.7

42,474.9

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

0.13

1.3

6.3

-

3.0E-02

0.15

0.30

0.61

Central Tendency

292.0

2,920.1

14,600.7

292.0

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

1.9

19.2

96.1

-

0.46

2.3

4.6

9.2

Central Tendency

4,424.5

44,244.7

221,223.4

4,424.5

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

1.4E-02

0.14

0.71

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

32.7

327.4

1,637.1

32.7

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

2.9E-03

2.9E-04

5.9E-05

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

9.9E-07

9.9E-08

2.0E-08

9.9E-07

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

792

Page 305 of 748


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793

794

795

796

797

798

799

800

801

802

803

804

805

806

807

808

809

810

811

812

813

814

815

816

817

818

819

820

821

822

823

824

825

826

827

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Repackaging utilized monitoring inhalation exposure data (with dermal modeling) and are presented in Table 4-19.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for multiple endpoints at high-end inhalation exposure even when assuming the highest plausible APF. MOEs remained
below the benchmark MOE for congenital heart defects at both dermal exposure levels even when assuming the highest plausible glove PF
protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for multiple endpoints at high-end inhalation exposure and at both dermal exposure levels even when assuming the highest
plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at at high-end inhalation exposures, but risk estimates were below
the benchmark for cancer at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from workers. Risk
estimates were above the benchmark at both dermal exposure levels. Risk estimates were not above the benchmark for high tendency
inhalation exposure when assuming APF = 50. Risk estimates remained above the benchmark for cancer at both dermal exposure levels even
when assuming the highest plausible glove PF protection.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

828 Table 4-20. Occupational I

iisk Estimation - Metalworking Fluids - Inhalation Monitoring I

>ata

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

1.5E-04

1.5E-03

7.4E-03

-

2.8E-03

1.4E-02

2.8E-02

5.6E-02

Central Tendency

1.6E-04

1.6E-03

8.0E-03

1.6E-04

8.5E-03

4.2E-02

8.5E-02

0.17

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.12

1.2

6.0

-

2.2

11.1

22.2

44.5

Central Tendency

0.13

1.3

6.5

0.13

6.7

33.4

66.7

133.4

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

0.92

9.2

45.8

-

15.2

75.9

151.9

303.8

Central Tendency

0.99

9.9

49.5

0.99

45.6

227.8

455.6

911.3

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

6.9E-02

0.69

3.5

-

1.5

7.4

14.9

29.7

Central Tendency

7.5E-02

0.75

3.7

7.5E-02

4.5

22.3

44.6

89.2

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

0.53

5.3

26.4

-

6.3

31.3

62.6

125.1

Central Tendency

0.57

5.7

28.6

0.57

18.8

93.8

187.7

375.4

Kidney

(Maltoni et al.. 1986)

10

High End

1.5E-03

1.5E-02

7.3E-02

-

1.2E-02

5.9E-02

0.12

0.24

Central Tendency

1.6E-03

1.6E-02

7.9E-02

1.6E-03

3.6E-02

0.18

0.36

0.71

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.28

2.8

13.9

-

5.1

25.7

51.5

103.0

Central Tendency

0.30

3.0

15.1

0.30

15.4

77.2

154.4

308.9

Immunotoxicity
(Keil et al.. 2009)

30

High End

1.9E-03

1.9E-02

9.6E-02

-

3.8E-02

0.19

0.38

0.76

Central Tendency

2.1E-03

2.1E-02

0.10

2.1E-03

0.11

0.57

1.1

2.3

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

2.9E-02

0.29

1.5

-

0.58

2.9

5.8

11.6

Central Tendency

3.1E-02

0.31

1.6

3.1E-02

1.7

8.7

17.3

34.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

2.2E-04

2.2E-03

1.1E-02

-

4.1E-03

2.1E-02

4.1E-02

8.2E-02

Central Tendency

2.3E-04

2.3E-03

1.2E-02

2.3E-04

1.2E-02

6.2E-02

0.12

0.25

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.19

1.9E-02

3.9E-03

-

3.0E-02

6.0E-03

3.0E-03

1.5E-03

Central Tendency

0.14

1.4E-02

2.8E-03

0.14

7.8E-03

1.6E-03

7.8E-04

3.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

Page 307 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

829

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Modeling)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.3E-02

0.43

2.1

-

2.8E-03

1.4E-02

2.8E-02

5.6E-02

Central Tendency

0.16

1.6

7.9

0.16

8.5E-03

4.2E-02

8.5E-02

0.17

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

34.6

346.2

1,730.8

-

2.2

11.1

22.2

44.5

Central Tendency

128.6

1,285.7

6,428.6

128.6

6.7

33.4

66.7

133.4

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

265.4

2,653.8

13,269.2

-

15.2

75.9

151.9

303.8

Central Tendency

985.7

9,857.1

49,285.7

985.7

45.6

227.8

455.6

911.3

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

20.1

200.8

1,003.8

-

1.5

7.4

14.9

29.7

Central Tendency

74.6

745.7

3,728.6

74.6

4.5

22.3

44.6

89.2

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

151.7

1,516.7

7,583.3

-

6.3

31.3

62.6

125.1

Central Tendency

568.8

5,687.5

28,437.5

568.8

18.8

93.8

187.7

375.4

Kidney

(Maltoni et al.. 1986)

10

High End

0.42

4.2

20.8

-

1.2E-02

5.9E-02

0.12

0.24

Central Tendency

1.6

15.6

78.1

1.6

3.6E-02

0.18

0.36

0.71

Neurotoxicity
(Arito et al.. 1994)

300

High End

80.0

800.0

4,000.0

-

5.1

25.7

51.5

103.0

Central Tendency

300.0

3,000.0

15,000.0

300.0

15.4

77.2

154.4

308.9

Immunotoxicity
(Keil et al.. 2009)

30

High End

0.55

5.5

27.5

-

3.8E-02

0.19

0.38

0.76

Central Tendency

2.1

20.6

103.1

2.1

0.11

0.57

1.1

2.3

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

8.3

83.3

416.7

-

0.58

2.9

5.8

11.6

Central Tendency

31.3

312.5

1,562.5

31.3

1.7

8.7

17.3

34.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

6.2E-02

0.62

3.1

-

4.1E-03

2.1E-02

4.1E-02

8.2E-02

Central Tendency

0.23

2.3

11.6

0.23

1.2E-02

6.2E-02

0.12

0.25

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

6.6E-04

6.6E-05

1.3E-05

-

3.0E-02

6.0E-03

3.0E-03

1.5E-03

Central Tendency

1.3E-04

1.3E-05

2.6E-06

1.3E-04

7.8E-03

1.6E-03

7.8E-04

3.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

830

Page 308 of 748


-------
831

832

833

834

835

836

837

838

839

840

841

842

843

844

845

846

847

848

849

850

851

852

853

854

855

856

857

858

859

860

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE calculations for Metalworking Fluids utilized both monitoring and modeling inhalation exposure data (with dermal modeling). Results
are presented in Table 4-20 and Table 4-21.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints based on monitoring and for congenital heart defects based on modeling
at both high-end and central tendency exposure levels via inhalation. Based on both monitoring and modeling data, EPA is unable to estimate
ONU exposures separately from workers. Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE
for multiple endpoints via dermal exposure. MOEs remained below the benchmark MOE for multiple endpoints based on monitoring and for
congenital heart defects based on modeling at both exposure levels via inhalation and for congenital heart defects at both dermal exposure
levels even when assuming the highest plausible APF and glove PF protection based on monitoring data.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints based on monitoring and for multiple endpoints based on modeling at
both high-end and central tendency exposure levels via inhalation. Based on both monitoring and modeling data, EPA is unable to estimate
ONU exposures separately from workers. Based on both monitoring and modeling data, MOEs for workers were below the benchmark MOE
for all endpoints via dermal exposure. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection based on monitoring data. For modeling data,
MOEs were not below the benchmark MOE at central tendency exposure level when assuming APF = 50, although MOEs were below the
benchmark MOE for multiple endpoints via the dermal route even when assuming the highest plausible glove PF protection.

Cancer Risk Estimates:

Based on both monitoring and modeling data, extra risk estimates for workers were above the benchmark level for cancer at both high-end
and central tendency exposure levels via both inhalation and dermal routes. Based on both monitoring and modeling data, EPA is unable to
estimate ONU exposures separately from workers. Risk estimates remained above the benchmark for cancer at both exposure levels via
dermal and inhalation routes even when assuming the highest plausible APF and glove PF protection based on monitoring data. For modeling
data, risk estimates were not above the benchmark at either inhalation exposure level when assuming APF = 10, although risk estimates were
above the benchmark via the dermal route even when assuming the highest plausible glove PF protection.

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861

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

2.8E-04

2.8E-03

1.4E-02

1.1E-02

2.5E-03

1.3E-02

2.5E-02

5.0E-02

Central Tendency

2.4E-03

2.4E-02

0.12

1.2E-02

7.5E-03

3.8E-02

7.5E-02

0.15

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.23

2.3

11.4

9.0

2.0

9.9

19.8

39.5

Central Tendency

1.9

19.4

97.1

9.6

5.9

29.7

59.3

118.6

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

1.7

17.5

87.4

69.0

13.5

67.5

135.0

270.0

Central Tendency

14.9

148.8

744.1

73.3

40.5

202.5

405.0

810.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.13

1.3

6.6

5.2

1.3

6.6

13.2

26.4

Central Tendency

1.1

11.3

56.3

5.5

4.0

19.8

39.6

79.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

1.0

10.1

50.5

39.9

5.6

27.8

55.6

111.2

Central Tendency

8.6

86.0

429.9

42.4

16.7

83.4

166.8

333.7

Kidney

(Maltoni et al.. 1986)

10

High End

2.8E-03

2.8E-02

0.14

0.11

1.1E-02

5.3E-02

0.11

0.21

Central Tendency

2.4E-02

0.24

1.2

0.12

3.2E-02

0.16

0.32

0.63

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.53

5.3

26.6

21.0

4.6

22.9

45.8

91.5

Central Tendency

4.5

45.3

226.7

22.3

13.7

68.6

137.3

274.5

Immunotoxicity
(Keil et al.. 2009)

30

High End

3.7E-03

3.7E-02

0.18

0.14

3.4E-02

0.17

0.34

0.68

Central Tendency

3.1E-02

0.31

1.6

0.15

0.10

0.51

1.0

2.0

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

5.5E-02

0.55

2.8

2.2

0.51

2.6

5.1

10.3

Central Tendency

0.47

4.7

23.6

2.3

1.5

7.7

15.4

30.8

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

4.1E-04

4.1E-03

2.1E-02

1.6E-02

3.7E-03

1.8E-02

3.7E-02

7.3E-02

Central Tendency

3.5E-03

3.5E-02

0.17

1.7E-02

1.1E-02

5.5E-02

0.11

0.22

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.10

1.0E-02

2.0E-03

2.6E-03

3.4E-02

6.8E-03

3.4E-03

1.7E-03

Central Tendency

9.3E-03

9.3E-04

1.9E-04

1.9E-03

8.7E-03

1.7E-03

8.7E-04

4.4E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

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862

863

864

865

866

867

868

869

870

871

872

873

874

875

876

877

878

879

880

881

882

883

884

885

886

887

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Adhesives, Sealants, Paints, and Coatings (Industrial Setting) utilized monitoring inhalation exposure data (with dermal
modeling) and are presented in Table 4-22. Inhalation exposures are estimated to be identical for industrial and commercial workers.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via inhalation
and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central tendency
inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both inhalation exposure levels even when
assuming the highest plausible APF. MOEs remained below the benchmark MOE for congenital heart defects at both dermal exposure levels
even when assuming the highest plausible glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at both high-end and central tendency
inhalation exposure levels. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

888

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

2.8E-04

2.8E-03

1.4E-02

1.1E-02

1.6E-03

8.0E-03

1.6E-02

N/A1

Central Tendency

2.4E-03

2.4E-02

0.12

1.2E-02

4.8E-03

2.4E-02

4.8E-02

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.23

2.3

11.4

9.0

1.3

6.3

12.6

Central Tendency

1.9

19.4

97.1

9.6

3.8

18.9

37.8

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

1.7

17.5

87.4

69.0

8.6

43.0

86.0

Central Tendency

14.9

148.8

744.1

73.3

25.8

129.0

258.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.13

1.3

6.6

5.2

0.84

4.2

8.4

Central Tendency

1.1

11.3

56.3

5.5

2.5

12.6

25.2

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

1.0

10.1

50.5

39.9

3.5

17.7

35.4

N/A1

Central Tendency

8.6

86.0

429.9

42.4

10.6

53.1

106.3

Kidney

(Maltoni et al.. 1986)

10

High End

2.8E-03

2.8E-02

0.14

0.11

6.7E-03

3.4E-02

6.7E-02

Central Tendency

2.4E-02

0.24

1.2

0.12

2.0E-02

0.10

0.20

Neurotoxicity
(Arito et al.. 1994)

300

High End

0.53

5.3

26.6

21.0

2.9

14.6

29.1

Central Tendency

4.5

45.3

226.7

22.3

8.7

43.7

87.4

Immunotoxicity
(Keil et al.. 2009)

30

High End

3.7E-03

3.7E-02

0.18

0.14

2.2E-02

0.11

0.22

Central Tendency

3.1E-02

0.31

1.6

0.15

6.5E-02

0.32

0.65

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

5.5E-02

0.55

2.8

2.2

0.33

1.6

3.3

Central Tendency

0.47

4.7

23.6

2.3

0.98

4.9

9.8

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

4.1E-04

4.1E-03

2.1E-02

1.6E-02

2.3E-03

1.2E-02

2.3E-02

Central Tendency

3.5E-03

3.5E-02

0.17

1.7E-02

7.0E-03

3.5E-02

7.0E-02

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

0.10

1.0E-02

2.0E-03

2.6E-03

5.3E-02

1.1E-02

5.3E-03

N/A1

Central Tendency

9.3E-03

9.3E-04

1.9E-04

1.9E-03

1.4E-02

2.7E-03

1.4E-03

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario under a rigorous PPE program.
1 Glove PF =20 is only applicable to industrial settings (See Section 2.3.1).

889

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890

891

892

893

894

895

896

897

898

899

900

901

902

903

904

905

906

907

908

909

910

911

912

913

914

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Adhesives, Sealants, Paints, and Coatings (Commercial Setting) utilized monitoring inhalation exposure data (with dermal
modeling) and are presented in Table 4-23. Inhalation exposures are estimated to be identical for industrial and commercial settings.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at both high-end and central tendency
inhalation exposure levels. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

915

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

5.8E-04

5.8E-03

2.9E-02

2.5E-03

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

1.7E-03

1.7E-02

8.7E-02

5.6E-03

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

0.47

4.7

23.4

2.1

1.8

8.9

17.8

35.6

Central Tendency

1.4

14.1

70.6

4.6

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

3.6

35.9

179.6

15.8

12.2

60.8

121.5

243.0

Central Tendency

10.8

108.2

540.9

35.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

0.27

2.7

13.6

1.2

1.2

5.9

11.9

23.8

Central Tendency

0.82

8.2

40.9

2.7

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

2.1

20.7

103.7

9.2

5.0

25.0

50.1

100.1

Central Tendency

6.2

62.5

312.5

20.3

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

5.7E-03

5.7E-02

0.28

2.5E-02

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

1.7E-02

0.17

0.86

5.6E-02

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

1.1

10.9

54.7

4.8

4.1

20.6

41.2

82.4

Central Tendency

3.3

33.0

164.8

10.7

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

7.5E-03

7.5E-02

0.38

3.3E-02

3.0E-02

0.15

0.30

0.61

Central Tendency

2.3E-02

0.23

1.1

7.3E-02

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.11

1.1

5.7

0.50

0.46

2.3

4.6

9.2

Central Tendency

0.34

3.4

17.2

1.1

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

8.4E-04

8.4E-03

4.2E-02

3.7E-03

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

2.5E-03

2.5E-02

0.13

8.2E-03

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

4.9E-02

4.9E-03

9.9E-04

1.1E-02

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

1.3E-02

1.3E-03

2.5E-04

3.9E-03

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.

916

917

Page 314 of 748


-------
918

919

920

921

922

923

924

925

926

927

928

929

930

931

932

933

934

935

936

937

938

939

940

941

942

943

944

945

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Industrial Processing Aid utilized 12hr monitoring inhalation exposure data (with dermal modeling) and are presented in
Table 4-24.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for most endpoints at both high-end and central tendency exposure levels via inhalation
and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central tendency
inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both inhalation exposure levels even when
assuming the highest plausible APF. MOEs remained below the benchmark MOE for congenital heart defects at both dermal exposure levels
even when assuming the highest plausible glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for all endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. MOEs for ONUs were also below the benchmark MOE for multiple endpoints at both high-end and central
tendency inhalation exposure levels. MOEs remained below the benchmark MOE for multiple endpoints at both exposure levels via dermal
and inhalation routes even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. Risk estimates for ONUs were also above the benchmark for cancer at both high-end and central tendency
inhalation exposure levels. Risk estimates remained above the benchmark for cancer at both exposure levels via dermal and inhalation routes
even when assuming the highest plausible APF and glove PF protection.

Page 315 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

946

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

5.3E-03

5.3E-02

0.26

-

4.1E-03

2.1E-02

4.1E-02

NA2

Central Tendency

0.13

1.3

6.5

0.13

1.2E-02

6.2E-02

0.12

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

4.3

42.9

214.7

-

3.2

16.2

32.4

Central Tendency

105.9

1,058.8

5,294.1

105.9

9.7

48.6

97.1

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

32.9

329.3

1,646.4

-

22.1

110.6

221.1

Central Tendency

811.8

8,117.6

40,588.2

811.8

66.3

331.7

663.4

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

30

High End

2.5

24.9

124.6

-

2.2

10.8

21.6

Central Tendency

61.4

614.1

3,070.6

61.4

6.5

32.5

64.9

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

19.0

190.2

951.0

-

9.1

45.5

91.1

NA2

Central Tendency

468.9

4,689.2

23,445.9

468.9

27.3

136.6

273.3

Kidney

(Maltoni et al.. 1986)

10

High End

5.2E-02

0.52

2.6

-

1.7E-02

8.6E-02

0.17

Central Tendency

1.3

12.9

64.4

1.3

5.2E-02

0.26

0.52

Neurotoxicity
(Arito et al.. 1994)

300

High End

10.0

100.3

501.6

-

7.5

37.5

74.9

Central Tendency

247.3

2,473.4

12,367.1

247.3

22.5

112.4

224.8

Immunotoxicity
(Keil et al.. 2009)

30

High End

6.9E-02

0.69

3.4

-

5.5E-02

0.28

0.55

Central Tendency

1.7

17.0

85.0

1.7

0.17

0.83

1.7

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

1.0

10.5

52.3

-

0.84

4.2

8.4

Central Tendency

25.8

257.6

1,288.2

25.8

2.5

12.6

25.2

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

7.7E-03

7.7E-02

0.39

-

6.0E-03

3.0E-02

6.0E-02

Central Tendency

0.19

1.9

9.5

0.19

1.8E-02

9.0E-02

0.18

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

5.4E-03

5.4E-04

1.1E-04

-

2.1E-02

4.1E-03

2.1E-03

NA2

Central Tendency

1.7E-04

1.7E-05

3.4E-06

1.7E-04

5.3E-03

1.1E-03

5.3E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario under a rigorous PPE program.

1	EPA is unable to estimate ONU exposures separately from workers.

2	Glove PF =20 is only applicable to industrial settings (See Section 2.3.1).

947

Page 316 of 748


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948

949

950

951

952

953

954

955

956

957

958

959

960

961

962

963

964

965

966

967

968

969

970

971

972

973

974

975

976

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Commercial Printing and Copying utilized monitoring inhalation exposure data (with dermal modeling) and are presented in
Table 4-25.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE congenital heart defects at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for congenital heart defects via inhalation and for multiple endpoints via dermal exposure at both exposure levels even when assuming
the highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via
inhalation and for all endpoints via the dermal route. EPA is unable to estimate ONU exposures separately from workers. MOEs remained
below the benchmark MOE for congenital heart defects via inhalation and for multiple endpoints via dermal exposure at both exposure levels
even when assuming the highest plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. Risk estimates remained above the
benchmark at high-end inhalation exposure but were not above the benchmark at central tendency inhalation exposure when assuming APF =
10. Risk estimates remained above the benchmark at both dermal exposure levels even when assuming the highest plausible glove PF
protection.

PPE Considerations

EPA is presenting risk estimates for respiratory protection up to APF = 50 as a what-if scenario, however EPA believes that small commercial
facilities performing commercial printing and copying are unlikely to have a respiratory protection program. Therefore, the use of respirators is
unlikely for workers in these facilities.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

977

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF= 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

4.3E-03

4.3E-02

0.21

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

3.0E-02

0.30

1.5

3.0E-02

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

3.5

34.8

173.9

-

1.8

8.9

17.8

35.6

Central Tendency

24.0

239.9

1,199.4

24.0

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

26.7

266.6

1,333.0

-

12.2

60.8

121.5

243.0

Central Tendency

183.9

1,839.1

9,195.6

183.9

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

100

High End

2.0

20.2

100.8

-

1.2

5.9

11.9

23.8

Central Tendency

13.9

139.1

695.7

13.9

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

15.4

154.0

770.0

-

5.0

25.0

50.1

100.1

Central Tendency

106.2

1,062.4

5,311.8

106.2

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

4.2E-02

0.42

2.1

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

0.29

2.9

14.6

0.29

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

8.1

81.2

406.2

-

4.1

20.6

41.2

82.4

Central Tendency

56.0

560.4

2,801.8

56.0

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

5.6E-02

0.56

2.8

-

3.0E-02

0.15

0.30

0.61

Central Tendency

0.39

3.9

19.3

0.39

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

0.85

8.5

42.3

-

0.46

2.3

4.6

9.2

Central Tendency

5.8

58.4

291.9

5.8

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

6.3E-03

6.3E-02

0.31

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

4.3E-02

0.43

2.2

4.3E-02

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

6.7E-03

6.7E-04

1.3E-04

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

7.5E-04

7.5E-05

1.5E-05

7.5E-04

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

Page 318 of 748


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978

979

980

981

982

983

984

985

986

987

988

989

990

991

992

993

994

995

996

997

998

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Other Industrial Uses utilized monitoring inhalation exposure data (with dermal modeling) and are presented in Table 4-26.
Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. MOEs remained below the benchmark
MOE for congenital heart defects at both exposure levels via dermal and inhalation routes even when assuming the highest plausible APF and
glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at both high-end and central tendency exposure levels via
inhalation and for all endpoints via the dermal route. EPA is unable to estimate ONU exposures separately from workers. MOEs remained
below the benchmark MOE for multiple endpoints at both exposure levels via dermal and inhalation routes even when assuming the highest
plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at both high-end and central tendency exposure levels via both
inhalation and dermal routes. EPA is unable to estimate ONU exposures separately from workers. Risk estimates remained above the
benchmark at high-end inhalation exposure but were not above the benchmark at central tendency inhalation exposure when assuming APF =
10. Risk estimates remained above the benchmark at both dermal exposure levels even when assuming the highest plausible glove PF.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

999

Endpoint

Benchmark
MOE

Exposure Level

Inhalation (Monitoring)

Dermal (Modeling)

No PPE
Worker MOE

APF = 10
Worker MOE

APF = 50
Worker MOE

No PPE
ONU MOE1

No PPE
Worker MOE

Glove PF=5
Worker MOE

Glove PF=10
Worker MOE

Glove PF=20
Worker MOE

ACUTE NON-CANCER

Developmental -
Congenital Heart Defects
(¦Johnson et al.. 2003)

10

High End

9.7E-03

9.7E-02

0.49

-

2.3E-03

1.1E-02

2.3E-02

4.5E-02

Central Tendency

22.4

224.3

1,121.3

22.4

6.8E-03

3.4E-02

6.8E-02

0.14

Developmental -
Neurotoxicity
(Fredriksson et al.. 1993)

100

High End

7.9

78.9

394.7

-

1.8

8.9

17.8

35.6

Central Tendency

18,182.7

181,827.5

909,137.3

18,182.7

5.3

26.7

53.4

106.7

Developmental -
Mortality

(Narotskv et al.. 1995)

10

High End

60.5

605.3

3,026.3

-

12.2

60.8

121.5

243.0

Central Tendency

139,401.1

1,394,010.5

6,970,052.6

139,401.1

36.5

182.3

364.5

729.0

Immunotoxicity -
Immunosuppression
(Selarade and Gilmour. 2010)

100

High End

4.6

45.8

228.9

-

1.2

5.9

11.9

23.8

Central Tendency

10,546.0

105,459.9

527,299.6

10,546.0

3.6

17.8

35.7

71.3

CHRONIC NON-CANCER

Liver

(Kiellstrand et al.. 1983)

10

High End

35.0

349.6

1,748.2

-

5.0

25.0

50.1

100.1

Central Tendency

80,525.3

805,253.2

4,026,266.0

80,525.3

15.0

75.1

150.2

300.3

Kidney

(Maltoni et al.. 1986)

10

High End

9.6E-02

0.96

4.8

-

9.5E-03

4.8E-02

9.5E-02

0.19

Central Tendency

221.2

2,212.2

11,061.2

221.2

2.9E-02

0.14

0.29

0.57

Neurotoxicity
(Arito et al.. 1994)

300

High End

18.4

184.4

922.1

-

4.1

20.6

41.2

82.4

Central Tendency

42,474.9

424,748.9

2,123,744.7

42,474.9

12.4

61.8

123.5

247.1

Immunotoxicity
(Keil et al.. 2009)

30

High End

0.13

1.3

6.3

-

3.0E-02

0.15

0.30

0.61

Central Tendency

292.0

2,920.1

14,600.7

292.0

9.1E-02

0.46

0.91

1.8

Reproductive Toxicity
(Cilia etal.. 1996)

30

High End

1.9

19.2

96.1

-

0.46

2.3

4.6

9.2

Central Tendency

4,424.5

44,244.7

221,223.4

4,424.5

1.4

6.9

13.9

27.7

Developmental Toxicity
(Johnson et al.. 2003)

10

High End

1.4E-02

0.14

0.71

-

3.3E-03

1.6E-02

3.3E-02

6.6E-02

Central Tendency

32.7

327.4

1,637.1

32.7

9.9E-03

4.9E-02

9.9E-02

0.20

LIFETIME CANCER RISK

Combined Cancer Risk -
Kidney, NHL, Liver

1 x 10"4

High End

2.9E-03

2.9E-04

5.9E-05

-

3.8E-02

7.5E-03

3.8E-03

1.9E-03

Central Tendency

9.9E-07

9.9E-08

2.0E-08

9.9E-07

9.7E-03

1.9E-03

9.7E-04

4.9E-04

Bold text/pink shading indicates MOE < benchmark MOE. The highest PPE scenarios displayed are plausible for this exposure scenario.
1 EPA is unable to estimate ONU exposures separately from workers.

Page 320 of 748


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1000

1001

1002

1003

1004

1005

1006

1007

1008

1009

1010

1011

1012

1013

1014

1015

1016

1017

1018

1019

1020

1021

1022

1023

1024

1025

1026

1027

1028

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

MOE results for Process Solvent Recycling and Worker Handling of Wastes utilized monitoring inhalation exposure data (with dermal
modeling) and are presented in Table 4-27.

Acute Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for congenital heart defects at high-end inhalation exposure and at both dermal exposure levels even when assuming the
highest plausible APF and glove PF protection.

Chronic Non-Cancer Risk Estimates:

MOEs for workers were below the benchmark MOE for multiple endpoints at high-end inhalation exposures, but MOEs were above the
benchmark MOE for all endpoints at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from
workers. MOEs were below the benchmark MOE for multiple endpoints at both dermal exposure levels. MOEs remained below the
benchmark MOE for multiple endpoints at high-end inhalation exposure and at both dermal exposure levels even when assuming the highest
plausible APF and glove PF protection.

Cancer Risk Estimates:

Extra risk estimates for workers were above the benchmark level for cancer at at high-end inhalation exposures, but risk estimates were above
the benchmark MOE for cancer at central tendency inhalation exposures. EPA is unable to estimate ONU exposures separately from workers.
Risk estimates were not above the benchmark at central tendency inhalation exposure when assuming APF = 50. Risk estimates remained
above the benchmark at both dermal exposure levels even when assuming the highest plausible glove PF protection.

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1029

1030

1031

1032

1033

1034

1035

1036

1037

1038

1039

1040

1041

1042

1043

1044

1045

1046

1047

1048

1049

1050

1051

1052

1053

1054

1055

1056

1057

1058

1059

1060

1061

1062

1063

1064

1065

1066

1067

1068

1069

1070

1071

1072

1073

1074

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

4.2.3 Risk Estimation for Consumer Exposures by Exposure Scenario

Risk estimates via inhalation and dermal routes are provided below for consumers and bystanders
following acute exposure. Risk estimates were presented for differing exposure assumptions,
categorized as high, moderate, or low intensity users based on variation in weight fraction, mass of
product used, and duration of use/exposure duration. Risk estimates primarily utilized central tendency
values for other modeling parameters (e.g., room volume, air exchange rate, building volume) and
therefore do not necessarily represent an upper bound of possible exposures. See Section 2.3.2.6.1 for
more details on the characterization of consumer exposure and [CEMModeling Results and Risk
Estimates. Docket # EPA-HQ-OPPT-2019-0500] for MOE estimates of all modeled scenarios.

As discussed in Section 2.3.2.2, in general, the frequency of product use was considered to be too low to
create chronic risk concerns. Although high-end frequencies of consumer use are up to 50 times per
year, available toxicological data is based on either single or continuous TCE exposure and it is
unknown whether these use patterns are expected to be clustered or intermittent (e.g. one time per
week). There is uncertainty regarding the extrapolation from continuous studies in animals to the case of
repeated, intermittent human exposures. Therefore, EPA cannot fully rule out that consumers at the high-
end frequency of use could possibly be at risk for chronic hazard effects, however it is expected to be
unlikely. Therefore, based on reasonably available information, EPA did not develop risk estimates for
this population.

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1075	Table 4-28. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Brake and Parts

1076	Cleaner

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al.. 1993)

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.



2010)

Inhalation Exposure

High-
Intensity
User

User

6.4E-05

5.2E-02

0.40

3.5E-02

Bystander

2.2E-04

1.8E-01

1.4

0.14

Moderate-
Intensity
User

User

4.1E-04

0.33

2.5

0.21

Bystander

1.6E-03

1.3

10

0.94

Low-
Intensity
User

User

5.2E-03

4.2

32

2.7

Bystander

2.0E-02

17

127

12

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

6.8E-05

5.4E-02

0.37

3.6E-02

Children (16-20 years)

7.3E-05

5.7E-02

0.39

3.8E-02

Children (11-15 years)

6.7E-05

5.3E-02

0.36

3.5E-02

Moderate-
Intensity
User

Adult (>21 years)

9.1E-04

0.72

4.9

0.48

Children (16-20 years)

9.7E-04

0.77

5.2

0.51

Children (11-15 years)

8.9E-04

0.70

4.8

0.47

Low-
Intensity
User

Adult (>21 years)

4.1E-02

32

220

22

Children (16-20 years)

4.4E-02

34

235

23

Children (11-15 years)

4.0E-02

32

215

21

1077

1078	MOE results for Brake and Parts Cleaner are presented in Table 4-28.

1079

1080	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1081	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1082	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1083	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1084	levels.

Page 323 of 748


-------
1085

1086

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
Table 4-29. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al.. 19931

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.
2010)

Inhalation Exposure

High-
Intensity
User

User

9.8E-05

8.0E-02

0.61

5.0E-02

Bystander

4.9E-04

0.40

3.0

0.28

Moderate-
Intensity
User

User

2.3E-03

1.9

15

1.2

Bystander

1.3E-02

10

78

7.1

Low-
Intensity
User

User

6.7E-02

54

414

33

Bystander

0.34

277

2123

193

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1087

1088

1089

1090

1091

1092

1093

1094

1095

1096

1097

1098

1099

1100

1101

1102

MOE results for Aerosol Electronic Degreaser Cleaner are presented in Table 4-29.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for congenital heart defects at high, medium, and low-intensity user
inhalation exposure levels and for multiple endpoints at high and medium-intensity exposure levels.

Page 324 of 748


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1103	Table 4-30. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid Electronic

1104	Degreaser/Cleaner	

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

1.0E-04

8.3E-02

0.64

5.2E-02

Bystander

5.1E-04

0.41

3.2

0.29

Moderate-
Intensity
User

User

1.6E-03

1.3

9.9

0.79

Bystander

8.5E-03

6.9

53

4.8

Low-
Intensity
User

User

2.1E-02

17

132

11

Bystander

0.11

88

674

61

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

1.2E-04

9.5E-03

0.65

6.4E-02

Children (16-20 years)

1.3E-04

0.10

0.70

6.8E-02

Children (11-15 years)

1.2E-04

9.3E-02

0.64

6.2E-02

Moderate-
Intensity
User

Adult (>21 years)

1.8E-03

1.4

9.7

9.5E-01

Children (16-20 years)

1.9E-03

1.5

10

1.0

Children (11-15 years)

1.8E-03

1.4

9.6

9.4E-01

Low-
Intensity
User

Adult (>21 years)

7.3E-03

5.7

39

3.8

Children (16-20 years)

7.8E-03

6.1

42

4.1

Children (11-15 years)

7.1E-03

5.6

38

3.7

1105

1106	MOE results for Liquid Electronic Degreaser/Cleaner are presented in Table 4-30.

1107

1108	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1109	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1110	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1111	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1112	levels.

1113

Page 325 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1114 Table 4-31. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol Spray

5 Degreaser/Cleaner





Benchmark





10

100

10

30

Scenario

Consumer
Receptor

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.





1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

2.3E-05

1.8E-02

0.14

1.2E-02

Bystander

7.9E-05

6.4E-02

0.49

4.9E-02

Moderate-
Intensity
User

User

9.0E-05

7.3E-02

0.56

4.6E-02

Bystander

3.6E-04

0.29

2.2

0.21

Low-
Intensity
User

User

6.0E-04

0.48

3.7

0.31

Bystander

2.5E-03

2.0

15

1.4

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

7.3E-05

5.7E-02

0.39

3.8E-02

Children (16-20 years)

7.8E-05

6.1E-02

0.42

4.1E-02

Children (11-15 years)

7.1E-05

5.6E-02

0.38

3.7E-02

Moderate-
Intensity
User

Adult (>21 years)

5.8E-04

0.46

3.1

0.31

Children (16-20 years)

6.2E-04

0.49

3.3

0.33

Children (11-15 years)

5.7E-04

0.45

3.1

0.30

Low-
Intensity
User

Adult (>21 years)

2.9E-03

2.3

16

1.5

Children (16-20 years)

3.1E-03

2.4

17

1.6

Children (11-15 years)

2.8E-03

2.2

15

1.5

6

1117	MOE results for Aerosol Spray Degi'eciser Cleaner are presented in Table 4-31.

1118

1119	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1120	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1121	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1122	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1123	levels.

1124

Page 326 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1125	Table 4-32. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid

1126	Degreaser/Cleaner	

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

2.5E-05

2.0E-02

0.16

1.3E-02

Bystander

1.0E-04

8.3E-02

0.64

6.1E-02

Moderate-
Intensity
User

User

2.4E-04

0.19

1.5

0.12

Bystander

1.2E-03

1.0

7.8

0.70

Low-
Intensity
User

User

1.4E-03

1.2

8.8

0.71

Bystander

7.6E-03

6.2

47

4.3

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

3.0E-05

2.4E-02

0.16

1.6E-02

Children (16-20 years)

3.2E-05

2.6E-02

0.17

1.7E-02

Children (11-15 years)

3.0E-05

2.3E-02

0.16

1.6E-02

Moderate-
Intensity
User

Adult (>21 years)

2.4E-04

0.19

1.3

0.13

Children (16-20 years)

2.6E-04

0.20

1.4

0.14

Children (11-15 years)

2.4E-04

0.19

1.3

0.13

Low-
Intensity
User

Adult (>21 years)

1.8E-03

1.4

9.8

0.96

Children (16-20 years)

1.9E-03

1.5

10

1.0

Children (11-15 years)

1.8E-03

1.4

9.6

0.94

1127

1128	MOE results for Liquid Degreaser/Cleaner are presented in Table 4-32.

1129

1130	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1131	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1132	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1133	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1134	levels.

1135

Page 327 of 748


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1136	Table 4-33. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol Gun

1137	Scrubber

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

5.0E-02

40

309

26

Bystander

0.20

164

1255

120

Moderate-
Intensity
User

User

4.7E-02

38

294

24

Bystander

0.25

202

1551

141

Low-
Intensity
User

User

8.1E-02

66

506

41

Bystander

0.44

354

2715

247

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

7.5E-05

5.9E-02

0.41

4.0E-02

Children (16-20 years)

8.1E-05

6.4E-02

0.43

4.2E-02

Children (11-15 years)

7.4E-05

5.8E-02

0.40

3.9E-02

Moderate-
Intensity
User

Adult (>21 years)

6.0E-04

0.48

3.2

0.32

Children (16-20 years)

6.4E-04

0.51

3.5

0.34

Children (11-15 years)

5.9E-04

0.46

3.2

0.31

Low-
Intensity
User

Adult (>21 years)

7.5E-03

5.9

41

4.0

Children (16-20 years)

8.0E-03

6.3

43

4.2

Children (11-15 years)

7.3E-03

5.8

40

3.9

1138

1139	MOE results for Aerosol Gun Scrubber are presented in Table 4-33.

1140

1141	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1142	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1143	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1144	benchmark MOE for congenital heart defects at high, medium, and low-intensity user inhalation

1145	exposure levels.

Page 328 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1146 Table 4-34. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid Gun

7 Scrubber





Benchmark





10

100

10

30

Scenario

Consumer
Receptor

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.





1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

5.8E-02

47

361

30

Bystander

0.24

191

1465

140

Moderate-
Intensity
User

User

5.5E-02

45

343

28

Bystander

0.29

236

1809

164

Low-
Intensity
User

User

5.9E-02

48

370

30

Bystander

0.30

247

1893

172

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

3.3E-05

2.6E-02

0.18

1.7E-02

Children (16-20 years)

3.5E-05

2.7E-02

0.19

1.8E-02

Children (11-15 years)

3.2E-05

2.5E-02

0.17

1.7E-02

Moderate-
Intensity
User

Adult (>21 years)

2.6E-04

0.21

1.4

0.14

Children (16-20 years)

2.8E-04

0.22

1.5

0.15

Children (11-15 years)

2.5E-04

0.20

1.4

0.13

Low-
Intensity
User

Adult (>21 years)

1.9E-03

1.5

10

1.0

Children (16-20 years)

2.1E-03

1.6

11

1.1

Children (11-15 years)

1.9E-03

1.5

10

1.0

48

1149	MOE results for Liquid Gun Scrubber are presented in Table 4-34.

1150

1151	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1152	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1153	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1154	benchmark MOE for congenital heart defects at high, medium, and low-intensity user inhalation

1155	exposure levels.

1156

1157

1158

Page 329 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

2.3E-04

0.18

1.4

0.11

Bystander

1.1E-03

0.91

7.0

0.64

Moderate-
Intensity
User

User

2.1E-03

1.7

13

1.1

Bystander

1.1E-02

9.2

71

6.4

Low-
Intensity
User

User

2.1E-02

17

130

11

Bystander

0.11

87

667

61

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1160

1161

1162

1163

1164

1165

1166

1167

1168

MOE results for Mold Release are presented in Table 4-35.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user
inhalation exposure levels.

Page 330 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1169	Table 4-36. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Aerosol Tire

1170	Cleaner

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

2.4E-04

0.19

1.5

0.13

Bystander

5.4E-04

0.44

3.4

0.32

Moderate-
Intensity
User

User

8.9E-04

0.72

5.5

0.46

Bystander

3.6E-03

2.9

22

2.0

Low-
Intensity
User

User

6.4E-03

5.2

40

3.3

Bystander

2.6E-02

21

164

15

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

3.3E-04

0.26

1.8

0.17

Children (16-20 years)

3.5E-04

0.28

1.9

0.19

Children (11-15 years)

3.2E-04

0.26

1.7

0.17

Moderate-
Intensity
User

Adult (>21 years)

1.3E-03

1.0

7.1

0.70

Children (16-20 years)

1.4E-03

1.1

7.6

0.74

Children (11-15 years)

1.3E-03

1.0

6.9

0.68

Low-
Intensity
User

Adult (>21 years)

5.7E-03

4.5

31

3.0

Children (16-20 years)

6.0E-03

4.8

33

3.2

Children (11-15 years)

5.5E-03

4.4

30

2.9

1171

1172	MOE results for Aerosol Tire Cleaner are presented in Table 4-36.

1173

1174	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1175	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1176	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1177	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1178	levels.

1179

Page 331 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1180	Table 4-37. Consumer Risk Estimation - Solvents for Cleaning and Degreasing - Liquid Tire

1181	Cleaner

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

7.8E-05

6.3E-02

0.48

4.2E-02

Bystander

2.4E-04

0.20

1.5

0.14

Moderate-
Intensity
User

User

4.0E-04

0.32

2.5

0.21

Bystander

1.6E-03

1.3

9.9

0.92

Low-
Intensity
User

User

2.0E-03

1.6

12

1.0

Bystander

8.3E-03

6.7

51

4.7

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

5.9E-05

4.7E-02

0.32

3.1E-02

Children (16-20 years)

6.3E-05

5.0E-02

0.34

3.3E-02

Children (11-15 years)

5.8E-05

4.6E-02

0.31

3.0E-02

Moderate-
Intensity
User

Adult (>21 years)

2.4E-04

0.19

1.3

0.12

Children (16-20 years)

2.5E-04

0.20

1.4

0.13

Children (11-15 years)

2.3E-04

0.18

1.2

0.12

Low-
Intensity
User

Adult (>21 years)

7.1E-04

0.56

3.8

0.37

Children (16-20 years)

7.6E-04

0.60

4.1

0.40

Children (11-15 years)

6.9E-04

0.55

3.7

0.37

1182

1183	MOE results for Liquid Tire Cleaner are presented in Table 4-37.

1184

1185	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1186	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1187	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1188	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1189	levels.

1190

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Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

2.5E-04

0.20

1.6

0.13

Bystander

1.3E-03

1.0

7.8

0.71

Moderate-
Intensity
User

User

2.4E-03

1.9

15

1.2

Bystander

1.3E-02

10

79

7.1

Low-
Intensity
User

User

1.3E-02

11

83

6.8

Bystander

4.3E-02

35

270

28

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1192

1193

1194

1195

1196

1197

1198

1199

MOE results for Tap and Die Fluid are presented in Table 4-38.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user
inhalation exposure levels.

Page 333 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

0 Table 4-39. Consumer I

lisk Estimation - Lubricants and Greases - Penetrating Lubricant

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

3.2E-04

0.26

2.0

0.16

Bystander

1.6E-03

1.3

9.8

0.89

Moderate-
Intensity
User

User

5.4E-03

4.4

33

2.7

Bystander

2.9E-02

23

179

16

Low-
Intensity
User

User

0.17

139

1065

86

Bystander

0.88

712

5460

496

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is



1202	MOE results for Penetrating Lubricant are presented in Table 4-39.

1203

1204	MOEs for consumer users were below the benchmark MOE for congenital heart defects at high,

1205	medium, and low-intensity inhalation exposure levels and for multiple endpoints at high and medium-

1206	intensity exposure levels. Dermal exposure was not quantified. MOEs for bystanders were below the

1207	benchmark MOE for multiple endpoints for high and medium-intensity users and for congenital heart

1208	defects at all user intensity inhalation exposure levels.

1209

Page 334 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1210 Table 4-40. Consumer Risk Estimation - Adhesives and Sealants - Solvent-Based Adhesive and

Sealant

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

1.1E-04

9.3E-02

0.71

5.6E-02

Bystander

9.1E-04

0.74

5.7

0.52

Moderate-
Intensity
User

User

3.7E-03

3.0

23

1.8

Bystander

3.6E-02

29

223

20

Low-
Intensity
User

User

0.42

340

2604

207

Bystander

2.8

2300

17636

1602

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1212

1213	MOE results for Solvent-Based Adhesive and Sealant are presented in Table 4-40.

1214

1215	MOEs for consumer users were below the benchmark MOE for congenital heart defects at high,

1216	medium, and low-intensity inhalation exposure levels and for multiple endpoints at high and medium-

1217	intensity exposure levels. Dermal exposure was not quantified. MOEs for bystanders were below the

1218	benchmark MOE for multiple endpoints for high and medium-intensity users and for congenital heart

1219	defects at all user intensity inhalation exposure levels.

1220

Page 335 of 748


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Table 4-41. Consumer I

lisk Estimation - Adhesives and Sealants - Mirror Edge Sealant

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

1.1E-03

0.90

6.9

0.57

Bystander

4.7E-03

3.8

29

2.7

Moderate-
Intensity
User

User

3.3E-03

2.7

21

1.7

Bystander

1.8E-02

15

114

10

Low-
Intensity
User

User

0.17

134

1028

83

Bystander

0.91

737

5651

513

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1222

1223	MOE results for Mirror Edge Sealant are presented in Table 4-41.

1224

1225	MOEs for consumer users were below the benchmark MOE for congenital heart defects at high,

1226	medium, and low-intensity inhalation exposure levels and for multiple endpoints at high and medium-

1227	intensity exposure levels. Dermal exposure was not quantified. MOEs for bystanders were below the

1228	benchmark MOE for multiple endpoints for high and medium-intensity users and for congenital heart

1229	defects at all user intensity inhalation exposure levels.

1230

Page 336 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Table 4-42. Consumer I

lisk Estimation - Adhesives and Sealants - Tire Repair Cement / Sealer

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

3.1E-04

0.25

1.9

0.17

Bystander

9.7E-04

0.79

6.1

0.57

Moderate-
Intensity
User

User

5.6E-03

4.5

35

2.9

Bystander

2.3E-02

18

141

13

Low-
Intensity
User

User

6.2E-02

50

385

32

Bystander

0.23

188

1444

133

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1232

1233	MOE results for Tire Repair Cement Sealer are presented in Table 4-42.

1234

1235	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1236	low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders

1237	were below the benchmark MOE for multiple endpoints for high and medium-intensity users and for

1238	congenital heart defects at all user intensity inhalation exposure levels.

1239

1240

Page 337 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

1 Table 4-43. Consumer I

lisk Estimation - Cleaning and Furniture Care Products - Carpet Cleaner

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

7.0E-05

5.7E-02

0.44

3.6E-02

Bystander

3.2E-04

0.26

2.0

0.18

Moderate-
Intensity
User

User

5.8E-04

0.47

3.6

0.29

Bystander

2.9E-03

2.4

18

1.7

Low-
Intensity
User

User

3.4E-03

2.7

21

1.7

Bystander

1.6E-02

13

99

9.0

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

1.1E-04

8.8E-02

0.60

5.9E-02

Children (16-20 years)

1.2E-04

9.4E-02

0.64

6.3E-02

Children (11-15 years)

1.1E-04

8.6E-02

0.59

5.7E-02

Moderate-
Intensity
User

Adult (>21 years)

6.7E-04

0.53

3.6

0.35

Children (16-20 years)

7.1E-04

0.56

3.8

0.38

Children (11-15 years)

6.6E-04

0.52

3.5

0.35

Low-
Intensity
User

Adult (>21 years)

1.3E-02

11

72

7.1

Children (16-20 years)

1.4E-02

11

77

7.5

Children (11-15 years)

1.3E-02

10

70

6.9

42

1243	MOE results for Carpet Cleaner are presented in Table 4-43.

1244

1245	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1246	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1247	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1248	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1249	levels.

1250

Page 338 of 748


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1251	Table 4-44. Consumer Risk Estimation - Cleaning and Furniture Care Products - Aerosol Spot

1252	Remover

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

1.1E-04

9.3E-02

0.71

5.6E-02

Bystander

1.1E-03

0.87

6.7

0.61

Moderate-
Intensity
User

User

9.8E-04

0.79

6.1

0.47

Bystander

9.9E-03

8.0

61

5.6

Low-
Intensity
User

User

6.5E-03

5.3

41

3.2

Bystander

5.4E-02

43

333

30

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

9.4E-04

0.74

5.1

0.50

Children (16-20 years)

1.0E-03

0.79

5.4

0.53

Children (11-15 years)

9.2E-04

0.73

5.0

0.49

Moderate-
Intensity
User

Adult (>21 years)

5.7E-03

4.5

31

3.0

Children (16-20 years)

6.0E-03

4.8

33

3.2

Children (11-15 years)

5.5E-03

4.4

30

2.9

Low-
Intensity
User

Adult (>21 years)

5.7E-02

45

305

30

Children (16-20 years)

6.0E-02

48

325

32

Children (11-15 years)

5.5E-02

44

297

29

1253

1254	MOE results for Aerosol Spot Remover are presented in Table 4-44.

1255

1256	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1257	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1258	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1259	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1260	levels.

1261

Page 339 of 748


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1262	Table 4-45. Consumer Risk Estimation - Cleaning and Furniture Care Products - Liquid Spot

1263	Remover

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

9.3E-05

7.5E-02

0.58

4.7E-02

Bystander

4.6E-04

0.37

2.9

0.26

Moderate-
Intensity
User

User

7.8E-04

0.63

4.9

0.39

Bystander

4.2E-03

3.4

26

2.4

Low-
Intensity
User

User

6.8E-03

5.5

42

3.4

Bystander

3.4E-02

28

214

19

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

1.6E-04

0.13

0.87

8.5E-02

Children (16-20 years)

1.7E-04

0.14

0.93

9.1E-02

Children (11-15 years)

1.6E-04

0.13

0.85

8.4E-02

Moderate-
Intensity
User

Adult (>21 years)

9.8E-04

0.77

5.3

0.51

Children (16-20 years)

1.0E-03

0.82

5.6

0.55

Children (11-15 years)

9.5E-04

0.75

5.1

0.50

Low-
Intensity
User

Adult (>21 years)

1.5E-02

12

79

7.7

Children (16-20 years)

1.6E-02

12

84

8.2

Children (11-15 years)

1.4E-02

11

77

7.5

1264

1265	MOE results for Liquid Spot Remover are presented in Table 4-45.

1266

1267	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1268	low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the

1269	benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the

1270	benchmark MOE for multiple endpoints at high, medium, and low-intensity user inhalation exposure

1271	levels.

1272

Page 340 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1273 Table 4-46. Consumer Risk Estimation - Arts, Crafts, and Hobby Materials - Fixatives and

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

4.0E-04

0.32

2.5

0.20

Bystander

1.6E-03

1.3

10

0.92

Moderate-
Intensity
User

User

2.5E-03

2.0

15

1.2

Bystander

1.3E-02

11

83

7.6

Low-
Intensity
User

User

1.3E-02

10

79

6.4

Bystander

6.5E-02

53

407

37

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1275

1276

1277

1278

1279

1280

1281

1282

MOE results for Fixatives and Finishing Spray Coatings are presented in Table 4-46.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user
inhalation exposure levels.

Page 341 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inha

ation Exposure

High-
Intensity
User

User

1.1E-03

0.89

6.8

0.55

Bystander

5.5E-03

4.4

34

3.1

Moderate-
Intensity
User

User

1.1E-02

8.8

67

5.4

Bystander

5.9E-02

48

366

33

Low-
Intensity
User

User

6.2E-02

50

386

31

Bystander

3.2E-01

258

1977

180

Dermal Exposure

High-
Intensity
User

Adult (>21 years)

1.7E-03

1.4

9.3

0.91

Children (16-20 years)

1.8E-03

1.45

9.9

0.97

Children (11-15 years)

1.7E-03

1.3

9.1

0.89

Moderate-
Intensity
User

Adult (>21 years)

1.0E-02

8.2

56

5.5

Children (16-20 years)

1.1E-02

8.7

60

5.8

Children (11-15 years)

1.0E-02

8.0

54

5.3

Low-
Intensity
User

Adult (>21 years)

0.10

82

560

55

Children (16-20 years)

0.11

87

596

58

Children (11-15 years)

0.10

80

545

53

1284

1285

1286

1287

1288

1289

1290

1291

1292

MOE results for Shoe Polish are presented in Table 4-47.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity exposure levels via both inhalation and dermal routes. Dermal MOEs were below the
benchmark MOE for multiple endpoints and all age groups. MOEs for bystanders were below the
benchmark MOE for multiple endpoints for high and medium-intensity users and for congenital heart
defects at all user intensity inhalation exposure levels.

Page 342 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

5.8E-05

0.12

0.91

7.2E-02

Bystander

2.4E-04

0.94

7.2

0.66

Moderate-
Intensity
User

User

3.6E-04

0.72

5.5

0.43

Bystander

1.9E-03

7.3

56

5.1

Low-
Intensity
User

User

1.9E-03

4.1

31

2.5

Bystander

9.5E-03

33

251

23

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1294

1295

1296

1297

1298

1299

1300

1301

MOE results for Fabric Spray are presented in Table 4-48.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user
inhalation exposure levels.

Page 343 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1302 Table 4-49. Consumer Risk Estimation - Other Consumer Uses - Film Cleaner

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

5.8E-05

4.7E-02

0.36

3.0E-02

Bystander

2.4E-04

0.19

1.5

0.13

Moderate-
Intensity
User

User

3.6E-04

0.29

2.2

0.18

Bystander

1.9E-03

1.6

12

1.1

Low-
Intensity
User

User

1.9E-03

1.5

12

0.93

Bystander

9.5E-03

7.7

59

5.4

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1303

1304

1305

1306

1307

1308

1309

1310

MOE results for Fabric Spray are presented in Table 4-49.

MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and
low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders
were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user
inhalation exposure levels.

Page 344 of 748


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Table 4-50. Consumer I

lisk Estimation - Other Consumer Uses - Hoof Polish

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Frcdriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

1.7E-03

1.4

10

0.79

Bystander

0.34

272

2084

157

Moderate-
Intensity
User

User

1.7E-02

14

106

8.0

Bystander

7.8

6307

48351

3653

Low-
Intensity
User

User

0.12

97

747

56

Bystander

48

38519

295309

22309

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1312

1313	MOE results for Hoof Polish are presented in Table 4-50.

1314

1315	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1316	low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders

1317	were below the benchmark MOE for congenital heart defects only for high and medium-intensity users.

1318	MOEs for bystanders were not below the benchmark MOE for any endpoint at low-intensity inhalation

1319	exposure levels.

1320

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Table 4-51. Consumer I

lisk Estimation - Other Consumer Uses - Pepper Spray

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Immunosuppression
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

Single
Scenario

User

0.21

169

1297

98

Bystander

Not modeled due to simulated outdoor scenario - can be considered equal to user.

Dermal exposures were not quantified for this scenario, as dermal exposure with impeded evaporation is

not expected.

1322

1323	MOE results for Pepper Spray are presented in Table 4-51.

1324

1325	MOEs for consumer users were below the benchmark MOE for congenital heart defects. Dermal

1326	exposure was not quantified. MOEs for bystanders are expected to be equivalent to users.

1327

1328

1329	Table 4-52. Consumer Risk Estimation - Other Consumer Uses - Toner Aid

Scenario

Consumer
Receptor

Benchmark

10

100

10

30

Developmental Effects

Congenital
Heart Defects
(Johnson et al.. 2003)

Developmental Effects

Developmental
Neurotoxicity
(Fredriksson et al..

Developmental Effects

Increased Resorptions
(Narotskv et al.. 1995)

Acute
Immunotoxicity

Response to Infection
(Selerade and Gilmour.

1993)



2010)

Inhalation Exposure

High-
Intensity
User

User

4.2E-04

0.34

2.6

0.21

Bystander

1.7E-03

1.4

11

0.97

Moderate-
Intensity
User

User

2.6E-03

2.1

16

1.3

Bystander

1.4E-02

11

88

8.0

Low-
Intensity
User

User

1.4E-02

11

84

6.8

Bystander

6.9E-02

56

431

39

Dermal exposures were not quantified for this scenario, as dermal exposure with impec

not expected.

ed evaporation is

1330

1331	MOE results for Toner Aid are presented in Table 4-52.

1332

1333	MOEs for consumer users were below the benchmark MOE for multiple endpoints at high, medium, and

1334	low-intensity inhalation exposure levels. Dermal exposure was not quantified. MOEs for bystanders

1335	were below the benchmark MOE for multiple endpoints at high, medium, and low-intensity user

1336	inhalation exposure levels.

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4.3 Assumptions and Key Sources of Uncertainty for Risk Characterization

4.3.1	Environmental Risk Characterization

There were some uncertainties related to environmental risk for TCE, with some leading to potentially
underestimating risk and some leading to potentially overestimating risk. As mentioned in Section 3.1.7,
there were uncertainties regarding the hazard data for aquatic species; however, some of the uncertainty
was mitigated by the use of multiple lines of evidence supporting the assessment of hazard.

There were also uncertainties around surface water concentrations used to determine the environmental
risk. EPA used E-FAST, monitored data, and data from reasonably available literature to characterize
acute and chronic exposures of TCE to aquatic organisms. In some ways the E-FAST estimates are
underestimating exposure, because data used in E-FAST include TRI and DMR data. TRI does not
include smaller facilities with fewer than 10 full time employees, nor does it cover certain sectors, which
may lead to underestimates in total TCE releases to the environment. DMR data are submitted by
NPDES permit holders to states or directly to the EPA according to the monitoring requirements of the
facility's permit. States are only required to load major discharger data into DMR and may or may not
load minor discharger data. The definition of major vs. minor discharger is set by each state and could
be based on discharge volume or facility size. Due to these limitations, some sites that discharge may
not be included in the DMR dataset.

In other ways the E-FAST estimates are overestimating exposure, because TCE is a volatile chemical,
and E-FAST doesn't take volatilization into consideration; and, for static water bodies, E-FAST uses a
dilution factor as low as one. This may have led to an over estimation of surface water concentrations
for the two facilities with environmental risks, as both release to still water bodies. Additionally, both
facilities with risk showed 20 days of exceeding the chronic COC. (The 20-day chronic risk criterion is
derived from partial life cycle tests [e.g., daphnid chronic and fish early life stage tests] that typically
range from 21 to 28 days in duration.) However, there is uncertainty about whether those 20 days would
be consecutive, because the days of exceedance modeled in E-FAST occur sporadically throughout the
year. Because TCE is a volatile chemical, it is more likely that a chronic exposure duration will occur
when there are more days of exceedances.

The reasonably available monitored data was limited temporally and geographically. Aquatic
environmental conditions such as temperature and composition (i.e., total organic carbon, water
hardness, dissolve oxygen, and pH) can fluctuate with the seasons, which could affect TCE
concentrations in water and sediment pore water. In addition, TCE monitoring data was collected only in
certain areas, and within a limited number of states in the U.S. There were no measurements reasonably
available immediately downstream from facilities releasing TCE to surface water; these data are only a
limited representation of ambient water.

4.3.2	Human Health Risk Characterization

4.3.2.1 Occupational Exposure Considerations

Air concentrations. In most scenarios where data were reasonably available, EPA did not find enough
reasonably available data to determine complete statistical distributions of actual air concentrations for
the workers exposed to TCE. Ideally, EPA would like to know 50th and 95th percentiles for each
exposed population. In the absence of percentile data for monitoring, the air concentration means and
medians (means are preferred over medians) of the data sets served as substitutes for 50th percentiles
(central tendencies) of the actual distributions, whereas high ends of ranges served as substitutes for 95th

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percentiles of the actual distributions. However, these substitutes are uncertain and are not as reliable as
the true percentiles. For instance, in the few cases where enough data were found to determine statistical
means and 95th percentiles, the associated substitutes (i.e., medians and high ends of ranges) were
shown to overestimate exposures, sometimes significantly. While it most air concentration data
represent real exposure levels, EPA cannot determine whether these concentrations are representative of
the statistical distributions of actual air concentrations to which workers are exposed. It is unknown
whether these uncertainties overestimate or underestimate exposures. The range of air concentration
estimates from central tendency to high-end was generally not large (e.g., less than 20-fold for most
exposure scenarios). Because of this the results of risk characterization were generally not sensitive to
the individual estimates of the central tendency and high-end separately but rather were based on
considering both central tendency and high-end exposure estimates which increase the overall
confidence in the risk characterization.

Exposures for ONUs can vary substantially. Most data sources do not sufficiently describe the proximity
of these employees to the exposure source. As such, exposure levels for the "occupational non-user"
category will have high variability depending on the specific work activity performed. It is possible that
some employees categorized as "occupational non-user" have exposures similar to those in the "worker"
category depending on their specific work activity pattern. Therefore, in the absence of specific
monitoring or modeling data, worker risk estimates were applied to ONUs. In many instances, this is
likely to overestimate exposures, although the central tendency worker values may be a reasonable
approximation of ONU estimates.

Additionally, some data sources may be inherently biased. For example, bias may be present if exposure
monitoring was conducted to address concerns regarding adverse human health effects reported
following exposures during use. These sources may cause exposures to be overestimated.

Where data were not reasonably available, the modeling approaches used to estimate air concentrations
also involve uncertainties. Model parameter values did not all contain distributions known to represent
the modeled scenario. It is also uncertain whether the model equations generate results that represent
actual workplace air concentrations. It is unknown whether these uncertainties overestimate or
underestimate exposures.

Averaging Times. EPA cannot determine how accurately the assumptions of exposure frequencies
(days/yr exposed) and exposed working years may represent actual exposure frequencies and exposed
working years. For example, tenure is used to represent exposed working years, but many workers may
not be exposed during their entire tenure. It is unknown whether these uncertainties overestimate or
underestimate exposures, although the high-end values may result in overestimates when used in
combination with high-end values of other parameters.

See Section 2.3.1.3 for more details on uncertainties and assumptions underlying the occupational
exposure assessment.

43,2.2 Consumer/Bystander Exposure Considerations

Inhalation and dermal exposures are evaluated for acute exposure scenarios, i.e., those resulting from
short-term or daily exposures. Chronic exposure scenarios resulting from long-term use of household
consumer products are not evaluated. As discussed in Section 2.3.2.2, in general, the frequency of
product use was considered to be too low to create chronic risk concerns. Although high-end frequencies
of consumer use are up to 50 times per year, reasonably available toxicological data is based on either
single or continuous TCE exposure and it is unknown whether these use patterns are expected to be

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clustered or intermittent (e.g. one time per week). There is uncertainty regarding the extrapolation from
continuous studies in animals to the case of repeated, intermittent human exposures. Therefore, EPA
cannot fully rule out that consumers at the high-end frequency of use could possibly be at risk for chronic
hazard effects, however it is expected to be unlikely.

The output of the consumer exposure model is fully determined by the choices of parameter values and
initial conditions. Stochastic approaches feature inherent randomness, such that a given set of parameter
values and initial conditions can lead to an ensemble of different model outputs. Because EPA's largely
deterministic approach involves choices regarding low, medium, and high values for highly influential
factors such as chemical mass and frequency/duration of product use, it likely captures the range of
potential exposure levels although it does not necessarily enable characterization of the full probabilistic
distribution of all possible outcomes.

Certain inputs to which model outputs are sensitive, such as zone volumes and airflow rates, were not
varied across product-use scenarios. As a result, model outcomes for extreme circumstances such as a
relatively large chemical mass in a relatively low-volume environment likely are not represented among
the model outcomes. Such extreme outcomes are believed to lie near the upper end (e.g., at or above the
90th percentile) of the exposure distribution.

See Section 2.3.2.7 for more details on uncertainties and assumptions underlying the consumer exposure
assessment.

4.3.2.3	Dermal Absorption Considerations

The occupational and consumer assessment approaches utilize different models for estmating dermal
absorption. As discussed in Section 2.3.2.5.1, the occupational exposure assessment used a fractional
absorption model that accounts for evaporation of volatile chemicals such as TCE. In contrast, the
consumer assessment used a permeability model that incorporates duration of use and was only applied
to exposure scenarios where evaporation was believed to be impeded. There are several parameters that
must be estimated for each of the respective models, including quantity deposited on skin, surface area
of contact, evaporative flux, film thickness, and exposure duration. Many of these are likely to vary not
only by condition of use but also the particulars of the individual activity patterns on a daily basis.
Therefore, these parameters can only be approximated and the absorption estimates may either
underestimate or overestimate the actual exposure of any particular worker or consumer on a given day,
however they serve as a reasonable generalized approximation if not a higher-end bound.

The choice of one model over the other is primarily driven by the exposure scenario that needs to be
assessed and the information that is reasonably available. For example, EPA does not know the exact
duration of exposure for occupational loading and unloading hence EPA used the engineering model for
occupational exposure assessment since it is event based and does not require a duration input. In
contrast, for consumer applications there is reasonably available information for duration of use, hence
the permeability model can be used for these exposure scenarios with greater confidence. Overall, the
two models are considered appropriate for their respective uses based on the reasonably available
information.

4.3.2.4	Confidence in Risk Estimates

Occupational Exposure Scenarios

There is varying confidence in inhalation exposure estimates from different occupational risk scenarios,
ranging from low-to-medium to medium-to-high (see Table 2-12). Despite some OES with low to
medium overall confidence, many of these are further supported by the availability of both monitoring

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and modeling data, despite the uncertainties within each (see Table 2-26). Additionally, the data quality
scores for monitoring data ranged from medium to high, and the inhalation modeling approach was peer
reviewed during the 2014 TCE risk assessment process (U.S. EPA. 2014b) (for a subset of COUs).
EPA acknowledges the uncertainty and lower confidence in applying worker estimates to represent
ONUs in the absence of reasonably available ONU data for certain OES. Therefore, EPA has low
confidence in risk estimates for ONUs based on this assumption. There is medium confidence in the
occupational dermal modeling approach, which was developed from a peer-reviewed publication
(Kasting and Miller. 2006).

Consumer Exposure Scenarios

There is medium to high confidence in consumer inhalation exposure modeling (see Section 2.3.2.8),
however there is low to medium confidence in consumer dermal exposure modeling due to uncertainties
related to absorption (as discussed above) and assumptions regarding impeded evaporation for particular
conditions of use.

Human Health Hazard

The human health database covers a wide range of endpoints, with most health effects supported by
animal, epidemiological, and mechanistic evidence. There is medium confidence in the integration of
human health data for both acute non-cancer, medium to high confidence for cancer, and high
confidence for chronic non-cancer endpoints, although there is additional uncertainty in the dose-
response analysis for the congenital heart defects endpoint (see Section 3.2.6 for more details).

Risk Conclusions

For all exposure scenarios, the confidence in the risk estimates is raised due to the presence of both
central tendency and high end estimates for occupational scenarios and low-, moderate-, and high-
intensity user estimates for consumer scenarios. Any reduced confidence in individual exposure
estimates is mitigated by the use of a range of exposure estimates, which cover a variety of different
assumptions to account for any uncertainty and variability. Therefore, while there is lower confidence in
various occupational inhalation estimates and for consumer dermal exposure estimates, there is high
confidence in the overall approach and it is unlikely that any refinement of risk estimates would result in
variation of more than a few fold in either direction.

In considering risk estimates relative to the benchmark MOE/extra risk, identified risks are typically
present for multiple endpoints, at both high-end and central tendency (or high and medium-intensity user
scenarios for consumers) exposure levels, for both inhalation and dermal exposure, and based on both
monitoring and modeling data, when available (Sections 4.5.2.1 and 4.5.2.2). In accounting for the
totality of uncertainties, including confidence levels for each exposure scenario/COU, strength of the
human health hazard information, and range of risk estimates provided for the different aspects of the
risk evaluation relative to the benchmark, confidence in the risk estimates for each of the receptors and
exposure durations is as follows:

Acute Non-Cancer Inhalation Occupational Risk (workers): Medium
Acute Non-Cancer Dermal Occupational Risk (workers): Medium

Acute Non-Cancer Inhalation Occupational Risk (ONUs): Medium (Low19 when based on central
tendency of workers without ONU-specific data)

19 EPA notes that while there is Low confidence in the accuracy of the risk estimates due to Low confidence in the exposure
estimates in these instances, the risk conclusions (i.e. risk estimate below or above benchmark) does not change if ONU
chronic exposure values are varied by lOx in either direction.

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Chronic Inhalation Non-Cancer Occupational Risk (workers): High
Chronic Dermal Non-Cancer Occupational Risk (workers): Medium-High

Chronic Inhalation Non-Cancer Occupational Risk (ONUs): Medium-High (Low19 when based on
central tendency of workers without ONU-specific data)

Lifetime Cancer Inhalation Occupational Risk (workers): Medium-High
Lifetime Cancer Dermal Occupational Risk (workers): Medium-High

Lifetime Cancer Inhalation Occupational Risk (ONUs): Medium-High (Low19 when based on central
tendency of workers without ONU-specific data)

Acute Non-Cancer Inhalation Consumer Risk (users): Medium-High
Acute Non-Cancer Dermal Consumer Risk (users): Low-Medium
Acute Non-Cancer Inhalation Consumer Risk (bystanders): Medium-High

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4,4 Other Risk Related Considerations

4.4.1	Potentially Exposed or Susceptible Populations

EPA identified workers, ONUs, consumers, and bystanders as potentially exposed populations. EPA
provided risk estimates for workers and ONUs at both central tendency and high-end exposure levels for
all COUs. Consumer and bystander risk estimates were provided for low, medium, and high intensities
of use, accounting for differences in duration, weight fraction, and mass used. Dermal risk estimates
were calculated for both average workers and women of childbearing age [Occupational Risk Estimate
Calculator. Docket # EPA-HQ-OPPT-2019-0500], based on differences in delivered dose accounting for
differing body weight and hand size. Exposures differ by only -10% between these groups, so this
difference is relatively insignificant considering the magnitude of risk estimates relative to the
benchmark MOE. Accordingly, the risk characterization section only presents dermal risk estimates for
average adult workers (Section 4.2.2). Similarly, risk estimates were provided for each of the three
lifestages that are expected to potentially be directly exposed through consumer use, namely 11-15 year
olds, 16-20 year olds, and adults 21 and over (Section 4.2.3). These risk estimates also only varied by a
small percentage relative to the magnitude of risk estimates relative to the benchmark MOE. EPA
determined that bystanders may include lifestages of any age.

For inhalation exposures, risk estimates did not differ between genders or across lifestages because both
exposures and inhalation hazard values are expressed as an air concentration. EPA expects that
variability in human physiological factors (e.g., breathing rate, body weight, tidal voume) which may
affect internal delivered concentration or dose is sufficiently accounted for in the PBPK model, although
some differences among lifestages or between working and at-rest individuals may not have been
accounted for. The use of HEC/HED99 values is expected to account for the vast majority of
physiological differences among individuals.

EPA identified lifestage, gender, genetic polymorphisms, race/ethnicity, preexisting health status, and
lifestyle factors and nutrition status as factors affecting biological susceptibility. The use of HEC/HED99
POD values derived from relevant PBPK dose metrics accounts for the vast majority of toxicokinetic
variation across the population. By relying on the 99th percentile output of the PBPK model, these values
are expected to be protective of particularly susceptible subpopulations, including those with genetic
polymorphisms resulting in increased activity of bioactivating enzymes. The (S el grade and Gilmour.
2010) study accounts for pre-existing infection concurrent with TCE exposure, representing a
susceptible status that applies intermittently to the entire population. Cardiac malformations are most
strongly associated with offspring of older mothers (Brender et ai. 2014; Yauck et al. 2004). While
inconsistencies in the data on cardiac malformations (Appendix G.2) suggest that there may nor be a risk
for all individuals, inclusion of risk estimates for cardiac malformations is protective of susceptible
mothers (Jenkins et al.. 2007) and their offspring.

4.4.2	Aggregate and Sentinel Exposures

Section 2605(b)(4)(F)(ii) of TSCA requires the EPA, as a part of the risk evaluation, to describe whether
aggregate or sentinel exposures under the conditions of use were considered and the basis for their
consideration. The EPA has defined aggregate exposure as "the combined exposures to an individual
from a single chemical substance across multiple routes and across multiple pathways'' (40 CFR §
702.33). In this risk evaluation, EPA determined that aggregating dermal and inhalation exposure for
risk characterization was not appropriate due to uncertainties in quantifying the relative contribution of
dermal vs inhalation exposure, since dermally applied dose could evaporate and then be inhaled.
Aggregating exposures from multiple routes could therefore inappropriately overestimate total exposure,

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as simply adding exposures from different routes without an available PBPK model for those routes
would compound uncertainties. EPA also did not consider aggregate exposure among individuals who
may be exposed both in an occupational and consumer context because there is insufficient information
reasonably available as to the likelihood of this scenario or the relative distribution of exposures from
each pathway.

EPA defines sentinel exposure as "the exposure to a single chemical substance that represents the plausible
upper bound of exposure relative to all other exposures within a broad category of similar or related
exposures" (40 CFR § 702.33). In terms of this risk evaluation, EPA considered sentinel exposures by
considering risks to populations who may have upper bound exposures - for example, workers and
ONUs who perform activities with higher exposure potential, or consumers who have higher exposure
potential (e.g., those involved with do-it-yourself projects) or certain physical factors like body weight
or skin surface area exposed. EPA characterized high-end exposures in evaluating exposure using both
monitoring data and modeling approaches. Where statistical data are reasonably available, EPA typically
uses the 95th percentile value of the reasonably available dataset to characterize high-end exposure for a
given condition of use. For consumer and bystander exposures, EPA characterized sentinel exposure
through a "high-intensity use" category based on both product and user-specific factors.

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4,5 Risk Conclusions

4,5.1 Environmental Risk Conclusions

Risks to aquatic organisms like fish and invertebrates were identified near one open-top vapor
degreasing facility and one facility that processes TCE as a reactant (See Table 4-53). These facilities
had an acute RQ > 1, or a chronic RQ > 1 and 20 days or more of exceedance for the chronic COC.

Risk to the most sensitive species of algae were identified near 521 facilities (with 20 days or more of
exceedances for 461 of these facilities, and more than 100 days exceedances for 10 facilities); however,
as a taxonomic group, 95% of algae species not experience risk. (They had RQs > 1 using the algae
COC of 3 ppb but RQs < 1 using the algae HCos of 52,000 ppb.) These facilities are not included in
Table 4-53 in this section, but are in Table 4-1 for reference.

EPA did not identify risks to aquatic organisms like fish and invertebrates in the ambient water where
monitored data were reasonably available. Monitored data from the Water Quality Portal and the
reasonably available literature show no exceedances of the acute COC, or chronic COC in ambient
water. Monitored data from literature showed some exceedances of the algae COC of 3 ppb in ambient
water; however, the data show no exceedances of the algae COC of 52,000 ppb.

Near-facility monitoring data report levels of TCE ranging from 0.4 to 447 |ig/L (U.S. EPA. 1977).
These data show that measured, near-facility concentrations compare to the modeled near-facility
concentrations from E-FAST. With the exception of two sites, the measured concentrations in this study
encompasses the range of the modeled estimates across all OES from E-FAST.

Open-top Vapor Degreasing:

One out of 64 open-top vapor degreasing facilities had releases of TCE to surface water that indicate
risk to aquatic organisms. U.S. NASA Michoud Assembly Facility in New Orleans, LA had an acute RQ
> 1 (RQ = 3.11). In other words, the surface water concentration modeled for this facility was 3.11 times
higher than the acute COC of 3,200 ppb, indicating risk to aquatic organisms from acute exposures. The
facility also had a chronic RQ of 12.61 with 20 days of exceedance. In other words, the surface water
concentration was 12.61 higher than the COC of 788 for 20 days. Therefore, EPA identified risk to
aquatic organisms at this site for acute and chronic exposures to TCE.

Processing as a Reactant:

One out of 443 facilties (including 440 unknown sites modeled in E-FAST) that process TCE as a
reactant had releases of TCE to surface water that indicate risk to aquatic organisms like fish and
invertebrates. Praxair Technology Center in Tonawanda, NY had a chronic RQs of 3.81 with 20 days of
exceedance. In other words, the surface water concentration modeled for this facility was 3.81 times
higher than the COC for chronic exposures. Therefore, EPA identified risk to aquatic organisms at this
site for chronic exposures to TCE.

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Table 4-53. Facilities with Acute or Chronic Risk Identified for Aquatic Organisms (RQs > 1 in bold)

Name, Location, and
ID of Active Releaser
Facility a

Release
Media b

Modeled Facility or
Industry Sector in
EFAST c

EFAST
Waterbody
Type d

Days of
Release

e

Release
(kg/day)f

7Q10
SWC
(ppb)g

COC Type

COC
(ppb)

Days of
Exceedance
(days/year)

h"

Risk
Quotient

OES: Processing as a Reactant















Acute

3,200

NA

0.05

Praxair Technology
Center,
Tonawanda, NY
NPDES: NY0000281







350

0.00169

169

Chronic

788

0

0.21







Algae

3

350

56.33

Surface

NPDES NY0000281

Still body







Algae (HCos)

52,000

0

0.00

Water







Acute

3,200

NA

0.94







20

0.03

3000

Chronic

788

20

3.81









Algae

3

20

1,000.00















Algae (HCos)

52,000

0

0.06

OES: OTVD (Includes releases for Closed-Loop Degreasing, Conveyorized Degreasing, Web Degreasing, and Metalworking Fluids)















Acute

3,200

NA

0.24

US Nasa Michoud







260

1.96

765.63

Chronic

788

0

0.97

Assembly Facility,







Algae (COC)

3

260

255.21

New Orleans, LA

Surface

Surrogate NPDES

Still body







Algae (HCos)

52,000

0

0.01

NPDES: LA0052256

Water

LA0003280







Acute

3,200

NA

3.11









20

25.44

9937.5

Chronic

788

20

12.61









Algae

3

20

3,312.50















Algae (HCos)

52,000

0

0.19

a.	Facilities actively releasing tricliloroethylene were identified via DMR, TRI, and CDR databases for the 2016 reporting year.

b.	Release media are either direct (release from active facility directly to surface water) or indirect (transfer of wastewater from active facility to a receiving POTW or

non-POTW WWTP facility). A wastewater treatment removal rate of 81% is applied to all indirect releases, as well as direct releases from WWTPs.

c.	If a valid NPDES of the direct or indirect releaser was not reasonably available in EFAST, the release was modeled using either a surrogate representative facility in
EFAST (based on location) or a representative generic industry sector. The name of the indirect releaser is provided, as reported in TRI.

d.	EFAST uses ether the "surface water" model, for rivers and streams, or the "still water" model, for lakes, bays, and oceans.

e.	Modeling was conducted with the maximum days of release per year expected. For direct releasing facilities, a minimum of 20 days was also modeled.

f.	The daily release amount was calculated from the reported annual release amount divided by the number of release days per year.

g.	For releases discharging to lakes, bays, estuaries, and oceans, the acute scenario mixing zone water concentration was reported in place of the 7Q10 SWC.

h.	To determine the PDM days of exceedance for still bodies of water, the release days provided by the EPA Engineers should become the days of exceedance only if the
predicted surface water concentration exceeds the COC. Otherwise, the days of exceedance can be assumed to be zero.

Page 355 of 748


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1652

1653

1654

1655

1656

1657

1658

1659

1660

1661

1662

1663

1664

1665

1666

1667

1668

1669

1670

1671

1672

1673

1674

1675

1676

1677

1678

1679

1680

1681

1682

1683

1684

1685

1686

1687

1688

1689

1690

1691

1692

1693

1694

1695

1696

1697

1698

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
4.5.2 Human Health Risk Conclusions

4.5.2.1 Summary of Risk Estimates for Workers and ONUs

Table 4-54 summarizes the representative risk estimates for inhalation and dermal exposures for all
occupational exposure scenarios. Risk estimates that exceed the benchmark (i.e. MOEs less than the
benchmark MOE or cancer risks greater than the cancer risk benchmark) are highlighted by bolding the
number and shading the cell in gray. When both monitoring and modeling inhalation exposures were
available, EPA presented the most reliable data source in the table. The occupational exposure
assessment and risk characterization are described in more detail in Sections 2.3.1 and 4.2.2,
respectively. Specific links to the relevant risk characterization sections are listed in Table 4-54 in the
Occupational Exposure Scenario column.

Of note, the risk summary below is based on the most robust and well-supported PODs selected from
among the most sensitive acute and chronic non-cancer endpoints, as well as cancer. EPA selected
immunosuppression (Selerade and Gilmour. ) as the best overall representative acute endpoint, and
autoimmunity from the immunotoxicity domain (Keil et al. 2009) was selected to best represent chronic
exposure (Section 3.2.6.4). For the majority of exposure scenarios, risks were identified for multiple
endpoints in both acute and chronic exposure scenarios, however risk estimates are only summarized for
these particular endpoints. Risk estimates are also presented considering PPE up to respirator APF 50
and glove PF 10 or 20. When risks did not exceed the benchmark, the lowest protection factor that
results in no risk is shown (i.e., if risks do not exceed the benchmark for APF 10 and above, the risk
estimate for APF 10 is shown).

Inhalation Exposure

For acute and chronic exposures via inhalation without PPE (i.e. no respirators) there are risks for
workers relative to the benchmarks for all the OES at the high-end exposure level for non-cancer effects
from both acute and chronic exposure durations as well as for cancer. Occupational non-users (ONUs)
are expected to have lower exposure levels than workers in most instances but exposures could not
always be quantified. Therefore, when separate ONU exposure estimates were not reasonably available,
EPA provided risk estimates for ONUs based on worker values (without PPE). These instances are
indicated in Table 4-54 with "upper limit" added to the ONU cell in the Population column. Risks to
ONUs were indicated at high-end exposure levels for all OES following chronic exposure and for most
OES following acute exposure, although central-tendency exposure levels are considered more
representative for ONUs.

When only considering central tendency inhalation exposure level, risks for any endpoint were not
identified to workers or ONUs for the following exposure scenarios:

•	Formulation of Aerosol and Non-Aerosol Products

•	Repackaging

•	Process Solvent Recycling and Worker Handling of Wastes

When respirators are worn (either APF 10 or 50) there are risks relative to the benchmarks for non-
cancer effects and for cancer for workers (ONUs are assumed to not consistently wear respirators) from
both acute and chronic exposure durations at high-end exposure levels for the majority of OES (risks
remain with respirator use for all exposure scenarios following chronic exposure). Risks for any
endpoint were not identified when assuming the maximum plausible APF (up to APF =50) and central
tendency exposure levels for the same exposure scenarios that did not demonstrate risk without PPE:

•	Formulation of Aerosol and Non-Aerosol Products

Page 356 of 748


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1699	• Repackaging

1700	• Process Solvent Recycling and Worker Handling of Wastes

1701

1702	Dermal Exposure

1703	For acute and chronic exposures via dermal contact without PPE (i.e. no gloves) there are risks to

1704	workers for both non-cancer effects and cancer (ONUs are assumed to not have direct dermal contact

1705	with TCE) at both high-end and central-tendency exposure levels for all OES. Risks are still identified

1706	for all exposure scenarios (at high-end exposure levels following acute exposure and at both exposure

1707	levels following chronic exposure) when gloves are worn even when assuming the maximum applicable

1708	glove protection (either PF 10 or 20).

Page 357 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
1709 Table 4-54. Occupational Risk Summary Table				













Risk Estimates for No PPE

Risk Estimates with PPE

Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)









Inhalation

High-
End

2.0

5.6E-02

6.7E-03

100.8
(APF 50)

2.8
(APF 50)

1.3E-04
(APF 50)







Worker

Central
Tendency

13.9

0.39

7.5E-04

139.1
(APF 10)

19.3
(APF 50)

7.5E-05
(APF 10)

Manufacture -

Domestic
manufacture

Domestic manufacture

Manufacturing -

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Table 4-6



Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)







ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

13.9

0.39

7.5E-04

N/A









Inhalation

High-
End

4.6

0.13

2.9E-03

45.8
(APF 10)

6.3
(APF 50)

5.9E-05
(APF 50)







Worker

Central
Tendency

10546

292

9.9E-07

105460
(APF 10)

2920
(APF 10)

9.9E-08
(APF 10)

Manufacture -

Import

Repackaging -

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Import

Table 4-19



Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)







ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

10546

292

9.9E-07

N/A

Processing -
Processing as a

Intermediate in industrial
gas manufacturing (e.g..

Processing as a
Reactant -
Table 4-7

Worker

Inhalation

High-
End

2.0

5.6E-02

6.7E-03

100.8
(APF 50)

2.8
(APF 50)

1.3E-04
(APF 50)

reactant/
intermediate

manufacture of
fluorinated gases used as

Central
Tendency

13.9

0.39

7.5E-04

139.1
(APF 10)

19.3
(APF 50)

7.5E-05
(APF 10)

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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Life Cycle
Stage/
Category

Subcategory

refrigerants, foam
blowing agents and
solvents)

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)

ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-

Central
Tendency

13.9

0.39

7.5E-04

N/A

Processing -
Incorporation
into formulation,

mixture or
reaction product

Processing -
incorporated
into articles

Solvents (for cleaning or
degreasing)

Formulation of
Aerosol and Non-
Aerosol Products ¦
Table 4-18

Worker

Inhalation

High-
End

4.6

0.13

2.9E-03

45.8
(APF 10)

6.3
(APF 50)

5.9E-05
(APF 50)

Adhesives and sealant
chemicals

Central
Tendency

10546

292

9.9E-07

105460
(APF 10)

2920
(APF 10)

9.9E-08
(APF 10)

Solvents (which become

part of product
formulation or mixture)
(e.g., lubricants and
greases, paints and
coatings, other uses)

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04 (PF
20)

ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-

Solvents (becomes an
integral component of
articles)

Central
Tendency

10546

292

9.9E-07

N/A

Processing -
Repackaging

Solvents (for cleaning or
degreasing)

Repackaging -
Table 4-19

Worker

Inhalation

High-
End

4.6

0.13

2.9E-03

45.8
(APF 10)

6.3
(APF 50)

5.9E-05
(APF 50)

Central
Tendency

10546

292

9.9E-07

105460
(APF 10)

2920
(APF 10)

9.9E-08
(APF 10)

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)

Page 359 of 748


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Risk Estimates for No PPE

Risk Estimates with PPE

Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)







ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

10546

292

9.9E-07

N/A









Inhalation

High-
End

4.(i

0.13

2.91-113

45.8
(APF 10)

(>.3
(API- 50)

5.9E-05
(APF 50)







Workers

Central
Tendency

10546

292

9.9E-07

105460
(APF 10)

(APF 10)

9.9E-08
(APF 10)

Processing -

Recycling

Process Solvent
Recycling and
Worker Handling
of Wastes -
Table 4-27

Dermal

High-
End

1.2

3.0I-.-02

3.XI-.-02

23.S
(PI- 20)

0.(,l

(PI" 20)

i.'h:-o3
(P1- 20)

Recycling



Central
Tendency

3.(.

'ur.-o2

«>.T.-03

35.7
(PI' 1U)

I.X

(PI" 20)

4.*>i:-o4
(PI" 20)







ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

10546

292

9.9E-07

N/A

Distribution in
commerce -
Distribution

Distribution

Distribution

Distribution is accounted for as part of other COUs

Industrial/
commercial use ¦
Solvents (for







Inhalation
(Monitoring
Data)3

High-
End

(..T.-02

i.')i:-o3

0.20

3.4
(API- 50)

'Ui:-o2

(API- 50)

4.0T.-03
(API- 50)

Batch vapor degreaser
(e.g., open-top, closed-
loop)

Batch Open-Top
Vapor Degreasing
- Table 4-8

Workers

Central
Tendency

0.3X

i.oi:-o2

2.XI-.-02

ix.y

(API- 50)

0.52
(API- 50)

5.51.-04
(API- 50)

cleaning or
degreasing)

Dermal

High-
End

1.2

3.0T.-02

3.XI-.-02

23.X
(PI- 20)

0.(>l

(PI" 20)

l.«>l-'.-03
(PI- 20)









Central
Tendency

3.(i

'XII.-112

9.T.-03

35.7
l-'.-04
(PI- 20)

Page 360 of 748


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Risk Estimates for No PPE

Risk Estimates with PPE

Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)







ONU

Inhalation
(Monitoring

High-
End

0.57

1.6E-02

2.3E-02

N/A









Data)3

Central
Tendency

4.7

0.13

2.2E-03

N/A









Inhalation

High-
End

3.6

9.9E-02

3.7E-03

35.9
(APF 10)

5.0
(APF 50)

7.5E-05
(APF 50)







Workers

Central
Tendency

11.4

0.32

9.1E-04

114.0
(APF 10)

15.8
(APF 50)

9.1E-05
(APF 10)





Batch Closed-
Loop Vapor

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Industrial/
commercial use ¦
Solvents (for



Degreasing -
Table 4-10



Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)





ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-

cleaning or
degreasing)





Central
Tendency

11.4

0.32

9.1E-04

N/A









Inhalation
(Monitoring
Data)a

High-
End

0.11

3.0E-03

0.12

5.4
(APF 50)

0.15
(APF 50)

2.5E-03
(APF 50)







Workers

Central
Tendency

0.16

4.5E-03

6.5E-02

8.1
(APF 50)

0.22
(APF 50)

1.3E-03
(APF 50)



In-line vapor degreaser
(e.g., conveyorized, web
cleaner)

Conveyorized
Vapor Degreasing
-Table 4-11

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)





Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)







ONU
(upper
limit)

Inhalation
(Monitoring
Data)3

High-
End

-

-

-

-







Central
Tendency

0.16

4.5E-03

6.5E-02

N/A

Page 361 of 748


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Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Industrial/
commercial use ¦
Solvents (for
cleaning or
degreasing)



Web Vapor
Degreasing -
Table 4-13

Workers

Inhalation

High-
End

0.3"7

i.oi:-o2

2.91.-02

IS.5
(API- 50)

0.51
(API- 50)

5.XI.-04
(API- 50)

Central
Tendency

O.XX

2.41-'.-02

I.I 1.-02

4'

( \H' 5(1)

1.2
(API- 50)

2.3I.-04
(API- 50)

Dermal

High-
End

1.2

3.01-'.-02

3.XI-.-02

23.S
(i»r 20)

0.(.l

(PI" 20)

l.«>l-'.-03
(PI- 20)

Central
Tendency

3.(i

'XII.-112

«j.",i:-o3

35.7
.ii-:-o2

2.51-'.-03

0.11

4.(i
(API- 50)

0.13
(API- 50)

2.3E-03
(API- 50)

Central
Tendency

1.6

4.31-'.-02

(..21.-03

~S 4
( \H' 5(1)

2.2
(API- 50)

I.2T.-04
(API- 50)

Dermal

High-
End

1.2

3.01-'.-02

3.XE-02

23.S
(PI- 20)

0.(>l
(PI" 20)

l.«)l-'.-03
(PI- 20)

Central
Tendency

3.(i

«).ir.-o2

«>.7l-'.-03

35.7
il'l' Id)

I.S

(PI" 20)

4.') 1.-04
(PI- 20)

ONU

Inhalation

High-
End

0.15

4.T.-04

(..«>i-:-o2

N/A

Central
Tendency

2.S

s.si:-o3

3.3I.-03

N/A

Aerosol spray
degreaser/cleaner

Aerosol
Applications -
Table 4-15

Worker

Inhalation

High-
End

0.22

(>.oi:-o3

4.«)l-'.-02

io.y
(API- 50)

0.30
(API- 50)

^T.-O-t
(API- 50)

Central
Tendency

0.(.X

i.')i:-o2

I.4I-.-02

u:

( \H' 5(1)

0.«>5
(API- 50)

2.«)l-:-04
(API- 50)

Page 362 of 748


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Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)



Dermal

High-
End

o.^r.

i.')i:-o2

5.') 1.-02

15.1
(PI- 20)

0.3')
(PI- 20)

2.9I.-03
(PI- 20)

Mold release

Central
Tendency

2.3

5.XI-.-02

1.51.-02

45 4
5
( \H' 5(1)

Central
Tendency

"4 (>

2.1

1.31.-04

"45 "

(\\>\: III)

|Ui |

( \H' 5(1)

: (.i:-()(.
( \H' 5(1)

Dermal

High-
End

1.5

3.Sl-:-02

3.0T-02

2')."'
(PI- 20)

O.^f.
(PI" 20)

1.51.-03
(PI- 20)

Central
Tendencs

4.5

0.11

¦'.si:-o3

o.r

(PI- 20)

2.3
(PI- 20)

3.91-!-04
(P1- 20)

ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-

Central
Tendency

"4 (>

2.1

1.31.-04

N/A

Penetrating lubricant

Aerosol
Applications -
Table 4-15

Worker

Inhalation

High-
End

0.22

r..oi:-o3

4.9I-.-02

10.9

(API- 50)

0.30
(API- 50)

9.T.-04
(API- 50)

Central
Tendency

0.(.X

1.91.-112

1.41.-02

u:

( \H' 5(1)

0.95
(API- 50)

2.9I-.-04
(API- 50)

Dermal

High-
End

O.-'f,

i.yi:-o2

5.91-112

15.1
(PI- 20)

0.39
(PI" 20)

2.9I.-03
(P1- 20)

Central
Tendency

2.3

5.XI-.-02

I.5I-.-02

45 4
il'l' :<))

1.2

(PI" 20)

¦'.(.ixm

(P1- 20)

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Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Industrial/
commercial use
- Lubricants and

greases/
lubricants and
lubricant
additives

ONU

Inhalation

High-
End

5.0

0.14

2.0E-03

N/A

Central
Tendency

37.3

1.0

2.6E-04

N/A

Solvent-based adhesives
and sealants

Adhesives,
Sealants, Paints,
and Coatings -
Table 4-22 and
Table 4-23

Worker

Inhalation

High-
End

0.13

3.7E-03

0.10

6.6
(APF 50)

0.18
(APF 50)

2.0E-03
(APF 50)

Central
Tendency

1.1

3.1E-02

9.3E-03

56.3
(APF 50)

1.6
(APF 50)

1.9E-04
(APF 50)

Dermal
(Industrial)

High-
End

1.3

3.4E-02

3.4E-02

26.4
(PF 20)

0.68
(PF 20)

1.7E-03
(PF 20)

Tire repair cement/
Sealer

Central
Tendency

4.0

0.10

8.7E-03

39.6
(PF 10)

2.0
(PF 20)

4.4E-04
(PF 20)

Dermal
(Commercial)

High-
End

0.84

2.2E-02

5.3E-02

8.4
(PF 10)

0.22
(PF 10)

5.3E-03
(PF 10)

Central
Tendency

2.5

6.5E-02

1.4E-02

25.2
(PF 10)

0.65
(PF 10)

1.4E-03
(PF 10)

Mirror edge sealant

ONU

Inhalation

High-
End

5.2

0.14

2.6E-03

N/A

Central
Tendency

5.5

0.15

1.9E-03

N/A

Industrial/
commercial use -
Functional fluids
(closed systems)

Heat exchange fluid

Other Industrial
Uses -
Table 4-26

Worker

Inhalation

High-
End

2.0

5.6E-02

6.7E-03

100.8
(APF 50)

2.8
(APF 50)

1.3E-04
(APF 50)

Central
Tendency

13.9

0.39

7.5E-04

139.1
(APF 10)

19.3
(APF 50)

7.5E-05
(APF 10)

Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)

Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)

Page 364 of 748


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Risk Estimates for No PPE

Risk Estimates with PPE

Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)







ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

13.9

0.39

7.5E-04

N/A









Inhalation

High-
End

0.13

3.7E-03

0.10

6.6
(APF 50)

0.18
(APF 50)

2.0E-03
(APF 50)









Central
Tendency

1.1

3.1E-02

9.3E-03

56.3
(APF 50)

1.6
(APF 50)

1.9E-04
(APF 50)







Worker

Dermal

High-
End

1.3

3.4E-02

3.4E-02

26.4
(PF 20)

0.68
(PF 20)

1.7E-03
(PF 20)

Industrial/
commercial use ¦

Diluent in solvent-based

Adhesives,
Sealants, Paints,
and Coatings -
Table 4-22 and
Table 4-23

(Industrial)

Central
Tendency

4.0

0.10

8.7E-03

39.6
(PF 10)

2.0
(PF 20)

4.4E-04
(PF 20)

Paints and
coatings

paints and coatings



Dermal

High-
End

0.84

2.2E-02

5.3E-02

8.4
(PF 10)

0.22
(PF 10)

5.3E-03
(PF 10)









(Commercial)

Central
Tendency

2.5

6.5E-02

1.4E-02

25.2
(PF 10)

0.65
(PF 10)

1.4E-03
(PF 10)







ONU

Inhalation

High-
End

5.2

0.14

2.6E-03

N/A







Central
Tendency

5.5

0.15

1.9E-03

N/A



Carpet cleaner





Inhalation
(Modeling
Data)b

High-
End

1.9

5.1E-02

5.8E-03

94.2
(APF 50)c

2.5
(APF 50)c

1.2E-04
(APF 50)c

Industrial/
commercial use -
Cleaning and
furniture care
products

Spot Cleaning
and Wipe

Worker

Central
Tendency

5.4

0.15

1.8E-03

54.3
(APF 10)c

7.3
(APF 50)c

3.7E-05
(APF 10)c

Wipe cleaning

Cleaning0 -
Table 4-17

Dermal

High-
End

0.76

1.7E-02

6.9E-02

7.6
(PF 10)

0.17
(PF 10)

6.9E-03
(PF 10)







Central
Tendency

2.3

5.6E-02

1.6E-02

22.7
(PF 10)

0.56
(PF 10)

1.6E-03
(PF 10)

Page 365 of 748


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Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Industrial/
commercial use -
Laundry and
dishwashing
products

Spot remover

ONU

Inhalation
(Modeling
Data)b

High-
End

3.0

8.0E-02

3.6E-03

N/A

Central
Tendency

10.9

0.29

9.2E-04

N/A

Industrial/
commercial use -
Arts, crafts and
hobby materials

Fixatives and finishing
spray coatings

Adhesives,
Sealants, Paints,
and Coatings -
Table 4-22 and
Table 4-23

Worker

Inhalation

High-
End

0.13

3.7E-03

0.10

6.6
(APF 50)

0.18
(APF 50)

2.0E-03
(APF 50)

Central
Tendency

1.1

3.1E-02

9.3E-03

56.3
(APF 50)

1.6
(APF 50)

1.9E-04
(APF 50)

Dermal
(Industrial)

High-
End

1.3

3.4E-02

3.4E-02

26.4
(PF 20)

0.68
(PF 20)

1.7E-03
(PF 20)

Central
Tendency

4.0

0.10

8.7E-03

39.6
(PF 10)

2.0
(PF 20)

4.4E-04
(PF 20)

Dermal
(Commercial)

High-
End

0.84

2.2E-02

5.3E-02

8.4
(PF 10)

0.22
(PF 10)

5.3E-03
(PF 10)

Central
Tendency

2.5

6.5E-02

1.4E-02

25.2
(PF 10)

0.65
(PF 10)

1.4E-03
(PF 10)

ONU

Inhalation

High-
End

5.2

0.14

2.6E-03

N/A

Central
Tendency

5.5

0.15

1.9E-03

N/A

Industrial/
commercial use -
Corrosion
inhibitors and
anti-scaling
agents

Corrosion inhibitors and
anti-scaling agents

Industrial
Processing Aid -
Table 4-24

Worker

Inhalation

High-
End

0.27

7.5E-03

4.9E-02

13.6
(APF 50)

3.0E-02
(APF 50)

9.9E-04
(APF 50)

Central
Tendency

0.82

2.3E-02

1.3E-02

40.9
(APF 50)

9.1E-02
(APF 50)

2.5E-04
(APF 50)

1710

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Risk Estimates for No PPE

Risk Estimates with PPE

Life Cycle

Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= lO"4)



Process solvent used in





Dermal

High-
End

1.2

3.0E-02

3.8E-02

23.8
(PF 20)

0.61
(PF 20)

1.9E-03
(PF 20)



battery manufacture





Central
Tendency

3.6

9.1E-02

9.7E-03

35.7
(PF 10)

1.8
(PF 20)

4.9E-04
(PF 20)

Industrial/
commercial use -
Processing aids

Process solvent used in
polymer fiber spinning,
fluoroelastomer
manufacture and
Alcantara manufacture

Industrial
Processing Aid -
Table 4-24

ONU

Inhalation

High-
End

1.2

3.3E-02

1.1E-02

N/A



Extraction solvent used in
caprolactam manufacture



Central

2.7

7.3E-02

3.9E-03



N/A





Precipitant used in beta-
cyclodextrin manufacture







Tendency













Inhalation

High-
End

2.5

6.9E-02

5.4E-03

124.6
(APF 50)c

3.4
(APF 50)c

1.1E-04
(APF 50)c







Workers

Central
Tendency

61.4

1.7

1.7E-04

614.1
(APF 10)c

85.0
(APF 50)c

1.7E-05
(APF 10)c

Industrial/
commercial use -

Toner aid

Commercial
Printing and
Copyingc -
Table 4-25

Dermal

High-
End

2.2

5.5E-02

2.1E-02

21.6
(PF 10)

0.55
(PF 10)

2.1E-03
(PF 10)

Ink, toner and
colorant
products



Central
Tendency

6.5

0.17

5.3E-03

32.5
(PF 5)

1.7
(PF 10)

5.3E-04
(PF 10)





ONU
(upper
limit)

Inhalation

High-
End

-

-

-

-







Central
Tendency

61.4

1.7

1.7E-04

N/A

Industrial/
commercial use -

Brake and parts cleaner

Aerosol
Applications -
Table 4-15

Workers

Inhalation

High-
End

0.22

6.0E-03

4.9E-02

10.9
(APF 50)

0.30
(APF 50)

9.7E-04
(APF 50)

Automotive care
products

Central
Tendency

0.68

1.9E-02

1.4E-02

34.2
(APF 50)

0.95
(APF 50)

2.9E-04
(APF 50)

Page 367 of 748


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Life Cycle

Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= 10"4)

Acute Non-

Cancer
(benclunark
MOE = 30)

Chronic
Non-Cancer
(benclunark
MOE = 30)

Cancer
(benclunark
= lO"4)

Dermal

High-
End

0.76

1.9E-02

5.9E-02

15.1
(PF 20)

0.39
(PF 20)

2.9E-03
(PF 20)

Central
Tendency

2.3

5.8E-02

1.5E-02

45.4
(PF 20)

1.2
(PF 20)

7.6E-04
(PF 20)

ONU

Inhalation

High-
End

5.0

0.14

2.0E-03

N/A

Central
Tendency

37.3

1.0

2.6E-04

N/A

Industrial/
commercial use ¦
Apparel and
footwear care
products

Shoe polish

Other Commercial
Uses
(Spot Cleaning

and Wipe
Cleaning)0 -
Table 4-17

Worker

Inhalation
(Modeling
Data)b

High-
End

1.9

5.1E-02

5.8E-03

94.2
(APF 50)c

2.5
(APF 50)c

1.2E-04
(APF 50)c

Central
Tendency

5.4

0.15

1.8E-03

54.3
(APF 10)c

7.3
(APF 50)c

3.7E-05
(APF 10)c

Dermal

High-
End

0.76

1.7E-02

6.9E-02

7.6
(PF 10)

0.17
(PF 10)

6.9E-03
(PF 10)

Central
Tendency

2.3

5.6E-02

1.6E-02

22.7
(PF 10)

0.56
(PF 10)

1.6E-03
(PF 10)

Industrial/
commercial use ¦
Other uses

Hoof polishes
Gun Scrubber

ONU

Inhalation
(Modeling
Data)b

High-
End

3.0

8.0E-02

3.6E-03

N/A
N/A

Pepper spray

Other miscellaneous
industrial and commercial
uses

Central
Tendency

10.9

0.29

9.2E-04

N/A

1711

Page 368 of 748


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Life Cycle
Stage/
Category

Subcategory

Occupational
Exposure
Scenario

Population

Exposure
Route and
Duration

Exposure
Level

Risk Estimates for No PPE

Risk Estimates with PPE

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Acute Non-

Cancer
(benchmark
MOE = 30)

Chronic
Non-Cancer
(benchmark
MOE = 30)

Cancer
(benchmark
= 10"4)

Disposal

Industrial pre-treatment

Process Solvent
Recycling and
Worker Handling
of Wastes -
Table 4-27

Workers

Inhalation

High-
End

4.(i

0.13

2.91-113

45.8
(APF 10)

(..3
(API- 50)

5.9E-05
(APF 50)

Central
Tendency

10546

292

9.9E-07

105460
(APF 10)

2920
(APF 10)

9.9E-08
(APF 10)

Industrial wastewater
treatment

Dermal

High-
End

1.2

3.01.-02

3.Sl-:-02

23.X
(PI- 20)

0.(»l
(PI- 20)

I.S
(PI- 20)

I.1'>1.-03
(PI- 20)

4.'>l-:-04
(PI- 20)

Central
Tendencs

3.(i

'XII.-112

«>.T.-03

35.7

-------
1713

1714

1715

1716

1717

1718

1719

1720

1721

1722

1723

1724

1725

1726

1727

1728

1729

1730

1731

1732

1733

1734

1735

1736

1737

1738

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

4.5.2.2 Summary of Risk Estimates for Consumers and Bystanders

Table 4-55 summarizes the risk estimates for CNS effects from acute inhalation and dermal exposures
for all consumer exposure scenarios. Risk estimates that exceed the benchmark (i.e. MOEs less than the
benchmark MOE) are highlighted by holding the number and shading the cell in gray. The consumer
exposure assessment and risk characterization are described in more detail in Sections 2.3.2 and 4.2.3,
respectively. Specific links to the relevant risk characterization sections are listed in Table 4-55 in the
Consumer Condition of Use Scenario column.

Of note, the risk summary below is based on the most robust and well-supported PODs selected from
among the most sensitive acute and chronic non-cancer endpoints, as well as cancer. EPA selected
immunosuppression (Selgrade and Gilmour. 2010) as the best overall representative acute endpoint
(Section 3.2.6.4). For the majority of exposure scenarios, risks were identified for multiple endpoints,
however risk estimates are only summarized for this particular endpoint.

Inhalation

For acute inhalation exposures there are risks for non-cancer effects for consumer users relative to the
benchmarks for all COUs except Pepper Spray and for bystanders for most COUs at both medium and
high-intensity user exposure levels.

Dermal

For acute dermal exposures there are risks for non-cancer effects for consumer users (bystanders are
assumed to not have direct dermal contact with TCE) relative to the benchmarks for all COUs where
dermal exposure is expected at both medium and high-intensity user exposure levels (and for most
COUs at low-intensity).

Table 4-55. Consumer Risk Summary Table

Life Cycle

Stage/
Category

Subcategory/
Consumer
Condition of Use
Scenario

Population

Exposure
Route and
Duration

Age
Group

Acute Non-Cancer
(benchmark MOE = 30)

High-Intensity
User

Moderate-
Intensity User

Low-Intensity
User

Consumer Use -
Solvents (for
cleaning or
degreasing)

Brake and Parts
Cleaner -
Table 4-28

User

Inhalation

Alla

3.5E-02

0.21

2.7

Dermal

21+

3.6E-02

0.48

22

16-20

3.8E-02

0.51

23

11-15

3.5E-02

0.47

21

Bystander

Inhalation

All

0.14

0.94

12

Aerosol electronic
degreaser/cleaner -
Table 4-29

User

Inhalation

All

5.0E-02

1.2

33

Bystander

Inhalation

All

0.28

7.1

193

Liquid electronic
degreaser/cleaner -
Table 4-30

User

Inhalation

All

5.2E-02

0.79

11

Dermal

21+

6.4E-02

9.5E-01

3.8

16-20

6.8E-02

1.0

4.1

11-15

6.2E-02

9.4E-01

3.7

Bystander

Inhalation

All

0.29

4.8

61

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Life Cycle

Stage/
Category

Subcategory/
Consumer
Condition of Use
Scenario

Population

Exposure
Route and
Duration

Age
Group

Acute Non-Cancer
(benchmark MOE = 30)

High-Intensity
User

Moderate-
Intensity User

Low-Intensity
User

Aerosol spray
degreaser/cleaner -
Table 4-31

User

Inhalation

All

1.2E-02

4.6E-02

0.31

Dermal

21+

3.8E-02

0.31

1.5

16-20

4.1E-02

0.33

1.6

11-15

3.7E-02

0.30

1.5

Bystander

Inhalation

All

4.9E-02

0.21

1.4

Liquid

degreaser/cleaner -
Table 4-32

User

Inhalation

All

1.3E-02

0.12

0.71

Dermal

21+

1.6E-02

0.13

0.96

16-20

1.7E-02

0.14

1.0

11-15

1.6E-02

0.13

0.94

Bystander

Inhalation

All

6.1E-02

0.70

4.3

Aerosol gun
scrubber -
Table 4-33

User

Inhalation

All

26

24

41

Dermal

21+

4.0E-02

0.32

4.0

16-20

4.2E-02

0.34

4.2

11-15

3.9E-02

0.31

3.9

Bystander

Inhalation

All

120

141

247

Liquid gun
scrubber -
Table 4-34

User

Inhalation

All

30

28

30

Dermal

21+

1.7E-02

0.14

1.0

16-20

1.8E-02

0.15

1.1

11-15

1.7E-02

0.13

1.0

Bystander

Inhalation

All

140

164

172

Mold Release -
Table 4-35

User

Inhalation

All

0.11

1.1

11

Bystander

Inhalation

All

0.64

6.4

61

Aerosol Tire Cleaner
- Table 4-36

User

Inhalation

All

0.13

0.46

3.3

Dermal

21+

0.17

0.70

3.0

16-20

0.19

0.74

3.2

11-15

0.17

0.68

2.9

Bystander

Inhalation

All

0.32

2.0

15

Liquid Tire Cleaner -
Table 4-37

User

Inhalation

All

4.2E-02

0.21

1.0

Dermal

21+

3.1E-02

0.12

0.37

16-20

3.3E-02

0.13

0.40

11-15

3.0E-02

0.12

0.37

Bystander

Inhalation

All

0.14

0.92

4.7

Consumer Use -
Lubricants and
greases

Tap and Die Fluid -
Table 4-38

User

Inhalation

All

0.13

1.2

6.8

Bystander

Inhalation

All

0.71

7.1

28



User

Inhalation

All

0.16

2.7

86

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Life Cycle

Stage/
Category

Subcategory/
Consumer
Condition of Use
Scenario

Penetrating lubricant
- Table 4-39

Population

Exposure
Route and
Duration

Age
Group

Acute Non-Cancer
(benchmark MOE = 30)

High-Intensity
User

Moderate-
Intensity User

Low-Intensity
User

Bystander

Inhalation

All

o.x9

l(.

4 <><¦

Consumer Use -
Adhesives and
sealants

Solvent-based
adhesives and
sealants -
Table 4-40

User

Inhalation

All

5.r. i-:-o2

I.S

:

si

Bystander

Inhalation

All

2.7

10

51'

Tire repair cement/
sealer -
Table 4-42

User

Inhalation

N/A

0.17

2.9



Bystander

Inhalation

N/A

0.57

13

1 v.

Consumer use -
Cleaning and
furniture care
products

Carpet cleaner -
Table 4-43

User

Inhalation

All

3.(.i:-02

0.29

\r

Dermal

21+

5.91.-02

0.35

7.1

16-20

(..3i:-02

0.3S

7.5

11-15

5.T.-02

0.35

(..9

Bystander

Inhalation

All

O.IS

\.->

9.0

Aerosol Spot
Remover -
Table 4-44

User

Inhalation

All

5.(.i:-02

0.4"7

3.2

Dermal

21+

0.50

3.0

30

16-20

0.53

3.2



11-15

0.49

2.9

29

Bystander

Inhalation

All

0.(.l

5.(>

}<)

Liquid Spot
Remover -
Table 4-45

User

Inhalation

All

4.7i:-02

0.39

3.4

Dermal

21+

X.5I-.-02

0.51

7.7

16-20

9.11-:-02

0.55

S.2

11-15

S.4i:-02

0.50

7.5

Bystander

Inhalation

All

0.2(»

2.4

19

Consumer use -
Arts, crafts, and
hobby materials

Fixatives and
finishing spray
coatings -
Table 4-46

User

Inhalation

All

0.20

1.2

(..4

Bystander

Inhalation

All

0.92



37

Consumer use -
Apparel and
footwear care
products

Shoe polish -
Table 4-47

User

Inhalation

All

0.55

5.4

'1

Dermal

21+

0.91

5.5

55

16-20

0.97

5.S

5X

11-15

0.S9

5.3

53

Bystander

Inhalation

All

3.1

33

ISO

Consumer use -
Other consumer
uses

Fabric spray -
Table 4-48

User

Inhalation

All

"7.2l-:-02

0.43

2.5

Bystander

Bystander

All

0.(.(.

5.1

23

Film cleaner -

User

Inhalation

All

3.0T-02

O.IS

0.93

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Life Cycle

Stage/
Category

Subcategory/
Consumer
Condition of Use
Scenario

Table 4-49

Population

Exposure
Route and
Duration

Age
Group

Acute Non-Cancer
(benchmark MOE = 30)

High-Intensity
User

Moderate-
Intensity User

Low-Intensity
User

Bystander

Bystander

All

0.13

I.I

5.4

Hoof polish -
Table 4-50

User

Inhalation

All

o.-»>

s.o

5<>

Bystander

Bystander

All

157

3653

22309

Pepper spray -
Table 4-51

User

Inhalation

All

98

Bystander

Toner aid -
Table 4-52

User

Inhalation

All

0.21

1.3

(..X

Bystander

Bystander

All

o.y

S.O

V)

a Inhalation exposures are based on a 2-zone model of air concentrations (Section \ V \4 1; lli.il ;nv nukpciuknl of any age-
specific exposure factors.

1739

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5 RISK DETERMINATION

5.1 Unreasonable Risk

5.1.1 Overview

In each risk evaluation under TSCA section 6(b), EPA determines whether a chemical substance
presents an unreasonable risk of injury to health or the environment, under the conditions of use. These
determinations do not consider costs or other non-risk factors. In making these determinations, EPA
considers relevant risk-related factors, including, but not limited to: the effects of the chemical substance
on health and human exposure to such substance under the conditions of use (including cancer and non-
cancer risks); the effects of the chemical substance on the environment and environmental exposure
under the conditions of use; the population exposed (including any potentially exposed or susceptible
subpopulations (PESS)); the severity of hazard (including the nature of the hazard, the irreversibility of
the hazard); and uncertainties. EPA also takes into consideration the Agency's confidence in the data
used in the risk estimate. This includes an evaluation of the strengths, limitations and uncertainties
associated with the information used to inform the risk estimate and the risk characterization. This
approach is in keeping with the Agency's final rule, Procedures for Chemical Risk Evaluation Under the
Amended Toxic Substances Control Act (82 FR 33726).20

Under TSCA, conditions of use are defined as the circumstances, as determined by the Administrator,
under which the substance is intended, known, or reasonably foreseen to be manufactured, processed,
distributed in commerce, used, or disposed of. TSCA §3(4).

An unreasonable risk may be indicated when health risks under the conditions of use are identified by
comparing the estimated risks with the risk benchmarks and where the risks affect the general
population or PESS, identified as relevant. For workers (which are one example of PESS), an
unreasonable risk may be indicated when risks are not adequately addressed through expected use of
workplace practices and exposure controls, including engineering controls or use of personal protective
equipment (PPE). An unreasonable risk may be indicated when environmental risks under the conditions
of use are greater than environmental risk benchmarks. The risk estimates contribute to the evidence
EPA uses to determine unreasonable risk.

EPA uses the term "indicates unreasonable risk" to indicate EPA concern for potential unreasonable
risk. For non-cancer endpoints, "less than MOE benchmark" is used to indicate potential unreasonable
risk; this occurs if an MOE value is less than the benchmark MOE (e.g.,, MOE 0.3 < benchmark MOE
30). For cancer endpoints, EPA uses the term "greater than risk benchmark" to indicate potential
unreasonable risk; this occurs, for example, if the lifetime cancer risk value is greater than 1 in 10,000
(e.g.,, cancer risk value is 5xl0"2 which is greater than the standard range of acceptable cancer risk
benchmarks of lxlO"4 to lxlO"6). For environmental endpoints, to indicate potential unreasonable risk
EPA uses a risk quotient (RQ) value "greater than 1" (i.e., RQ >1). Conversely, EPA uses the term
"does not indicate unreasonable risk" to indicate that it is unlikely that EPA has a concern for potential
unreasonable risk. More details are described below.

20 This risk determination is being issued under TSCA section 6(b) and the terms used, such as unreasonable risk, and the
considerations discussed are specific to TSCA. Other statutes have different authorities and mandates and may involve risk
considerations other than those discussed here.

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The degree of uncertainty surrounding the MOEs, cancer risk or RQs is a factor in determining whether
or not unreasonable risk is present. Where uncertainty is low, and EPA has high confidence in the
hazard and exposure characterizations (for example, the basis for the characterizations is measured or
monitoring data or a robust model and the hazards identified for risk estimation are relevant for
conditions of use), the Agency has a higher degree of confidence in its risk determination. EPA may also
consider other risk factors, such as severity of endpoint, reversibility of effect, or exposure-related
considerations, such as magnitude or number of exposures, in determining that the risks are
unreasonable under the conditions of use. Where EPA has made assumptions in the scientific evaluation,
whether or not those assumptions are protective will also be a consideration. Additionally, EPA
considers the central tendency and high-end scenarios when determining the unreasonable risk. High-
end risk estimates (i.e., 95th percentile) are generally intended to cover individuals or sub-populations
with greater exposure (PESS) and central tendency risk estimates are generally estimates of average or
typical exposure.

EPA may make a no unreasonable risk determination for conditions of use where the substance's hazard
and exposure potential, or where the risk-related factors described previously, lead EPA to determine
that the risks are not unreasonable.

5.1,2 Risks to Human Health

5,1.2,1 Determining Non-Cancer Risks

Margins of exposure (MOEs) are used in EPA's risk evaluations as a starting point to estimate non-
cancer risks for acute and chronic exposures. The non-cancer evaluation refers to potential adverse
health effects associated with health endpoints other than cancer, including to the body's organ systems,
such as reproductive/developmental effects, cardiac and lung effects, and kidney and liver effects. The
MOE is the point of departure (POD) (an approximation of the no-observed adverse effect level
(NOAEL) or benchmark dose level (BMDL)) for a specific health endpoint divided by the exposure
concentration for the specific scenario of concern. The benchmark for the MOE that is used accounts for
the total uncertainty in a POD, including, as appropriate: (1) the variation in sensitivity among the
members of the human population (i.e., intrahuman/intraspecies variability); (2) the uncertainty in
extrapolating animal data to humans (i.e., interspecies variability); (3) the uncertainty in extrapolating
from data obtained in a study with less-than-lifetime exposure to lifetime exposure (i.e., extrapolating
from subchronic to chronic exposure); and (4) the uncertainty in extrapolating from a lowest observed
adverse effect level (LOAEL) rather than from a NOAEL. MOEs can provide a non-cancer risk profile
by presenting a range of estimates for different non-cancer health effects for different exposure scenarios
and are a widely recognized point estimate method for evaluating a range of potential non-cancer health
risks from exposure to a chemical.

A calculated MOE that is less than the benchmark MOE indicates the possibility of risk to human health.
Whether those risks are unreasonable will depend upon other risk-related factors, such as severity of
endpoint, reversibility of effect, exposure-related considerations (e.g.,, duration, magnitude, frequency
of exposure, population exposed), and the confidence in the information used to inform the hazard and
exposure values. If the calculated MOE is greater than the benchmark MOE, generally it is less likely
that there is risk.

Uncertainty factors (UFs) also play an important role in the risk estimation approach and in determining
unreasonable risk. A lower benchmark MOE (e.g., 30) indicates greater certainty in the data (because
fewer of the default UFs relevant to a given POD as described above were applied). A higher benchmark

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MOE (e.g., 1000) would indicate more uncertainty in risk estimation and extrapolation for the MOE for
specific endpoints and scenarios. However, these are often not the only uncertainties in a risk evaluation.

5,1.2,2 Determining Cancer Risks

EPA estimates cancer risks by determining the incremental increase in probability of an individual in an
exposed population developing cancer over a lifetime (excess lifetime cancer risk (ELCR)) following
exposure to the chemical under specified use scenarios. Standard cancer benchmarks used by EPA and
other regulatory agencies are an increased cancer risk above benchmarks ranging from 1 in 1,000,000 to
1 in 10,000 (i.e., lxlO"6 to lxlO"4) depending on the subpopulation exposed. Generally, EPA considers 1
x 10"6 to lx 10"4 as the appropriate benchmark for the general population, consumer users, and non-
occupational PESS.21

For the subject chemical substance, the EPA, consistent with case law and 2017 NIOSH guidance,22
used 1 x 10"4 as the benchmark for the purposes of this risk determination for individuals in industrial
and commercial work environments subject to Occupational Safety and Health Act (OSHA)
requirements. It is important to note that lxlO"4 is not a bright line and EPA has discretion to make risk
determinations based on other benchmarks as appropriate. It is important to note that exposure-related
considerations (duration, magnitude, population exposed) can affect EPA's estimates of the excess
lifetime cancer risk.

5,1,3 Determining Environmental Risk

To assess environmental risk, EPA identifies and evaluates environmental hazard data for aquatic,
sediment-dwelling, and terrestrial organisms exposed under acute and chronic exposure conditions. The
environmental risk includes any risks that exceed benchmarks to the aquatic environment from levels of
the evaluated chemical released to the environment (e.g.,, surface water, sediment, soil, biota) under the
conditions of use, based on the fate properties, release potential, and reasonably available environmental
monitoring and hazard data.

Environmental risks are estimated by calculating a RQ. The RQ is defined as:

RQ = Environmental Concentration / Effect Level

An RQ equal to 1 indicates that the exposures are the same as the concentration that causes effects. If the
RQ is greater than 1, the exposure is greater than the effect concentration and there is potential for risk
presumed. If the RQ is less than 1, the exposure is less than the effect concentration and unreasonable
risk is not likely. The Concentrations of Concern (COC) or hazard value for certain aquatic organisms
are used to calculate RQs for acute and chronic exposures. For environmental risk, EPA is more likely to

21	As an example, whenEPA's Office of Water in 2017 updated the Human Health Benchmarks for Pesticides, the
benchmark for a "theoretical upper-bound excess lifetime cancer risk" from pesticides in drinking water was identified as 1 in
1,000,000 to 1 in 10,000 over a lifetime of exposure (EPA. Human Health Benchmarks for Pesticides: Updated 2017
Technical Document. January 2017. https://www.epa.gov/sites/production/files/2015-10/documents/hh-benchmarks-
techdoc.pdf). Similarly, EPA's approach under the Clean Air Act to evaluate residual risk and to develop standards is a two-
step approach that includes a "presumptive limit on maximum individual lifetime [cancer] risk (MIR) of approximately 1 in
10 thousand" and consideration of whether emissions standards provide an ample margin of safety to protect public health "in
consideration of all health information, including the number of persons at risk levels higher than approximately 1 in 1
million, as well as other relevant factors" (54 FR 38044, 38045, September 14, 1989).

22	International Union, UAW v. Pendergrass, 878 F.2d 389 (D.C. Cir. 1989), citing Industrial Union Department, AFL-CIO v.
American Petroleum Institute, 448 U.S. 607 (1980) ("Benzene decision"), in which it was found that a lifetime cancer risk of
1 in 1,000 was found to be clearly significant; and NIOSH (Whittaker et at. 20.1.6). Current intelligence bulletin 68: NIOSH
chemical carcinogen policy, available at https://www.cdc. gov/n.iosIi/docs/20.1.7-.1.00/p(lK	).pdf.

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determine that there is unreasonable risk if the RQ exceeds 1 for the conditions of use being evaluated.
Consistent with EPA's human health evaluations, the RQ is not treated as a bright line and other risk-
based factors may be considered (e.g., exposure scenario, uncertainty, severity of effect) for purposes of
making a risk determination.

5,2 Risk Determinations for TCE

EPA's preliminary determinations of unreasonable risk for specific conditions of use of TCE listed
below are based on health risks to workers and occupational non-users (ONUs) during occupational
exposures, and to consumers and bystanders during exposures to consumer uses.

As described in section 4, significant risks associated with more than one adverse effect (e.g.,
developmental toxicity, reproductive toxicity, liver toxicity, kidney toxicity, immunotoxicity,
neurotoxicity, and cancer) were identified for particular conditions of use. While congenital heart
defects were the most sensitive endpoint for TCE, for the purpose of the draft risk determination, there
are uncertainties which decrease EPA's confidence in this endpoint. Section 26 of TSCA requires that
EPA make decisions consistent with the "best available science." Section 26 also requires other
scientific considerations including consideration of the "extent of independent verification" and "weight
of the scientific evidence." As described in EPA's framework rule for risk evaluation [82 FR 33726]
weight of the scientific evidence includes consideration of the "strengths, limitations and relevance of
the information." Neither the statute nor the framework rule require that EPA choose the lowest number
and EPA believes that public health is best served when EPA relies upon the highest quality information
for which EPA has the greatest confidence. Based on these considerations, EPA is relying upon
immunosuppression for acute inhalation and dermal exposures, and autoimmunity for chronic inhalation
and dermal exposures. In Table 5-1 and Section 5.3 below, EPA has identified immunosuppression and
autoimmunity as the critical endpoints for determining whether or not a condition of use presents
unreasonable risks. EPA has the most confidence in these endpoints and it is expected that addressing
risks for these effects would address other identified risks. For the majority of the occupational and
consumer conditions of use, unreasonable risk determinations were consistent whether based on
congenital heart defects (an endpoint for which EPA has lower confidence) or immunosuppression and
autoimmunity endpoints.

•	Workers: EPA evaluated workers' acute and chronic inhalation and dermal exposures for cancer
and non-cancer risks and determined whether any risks are unreasonable. The drivers for EPA's
determination of unreasonable risk for workers are immunosuppression resulting from acute
inhalation and dermal exposures, autoimmunity resulting from chronic inhalation and dermal
exposures, and cancer resulting from chronic inhalation and dermal exposure. The
determinations reflect the severity of the effects associated with the occupational exposures to
TCE and incorporate consideration of expected PPE. EPA expects there is compliance with
federal and state laws, such as worker protection standards, unless case-specific facts indicate
otherwise, and therefore existing OSHA regulations for worker protection and hazard
communication will result in use of appropriate PPE consistent with the applicable SDSs.
Estimated numbers of workers are in Section 2.3.1.2.7.

•	Occupational Non-Users (ONUs): EPA evaluated ONU acute and chronic inhalation exposures
for cancer and non-cancer risks and determined whether any risks are unreasonable. EPA
considers occupational non-users to be a subset of workers for whom the potential inhalation
exposures may differ based on proximity to the exposure source. The drivers for EPA's
determination of unreasonable risks to ONUs are immunosuppression resulting from acute

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inhalation exposures, autoimmunity resulting from chronic inhalation exposures, and cancer
resulting from chronic inhalation exposure. The determinations reflect the severity of the effects
associated with the occupational exposures to TCE and the expected absence of PPE for ONUs.
For dermal exposures, because ONUs are not expected to be dermally exposed to TCE, dermal
risks to ONUs generally were not evaluated. For inhalation exposures, EPA, where possible,
used monitoring or modeling information to estimate ONU exposures and to describe the risks
separately from workers directly exposed. For some conditions of use, EPA did not separately
calculate risk estimates for ONUs and workers. For these conditions of use, there is uncertainty
in the ONU risk estimates since the data or modeling did not distinguish between worker and
ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower than
inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this
uncertainty, EPA considered the central tendency risk estimate when determining ONU risk for
those conditions of use for which ONU exposures were not separately estimated. Estimated
numbers of occupational non-users are in Section 2.3.1.2.7.

•	Consumers: EPA evaluated consumer acute inhalation and dermal exposures for non-cancer risks
and determined whether any risks are unreasonable. The driver for EPA's determination of
unreasonable risk is immunosuppression from acute inhalation and dermal exposures. Generally,
risks for consumers were indicated by acute inhalation and dermal exposure at low, medium, and
high intensity use. Estimated numbers of consumers are in Section 2.3.1.2.7.

•	Bystanders (from consumer uses): EPA evaluated bystander acute inhalation exposures for non-
cancer risks and determined whether any risks are unreasonable. The driver for EPA's
determination of unreasonable risk is immunosuppression from acute inhalation exposure.
Generally, risks for bystanders were indicated by acute inhalation exposure scenarios at low,
medium, and high intensity use. Because bystanders are not expected to be dermally exposed to
TCE, dermal non-cancer risks to bystanders were not evaluated. Estimated numbers of
bystanders are in Section 2.3.1.2.7.

As described below, risks to the environment and general population either were not relevant for these
conditions of use or were evaluated and not found to be unreasonable. For the conditions of use where
EPA found no unreasonable risk, EPA describes the estimated risks in Section 4.5.2 (Table 4-54 and
Table 4-55).

• Environmental risks: EPA concluded that environmental exposures are expected for aquatic

species for the conditions of use within the scope of the evaluation. EPA identified risks from acute
and chronic exposures for aquatic organisms like aquatic invertebrates and fish near two facilities
releasing TCE to surface water and risks to the most sensitive algae species near over 400 facilities.
EPA did not identify any additional scenarios indicating unreasonable risk for aquatic organisms
from exposures to TCE in surface waters. For aquatic organisms like aquatic invertebrates and fish,
one facility had an acute RQ greater than 1 (RQ = 3.11), exceeding the acute COC of 3,200 ppb and
indicating risk to aquatic organisms from acute exposures. This facility is one of 59 facilities
modeled by EPA that use TCE for open-top vapor degreasing (see Section 4.5.1). Another facility
had an acute RQ of 0.94 indicating some uncertainty about whether it would also pose risks to
aquatic organisms from acute exposures. This facility is one of 11 facilities modeled by EPA that
process TCE as a reactant (see Section 4.5.1). Both facilities had chronic RQs greater than 1,
exceeding the chronic COC of 788 ppb for 20 days. The over 400 facilities with potential risks to the

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217	most sensitive algae species (exceeding the algae COC of 3 ppb) did not show risks for algae species

218	as a whole, as they showed no risks for 95% of algae species (no exceedances of the algae COC of

219	52,000 ppb). Monitored data from the Water Quality Portal and grey literature show no exceedances

220	of the acute COC and the chronic COC in ambient water. Monitored data from literature showed

221	some exceedances of the algae COC of 3 ppb in ambient water; however, the data show no

222	exceedances of the algae COC of 52,000 ppb. Therefore, EPA did not identify risks for acute or

223	chronic exposure durations in ambient water for areas where monitored data were reasonably

224	available. Given the uncertainties in the modeling data and exceedance of the acute RQ for only one

225	data point and of the chronic RQ for only two out of 70 facilities modeled, EPA does not consider

226	these risks unreasonable (see Section 4.5.2).

227

228	• General population: Exposure pathways to the general population are covered by other statutes and

229	consist of: the ambient air pathway (i.e., TCE is listed as a HAP in the Clean Air Act (CAA)), the

230	drinking water pathway (i.e., National Primary Drinking Water Regulations (NPDWRs) are

231	promulgated for TCE under the Safe Drinking Water Act), ambient water pathways (i.e., TCE is a

232	priority pollutant with recommended water quality criteria for protection of human health under the

233	CWA), the biosolids pathway (i.e., the biosolids pathway for TCE is currently being addressed in the

234	CWA regulatory analytical process), disposal pathways (TCE disposal is managed and prevented

235	from further environmental release by RCRA and SDWA regulations). As described above, other

236	environmental statutes administered by EPA adequately assess and effectively manage these

237	exposures. EPA believes that the TSCA risk evaluation should focus on those exposure pathways

238	associated with TSCA conditions of use that are not subject to the regulatory regimes discussed

239	above because those pathways are likely to represent the greatest areas of concern to EPA.

240	Therefore, EPA did not evaluate hazards or exposures to the general population in this risk

241	evaluation, and there is no risk determination for the general population (U.S. EPA. 2018d).

242

243	Table 5-1 below presents an overview of risk determinations by condition of use. An in-depth

244	explanation of each determination follows the table, in Section 5.3.

245

246	Table 5-1. Summary of Unreasonable Risk Determinations by Condition of Use	

Condition of Use

Unreasonable Risk Determination

Manufacture - Domestic Manufacture

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Manufacture - Import (includes repackaging and
loading/unloading)

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

Processing - Processing as a reactant/intermediate in
industrial gas manufacturing (e.g., manufacture of
fluorinated gases used as refrigerants, foam blowing
agents and solvents)

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Processing - Incorporation into formulation, mixture or
reaction product - Solvents (for cleaning or degreasing);
adhesives and sealant chemicals; solvents (which
become part of product formulation or mixture) (e.g.,
lubricants and greases, paints and coatings, other uses)

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

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Condition of Use

Unreasonable Risk Determination

Processing - Incorporation into articles - Solvents
(becomes an integral components of articles)

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

Processing - Repackaging - Solvents (for cleaning or
degreasing)

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

Processing - Recycling

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

Distribution in Commerce

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - Batch vapor degreaser (open-top)

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - Batch vapor degreaser (closed-loop)

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - In-line vapor degreaser (conveyorized)

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - In-line vapor degreaser (web cleaner)

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - Cold cleaner

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Solvents (for cleaning or
degreasing) - Aerosol spray degreaser/cleaner; mold
release

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Lubricants and
greases/lubricants and lubricant additives - Tap and die
fluid

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Lubricants and
greases/lubricants and lubricant additives - Penetrating
lubricant

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Adhesives and sealants -
Solvent-based adhesives and sealants; tire repair
cement/sealer; mirror edge sealant

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Functional fluids (closed
systems) - Heat exchange fluid

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Paints and coatings -
Diluent in solvent-based paints and coatings

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

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Condition of Use

Unreasonable Risk Determination

Industrial/Commercial Use - Cleaning and furniture
care products - Carpet cleaner; wipe cleaner

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Laundry and dishwashing
products - Spot remover

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Arts, crafts and hobby
materials - Fixatives and finishing spray coatings

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Corrosion inhibitors and
anti-scaling agents - Corrosion inhibitors and anti-
scaling agents

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Processing aids - Process
solvent used in battery manufacture; process solvent
used in polymer fiber spinning, fluoroelastomer
manufacture, and Alcantara manufacture; extraction
solvent used in caprolactam manufacture; precipitant
used in beta-cyclodextrin manufacture

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Ink, toner and colorant
products - Toner aid

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Automotive care products
- Brake and parts cleaners

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Apparel and footwear care
products - Shoe polish

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Industrial/Commercial Use - Other commercial uses -
Hoof polishes; gun scrubber; pepper spray; other
miscellaneous industrial and commercial uses

Presents an unreasonable risk of injury to health
(workers and occupational non-users)

Disposal

Presents an unreasonable risk of injury to health
(workers)

Does not present an unreasonable risk of injury to
health (occupational non-users)

Consumer Use - Solvents (for cleaning or degreasing) -
Brake and parts cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Aerosol electronic degreaser/cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Liquid electronic degreaser/cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Aerosol spray degreaser/cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Liquid degreaser/cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

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Condition of Use

Unreasonable Risk Determination

Consumer Use - Solvents (for cleaning or degreasing) -
Aerosol gun scrubber

Presents an unreasonable risk of injury to health
(consumers)

Does not present an unreasonable risk of injury to
health (bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Liquid gun scrubber

Presents an unreasonable risk of injury to health
(consumers)

Does not present an unreasonable risk of injury to
health (bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Mold release

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Aerosol tire cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Solvents (for cleaning or degreasing) -
Liquid tire cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Lubricants and greases - Tap and die
fluid

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Lubricants and greases - Penetrating
lubricant

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Adhesives and sealants - Solvent-
based adhesive and sealant

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Adhesives and sealants - Mirror edge
sealant

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Adhesives and sealants - Tire repair
cement/sealer

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Cleaning and furniture care products -
Carpet cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Cleaning and furniture care products -
Aerosol spot remover

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Cleaning and furniture care products -
Liquid spot remover

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Arts, crafts, and hobby materials -
Fixatives and finishing spray coatings

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Apparel and footwear care products -
Shoe polish

Presents an unreasonable risk of injury to health
(consumers)

Does not present an unreasonable risk of injury to
health (bystanders)

Consumer Use - Other consumer uses - Fabric spray

Presents an unreasonable risk of injury to health
(consumers and bystanders)

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Condition of Use

Unreasonable Risk Determination

Consumer Use - Other consumer uses - Film cleaner

Presents an unreasonable risk of injury to health
(consumers and bystanders)

Consumer Use - Other consumer uses - Hoof polish

Presents an unreasonable risk of injury to health
(consumers)

Does not present an unreasonable risk of injury to
health (bystanders)

Consumer Use - Other consumer uses - Pepper spray

Does not present an unreasonable risk of injury to
health (consumers)

Consumer Use - Other consumer uses - Toner aid

Presents an unreasonable risk of injury to health
(consumers and bystanders)

247 5.3 Detailed Risk Determinations by Condition of Use

248	5.3.1 Manufacture - Domestic manufacture

249

250	Section 6(b)(4)(A) unreasonable risk determination for domestic manufacture of TCE:

251	• Presents an unreasonable risk of injury to health (workers and occupational non-users

252	(ONUs)).

253

254	Unreasonable risk driver - workers:

255	• Immunosuppression resulting from acute dermal exposures.

256	• Autoimmunity resulting from chronic inhalation and dermal exposures.

257	• Cancer resulting from chronic inhalation and dermal exposures.

258

259	Unreasonable risk driver - ONUs:

260	~ Immunosuppression resulting from acute inhalation exposures.

261	• Autoimmunity resulting from chronic inhalation exposures.

262	• Cancer resulting from chronic inhalation exposures.

263

264	Driver benchmarks - workers and ONUs:

265	• Immunosuppression: Benchmark MOE = 30.

266	• Autoimmunity: Benchmark MOE = 30.

267	• Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

268

269	Risk estimate - workers:

270	• Immunosuppression:

271	o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-6)

272	• Autoimmunity:

273	o Chronic inhalation MOEs 19.3 and 2.8 (central tendency and high-end) with PPE

274	(respirator APF 50).

275	o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF

276	20). (Table 4-6)

277	• Cancer:

278	o Inhalation: 1.3E-04 (high-end) with PPE (respirator APF 50).

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o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-6)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 13.9 (central tendency). (Table 4-6)

•	Autoimmunity:

o Chronic inhalation MOE 0.39 (central tendency). (Table 4-6)

•	Cancer:

o Inhalation: 7.5E-04 (central tendency). (Table 4-6)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, while non-cancer risk estimates for acute
inhalation exposures do not indicate risks with expected respiratory protection (APF 50), all other risk
estimates indicate risk even with expected respiratory and dermal protection. EPA did not separately
calculate risk estimates for ONUs and workers. There is uncertainty in the ONU risk estimate since the
data did not distinguish between worker and ONU inhalation exposure estimates. ONU inhalation
exposures are expected to be lower than inhalation exposures for workers directly handling the chemical
substance; however, the relative exposure of ONUs to workers in these cases cannot be quantified. To
account for this uncertainty, EPA considered the central tendency estimate when determining ONU risk.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA assessed inhalation exposures during manufacturing using monitoring data
submitted by the Halogenated Solvents Industry Alliance (HSIA). EPA estimated dermal exposures
using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably
available for the condition of use.

Life Cycle Stage

Category

Subcategory

Manufacture

Domestic Manufacture

Domestic manufacture

5.3.2 Manufacture - Import (includes repackaging and loading/unloading)

Section 6(b)(4)(A) unreasonable risk determination for import of TCE:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

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•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-19)

•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-19)

•	Cancer:

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-19)

Risk Considerations: For workers, while non-cancer risk estimates for acute inhalation exposures and
cancer risk estimates for inhalation exposures do not indicate risks with expected respiratory protection
(APF 50), all other risk estimates indicate risk even with expected respiratory and dermal protection.
Acute and chronic inhalation exposures at the central tendency for cancer and non-cancer effects do not
indicate risks in the absence of PPE. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA
assessed inhalation exposures during import using the repackaging exposure scenario. EPA estimated
dermal exposures using the Dermal Exposure to Volatile Liquids Model because dermal exposure data
was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Manufacture

Import

Import

5,3,3 Processing - Processing as a reactant/intermediate in industrial gas manufacturing
(e.g., manufacture of fluorinated gases used as refrigerants, foam blowing agents
and solvents)

Section 6(b)(4)(A) unreasonable risk determination for processing of TCE as a reactant/intermediate:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

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•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-7)

•	Autoimmunity:

o Chronic inhalation MOEs 19.3 and 2.8 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-7)

•	Cancer:

o Inhalation: 1.3E-04 (high-end) with PPE (respirator APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-7)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 13.9 (central tendency). (Table 4-7)

•	Autoimmunity:

o Chronic inhalation MOE 0.39 (central tendency). (Table 4-7)

•	Cancer:

o Inhalation: 7.5E-04 (central tendency). (Table 4-7)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, while non-cancer risk estimates for acute
inhalation exposures do not indicate risks with expected respiratory protection (APF 50), all other risk
estimates indicate risk even with expected respiratory and dermal protection (PF = 20). EPA did not
separately calculate risk estimates for ONUs and workers. There is uncertainty in the ONU risk estimate
since the data did not distinguish between worker and ONU inhalation exposure estimates. ONU
inhalation exposures are expected to be lower than inhalation exposures for workers directly handling
the chemical substance; however, the relative exposure of ONUs to workers in these cases cannot be
quantified. To account for this uncertainty, EPA considered the central tendency estimate when
determining ONU risk. The high volatility of TCE and potentially severe effects from short term
exposure are factors when weighing uncertainties. EPA did not identify inhalation exposure monitoring
data related to processing TCE as a reactant. Therefore, EPA used monitoring data from the manufacture
of TCE as surrogate data for the processing condition of use. EPA believes the handling and TCE
concentrations for both conditions of use to be similar. EPA estimated dermal exposures using the
Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available
for the condition of use.

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Life Cycle Stage

Category

Subcategory

Processing

Processing as a Reactant/
Intermediate

Intermediate in industrial gas
manufacturing (e.g., manufacture of
fluorinated gases used as refrigerants,
foam blowing agents and solvents)

5.3.4 Processing - Incorporation into formulation, mixture or reaction product - Solvents
(for cleaning or degreasing); adhesives and sealant chemicals; solvents (which
become part of product formulation or mixture) (e.g., lubricants and greases, paints
and coatings, other uses)

Section 6(b)(4)(A) unreasonable risk determination for incorporation of TCE into formulation, mixture,
reaction product, or articles:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-18)

•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).
o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-18)

•	Cancer:

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-18)

Risk Considerations: For workers, while non-cancer risk estimates for acute inhalation exposures and
cancer risk estimates for inhalation exposures do not indicate risks with expected respiratory protection
(APF 50), all other risk estimates indicate risk even with expected respiratory and dermal protection.
Acute and chronic inhalation exposures at the central tendency for cancer and non-cancer effects do not
indicate risks in the absence of PPE. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower

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than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA did
not identify inhalation exposure monitoring data related to using TCE when formulating aerosol and
non-aerosol products. Therefore, EPA used monitoring data from repackaging as a surrogate. EPA
estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model because dermal
exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Processing

Processing - Incorporation
into formulation, mixture or
reaction product

•	Solvents (for cleaning or
degreasing)

•	Adhesives and sealant
chemicals

•	Solvents (which become part of
product formulation or mixture)
(e.g., lubricants and greases,
paints and coatings, other uses)

5.3.5 Processing - Incorporation into articles - Solvents (becomes an integral components
of articles)

Section 6(b)(4)(A) unreasonable risk determination for incorporation of TCE into articles as solvents
that become integral components of articles:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-18)

•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).
o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-18)

•	Cancer:

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o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-18)

Risk Considerations: For workers, while non-cancer risk estimates for acute inhalation exposures and
cancer risk estimates for inhalation exposures do not indicate risks with expected respiratory protection
(APF 50), all other risk estimates indicate risk even with expected respiratory and dermal protection.
Acute and chronic inhalation exposures at the central tendency for cancer and non-cancer effects do not
indicate risks in the absence of PPE. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA did
not identify inhalation exposure monitoring data related using TCE when formulating aerosol and non-
aerosol products. Therefore, EPA used monitoring data from repackaging as a surrogate. EPA estimated
dermal exposures using the Dermal Exposure to Volatile Liquids Model because dermal exposure data
was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Processing

Processing - incorporated
into articles

Solvents (becomes an integral
components of articles)

5.3.6 Processing - Repackaging - Solvents (for cleaning or degreasing)

Section 6(b)(4)(A) unreasonable risk determination for processing and repackaging of TCE as a solvent
for cleaning or degreasing:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-19)

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•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-19)

•	Cancer:

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-19)

Risk Considerations: For workers, while non-cancer risk estimates for acute inhalation exposures and
cancer risk estimates for inhalation exposures do not indicate risks with expected respiratory protection
(APF 50), all other risk estimates indicate risk even with expected respiratory and dermal protection.
Acute and chronic inhalation exposures at the central tendency for cancer and non-cancer effects do not
indicate risks in the absence of PPE. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA
assessed inhalation exposures during import using the repackaging exposure scenario. EPA estimated
dermal exposures using the Dermal Exposure to Volatile Liquids Model because dermal exposure data
was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Processing

Processing - repackaging

Solvents (for cleaning or degreasing)

5,3,7 Processing - Recycling

Section 6(b)(4)(A) unreasonable risk determination for recycling of TCE:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-27)

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•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-27)

•	Cancer:

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-27)

Risk Considerations: For workers, while non-cancer risk estimates for acute inhalation exposures and
cancer risk estimates for inhalation exposures do not indicate risks with expected respiratory protection
(APF 50), all other risk estimates indicate risk even with expected respiratory and dermal protection.
Acute and chronic inhalation exposures at the central tendency for cancer and non-cancer effects do not
indicate risks in the absence of PPE. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA did
not identify inhalation exposure monitoring data related to using TCE when formulating aerosol and
non-aerosol products. Therefore, EPA used monitoring data from repackaging as a surrogate for
recycling. EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model
because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Processing

Recycling

Recycling

5.3.8 Distribution in Commerce

Section 6(b)(4)(A) unreasonable risk determination for distribution of TCE:

• Presents an unreasonable risk of injury to health (workers and occupational non-users).

Risk Considerations: A quantitative evaluation of the distribution of TCE was not included in the risk
evaluation because exposures and releases from distribution were considered within each condition of
use.

Life Cycle Stage

Category

Subcategory

Distribution in commerce

Distribution

Distribution in commerce

5.3.9 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Batch vapor
degreaser (open-top)

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for batch vapor degreasing (open-top):

• Presents an unreasonable risk of injury to health (workers and occupational non-users).

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Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 18.9 and 3.4 (central tendency and high-end) with PPE

(respirator APF 50).
o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-8)

•	Autoimmunity:

o Chronic inhalation MOEs 0.52 and 9.3E-02 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-8)

•	Cancer:

o Inhalation: 5.5E-04 and 4.0E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-8)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 4.7 (central tendency). (Table 4-8)

•	Autoimmunity:

o Chronic inhalation MOE 0.13 (central tendency). (Table 4-8)

•	Cancer:

o Inhalation: 2.2E-03 (central tendency). (Table 4-8)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from NIOSH investigations at twelve sites using TCE as a degreasing solvent in
OTVDs. Due to the large variety in shop types that may use TCE as a vapor degreasing solvent, it is
unclear how representative these data are of a "typical" shop. Therefore, EPA supplemented the

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identified monitoring data using the Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation
Exposure Model. EPA's inhalation exposure modeling is based on a near-field/far-field approach, where
a vapor generation source located inside the near-field diffuses into the surrounding environment.
Workers are assumed to be exposed to TCE vapor concentrations in the near-field, while occupational
non-users are exposed at concentrations in the far-field. These estimates were used for determining
worker and ONU risks. For workers, EPA estimated dermal exposures using the Dermal Exposure to
Volatile Liquids Model because dermal exposure data was not reasonably available for the condition of
use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

Batch vapor degreaser (open-top)

5.3.10 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Batch vapor
degreaser (closed-loop)

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for batch vapor degreasing (closed-loop):

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-10)

•	Autoimmunity:

o Chronic inhalation MOEs 15.8 and 5.0 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-10)

•	Cancer:

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o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-10)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 11.4 (central tendency). (Table 4-10)

•	Autoimmunity:

o Chronic inhalation MOE 0.32 (central tendency). (Table 4-10)

•	Cancer (liver, kidney, NHL):

o Inhalation: 9.1E-04 (central tendency). (Table 4-10)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, while non-cancer risk estimates for acute
inhalation exposures and cancer risk estimates for inhalation exposures do not indicate risks with
expected respiratory protection (APF 50), all other risk estimates indicate risk even with expected
respiratory and dermal protection. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA
identified inhalation exposure monitoring data from a European Chemical Safety report using TCE in
closed degreasing operations. EPA estimated dermal exposures using the Dermal Exposure to Volatile
Liquids Model because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

Batch vapor degreaser (closed-loop)

5.3.11 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - In-line vapor
degreaser (conveyorized)

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for in-line vapor degreasing (conveyorized):

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

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Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 8.1 and 5.4 (central tendency and high-end) with PPE (respirator
APF 50).

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-11)

•	Autoimmunity:

o Chronic inhalation MOEs 0.22 and 0.15 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-11)

•	Cancer (liver, kidney, NHL):

o Inhalation: 1.3E-03 and 2.5E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-11)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 0.16 (central tendency). (Table 4-11)

•	Autoimmunity:

o Chronic inhalation MOE 4.5E-03 (central tendency). (Table 4-11)

•	Cancer (liver, kidney, NHL):

o Inhalation: 6.5E-02 (central tendency). (Table 4-11)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection (APF 50 and PF = 20). The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA
identified inhalation exposure monitoring data from NIOSH investigations at two sites using TCE in
conveyorized degreasing. Due to the large variety in shop types that may use TCE as a vapor degreasing
solvent, it is unclear how representative these data are of a "typical" shop. Therefore, EPA supplemented
the identified monitoring data using the Conveyorized Degreasing Near-Field/Far-Field Inhalation
Exposure Model. For workers, EPA estimated dermal exposures using the Dermal Exposure to Volatile
Liquids Model because dermal exposure data was not reasonably available for this condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

In-line vapor degreaser (conveyorized)

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5,3,12 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - In-line vapor
degreaser (web cleaner)

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for in-line vapor degreaser (web cleaner):

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 18.5 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-13)

•	Autoimmunity:

o Chronic inhalation MOEs 1.2 and 0.51 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-13)

•	Cancer:

o Inhalation: 2.3E-04 and 5.8E-04 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-13)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 1.7 (central tendency). (Table 4-13)

•	Autoimmunity:

o Chronic inhalation MOE 4.6E-02 (central tendency). (Table 4-13)

•	Cancer:

o Inhalation: 5.9E-03 (central tendency). (Table 4-13)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with

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expected respiratory and dermal protection (APF 50 and PF = 20). The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA did
not identify any inhalation exposure monitoring data related to the use of TCE in web degreasing.
Therefore, EPA assessed inhalation exposures during web degreasing using the Web Degreasing Near-
Field/Far-Field Inhalation Exposure Model. EPA's inhalation exposure modeling is based on a near-
field/far-field approach, where a vapor generation source located inside the near-field diffuses into the
surrounding environment. Workers are assumed to be exposed to TCE vapor concentrations in the near-
field, while occupational non-users are exposed at concentrations in the far-field. These estimates were
used for determining worker and ONU risks. For workers, EPA estimated dermal exposures using the
Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available
for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

In-line vapor degreaser (web cleaner)

5.3.13 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Cold cleaner

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for cold cleaning:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 4.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-14)

•	Autoimmunity:

o Chronic inhalation MOEs 2.2 and 0.13 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-14)

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•	Cancer:

o Inhalation: 1.2E-04 and 2.3E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-14)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 2.8 (central tendency). (Table 4-14)

•	Autoimmunity:

o Chronic inhalation MOE 7.9E-02 (central tendency). (Table 4-14)

•	Cancer:

o Inhalation: 3.3E-03 (central tendency). (Table 4-14)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA did not identify inhalation
exposure monitoring data for the Cold Cleaning condition of use. Therefore, EPA used the Cold
Cleaning Near-Field/Far-Field Inhalation Exposure Model to estimate exposures to workers and ONUs.
EPA's inhalation exposure modeling is based on a near-field/far-field approach, where a vapor
generation source located inside the near-field diffuses into the surrounding environment. Workers are
assumed to be exposed to TCE vapor concentrations in the near-field, while occupational non-users are
exposed at concentrations in the far-field. These estimates were used for determining worker and ONU
risks. For workers, EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids
Model because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

Cold cleaner

5,3.14 Industrial/Commercial Use - Solvents (for cleaning or degreasing) - Aerosol spray
degreaser/cleaner; mold release

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a solvent
for aerosol spray degreaser/cleaner and for mold release:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

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•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 15.1 (high-end) with PPE (gloves PF 20). (Table 4-15)

•	Autoimmunity:

o Chronic inhalation MOEs 0.95 and 0.30 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.2 and 0.39 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-15)

•	Cancer:

o Inhalation: 2.9E-04 and 9.7E-04 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 7.6E-04 and 2.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-15)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.0 (high-end). (Table 4-15)

•	Autoimmunity:

o Chronic inhalation MOE 1.0 (central tendency). (Table 4-15)

•	Cancer:

o Inhalation: 2.6E-04 (central tendency). (Table 4-15)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection (APF=50 and PF=20). EPA estimated ONU exposures could
be as high as worker exposures as a high-end estimate. The high volatility of TCE and potentially severe
effects from short term exposure are factors when weighing uncertainties. EPA did not identify
inhalation exposure monitoring data related to the use of TCE in aerosol degreasers. Therefore, EPA
estimated inhalation exposures using the Brake Servicing Near-field/Far-field Exposure Model. EPA's
inhalation exposure modeling is based on a near-field/far-field approach, where a vapor generation
source located inside the near-field diffuses into the surrounding environment. Workers are assumed to
be exposed to TCE vapor concentrations in the near-field, while occupational non-users are exposed at
concentrations in the far-field. These estimates were used for determining worker and ONU risks. For
workers, EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model
because dermal exposure data was not reasonably available for the condition of use.

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Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Solvents (for cleaning or
degreasing)

•	Aerosol spray degreaser/cleaner

•	Mold release

5.3.15 Industrial/Commercial Use - Lubricants and greases/lubricants and lubricant
additives - Tap and die fluid

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a lubricant
grease/lubricant, and lubricant additive in tap and die fluid:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Unreasonable risk driver - ONUs:

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 29.7 (high-end) with PPE (gloves PF 20). (Table 4-21)

•	Autoimmunity:

o Chronic inhalation MOE 27.5 (high-end) with PPE (respirator APF 50).
o Chronic dermal MOEs 2.3 and 0.76 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-21)

•	Cancer:

o Dermal: 3.9E-04 and 1.5E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-21)

Risk estimate - ONUs:

•	Autoimmunity:

o Chronic inhalation MOE 2.1 (central tendency). (Table 4-21)

•	Cancer:

o Inhalation: 1.3E-04 (central tendency). (Table 4-21)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE, with the exception of acute inhalation exposures at the central
tendency. For workers, while non-cancer risk estimates for acute inhalation exposures and cancer risk

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estimates from inhalation exposures do not indicate risks with expected respiratory protection (APF 50),
all other risk estimates indicate risk even with expected respiratory and dermal protection. EPA did not
separately calculate risk estimates for ONUs and workers. There is uncertainty in the ONU risk estimate
since the data did not distinguish between worker and ONU inhalation exposure estimates. ONU
inhalation exposures are expected to be lower than inhalation exposures for workers directly handling
the chemical substance; however, the relative exposure of ONUs to workers in these cases cannot be
quantified. To account for this uncertainty, EPA considered the central tendency estimate when
determining ONU risk. The high volatility of TCE and potentially severe effects from short term
exposure are factors when weighing uncertainties. EPA identified inhalation exposure monitoring data
from OSHA facility inspections at two sites using TCE in metalworking fluids. EPA estimated dermal
exposures using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not
reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Lubricants and
greases/lubricants and
lubricant additives

Tap and die fluid

5.3.16 Industrial/Commercial Use - Lubricants and greases/lubricants and lubricant
additives - Penetrating lubricant

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as penetrating
lubricant:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 15.1 (high-end) with PPE (gloves PF 20). (Table 4-15)

•	Autoimmunity:

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o Chronic inhalation MOEs 0.95 and 0.30 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.2 and 0.39 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-15)

•	Cancer:

o Inhalation: 2.9E-04 and 9.7E-04 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 7.6E-04 and 2.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-15)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.0 (high-end). (Table 4-15)

•	Autoimmunity:

o Chronic inhalation MOE 1.0 (central tendency). (Table 4-15)

•	Cancer:

o Inhalation: 2.6E-04 (central tendency). (Table 4-15)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. EPA estimated ONU exposures could be as high as worker
exposures as a high-end estimate. The high volatility of TCE and potentially severe effects from short
term exposure are factors when weighing uncertainties. EPA did not identify inhalation exposure
monitoring data related to the use of TCE in aerosol degreasers. Therefore, EPA estimated inhalation
exposures using the Brake Servicing Near-field/Far-field Exposure Model. EPA estimated dermal
exposures using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not
reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Lubricants and
greases/lubricants and
lubricant additives

Penetrating lubricant

5.3.17 Industrial/Commercial Use - Adhesives and sealants - Solvent-based adhesives and
sealants; tire repair cement/sealer; mirror edge sealant

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as an adhesive
and sealant in solvent-based adhesives and sealants, tire repair cement/sealer, and mirror edge sealant:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

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• Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 6.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOEs 25.2 and 8.4 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOEs 1.6 and 0.18 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 0.65 and 0.22 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-04 and 2.0E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 1.4E-03 and 5.3E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-23)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.5 (central tendency). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOE 0.15 (central tendency). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-03 (central tendency). (Table 4-23)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from a NIOSH Health Hazard Evaluation report (Chrostek, 1981) using TCE in coating
applications and from OSHA facility inspections (OSHA, 2017) at three sites using TCE in adhesives
and coatings. The OSHA data also provided two data points where the worker job description was
"foreman." EPA assumed this data is applicable to ONU exposure. EPA estimated dermal exposures
using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably
available for the condition of use.

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Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Adhesives and sealants

•	Solvent-based adhesives and
sealants

•	Tire repair cement/sealer

•	Mirror edge sealant

5.3.18 Industrial/Commercial Use - Functional fluids (closed systems) - Heat exchange
fluid

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as a functional
fluid (closed systems) for heat exchange fluid:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-26)

•	Autoimmunity:

o Chronic inhalation MOEs 19.3 and 2.8 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-26)

•	Cancer:

o Inhalation: 1.3E-04 (high-end) with PPE (respirator APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-26)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 13.9 (central tendency). (Table 4-26)

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•	Autoimmunity:

o Chronic inhalation MOE 0.39 (central tendency). (Table 4-26)

•	Cancer:

o Inhalation: 7.5E-04 (central tendency). (Table 4-26)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, while non-cancer risk estimates for acute
inhalation exposures do not indicate risks with expected respiratory protection (APF 50), all other risk
estimates indicate risk even with expected respiratory and dermal protection. EPA did not separately
calculate risk estimates for ONUs and workers. There is uncertainty in the ONU risk estimate since the
data did not distinguish between worker and ONU inhalation exposure estimates. ONU inhalation
exposures are expected to be lower than inhalation exposures for workers directly handling the chemical
substance; however, the relative exposure of ONUs to workers in these cases cannot be quantified. To
account for this uncertainty, EPA considered the central tendency estimate when determining ONU risk.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA did not identify inhalation exposure monitoring data related to using TCE
for other industrial uses. Therefore, EPA used monitoring data from loading/unloading TCE during
manufacturing as a surrogate for this condition of use. EPA estimated dermal exposures using the
Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available
for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Functional fluids (closed
systems)

Heat exchange fluid

5.3.19 Industrial/Commercial Use - Paints and coatings - Diluent in solvent-based paints
and coatings

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in paints and
coatings as a diluent in solvent-based paint and coatings:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

•	Does not present an unreasonable risk of injury to the environment (aquatic, sediment dwelling
and terrestrial organisms).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

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Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 6.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOEs 25.2 and 8.4 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOEs 1.6 and 0.18 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 0.65 and 0.22 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-04 and 2.0E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 1.4E-03 and 5.3E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-23)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.5 (central tendency). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOE 0.15 (central tendency). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-03 (central tendency). (Table 4-23)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from a NIOSH Health Hazard Evaluation report (Chrostek, 1981) using TCE in coating
applications and from OSHA facility inspections (OSHA, 2017) at three sites using TCE in adhesives
and coatings. The OSHA data also provided two data points where the worker job description was
"foreman." EPA assumed this data is applicable to ONU exposure. EPA estimated dermal exposures
using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably
available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Paints and coatings

Diluent in solvent-based paints and
coatings

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5.3,20 Industrial/Commercial Use - Cleaning and furniture care products - Carpet
cleaner; wipe cleaning

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in cleaning
and furniture care products for carpet cleaning and wipe cleaning, and in laundry and dishwashing
products as a spot remover:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 5.4 and 1.9 (central tendency and high-end) without respiratory
PPE.

o Acute dermal MOEs 22.7 and 7.6 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOEs 0.15 and 5.1E-02 (central tendency and high-end) without
respiratory PPE.

o Chronic dermal MOEs 0.56 and 0.17 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-17)

•	Cancer:

o Inhalation: 1.8E-03 and 5.8E-03 (central tendency and high-end) without respiratory
PPE.

o Dermal: 1.6E-03 and 6.9E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-17)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (central tendency). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOE 0.29 (central tendency). (Table 4-17)

•	Cancer:

o Inhalation: 9.2E-04 (central tendency). (Table 4-17)

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Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. While workers are unlikely to wear respiratory protection for
this condition of use, all other risk estimates indicate risk even with respiratory and dermal protection.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA identified minimal inhalation exposure monitoring data related to the spot
cleaning using TCE. Therefore, EPA supplemented the identified monitoring data using the Near-
field/Far-field Exposure Model. EPA's inhalation exposure modeling is based on a near-field/far-field
approach, where a vapor generation source located inside the near-field diffuses into the surrounding
environment. Workers are assumed to be exposed to TCE vapor concentrations in the near-field, while
occupational non-users are exposed at concentrations in the far-field. These estimates were used for
determining worker and ONU risks. For workers, EPA estimated dermal exposures using the Dermal
Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available for the
condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Cleaning and furniture care
products

•	Carpet cleaner

•	Wipe cleaning

5.3.21 Industrial/Commercial Use - Laundry and dishwashing products - Spot remover

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in laundry and
dishwashing products as a spot remover:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 5.4 and 1.9 (central tendency and high-end) without respiratory
PPE.

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o Acute dermal MOEs 22.7 and 7.6 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOEs 0.15 and 5.1E-02 (central tendency and high-end) without
respiratory PPE.

o Chronic dermal MOEs 0.56 and 0.17 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-17)

•	Cancer:

o Inhalation: 1.8E-03 and 5.8E-03 (central tendency and high-end) without respiratory
PPE.

o Dermal: 1.6E-03 and 6.9E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-17)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (central tendency). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOE 0.29 (central tendency). (Table 4-17)

•	Cancer:

o Inhalation: 9.2E-04 (central tendency). (Table 4-17)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. While workers are unlikely to wear respiratory protection for
this condition of use, all other risk estimates indicate risk even with respiratory and dermal protection.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA identified minimal inhalation exposure monitoring data related to the spot
cleaning using TCE. Therefore, EPA supplemented the identified monitoring data using the Near-
field/Far-field Exposure Model. EPA's inhalation exposure modeling is based on a near-field/far-field
approach, where a vapor generation source located inside the near-field diffuses into the surrounding
environment. Workers are assumed to be exposed to TCE vapor concentrations in the near-field, while
occupational non-users are exposed at concentrations in the far-field. These estimates were used for
determining worker and ONU risks. For workers, EPA estimated dermal exposures using the Dermal
Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available for the
condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Laundry and dishwashing
products

Spot remover

5.3.22 Industrial/Commercial Use - Arts, crafts and hobby materials - Fixatives and
finishing spray coatings

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in arts, crafts
and hobby materials as a fixative and finishing spray coating:

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• Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 6.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOEs 25.2 and 8.4 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOEs 1.6 and 0.18 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 0.65 and 0.22 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-04 and 2.0E-03 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 1.4E-03 and 5.3E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-23)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.5 (central tendency). (Table 4-23)

•	Autoimmunity:

o Chronic inhalation MOE 0.15 (central tendency). (Table 4-23)

•	Cancer:

o Inhalation: 1.9E-03 (central tendency). (Table 4-23)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from a NIOSH Health Hazard Evaluation report (Chrostek, 1981) using TCE in coating
applications and from OSHA facility inspections (OSHA, 2017) at three sites using TCE in adhesives

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and coatings. The OSHA data also provided two data points where the worker job description was
"foreman." EPA assumed this data is applicable to ONU exposure. EPA estimated dermal exposures
using the Dermal Exposure to Volatile Liquids Model because dermal exposure data was not reasonably
available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Arts, crafts and hobby
materials

Spot remover

5.3.23 Industrial/Commercial Use - Corrosion inhibitors and anti-scaling agents -
Corrosion inhibitors and anti-scaling agents

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as corrosion
inhibitor, and anti-scaling agent:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 13.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-24)

•	Autoimmunity:

o Chronic inhalation MOEs 1.1 and 0.38 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-24)

•	Cancer:

o Inhalation: 2.5E-04 and 9.9E-04 (central tendency and high-end) with PPE (respirator
APF 50).

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o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-24)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 2.7 (central tendency). (Table 4-24)

•	Autoimmunity:

o Chronic inhalation MOE 7.3E-02 (central tendency). (Table 4-24)

•	Cancer:

o Inhalation: 3.9E-03 (central tendency). (Table 4-24)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from a European Commission (EC) Technical Report (European Commission, 2014,
3970806). The data was supplied to the EC as supporting documentation in an application for continued
use of TCE under the REACH Regulation. EPA estimated dermal exposures using the Dermal Exposure
to Volatile Liquids Model because dermal exposure data was not reasonably available for the condition
of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Corrosion inhibitors and
anti-scaling agents

Corrosion inhibitors and anti-scaling
agents

5.3,24 Industrial/Commercial Use - Processing aids - Process solvent used in battery
manufacture; process solvent used in polymer fiber spinning, fluoroelastomer
manufacture, and Alcantara manufacture; extraction solvent used in caprolactam
manufacture; precipitant used in beta-cyclodextrin manufacture

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in processing
aids as a process solvent used in battery manufacture, polymer fiber spinning, fluoroelastomer
manufacture, and Alcantara manufacture, as an extraction solvent used in caprolactam manufacture, and
as a precipitant used in beta-cyclodextrin manufacture:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

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•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 13.6 (high-end) with PPE (respirator APF 50).
o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-24)

•	Autoimmunity:

o Chronic inhalation MOEs 1.1 and 0.38 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-24)

•	Cancer:

o Inhalation: 2.5E-04 and 9.9E-04 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-24)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 2.7 (central tendency). (Table 4-24)

•	Autoimmunity:

o Chronic inhalation MOE 7.3E-02 (central tendency). (Table 4-24)

•	Cancer:

o Inhalation: 3.9E-03 (central tendency). (Table 4-24)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection. The high volatility of TCE and potentially severe effects
from short term exposure are factors when weighing uncertainties. EPA identified inhalation exposure
monitoring data from a European Commission (EC) Technical Report (European Commission, 2014,
3970806). The data was supplied to the EC as supporting documentation in an application for continued
use of TCE under the REACH Regulation. EPA estimated dermal exposures using the Dermal Exposure
to Volatile Liquids Model because dermal exposure data was not reasonably available for the condition
of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Processing aids

• Process solvent used in battery
manufacture

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Life Cycle Stage

Category

Subcategory





•	Process solvent used in polymer
fiber spinning, fluoroelastomer
manufacture, and Alcantara
manufacture

•	Extraction solvent used in
caprolactam manufacture

•	Precipitant used in beta-
cyclodextrin manufacture

5.3.25 Industrial/Commercial Use - Ink, toner, and colorant products - Toner aid

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE as an ink,
toner, and colorant product as a toner aid:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOE 2.5 (high-end) without respiratory PPE.
o Acute dermal MOE 21.6 (high-end) with PPE (gloves PF 20). (Table 4-25)

•	Autoimmunity:

o Chronic inhalation MOEs 1.7 and 6.9E-02 (central tendency and high-end) without
respiratory PPE.

o Chronic dermal MOEs 1.7 and 0.55 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-25)

•	Cancer:

o Inhalation: 1.7E-04 and 5.4E-03 (central tendency and high-end) without respiratory
PPE.

o Dermal: 5.3E-04 and 2.1E-03 (central tendency and high-end) with PPE (gloves PF=10).
(Table 4-25)

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Risk estimate - ONUs:

•	Autoimmunity:

o Chronic inhalation MOE 1.7 (central tendency). (Table 4-25)

•	Cancer:

o Inhalation: 1.7E-04 (central tendency). (Table 4-25)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. While workers are unlikely to wear respiratory protection for
this condition of use, all other risk estimates indicate risk even with respiratory and dermal protection.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA identified inhalation exposure monitoring data from a European
Commission (EC) Technical Report (European Commission, 2014, 3970806). The data was supplied to
the EC as supporting documentation in an application for continued use of TCE under the REACH
Regulation. EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model
because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Ink, toner and colorant
products

Toner aid

5,3.26 Industrial/Commercial Use - Automotive care products - Brake and parts cleaners

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE for automotive
care products as a brake and part cleaner:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

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•	Immunosuppression:

o Acute inhalation MOE 10.9 (high-end) with PPE (respirator APF 50).

o Acute dermal MOE 15.1 (high-end) with PPE (gloves PF 20). (Table 4-15)

•	Autoimmunity:

o Chronic inhalation MOEs 0.95 and 0.30 (central tendency and high-end) with PPE
(respirator APF 50).

o Chronic dermal MOEs 1.2 and 0.39 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-15)

•	Cancer:

o Inhalation: 2.9E-04 and 9.7E-04 (central tendency and high-end) with PPE (respirator
APF 50).

o Dermal: 7.6E-04 and 2.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-15)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 5.0 (high-end). (Table 4-15)

•	Autoimmunity:

o Chronic inhalation MOE 1.0 (central tendency). (Table 4-15)

•	Cancer:

o Inhalation: 2.6E-04 (central tendency). (Table 4-15)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, all risk estimates indicate risk even with
expected respiratory and dermal protection (APF=50 and PF=20). EPA estimated ONU exposures could
be as high as worker exposures as a high-end estimate. The high volatility of TCE and potentially severe
effects from short term exposure are factors when weighing uncertainties. EPA did not identify
inhalation exposure monitoring data related to the use of TCE in aerosol degreasers. Therefore, EPA
estimated inhalation exposures using the Brake Servicing Near-field/Far-field Exposure Model. EPA's
inhalation exposure modeling is based on a near-field/far-field approach, where a vapor generation
source located inside the near-field diffuses into the surrounding environment. Workers are assumed to
be exposed to TCE vapor concentrations in the near-field, while occupational non-users are exposed at
concentrations in the far-field. These estimates were used for determining worker and ONU risks. For
workers, EPA estimated dermal exposures using the Dermal Exposure to Volatile Liquids Model
because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Automotive care products

Brake and parts cleaners

5.3.27 Industrial/Commercial Use - Apparel and footwear care products - Shoe polish

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in apparel and
footwear care products as a shoe polish:

• Presents an unreasonable risk of injury to health (workers and occupational non-users).

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Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 5.4 and 1.9 (central tendency and high-end) without respiratory
PPE.

o Acute dermal MOEs 22.7 and 7.6 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOEs 0.15 and 5.1E-02 (central tendency and high-end) without
respiratory PPE.

o Chronic dermal MOEs 0.56 and 0.17 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-17)

•	Cancer:

o Inhalation: 1.8E-03 and 5.8E-03 (central tendency and high-end) without respiratory
PPE.

o Dermal: 1.6E-03 and 6.9E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-17)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (central tendency). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOE 0.29 (central tendency). (Table 4-17)

•	Cancer:

o Inhalation: 9.2E-04 (central tendency). (Table 4-17)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. While workers are unlikely to wear respiratory protection for
this condition of use, all other risk estimates indicate risk even with respiratory and dermal protection.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA identified minimal inhalation exposure monitoring data related to the spot
cleaning using TCE. Therefore, EPA supplemented the identified monitoring data using the Near-
field/Far-field Exposure Model. EPA's inhalation exposure modeling is based on a near-field/far-field

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approach, where a vapor generation source located inside the near-field diffuses into the surrounding
environment. Workers are assumed to be exposed to TCE vapor concentrations in the near-field, while
occupational non-users are exposed at concentrations in the far-field. These estimates were used for
determining worker and ONU risks. For workers, EPA estimated dermal exposures using the Dermal
Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available for the
condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Apparel and footwear care
products

Shoe polish

5.3.28 Industrial/Commercial Use - Hoof polishes; gun scrubber; pepper spray; other
miscellaneous industrial and commercial uses

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE in other
commercial uses for hoof polishes, sun scrubber, pepper spray, and other miscellaneous industrial and
commercial uses:

•	Presents an unreasonable risk of injury to health (workers and occupational non-users).

Unreasonable risk driver - workers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic inhalation and dermal exposures.

Unreasonable risk driver - ONUs:

•	Immunosuppression resulting from acute inhalation exposures.

•	Autoimmunity resulting from chronic inhalation exposures.

•	Cancer resulting from chronic inhalation exposures.

Driver benchmarks - workers and ONUs:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute inhalation MOEs 5.4 and 1.9 (central tendency and high-end) without respiratory
PPE.

o Acute dermal MOEs 22.7 and 7.6 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOEs 0.15 and 5.1E-02 (central tendency and high-end) without
respiratory PPE.

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o Chronic dermal MOEs 0.56 and 0.17 (central tendency and high-end) with PPE (gloves
PF 20). (Table 4-17)

•	Cancer:

o Inhalation: 1.8E-03 and 5.8E-03 (central tendency and high-end) without respiratory
PPE.

o Dermal: 1.6E-03 and 6.9E-03 (central tendency and high-end) with PPE (gloves PF =
10). (Table 4-17)

Risk estimate - ONUs:

•	Immunosuppression:

o Acute inhalation MOE 10.9 (central tendency). (Table 4-17)

•	Autoimmunity:

o Chronic inhalation MOE 0.29 (central tendency). (Table 4-17)

•	Cancer:

o Inhalation: 9.2E-04 (central tendency). (Table 4-17)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. While workers are unlikely to wear respiratory protection for
this condition of use, all other risk estimates indicate risk even with respiratory and dermal protection.
The high volatility of TCE and potentially severe effects from short term exposure are factors when
weighing uncertainties. EPA identified minimal inhalation exposure monitoring data related to the spot
cleaning using TCE. Therefore, EPA supplemented the identified monitoring data using the Near-
field/Far-field Exposure Model. EPA's inhalation exposure modeling is based on a near-field/far-field
approach, where a vapor generation source located inside the near-field diffuses into the surrounding
environment. Workers are assumed to be exposed to TCE vapor concentrations in the near-field, while
occupational non-users are exposed at concentrations in the far-field. These estimates were used for
determining worker and ONU risks. For workers, EPA estimated dermal exposures using the Dermal
Exposure to Volatile Liquids Model because dermal exposure data was not reasonably available for the
condition of use.

Life Cycle Stage

Category

Subcategory

Industrial/commercial use

Other commercial uses

•	Hoof polishes

•	Gun scrubber

•	Pepper spray

•	Other miscellaneous industrial
and commercial uses

5.3.29 Disposal

Section 6(b)(4)(A) unreasonable risk determination for industrial/commercial use of TCE for disposal:

•	Presents an unreasonable risk of injury to health (workers).

•	Does not present an unreasonable risk of injury to health (occupational non-users).

Unreasonable risk driver - workers:

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•	Immunosuppression resulting from acute dermal exposures.

•	Autoimmunity resulting from chronic inhalation and dermal exposures.

•	Cancer resulting from chronic dermal exposures.

Driver benchmarks - workers:

•	Immunosuppression: Benchmark MOE = 30.

•	Autoimmunity: Benchmark MOE = 30.

•	Cancer (liver, kidney, NHL): Benchmark = lxlO"4.

Risk estimate - workers:

•	Immunosuppression:

o Acute dermal MOE 23.8 (high-end) with PPE (gloves PF 20). (Table 4-27)

•	Autoimmunity:

o Chronic inhalation MOE 6.3 (high-end) with PPE (respirator APF 50).
o Chronic dermal MOEs 1.8 and 0.61 (central tendency and high-end) with PPE (gloves PF
20). (Table 4-27)

•	Cancer:

o Dermal: 4.9E-04 and 1.9E-03 (central tendency and high-end) with PPE (gloves PF =
20). (Table 4-27)

Risk Considerations: For workers and ONUs, all pathways of occupational exposure for this condition
of use indicate risk in the absence of PPE. For workers, while non-cancer risk estimates for acute
inhalation exposures and cancer risk estimates for inhalation exposures do not indicate risks with
expected respiratory protection (APF 50), all other risk estimates indicate risk even with expected
respiratory and dermal protection. EPA did not separately calculate risk estimates for ONUs and
workers. There is uncertainty in the ONU risk estimate since the data did not distinguish between
worker and ONU inhalation exposure estimates. ONU inhalation exposures are expected to be lower
than inhalation exposures for workers directly handling the chemical substance; however, the relative
exposure of ONUs to workers in these cases cannot be quantified. To account for this uncertainty, EPA
considered the central tendency estimate when determining ONU risk. The high volatility of TCE and
potentially severe effects from short term exposure are factors when weighing uncertainties. EPA did
not identify inhalation exposure monitoring data related to using TCE for other industrial uses.
Therefore, EPA used monitoring data from loading/unloading TCE during manufacturing as a surrogate
for this condition of use. EPA estimated dermal exposures using the Dermal Exposure to Volatile
Liquids Model because dermal exposure data was not reasonably available for the condition of use.

Life Cycle Stage

Category

Subcategory

Disposal

Disposal

•	Industrial pre-treatment

•	Industrial wastewater treatment

•	Publicly owned treatment works
(POTW)

5.3.30 Consumer Use - Solvents (for cleaning or degreasing) - Brake and parts cleaner

Page 420 of 748


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1847

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1855

1856

1857

1858

1859

1860

1861

1862

1863

1864

1865

1866

1867

1868

1869

1870

1871

1872

1873

1874

1875

1876

1877

1878

1879

1880

1881

1882

1883

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for brake and
parts cleaners:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.21 (moderate intensity user),
o Acute dermal MOE 0.48 (moderate intensity user). (Table 4-28)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 0.94 (moderate intensity user). (Table 4-28)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders, the risk estimates for the medium
intensity use scenario of acute inhalation indicate risk. Because bystanders are not expected to be
dermally exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure
scenario for bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to
estimate exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air
concentrations a user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Brake and Parts cleaner

5,3,31 Consumer Use - Solvents (for cleaning or degreasing) - Aerosol electronic
degreaser/cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for aerosol
electronic degreaser/cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Page 421 of 748


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1889

1890

1891

1892

1893

1894

1895

1896

1897

1898

1899

1900

1901

1902

1903

1904

1905

1906

1907

1908

1909

1910

1911

1912

1913

1914

1915

1916

1917

1918

1919

1920

1921

1922

1923

1924

1925

1926

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.2 (moderate intensity user). (Table 4-29)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 7.1 (moderate intensity user). (Table 4-29)

Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Aerosol electronic degreaser/cleaner

5,3.32 Consumer Use - Solvents (for cleaning or degreasing) - Liquid electronic
degreaser/cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for liquid
electronic degreaser/cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:
• Immunosuppression:

Page 422 of 748


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1927

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1929

1930

1931

1932

1933

1934

1935

1936

1937

1938

1939

1940

1941

1942

1943

1944

1945

1946

1947

1948

1949

1950

1951

1952

1953

1954

1955

1956

1957

1958

1959

1960

1961

1962

1963

1964

1965

1966

1967

1968

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

o Acute inhalation MOE 0.79 (moderate intensity user),
o Acute dermal MOE 9.5E-01 (moderate intensity user). (Table 4-30)

Risk estimate - bystanders:

• Immunosuppression:

o Acute inhalation MOE 4.8 (moderate intensity user). (Table 4-30)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Liquid electronic degreaser/cleaner

5.3.33 Consumer Use - Solvents (for cleaning or degreasing) - Aerosol spray
degreaser/cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for aerosol
spray degreaser/cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 4.6E-02 (moderate intensity user),
o Acute dermal MOE 0.31 (moderate intensity user). (Table 4-31)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 0.21 (moderate intensity user). (Table 4-31)

Page 423 of 748


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1969

1970

1971

1972

1973

1974

1975

1976

1977

1978

1979

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Aerosol spray degreaser/cleaner

5.3,34 Consumer Use - Solvents (for cleaning or decreasing) - Liquid degreaser/cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for liquid
degreaser/cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE =10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.12 (moderate intensity user),
o Acute dermal MOE 0.13 (moderate intensity user). (Table 4-32)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 0.70 (moderate intensity user). (Table 4-32)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate

Page 424 of 748


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2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

2026

2027

2028

2029

2030

2031

2032

2033

2034

2035

2036

2037

2038

2039

2040

2041

2042

2043

2044

2045

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Liquid degreaser/cleaner

5,3,35 Consumer Use - Solvents (for cleaning or degreasing) - Aerosol gun scrubber

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for aerosol
gun scrubber:

•	Presents an unreasonable risk of injury to health (consumers).

•	Does not present an unreasonable risk of injury to health (bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Driver benchmarks - consumers:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 24 (moderate intensity user),
o Acute dermal MOE 0.32 (moderate intensity user). (Table 4-33)

Risk Considerations: All pathways of consumer exposure for this condition of use indicate risk.
Consumer risk determinations reflect the severity of the effects associated with acute exposures. Risk
estimates for consumer users at the medium intensity use scenarios of acute inhalation and dermal
exposures indicate risk. For bystanders the risk estimates for the medium intensity use scenario of acute
inhalation do not indicate risk. Because bystanders are not expected to be dermally exposed to TCE,
dermal risks to bystanders were not evaluated. For the consumer exposure scenario for bystanders,
inhalation exposures were estimated using the same model (CEM 2.1) used to estimate exposure to
users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a user and
bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Aerosol gun scrubber

5.3.36 Consumer Use - Solvents (for cleaning or degreasing) - Liquid gun scrubber

Page 425 of 748


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2046

2047

2048

2049

2050

2051

2052

2053

2054

2055

2056

2057

2058

2059

2060

2061

2062

2063

2064

2065

2066

2067

2068

2069

2070

2071

2072

2073

2074

2075

2076

2077

2078

2079

2080

2081

2082

2083

2084

2085

2086

2087

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for liquid gun
scrubber:

•	Presents an unreasonable risk of injury to health (consumers).

•	Does not present an unreasonable risk of injury to health (bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Driver benchmarks - consumers:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 28 (moderate intensity user),
o Acute dermal MOE 0.14 (moderate intensity user). (Table 4-34)

Risk Considerations: All pathways of consumer exposure for this condition of use indicate risk.
Consumer risk determinations reflect the severity of the effects associated with acute exposures. Risk
estimates for consumer users at the medium intensity use scenarios of acute inhalation and dermal
exposures indicate risk. For bystanders the risk estimates for the medium intensity use scenario of acute
inhalation do not indicate risk. Because bystanders are not expected to be dermally exposed to TCE,
dermal risks to bystanders were not evaluated. For the consumer exposure scenario for bystanders,
inhalation exposures were estimated using the same model (CEM 2.1) used to estimate exposure to
users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a user and
bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Liquid gun scrubber

5.3.37 Consumer Use - Solvents (for cleaning or degreasing) - Mold release

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for mold
release:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Page 426 of 748


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2088

2089

2090

2091

2092

2093

2094

2095

2096

2097

2098

2099

2100

2101

2102

2103

2104

2105

2106

2107

2108

2109

2110

2111

2112

2113

2114

2115

2116

2117

2118

2119

2120

2121

2122

2123

2124

2125

2126

2127

2128

2129

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.1 (moderate intensity user). (Table 4-35)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 6.4 (moderate intensity user). (Table 4-35)

Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Mold release

5.3.38 Consumer Use - Solvents (for cleaning or degreasing) - Aerosol tire cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for aerosol tire
cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.46 (moderate intensity user),
o Acute dermal MOE 0.70 (moderate intensity user). (Table 4-36)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 2.0 (moderate intensity user). (Table 4-36)

Page 427 of 748


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2130

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2132

2133

2134

2135

2136

2137

2138

2139

2140

2141

2142

2143

2144

2145

2146

2147

2148

2149

2150

2151

2152

2153

2154

2155

2156

2157

2158

2159

2160

2161

2162

2163

2164

2165

2166

2167

2168

2169

2170

2171

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Aerosol tire cleaner

5.3.39 Consumer Use - Solvents (for cleaning or degreasing) - Liquid tire cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a solvent for liquid tire
cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.21 (moderate intensity user),
o Acute dermal MOE 0.12 (moderate intensity user). (Table 4-37)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 0.92 (moderate intensity user). (Table 4-37)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate

Page 428 of 748


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2172

2173

2174

2175

2176

2177

2178

2179

2180

2181

2182

2183

2184

2185

2186

2187

2188

2189

2190

2191

2192

2193

2194

2195

2196

2197

2198

2199

2200

2201

2202

2203

2204

2205

2206

2207

2208

2209

2210

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Solvents (for cleaning or
degreasing)

Liquid tire cleaner

5.3.40 Consumer Use - Lubricants and greases - Tap and die fluid

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a lubricant and grease
in tap and die fluid:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.2 (moderate intensity user). (Table 4-38)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 7.1 (moderate intensity user). (Table 4-38)

Risk Considerations: Consumer and bystander risk determinations reflect the severity of the effects
associated with acute exposures. Risk estimates for consumer users at the medium intensity use
scenarios of acute inhalation indicate risk. For bystanders the risk estimates for the medium intensity use
scenario of acute inhalation indicate risk. Dermal exposures were not quantified for this scenario, as
consumer dermal exposure with impeded evaporation is not expected, and bystanders are not expected
to be dermally exposed to TCE. For the consumer exposure for scenario bystanders, inhalation
exposures were estimated using the same model (CEM 2.1) used to estimate exposure to users. CEM 2.1
is a two-zone model that allows for the estimation of air concentrations a user and bystander(s) would be
exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Lubricants and greases

Tap and die fluid

Page 429 of 748


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2211

2212

2213

2214

2215

2216

2217

2218

2219

2220

2221

2222

2223

2224

2225

2226

2227

2228

2229

2230

2231

2232

2233

2234

2235

2236

2237

2238

2239

2240

2241

2242

2243

2244

2245

2246

2247

2248

2249

2250

2251

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
5.3.41 Consumer Use - Lubricants and greases - Penetrating lubricant

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE as a penetrating lubricant:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 2.7 (moderate intensity user). (Table 4-39)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 16 (moderate intensity user). (Table 4-39)

Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Lubricants and greases

Penetrating lubricant

5.3.42 Consumer Use - Adhesives and sealants - Solvent-based adhesive and sealant

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in adhesives and sealants
as solvent-based adhesive and sealant:

• Presents an unreasonable risk of injury to health (consumers and bystanders).

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2252

2253

2254

2255

2256

2257

2258

2259

2260

2261

2262

2263

2264

2265

2266

2267

2268

2269

2270

2271

2272

2273

2274

2275

2276

2277

2278

2279

2280

2281

2282

2283

2284

2285

2286

2287

2288

2289

2290

2291

2292

2293

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.8 (moderate intensity user). (Table 4-40)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 20 (moderate intensity user). (Table 4-40)

Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Adhesives and sealants

Solvent-based adhesive and sealant

5.3.43 Consumer Use - Adhesives and sealants - Mirror edge sealant

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in adhesives and sealants
as mirror edge sealant:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

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Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.7 (moderate intensity user). (Table 4-41)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 10 (moderate intensity user). (Table 4-41)

Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Adhesives and sealants

Mirror edge sealant

5,3.44 Consumer Use - Adhesives and sealants - Tire repair cement/sealer

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in adhesives and sealants
as tire repair cement/sealer:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE =10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 2.9 (moderate intensity user). (Table 4-42)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 13 (moderate intensity user). (Table 4-42)

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Risk Considerations: Risk estimates for consumer users and bystanders at the medium intensity use
scenarios of acute inhalation exposures indicate risk. Consumer and bystander risk determinations
reflect the severity of the effects associated with acute exposures. Dermal exposures were not quantified
for this scenario, as consumer dermal exposure with impeded evaporation is not expected, and
bystanders are not expected to be dermally exposed to TCE. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Adhesives and sealants

Tire repair cement/sealer

5.3.45 Consumer Use - Cleaning and furniture care products - Carpet cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in cleaning and furniture
care products as carpet cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.29 (moderate intensity user),
o Acute dermal MOE 0.35 (moderate intensity user). (Table 4-43)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 1.7 (moderate intensity user). (Table 4-43)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally

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exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Cleaning and furniture care
products

Carpet cleaner

5.3.46 Consumer Use - Cleaning and furniture care products - Aerosol spot remover

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in cleaning and furniture
care products as aerosol spot remover:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.47 (moderate intensity user),
o Acute dermal MOE 3.0 (moderate intensity user). (Table 4-44)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 5.6 (moderate intensity user). (Table 4-44)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

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Life Cycle Stage

Category

Subcategory

Consumer use

Cleaning and furniture care
products

Aerosol spot remover

5,3,47 Consumer Use - Cleaning and furniture care products - Liquid spot remover

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in cleaning and furniture
care products as liquid spot remover:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.39 (moderate intensity user),
o Acute dermal MOE 0.51 (moderate intensity user). (Table 4-45)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 2.4 (moderate intensity user). (Table 4-45)

Risk Considerations: All pathways of consumer and bystander exposure for this condition of use
indicate risk. Consumer and bystander risk determinations reflect the severity of the effects associated
with acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation and dermal exposures indicate risk. For bystanders the risk estimates for the medium intensity
use scenario of acute inhalation indicate risk. Because bystanders are not expected to be dermally
exposed to TCE, dermal risks to bystanders were not evaluated. For the consumer exposure scenario for
bystanders, inhalation exposures were estimated using the same model (CEM 2.1) used to estimate
exposure to users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a
user and bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Cleaning and furniture care
products

Liquid spot remover

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5.3,48 Consumer Use - Arts, crafts, and hobby materials - Fixatives and finishing spray
coatings

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in arts, crafts, and hobby
materials as fixative and finishing spray coating:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.2 (moderate intensity user). (Table 4-46)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 7.6 (moderate intensity user). (Table 4-46)

Risk Considerations: Consumer and bystander risk determinations reflect the severity of the effects
associated with acute exposures. Risk estimates for consumer users at the medium intensity use
scenarios of acute inhalation indicate risk. For bystanders the risk estimates for the medium intensity use
scenario of acute inhalation indicate risk. Dermal exposures were not quantified for this scenario, as
consumer dermal exposure with impeded evaporation is not expected, and bystanders are not expected
to be dermally exposed to TCE. For the consumer exposure scenario for bystanders, inhalation
exposures were estimated using the same model (CEM 2.1) used to estimate exposure to users. CEM 2.1
is a two-zone model that allows for the estimation of air concentrations a user and bystander(s) would be
exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Arts, crafts, and hobby
materials

Fixatives and finishing spray coatings

5.3.49 Consumer Use - Apparel and footwear care products - Shoe polish

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in apparel and footwear
care products in shoe polish:

• Presents an unreasonable risk of injury to health (consumers).

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•	Does not present an unreasonable risk of injury to health (bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation and dermal exposures.

Driver benchmarks - consumers:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 5.4 (moderate intensity user),
o Acute dermal MOE 5.5 (moderate intensity user). (Table 4-47)

Risk Considerations: All pathways of consumer exposure for this condition of use indicate risk.
Consumer risk determinations reflect the severity of the effects associated with acute exposures. Risk
estimates for consumer users at the medium intensity use scenarios of acute inhalation and dermal
exposures indicate risk. For bystanders the risk estimates for the medium intensity use scenario of acute
inhalation do not indicate risk. Because bystanders are not expected to be dermally exposed to TCE,
dermal risks to bystanders were not evaluated. For the consumer exposure scenario for bystanders,
inhalation exposures were estimated using the same model (CEM 2.1) used to estimate exposure to
users. CEM 2.1 is a two-zone model that allows for the estimation of air concentrations a user and
bystander(s) would be exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Apparel and footwear care
products

Shoe polish

5.3.50 Consumer Use - Other consumer uses - Fabric spray

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in fabric spray:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.43 (moderate intensity user). (Table 4-48)

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Risk estimate - bystanders:

• Immunosuppression:

o Acute inhalation MOE 5.1 (moderate intensity user). (Table 4-48)

Risk Considerations: Consumer and bystander risk determinations reflect the severity of the effects
associated with acute exposures. Risk estimates for consumer users at the medium intensity use
scenarios of acute inhalation indicate risk. For bystanders the risk estimates for the medium intensity use
scenario of acute inhalation indicate risk. Dermal exposures were not quantified for this scenario, as
consumer dermal exposure with impeded evaporation is not expected, and bystanders are not expected
to be dermally exposed to TCE. For the consumer exposure scenario for bystanders, inhalation
exposures were estimated using the same model (CEM 2.1) used to estimate exposure to users. CEM 2.1
is a two-zone model that allows for the estimation of air concentrations a user and bystander(s) would be
exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Other consumer uses

Fabric spray

5.3.51 Consumer Use - Other consumer uses - Film cleaner

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in film cleaner:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 0.18 (moderate intensity user). (Table 4-49)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 1.1 (moderate intensity user). (Table 4-49)

Risk Considerations: Consumer and bystander risk determinations reflect the severity of the effects
associated with acute exposures. Risk estimates for consumer users at the medium intensity use

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scenarios of acute inhalation indicate risk. For bystanders the risk estimates for the medium intensity use
scenario of acute inhalation indicate risk. Dermal exposures were not quantified for this scenario, as
consumer dermal exposure with impeded evaporation is not expected, and bystanders are not expected
to be dermally exposed to TCE. For the consumer exposure scenario for bystanders, inhalation
exposures were estimated using the same model (CEM 2.1) used to estimate exposure to users. CEM 2.1
is a two-zone model that allows for the estimation of air concentrations a user and bystander(s) would be
exposed to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Other consumer uses

Film cleaner

5,3.52 Consumer Use - Other consumer uses - Hoof polish

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in hoof polish:

•	Presents an unreasonable risk of injury to health (consumers).

•	Does not present an unreasonable risk of injury to health (bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 8.0 (moderate intensity user). (Table 4-50)

Risk Considerations: Consumer risk determinations reflect the severity of the effects associated with
acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation indicate risk. For bystanders the risk estimates for the medium intensity use scenario of acute
inhalation do not indicate risk. Dermal exposures were not quantified for this scenario, as consumer
dermal exposure with impeded evaporation is not expected, and bystanders are not expected to be
dermally exposed to TCE. For the consumer exposure scenario for bystanders, inhalation exposures
were estimated using the same model (CEM 2.1) used to estimate exposure to users. CEM 2.1 is a two-
zone model that allows for the estimation of air concentrations a user and bystander(s) would be exposed
to following an exposure event.

Life Cycle Stage

Category

Subcategory

Consumer use

Other consumer uses

Hoof polish

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5,3.53 Consumer Use - Other consumer uses - Pepper spray

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in pepper spray:

•	Does not present an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 98 (moderate intensity user). (Table 4-51)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 98 (moderate intensity user). (Table 4-51)

Risk Considerations: Consumer risk determinations reflect the severity of the effects associated with
acute exposures. Risk estimates for consumer users at the medium intensity use scenarios of acute
inhalation do not indicate risk. For bystanders, MOEs are expected to be equivalent to consumers.
Dermal exposures were not quantified for this scenario, as consumer dermal exposure with impeded
evaporation is not expected, and bystanders are not expected to be dermally exposed to TCE.

Life Cycle Stage

Category

Subcategory

Consumer use

Other consumer uses

Pepper spray

5.3,54 Consumer Use - Other consumer uses - Toner aid

Section 6(b)(4)(A) unreasonable risk determination for consumer use of TCE in toner aid:

•	Presents an unreasonable risk of injury to health (consumers and bystanders).

Unreasonable risk driver - consumers:

•	Immunosuppression resulting from acute inhalation exposures.

Unreasonable risk driver - bystanders:

•	Immunosuppression resulting from acute inhalation exposures.

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Driver benchmarks - consumers and bystanders:

•	Immunosuppression: Benchmark MOE = 10.

Risk estimate - consumers:

•	Immunosuppression:

o Acute inhalation MOE 1.3 (moderate intensity user). (Table 4-52)

Risk estimate - bystanders:

•	Immunosuppression:

o Acute inhalation MOE 8.0 (moderate intensity user). (Table 4-52)

Risk Considerations: Consumer and bystander risk determinations reflect the severity of the effects
associated with acute exposures. Risk estimates for consumer users at the medium intensity use
scenarios of acute inhalation indicate risk. For bystanders the risk estimates for the medium intensity use
scenario of acute inhalation indicate risk. Dermal exposures were not quantified for this scenario, as
consumer dermal exposure with impeded evaporation is not expected, and bystanders are not expected
to be dermally exposed to TCE.

Life Cycle Stage

Category

Subcategory

Consumer use

Other consumer uses

Toner Aid

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hydrocarbons and chlorinated hydrocarbons to two planktonic crustaceans the key role of
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Adgate ,11 , Church. TR; Ryan. AD; Ramachandran. t ledrickseii \< C4(»ck. TH; Morandi. MT;

Sexton. K. (2004). Outdoor, indoor, and personal exposure to VOCs in children. Environ Health
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AIHA. (2009). Mathematical models for estimating occupational exposure to chemicals. In CB Keil; CE
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Alanee. S; demons. J; Zahnd. W; Sadowski. nda. D. (2015). Trichloroethylene Is Associated with
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Alexander. HC; McCartv. WM; Bartlett. EA. (1978). Toxicity of perchloroethylene, trichloroethylene,
1,1,1-trichloroethane, and methylene chloride to fathead minnows. Bull Environ Contam Toxicol
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An do jtuka. S; Nishiyama. M; Senoo. K; Watanabe. MM; Matsumoto. S. (2003). Toxic Effects of
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Anttil	:ala. E; Sallmen. M; Hernberg. S; Hemminki. K. (1995). Cancer incidence among

Finnish workers exposed to halogenated hydrocarbons. J Occup Environ Med 37: 797-806.

Arito. H; Takahashi. M; Ishikawa. T. (1994). Effect of subchronic inhalation exposure to low-level

trichloroethylene on heart rate and wakefulness-sleep in freely moving rats. Sangyo Igaku 36: 1-
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AT SDR. (2019). Toxicological Profile for T ri chl oroethyl ene: CAS # 79-01-6. Atlanta, GA.

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Axelson. O; S el den. A; Andersson. K; Hogstedt. C. (1994). Updated and expanded Swedish cohort
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Bahr. DE: Aldrich. TE; Seidu. D; Brion. GM; Toilet	int. PGP. (2011). OCCUPATIONAL

EXPOSURE TO TRICHLOROETHYLENE AND CANCER RISK FOR WORKERS AT THE
PADUCAH GASEOUS DIFFUSION PLANT. Int J Occup Med Environ Health 24: 67-77.
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Baldwin. PE; Mayn	(1998a). A survey of wind speed in indoor workplaces. Ann Occup Hyg

42: 303-313. http://dx.doi.org/lO 101 ' 0003-4878(98)000 < I

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AK03). Washington D.C.: Office of Chemical Safety and Pollution Prevention.
https://www.reeiilations.eov/documeiii * KPA-H.Q~QJT 1 _0l 01 3-0021
U.S. EPA. (2016g). Supplemental occupational exposure and risk reduction technical report in support
of risk management options for trichloroethylene (TCE) use in spot cleaning. (RIN 2070-AK03).
Washington D.C.: Office of Chemical Safety and Pollution Prevention.
https://www.reeiilations.eov/documeiii * KPA-H.Q~QJT 1 _0l 01 3-0024
U.S. EPA. (2016h). Supplemental occupational exposure and risk reduction technical report in support
of risk management options for trichloroethylene (TCE) use in vapor degreasing. (RIN 2070-
AK11). Washington D.C.: Office of Chemical Safety and Pollution Prevention.
https://www.reeiilations.eov/documeiii * < 'PA-H.Q-01 * I
U.S. EPA. (2016i). Weight of evidence in ecological assessment [EPA Report], (EPA 100R16001).
Washington, DC: Office of the Science Advisor.

https://cfpub.epa.gov/si/si public i-voix! report.cfm?dirEntryLl ' ' ^'

U.S. EPA. (2017a). Chemical test rule data: Trichloroethylene. Washington, DC. Retrieved from
http://i ava.epa. gov/chemview

(2017b). Consumer Exposure Model (CEM) version 2.0: User guide. U.S. Environmental
Protection Agency, Office of Pollution Prevention and Toxics.

https://www.epa.eov/sites/prodiiction/files/2i 'documents/cem 2.0 user guide.pdf

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U.S. EPA. (2017c). Preliminary information on manufacturing, processing, distribution, use, and

disposal: Trichloroethylene [Comment], (EPA-HQ-OPPT-2016-0737-003). Washington, DC:
Office of Chemical Safety and Pollution Prevention.

https://www.reeiilations.eov/documeiii * KPA~H.Q~QJT 1 .01 0 '< 0003
U.S. EPA. (2017d). Scope of the risk evaluation for trichloroethylene. CASRN: 79-01-6 [EPA
Report], (EPA-740-R1-7004). https://www.epa.eov/sites/production/files/

06/docum ents/tce scot	If

U.S. EPA. (2017e). Strategy for conducting literature searches for trichloroethylene (TCE):

Supplemental document to the TSCA Scope Document. CASRN: 79-01-6 [EPA Report],
https://www.epa.gov/sites/production/files/2Q17-
06/docum ents/tce lit search strategy 05	if

U.S. EPA. (2017f). Toxics Release Inventory (TRI), reporting year 2015. Retrieved from
https://www.epa.gov/toxics-release-inventorv-tri-program/tri-data-and-tools

(2017h). Trichloroethylene market and use report. Washington, DC: U.S. Environmental
Protection Agency, Office of Chemical Safety and Pollution Prevention, Chemistry, Economics,
and Sustainable Strategies Division, https://www.epa.gov/sites/production/files/^
05/documents/instructions for reporting 2016 tsca cdi I 'i>nn .0 \ |;&m c=true&n ode=pt4 0 '<1 II K\.rgn=div5
U.S. EPA. (2019d). Biennial Review of 40 CFR Part 503 As Required Under the Clean Water Act
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2017-biosolids-biennial-review.pdf
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drinking-water sources: Results of the random survey. Reston, VA: U.S. Department of the
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LISGS. (2006). Water-quality conditions of Chester Creek, Anchorage, Alaska, 1998-2001. Reston, VA:
U.S. Department of the Interior, U.S. Geological Survey.

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endpoints for acute limits settings (pp. 1-88). (RIVM Report 601900004). Nederlands:
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Vidal. M; Basseres. A; Narbon (2001). Potential biomarkers of trichloroethylene and toluene
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Vlaanderen. J ; Straif. K; Pukkala. E; Kauppinen. T; Kyyronen. P; Martin sen. J; Kiaerheim. K;

Trveevadott Hansen. J; Sparen. P. an Weiderpass. E. (2013). Occupational exposure to
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Med 48: 249-258. http://dx.doi.org/10.1002/aiim.20216

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1	APPENDICES

2		

3	V|)|K'iHii\ \ ui (.1 i \iom iiisioin

4	A.l Federal Laws and Regulations

5

Table Apx A-l. Federa

Laws and Regulations

Statutes/Regulations

Description of Authority/Regulation

Description of Regulation

EPA Regulations

Toxics Substances
Control Act (TSCA) -
Section 6(a)

Provides EPA with the authority to
prohibit or limit the manufacture
(including import), processing,
distribution in commerce, use or disposal
of a chemical if EPA evaluates the risk
and concludes that the chemical presents
an unreasonable risk to human health or
the environment.

Proposed rule under section 6 of
TSCA to address the unreasonable
risks presented by TCE use in
vapor degreasing (h„ t ^ 1
January 19, 2017).

TSCA - Section 6(a)

Provides EPA with the authority to
prohibit or limit the manufacture
(including import), processing,
distribution in commerce, use or disposal
of a chemical if EPA evaluates the risk
and concludes that the chemical presents
an unreasonable risk to human health or
the environment

Proposed rule under section 6 of
TSCA to address the unreasonable
risks presented by TCE use in
commercial and consumer aerosol
degreasing and for spot cleaning at
dry cleaning facilities (
"i - December 16, 2016).

TSCA - Section 6(b)

Directs EPA to promulgate regulations to
establish processes for prioritizing
chemicals and conducting risk
evaluations on priority chemicals. In the
meantime, EPA is directed to identify
and begin risk evaluations on
10 chemical substances drawn from the
2014 update of the TSCA Work Plan for
Chemical Assessments.

TCE is on the initial list of
chemicals to be evaluated for
unreasonable risks under TSCA
( , December 19,
2016).

TSCA - Section 5(a)

Once EPA determines that a use of a
chemical substance is a significant new
use under TSCA section 5(a), persons are
required to submit a significant new use
notice (SNUN) to EPA at least 90 days
before they manufacture (including
import) or process the chemical
substance for that use.

Significant New Use Rule (SNUR)
031 FR 20535; April 8. 2016V
TCE is subject to reporting under
the SNUR for manufacture
(including import) or processing of
TCE for use in a consumer product
except for use in cleaners and
solvent degreasers, film cleaners,
hoof polishes, lubricants, mirror

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edge sealants and pepper spray.
This SNUR ensures that EPA will
have the opportunity to review any
new consumer uses of TCE and, if
appropriate, take action to prohibit
or limit those uses.

TSCA - Section 8(a)

The TSCA section 8(a) CDR rule
requires manufacturers (including
importers) to give EPA basic exposure-
related information on the types,
quantities and uses of chemical
substances produced domestically and
imported into the United States.

TCE manufacturing (including
importing), processing and use
information is reported under the
CDR rule ( 0816. August
16, 2011).

TSCA - Section 8(b)

EPA must compile, keep current and
publish a list (the TSCA Inventory) of
each chemical substance manufactured,
processed or imported in the United
States.

TCE was on the initial TSCA
Inventory and was therefore not
subject to EPA's new chemicals
review process (60 FR 16309,
March 29, 1995).

TSCA - Section 8(e)

Manufacturers (including imports),
processors and distributors must
immediately notify EPA if they obtain
information that supports the conclusion
that a chemical substance or mixture
presents a substantial risk of injury to
health or the environment.

28 substantial risk notifications
received for TCE (U.S. EPA,
ChemView. Accessed April 13,
2017).

TSCA - Section 4

Provides EPA with authority to issue
rules and orders requiring manufacturers
(including importers) and processors to
test chemical substances and mixtures.

Seven studies received for TCE
(U.S. EPA, ChemView. Accessed
April 13, 2017).

Emergency Planning
and Community Right-
to-Know Act (EPCRA)
- Section 313

Requires annual reporting from facilities
in specific industry sectors that employ
10 or more full time equivalent
employees and that manufacture, process,
or otherwise use a TRI-listed chemical in
quantities above threshold levels. A
facility that meets reporting requirements
must submit a reporting form for each
chemical for which it triggered reporting,
providing data across a variety of
categories, including activities and uses
of the chemical, releases and other waste
management (e.g., quantities recycled,
treated, combusted) and pollution
prevention activities (under section 6607

TCE is a listed substance subject
to reporting requirements under
40 CFR 372.65 effective as of
January 1, 1987.

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of the Pollution Prevention Act). These
data include on- and off-site data as well
as multimedia data (i.e., air, land and
water).



Federal Insecticide,
Fungicide, and
Rodenticide Act
(FIFRA) - Section 6

FIFRA governs the sale, distribution and
use of pesticides. Section 3 of FIFRA
generally requires that pesticide products
be registered by EPA prior to distribution
or sale. Pesticides may only be registered
if, among other things, they do not cause
"unreasonable adverse effects on the
environment." Section 6 of FIFRA
provides EPA with the authority to
cancel pesticide registrations if either: (1)
the pesticide, labeling, or other material
does not comply with FIFRA or (2) when
used in accordance with widespread and
commonly recognized practice, the
pesticide generally causes unreasonable
adverse effects on the environment.

TCE is no longer used as an inert
ingredient in pesticide products.

Clean Air Act (CAA) -
Section 112(b)

Defines the original list of CAA
hazardous air pollutants (HAPs). Under
112(c) of the CAA, EPA must identify
and list source categories that emit HAPs
and then set emission standards for those
listed source categories under CAA
section 112(d). CAA section
112(b)(3)(A) specifies that any person
may petition the Administrator to modify
the list of HAPs by adding or deleting a
substance.

Lists TCE as a HAP (42 U.S.C.
7412(b)(1)).

CAA - Section 112(d)

Section 112(d) states that the EPA must
establish a National Emission Standards
for Hazardous Air Pollutants (NESHAP)
for each category or subcategory of
major sources and area sources of HAPs
(listed pursuant to Section 112(c)). The
standards must require the maximum
degree of emission reduction that EPA
determines to be achievable by each
particular source category. Different
criteria for maximum achievable control
technology (MACT) apply for new and
existing sources. Less stringent
standards, known as generally available

EPA has promulgated a number of
NES regulating industrial
source categories that emit
trichloroethylene and other HAP.
These include, for example, the
NESHAP for Halogenated Solvent
Cleaning (59 FR 61801; December
2, 1994), among others.

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control technology (GACT) standards,
are allowed at the Administrator's
discretion for area sources.



CAA - Sections 112(d)
and 112 (f)

Risk and technology review (RTR) of
section 112(d) MACT standards. Section
112(f)(2) requires EPA to conduct risk
assessments for each source category
subject to section 112(d) MACT
standards, and to determine if additional
standards are needed to reduce remaining
risks. Section 112(d)(6) requires EPA to
review and revise the MACT standards,
as necessary, taking into account
developments in practices, processes and
control technologies.

EPA has promulgated a number of
RTR NESHAP (e.g., the RTR
NESHAP for Halogenated Solvent
Cleaning (72 FR 25138; Mav 3.
2007) and will do so, as required,
for the remaining source
categories with NESHAP.

CWA - Sections
301(b), 304(b), 306,
and 307(b)

Requires establishment of Effluent
Limitations Guidelines and Standards for
conventional, toxic, and
non-conventional pollutants. For toxic
and non-conventional pollutants, EPA
identifies the best available technology
that is economically achievable for that
industry after considering statutorily
prescribed factors and sets regulatory
requirements based on the performance
of that technology. Regulations apply to
existing and new sources.

TCE is designated as a toxic
pollutant under section 307(a)(1)
of the CWA and as such, is subject
to effluent limitations.

CWA - Section 307(a)

Establishes a list of toxic pollutants or
combination of pollutants under the to
the CWA. The statute specifies a list of
families of toxic pollutants also listed in
40 CFR 401.15. The "priority pollutants"
specified by those families are listed in
40 CFR part 423, Appendix A. These are
pollutants for which best available
technology effluent limitations must be
established on either a national basis
through rules, or on a case-by-case best
professional judgement basis in National
Pollutant Discharge Elimination System
(NPDES) permits.



Safe Drinking Water
Act (SDWA) - Section
1412

Requires EPA to publish a non-
enforceable maximum contaminant level
goals (MCLGs) for contaminants which
1. may have an adverse effect on the

EPA issued drinking water
standards for TCE pursuant to
section 1412 of the SDWA. EPA
promulgated the NPDWR for TCE

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health of persons; 2. are known to occur
or there is a substantial likelihood that
the contaminant will occur in public
water systems with a frequency and at
levels of public health concern; and 3. in
the sole judgement of the Administrator,
regulation of the contaminant presents a
meaningful opportunity for health risk
reductions for persons served by public
water systems. When EPA publishes an
MCLG, EPA must also promulgate a
National Primary Drinking Water
Regulation (NPDWR) which includes
either an enforceable maximum
contaminant level (MCL), or a required
treatment technique. Public water
systems are required to comply with
NPDWRs

in 1987 with a MCLG of zero an
enforceable MCL of 0.005 mg/L
(52 FR 25690, July 8, 1987).

RCRA - Section 3001

Directs EPA to develop and promulgate
criteria for identifying the characteristics
of hazardous waste, and for listing
hazardous waste, taking into account
toxicity, persistence, and degradability in
nature, potential for accumulation in
tissue and other related factors such as
flammability, corrosiveness, and other
hazardous characteristics.

TCE is included on the list of
commercial chemical products,
manufacturing chemical
intermediates or off-specification
commercial chemical products or
manufacturing chemical
intermediates that, when disposed
(or when formulations containing
any one of these as a sole active
ingredient are disposed) unused,
become hazardous wastes pursuant
to RCRA 3001. RCRA Hazardous
Waste Status: D040 at 0.5 mg/L;
F001, F002; U228

Comprehensive
Environmental
Response,
Compensation and
Liability Act
(CERCLA) - Section
102(a)

Authorizes EPA to promulgate
regulations designating as hazardous
substances those substances which, when
released into the environment, may
present substantial danger to the public
health or welfare or the environment.
EPA must also promulgate regulations
establishing the quantity of any
hazardous substance the release of which
must be reported under Section 103.

Section 103 requires persons in charge of
vessels or facilities to report to the
National Response Center if they have

TCE is a hazardous substance with
a reportable quantity pursuant to
section 102(a) of CERCLA (40
CFR 302.4) and EPA is actively
overseeing cleanup of sites
contaminated with TCE pursuant
to the National Contingency Plan
(NCP) (40 CFR 751).

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knowledge of a release of a hazardous
substance above the reportable quantity
threshold.



Other Federal Regulations

OSHA

Requires employers to provide their
workers with a place of employment free
from recognized hazards to safety and
health, such as exposure to toxic
chemicals, excessive noise levels,
mechanical dangers, heat or cold stress or
unsanitary conditions.

In 1971, OSHA issued
occupational safety and health
standards for TCE that included a
Permissible Exposure Limit (PEL)
of 100 ppm TWA, exposure
monitoring, control measures and
respiratory protection (29 CFR
1910.1000).

While OSHA has established a
PEL for TCE, OSHA has
recognized that many of its
permissible exposure limits (PELs)
are outdated and inadequate for
ensuring protection of worker
health. Most of OSHA's PELs
were issued shortly after adoption
of the Occupational Safety and
Health (OSH) Act in 1970, and
have not been updated since that
time. Section 6(a) of the OSH Act
granted the Agency the authority
to adopt existing Federal standards
or national consensus standards as
enforceable OSHA standards. For
TCE, OSHA recommends the use
of the NIOSH REL of 2 ppm (as a
60-minute ceiling) during the
usage of TCE as an anesthetic
agent and 25 ppm (as a 10-hour
TWA) during all other exposures.

Atomic Energy Act

The Atomic Energy Act authorizes the
Department of Energy to regulate the
health and safety of its contractor
employees

10 CFR 851.23, Worker Safety
and Health Program, requires the
use of the ACGIH TLVs if they
are more protective than the
OSHA PEL. The 2012 TLV for
TCE is 10 ppm and the short-term
limit is 25 ppm CAT SDR.: ).

Federal Food, Drug,
and Cosmetic Act
(FFDCA)

Provides the FDA with authority to
oversee the safety of food, drugs and
cosmetics.

Tolerances are established for
residues of TCE resulting from its
use as a solvent in the manufacture

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of decaffeinated coffee and spice
oleoresins (21 CFR 173.290).

7

8

9	A.2 State Laws and Regulations

10

11	Table Apx A-2. State Laws and Regulations

State Actions

Description of Action

California Code of
Regulations (CCR), Title 17,
Section 94509(a)

Lists standards for VOCs for consumer products sold, supplied, offered
for sale or manufactured for use in California. As part of that
regulation, use of consumer general purpose degreaser products that
contain TCE are banned in California and safer substitutes are in use
(17 CCR, Section 94509(a).

State Permissible Exposure
Limits (PELs)

Most states have set PELs identical to the OSHA 100 ppm 8-hour
TWA PEL. Nine states have PELs of 50 ppm. California's PEL of
25 ppm is the most stringent (CCR, Title 8, Table AC-1).

VOC regulations for
consumer products

Many states regulate TCE as a VOC. These regulations may set VOC
limits for consumer products and/or ban the sale of certain consumer
products as an ingredient and/or impurity. Regulated products vary
from state to state, and could include contact and aerosol adhesives,
aerosols, electronic cleaners, footwear or leather care products and
general degreasers, among other products. California (Title 17,
California Code of Regulations, Division 3, Chapter 1, Subchapter 8.5,
Articles 1, 2, 3 and 4), Connecticut (R.C.S.A Sections 22a-174-40,
22a-174-41, and 22a-174-44), Delaware (Adm. Code Title 7, 1141),
District of Columbia (Rules 20-720, 20-721, 20-735, 20-736, 20-737),
Illinois (35 Adm Code 223), Indiana ( 326 IAC 8-15), Maine (Chapter
152 of the Maine Department of Environmental Protection
Regulations), Maryland (COMAR 26.11.32.00 to 26.11.32.26),
Michigan (R 336.1660 and R 336. 1661), New Hampshire (Env-A
4100) New Jersey (Title 7, Chapter 27, Subchapter 24), New York (6
CRR-NY III A 235), Rhode Island (Air Pollution Control Regulation
No. 31) and Virginia (9VAC5 Chapter 45) all have VOC regulations or
limits for consumer products. Some of these states also require
emissions reporting.

Other

TCE is on California Proposition 65 List of chemicals known to cause
cancer in 1988 or birth defects or other reproductive harm in 2014
(CCR Title 27, section 27001). TCE is on California's Safer Consumer
Products Regulations Candidate List of chemicals that exhibit a hazard
trait and are on an authoritative list (CCR Title 22, Chapter 55).

12

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13	A.3 International Laws and Regulations

14

15	Table Apx A-3. Regulatory Actions by Other Governments and Tribes

Country/ Organization

Requirements and Restrictions

Canada

TCE is on the Canadian List of Toxic Substances (CEPA
1999 Schedule 1). TCE is also regulated for use and sale
for solvent degreasing under Solvent Degreasing
Regulations (SOR/2003-283) (Canada Gazette, Part II on
August 13, 2003). The purpose of the regulation is to
reduce releases of TCE into the environment from solvent
degreasing facilities using more than 1000 kilograms of
TCE per year. The regulation includes a market
intervention by establishing tradable allowances for the
use of TCE in solvent degreasing operations that exceed
the 1000 kilograms threshold per year.

European Union

In 2011, TCE was added to Annex XIV (Authorisation
list) of regulation (EC) No 1907/2006 - REACH
(Registration, Evaluation, Authorization and Restriction
of Chemicals). Entities that would like to use TCE needed
to apply for authorization by October 2014, and those
entities without an authorization must stop using TCE by
April 2016. The European Chemicals Agency (ECHA)
received 19 applications for authorization from entities
interested in using TCE beyond April 2016.

TCE is classified as a carcinogen category IB, and was
added to the EU REACH restriction of substances
classified as carcinogen category 1A or IB under the EU
Classification and Labeling regulation (among other
characteristics) in 2009. The restriction bans the placing
on the market or use of TCE as substance, as constituent
of other substances, or, in mixtures for supply to the
general public when the individual concentration in the
substance or mixture is equal to or greater than 0.1 % w/w
(Regulation (EC) No 1907/2006 - REACH (Registration,
Evaluation, Authorization and Restriction of Chemicals)).
Previous regulations, such as the Solvent Emissions
Directive (Directive 1999/13/EC) introduced stringent
emission controls of TCE.

Australia

In 2000, TCE was assessed (National Industrial Chemicals
Notification and Assessment Scheme. NICNAS (2000).
Trichloroethylene. Accessed April, 18 2017).

Japan Chemical Substances
Control Law

TCE is regulated in Japan under the following legislation:

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-Act on the Evaluation of Chemical Substances and Regulation
of Their Manufacture, etc. (Chemical Substances Control Law;
CSCL)

-Act on Confirmation, etc. of Release Amounts of Specific

Chemical Substances in the Environment and Promotion of

Improvements to the Management Thereof

-Industrial Safety and Health Act (ISHA)

-Air Pollution Control Law

-Water Pollution Control Law

-Soil Contamination Countermeasures Act

-Law for the Control of Household Products Containing Harmful

Substances

(National Institute of Technology and Evaluation (NITE)
Chemical Risk Information Platform (CHIRP), Accessed
April 18, 2017).

Australia, Austria, Belgium,
Canada, Denmark, Finland,
France, Germany, Hungary,
Ireland, Israel, Japan, Latvia,
New Zealand, People's Republic
of China, Poland, Singapore,
South Korea, Spain, Sweden,
Switzerland, United Kingdom

Occupational exposure limits for TCE (GESTIS
International limit values for chemical agents
(Occupational exposure limits, OELs) database. Accessed
April 18, 2017).

16

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Appendix B LIST OF SUPPLEMENTAL DOCUMENTS

List of supplemental documents (see Docket: I 1: \-Uo-Ul']' \ - JO l^-O^OO for access to all flies):

Associated Systematic Review Data Quality Evaluation and Data Extraction Documents -
Provides additional detail and information on individual study evaluations and data extractions
including criteria and scoring results:

Physical/Chemical Properties. Fate and Transport

a.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Physical-Chemical Properties Studies

b.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Environmental Fate and Transport Studies

c.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Extraction
for Environmental Fate and Transport Studies

Occupational Exposures and Releases

d.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Environmental Releases and Occupational Exposure Data

e.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Environmental Releases and Occupational Exposure Common Sources

f Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: List of Key and
Supporting Studies for Environmental Releases and Occupational Exposure

Consumer and Environmental Exposures

g.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation for Data Sources on Consumer and Environmental Exposure

h.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Extraction
Tables for Environmental Monitoring Data

i.	Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Extraction
for Biomonitoring Data

Environmental Hazard

j. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Environmental Hazard Studies

k Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Extraction
for Environmental Hazard Studies

Human Health Hazard

I. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Human Health Hazard Studies - Animal and Mechanistic Data

Page 472 of 748


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m. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Quality
Evaluation of Human Health Hazard Studies - Epidemiological Data

n. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Updates to the
Data Quality Criteria for Epidemiological Studies

o. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: Data Extraction
for Human Health Hazard Studies

p. Risk Evaluation for Trichloroethylene, Systematic Review Supplemental File: List of Key and
Supporting Studies for Human Health Hazard Assessment

Associated Supplemental Information Documents - Provides additional details and information
on exposure, hazard and risk assessments:

Occupational Exposures and Releases

q. Risk Evaluation for Trichloroethylene, Supplemental Information File: Environmental
Releases and Occupational Exposure Assessment

r. Risk Evaluation for Trichloroethylene, Supplemental Information File: Risk Calculator for
Occupational Exposures

Consumer and Environmental Exposures

5. Risk Evaluation for Trichloroethylene, Supplemental Information File: Aquatic Exposure
Modeling Outputs from E-FAST

t. Risk Evaluation for Trichloroethylene, Supplemental Information File: Consumer Exposure
Assessment Model Input Parameters

u. Risk Evaluation for Trichloroethylene, Supplemental Information File: Exposure Modeling
Results and Risk Estimates for Consumer Inhalation Exposures

v. Risk Evaluation for Trichloroethylene, Supplemental Information File: Exposure Modeling
Results and Risk Estimates for Consumer Dermal Exposures

Human Health

w. Risk Evaluation for Trichloroethylene, Supplemental Information File: Data Table for
Congenital Heart Defects Weight of Evidence Analysis

x. Risk Evaluation for Trichloroethylene, Supplemental Information File: Personal
Communication to OPPT. Raw Data Values from Selgrade and Gilmour, 2010

y. Risk Evaluation for Trichloroethylene, Supplemental Information File: PBPK Model and
ReadMe (zipped)

Additional Information

z. Risk Evaluation for Trichloroethylene, Supplemental Information File:

Memorandum NIOSH BLS Respirator Usage in Private Sector Firms

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116 Appendix € ENVIRONMENTAL EXPOSURES

117

118

119

120

121

A break-out of facility-specific modeling results organized per OES, with predicted surface water concentrations and associated days of COC
exceedance, are included in Table Apx C-l. These facility-specific modeling results are utilized and discussed in environmental risk
characterization presented in Section 4.1.2.

Table Apx C-l. Facility-Specific Aquatic Exposure Modeling Results

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

OES: Manufacturing

















3

0

Axiall Corporation,

Westlake, LA
NPDES: LA0007129







350

1.266

0.00156

0.0051

788

0

Surface

NPDES

Surface









52,000

0

Water

LA0007129

water









3

0







20

22.150

0.0273

0.0897

788

0

















52,000

0

















3

37

Olin Blue Cube,
Freeport, TX
NPDES: Not available

Off-site

Organic
Chemicals
Manuf.



350

0.069

0.26

2.42

788

0

Waste-

Surface









52,000

0

water

water









3

11

Treatment



20

1.200

4.51

42.14

788

0

















52,000

0

















3

17



Off-site

Organic
Chemicals
Manuf.



350

0.015

0.0564

0.53

788

0



Waste-

Surface









52,000

0



water

water









3

5

Solvents & Chemicals,

Pearland, TX
NPDES: Not available

Treatment



20

0.265

1.01

9.48

788

0















52,000

0















3

40



Organic
Chemicals
Manuf.



350

0.015

0.30

2.77

788

0



Surface

Surface









52,000

0



Water

water









3

12







20

0.265

5.34

49.91

788

0

















52,000

0

Page 474 of 748


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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

0





Surrogate
NPDES
KS0043036



350

0.015

0.02

0.07

788

0



Surface

Surface









52,000

0



Water

water









3

0

Occidental Chemical Corp
Wichita,

Wichita, KS





20

0.265

0.27

1.33

788

0















52,000

0

















17

NPDES: KS0096903 and
Organic ChemMFG SIC















3

Off-site

Organic
Chemicals
Manuf.



350

0.015

0.0564

0.53

788

0

Waste-

Surface









52,000

0



water

water









3

5



Treatment



20

0.265

1.01

9.48

788

0

















52,000

0

OES: Processing as a Reactant

















3

5



Off-site

Organic
Chemicals
Manufacture



350

0.005

0.0188

0.18

788

0



Waste-

Surface









52,000

0



water

water









3

2



Treatment



20

0.089

0.33

3.13

788

0

440 unknown sites8















52,000

0

NPDES: Not applicable















3

23





Organic
Chemicals
Manufacture



350

0.005

0.0989

0.92

788

0



Surface

Surface









52,000

0



Water

water









3

7







20

0.089

1.76

16.45

788

0

















52,000

0















0.00073
7

3

0

Arkema Inc.
Calvert City, KY
NPDES: KY0003603







350

0.017

0.000197

788

0

Surface

NPDES

Surface







52,000

0

Water

KY0003603

water









3

0







20

0.295

0.00342

0.128

788

0

















52,000

0









350

0.0128

0.0000158



3

0

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Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

Honeywell International -
Geismar Complex,

Geismar, LA
NPDES: LA0006181













0.00005

788

0

Surface
Water

NPDES
LA0006181

Surface
water







18

52,000

0







0.00090
7

3

0

20

0.224

0.000276

788

0













52,000

0

















3

350

Praxair Technology Center,
Tonawanda, NY
NPDES: NY0000281







350

0.00169

n/a

169.00

788

0

Surface

NPDES

Still body









52,000

0

Water

NY0000281









3

20







20

0.030

n/a

3000.00

788

20

















52,000

0

OES: OTVD (Includes releases for Closed-Loop Degreasing, Conveyorized Degreasing, Web Degreasing, and Metalworking Fluids)

















3

0

Texas Instruments, Inc.,

Attleboro, MA
NPDES: MA0001791







260

0.005

0.00502

0.0188

788

0

Surface

NPDES

Surface









52,000

0

Water

MA0001791

water









3

0







20

0.067

0.0673

0.25

788

0

















52,000

0

















3

0

Accellent Inc/Collegeville
Microcoax, Collegeville, PA
NPDES: PA0042617







260

0.002

0.00711

0.0425

788

0

Surface

NPDES

Surface









52,000

0

Water

PA0042617

water









3

0







20

0.029

0.10

0.62

788

0

















52,000

0

















3

0

Ametek Inc. U.S. Gauge Div.,
Sellersville, PA
NPDES: PA0056014



Surrogate
NPDES
PA0020460



260

0.001

0.0113

0.0619

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.011

0.12

0.68

788

0

















52,000

0

Atk-Allegany Ballistics Lab

Surface

NPDES

Surface

260

0.0005

0.000669

0.00311

3

0

(Nirop),

Water

WV0020371

water

788

0

Page 476 of 748


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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

Keyser, WV















52,000

0

NPDES: WV0020371















3

0









20

0.0061

0.00803

0.0373

788

0

















52,000

0

Handy & Harman Tube



















Co/East Norriton, Norristown,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

PA

NPDES: PA0011436

Water

exceed the most sensitive COC using the most conservative input assumptions.



















3

260

US Nasa Michoud Assembly
Facility,



Surrogate
NPDES
LA0003280



260

1.96

n/a

765.63

788

0

Surface

Still body









52,000

0

New Orleans, LA

Water









3

20

NPDES: LA0052256





20

25.44

n/a

9937.50

788

20

















52,000

0

















3

117

GM Components Holdings
LLC,







260

0.13

3.14

10.97

788

0

Surface

NPDES

Surface









52,000

0

Lockport, NY

Water

NY0000558

water









3

20

NPDES: NY0000558







20

1.71

41.38

144.47

788

0

















52,000

0

















3

27

Akebono Elizabethtown Plant,
Elizabethtown, KY
NPDES: KY0089672



Surrogate
NPDES
KY0022039



260

0.07

1.15

4.87

788

0

Surface

Surface









52,000

0

Water

water









3

16





20

0.897

14.77

62.38

788

0

















52,000

0

















3

0

Delphi Harrison Thermal
Systems,







260

0.04

0.0175

0.0752

788

0

Surface

NPDES

Surface









52,000

0

Dayton, OH

Water

OH0009431

water









3

0

NPDES: OH0009431







20

0.465

0.20

0.87

788

0

















52,000

0

Chemours Company Fc LLC,







260

0.03

0.000631

0.00301

3

0

Page 477 of 748


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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

Washington, WV















788

0

NPDES: WV0001279

Surface

NPDES

Surface









52,000

0













0



Water

WV0001279

water









J



20

0.334

0.00703

0.0335

788

0

















52,000

0

















3

38

Equistar Chemicals Lp,

La Porte, TX
NPDES: TXO119792



Primary Metal
Forming
Manuf.



260

0.02

0.46

2.22

788

1

Surface

Surface









52,000

0

Water

water









3

12





20

0.218

5.06

24.44

788

1

















52,000

0

















3

0

GE Aviation,
Lynn, MA
NPDES: MA0003905







260

0.01

n/a

0.0425

788

0

Surface

NPDES

Still water









52,000

0

Water

MA0003905









3

0







20

0.128

n/a

0.54

788

0

















52,000

0

















3

28

Certa Vandalia LLC,

Vandalia, OH
NPDES: OHO 122751



Primary Metal
Forming
Manuf.



260

0.01

0.23

1.11

788

0

Surface

Surface









52,000

0

Water

water









3

9





20

0.107

2.46

11.89

788

1

















52,000

0

















3

0

GM Components Holdings
LLC Kokomo Ops,







260

0.01

0.0387

0.20

788

0

Surface

NPDES

Surface









52,000

0

Kokomo, IN

Water

IN0001830

water









3

0

NPDES: IN0001830







20

0.086

0.33

1.73

788

0

















52,000

0

Amphenol Corp-Aerospace

Surface
Water

NPDES
NY0003824

Surface
water









3

0

Operations,

260

0.01

0.00882

0.0486

788

0

Sidney, NY









52,000

0

Page 478 of 748


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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

NPDES: NY0003824















3

0









20

0.082

0.0723

0.40

788

0

















52,000

0















0.00040
0

3

3

Emerson Power Trans Corp,
Maysville, KY
NPDES: KY0100196



Surrogate
NPDES
KY0020257



260

0.01

0.000076

788

3

Surface

Surface







52,000

3

Water

water









3

0





20

0.081

0.000995

0.00522

788

0

















52,000

0

















3

0

Olean Advanced Products,
Olean, NY
NPDES: NY0073547



Surrogate
NPDES
NY0027162



260

0.01

0.00462

0.0188

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.068

0.0314

0.13

788

0

















52,000

0

















3

24

Hollingsworth Saco Lowell,
Easley, SC
NPDES: SC0046396



Primary Metal
Forming
Manuf.



260

0.00469

0.11

0.52

788

0

Surface

Surface









52,000

0

Water

water









3

6





20

0.061

1.40

6.78

788

1

















52,000

0

















3

1

Trelleborg YSH Incorporated
Sandusky Plant,







260

0.00360

0.21

1.76

788

0

Surface

NPDES

Surface









52,000

0

Sandusky, MI

Water

MI0028142

water









3

4

NPDES: MI0028142







20

0.047

2.69

23.04

788

0

















52,000

0

















3

2

Timken Us Corp Honea Path,

Surface
Water

Surrogate

Surface
water

260

0.00355

0.20

1.06

788

0

Honea Path, SC

NPDES









52,000

0

NPDES: SC0047520

SC0000698

20

0.0462

2.63

13.77

3

5









788

0

Page 479 of 748


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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0

Johnson Controls







260

0.00228

0.0068

0.0548

788

0

Incorporated,

Surface

NPDES

Surface









52,000

0

Wichita, KS

Water

KS0000850

water









3

0

NPDES: KS0000850







20

0.0296

0.0898

0.72

788

0

















52,000

0

National Railroad Passenger
Corporation (Amtrak)
Wilmington Maintenance















3

21



Primary Metal
Forming
Manuf.



260

0.00203

0.0467

0.230

788

0

Surface

Surface









52,000

0

Facility,

Water

water









3

3

Wilmington, DE





20

0.026

0.60

2.89

788

0

NPDES: DE0050962















52,000

0

















3

0

Electrolux Home Products







260

0.00201

0.00644

0.0171

788

0

(Formerly Frigidaire),

Surface

NPDES

Surface









52,000

0

Greenville, MI

Water

MI0002135

water









3

0

NPDES: MI0002135







20

0.026

0.0834

0.22

788

0

















52,000

0

















3

0

Rex Heat Treat Lansdale Inc,
Lansdale, PA
NPDES: PA0052965



Surrogate
NPDES
PA0026182



260

0.00194

0.00896

0.0523

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.025

0.12

0.67

788

0

















52,000

0

















3

0

Carrier Corporation,

Syracuse, NY
NPDES: NY0001163







260

0.00177

n/a

0.220

788

0

Surface

NPDES

Still water









52,000

0

Water

NY0001163









3

0







20

0.023

n/a

2.84

788

0

















52,000

0

Cascade Corp (0812100207),







260

0.00117

0.0269

0.130

3

18

Page 480 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

Springfield, OH















788

0

NPDES: OH0085715

Surface
Water

Primary Metal

Surface
water









52,000

0



Forming









3

3



Manuf.

20

0.015

0.35

1.67

788

0

















52,000

0















0.00075

3

3

0

USAF-Wurtsmith Afb,

Oscoda, MI
NPDES: MI0042285



Surrogate
NPDES
MI0028282



260

0.00115

0.000320

788

0

Surface

Surface







52,000

0

Water

water









3

0





20

0.015

0.00417

0.00983

788

0

















52,000

0

















3

0

AAR Mobility Systems,
Cadillac, MI
NPDES: MI0002640



Surrogate
NPDES
MI0020257



260

0.00112

0.00413

0.00916

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.014

0.0517

0.11

788

0

















52,000

0

















3

0

Eaton Mdh Company Inc,
Kearney, NE
NPDES: NE0114405



Surrogate
NPDES
NE0052647



260

0.00107

n/a

0.130

788

0

Surface

Still water









52,000

0

Water









3

0





20

0.014

n/a

1.69

788

0

















52,000

0

















3

0

Lake Region Medical,

Trappe, PA
NPDES: PA0042617







260

0.000500

0.00178

0.0106

788

0

Surface

NPDES

Surface









52,000

0

Water

PA0042617

water









3

0







20

0.007

0.0249

0.15

788

0

















52,000

0

Motor Components LLC,

Surface
Water

NPDES
NY0004081

Surface
water









3

0

Elmira, NY

260

0.00096

0.0143

0.0618

788

0

NPDES: NY0004081









52,000

0

Page 481 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















3

0









20

0.0125

0.19

0.83

788

0

















52,000

0

















3

17

Salem Tube Mfg,
Greenville, PA
NPDES: PA0221244



Primary Metal
Forming
Manuf.



260

0.000897

0.0206

0.0997

788

0

Surface

Surface









52,000

0

Water

water









3

2





20

0.012

0.28

1.33

788

0

















52,000

0

















3

0

GE (Greenville) Gas Turbines
LLC,







260

0.000806

0.0378

0.0821

788

0

Surface

NPDES

Surface









52,000

0

Greenville, SC

Water

SC0003484

water









3

0

NPDES: SC0003484







20

0.010

0.47

1.02

788

0

















52,000

0

















3

16

Parker Hannifin Corporation,
Waverly, OH
NPDES: OH0104132



Primary Metal
Forming
Manuf.



260

0.000747

0.0172

0.0830

788

0

Surface

Surface









52,000

0

Water

water









3

2





20

0.010

0.23

1.11

788

0

















52,000

0

















3

0

Mahle Engine Components
Usa Inc,







260

0.000742

0.00808

0.0336

788

0

Surface

NPDES

Surface









52,000

0

Muskegon, MI

Water

MI0004057

water









3

0

NPDES: MI0004057







20

0.010

0.11

0.45

788

0

















52,000

0

General Electric Company -
Waynesboro,
Waynesboro, VA















3

0

Surface
Water

NPDES
VA0002402

Surface
water

260

0.000733

0.00241

0.00705

788

0









52,000

0











0

NPDES: VA0002402







20

0.010

0.0329

0.0962

3







788

0

Page 482 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0

Globe Engineering Co Inc,
Wichita, KS
NPDES: KS0086703



Surrogate
NPDES
KS0043036



260

0.00173

0.00175

0.00853

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.023

0.0232

0.110

788

0

















52,000

0

















3

0

Gayston Corp,
Dayton, OH
NPDES: OHO 127043



Surrogate
NPDES
OH0024881



260

0.000643

0.000281

0.00121

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.008

0.0035

0.0150

788

0

















52,000

0















0.00022
1

3

0

Styrolution America LLC,
Channahon, IL
NPDES: IL0001619







260

0.000637

0.0000845

788

0

Surface

NPDES

Surface







52,000

0

Water

IL0001619

water









3

0







20

0.008

0.00106

0.00278

788

0

















52,000

0















0.00079
9

3

0

Remington Arms Co Inc,
Ilion, NY
NPDES: NY0005282







260

0.000612

0.000291

788

0

Surface

NPDES

Surface







52,000

0

Water

NY0005282

water









3

0







20

0.008

0.00380

0.0104

788

0

















52,000

0















0.00008
22

3

0

United Technologies
Corporation, Pratt And
Whitney Division,
East Hartford, CT
NPDES: CT0001376







260

0.000480

0.0000218

788

0

Surface

NPDES

Surface







52,000

0

Water

CT0001376

water









3

0







20

0.006

0.000273

0.00103

788

0















52,000

0









260

0.000470

0.000629

0.00292

3

0

Page 483 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

Atk-Allegany Ballistics Lab
(Nirop),

Keyser, WV
NPDES: WV0020371















788

0

Surface
Water

NPDES
WV0020371

Surface
water









52,000

0









3

0

20

0.006

0.00803

0.0373

788

0















52,000

0

















3

0

Sperry & Rice Manufacturing
Co LLC,







260

0.000328

0.00117

0.00569

788

0

Surface

NPDES

Surface









52,000

0

Brookville, IN

Water

IN0001473

water









3

0

NPDES: IN0001473







20

0.004

0.0143

0.0694

788

0

















52,000

0

















3

0

Owt Industries,
Pickens, SC
NPDES: SC0026492







260

0.000314

0.000820

0.00213

788

0

Surface

NPDES

Surface









52,000

0

Water

SC0026492

water









3

0







20

0.004

0.0104

0.0272

788

0

















52,000

0

















3

0

Boler Company,
Hillsdale, MI
NPDES: MI0053651



Surrogate
NPDES
MI0022136



260

0.000269

0.00461

0.0204

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.003

0.0514

0.23

788

0

















52,000

0















0.00091
1

3

0

Mccannalnc.,
Carpentersville, IL
NPDES: IL0071340



Surrogate
NPDES
IL0027944



260

0.000268

0.000260

788

0

Surface

Surface







52,000

0

Water

water









3

0





20

0.003

0.00291

0.0102

788

0

















52,000

0

Cutler Hammer,

Surface
Water

Surrogate

Surface
water









3

0

Horseheads, NY

NPDES

260

0.000238

0.00352

0.0153

788

0

NPDES: NY0246174

NY0004081









52,000

0

Page 484 of 748


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PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

0









20

0.003

0.0443

0.19

788

0

















52,000

0

















3

5

US Air Force Offutt Afb Ne,
Offutt A F B, NE
NPDES: NE0121789



Primary Metal
Forming
Manuf.



260

0.000159

0.00366

0.0177

788

0

Surface

Surface









52,000

0

Water

water









3

2





20

0.002

0.0460

0.22

788

0

















52,000

0















0.00074
1

3

0

Troxel Company,
Moscow, TN
NPDES: TN0000451







260

0.000134

0.000254

788

0

Surface

NPDES

Surface







52,000

0

Water

TN0000451

water









3

0







20

0.002

0.00379

0.0111

788

0

















52,000

0

















3

3

Austin Tube Prod,
Baldwin, MI
NPDES: MI0054224



Primary Metal
Forming
Manuf.



260

0.000114

0.00262

0.0127

788

0

Surface

Surface









52,000

0

Water

water









3

1





20

0.001

0.023

0.11

788

0

















52,000

0

















3

0

LS Starrett Precision Tools,
Athol, MA
NPDES: MA0001350







260

0.000102

0.000339

0.00153

788

0

Surface

NPDES

Surface









52,000

0

Water

MA0001350

water









3

0







20

0.001

0.00333

0.015

788

0

















52,000

0

















3

2

Avx Corp,

Surface
Water

Primary Metal

Surface
water

260

0.0000883

0.00203

0.00981

788

0

Raleigh, NC

Forming









52,000

0

NPDES: NC0089494

Manuf.

20

0.001

0.023

0.11

3

1









788

0

Page 485 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

Indian Head Division, Naval
Surface Warfare Center,

Indian Head, MD
NPDES: MD0003158

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

General Dynamics Ordnance
Tactical Systems,
Red Lion, PA
NPDES: PA0043672

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Trane Residential Solutions -
Fort Smith,

Fort Smith, AR
NPDES: AR0052477

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Lexmark International Inc.,
Lexington, KY
NPDES: KY0097624

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Alliant Techsystems
Operations LLC,
Elkton, MD
NPDES: MD0000078

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Daikin Applied America, Inc.
(Formally Mcquay
International),
Scottsboro, AL
NPDES: AL0069701

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Beechcraft Corporation,
Wichita, KS
NPDES: KS0000183

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Federal-Mogul Corp,

Scottsville, KY
NPDES: KY0106585

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Cessna Aircraft Co (Pawnee
Facility),

Wichita, KS
NPDES: KS0000647

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

N.G.I,
Parkersburg, WV

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Page 486 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

NPDES: WV0003204





Hyster-Yale Group, Inc,
Sulligent, AL
NPDES: AL0069787

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

Hitachi Electronic Devices
(Usa), Inc.,
Greenville, SC
NPDES: SC0048411

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

OES: Spot Cleaning and Carpet Cleaning

















3

0

Boise State University,

Boise, ID
NPDES: IDG911006



Surrogate
NPDES
ID0023981



300

0.00008

0.000205

0.00388

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.001

0.00256

0.0485

788

0

















52,000

0

Venetian Hotel And Casino,
Las Vegas, NV
NPDES: NV0022888

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

63,746 unknown sites
NPDES: All POTW SIC

Surface
Water or
POTW

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to
exceed the most sensitive COC using the most conservative input assumptions.

OES: Repackaging

















3

194

Hubbard-Hall Inc,

Waterbury, CT
NPDES: Unknown

Off-site

Receiving
Facility:



250

1.108

5.33

27.18

788

0

Waste-

Surface









52,000

0

water

Recycle Inc.;

water









3

20

Treatment

POTW (Ind.)



20

13.85

66.45

339.11

788

1

















52,000

0

















3

2

Oiltanking Houston Inc,
Houston, TX
NPDES: TX0091855



Surrogate
NPDES
TX0065943



250

0.003

0.32

6.52

788

0

Surface

Surface









52,000

0

Water

water









3

4





20

0.041

4.36

89.13

788

0

















52,000

0

Page 487 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)















0.00002
23

3

0

St. Gabriel Terminal,

Saint Gabriel, LA
NPDES: LA0005487







250

0.00550

0.00000677

788

0

Surface

NPDES

Surface







52,000

0

Water

LA0005487

water







0.00027
9

3

0







20

0.069

0.0000850

788

0















52,000

0















0.00001
89

3

0

Vopak Terminal Westwego
Inc,



Surrogate
NPDES
LA0042064



250

0.00468

0.00000576

788

0

Surface

Surface







52,000

0

Westwego, LA

Water

water







0.00023
5

3

0

NPDES: LAO 124583





20

0.058

0.0000714

788

0















52,000

0

Research Solutions Group Inc,
Pelham, AL
NPDES: AL0074276

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



Carlisle Engineered Products
Inc, Middlefield, OH
NPDES: OH0052370

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



OES: Process Solvent Recycling and Worker Handling of Wastes

















3

250

Clean Water Of New York



Surrogate
NPDES
NJ0000019



250

0.004

n/a

11.76

788

0

Inc,

Surface

Still body









52,000

0

Staten Island, NY

Water









3

20

NPDES: NY0200484





20

0.047

n/a

138.24

788

0

















52,000

0

Reserve Environmental



















Services,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Ashtabula, OH

Water

exceed the most sensitive COC using the most conservative input assumptions.



NPDES: OH0098540



















VeoliaEs Technical Solutions
LLC,

Middlesex, NJ

Off-site
Waste-
water

Receiving
Facility:
Middlesex











3

0



250

24.1

n/a

2.85

788

0

Still body









52,000

0













20

NPDES: NJ0020141

Treatment

Cnty UA;



20

301.78

n/a

35.72

3



788

0

Page 488 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)





NPDES











52,000

0





NJ0020141



























3

110

Clean Harbors Deer Park

Off-site





250

0.35

1.68

8.57

788

0

LLC,

Waste-

POTW (Ind.)

Surface









52,000

0

La Porte, TX

water

water









3

19

NPDES: TX0005941

Treatment





20

4.36

20.92

106.75

788

0

















52,000

0

















3

6

Clean Harbors El Dorado

Off-site





250

0.04

0.19

0.98

788

0

LLC,

Waste-

POTW (Ind.)

Surface









52,000

0

El Dorado, AR

water

water









3

11

NPDES: AR0037800

Treatment





20

0.455

2.21

11.26

788

0

















52,000

0

OES: Adhesives, Sealants, Paints, and Coatings

Able Electropolishing Co Inc,
Chicago, IL



Adhesives and

Surface
water









3

8

POTW

Sealants

250

0.298

0.86

7.28

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0









250

0.00033

0.00252

0.00716

788

0

Garlock Sealing Technologies,
Palmyra, NY
NPDES: NY0000078

Surface

NPDES

Surface









52,000

0

Water

NY0000078

water









3

0









20

0.00407

0.0312

0.0889

788

0

















52,000

0

Ls Starrett Co,
Athol, MA
NPDES: MAR05B615

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



Aerojet Rocketdyne8, Inc.,
East Camden, AR















3

0

Surface

Adhesives and
Sealants
Manuf.

Surface

250

0.013

0.20

1.67

788

0

NPDES: AR0051071,

Water

water









52,000

0

ARR00A521, ARR00A520







20

0.160

2.42

20.57

3

3

Page 489 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0

















52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Best One Tire & Service8,

Water

Adhesives and

Surface
water









3

3

Nashville, TN



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Bridgestone Aircraft Tire

Water

Adhesives and

Surface
water









3

3

(Usa), Inc.8,
Mayodan, NC
NPDES: Not available



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0

Clayton Homes Inc8,
Oxford, NC

Surface
Water

Adhesives and

Surface
water

250

0.013

0.20

1.67

788

0

Sealants









52,000

0

NPDES: Not available

Manuf.

20

0.160

2.42

20.57

3

3









788

0

Page 490 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Cmh Manufacturing, Inc.
Dba Schult Homes - Plant

Surface













52,000

0

Water

Adhesives and

Surface
water









3

3

958s,



Sealants

20

0.160

2.42

20.57

788

0

Richfield, NC
NPDES: Not available



Manuf.









52,000

0















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

2









250

0.013

0.31

1.10

788

0



Surface

NPDES











52,000

0



Water

NY0000558











3

11

Delphi Thermal Systems8,





Surface
water

20

0.160

3.87

13.50

788

0

Lockport, NY
NPDES: NY0000558













52,000

0



No info on











3

0





receiving
facility;
Adhesives and
Sealants
Manuf.











788

0



POTW



250

0.013

0.0374

0.32

52,000

0

Green Bay Packaging Inc -
Coon Rapids8,















3

0

Surface

Adhesives and
Sealants
Manuf.

Surface

250

0.013

0.20

1.67

788

0

Coon Rapids, MN
NPDES: Not available

Water

water









52,000

0







20

0.160

2.42

20.57

3

3

Page 491 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Mastercraft Boat Company8,
Vonore, TN
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Michelin Aircraft Tire
Company8,
Norwood, NC
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

M-Tek, Inc8,
Manchester, TN
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

Page 492 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.08

0.18

788

0



Surface

NPDES











52,000

0



Water

IL0000230











3

7

Olin Corp8,





Surface
water

20

0.160

1.03

2.26

788

0

East Alton, IL
NPDES: IL0000230













52,000

0



No info on











3

0





receiving
facility;
Adhesives and
Sealants
Manuf.











788

0



POTW



250

0.013

0.0374

0.32

52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Parker Hannifin Corp -

Water

Adhesives and

Surface
water









3

3

Paraflex Division8,
Manitowoc, WI
NPDES: Not available



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0

Parrish Tire Company8,

Yadkinville, NC
NPDES: Not available

Surface

Adhesives and
Sealants
Manuf.

Surface

250

0.013

0.20

1.67

788

0

Water

water









52,000

0









20

0.160

2.42

20.57

3

3

Page 493 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Republic Doors And Frames8,
Mckenzie, TN
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Ro-Lab Rubber
Company Inc.8,
Tracy, CA
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Royale Comfort Seating, Inc.8
-Plant No. 1,
Taylorsville, NC
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

Page 494 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Snider Tire, Inc.8,
Statesville, NC

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Snyder Paper Corporation8,
Hickory, NC

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Stellana Us8,
Lake Geneva, WI
NPDES: Not available

Surface

Adhesives and
Sealants
Manuf.

Surface









52,000

0

Water

water









3

3









20

0.160

2.42

20.57

788

0

















52,000

0

Page 495 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Thomas Built Buses -
Courtesy Road8,
High Point, NC
NPDES: Not available

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Unicel Corp8,
Escondido, CA

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Acme Finishing Co Lie8,
Elk Grove Village, IL

Surface

Adhesives and

Surface
water









52,000

0

Water

Sealants









3

3

NPDES: Not available



Manuf.

20

0.160

2.42

20.57

788

0

















52,000

0



POTW





250

0.013

0.0374

0.32

3

0

Page 496 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0

52,000

0

Aerojet Rocketdyne, Inc.8,
Rancho Cordova, CA
NPDES: CA0004111

Surface
Water

NPDES
CA0004111

Surface
water

250

0.013

0.000295

0.00081
8

3

0

788

0

52,000

0

20

0.160

0.00363

0.0101

3

0

788

0

52,000

0

POTW

No info on
receiving
facility;

Adhesives and
Sealants
Manuf.

250

0.013

0.0374000

0.32000
0

3

0

788

0

52,000

0

Allegheny Cnty Airport Auth/
Pgh Intl Airport8, Coroapolis
Pittsburgh, PA
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Amphenol Corp -
Aerospace Operations8,

Sidney, NY
NPDES: NY0003824

Surface
Water

NPDES
NY0003824

Surface
water

250

0.013

0.0115

0.0631

3

0

788

0

52,000

0

20

0.160

0.14

0.78

3

0

788

0

52,000

0

Page 497 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)





No info on











3

0





receiving
facility;
Adhesives and
Sealants
Manuf.











788

0



POTW



250

0.013

0.03740

0.3200

52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Aprotech Powertrain8,
Asheville, NC

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Coating & Converting Tech
Corp /

Adhesive Coatings8,

Surface













52,000

0

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

Philadelphia, PA
NPDES: Not available



Manuf.









52,000

0















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0

Corpus Christi Army Depot8,
Corpus Christi, TX

Surface
Water

Adhesives and

Surface
water

250

0.013

0.20

1.67

788

0

Sealants









52,000

0

NPDES: Not available

Manuf.

20

0.160

2.42

20.57

3

3









788

0

Page 498 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Electronic Data Systems
Camp Pendleton8, Camp

Pendleton, CA
NPDES: Not available

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Florida Production

Water

Adhesives and

Surface
water









3

3

Engineering, Inc.8,
Ormond Beach, FL
NPDES: Not available



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Goodrich Corporation8,

Jacksonville, FL
NPDES: Not available

Surface

Adhesives and
Sealants
Manuf.

Surface









52,000

0

Water

water









3

3









20

0.160

2.42

20.57

788

0

















52,000

0

Page 499 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Kasai North America Inc8,

Water

Adhesives and

Surface
water









3

3

Madison Plant, Madison, MS



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Kirtland Air Force Base8,

Water

Adhesives and

Surface
water









3

3

Albuquerque, NM



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Marvin Windows & Doors8,

Surface

Adhesives and

Surface
water









52,000

0

Warroad, MN

Water

Sealants









3

3

NPDES: Not available



Manuf.

20

0.160

2.42

20.57

788

0

















52,000

0



POTW





250

0.013

0.0374

0.32

3

0

Page 500 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0

52,000

0

Mcneilus Truck &
Manufacturing Inc8,
Dodge Center, MN
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Metal Finishing Co.8 -
Wichita (S Mclean Blvd),
Wichita, KS
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

52,000

0

Murakami Manufacturing Usa
Inc8, Campbellsville, KY
NPDES: Not available

Surface
Water

Adhesives and
Sealants
Manuf.

Surface
water

250

0.013

0.20

1.67

3

0

788

0

52,000

0

20

0.160

2.42

20.57

3

3

788

0

52,000

0

POTW

250

0.013

0.0374

0.32

3

0

788

0

Page 501 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Peterbilt Motors Denton

Water

Adhesives and

Surface
water









3

3

Facility8,
Denton, TX
NPDES: Not available



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Portsmouth Naval Shipyard8,
Kittery, ME

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

R.D. Henry & Co.8,
Wichita, KS

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

Page 502 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

250









250

0.013

n/a

10.83

788

0



Surface

NPDES











52,000

0



Water

RI0000281











3

20

Raytheon Company8,







20

0.160

n/a

133.33

788

0

Portsmouth, RI
NPDES: RI0000281





Still body









52,000

0



No info on











3

0





receiving
facility;
Adhesives and
Sealants
Manuf.











788

0



POTW



250

0.013

0.03740

0.32

52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Rehau Inc8,

Water

Adhesives and

Surface
water









3

3

Cullman, AL



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Rotochopper Inc8,
Saint Martin, MN
NPDES: Not available

Water

Adhesives and
Sealants
Manuf.

Surface









3

3



water

20

0.160

2.42

20.57

788

0

















52,000

0



POTW





250

0.013

0.0374

0.32

3

0







788

0

Page 503 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Rubber Applications8,
Mulberry, FL

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Sapa Precision Tubing
Rockledge, Lie8,
Rockledge, FL
NPDES: Not available

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Thomas & Betts8,

Water

Adhesives and

Surface
water









3

3

Albuquerque, NM



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

Page 504 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Thomas Built Buses - Fairfield

Water

Adhesives and

Surface
water









3

3

Road8,

High Point, NC
NPDES: Not available



Sealants

20

0.160

2.42

20.57

788

0



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Timco,
Dba Haeco Americas

Surface













52,000

0

Water

Adhesives and

Surface
water









3

3

Airframe Services8,



Sealants

20

0.160

2.42

20.57

788

0

Greensboro, NC
NPDES: Not available



Manuf.









52,000

0















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0

Trelleborg Coated Systems

Us, Inc8 -
Grace Advanced Materials,

Surface













52,000

0

Water

Adhesives and

Surface
water









3

3



Sealants

20

0.160

2.42

20.57

788

0

Rutherfordton, NC
NPDES: Not available



Manuf.









52,000

0















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0









250

0.013

0.20

1.67

3

0

Page 505 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















788

0



Surface
Water













52,000

0

U.S. Coast Guard Yard -
Curtis Bay8,













3

3

Adhesives and
Sealants
Manuf.

Surface

20

0.160

2.42

20.57

788

0

Curtis Bay, MD
NPDES: Not available



water









52,000

0















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

















3

0









250

0.013

0.20

1.67

788

0



Surface













52,000

0

Viracon Inc8,

Water

Adhesives and

Surface
water









3

3

Owatonna, MN



Sealants

20

0.160

2.42

20.57

788

0

NPDES: Not available



Manuf.









52,000

0

















3

0



POTW





250

0.013

0.0374

0.32

788

0

















52,000

0

OES: Industrial Processing Aid

















3

0

Occidental Chemical Corp
Niagara Plant,







300

0.019

n/a

0.14

788

0

Surface

NPDES

Still body









52,000

0

Niagara Falls, NY

Water

NY0003336









3

0

NPDES: NY0003336







20

0.292

n/a

2.200

788

0

















52,000

0















0.00041
9

3

0

Stepan Co Millsdale Road,

Surface
Water

NPDES
IL0002453

Surface
water

300

0.001

0.00016

788

0

Elwood, IL







52,000

0

NPDES: IL0002453

20

0.008

0.00128

0.00335

3

0









788

0

Page 506 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

140

Entek International LLC,
Lebanon, OR
NPDES: N/A

Off-site

No info on



300

0.38

1.82

9.30

788

0

Waste-

receiving

Surface









52,000

0

water

facility;

water









3

20

Treatment

POTW (Ind.)



20

5.65

27.11

138.34

788

0

















52,000

0

















3

0

National Electrical Carbon

Products
Dba Morgan Adv Materials,
Fostoria, OH
NPDES: OH0052744

Off-site

Receiving
Facility: City
of Fostoria;

NPDES
OH0052744



300

0.008

0.0336

0.15

788

0

Waste-

Surface









52,000

0

water

water









3

1

Treatment



20

0.115

0.50

2.32

788

0













52,000

0

















3

0

PPG Industries Inc Barberton,
Barberton, OH
NPDES: OH0024007

Off-site

Receiving
Facility: City
of Barberton;

NPDES
OH0024007



300

0.005

0.00478

0.0141

788

0

Waste-

Surface









52,000

0

water

water









3

0

Treatment



20

0.070

0.067

0.20

788

0















52,000

0

















3

0

Daramic LLC,
Corydon, IN
NPDES: IN0020893







300

0.008

0.00572

0.0206

788

0

Surface

NPDES

Surface









52,000

0

Water

IN0020893

water









3

0







20

0.114

0.0816

0.29

788

0

















52,000

0

OES: Commercial Printing and Copying

















3

0

Printing And Pub Sys Div,
Weatherford, OK

Surface
Water



Surface
water

250

0.00020

0.000662

0.00292

788

0

Printing









52,000

0

NPDES: OK0041785











3

0









20

0.00250

0.00827

0.0365











788

0

Page 507 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

OES: Other Industrial Uses

















3

35

Eli Lilly And Company-
Lilly Tech Ctr,







250

1.553

1.63

9.03

788

0

Surface

NPDES

Surface









52,000

0

Indianapolis, IN

Water

IN0003310

water









3

17

NPDES: IN0003310







20

19.410

20.47

113.09

788

0

















52,000

0

















3

1

Oxy Vinyls LP - Deer Park
Pvc,







250

0.148

0.13

0.49

788

0

Surface

NPDES

Surface









52,000

0

Deer Park, TX

Water

TX0007412

water









3

9

NPDES: TX0007412







20

1.854

1.58

5.98

788

0

















52,000

0

















3

22

Washington Penn Plastics,
Frankfort, KY
NPDES: KY0097497



Surrogate
NPDES
KY0028410



250

0.032

1.25

7.53

788

0

Surface

Surface









52,000

0

Water

water









3

13





20

0.399

15.62

94.12

788

0

















52,000

0

















3

0

Natrium Plant,
New Martinsville, WV
NPDES: WV0004359







250

0.022

0.000566

0.00262

788

0

Surface

NPDES

Surface









52,000

0

Water

WV0004359

water









3

0







20

0.274

0.00695

0.0322

788

0

















52,000

0

















3

0

Leroy Quarry,
Leroy, NY
NPDES: NY0247189



Surrogate
NPDES
NY0030546



250

0.019

0.16

0.71

788

0

Surface

Surface









52,000

0

Water

water









3

3





20

0.242

2.05

8.91

788

0

















52,000

0

Page 508 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE





Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

0

George C Marshall Space
Flight Center,



Surrogate
NPDES
AL0025585



250

0.010

0.0738

0.20

788

0

Surface

Surface









52,000

0

Huntsville, AL

Water

water









3

8

NPDES: AL0000221





20

0.128

0.96

2.63

788

0

















52,000

0

















3

30

Whelan Energy Center Power
Plant,







250

0.009

0.67

2.92

788

0

Surface

NPDES

Surface









52,000

0

Hastings, NE

Water

NE0113506

water









3

13

NPDES: NEO113506







20

0.118

8.95

38.96

788

0

















52,000

0















0.00010

3

3

0

Army Cold Regions Research
& Engineering Lab,



Surrogate
NPDES
NHO100099



250

0.0002

0.0000266

788

0

Surface

Surface







52,000

0

Hanover, NH

Water

water









3

0

NPDES: NH0001619





20

0.0029

0.000398

0.00154

788

0

















52,000

0















0.00034
0

3

0

Corning - Canton Plant,

Canton, NY
NPDES: NY0085006



Surrogate
NPDES
NY0034762



250

0.0002

0.000101

788

0

Surface

Surface







52,000

0

Water

water









3

0





20

0.0028

0.00152

0.00510

788

0

















52,000

0

















3

53'

Ames Rubber Corp Plant #1,
Hamburg Boro, NJ
NPDES: NJ0000141



Surrogate
NPDES
NJ00001411



250

0.00011

0.00258

0.0149

788

50'

Surface

Surface









52,000

50'

Water

water









3

6





20

0.00133

0.0304

0.18

788

4

















52,000

4

Gorham,

Surface

POTW (Ind.)

Surface

250

0.0001

0.00253

0.0129

3

0

Providence, RI

Water

water

788

0

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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

NPDES: RIG85E004















52,000

0

















3

0









20

0.0012

0.0253

0.13

788

0

















52,000

0

















3

3

Solvay - Houston Plant,

Houston, TX
NPDES: TX0007072







350

0.024

0.22

4.44

788

0

Surface

NPDES

Surface









52,000

0

Water

TX0007072

water









3

5







20

0.414

3.72

75.93

788

0

















52,000

0















0.00068

Q

3

0

Akzo Nobel Surface







350

0.000329

0.000300

788

0

Chemistry LLC,

Surface

NPDES

Surface









52,000

0

Morris, IL

Water

IL0026069

water









3

0

NPDES: IL0026069







20

0.006

0.00546

0.0125

788

0

















52,000

0















0.00009
41

3

0

Solutia Nitro Site,
Nitro, WV
NPDES: WV0116181



Surrogate
NPDES
WV0023229



350

0.000318

0.0000214

788

0

Surface

Surface







52,000

0

Water

water









3

0





20

0.006

0.000401

0.00176

788

0

















52,000

0

















3

0

Amphenol Corporation -
Columbia,



Organic
Chemicals
Manufacture



350

0.000202

0.00395

0.037

788

0

Surface

Surface









52,000

0

Columbia, SC

Water

water









3

1

NPDES: SC0046264





20

0.004

0.0791

0.74

788

0

















52,000

0

Keeshan and Bost Chemical















3

350

Co., Inc.,

Surface

NPDES

Still body

350

0.000095

n/a

9.50

788

0

Manvel, TX

Water

TX0072168









52,000

0

NPDES: TX0072168







20

0.002

n/a

200.00

3

20

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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(ppb)

7Q10
SWC6
(ppb)

COC
(ppb)

Days of
Exceedance7
(days/yr)

















788

0

















52,000

0

Chemtura North and South



















Plants,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Morgantown WV
NPDES: WV0004740

Water

exceed the most sensitive COC using the most conservative input assumptions.



Indoraina Ventures Olefins,



















LLC,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Sulphur, LA
NPDES: LA0069850

Water

exceed the most sensitive COC using the most conservative input assumptions.



Emerson Power Transmission,
Ithaca, NY
NPDES: NY0002933

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



William E. Warne Power



















Plant,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Los Angeles County, CA
NPDES: CA0059188

Water

exceed the most sensitive COC using the most conservative input assumptions.



Raytheon Aircraft Co(Was
Beech Aircraft), Boulder, CO
NPDES: COG315176

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



OES: Other Commercial Uses

















3

0

Corning Hospital,
Corning, NY
NPDES: NY0246701



Surrogate
NPDES
NY0025721



250

0.013

0.00597

0.0271

788

0

Surface

Surface









52,000

0

Water

water









3

0





20

0.159

0.0735

0.33

788

0

















52,000

0

















3

0

Water Street Commercial



Surrogate
NPDES
OH0009521



250

0.003

0.00131

0.00564

788

0

Bldg,

Surface

Surface









52,000

0

Dayton OH

Water

water









3

0

NPDES: OHO 141496





20

0.035

0.0153

0.0658

788

0

















52,000

0









250

0.00040

0.0196

0.0881

3

213J

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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















788

213J

Union Station North Wing

Surface
Water

Surrogate

Surface
water









52,000

213J

Office Building, Denver, CO

NPDES









3

18

NPDES: COG315293

C00020095J

20

0.00499

0.24

1.10

788

17

















52,000

17

















3

213J

Confluence Park Apartments,
Denver, CO
NPDES: COG315339



Surrogate
NPDES
C00020095J



250

0.00028

0.0137

0.0617

788

213J

Surface

Surface









52,000

213J

Water

water









3

17





20

0.00354

0.17

0.77

788

17

















52,000

17

















3

250

Park Place Mixed Use



Surrogate
NPDES
MD0052868



250

0.00027

n/a

9.00

788

0

Development,

Surface

Still body









52,000

0

Annapolis, MD

Water





n/a



3

20

NPDES: MD0068861





20

0.00334



110.00

788

0

















52,000

0

Tree Top Inc Wenatchee



















Plant,

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Wenatchee, WA

Water

exceed the most sensitive COC using the most conservative input assumptions.



NPDES: WA0051527



















Wynkoop Denver LLCP St,
Denver, CO
NPDES: COG603115

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



Greer Family Lie,
South Burlington, VT
NPDES: VT0001376

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



John Marshall III Site,

Mclean, VA
NPDES: VA0090093

Surface

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to

Water

exceed the most sensitive COC using the most conservative input assumptions.



OES: N/A (WWTP)

New Rochelle STP,

Surface
Water

NPDES
NY0026697











3

0

New Rochelle, NY

Still body

365

0.043

n/a

0.70

788

0

NPDES: NY0026697











52,000

0

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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

coc

(PPb)

Days of
Exceedance7
(days/yr)

















3

20









20

0.786

n/a

12.79

788

0

















52,000

0

















3

0

Everett Water Pollution







365

0.016

0.13

0.17

788

0

Control Facility,

Surface

NPDES

Surface









52,000

0

Everett, WA

Water

WA0024490

water









3

7

NPDES: WA0024490







20

0.299

2.37

3.11

788

0

















52,000

0

















3

2

Sullivan WWTP,
Sullivan, MO
NPDES: MOO 104736







365

0.010

0.16

0.61

788

0

Surface

NPDES

Surface









52,000

0

Water

MOO 104736

water









3

7







20

0.176

2.81

10.97

788

0

















52,000

0

















3

0

Sunnyside STP,
Sunny side, WA
NPDES: WA0020991







365

0.005

0.00146

0.00673

788

0

Surface

NPDES

Surface









52,000

0

Water

WA0020991

water









3

0







20

0.083

0.0242

0.110

788

0

















52,000

0

















3

0

Port Of Sunnyside Industrial
WWTF,







365

0.002

0.0505

0.26

788

0

Surface

POTW (Ind.)

Surface









52,000

0

Sunnyside, WA

Water

water









3

5

NPDES: WA0052426







20

0.035

0.88

4.51

788

0

















52,000

0

















3

0

U.S. Air Force Shaw AFB SC,

Surface
Water



Surface
water

365

0.002

0.0505

0.26

788

0

Shaw AFB, SC

POTW (Ind.)









52,000

0

NPDES: SC0024970



20

0.032

0.81

4.12

3

4









788

0

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Modeled















Name, Location, and ID of
Active Releaser Facility

Release
Media1

Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

















52,000

0

















3

0

Gnf-A Wilmington-Castle
Hayne WWTP,







365

0.0004

0.000304

0.00194

788

0

Surface

NPDES

Surface









52,000

0

Wilmington, NC

Water

NC0001228

water









3

0

NPDES: NC0001228







20

0.0067

0.00533

0.0340

788

0

















52,000

0

















3

0

Cameron Trading Post
WWTP,







365

0.0003

0.00758

0.0387

788

0

Surface

POTW (Ind.)

Surface









52,000

0

Cameron, AZ

Water

water









3

0

NPDES: NN0021610







20

0.0047

0.13

0.64

788

0

















52,000

0















0.00001
27

3

0

Coal Grove WWTP,

Coal Grove, OH
NPDES: OH0104558







365

0.0002

0.00000250

788

0

Surface

NPDES

Surface







52,000

0

Water

OH0029432

water









3

0







20

0.0031

0.0000375

0.00019

788

0

















52,000

0

1 Release media are either direct (release from facility directly to surface water) or indirect (transfer of wastewater from active facility to a receiving POTW or
non-POTW WWTP facility). A wastewater treatment removal rate of 81% is applied to all indirect releases.

2 If a valid NPDES of facility was not available in EFAST, the release was modeled using either a surrogate representative facility in EFAST (based on

location discharging into the same water body) or a representative generic industry sector.

3 EFAST uses ether the "surface water" model, for rivers and streams, or the "still water" model, for lakes, bays, and oceans.





4	Modeling was conducted with the maximum days of release per year expected. For direct releasing facilities, a minimum of 20 days was also modeled.

5	The daily release amount was calculated from the reported annual release amount divided by the number of release days per year.

6	For releases discharging to lakes, bays, estuaries, and oceans, the acute scenario mixing zone water concentration was reported in place of the 7Q10 SWC.

7	To determine the PDM days of exceedance for still bodies of water, the release days provided by the EPA Engineers is equal to the days of exceedance only
if the predicted surface water concentration exceeds the COC. Otherwise, the days of exceedance can be assumed to be zero.

8 Predicted water releases for the indicated sites changed slightly between modeling and publication of the draft risk evaluation. For the 440 unknown sites in
the Processing as a Reactant OES changed from 1.75 kg/yr to 2.2 kg/yr. For the sites listed under the Adhesives, Sealants, Paints, and Coatings OES, annual

release predictions changed from 3.25 kg/yr to 4.4 kg/yr. These slight differences (i.e., between 0.5 to 1.2 kg/yr) are unlikely to impact risk characterization.

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Name, Location, and ID of
Active Releaser Facility

Release
Media1

Modeled
Facility or
Industry
Sector in
EFAST2

EFAST
Waterbody
Type3

Days of
Release4

Release5
(kg/day)

Harmonic
Mean SWC
(PPb)

7Q10
SWC6
(PPb)

COC
(PPb)

Days of
Exceedance7
(days/yr)

9	The predicted days of exceedance are presented although the estimated 7Q10 never approaches the lowest COC due to the fact that the EFAST database has
minimum stream flow of 0 MLD and a mean stream flow of 2.69 MLD for this site. Therefore, these days of exceedances were not considered in
environmental risk characterization.

10	The predicted days of exceedance are presented although the estimated 7Q10 never approaches the lowest COC due to the fact that the EFAST database has
minimum stream flow of 0 MLD and a mean stream flow of 0 MLD for this site. Therefore, these days of exceedances were not considered in environmental
risk characterization.

122

123

124

125

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Appendix D CONSUMER EXPOSURES
D.1 Model Sensitivity

The CEM developers conducted a detailed sensitivity analysis for CEM, as described in Appendix C of
the CEM User Guide (U.S. EPA. 2019b). The CEM developers included results of model corroboration
analysis in Appendix D of the CEM User Guide (	)).

In brief, the analysis was conducted on continuous variables and categorical variables that were used in
CEM emission or dermal models. A base run of different CEM models using various product or article
categories, along with CEM defaults, was used. Individual variables were modified, one at a time, and
the resulting Acute Dose Rate (ADR) and Chronic Average Daily Dose (CADD) were compared to the
corresponding results for the base run. Benzyl alcohol, a VOC, was used as an example for product
models such as those applied in this evaluation of TCE.

The tested model parameters were increased by 10%. The measure of sensitivity for continuous
variables such as mass of product used, weight fraction, and air exchange rate was "elasticity," defined
as the ratio of percent change in each result to the corresponding percent change in model input. A
positive elasticity indicates that an increase in the model parameter resulted in an increase in the model
output, whereas a parameter with negative elasticity is associated with a decrease in the model output.
For categorical variables such as receptor activity pattern (i.e., work schedule) and room of use, the
percent difference in model outputs for different category pairs was used as the measure of sensitivity.

The results are summarized below for the inhalation and dermal models used to evaluate consumer
exposures to TCE (i.e., emission models El and E3 and the dermal permeability model P_DER2b. For
full results and additional background, refer to Appendix C of the CEM User Guide (	>).

D.l.l Continuous Variables

For acute exposures generated from emission model El, WF (weight fraction) and M acute (mass of
product used) have the greatest positive elasticities of the tested parameters (see FigureApx D-l). The
next most sensitive parameters demonstrate negative elasticity and include: Vol Building (building
volume); AER_Zone2 (air exchange rate in Zone 2); AER Zonel (air exchange rate in Zone 1);
Vol Zonel (room of use, or Zone 1 volume). Inhalation exposures from liquid consumer product
formulations were modeled using El and the two most sensitive variables identified in this analysis were
varied to estimate a range of exposures.

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El Elasticity for ADR and CADD

WF
VP*

VP

Vol_Zonel
Vol_Building
Q_zl2
MW*

MW

M_Chronic
M_Acute
AER_Zone2
AER_Zonel

1.2

FigureApx D-l. Elasticities (> 0.05) for Parameters Applied in El

For acute exposures generated from emission model E3, WF (weight fraction) and M acute (mass of
product used) have the greatest positive elasticities of the tested parameters (see Figure Apx D-2). The
next most sensitive parameters demonstrate negative elasticity and include: Vol Building (building
volume); AER_Zone2 (air exchange rate in Zone 2); MW (molecular weight); VP (vapor pressure);
AER Zonel (air exchange rate in Zone 1); Vol Zonel (room of use, or Zone 1 volume). Inhalation
exposures from aerosol or spray consumer product formulations were modeled using E3 and the two
most sensitive variables identified in this analysis were varied to estimate a range of exposures.

-0.8 -0.6 -0.4 -0.2 0	0.2 0.4 0.6 0.8	1

Elasticity (% change in dose/% change in variable)

¦ ADR Negative ~ ADR Positive 13 CADD Negative ~ CADD Positive

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E3 Elasticity for ADR and CADD

WF
VP*

VP

Vol_Zonel
Vol_Building
Q_zl2
MW*

MW

M_Chronic
MAciite
Du rationChron ic
DurationAcute
CSATA

Ae ros o l_Fra ct i o n
AER_Zorie2
AER_Zoriel

-0.7 -0.4 -0.1	0.2	0.5	0.8	1.1

Elasticity (% change in dose/% change in variable)

¦ ADR Negative ¦ ADR Positive ~ CADD Negative ~ CADD Positive
FigureApx D-2. Elasticities (> 0.05) for Parameters Applied in E3

For acute exposures generated from emission model P_DER2b, the chemical properties that inform
absorption rate, or absorption rate estimates, have the greatest elasticities (see Figure Apx D-3). Dermal
exposures from consumer product formulations were modeled using P DER2B with a measured Kp
(permeability coefficient). Therefore, LogKow (octanol/water partition coefficient) and MW (molecular
weight) were not used to estimate skin penetration.

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LogKow*

-2.0	-1.0	0.0	1.0	2.0	3.0

Elasticity (% change in dose/% change in variable)

¦ ADR Megative ~ ADR Positive ~ CADD Negative ~ CADD Positive

FigureApx D-3. Elasticities (> 0.05) for Parameters Applied in P_DER2b

D.1.2 Categorical Variables

For categorical variables there were multiple parameters that affected other model inputs. For example,
varying the room type changed the ventilation rates, volume size and the amount of time per day that a
person spent in the room. Thus, each modeling result was calculated as the percent difference from the
base run. For continuous variables, each modeling result was calculated as elasticity.

Among the categorical variables, the most sensitive parameters included receptor type (adult vs. child),
room of use (Zone 1) selection, and application of the near-field bubble within Zone 1. However, these
types of variables were held constant within a given product modeling scenario and were applied using
consistent assumptions across all modeling scenarios.

D.2 Monitoring Data

D.2.1 Indoor Air Monitoring

Systematic review identified indoor air monitoring studies reporting levels of TCE in residential indoor
air samples. The air concentrations reported in these studies are not used to evaluate risk to consumers
since measurements are not attributable to consumer conditions of use. The full suite of extracted data
(including residential, commercial) and associated data evaluation forms are found in [Data Extraction
Tables for Environmental Monitoring Data. Docket: EPA-HO-OPPT-2019-0500\.

Concentrations of TCE in residential indoor air in the United States and Canada collected from nine
studies identified during Systematic Review are summarized in Table Apx D-l. Overall, more than
1,800 samples were collected between 1986 and 2010 in eleven US states (CA, CO, IL, IN, MA, MI,
MN, NJ, NY, OH, and TX) and Canada (exact location not reported). Concentrations ranged from non-
detect (detection limits varied) to 42 |ig/m3. The highest concentrations were observed in residential
garages and apartment hallways. Measures of central tendency (mean or median) across all studies were
generally less than 1 |ig/m3, with a couple central tendency measurements above 3 |ig/m3.

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209	Data extracted for residential indoor air samples from studies conducted outside of North America, as

210	well as studies conducted in schools and commercial establishments in the US and other countries, are

211	provided in [Data Extraction Tables for Environmental Monitoring Data. Docket: EPA-HQ-OPPT-

212	2019-05001

213

214	TableApx D-l. TCE Residential Indoor Air Concentrations (jig/m3) in the United States and

215	Canada

Study Info

Site Description

LOQ

Min.

Mean

Median

Max.

Variance

Data Eval.
Score

(Chin et aL 2014)

Detroit, MI area; Homes

0.09

ND

0.07

0.04

1.48

0.14 (SD)

High

US, 2009-2010 (n=126; DF =

(n=126) with children















0.06)

with asthma















(Dodson et aL 2008)a
US, 2004-2005 (n=83; DF =

Boston, MA; Interior
room of residences

0.04

ND

0.6

0.2

2.2 (95th)

1.7 (SD)

High

0.93)

















(Dodson et aL 2(>08)a
US, 2004-2005 (n=52; DF =

Boston, MA; Basement
of residences

0.04

ND

0.4

0.1

1.4 (95th)

1.1 (SD)

High

0.75)

















(Dodson et aL 2(>08)a
US, 2004-2005 (n=10; DF =

Boston, MA; Apartment
hallway of residences

0.04

ND

3.7

0.3

23 (95th)

7.3 (SD)

High

0.9)

















(Dodson et aL 2(>08)a
US, 2004-2005 (n=16; DF =

Boston, MA; Garage of
residences

0.04

ND

3.3

0.1

42 (95th)

10 (SD)

High

0.63)

















(Jia et aL. 2008a)

Ann Arbor, Ypsilanti,

0.008

ND

0.06

0.03

2.01

--

Medium

US, 2004-2005

and Dearborn MI;















(n=252; DF = 0.56)

Residences (n=159) in
industrial, urban, and
suburban cities over two
seasons















(Adeate et aL. 2004)

US, 2000 (n=113; DF = 0.828)

Minneapolis, MN;
Inside home, during the
winter. Sampling from
room where child spent
the most time.



ND
(10th
0.1)



0.3





Medium

(Adeate et aL. 2004)

US, 2000 (n=113; DF = 0.737)

Minneapolis, MN;
Inside home, during the
spring. Sampling from
room where child spent
the most time.



ND
(10th
0.1)



0.2





Medium

(Sax et al.. 2004)

US, 2000 (n=32; DF = 0.47)

Los Angeles, CA;
Homes (n=35) in inner-
city neighborhood,
sampled in the fall

0.13

ND

0.2

0.1

0.8

0.2 (SD)

High

(Sax et al. 2004)

US, 2000 (n=40; DF = 0.68)

Los Angeles, CA;
Homes (n=40) in inner-
city neighborhood,
sampled in the winter

0.13

ND

0.2

0.2

1.2

0.3 (SD)

High

(Sax et al. 2004)

New York, NY; Homes

0.13

ND

1.1

0.4

19

3.2 (SD)

High

US, 1999 (n=36; DF = 0.92)

(n=38) in inner-city
neighborhood, sampled
in the winter















(Sax et al. 2004)

New York, NY; Homes

0.13

ND

0.3

0.1

2.6

0.5 (SD)

High

US, 1999 (n=30; DF = 0.44)

(n=41) in inner-city















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Study Info

Site Description

LOQ

Min.

Mean

Median

Max.

Variance

Data Eval.
Score



neighborhood, sampled
in the summer















rsu et al.. 2013)b

US, 1999-2001 (n=539; DF =

NR)

Elizabeth, NJ; Houston,
TX; and Los Angeles,
CA; Non-smoking
households (n=310)





0.99

0.22

1.74 (95th)

7.29 (SD)

Medium

(Clayton et al.. 1999)°

US, 1995-1997 (n=402; DF =

0.361)

IL, IN, OH, MI, MN,
WI (Great Lakes
Region); Non-
institutionalized persons
residing in households
in six states



ND

3.84

0.56

2.28 (90th)



High

(Lindstrom et al., 1995)
US, 1994 (n=9; DF = 0.56)

Denver, CO; Homes,
occupied (n=9)

0.12

ND

0.64

0.61



0.66 (SD)

Medium

(Chan et al.. 1990)
CA, 1987 (n=6; DF = 0.83)

Homes (n=6), main
floor



ND

1.6



5



Medium

(Chan et al.. 1990)

CA, 1986 (n=12; DF = 0.42)

Homes (n=12), main
floor



ND

0.5



2



Medium

Study Info: The information provided includes the citation; country and year samples collected; number of samples and detection
frequency.

Abbreviations: If a value was not reported, it is shown in this table as ND = not detected at the reported detection limit. GSD =

geometric standard deviation. DF = detection frequency. NR = Not reported. US = United States. CA = Canada

Parameters: All statistics are shown as reported in the study. Some reported statistics may be less than the detection limit; the method

of handling non-detects varied by study. All minimum values determined to be less than the detection limit are shown in this table as

"ND." If a maximum value was not provided, the highest percentile available is shown (as indicated in parentheses); if a minimum

value was not provided, the lowest percentile available is shown (as indicated in parentheses).

a Samples from this study were collected as part of the BEAMS study.

b Samples from this study were collected as part of the RIOPA study.

0 Samples from this study were collected as part of the NHEXAS Phase 1 field study.

216

217	D.2.2 Personal breathing Zone Monitoring Data

218	Concentrations of TCE (TCE) in the personal breathing zones of residents in the United States collected

219	from seven studies identified during Systematic Review are summarized in Table Apx D-2. Overall, the

220	measured concentration dataset contains approximately 2,750 samples that were collected between 1981

221	and 2001, and represents time spent in various microenvironments (i.e., home, school, work, transit)

222	during the monitoring period. Only the 3-hr samples from Heavner et al. (1995) represent time inside the

223	home only. Concentrations ranged from non-detect (limits varied) to 327.3 |ig/m3. The highest

224	concentration was observed in samples collected in 2000 as part of the NHANES 1999-2000 study (Jia

225	et al.. 2008b). The study states that the top ten highest concentrations exceeded 300 (J,g/m3, which they

226	suggest may indicate exposure from immediate contact with solvents. The 95th percentile concentration

227	in this study is 7.4 [j,g/m3. All other studies showed maximum concentrations less than 10 |ig/m3.

228	Median concentrations ranged from ND to 1.05 (J,g/m3; and average concentrations ranged from 0.66 to

229	13 |ig/m3.

230

231	Data extracted for residential/general personal breathing zones studies conducted outside of North

232	America, as well as studies conducted in schools and commercial establishments in the US and other

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233	countries, is provided in [Data Extraction Tables for Environmental Monitoring Data. Docket: EPA-

234	HO-OPPT-2019-0500],

235

236	TableApx D-2. Personal Breathing Zone Concentrations (jig/m3) for TCE in the United States

237	(General/Residential) 							



















Data

Study Info

Type

Site Description

LOD

Min.

Mean

Median

Max

Variance

Eval.
Score

(Suetal.. 2013V

48-hr

Elizabeth, NJ; Houston















US, 1999-2001
(n=544; DF = 0.23)



TX; and Los Angeles, CA;
Adults (n=309) and
children (n=l 18) from 310
non-smoking households.

--

ND

1.44

0.22

2.37
(95th)

10.74
(SD)

Medium

(Jia et al.. 2008bV

48-to

Nation-wide; Adults (ages





0.4
(GM)



327.3

3.4
(GSD)



US, 1999-2000

72-hr

20-59 years) in NHANES

0.44

ND

ND

(7.4 -

High

(n=665; DF = 0.229)



study







95th1



(Sexton et al.. 2007)
US, 1999

(n=333;DF = 0.925)

48-hr

Minneapolis -St. Paul, MN;
Adults, non-smoking
(n=70) living in three
neighborhoods: (inner-city,
blue-collar/near
manufacturing plants, and
affluent)

--

ND

1

0.2

1.8
(90th)

--

High

(Clavtonet al.. 1999)°
US, 1995-1997
(n=386; DF = 0.394)

6-day

IL, IN, OH, MI, MN, WI
(Great Lakes Region);
Non-institutionalized
persons

--

ND

5.27

0.63

5.98
(90th)

--

High

(Heavner et al.. 1995)

3-hrs

Columbus, OH; Non-















US, 1991
(n=24; DF = NR)

(in

home

only)

smoking women (n=24)
with non-smoking
husbands

--

ND

1.84

1.05

9.08

2.39

Medium

(Heavner et al.. 1995)

3-hrs

Columbus, OH; Non-















US, 1991
(n=25; DF = NR)

(in

home

only)

smoking (n=25) women
with smoking husbands

--

ND

0.66

ND

3.41

1.04

Medium

(Wallace. 1987V
US, 1981-1984

12-hrs

Elizabeth and Bayonne, NJ,
Los Angeles, CA, and















(n=772; DF = 0-0.97)



Contra Costa, CA; Adults





3.8 to
13













in industrial/ chemical

--

—

--

—

--

High





manufacturing and /or
petroleum refining regions
of the US.













Abbreviations: If a value was not reported, it is shown in this table as "-

LOD = level of detection. ND = not detected at the

reported detection limit. GM = geometric mean. GSD = geometric standard deviation. DF = detection frequency. NR = Not reported.
US = United States.

Parameters: All statistics are shown as reported in the study. Some reported statistics may be less than the detection limit; the method

of handling non-detects varied by study. All minimum values determined to be less than the detection limit are shown in this table as

"ND." If a maximum value was not provided, the highest percentile available is shown (as indicated in parentheses); if a minimum
value was not provided, the lowest percentile available is shown (as indicated in parentheses).
a Samples from this study were collected as part of the RIOPA study.

b Samples from this study were collected as part of the NHANES 1999-2000. The top ten highest concentrations exceeded 300

|ig/ml which the authors suggest may be from immediate contact with solvents.









0 Samples from this study were collected as part of the NHEXAS Phase 1 field study.
d Samples from this study were collected as part of the TEAMS study.









238

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Appendix E ENVIRONMENTAL HAZARDS

E.l Species Sensitivity Distribution (SSD) Methodology

The SSD Toolbox is a resource created by EPA's Office of Research and Development (ORD) that can
fit SSDs to environmental hazard data (Etterson. 2019). It runs on Matlab 2018b (9.5) for Windows 64
bit. For this TCE Risk Evaluation, EPA created two SSDs with the SSD Toolbox, one using only algae
hazard data and the other using acute hazard data for all other aquatic species. This appendix outlines the
methodology used to create each.

For the algae SSD, algae hazard data were curated to prioritize study quality and to assure comparability
between toxicity values (e.g., comparing ECsos to EC50s). The dataset included both saltwater and
freshwater species, because the only saltwater species value was within the range of values reported for
freshwater species. With this dataset, the Toolbox was used to apply a variety of algorithms to fit and
visualize SSDs with different distributions. FigureApx E-l shows the Toolbox interface after each
distribution and fitting method was fit to the data. A hazardous concentration for 5% of species (HC05) is
calculated for each.

Figure Apx E-l. SSD Toolbox interface and list of HCoss for each distribution and fitting method
using TCE's algae hazard data (Etterson, 2019)

¦A SSD Toolbox
File Plot

~

X

C:\U5er5\KKoehrn\DDCuments\RAD\TCE\SSD_TCE_algae_files\Algae_revised.xl5x

Fit Distribution

Fitting Method:

metro poiis-h a stings

Distribution:

burr

Scaling parameters

1.15

Mineau scaling
Target weight: ioo

Goodness of Fit:
Iteration 1000

Units:

mg/L

Status:
Ready

Results:

Distribution

Method

HC 05

1

normal

|

70.7294

0.9930

2

normal

MO

65.4897

1

3

normal

GR

4S.7427

0.9950

4

normal

MH

50.1369

0.0985

5

logistic

ML

61.3796

0.9S20

6

logistic

MO

66.6519

0.9800

7

logistic

GR

43.9740

0.9141

8

logistic

MH

40.85-68

0.1075

9

triangular

ML

86.6386

1

10

triangular

MO

63.S997

1

11

triangular

GR

51.9060

1

12

triangular

MH

57.8295

0.1375

13

g umbel

ML

81.3972

1

14

gumbel

MO

86.4467

1

15

gumbel

GR

67.3150

0.9990

16

gumbel

MH

65.1299

0.1639

17

burr

MH

121.5295

0.0770

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The SSD Toolbox's output contained several methods for choosing an appropriate distribution and
fitting method, including goodness-of-fit and standard error among others. However, choosing the
distribution with the best fit was challenging with a small dataset (e.g., hazard data for 9 algae species).
P values for goodness-of-fit were all above 0.05, showing no evidence for lack of fit, and providing no
help in discriminating among distributions (Figure Apx E-l). Standard error was lowest across fitting
methods for the Gumbel and Burr distributions (TableApx E-l). Because the ability for these measures
to distinguish between distributions was limited, visual inspection of the distributions was used. For
example, visual inspection showed Burr was not a good fit (Figure Apx E-2).

Table Apx E-l. Standard Error for all dsitributions and fitting methods using TCE's algae
hazard data (Etterson, 2019) 			



Normal Distribution

Logistic Distribution

Triangular Distribution

Gumbel Distribution

Bun-

Distribution



ML

MO

GR

MH

ML

MO

GR

MH

ML

MO

GR

MH

ML

MO

GR

MH

MH

Standard Error
for HCos

35.7

33.9

26.1

27.9

36.4

33.7

26.1

29.2

34.0

33.4

26.5

28.9

26.6

28.6

26.2

23.9

20.9

Figure Apx E-2. All distributions and fitting methods in the SSD Toolbox for TCE's algae hazard
data (Etterson, 2019)

1

0.9
0.8
0.7

1 0.6

.Q
£

CL

o) 0.5
>

To

| 0.4

Z>

O

0.3
0.2
0.1
0

1	1.5	2	2.5	3	3.5	4	4.5

Toxicity Value (Log 10[EC50]) mg/L

triangular distributions

	normal distributions

		logistic distributions Synechococcus elongaJf+pTs'

	gumbel distributions 'fy /

burr distribution /// /





~ Desmodesmus subspicattmWw/ i







Synechococcus leopolien&is •/

M • (Mhioreiia kessieri





® CMUydominas rainhartdtii



• Wmmocystm aeruginosa



- o^BBmonem&costatum



~ ^rjflUUKaphido cm lis subcapitata

i

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Using standard error and visual inspection, the distributions with the best fit for the most sensitive algae
species included triangular and Gumbel. The triangular distribution with graphical methods fitting was
the most protective, and was used as a line of evidence for assessing algae in this assessment
(Figure_Apx E-3). The resulting SSD calculated an HCos of 52 mg/L or 52,000 |ig/L.

Figure Apx E-3. TCE algae data fit with triangular distribution fit with graphical methods
(Etterson. 2019)

Toxicity Value (Log 10[EC50]) mg/L

For the acute SSD, acute hazard data for fish, amphibians, and invertebrates were curated to prioritize
study quality and to assure comparability between toxicity values. For example, the dataset included
only LCsos for fish and amphibians, and EC50S or LC50S that measured immobilization and mortality for
aquatic invertebrates. The dataset included both saltwater and freshwater species, because the toxicity
values for saltwater species value were within the range of values reported for freshwater species in the
same taxonomic group. Additionally, for fish and invertebrates, the mode of action for freshwater and
saltwater species expected to be the same. With this dataset, the Toolbox was used to apply a variety of
algorithms to fit and visualize SSDs with different distributions. Figure Apx E-4 shows the Toolbox
interface after each distribution and fitting method was fit to the data. An HCos is calculated for each.

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FigureApx E-4. SSD Toolbox interface showing HCoss and P values for each distribution and
fitting method using TCE's acute hazard data (Etterson, 2019)	

A SSD Toolbox
File Plot

~

X

C:\U sers\KKo eh rn\Do cu ments\RADYTCE\SSD_TCE_a lg a e_f iles\AII_species.xlsx

Fit Distribution

Fitting Method:

metro poiis-h a stings

Distribution

burr

Scaling parameters

Mineau scaling
Target weight: 10Q

1.15

Goodness of Fit:

Iteration 1000

Units

mg/L

Status:
Ready

Results:



Distribution

Method

HC.05

P





1

normal

ML

7.1130

0.8182



2

normal

HO

6.3275

0.7173



3

normal

GR

4.1033

0.4266



4

normal

MH

4.1173

0.390S



5

logistic

ML

6.9555

0.5215



6

logistic

HO

6.4792

0.4785



7

logistic

GR

3.5349

0.1319



8

logistic

MH

3.8530

0.3991



9

triangular

ML

7.2234

1



10

triangular

MO

6.1216

0.9SS0



11

triangular

GR

4.4SE6

0.8122



12

triangular

MH

3.9220

0.445S



13

gumbel

ML

11.9649

0.6783



14

gumbel

MO

9.1953

0.4106



15

gumbel

GR

6.3906

0.1379



16

gumbel

MH

8.7641

0.35B6



17

burr

MH

26.6552

0.9037















Again the SSD Toolbox's output contained several methods for choosing an appropriate distribution and
fitting method, including goodness-of-fit, standard error, and sample-size corrected Akaike Information
Criterion (AICc, rBurnham and Anderson. 20021). P values for goodness-of-fit were all above 0.05,
showing no evidence for lack of fit, and providing no help in discriminating among distributions
(Figure Apx E-4). Standard error was mixed across fitting methods for some distributions but generally
the lowest for the burr distribution (Table Apx E-2). Figure Apx E-5 shows that the gumbel distribution
has the lowest AICc, indicating it may be the best distribution for this data though the relative AIC
support compared to other distributions is weak. Because the ability for these measures to distinguish
between distributions was limited, visual inspection of the distributions was also used. For example,
visual inspection showed Burr was not a good fit (Figure Apx E-6).

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TableApx E-2. Standard Error for all distributions and fitting methods using TCE's acute



Normal Distribution

Logistic Distribution

Triangular Distribution

Gumbel Distribution

Bun-

Distribution



ML

MO

GR

MH

ML

MO

GR

MH

ML

MO

GR

MH

ML

MO

GR

MH

MH

Standard Error
for HC05

5.8

5.2

3.7

3.7

4.8

5.9

3.4

3.8

6.9

5.0

3.9

4.1

4.1

4.6

3.6

3.9

2.9

Figure Apx E-5. AICc for the four distribution options in the SSD Toolbox for TCE's acute
lazard data (Etterson, 2019)	

5 AIC

Percentile of interest:
Model-averaged HCp:
Model-averaged SE of HCp:

9.8989

4.1585

CV of HCp: 0.42011

AICc Table

1

_2_
4

Distribution

AICc

delta AICc Weight

HCp

SE HCp

gumbel
logistic
triangular
normal

84.9297
87.3190
87.9152
88.0905

0

2.8892
2.9865
3.1608

0.5769
0.1747
0.1296
0.1188

11.9649
6.9555
7.2234
7.1130

3.3637
3.7861
2.0728
3.9783

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317

318

319

320

321	EPA used a model average of the Gumhel, logistic, triangular, and normal distributions, because it was

322	not clear which distribution had the best fit after considering standard error, AICc, and visual inspection.

323	The model-averaged HCos from all four distributions was 9.9 mg/L or 9,900 |ig/L, and the SSDs showed

324	aquatic invertebrates were the most sensitive species (FigureApx E-7).

325

1aphnia

Mystdopas bahia

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Figure Apx E-6. All distributions and fitting methods in the SSD Toolbox for TCE's acute hazard
data (Etterson, 2019)

TO
X!

E

CL

Q)
>

_ro
=s
E
zs

O

0.6

¦i 0.4

normal distributions

¦	logistic distributions	Xenopus laevisj
¦triangular distributions

gumbel distributions . ,	, , _ „ „

^	Cypnnodon vaneqatus (sheepshead) •

¦	burr distribution

Lepomis macrochirus (bluegill)
Pimephales promelas (fathead minnow

Manilla ftoridae (flagfish)

fdaphnja dubia

1	1.5	2	2.5

Toxicity Value (Log 10[EC50])

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326	Figtire Apx E-7. TCE's acute hazard data fit with the normal, logistic, triangular, and Gunibel

327	distributions fit with maximum likelihood in the SSD Toolbox (Etterson, 2019)

328

329

330

Toxicity Value (Log 10[EC50])

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333

334

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E.2 Environmental Risk Quotients (RQs) for Facilities Releasing TCE to Surface Water as Modeled
in E-FAST

Table Apx E-3. Environmental

RQs by Facility (with RQs > 1 in bold)

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

OES: Manufacturing

Axiall Corporation.

Westlake, LA
NPDES: LA0007129

Surface
Water

NPDES
LA0007129

Surface
water

350

1.266

0.0051

0.00

0.00

0.00

0.00

20

22.15

0.0897

0.00

0.00

0.03

0.00

Olin Blue Cube,
Freeport, TX
NPDES: Not available

Off-site
Waste-
water
Treatment

Organic

Chemicals

Manuf.

Surface
water

350

0.069

2.42

0.00

0.00

0.81

0.00

20

1.2

42.14

0.01

0.05

14.05

0.00

Solvents & Chemicals,

Pearland, TX
NPDES: Not available

Off-site
Waste-
water
Treatment

Organic

Chemicals

Manuf.

Surface
water

350

0.015

0.53

0.00

0.00

0.18

0.00

20

0.265

9.48

0.00

0.01

3.16

0.00

Surface
Water

Organic

Chemicals

Manuf.

Surface
water

350

0.015

2.77

0.00

0.00

0.92

0.00

20

0.265

49.91

0.02

0.06

16.64

0.00

Occidental Chemical Corp
Wichita,

Wichita, KS
NPDES: KS0096903 and
Organic ChemMFG SIC

Surface
Water

Surrogate

NPDES

KS0043036

Surface
water

350

0.015

0.07

0.00

0.00

0.02

0.00

20

0.265

1.33

0.00

0.00

0.44

0.00

Off-site
Waste-
water
Treatment

Organic

Chemicals

Manuf.

Surface
water

350

0.015

0.53

0.00

0.00

0.18

0.00

20

0.265

9.48

0.00

0.01

3.16

0.00

OES: Processing as a Reactant

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Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

440 unknown sites
NPDES: Not applicable

Off-site
Waste-
water
Treatment

Organic

Chemicals

Manufacture

Surface
water

350

0.005

0.18

0.00

0.00

0.06

0.00

20

0.089

3.13

0.00

0.00

1.04

0.00

Surface
Water

Organic

Chemicals

Manufacture

Surface
water

350

0.005

0.92

0.00

0.00

0.31

0.00

20

0.089

16.45

0.01

0.02

5.48

0.00

Arkerna Inc.
Calvert City, KY
NPDES: KY0003603

Surface
Water

NPDES

KY0003603

Surface
water

350

0.017

0.000737

0.00

0.00

0.00

0.00

20

0.295

0.128

0.00

0.00

0.04

0.00

Honeywell International -
Geismar Complex,
Geismar, LA
NPDES: LA0006181

Surface
Water

NPDES
LA0006181

Surface
water

350

0.0128

0.0000518

0.00

0.00

0.00

0.00

20

0.224

0.000907

0.00

0.00

0.00

0.00

Praxair Technology Center,
Tonawanda, NY
NPDES: NY0000281

Surface
Water

NPDES
NY0000281

Still body

350

0.00169

169

0.05

0.21

56.33

0.00

20

0.03

3000

0.94

3.81

1000.00

0.06

US DOE Paducah Site,

Kevil, KY
NPDES: KY0102083

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

GNF-A Wilmington-Castle
Hayne,
Wilmington NC
NPDES: NC0001228

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: Repackaging

Page 531 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Hubbard-Hall Inc.

Waterbury, CT
NPDES: Unknown

Off-site
Waste-
water
Treatment

Receiving
Facility:
Recycle Inc.;
POTW (Ind.)

Surface
water

250

1.108

27.18

0.01

0.03

9.06

0.00

20

13.85

339.11

0.11

0.43

113.04

0.01

Oiltanking Houston Inc.
Houston. TX
NPDES: TX0091855

Surface
Water

Surrogate

NPDES

TX0065943

Surface
water

250

0.003

6.52

0.00

0.01

2.17

0.00

20

0.041

89.13

0.03

0.11

29.71

0.00

St. Gabriel Terminal,

Saint Gabriel, LA
NPDES: LA0005487

Surface
Water

NPDES
LA0005487

Surface
water

250

0.0055

0.0000223

0.00

0.00

0.00

0.00

20

0.069

0.000279

0.00

0.00

0.00

0.00

Vopak Terminal Westwego
Inc,

Westwego, LA
NPDES: LAO 124583

Surface
Water

Surrogate

NPDES

LA0042064

Surface
water

250

0.00468

0.0000189

0.00

0.00

0.00

0.00

20

0.058

0.000235

0.00

0.00

0.00

0.00

Research Solutions Group
Inc,

Pelham. AL
NPDES: AL0074276

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Carlisle Engineered
Products Inc, Middlefield,
OH

NPDES: OH0052370

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: OTVD (Includes releases for Closed-Loop Degreasing, Conveyorized Degreasing, Web Degreasing, and Metalworking Fluids)

Texas Instruments, Inc.,







260

0.005

0.0188

0.00

0.00

0.01

0.00

Page 532 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility"

Release
Media b

Modeled
Facility or
Industry
Sector in

EFAST c

EFAST
Waterbody
Typell

Days of
Release1

Release

(kg/day)f

7Q10

swe

(ppb) b

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC

of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Attleboro, MA
NPDES: MA0001791

Surface
Water

NPDES
MA0001791

Surface
water

20

0.067

0.25

0.00

0.00

0.08

0.00

Accellent Inc/Collegeville
Microcoax, Collegeville,
PA

NPDES: PA0042617

Surface
Water

NPDES
PA0042617

Surface
water

260

0.002

0.0425

0.00

0.00

0.01

0.00

20

0.029

0.62

0.00

0.00

0.21

0.00

Ametek Inc. U.S. Gauge
Div.,
Sellersville, PA
NPDES: PA0056014

Surface
Water

Surrogate

NPDES

PA0020460

Surface
water

260

0.001

0.0619

0.00

0.00

0.02

0.00

20

0.011

0.68

0.00

0.00

0.23

0.00

Atk-Allegany Ballistics
Lab (Nirop),
Keyser, WV
NPDES: WV0020371

Surface
Water

NPDES
WV0020371

Surface
water

260

0.0005

0.00311

0.00

0.00

0.00

0.00

20

0.0061

0.0373

0.00

0.00

0.01

0.00

Handy & Harman Tube
Co/East Norriton,
Norristown, PA
NPDES: PA0011436

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

US Nasa Michoud
Assembly Facility,
New Orleans, LA
NPDES: LA0052256

Surface
Water

Surrogate

NPDES

LA0003280

Still body

260

1.96

765.63

0.24

0.97

255.21

0.01

20

25.44

9937.5

3.11

12.61

3312.50

0.19

GM Components Holdings
LLC,

Surface
Water

NPDES
NY0000558

Surface
water

260

0.13

10.97

0.00

0.01

3.66

0.00

Page 533 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Lockport, NY
NPDES: NY0000558







20

1.71

144.47

0.05

0.18

48.16

0.00

Akebono Elizabethtown
Plant,
Elizabethtown, KY
NPDES: KY0089672

Surface
Water

Surrogate

NPDES

KY0022039

Surface
water

260

0.07

4.87

0.00

0.01

1.62

0.00

20

0.897

62.38

0.02

0.08

20.79

0.00

Delphi Harrison Thermal
Systems,

Dayton, OH
NPDES: OH0009431

Surface
Water

NPDES
OH0009431

Surface
water

260

0.04

0.0752

0.00

0.00

0.03

0.00

20

0.465

0.87

0.00

0.00

0.29

0.00

Chemours Company Fc
LLC,
Washington, WV
NPDES: WV0001279

Surface
Water

NPDES
WV0001279

Surface
water

260

0.03

0.00301

0.00

0.00

0.00

0.00

20

0.334

0.0335

0.00

0.00

0.01

0.00

Equistar Chemicals Lp,

La Porte, TX
NPDES: TX0119792

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.02

2.22

0.00

0.00

0.74

0.00

20

0.218

24.44

0.01

0.03

8.15

0.00

GE Aviation
Lynn, MA
NPDES: MA0003905

Surface
Water

NPDES
MA0003905

Still water

260

0.01

0.0425

0.00

0.00

0.01

0.00

20

0.128

0.54

0.00

0.00

0.18

0.00

Certa Vandalia LLC,

Vandalia, OH
NPDES: OH0122751

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.01

1.11

0.00

0.00

0.37

0.00

20

0.107

11.89

0.00

0.02

3.96

0.00

Page 534 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

PPb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

GM Components Holdings
LLC Kokomo Ops,

Kokomo, IN
NPDES: IN0001830

Surface
Water

NPDES
IN0001830

Surface
water

260

0.01

0.2

0.00

0.00

0.07

0.00

20

0.086

1.73

0.00

0.00

0.58

0.00

Amphenol Corp-Aerospace
Operations,

Sidney, NY
NPDES: NY0003824

Surface
Water

NPDES
NY0003824

Surface
water

260

0.01

0.0486

0.00

0.00

0.02

0.00

20

0.082

0.4

0.00

0.00

0.13

0.00

Emerson Power Trans
Corp,
Maysville, KY
NPDES: KY0100196

Surface
Water

Surrogate

NPDES

KY0020257

Surface
water

260

0.01

0.0004

0.00

0.00

0.00

0.00

20

0.081

0.00522

0.00

0.00

0.00

0.00

Olean Advanced Products,
Olean NY
NPDES: NY0073547

Surface
Water

Surrogate

NPDES

NY0027162

Surface
water

260

0.01

0.0188

0.00

0.00

0.01

0.00

20

0.068

0.13

0.00

0.00

0.04

0.00

Hollingsworth Saco
Lowell,
Easley, SC
NPDES: SC0046396

Surface
Water

Primary Metal

Fonning

Manuf.

Surface
water

260

0.00469

0.52

0.00

0.00

0.17

0.00

20

0.061

6.78

0.00

0.01

2.26

0.00

Trelleborg YSH
Incorporated Sandusky
Plant,
Sandusky, MI
NPDES: MI0028142

Surface
Water

NPDES
MI0028142

Surface
water

260

0.0036

1.76

0.00

0.00

0.59

0.00

20

0.047

23.04

0.01

0.03

7.68

0.00

Page 535 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Timken Us Corp Honea
Path,

Honea Path, SC
NPDES: SC0047520

Surface
Water

Surrogate

NPDES

SC0000698

Surface
water

260

0.00355

1.06

0.00

0.00

0.35

0.00

20

0.0462

13.77

0.00

0.02

4.59

0.00

Johnson Controls
Incorporated,
Wichita, KS
NPDES: KS0000850

Surface
Water

NPDES
KS0000850

Surface
water

260

0.00228

0.0548

0.00

0.00

0.02

0.00

20

0.0296

0.72

0.00

0.00

0.24

0.00

National Railroad
Passenger Corporation
(Amtrak) Wilmington
Maintenance Facility,

Wilmington DE
NPDES: DE0050962

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.00203

0.23

0.00

0.00

0.08

0.00

20

0.026

2.89

0.00

0.00

0.96

0.00

Electrolux Home Products
(Formerly Frigidaire),

Greenville, MI
NPDES: MI0002135

Surface
Water

NPDES
MI0002135

Surface
water

260

0.00201

0.0171

0.00

0.00

0.01

0.00

20

0.026

0.22

0.00

0.00

0.07

0.00

Rex Heat Treat Lansdale
Inc,

Lansdale, PA
NPDES: PA0052965

Surface
Water

Surrogate

NPDES

PA0026182

Surface
water

260

0.00194

0.0523

0.00

0.00

0.02

0.00

20

0.025

0.67

0.00

0.00

0.22

0.00

Carrier Corporation

Syracuse, NY
NPDES: NY0001163

Surface
Water

NPDES
NY0001163

Still water

260

0.00177

0.22

0.00

0.00

0.07

0.00

20

0.023

2.84

0.00

0.00

0.95

0.00

Page 536 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Cascade Corp
(0812100207),
Springfield, OH
NPDES: OH0085715

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.00117

0.13

0.00

0.00

0.04

0.00

20

0.015

1.67

0.00

0.00

0.56

0.00

USAF-Wurtsmith Afb,

Oscoda, MI
NPDES: MI0042285

Surface
Water

Surrogate

NPDES

MI0028282

Surface
water

260

0.00115

0.000753

0.00

0.00

0.00

0.00

20

0.015

0.00983

0.00

0.00

0.00

0.00

AAR Mobility Systems,
Cadillac, MI
NPDES: MI0002640

Surface
Water

Surrogate

NPDES

MI0020257

Surface
water

260

0.00112

0.00916

0.00

0.00

0.00

0.00

20

0.014

0.11

0.00

0.00

0.04

0.00

Eaton Mdh Company Inc,
Kearney, NE
NPDES: NE0114405

Surface
Water

Surrogate

NPDES

NE0052647

Still water

260

0.00107

0.13

0.00

0.00

0.04

0.00

20

0.014

1.69

0.00

0.00

0.56

0.00

Lake Region Medical,

Trappe, PA
NPDES: PA0042617

Surface
Water

NPDES
PA0042617

Surface
water

260

0.0005

0.0106

0.00

0.00

0.00

0.00

20

0.007

0.15

0.00

0.00

0.05

0.00

Motor Components LLC,
Elmira, NY
NPDES: NY0004081

Surface
Water

NPDES
NY0004081

Surface
water

260

0.00096

0.0618

0.00

0.00

0.02

0.00

20

0.0125

0.83

0.00

0.00

0.28

0.00

Salem Tube Mfg,
Greenville, PA
NPDES: PA0221244

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.000897

0.0997

0.00

0.00

0.03

0.00

20

0.012

1.33

0.00

0.00

0.44

0.00

Page 537 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility"

Release
Media b

Modeled
Facility or
Industry
Sector in

EFAST c

EFAST
Waterbody
Typell

Days of
Release1

Release

(kg/day)f

7Q10

swe

(ppb) b

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC

of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

GE (Greenville) Gas
Turbines LLC,
Greenville, SC
NPDES: SC0003484

Surface
Water

NPDES
SC0003484

Surface
water

260

0.000806

0.0821

0.00

0.00

0.03

0.00

20

0.01

1.02

0.00

0.00

0.34

0.00

Parker Hannifin
Corporation,
Waverly, OH
NPDES: OH0104132

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.000747

0.083

0.00

0.00

0.03

0.00

20

0.01

1.11

0.00

0.00

0.37

0.00

Mahle Engine Components
Usa Inc,
Muskegon, MI
NPDES: MI0004057

Surface
Water

NPDES
MI0004057

Surface
water

260

0.000742

0.0336

0.00

0.00

0.01

0.00

20

0.01

0.45

0.00

0.00

0.15

0.00

General Electric Company
- Waynesboro,
Waynesboro, VA
NPDES: VA0002402

Surface
Water

NPDES
VA0002402

Surface
water

260

0.000733

0.00705

0.00

0.00

0.00

0.00

20

0.01

0.0962

0.00

0.00

0.03

0.00

Globe Engineering Co Inc,
Wichita, KS
NPDES: KS0086703

Surface
Water

Surrogate

NPDES

KS0043036

Surface
water

260

0.00173

0.00853

0.00

0.00

0.00

0.00

20

0.023

0.11

0.00

0.00

0.04

0.00

Gayston Corp,
Dayton, OH
NPDES: OHO 127043

Surface
Water

Surrogate

NPDES

OH0024881

Surface
water

260

0.000643

0.00121

0.00

0.00

0.00

0.00

20

0.008

0.015

0.00

0.00

0.01

0.00

Styrolution America LLC,
Channahon, IL
NPDES: IL0001619

Surface
Water

NPDES
IL0001619

Surface
water

260

0.000637

0.000221

0.00

0.00

0.00

0.00

20

0.008

0.00278

0.00

0.00

0.00

0.00

Page 538 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

PPb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)























Remington Anns Co Inc.
Ilion NY
NPDES: NY0005282

Surface
Water

NPDES
NY0005282

Surface
water

260

0.000612

0.000799

0.00

0.00

0.00

0.00

20

0.008

0.0104

0.00

0.00

0.00

0.00

United Teclinologies
Corporation Pratt And
Whitney Division
East Hartford, CT
NPDES: CT0001376

Surface
Water

NPDES
CT0001376

Surface
water

260

0.00048

0.0000822

0.00

0.00

0.00

0.00

20

0.006

0.00103

0.00

0.00

0.00

0.00

Atk-Allegany Ballistics
Lab (Nirop),
Keyser, WV
NPDES: WV0020371

Surface
Water

NPDES
WV0020371

Surface
water

260

0.00047

0.00292

0.00

0.00

0.00

0.00

20

0.006

0.0373

0.00

0.00

0.01

0.00

Sperry & Rice
Manufacturing Co LLC,
Brookville, IN
NPDES: IN0001473

Surface
Water

NPDES
IN0001473

Surface
water

260

0.000328

0.00569

0.00

0.00

0.00

0.00

20

0.004

0.0694

0.00

0.00

0.02

0.00

Owt Industries,
Pickens, SC
NPDES: SC0026492

Surface
Water

NPDES
SC0026492

Surface
water

260

0.000314

0.00213

0.00

0.00

0.00

0.00

20

0.004

0.0272

0.00

0.00

0.01

0.00

Boler Company,
Hillsdale, MI
NPDES: MI0053651

Surface
Water

Surrogate

NPDES

MI0022136

Surface
water

260

0.000269

0.0204

0.00

0.00

0.01

0.00

20

0.003

0.23

0.00

0.00

0.08

0.00

Page 539 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb) s

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Mccanna Inc.,
Carpentersville, IL
NPDES: IL0071340

Surface
Water

Surrogate

NPDES

IL0027944

Surface
water

260

0.000268

0.000911

0.00

0.00

0.00

0.00

20

0.003

0.0102

0.00

0.00

0.00

0.00

Cutler Hammer,
Horseheads, NY
NPDES: NY0246174

Surface
Water

Surrogate

NPDES

NY0004081

Surface
water

260

0.000238

0.0153

0.00

0.00

0.01

0.00

20

0.003

0.19

0.00

0.00

0.06

0.00

US Air Force Offutt Afb

Ne,

Offutt A F B, NE
NPDES: NE0121789

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.000159

0.0177

0.00

0.00

0.01

0.00

20

0.002

0.22

0.00

0.00

0.07

0.00

Troxel Company,
Moscow, TN
NPDES: TN0000451

Surface
Water

NPDES
TN0000451

Surface
water

260

0.000134

0.000741

0.00

0.00

0.00

0.00

20

0.002

0.0111

0.00

0.00

0.00

0.00

Austin Tube Prod,
Baldwin MI
NPDES: MI0054224

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.000114

0.0127

0.00

0.00

0.00

0.00

20

0.001

0.11

0.00

0.00

0.04

0.00

LS Starrett Precision
Tools,

Athol, MA
NPDES: MA0001350

Surface
Water

NPDES
MA0001350

Surface
water

260

0.000102

0.00153

0.00

0.00

0.00

0.00

20

0.001

0.015

0.00

0.00

0.01

0.00

Avx Corp,
Raleigh, NC
NPDES: NC0089494

Surface
Water

Primary Metal

Forming

Manuf.

Surface
water

260

0.0000883

0.00981

0.00

0.00

0.00

0.00

20

0.001

0.11

0.00

0.00

0.04

0.00

Page 540 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Indian Head Division
Naval Surface Warfare
Center,

Indian Head, MD
NPDES: MD0003158

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

General Dynamics
Ordnance Tactical
Systems,
Red Lion, PA
NPDES: PA0043672

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Trane Residential
Solutions - Fort Smith.

Fort Smith. AR
NPDES: AR0052477

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Lexmark International Inc.,
Lexington KY
NPDES: KY0097624

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Alliant Techsystems
Operations LLC,
Elkton MD
NPDES: MD0000078

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Daikin Applied America,
Inc. (Formally Mcquay
International),
Scottsboro, AL
NPDES: AL0069701

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Page 541 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)







Beechcraft Corporation.
Wichita, KS
NPDES: KS0000183

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Federal-Mogul Corp,

Scottsville, KY
NPDES: KY0106585

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Cessna Aircraft Co
(Pawnee Facility),
Wichita, KS
NPDES: KS0000647

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

N.G.I,
Parkersburg, WV
NPDES: WV0003204

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Hyster-Yale Group, Inc,
Sulligent, AL
NPDES: AL0069787

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Hitaclii Electronic Devices
(Usa), Inc.,
Greenville, SC
NPDES: SC0048411

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: Adhesives, Sealants, Paints, and Coatings

Page 542 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Able Electropolishing Co
Inc.

Chicago, IL
NPDES: Not available

POTW

Adhesives and

Sealants

Manuf.

Surface
water

250

0.298

7.28

0.00

0.01

2.43

0.00

Garlock Sealing
Technologies, Palmyra,
NY, NPDES: NY0000078

Surface
Water

NPDES
NY0000078

Surface
water

250

0.00033

0.00716

0.00

0.00

0.00

0.00

20

0.00407

0.0889

0.00

0.00

0.03

0.00

Ls Starrett Co,
Athol, MA
NPDES: MAR05B615

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Aerojet Rocketdyne, Inc.,
East Camden AR
NPDES: AR0051071,
ARR00A521, ARR00A520

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Best One Tire & Service,
Nashville, TN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Bridgestone Aircraft Tire
(Usa), Inc.,
Mayodan NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Clayton Homes Inc,
Oxford, NC

Surface
Water



Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

Page 543 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility"

Release
Media b

Modeled
Facility or
Industry
Sector in

EFAST c

EFAST
Waterbody
Typell

Days of
Release1

Release

(kg/day)f

7Q10

swe

(ppb) b

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC

of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

NPDES: Not available

POTW

Adhesives and

Sealants

Manuf.



250

0.013

0.32

0.00

0.00

0.11

0.00

Cmh Manufacturing, Inc.
Dba Schult Homes - Plant
958,

Richfield, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Delphi Thermal Systems,
Lockport, NY
NPDES: NY0000558

Surface
Water

NPDES
NY0000558

Surface
water

250

0.013

1.1

0.00

0.00

0.37

0.00

20

0.16

13.5

0.00

0.02

4.50

0.00

POTW

No info on

receiving

facility;

Adhesives and

Sealants

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Green Bay Packaging Inc -
Coon Rapids,

Coon Rapids, MN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Mastercraft Boat
Company,
Vonore, TN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Michelin Aircraft Tire
Company,
Norwood, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 544 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)























M-Tek, Inc.
Manchester, TN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Olin Corp,

East Alton. IL
NPDES: IL0000230

Surface
Water

NPDES
IL0000230

Surface
water

250

0.013

0.18

0.00

0.00

0.06

0.00

20

0.16

2.26

0.00

0.00

0.75

0.00

POTW

No info on

receiving

facility;

Adhesives and

Sealants

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Parker Hannifin Corp -
Paraflex Division
Manitowoc, WI
NPDES: Not available

Surface
Water

Adhesives and
Sealants

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Parrish Tire Company,

Yadkinville, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Republic Doors And
Frames,
Mckenzie, TN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Ro-Lab Rubber Company
Inc.,

Surface
Water



Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

Page 545 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Tracy, CA
NPDES: Not available

POTW

Adhesives and

Sealants

Manuf.



250

0.013

0.32

0.00

0.00

0.11

0.00

Royale Comfort Seating,
Inc. - Plant No. 1,
Taylorsville, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW



250

0.013

0.32

0.00

0.00

0.11

0.00

Snider Tire, Inc.,
Statesville, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Snyder Paper Corporation,
Hickory, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Stellana Us,

Lake Geneva, WI
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Thomas Built Buses -
Courtesy Road,
High Point, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Unicel Corp,
Escondido, CA
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Acme Finishing Co Lie,
Elk Grove Village, IL

Surface
Water



Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

Page 546 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

NPDES: Not available

POTW

Adhesives and

Sealants

Manuf.



250

0.013

0.32

0.00

0.00

0.11

0.00

Aerojet Rocketdyne, Inc.,
Rancho Cordova, CA
NPDES: CA0004111

Surface
Water

NPDES
CA0004111

Surface
water

250

0.013

0.000818

0.00

0.00

0.00

0.00

20

0.16

0.0101

0.00

0.00

0.00

0.00

POTW

No info on

receiving

facility;

Adhesives and

Sealants

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Allegheny Cnty Airport
Auth/

Pgh Intl Airport,

Coroapolis
Pittsburgh, PA
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Amphenol Corp -
Aerospace Operations,

Sidney, NY
NPDES: NY0003824

Surface
Water

NPDES
NY0003824

Surface
water

250

0.013

0.0631

0.00

0.00

0.02

0.00

20

0.16

0.78

0.00

0.00

0.26

0.00

POTW

No info on

receiving

facility;

Adhesives and

Sealants

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Aprotech Powertrain

Asheville, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 547 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Coating & Converting
Tech Corp/
Adhesive Coatings,
Philadelphia, PA
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Corpus Christi Army

Depot,

Corpus Christi, TX
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Electronic Data Systems
Camp Pendleton Camp

Pendleton CA
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Florida Production
Engineering, Inc.,
Onnond Beach, FL
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Goodrich Corporation

Jacksonville, FL
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Kasai North America Inc,
Madison Plant, Madison
MS

NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Kirtland Air Force Base,







250

0.013

1.67

0.00

0.00

0.56

0.00

Page 548 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb) s

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Albuquerque, NM
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Marvin Windows & Doors,
Warroad, MN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Mcneilus Truck &
Manufacturing Inc,
Dodge Center, MN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Metal Finishing Co. -
Wichita (S Mclean Blvd),
Wichita, KS
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Murakami Manufacturing
Usa Inc, Campbellsville,
KY

NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Peterbilt Motors Denton
Facility,

Denton, TX
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Portsmouth Naval
Shipyard,
Kittery, ME
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 549 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility"

Release
Media b

Modeled
Facility or
Industry
Sector in

EFAST c

EFAST
Waterbody
Typell

Days of
Release1

Release

(kg/day)f

7Q10

swe

(ppb) b

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC

of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)























R.D. Henry & Co.,
Wichita, KS
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Raytheon Company,

Portsmouth, RI
NPDES: RI0000281

Surface
Water

NPDES
RI0000281

Still body

250

0.013

10.83

0.00

0.01

3.61

0.00

20

0.16

133.33

0.04

0.17

44.44

0.00

POTW

No info on

receiving

facility;

Adhesives and

Sealants

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Rehau Inc,
Cullman, AL
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Rotochopper Inc,
Saint Martin, MN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Rubber Applications,

Mulberry, FL
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Sapa Precision Tubing
Rockledge, Lie,
Rockledge, FL
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 550 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Thomas & Betts,
Albuquerque, NM
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Thomas Built Buses -
Fairfield Road,
High Point, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Timco,
Dba Haeco Americas
Airframe Services,
Greensboro, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Trelleborg Coated Systems

Us, Inc -
Grace Advanced Materials,
Rutherfordton, NC
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

U.S. Coast Guard Yard -
Curtis Bay,

Curtis Bay, MD
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Viracon Inc,
Owatonna, MN
NPDES: Not available

Surface
Water

Adhesives and

Sealants

Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

OES: Other Industrial Uses

Page 551 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Eli Lilly And Company-
Lilly Tech Ctr,
Indianapolis, IN
NPDES: IN0003310

Surface
Water

NPDES
IN0003310

Surface
water

250

1.553

9.03

0.00

0.01

3.01

0.00

20

19.41

113.09

0.04

0.14

37.70

0.00

Oxy Vinyls LP - Deer Park
Pvc,

Deer Park, TX
NPDES: TX0007412

Surface
Water

NPDES
TX0007412

Surface
water

250

0.148

0.49

0.00

0.00

0.16

0.00

20

1.854

5.98

0.00

0.01

1.99

0.00

Washington Penn Plastics,
Frankfort, KY
NPDES: KY0097497

Surface
Water

Surrogate

NPDES

KY0028410

Surface
water

250

0.032

7.53

0.00

0.01

2.51

0.00

20

0.399

94.12

0.03

0.12

31.37

0.00

Solvay - Houston Plant,

Houston TX
NPDES: TX0007072

Surface
Water

NPDES
TX0007072

Surface
water

350

0.024

4.44

0.00

0.01

1.48

0.00

20

0.414

75.93

0.02

0.10

25.31

0.00

Natrium Plant,
New Martinsville, WV
NPDES: WV0004359

Surface
Water

NPDES
WV0004359

Surface
water

250

0.022

0.00262

0.00

0.00

0.00

0.00

20

0.274

0.0322

0.00

0.00

0.01

0.00

Leroy Quarry,
Leroy, NY
NPDES: NY0247189

Surface
Water

Surrogate

NPDES

NY0030546

Surface
water

250

0.019

0.71

0.00

0.00

0.24

0.00

20

0.242

8.91

0.00

0.01

2.97

0.00

George C Marshall Space
Flight Center,
Huntsville, AL
NPDES: AL0000221

Surface
Water

Surrogate

NPDES

AL0025585

Surface
water

250

0.01

0.2

0.00

0.00

0.07

0.00

20

0.128

2.63

0.00

0.00

0.88

0.00

Page 552 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb) s

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Whelan Energy Center
Power Plant,
Hastings, NE
NPDES:NE0113506

Surface
Water

NPDES
NE0113506

Surface
water

250

0.009

2.92

0.00

0.00

0.97

0.00

20

0.118

38.96

0.01

0.05

12.99

0.00

Akzo Nobel Surface
Chemistry LLC,
Morris, IL
NPDES: IL0026069

Surface
Water

NPDES
IL0026069

Surface
water

350

0.000329

0.000688

0.00

0.00

0.00

0.00

20

0.006

0.0125

0.00

0.00

0.00

0.00

Solutia Nitro Site,
Nitro, WV
NPDES: WV0116181

Surface
Water

Surrogate

NPDES

WV0023229

Surface
water

350

0.000318

0.0000941

0.00

0.00

0.00

0.00

20

0.006

0.00176

0.00

0.00

0.00

0.00

Amphenol Corporation -
Columbia,
Columbia, SC
NPDES: SC0046264

Surface
Water

Organic

Chemicals

Manufacture

Surface
water

350

0.000202

0.037

0.00

0.00

0.01

0.00

20

0.004

0.74

0.00

0.00

0.25

0.00

Army Cold Regions
Research & Engineering
Lab,

Hanover, NH
NPDES: NH0001619

Surface
Water

Surrogate
NPDES
NHO100099

Surface
water

250

0.0002

0.000103

0.00

0.00

0.00

0.00

20

0.0029

0.00154

0.00

0.00

0.00

0.00

Corning - Canton Plant,

Canton, NY
NPDES: NY0085006

Surface
Water

Surrogate

NPDES

NY0034762

Surface
water

250

0.0002

0.00034

0.00

0.00

0.00

0.00

20

0.0028

0.0051

0.00

0.00

0.00

0.00

Page 553 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Keeshan and Bost
Chemical Co., Inc.,

Manvel, TX
NPDES: TX0072168

Surface
Water

NPDES
TX0072168

Still body

350

0.000095

9.5

0.00

0.01

3.17

0.00

20

0.002

200

0.06

0.25

66.67

0.00

Ames Rubber Corp Plant

#1,

Hamburg Boro, NJ
NPDES: NJG000141

Surface
Water

Surrogate

NPDES

NJ0000141

Surface
water

250

0.00011

0.0149

0.00

0.00

0.00

0.00

20

0.00133

0.18

0.00

0.00

0.06

0.00

Gorham,
Providence, RI
NPDES: RIG85E004

Surface
Water

POTW (Ind.)

Surface
water

250

0.0001

0.0129

0.00

0.00

0.00

0.00

20

0.0012

0.13

0.00

0.00

0.04

0.00

Chemtura North and South
Plants,
Morgantown WV
NPDES: WV0004740

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Indorama Ventures
Olefins, LLC,
Sulphur, LA
NPDES: LA0069850

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Emerson Power
Transmission,
Ithaca, NY
NPDES: NY0002933

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

William E. Warne Power
Plant,

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Page 554 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Los Angeles County, CA
NPDES: CA0059188





Raytheon Aircraft Co(Was
Beech Aircraft), Boulder,
CO

NPDES: COG315176

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: Spot Cleaning and Carpet Cleaning

Boise State University,

Boise, ID
NPDES: IDG911006

Surface
Water

Surrogate

NPDES

ID0023981

Surface
water

300

0.00008

0.00388

0.00

0.00

0.00

0.00

20

0.001

0.0485

0.00

0.00

0.02

0.00

Venetian Hotel And
Casino,
Las Vegas, NV
NPDES: NV0022888

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

63,746 unknown sites
NPDES: All POTW SIC

Surface
Water or
POTW

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: Industrial Processing Aid

Occidental Chemical Corp
Niagara Plant,
Niagara Falls, NY
NPDES: NY0003336

Surface
Water

NPDES

NY0003336

Still body

300

0.019

0.14

0.00

0.00

0.05

0.00

20

0.292

2.2

0.00

0.00

0.73

0.00

Stepan Co Millsdale Road,
Elwood, IL

Surface
Water

NPDES
IL0002453

Surface
water

300

0.001

0.000419

0.00

0.00

0.00

0.00

Page 555 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb) s

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

NPDES: IL0002453







20

0.008

0.00335

0.00

0.00

0.00

0.00

Entek International LLC,
Lebanon, OR
NPDES: N/A

Off-site
Waste-
water
Treatment

No info on
receiving
facility; POTW
(Ind.)'

Surface
water

300

0.38

9.3

0.00

0.01

3.10

0.00

20

5.65

138.34

0.04

0.18

46.11

0.00

National Electrical Carbon
Products
Dba Morgan Adv
Materials,
Fostoria, OH
NPDES: OH0052744

Off-site
Waste-
water
Treatment

Receiving
Facility: City
of Fostoria;
NPDES
OH0052744

Surface
water

300

0.008

0.15

0.00

0.00

0.05

0.00

20

0.115

2.32

0.00

0.00

0.77

0.00

PPG Industries Inc
Barberton,
Barberton, OH
NPDES: OH0024007

Off-site
Waste-
water
Treatment

Receiving
Facility: City
of Barberton;
NPDES
OH0024007

Surface
water

300

0.005

0.0141

0.00

0.00

0.00

0.00

20

0.07

0.2

0.00

0.00

0.07

0.00

Darainic LLC,
Corydon, IN
NPDES: IN0020893

Surface
Water

NPDES
IN0020893

Surface
water

300

0.008

0.0206

0.00

0.00

0.01

0.00

20

0.114

0.29

0.00

0.00

0.10

0.00

OES: Commercial Printing and Copying

Printing And Pub Sys Div,
Weatherford, OK
NPDES: OK0041785

Surface
Water

Printing

Surface
water

250

0.0002

0.00292

0.00

0.00

0.00

0.00

20

0.0025

0.0365

0.00

0.00

0.01

0.00

OES: Other Commercial Uses

Corning Hospital,







250

0.013

0.0271

0.00

0.00

0.01

0.00

Page 556 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

Corning, NY
NPDES: NY0246701

Surface
Water

Surrogate

NPDES

NY0025721

Surface
water

20

0.159

0.33

0.00

0.00

0.11

0.00

Water Street Commercial
Bldg,

Dayton, OH
NPDES: OHO 141496

Surface
Water

Surrogate

NPDES

OH0009521

Surface
water

250

0.003

0.00564

0.00

0.00

0.00

0.00

20

0.035

0.0658

0.00

0.00

0.02

0.00

Union Station North Wing
Office Building, Denver,
CO

NPDES: COG315293

Surface
Water

Surrogate

NPDES

C00020095

Surface
water

250

0.0004

0.0881

0.00

0.00

0.03

0.00

20

0.00499

1.1

0.00

0.00

0.37

0.00

Confluence Park
Apartments,
Denver, CO
NPDES: COG315339

Surface
Water

Surrogate

NPDES

C00020095

Surface
water

250

0.00028

0.0617

0.00

0.00

0.02

0.00

20

0.00354

0.77

0.00

0.00

0.26

0.00

Park Place Mixed Use
Development,
Annapolis, MD
NPDES: MD0068861

Surface
Water

Surrogate

NPDES

MD0052868

Still body

250

0.00027

9

0.00

0.01

3.00

0.00

20

0.00334

110

0.03

0.14

36.67

0.00

Tree Top Inc Wenatchee
Plant,
Wenatchee, WA
NPDES: WA0051527

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Wynkoop Denver LLCP
St,

Denver, CO
NPDES: COG603115

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

Page 557 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)







Greer Family Lie,
South Burlington. VT
NPDES: VT0001376

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

John Marshall III Site,

Mclean, VA
NPDES: VA0090093

Surface
Water

Annual releases estimated to be <0.02 kg/year were not modeled, as they were determined to be unlikely to exceed the most
sensitive COC using the most conservative input assumptions.

OES: Process Solvent Recycling and Worker Handling of Wastes

Clean Water Of New York
Inc,

Staten Island, NY
NPDES: NY0200484

Surface
Water

Surrogate

NPDES

NJ0000019

Still body

250

0.004

11.76

0.00

0.01

3.92

0.00

20

0.047

138.24

0.04

0.18

46.08

0.00

Reserve Environmental
Services,
Ashtabula, OH
NPDES: OH0098540

Surface
Water











0.00

0.00

0.00

0.00

Veolia Es Technical
Solutions LLC,
Middlesex, NJ
NPDES: NJ0020141

Off-site
Waste-
water
Treatment

Receiving

Facility:

Middlesex

Cnty UA;

NPDES

NJ0020141

Still body

250

24.1

2.85

0.00

0.00

0.95

0.00

20

301.78

35.72

0.01

0.05

11.91

0.00

Clean Harbors Deer Park
LLC,

Off-site
Waste-

POTW (Ind.)

Surface
water

250

0.35

8.57

0.00

0.01

2.86

0.00

Page 558 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

La Porte, TX
NPDES: TX0005941

water
Treatment





20

4.36

106.75

0.03

0.14

35.58

0.00

Clean Harbors El Dorado
LLC,
El Dorado, AR
NPDES: AR0037800

Off-site
Waste-
water
Treatment

POTW (Ind.)

Surface
water

250

0.04

0.98

0.00

0.00

0.33

0.00

20

0.455

11.26

0.00

0.01

3.75

0.00

OES: Wastewater Treatment Plant (WWTP)

New Rochelle STP,
New Rochelle, NY
NPDES: NY0026697

Surface
Water

NPDES
NY0026697

Still body

365

0.043

0.7

0.00

0.00

0.23

0.00

20

0.786

12.79

0.00

0.02

4.26

0.00

Everett Water Pollution
Control Facility,
Everett, WA
NPDES: WA0024490

Surface
Water

NPDES
WA0024490

Surface
water

365

0.016

0.17

0.00

0.00

0.06

0.00

20

0.299

3.11

0.00

0.00

1.04

0.00

Sullivan WWTP,
Sullivan MO
NPDES: MOO 104736

Surface
Water

NPDES
MOO 104736

Surface
water

365

0.01

0.61

0.00

0.00

0.20

0.00

20

0.176

10.97

0.00

0.01

3.66

0.00

Sunnyside STP,
Sunnyside, WA
NPDES: WA0020991

Surface
Water

NPDES
WA0020991

Surface
water

365

0.005

0.00673

0.00

0.00

0.00

0.00

20

0.083

0.11

0.00

0.00

0.04

0.00

Port Of Sunnyside
Industrial WWTF,
Sunnyside, WA
NPDES: WA0052426

Surface
Water

POTW (Ind.)

Surface
water

365

0.002

0.26

0.00

0.00

0.09

0.00

20

0.035

4.51

0.00

0.01

1.50

0.00

Page 559 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location, and ID
of Active Releaser
Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute

RQs

(using

COC of

3,200

ppb)

Chronic
RQs (using
fish COC
of 788
ppb)

Algae RQs
(using COC of
3 ppb)

Algae RQs
(using COC of
52,000 ppb)

U.S. Air Force Shaw AFB
SC.

Shaw AFB, SC
NPDES: SC0024970

Surface
Water

POTW (Ind.)

Surface
water

365

0.002

0.26

0.00

0.00

0.09

0.00

20

0.032

4.12

0.00

0.01

1.37

0.00

Gnf-A Wilmington-Castle
Hayne WWTP,
Wilmington NC
NPDES: NC0001228

Surface
Water

NPDES
NC0001228

Surface
water

365

0.0004

0.00194

0.00

0.00

0.00

0.00

20

0.0067

0.034

0.00

0.00

0.01

0.00

Cameron Trading Post
WWTP,
Cameron, AZ
NPDES: NN0021610

Surface
Water

POTW (Ind.)

Surface
water

365

0.0003

0.0387

0.00

0.00

0.01

0.00

20

0.0047

0.64

0.00

0.00

0.21

0.00

Coal Grove WWTP,

Coal Grove, OH
NPDES: OH0104558

Surface
Water

NPDES
OH0029432

Surface
water

365

0.0002

0.0000127

0.00

0.00

0.00

0.00

20

0.0031

0.00019

0.00

0.00

0.00

0.00

335

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFAST c

EFAST
Waterbody
Type d '

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb) s

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

OES: Adhesives, Sealants, Paints, and Coatings

Able

Electropolishing Co
Inc,
Chicago, IL
NPDES: Not
available

POTW

Adhesives
and Sealants
Manuf.

Surface
water

250

0.298

7.28

0.00

0.01

2.43

0.00

Page 560 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)









250

0.00033

0.00716

0.00

0.00

0.00

0.00

Garlock Sealing
Technologies,

Surface

NPDES

Surface















Palmyra, NY,
NPDES: NY0000078

Water

NY0000078

water























20

0.00407

0.0889

0.00

0.00

0.03

0.00

Ls Starrett Co,
Athol, MA
NPDES:
MAR05B615

Surface
Water

Not assessed (below the min risk level).

Aerojet Rocketdyne,

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Inc.,

Water





20

0.16

20.57

0.01

0.03

6.86

0.00

East Camden AR
NPDES:
AR0051071,
ARR00A521,
ARR00A520



Adhesives
and Sealants

Surface
water















POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Best One Tire &

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Service,

Water

Adhesives

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

Nashville, TN
NPDES: Not
available

POTW

and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Bridgestone Aircraft

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Tire (Usa), Inc.,

Water

Adhesives

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

Mayodan, NC
NPDES: Not
available

POTW

and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Clayton Homes Inc,
Oxford, NC

Surface

Adhesives

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

Water

and Sealants

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 561 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

NPDES: Not
available





















Cmh Manufacturing,

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Inc.

Water





20

0.16

20.57

0.01

0.03

6.86

0.00

Dba Schult Homes -
Plant 958,
Richfield, NC
NPDES: Not

POTW

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

available























Surface

NPDES



250

0.013

1.1

0.00

0.00

0.37

0.00

Delphi Thermal

Systems,
Lockport, NY
NPDES: NY0000558

Water

NY0000558



20

0.16

13.5

0.00

0.02

4.50

0.00

POTW

No info on
receiving
facility;
Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

Green Bay Packaging

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Inc - Coon Rapids,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Coon Rapids, MN
NPDES: Not
available

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

Mastercraft Boat

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Company,

Water

Adhesives

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

Vonore, TN
NPDES: Not
available

POTW

and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Michelin Aircraft

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Tire Company,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Norwood, NC
NPDES: Not
available

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

M-Tek, Inc,

Surface



Surface

250

0.013

1.67

0.00

0.00

0.56

0.00

Manchester, TN

Water



water

20

0.16

20.57

0.01

0.03

6.86

0.00

Page 562 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Seelor in
I I AS 1 '

F.I-AST
W;i(erl>od\
Tj pe

DjIJS ol
Release'

Release
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Acute HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Algae UQs
(using COC"
of 3 |)|)l>)

Algae UQs
(using COC
ol'52.000
pph)

NPDES: Not
available

POTW

Adhesives
and Sealants
Manuf.



250

0.013

0.32

0.00

0.00

0.11

0.00

Olin Corp,

East Alton, IL
NPDES: IL0000230

Surface
Water

NPDES
IL0000230

Surface
water

250

0.013

0.18

0.00

0.00

0.06

0.00

20

0.16

2.26

0.00

0.00

0.75

0.00

POTW

No info on
receiving
facility;
Adhesives
and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Parker Hannifin Corp

Paraflex Division,
Manitowoc, WI
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Parrish Tire
Company,
Yadkinville, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Republic Doors And
Frames,
Mckenzie, TN
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Ro-Lab Rubber
Company Inc.,
Tracy, CA
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Royale Comfort
Seating, Inc. - Plant
No. 1,

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 563 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Taylorsville, NC
NPDES: Not
available





















Snider Tire, Inc.,
Statesville, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Snyder Paper
Corporation,
Hickory, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Stellana Us,
Lake Geneva, WI
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Thomas Built Buses -
Courtesy Road,
High Point, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Unicel Corp,
Escondido, CA
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Acme Finishing Co
Lie,

Elk Grove Village, IL
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 564 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Aerojet Rocketdyne,
Inc.,

Rancho Cordova, CA
NPDES: CA0004111

Surface
Water

NPDES
CA0004111

Surface
water

250

0.013

0.00081
8

0.00

0.00

0.00

0.00

20

0.16

0.0101

0.00

0.00

0.00

0.00

POTW

No info on
receiving
facility;
Adhesives
and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Allegheny Cnty
Airport Autli/
Pgh Intl Airport,

Coroapolis
Pittsburgh, PA
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Amphenol Corp -
Aerospace
Operations,
Sidney, NY
NPDES: NY0003824

Surface
Water

NPDES
NY0003824

Surface
water

250

0.013

0.0631

0.00

0.00

0.02

0.00

20

0.16

0.78

0.00

0.00

0.26

0.00

POTW

No info on
receiving
facility;
Adhesives
and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Aprotech Powertrain
Asheville, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Coating &
Converting Tech
Corp/
Adhesive Coatings,
Philadelphia, PA
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00









250

0.013

1.67

0.00

0.00

0.56

0.00

Page 565 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Seelor in
I I AS 1 '

F.I-AST
W;i(erl>od\
Tj pe

DjIJS ol
Release'

Release
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Acute HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Algae UQs
(using COC"
of 3 |)|)l>)

Algae UQs
(using ('()(
ol'52.000
pph)

Corpus CMsti Army
Depot,

Surface
Water

Adhesives

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

Corpus CMsti, TX
NPDES: Not

POTW

and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

available





















Electronic Data

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Systems

Water





20

0.16

20.57

0.01

0.03

6.86

0.00

Camp Pendleton,
Camp Pendleton, CA



Adhesives
and Sealants

Surface
water















NPDES: Not

POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

available





















Florida Production

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Engineering, Inc.,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Ormond Beach, FL
NPDES: Not
available

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

Goodrich

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Corporation,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Jacksonville, FL



Surface















NPDES: Not
available

POTW

water

250

0.013

0.32

0.00

0.00

0.11

0.00

Kasai North America

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Inc,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Madison Plant,



Surface















Madison, MS
NPDES: Not

POTW

water

250

0.013

0.32

0.00

0.00

0.11

0.00

available





















Kirtland Air Force

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Base,

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Albuquerque, NM
NPDES: Not
available

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00









250

0.013

1.67

0.00

0.00

0.56

0.00

Page 566 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Marvin Windows &
Doors,

Surface
Water

Adhesives
and Sealants



20

0.16

20.57

0.01

0.03

6.86

0.00

Warroad, MN
NPDES: Not
available



Surface
water















POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Mcneilus Truck &

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Manufacturing Inc.

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Dodge Center, MN
NPDES: Not
available

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

Metal Finishing Co. -

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Wichita (S Mclean

Water

Adhesives
and Sealants
Manuf.



20

0.16

20.57

0.01

0.03

6.86

0.00

Blvd),
Wichita, KS
NPDES: Not

POTW

Surface
water

250

0.013

0.32

0.00

0.00

0.11

0.00

available





















Murakami

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Manufacturing Usa

Water

Adhesives
and Sealants



20

0.16

20.57

0.01

0.03

6.86

0.00

Inc, Campbellsville,
KY
NPDES: Not



Surface
water















POTW

Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

available





















Peterbilt Motors

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Denton Facility,

Water





20

0.16

20.57

0.01

0.03

6.86

0.00

Denton, TX



Adhesives
and Sealants
Manuf.

















NPDES: Not



Surface















available

POTW

water

250

0.013

0.32

0.00

0.00

0.11

0.00

Portsmouth Naval

Surface





250

0.013

1.67

0.00

0.00

0.56

0.00

Shipyard,

Water

Adhesives

Surface
water

20

0.16

20.57

0.01

0.03

6.86

0.00

Kittery, ME
NPDES: Not
available

POTW

and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 567 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)























R.D. Henry & Co.,
Wichita, KS
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Raytheon Company,

Portsmouth, RI
NPDES: RI0000281

Surface
Water

NPDES
RI0000281

Still body

250

0.013

10.83

0.00

0.01

3.61

0.00

20

0.16

133.33

0.04

0.17

44.44

0.00

POTW

No info on
receiving
facility;
Adhesives
and Sealants
Manuf.

250

0.013

0.32

0.00

0.00

0.11

0.00

Rehau Inc,
Cullman, AL
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Rotochopper Inc,
Saint Martin, MN
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Rubber Applications,
Mulberry, FL
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Sapa Precision
Tubing Rockledge,
Lie,
Rockledge, FL

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Page 568 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

NPDES: Not
available





















Thomas & Betts,
Albuquerque, NM
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Thomas Built Buses -
Fairfield Road,
High Point, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Timco,
Dba Haeco Americas
Airframe Services,
Greensboro, NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Trelleborg Coated
Systems Us, Inc -
Grace Advanced

Materials,
Rutherfordton NC
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

U.S. Coast Guard
Yard - Curtis Bay,
Curtis Bay, MD
NPDES: Not
available

Surface
Water

Adhesives
and Sealants
Manuf.

Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

POTW

250

0.013

0.32

0.00

0.00

0.11

0.00

Viracon Inc,
Owatonna, MN

Surface
Water



Surface
water

250

0.013

1.67

0.00

0.00

0.56

0.00

20

0.16

20.57

0.01

0.03

6.86

0.00

Page 569 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

NPDES: Not
available

POTW

Adhesives
and Sealants
Manuf.



250

0.013

0.32

0.00

0.00

0.11

0.00

OES: Commercial Printing and Copying

Printing And Pub Sys
Div,

Weatherford, OK
NPDES: OK0041785

Surface
Water

Printing

Surface
water

250

0.0002

0.00292

0.00

0.00

0.00

0.00

20

0.0025

0.0365

0.00

0.00

0.01

0.00

OES: Industrial Processing Aid

Occidental Chemical
Corp Niagara Plant,
Niagara Falls, NY
NPDES: NY0003336

Surface
Water

NPDES

NY0003336

Still body

300

0.019

0.14

0.00

0.00

0.05

0.00

20

0.292

2.2

0.00

0.00

0.73

0.00

Stepan Co Millsdale
Road,
Elwood, IL
NPDES: IL0002453

Surface
Water

NPDES
IL0002453

Surface
water

300

0.001

0.00041
9

0.00

0.00

0.00

0.00

20

0.008

0.00335

0.00

0.00

0.00

0.00

Entek International
LLC,
Lebanon, OR
NPDES: N/A

Off-site
Waste-
water
Treatment

No info on
receiving
facility;
POTW (Ind.)

Surface
water

300

0.38

9.3

0.00

0.01

3.10

0.00

20

5.65

138.34

0.04

0.18

46.11

0.00

National Electrical
Carbon Products
Dba Morgan Adv
Materials,
Fostoria, OH
NPDES: OH0052744

Off-site
Waste-
water
Treatment

Receiving
Facility: City
of Fostoria;

NPDES
OH0052744

Surface
water

300

0.008

0.15

0.00

0.00

0.05

0.00

20

0.115

2.32

0.00

0.00

0.77

0.00

PPG Industries Inc
Barberton,
Barberton OH
NPDES: OH0024007

Off-site
Waste-
water
Treatment

Receiving
Facility: City
of Barberton;

NPDES
OH0024007

Surface
water

300

0.005

0.0141

0.00

0.00

0.00

0.00

20

0.07

0.2

0.00

0.00

0.07

0.00

Darainic LLC,
Corydon, IN
NPDES: IN0020893

Surface
Water

NPDES
IN0020893

Surface
water

300

0.008

0.0206

0.00

0.00

0.01

0.00

20

0.114

0.29

0.00

0.00

0.10

0.00

Page 570 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

OES: Manufacturing

Axiall Corporation.

Westlake, LA
NPDES: LA0007129

Surface
Water

NPDES
LA0007129

Surface
water

350

1.266

0.0051

0.00

0.00

0.00

0.00

20

22.15

0.0897

0.00

0.00

0.03

0.00

Olin Blue Cube,
Freeport, TX
NPDES: Not
available

Off-site
Waste-
water
Treatment

Organic
Chemicals
Manuf.

Surface
water

350

0.069

2.42

0.00

0.00

0.81

0.00

20

1.2

42.14

0.01

0.05

14.05

0.00

Solvents &
Chemicals,
Pearland, TX
NPDES: Not
available

Off-site
Waste-
water
Treatment

Organic
Chemicals
Manuf.

Surface
water

350

0.015

0.53

0.00

0.00

0.18

0.00

20

0.265

9.48

0.00

0.01

3.16

0.00

Surface
Water

Organic
Chemicals
Manuf.

Surface
water

350

0.015

2.77

0.00

0.00

0.92

0.00

20

0.265

49.91

0.02

0.06

16.64

0.00

Occidental Chemical
Corp Wichita,
Wichita, KS
NPDES: KS0096903
and Organic Chem
MFG SIC

Surface
Water

Surrogate
NPDES
KS0043036

Surface
water

350

0.015

0.07

0.00

0.00

0.02

0.00

20

0.265

1.33

0.00

0.00

0.44

0.00

Off-site
Waste-
water
Treatment

Organic
Chemicals
Manuf.

Surface
water

350

0.015

0.53

0.00

0.00

0.18

0.00

20

0.265

9.48

0.00

0.01

3.16

0.00

OES: Waste Water Treatment Plant (WWTP)

New Rochelle STP,
New Rochelle, NY
NPDES: NY0026697

Surface
Water

NPDES
NY0026697

Still body

365

0.043

0.7

0.00

0.00

0.23

0.00

20

0.786

12.79

0.00

0.02

4.26

0.00

Everett Water
Pollution Control
Facility,
Everett, WA

NPDES:
WA0024490

Surface
Water

NPDES
WA0024490

Surface
water

365

0.016

0.17

0.00

0.00

0.06

0.00

20

0.299

3.11

0.00

0.00

1.04

0.00

Sullivan WWTP,







365

0.01

0.61

0.00

0.00

0.20

0.00

Page 571 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Sullivan, MO

NPDES:
MOO 104736

Surface
Water

NPDES
M00104736

Surface
water

20

0.176

10.97

0.00

0.01

3.66

0.00

Sunnyside STP,
Sunnyside, WA
NPDES:
WA0020991

Surface
Water

NPDES
WA0020991

Surface
water

365

0.005

0.00673

0.00

0.00

0.00

0.00

20

0.083

0.11

0.00

0.00

0.04

0.00

Port Of Sunnyside
Industrial WWTF,
Sunnyside, WA
NPDES:
WA0052426

Surface
Water

POTW (Ind.)

Surface
water

365

0.002

0.26

0.00

0.00

0.09

0.00

20

0.035

4.51

0.00

0.01

1.50

0.00

U.S. Air Force Shaw
AFB SC,

Shaw AFB, SC
NPDES: SC0024970

Surface
Water

POTW (Ind.)

Surface
water

365

0.002

0.26

0.00

0.00

0.09

0.00

20

0.032

4.12

0.00

0.01

1.37

0.00

Gnf-A Wilmington-
Castle Hayne
WWTP,
Wilmington, NC
NPDES: NC0001228

Surface
Water

NPDES
NC0001228

Surface
water

365

0.0004

0.00194

0.00

0.00

0.00

0.00

20

0.0067

0.034

0.00

0.00

0.01

0.00

Cameron Trading
Post WWTP,
Cameron AZ
NPDES: NN0021610

Surface
Water

POTW (Ind.)

Surface
water

365

0.0003

0.0387

0.00

0.00

0.01

0.00

20

0.0047

0.64

0.00

0.00

0.21

0.00

Coal Grove WWTP,

Coal Grove, OH
NPDES: OH0104558

Surface
Water

NPDES
OH0029432

Surface
water

365

0.0002

0.00001
27

0.00

0.00

0.00

0.00

20

0.0031

0.00019

0.00

0.00

0.00

0.00

OES: Other Commercial Uses

Corning Hospital,







250 0.013

0.0271

0.00

0.00

0.01

0.00

Page 572 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Sector in
I I AS 1 '

F.I-AST
W;i(crhod\
Tj pc

DjIJS ol
Kclc.isc'

Kclc.isc
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Aculc HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

\l»;io UQs
(iisinii COC"
ol'3 |)|)h)

Al»iie UQs
(usiiiii ('()(
ol'52.000
pph)

Corning, NY
NPDES: NY0246701

Surface
Water

Surrogate
NPDES
NY0025721

Surface
water

20

0.159

0.33

0.00

0.00

0.11

0.00

Water Street
Commercial Bldg,
Dayton, OH
NPDES: OHO 141496

Surface
Water

Surrogate
NPDES
OH0009521

Surface
water

250

0.003

0.00564

0.00

0.00

0.00

0.00

20

0.035

0.0658

0.00

0.00

0.02

0.00

Union Station North

Wing Office
Building, Denver,
CO
NPDES:
COG315293

Surface
Water

Surrogate
NPDES
C00020095

Surface
water

250

0.0004

0.0881

0.00

0.00

0.03

0.00

20

0.00499

1.1

0.00

0.00

0.37

0.00

Confluence Park
Apartments,
Denver, CO

NPDES:
COG315339

Surface
Water

Surrogate
NPDES
C00020095

Surface
water

250

0.00028

0.0617

0.00

0.00

0.02

0.00

20

0.00354

0.77

0.00

0.00

0.26

0.00

Park Place Mixed
Use Development,
Annapolis, MD
NPDES:
MD0068861

Surface
Water

Surrogate
NPDES
MD0052868

Still body

250

0.00027

9

0.00

0.01

3.00

0.00

20

0.00334

110

0.03

0.14

36.67

0.00

Tree Top Inc
Wenatchee Plant,
Wenatchee, WA
NPDES:
WA0051527

Surface
Water

Not assessed (below the min risk level).

Wynkoop Denver
LLCP St,
Denver, CO

NPDES:
COG603115

Surface
Water

Not assessed (below the min risk level).

Page 573 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Greer Family Lie,
South Burlington, VT
NPDES: VT0001376

Surface
Water

Not assessed (below the min risk level).

John Marshall III
Site,

Mclean VA
NPDES: VA0090093

Surface
Water

Not assessed (below the min risk level).

OES: Other Industrial Uses

Eli Lilly And

Company-
Lilly Tech Ctr,
Indianapolis, IN
NPDES: IN0003310

Surface
Water

NPDES
IN0003310

Surface
water

250

1.553

9.03

0.00

0.01

3.01

0.00

20

19.41

113.09

0.04

0.14

37.70

0.00

Oxy Vinyls LP -
Deer Park Pvc,
Deer Park, TX
NPDES: TX0007412

Surface
Water

NPDES
TX0007412

Surface
water

250

0.148

0.49

0.00

0.00

0.16

0.00

20

1.854

5.98

0.00

0.01

1.99

0.00

Washington Penn
Plastics,
Frankfort, KY
NPDES: KY0097497

Surface
Water

Surrogate
NPDES
KY0028410

Surface
water

250

0.032

7.53

0.00

0.01

2.51

0.00

20

0.399

94.12

0.03

0.12

31.37

0.00

Solvay - Houston
Plant,
Houston TX
NPDES: TX0007072

Surface
Water

NPDES
TX0007072

Surface
water

350

0.024

4.44

0.00

0.01

1.48

0.00

20

0.414

75.93

0.02

0.10

25.31

0.00

Natrium Plant,
New Martinsville,
WV
NPDES:
WV0004359

Surface
Water

NPDES
WV0004359

Surface
water

250

0.022

0.00262

0.00

0.00

0.00

0.00

20

0.274

0.0322

0.00

0.00

0.01

0.00

Leroy Quarry,







250

0.019

0.71

0.00

0.00

0.24

0.00

Page 574 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Leroy, NY
NPDES: NY0247189

Surface
Water

Surrogate
NPDES

Surface
water

20

0.242

8.91

0.00

0.01

2.97

0.00



NY0030546















George C Marshall



Surrogate
NPDES
AL0025585



250

0.01

0.2

0.00

0.00

0.07

0.00

Space Flight Center,

Huntsville, AL
NPDES: AL0000221

Surface
Water

Surface
water

20

0.128

2.63

0.00

0.00

0.88

0.00

Whelan Energy







250

0.009

2.92

0.00

0.00

0.97

0.00

Center Power Plant,

Surface

NPDES

Surface















Hastings, NE

Water

NE0113506

water

20

0.118

38.96

0.01

0.05

12.99

0.00

NPDES: NE0113506





















Anny Cold Regions
Research &

Surface
Water

Surrogate

Surface
water

250

0.0002

0.00010

3

0.00

0.00

0.00

0.00

Engineering Lab,
Hanover, NH

NPDES
NHO100099

20

0.0029

0.00154

0.00

0.00

0.00

0.00

NPDES: NH0001619





















Corning - Canton



Surrogate
NPDES
NY0034762



250

0.0002

0.00034

0.00

0.00

0.00

0.00

Plant,

Surface

Surface















Canton, NY

Water

water

20

0.0028

0.0051

0.00

0.00

0.00

0.00

NPDES: NY0085006



















Ames Rubber Corp







250

0.00011

0.0149

0.00

0.00

0.00

0.00

Plant #1,
Hamburg Boro, NJ
NPDES: NJG000141

Surface
Water

Surrogate
NPDES
NJ0000141

Surface
water

20

0.00133

0.18

0.00

0.00

0.06

0.00

Gorham







250

0.0001

0.0129

0.00

0.00

0.00

0.00

Providence, RI

Surface

POTW (Ind.)

Surface















NPDES: RIG85E004

Water

water

20

0.0012

0.13

0.00

0.00

0.04

0.00

Akzo Nobel Surface
Chemistry LLC,







350

0.000329

0.00068
8

0.00

0.00

0.00

0.00

Morris, IL

Surface

NPDES

Surface















NPDES: IL0026069

Water

IL0026069

water

20

0.006

0.0125

0.00

0.00

0.00

0.00

Solutia Nitro Site,

Surface



Surface

350

0.000318

0.00009

0.00

0.00

0.00

0.00

Nitro, WV

Water



water

41

Page 575 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

NPDES:
WV0116181



Surrogate

NPDES

WV0023229



20

0.006

0.00176

0.00

0.00

0.00

0.00

Amphenol
Corporation -

Columbia,
Columbia, SC
NPDES: SC0046264

Surface
Water

Organic

Chemicals

Manufacture

Surface
water

350

0.000202

0.037

0.00

0.00

0.01

0.00

20

0.004

0.74

0.00

0.00

0.25

0.00

Keeshan and Bost
Chemical Co., Inc.,

Manvel, TX
NPDES: TX0072168

Surface
Water

NPDES
TX0072168

Still body

350

0.000095

9.5

0.00

0.01

3.17

0.00

20

0.002

200

0.06

0.25

66.67

0.00

Chemtura North and

South Plants,
Morgantown WV
NPDES:

WV0004740

Surface
Water

Not assessed (below the min risk level).

Indorama Ventures
Olefins, LLC,
Sulphur, LA
NPDES: LA0069850

Surface
Water

Not assessed (below the min risk level).

Emerson Power
Transmission
Ithaca, NY
NPDES: NY0002933

Surface
Water

Not assessed (below the min risk level).

William E. Warne
Power Plant,
Los Angeles County,
CA

NPDES: CA0059188

Surface
Water

Not assessed (below the min risk level).

Raytheon Aircraft

Co(Was Beech
Aircraft), Boulder,
CO

Surface
Water

Not assessed (below the min risk level).

Page 576 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

NPDES:
COG315176





OES: OTVD (Includes releases for Closed-Loop Degreasing, Conveyorized Degreasing, Web Degreasing, and Metalworking Fluids)

Texas Instruments,
Inc.,
Attleboro, MA

NPDES:
MA0001791

Surface
Water

NPDES
MA0001791

Surface
water

260

0.005

0.0188

0.00

0.00

0.01

0.00

20

0.067

0.25

0.00

0.00

0.08

0.00

Accellent
Inc/Collegeville

Microcoax,
Collegeville, PA
NPDES: PA0042617

Surface
Water

NPDES
PA0042617

Surface
water

260

0.002

0.0425

0.00

0.00

0.01

0.00

20

0.029

0.62

0.00

0.00

0.21

0.00

Ainetek Inc. U.S.

Gauge Div.,
Sellersville, PA
NPDES: PA0056014

Surface
Water

Surrogate
NPDES
PA0020460

Surface
water

260

0.001

0.0619

0.00

0.00

0.02

0.00

20

0.011

0.68

0.00

0.00

0.23

0.00

Atk-Allegany
Ballistics Lab

(Nirop),
Keyser, WV

NPDES:
WV0020371

Surface
Water

NPDES
WV0020371

Surface
water

260

0.0005

0.00311

0.00

0.00

0.00

0.00

20

0.0061

0.0373

0.00

0.00

0.01

0.00

Handy & Hannan
Tube Co/East
Norriton, Norristown,
PA

NPDES: PA0011436

Surface
Water

Not assessed (below the min risk level).

US Nasa Michoud
Assembly Facility,
New Orleans, LA
NPDES: LA0052256

Surface
Water

Surrogate
NPDES
LA0003280

Still body

260

1.96

765.63

0.24

0.97

255.21

0.01

20

25.44

9937.5

3.11

12.61

3312.50

0.19









260

0.13

10.97

0.00

0.01

3.66

0.00

Page 577 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Seelor in
I I AS 1 '

r.i- \s i

W;i(erl>od\
Tj pe

DjIJS ol
Release'

Release
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Acute HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Algae UQs
(using COC"
of 3 |)|)h)

Algae UQs
(usiiiii ('()(
ol'52.000
pph)

GM Components
Holdings LLC,
Lockport, NY
NPDES: NY0000558

Surface
Water

NPDES
NY0000558

Surface
water

20

1.71

144.47

0.05

0.18

48.16

0.00

Akebono
Elizabethtown Plant,
Elizabethtown, KY
NPDES: KY0089672

Surface
Water

Surrogate
NPDES
KY0022039

Surface
water

260

0.07

4.87

0.00

0.01

1.62

0.00

20

0.897

62.38

0.02

0.08

20.79

0.00

Delphi Harrison
Thermal Systems,
Dayton, OH
NPDES: OH0009431

Surface
Water

NPDES
OH0009431

Surface
water

260

0.04

0.0752

0.00

0.00

0.03

0.00

20

0.465

0.87

0.00

0.00

0.29

0.00

Chemours Company
Fc LLC,
Washington, WV
NPDES:
WV0001279

Surface
Water

NPDES
WV0001279

Surface
water

260

0.03

0.00301

0.00

0.00

0.00

0.00

20

0.334

0.0335

0.00

0.00

0.01

0.00

Equistar Chemicals
LP,
La Porte, TX
NPDES: TXO119792

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.02

2.22

0.00

0.00

0.74

0.00

20

0.218

24.44

0.01

0.03

8.15

0.00

GE Aviation,
Lynn, MA
NPDES:
MA0003905

Surface
Water

NPDES
MA0003905

Still
water

260

0.01

0.0425

0.00

0.00

0.01

0.00

20

0.128

0.54

0.00

0.00

0.18

0.00

Certa Vandalia LLC,

Vandalia, OH
NPDES: OHO 122751

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.01

1.11

0.00

0.00

0.37

0.00

20

0.107

11.89

0.00

0.02

3.96

0.00

GM Components
Holdings LLC
Kokomo Ops,

Surface
Water

NPDES
IN0001830

Surface
water

260

0.01

0.2

0.00

0.00

0.07

0.00

20

0.086

1.73

0.00

0.00

0.58

0.00

Page 578 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Kokomo, IN
NPDES: IN0001830





















Amphenol Corp-
Aerospace
Operations,
Sidney, NY
NPDES: NY0003824

Surface
Water

NPDES
NY0003824

Surface
water

260

0.01

0.0486

0.00

0.00

0.02

0.00

20

0.082

0.4

0.00

0.00

0.13

0.00

Emerson Power

Trans Corp,
Maysville, KY
NPDES: KY0100196

Surface
Water

Surrogate
NPDES
KY0020257

Surface
water

260

0.01

0.0004

0.00

0.00

0.00

0.00

20

0.081

0.00522

0.00

0.00

0.00

0.00

Olean Advanced
Products,
Olean. NY
NPDES: NY0073547

Surface
Water

Surrogate
NPDES
NY0027162

Surface
water

260

0.01

0.0188

0.00

0.00

0.01

0.00

20

0.068

0.13

0.00

0.00

0.04

0.00

Hollingsworth Saco
Lowell,
Easley, SC
NPDES: SC0046396

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.00469

0.52

0.00

0.00

0.17

0.00

20

0.061

6.78

0.00

0.01

2.26

0.00

Trelleborg YSH

Incorporated
Sandusky Plant,
Sandusky, MI
NPDES: MI0028142

Surface
Water

NPDES
MI0028142

Surface
water

260

0.0036

1.76

0.00

0.00

0.59

0.00

20

0.047

23.04

0.01

0.03

7.68

0.00

TiinkenUs Corp

Honea Path,
Honea Path. SC
NPDES: SC0047520

Surface
Water

Surrogate
NPDES
SC0000698

Surface
water

260

0.00355

1.06

0.00

0.00

0.35

0.00

20

0.0462

13.77

0.00

0.02

4.59

0.00

Johnson Controls
Incorporated,
Wichita, KS
NPDES: KS0000850

Surface
Water

NPDES
KS0000850

Surface
water

260

0.00228

0.0548

0.00

0.00

0.02

0.00

20

0.0296

0.72

0.00

0.00

0.24

0.00

Page 579 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)























National Railroad
Passenger
Corporation

(Amtrak)
Wilmington
Maintenance Facility,

Wilmington, DE
NPDES: DE0050962

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.00203

0.23

0.00

0.00

0.08

0.00

20

0.026

2.89

0.00

0.00

0.96

0.00

Electrolux Home
Products (Formerly
Frigidaire),
Greenville, MI
NPDES: MI0002135

Surface
Water

NPDES
MI0002135

Surface
water

260

0.00201

0.0171

0.00

0.00

0.01

0.00

20

0.026

0.22

0.00

0.00

0.07

0.00

Rex Heat Treat
Lansdale Inc,
Lansdale, PA
NPDES: PA0052965

Surface
Water

Surrogate
NPDES
PA0026182

Surface
water

260

0.00194

0.0523

0.00

0.00

0.02

0.00

20

0.025

0.67

0.00

0.00

0.22

0.00

Carrier Corporation

Syracuse, NY
NPDES: NY0001163

Surface
Water

NPDES
NY0001163

Still

water

260

0.00177

0.22

0.00

0.00

0.07

0.00

20

0.023

2.84

0.00

0.00

0.95

0.00

Cascade Corp
(0812100207),
Springfield, OH
NPDES: OH0085715

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.00117

0.13

0.00

0.00

0.04

0.00

20

0.015

1.67

0.00

0.00

0.56

0.00

USAF-Wurtsmith
Afb,

Oscoda, MI
NPDES: MI0042285

Surface
Water

Surrogate
NPDES
MI0028282

Surface
water

260

0.00115

0.00075

3

0.00

0.00

0.00

0.00

20

0.015

0.00983

0.00

0.00

0.00

0.00

AAR Mobility

Systems,
Cadillac, MI
NPDES: MI0002640

Surface
Water

Surrogate
NPDES
MI0020257

Surface
water

260

0.00112

0.00916

0.00

0.00

0.00

0.00

20

0.014

0.11

0.00

0.00

0.04

0.00

Page 580 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Seelor in
I I AS 1 '

r.i- \s i

W;i(erl>od\
Tj pe

DjIJS ol
Release'

Release
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Acute HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Algae UQs
(using COC"
of 3 |)|)h)

Algae UQs
(using COC
ol'52.000
pph)























Eaton Mdh Company
Inc,
Kearney, NE
NPDES: NE0114405

Surface
Water

Surrogate
NPDES
NE0052647

Still
water

260

0.00107

0.13

0.00

0.00

0.04

0.00

20

0.014

1.69

0.00

0.00

0.56

0.00

Lake Region
Medical,
Trappe, PA
NPDES: PA0042617

Surface
Water

NPDES
PA0042617

Surface
water

260

0.0005

0.0106

0.00

0.00

0.00

0.00

20

0.007

0.15

0.00

0.00

0.05

0.00

Motor Components L
LC,

Elmira, NY
NPDES: NY0004081

Surface
Water

NPDES
NY0004081

Surface
water

260

0.00096

0.0618

0.00

0.00

0.02

0.00

20

0.0125

0.83

0.00

0.00

0.28

0.00

Salem Tube Mfg,
Greenville, PA
NPDES: PA0221244

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.000897

0.0997

0.00

0.00

0.03

0.00

20

0.012

1.33

0.00

0.00

0.44

0.00

GE (Greenville) Gas
Turbines LLC,
Greenville, SC
NPDES: SC0003484

Surface
Water

NPDES
SC0003484

Surface
water

260

0.000806

0.0821

0.00

0.00

0.03

0.00

20

0.01

1.02

0.00

0.00

0.34

0.00

Parker Hannifin
Corporation,
Waverly, OH
NPDES: OH0104132

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.000747

0.083

0.00

0.00

0.03

0.00

20

0.01

1.11

0.00

0.00

0.37

0.00

Mahle Engine
Components Usa Inc,

Muskegon, MI
NPDES: MI0004057

Surface
Water

NPDES
MI0004057

Surface
water

260

0.000742

0.0336

0.00

0.00

0.01

0.00

20

0.01

0.45

0.00

0.00

0.15

0.00

General Electric
Company -
Waynesboro,
Waynesboro, VA

Surface
Water

NPDES
VA0002402

Surface
water

260

0.000733

0.00705

0.00

0.00

0.00

0.00

20

0.01

0.0962

0.00

0.00

0.03

0.00

Page 581 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Sector in
I I AS 1 '

r.i- \s i

W;i(crhod\
Tj pc

DjIJS ol
Kclc.isc'

Kclc.isc
(kii/d;i>)1

¦'ym
s\\<
(|)|)b)"

Aculc HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Algae UQs
(using COC"
of 3 |)|)h)

Al»iie UQs
(usiiiii ('()(
ol'52.000
pph)

NPDES: VA0002402





















Globe Engineering







260

0.00173

0.00853

0.00

0.00

0.00

0.00

Co Inc,
Wichita, KS
NPDES: KS0086703

Surface
Water

Surrogate
NPDES
KS0043036

Surface
water

20

0.023

0.11

0.00

0.00

0.04

0.00

Gayston Corp,

Surface
Water

Surrogate

Surface
water

260

0.000643

0.00121

0.00

0.00

0.00

0.00

Dayton, OH
NPDES: OHO 127043

NPDES
OH0024881

20

0.008

0.015

0.00

0.00

0.01

0.00

Styrolution America
LLC,

Surface

NPDES

Surface

260

0.000637

0.00022
1

0.00

0.00

0.00

0.00

Channahon, IL
NPDES: IL0001619

Water

IL0001619

water

20

0.008

0.00278

0.00

0.00

0.00

0.00

Remington Arms Co
Inc,







260

0.000612

0.00079

0.00

0.00

0.00

0.00

Surface

NPDES

Surface















Ilion, NY
NPDES: NY0005282















Water

NY0005282

water

20

0.008

0.0104

0.00

0.00

0.00

0.00

United Technologies
Corporation, Pratt







260

0.00048

0.00008
22

0.00

0.00

0.00

0.00

And Whitney

Surface

NPDES

Surface















Division,

East Hartford, CT

Water

CT0001376

water

20

0.006

0.00103

0.00

0.00

0.00

0.00

NPDES: CT0001376





















Atk-Allegany







260

0.00047

0.00292

0.00

0.00

0.00

0.00

Ballistics Lab





















(Nirop),
Keyser, WV
NPDES:

Surface
Water

NPDES
WV0020371

Surface
water

20

0.006

0.0373

0.00

0.00

0.01

0.00

WV0020371





















Sperry & Rice







260

0.000328

0.00569

0.00

0.00

0.00

0.00

Manufacturing Co
LLC,
Brookville, IN

Surface

NPDES

Surface















Water

IN0001473

water

20

0.004

0.0694

0.00

0.00

0.02

0.00

NPDES: IN0001473





















Page 582 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)























Owt Industries,
Pickens, SC
NPDES: SC0026492

Surface
Water

NPDES
SC0026492

Surface
water

260

0.000314

0.00213

0.00

0.00

0.00

0.00

20

0.004

0.0272

0.00

0.00

0.01

0.00

Boler Company,
Hillsdale, MI
NPDES: MI0053651

Surface
Water

Surrogate
NPDES
MI0022136

Surface
water

260

0.000269

0.0204

0.00

0.00

0.01

0.00

20

0.003

0.23

0.00

0.00

0.08

0.00

Mccanna Inc.,
Carpentersville, IL
NPDES: IL0071340

Surface
Water

Surrogate
NPDES
IL0027944

Surface
water

260

0.000268

0.00091
1

0.00

0.00

0.00

0.00

20

0.003

0.0102

0.00

0.00

0.00

0.00

Cutler Hammer,
Horseheads, NY
NPDES: NY0246174

Surface
Water

Surrogate
NPDES
NY0004081

Surface
water

260

0.000238

0.0153

0.00

0.00

0.01

0.00

20

0.003

0.19

0.00

0.00

0.06

0.00

US Air Force Offutt
Afb Ne,

Offutt A F B, NE
NPDES: NE0121789

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.000159

0.0177

0.00

0.00

0.01

0.00

20

0.002

0.22

0.00

0.00

0.07

0.00

Troxel Company,
Moscow, TN
NPDES: TN0000451

Surface
Water

NPDES
TN0000451

Surface
water

260

0.000134

0.00074
1

0.00

0.00

0.00

0.00

20

0.002

0.0111

0.00

0.00

0.00

0.00

Austin Tube Prod,
Baldwin, MI
NPDES: MI0054224

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.000114

0.0127

0.00

0.00

0.00

0.00

20

0.001

0.11

0.00

0.00

0.04

0.00

LS Starrett Precision
Tools,

Athol, MA
NPDES:
MA0001350

Surface
Water

NPDES
MA0001350

Surface
water

260

0.000102

0.00153

0.00

0.00

0.00

0.00

20

0.001

0.015

0.00

0.00

0.01

0.00

Page 583 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

NiiiiK*. I.oi'iilion.
iiml II) ol' \cli\c
Kck'.iscr l-';icilil> ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Sector in
I I AS 1 '

F.I-AST
W;i(crhod\
Tj pc

DjIJS ol
Kclc.isc'

Kclc.isc
(kii/d;i>)1

¦'ym
s\\<
(|)|)h)"

Aculc HQs
(using
COC of
3.200 |)|)h)

('limine
UQs (iisinvi
I'isli ( (K ill'
¦'SS |)|)h)

Al»;ie UQs
(iisinu COC"
ol'3 |)|)h)

Al»iie UQs
(iisinu ('()(
ol'52.000
pph)























Avx Corp,
Raleigh, NC
NPDES: NC0089494

Surface
Water

Primary
Metal
Forming
Manuf.

Surface
water

260

0.0000883

0.00981

0.00

0.00

0.00

0.00

20

0.001

0.11

0.00

0.00

0.04

0.00

Indian Head
Division, Naval
Surface Warfare

Center,
Indian Head, MD
NPDES:
MD0003158

Surface
Water

Not assessed (below the min risk level).

General Dynamics
Ordnance Tactical
Systems,
Red Lion, PA
NPDES: PA0043672

Surface
Water

Not assessed (below the min risk level).

Trane Residential
Solutions - Fort

Smith,

Fort Smith, AR
NPDES: AR0052477

Surface
Water

Not assessed (below the min risk level).

Lexmark
International Inc.,
Lexington, KY
NPDES: KY0097624

Surface
Water

Not assessed (below the min risk level).

Alliant Techsystems
Operations LLC,
Elkton, MD

NPDES:
MD0000078

Surface
Water

Not assessed (below the min risk level).

Daikin Applied
America, Inc.
(Formally Mcquay
International),
Scottsboro, AL
NPDES: AL0069701

Surface
Water

Not assessed (below the min risk level).

Page 584 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Beechcraft
Corporation,
Wichita, KS
NPDES: KS0000183

Surface
Water

Not assessed (below the min risk level).

Federal-Mogul Corp,

Scottsville, KY
NPDES: KY0106585

Surface
Water

Not assessed (below the min risk level).

Cessna Aircraft Co
(Pawnee Facility),
Wichita, KS
NPDES: KS0000647

Surface
Water

Not assessed (below the min risk level).

N.G.I,
Parkersburg, WV
NPDES:
WV0003204

Surface
Water

Not assessed (below the min risk level).

Hyster-Yale Group,
Inc,
Sulligent, AL
NPDES: AL0069787

Surface
Water

Not assessed (below the min risk level).

Hitaclii Electronic
Devices (Usa), Inc.,

Greenville, SC
NPDES: SC0048411

Surface
Water

Not assessed (below the min risk level).

OES: Process Solvent Recycling and Worker Handling of Wastes

Clean Water Of New
York Inc,
Staten Island, NY
NPDES: NY0200484

Surface
Water

Surrogate
NPDES
NJ0000019

Still body

250

0.004

11.76

0.00

0.01

3.92

0.00

20

0.047

138.24

0.04

0.18

46.08

0.00

Reserve
Environmental

Services,
Ashtabula, OH
NPDES: OH0098540

Surface
Water











0.00

0.00

0.00

0.00

Veolia Es Technical
Solutions LLC,
Middlesex, NJ
NPDES: NJ0020141

Off-site
Waste-
water
Treatment

Receiving
Facility:
Middlesex
Cnty UA;

Still body

250

24.1

2.85

0.00

0.00

0.95

0.00

20

301.78

35.72

0.01

0.05

11.91

0.00

Page 585 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)





NPDES
NJ0020141

















Clean Harbors Deer
Park LLC,
La Porte, TX
NPDES: TX0005941

Off-site
Waste-
water
Treatment

POTW (Ind.)

Surface
water

250

0.35

8.57

0.00

0.01

2.86

0.00

20

4.36

106.75

0.03

0.14

35.58

0.00

Clean Harbors El
Dorado LLC,
El Dorado, AR
NPDES: AR0037800

Off-site
Waste-
water
Treatment

POTW (Ind.)

Surface
water

250

0.04

0.98

0.00

0.00

0.33

0.00

20

0.455

11.26

0.00

0.01

3.75

0.00

OES: Processing as a Reactant

440 unknown sites
NPDES: Not
applicable

Off-site
Waste-
water
Treatment

Organic
Chemicals
Manufacture

Surface
water

350

0.005

0.18

0.00

0.00

0.06

0.00

20

0.089

3.13

0.00

0.00

1.04

0.00

Surface
Water

Organic
Chemicals
Manufacture

Surface
water

350

0.005

0.92

0.00

0.00

0.31

0.00

20

0.089

16.45

0.01

0.02

5.48

0.00

Arkeina Inc.
Calvert City, KY
NPDES: KY0003603

Surface
Water

NPDES

KY0003603

Surface
water

350

0.017

0.00073
7

0.00

0.00

0.00

0.00

20

0.295

0.128

0.00

0.00

0.04

0.00

US DOE Paducah
Site,

Kevil, KY
NPDES: KY0102083

Surface
Water

Not assessed (below the min risk level).

GNF-A Wilmington-
Castle Hayne,
Wilmington NC
NPDES: NC0001228

Surface
Water

Not assessed (below the min risk level).

Solvay - Houston
Plant,
Houston TX
NPDES: TX0007072

Surface
Water

NPDES
TX0007072

Surface
water

350

0.024

4.44

0.00

0.01

1.48

0.00

20

0.414

75.93

0.02

0.10

25.31

0.00

Page 586 of 748


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Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Honeywell
International -
Geismar Complex,

Geismar, LA
NPDES: LA0006181

Surface
Water

NPDES
LA0006181

Surface
water

350

0.0128

0.00005
18

0.00

0.00

0.00

0.00

20

0.224

0.00090
7

0.00

0.00

0.00

0.00

Praxair Technology
Center,
Tonawanda, NY
NPDES: NY0000281

Surface
Water

NPDES
NY0000281

Still body

350

0.00169

169

0.05

0.21

56.33

0.00

20

0.03

3000

0.94

3.81

1000.00

0.06

US DOE Paducah
Site,

Kevil, KY
NPDES: KY0102083

Surface
Water

Not assessed (below the min risk level).

GNF-A Wilmington-
Castle Hayne,
Wilmington NC
NPDES: NC0001228

Surface
Water

Not assessed (below the min risk level).





























































































































































OES: Repackaging

Hubbard-Hall Inc,

Waterbury, CT
NPDES: Unknown

Off-site
Waste-
water
Treatment

Receiving
Facility:
Recycle Inc.;
POTW (Ind.)

Surface
water

250

1.108

27.18

0.01

0.03

9.06

0.00

20

13.85

339.11

0.11

0.43

113.04

0.01









250

0.003

6.52

0.00

0.01

2.17

0.00

Page 587 of 748


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Name, Location,
and ID of Active
Releaser Facility a

Release
Media b

Modeled
Facility or
Industry
Sector in
EFASTc

EFAST
Waterbody
Type d

Days of
Releasee

Release
(kg/day)f

7Q10
SWC
(ppb)g

Acute RQs
(using
COC of
3,200 ppb)

Chronic
RQs (using
fish COC of
788 ppb)

Algae RQs
(using COC
of 3 ppb)

Algae RQs
(using COC
of 52,000
ppb)

Oiltanking Houston
Inc.

Houston. TX
NPDES: TX0091855

Surface
Water

Surrogate
NPDES
TX0065943

Surface
water

20

0.041

89.13

0.03

0.11

29.71

0.00

St. Gabriel Terminal.

Saint Gabriel, LA
NPDES: LA0005487

Surface
Water

NPDES
LA0005487

Surface
water

250

0.0055

0.00002
23

0.00

0.00

0.00

0.00

20

0.069

0.00027
9

0.00

0.00

0.00

0.00

Vopak Terminal
Westwego Inc.
Westwego, LA
NPDES: LAO 124583

Surface
Water

Surrogate
NPDES
LA0042064

Surface
water

250

0.00468

0.00001
89

0.00

0.00

0.00

0.00

20

0.058

0.00023
5

0.00

0.00

0.00

0.00

Research Solutions
Group Inc.
Pelham AL
NPDES: AL0074276

Surface
Water

Not assessed (below the min risk level).

Carlisle Engineered
Products Inc.
Middlefield, OH
NPDES: OH0052370

Surface
Water

Not assessed (below the min risk level).

OES: Spot Cleaning and Carpet Cleaning

Boise State
University,
Boise, ID
NPDES: IDG911006

Surface
Water

Surrogate
NPDES
ID0023981

Surface
water

300

0.00008

0.00388

0.00

0.00

0.00

0.00

20

0.001

0.0485

0.00

0.00

0.02

0.00

Page 588 of 748


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NiiiiK*. l.oc;ilion.
iiml II) ol' \cli\c
Kck'siscr l";icilil\ ;|

Kok'iiso
Mediah

Modeled
l';icili(\ oi'
Indusln
Seelor in
I I AS 1 '

F.I-AST
\\;Mcrliod\
Tj po

l);i\s of
Kck'iiso'

Rck.ise
(kg/d;i>)1

"'QUI
SWC
(|)|)b)"

Aculi* HQs
(using
COC of
3.200 |)|)h)

Chronic
UQs (iisillvi
lisli ( (K ill'
¦'XX |)|)h)

Algsie UQs
(using COC
of 3 |)|)b)

Algsie UQs
(using COC
ol' 52.000
ppli)

Venetian Hotel And
Casino,
Las Vegas, NV
NPDES: NV0022888

Surface
Water

Not assessed (below the min risk level).

63,746 unknown sites
NPDES: All POTW
SIC

Surface
Water or
POTW

Not assessed (below the min risk level).

a. Facilities actively releasing trichloroethylene were identified via DMR, TRI, and CDR databases for the 2016 reporting year.

b. Release media are either direct (release from active facility directly to surface water) or indirect (transfer of wastewater from active facility to a receiving POTW
or non-POTW WWTP facility). A wastewater treatment removal rate of 81% is applied to all indirect releases, as well as direct releases from WWTPs.	

c. If a valid NPDES of the direct or indirect releaser was not available in EFAST, the release was modeled using either a surrogate representative facility in EFAST
(based on location) or a representative generic industry sector. The name of the indirect releaser is provided, as reported in TRI.	

d. EFAST uses ether the "surface water" model, for rivers and streams, or the "still water" model, for lakes, bays, and oceans.

e.	Modeling was conducted with the maximum days of release per year expected. For direct releasing facilities, a minimum of 20 days was also modeled.

f.	The daily release amount was calculated from the reported annual release amount divided by the number of release days per year.	

g. For releases discharging to lakes, bays, estuaries, and oceans, the acute scenario mixing zone water concentration was reported in place of the 7Q10 SWC.

h. To determine the PDM days of exceedance for still bodies of water, the release days provided by the EPA Engineers should become the days of exceedance only if
the predicted surface water concentration exceeds the COC. Otherwise, the days of exceedance can be assumed to be zero.	

336

Page 589 of 748


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337

338

339

340

341

342

343

344

345

346

347

348

349

350

351

352

353

354

355

356

357

358

359

360

361

362

363

364

365

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Appendix F BENCHMARK DOSE ANALYSIS FOE (Si

)

F.l BMDS Wizard Output Report - Mortality

The benchmark dose (BMD) modeling of dichotomous data was conducted with the EPA's BMD
software (BMDS (version 2.7) via BMDS Wizard (version 1.11). All reasonably available dichotomous
models (Gamma, Logistic, Dichotomous-Hill, Logistic, Log-Logistic, Probit, Log-Probit, Weibull,
Multistage, and Quantal Linear) were fit to the incidence data for mortality due to introduced infection
in mice following inhalation exposure to TCE. BMRs of 1%, 5%, and 10% extra risk were used in the
BMD modeling, per technical direction. Adequacy of model fit was judged based on the %2 goodness-
of-fit p-value (p> 0.1), magnitude of scaled residuals, and visual inspection of the model fit.

All models except for the Probit and Logistic provided adequate overall fit to the data, based on the %2
goodness-of-fit p-value (p> 0.1). Among the remaining models, the Quantal Linear, Multistage,
Weibull, Gamma and Log-Logistic models all showed poor fit at the 25 ppm data point, based on scaled
residuals ranging from > | 1.5 | to > | 2 |. This was the data point closest to the BMD for the Quantal
Linear at BMR = 10% and for the rest of these models at BMR = 5%. Regardless of whether the models
with poor fit at 25 ppm are included or not, the BMDLs at BMR = 10% or 5% are sufficiently close
(within 3-fold), so that the model with the lowest AIC was selected; this is the Log-Probit. At BMR =
P/o, however, the BMDLs are no longer within 3-fold; the results at this BMR show model-dependence.
This reflects the lack of information reasonably available for the models to use in the data for the low-
dose region of the dose-response curve (responses were similar in the control, 5, 10 and 25 ppm groups)
and signifies increased uncertainty in selecting an appropriate BMDL at this BMR. Excluding the
models with high scaled residuals at 25 ppm as less reliable leaves the Log-Probit and Dichotomous-Hill
models. BMDLs for these models are sufficiently close, so the model with the lower AIC, the Log-
Probit, was selected.

F.l.l BMDS Summary of Mortality - BMR 10%

Table Apx F-l. Summary of BMD Modeling Results for Mortality from Introduced Infection in
Mice Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 10% Extra
Risk

Model"

Goodness of fit

BMDioPct
(ppm)

BMDLioPct
(ppm)

Basis for model selection

/>-value

AIC

Gamma

0.292

342.35

43.5

31.2

All models provided adequate
overall fit to the data except for
the Probit and Logistic models

Dichotomous-Hill

0.563

340.91

44.7

36.2

Logistic

0.0074

351.35

66.2

57.6

(based on the yl goodness-of-fit
p-value). Although the Quantal
Linear model provided adequate
overall fit, the scaled residual
nearest the BMD was > | 2 |,
indicating poor fit in that part of
the curve. With or without the
Quantal Linear, the BMDLs are
sufficiently close (< 3 fold), so the
model with the lowest AIC was
selected (Log-Probit).

LogLogistic

0.370

341.62

43.3

31.6

Probit

0.0211

348.55

61.1

53.3

LogProbit

0.582

338.72

46.6

39.6

Weibull

0.259

342.81

42.5

30.3

Multistage 2ob

0.177

344.14

39.9

27.9

Multistage 3°°
Multistage 4od

0.177

344.14

39.9

27.9

Page 590 of 748


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366

367

368

369

370

371

372

373

374

375

376

377

378

379

380

381

382

383

384

385

386

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Multistage 5oe
Multistage 6of











Quantal-Linear

0.230

343.25

33.0

26.6

a Selected model in bold; scaled residuals for selected model for doses 0, 5,10, 25, 50,100, and 200 ppm were 0.38, -0.08, -
0.18, -1.16,1.08, 0.22, -1.02, respectively.

b The Multistage 2° model may appear equivalent to the Multistage 3° model, however differences exist in digits not displayed
in the table. This also applies to the Multistage 4° model. This also applies to the Multistage 5° model. This also applies to the
Multistage 6° model.

c Hie Multistage 3° model may appear equivalent to the Multistage 2° model, however differences exist in digits not displayed
in the table.

d For the Multistage 4° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 3° model.

e For the Multistage 5° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 4° model.

f For the Multistage 6° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 5° model.

LogProbit Model, with BMR of 10% Extra Risk for the BMD and 0.95 Lower Confidence Limit for the BMDL

FigureApx F-l. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit
Model for Mortality from Introduced Infection in Mice Following Inhalation
Exposure to TCE (Selgrade and Gilmour 2010); BMR = 10% Extra Risk

Probit Model. (Version: 3.4; Date: 5/21/2017)

The form of the probability function is: P[response] = Background + (1-Background) *
CumNorm(Intercept+Slope*Log(Dose)),where CumNorm(.) is the cumulative normal distribution
function

Slope parameter is restricted as slope >= 1

Benchmark Dose Computation.

BMR = 10% Extra risk
BMD = 46.6299

BMDL at the 95% confidence level = 39.5537

Parameter Estimates

Page 591 of 748


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Variable

Estimate

Default Initial
Parameter Values

background

0.0281182

0.0338983

intercept

-5.1238E+00

-5.2930E+00

slope

1

1

387

388	Analysis of Deviance Table

Model

Log(likelihood)

# Param's

Deviance

Test d.f.

p-value

Full model

-165.36

7







Fitted model

-167.36

2

4.00401

5

0.55

Reduced model

-208.64

1

86.5627

6

<0001

389

390	AIC: = 338.719

391

392	Goodness of Fit Table

Dose

Est. Prob.

Expected

Observed

Size

Scaled Resid

0

0.0281

3.318

4

118

0.38

5

0.0283

1.077

1

38

-0.08

10

0.0304

1.187

1

39

-0.18

25

0.0557

4.346

2

78

-1.16

50

0.1377

15.979

20

116

1.08

100

0.3216

25.088

26

78

0.22

200

0.5814

22.093

19

38

-1.02

393

394	ChiA2 = 3.78 d.f=5 P-value = 0.5818

395

396

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397	F.1.2 BMDS Summary of Mortality - BMR: 5%

398	Table Apx F-2. Summary of BMD Modeling Results for Mortality from Introduced Infection in

399	Mice Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 5% Extra

400	Risk

Model"

Goodness of fit

BMDspct
(ppm)

BMDLspct
(ppm)

Basis for model selection

/>-value

AIC

Gamma

0.292

342.35

26.2

15.7

All models provided adequate
overall fit to the data except for
the Probit and Logistic models

Dichotomous-Hill

0.563

340.91

33.9

22.5

Logistic

0.0074

351.35

40.3

34.4

(based on the yl goodness-of-fit
p-value). However, The Quantal
Linear, Multistage, Weibull,
Gamma and Log-Logistic models
all showed poor fit at the 25 ppm
data point, based on scaled
residuals ranging from > | 1.5 | to
> | 2 |. This was the data point
closest to the BMD for all of these
models except the Quantal Linear.
With or without these models, the
BMDLs are sufficiently close (< 3
fold), so the model with the
lowest AIC was selected (Log-
Probit).

LogLogistic

0.370

341.62

26.8

17.0

Probit

0.0211

348.55

36.6

31.4

LogProbit

0.582

338.72

32.4

27.5

Weibull

0.259

342.81

24.5

14.9

Multistage 2°
Multistage 3ob
Multistage 4oc
Multistage 5od
Multistage 6°e

0.177

344.14

20.6

13.6

Quantal-Linear

0.230

343.25

16.0

12.9

a Selected model in bold; scaled residuals for selected model for doses 0, 5,10, 25, 50,100, and 200 ppm were 0.38, -0.08, -
0.18, -1.16,1.08, 0.22, -1.02, respectively.

b For the Multistage 3° model, the beta coefficient estimates were 0 (boundary of parameters space). Hie models in this row
reduced to the Multistage 2° model.

c For the Multistage 4° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 3° model.

d For the Multistage 5° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 4° model.

e For the Multistage 6° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 5° model.

LogProbit Model, with BMR of 5% Extra Risk for the BMD and 0.95 Lower Confidence Limit for the BMDL

<

J 0.3

BMDL BMD

401	dose

402	Figure Apx F-2. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit

403	Model for Mortality from Introduced Infection in Mice Following Inhalation

404	Exposure to TCE (Selgrade and Gilmour 2010); BMR = 5% Extra Risk

405	Probit Model. (Version: 3.4; Date: 5/21/2017)

Page 593 of 748


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406

407

408

409

410

411

412

413

414

415

416

417

418

419

420

421

422

423

424

425

426

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

The form of the probability function is: P[response] = Background + (1-Background) *
CumNorm(Intercept+Slope*Log(Dose)),where CumNormQ is the cumulative normal distribution
function

Slope parameter is restricted as slope >= 1

Benchmark Dose Computation.

BMR =5% Extra risk
BMD = 32.4253

BMDL at the 95% confidence level = 27.5047

Parameter Estimates

Variable

Estimate

Default Initial
Parameter Values

background

0.0281182

0.0338983

intercept

-5.1238E+00

-5.2930E+00

slope

1

1

Analysis of Deviance Table

Model

Log(likelihood

)

# Param's

Deviance

Test d.f.

p-value

Full model

-165.36

7







Fitted model

-167.36

2

4.00401

5

0.55

Reduced model

-208.64

1

86.5627

6

<0001

AIC: = 338.719
Goodness of Fit Table

Dose

Est. Prob.

Expected

Observed

Size

Scaled Resid

0

0.0281

3.318

4

118

0.38

5

0.0283

1.077

1

38

-0.08

10

0.0304

1.187

1

39

-0.18

25

0.0557

4.346

2

78

-1.16

50

0.1377

15.979

20

116

1.08

100

0.3216

25.088

26

78

0.22

200

0.5814

22.093

19

38

-1.02

ChiA2 = 3.78 d.f=5 P-value = 0.5818

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427	F.1.3 BMDS Summary of Mortality - BMR: 1%

428	Table Apx F-3. Summary of BMD Modeling Results for Mortality from Introduced Infection in

429	Mice Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 1% Extra

430	Risk

Model"

Goodness of fit

BMDiPct
(ppm)

BMDLiPct
(ppm)

Basis for model selection

/>-value

AIC

Gamma

0.292

342.35

8.52

3.22

All models provided adequate
overall fit to the data except for
the Probit and Logistic models

Dichotomous-Hill

0.563

340.91

19.1

7.62

Logistic

0.0074

351.35

10.2

8.35

(based on the yl goodness-of-fit
p-value). However, The Quantal
Linear, Multistage, Weibull,
Gamma and Log-Logistic models
all showed poor fit at the 25 ppm
data point, based on scaled
residuals ranging from > | 1.5 | to
> | 2 |. If all models are
included, the BMDLs are not
sufficiently close (> 3-fold). For
this reason, the BMDS Wizard
recommended selection of the
Quantal Linear model, which had
the lowest BMDL. The > 3-fold
range of BMDLs is indicative of
model dependence and signifies
increased uncertainty in selecting
an appropriate BMDL at this
BMR. Excluding the models with
high scaled residuals at 25 ppm as
less reliable leaves the Log-Probit
and Dichotomous-Hill models.
BMDLs for these models are
sufficiently close, so the model
with the lower AIC, the Log-
Probit, was selected.

LogLogistic

0.370

341.62

9.29

4.17

Probit

0.0211

348.55

9.14

7.52

LogProbit

0.582

338.72

16.4

13.9

Weibull

0.259

342.81

7.05

2.93

Multistage 2ob

0.177

344.14

4.27

2.66

Multistage 3°°
Multistage 4od
Multistage 5oe
Multistage 6of

0.177

344.14

4.27

2.66

Quantal-Linear

0.230

343.25

3.14

2.53

a Selected model in bold; scaled residuals for selected model for doses 0, 5,10,25, 50,100, and 200 ppm were 0.38, -0.08, -
0.18, -1.16,1.08, 0.22, -1.02, respectively.

b The Multistage 2° model may appear equivalent to the Multistage 3° model, however differences exist in digits not displayed
in the table. This also applies to the Multistage 4° model. This also applies to the Multistage 5° model. This also applies to the
Multistage 6° model.

c The Multistage 3° model may appear equivalent to the Multistage 2° model, however differences exist in digits not displayed
in the table.

d For the Multistage 4° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 3° model.

e For the Multistage 5° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 4° model.

f For the Multistage 6° model, the beta coefficient estimates were 0 (boundary of parameters space). The models in this row
reduced to the Multistage 5° model.

431

Page 595 of 748


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432

433

434

435

436

437

438

439

440

441

442

443

444

445

446

447

448

449

450

451

452

453

454

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

LogProbit Model, with BMR of 1% Extra Risk for the BMD and 0.95 Lower Confidence Limit for the BMDL

FigureApx F-3. Plot of Incidence by Dose (ppm) with Fitted Curve for Log-Probit
Model for Mortality from Introduced Infection in Mice Following Inhalation
Exposure to TCE (Selgrade and Gilmour 2010); BMR =1% Extra Risk

Probit Model. (Version: 3.4; Date: 5/21/2017)

The form of the probability function is: P[response] = Background + (1-Background) *
CumNorm(Intercept+Slope*Log(Dose)),where CumNorm(.) is the cumulative normal distribution
function

Slope parameter is restricted as slope >= 1

Benchmark Dose Computation.

BMR =1% Extra risk
BMD = 16.4027

BMDL at the 95% confidence level = 13.9135
Parameter Estimates

Variable

Estimate

Default Initial
Parameter Values

background

0.0281182

0.0338983

intercept

-5.1238E+00

-5.2930E+00

slope

1

1

Analysis of Deviance Table

Model

Log(likelihood

)

# Param's

Deviance

Test d.f.

p-value

Full model

-165.36

7







Fitted model

-167.36

2

4.00401

5

0.55

Reduced model

-208.64

1

86.5627

6

<0001

AIC: = 338.719

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455 Goodness of Fit Table

Dose

Est. Prob.

Expected

Observed

Size

Scaled Resid

0

0.0281

3.318

4

118

0.38

5

0.0283

1.077

1

38

-0.08

10

0.0304

1.187

1

39

-0.18

25

0.0557

4.346

2

78

-1.16

50

0.1377

15.979

20

116

1.08

100

0.3216

25.088

26

78

0.22

200

0.5814

22.093

19

38

-1.02

456

457	ChiA2 = 3.78 d.f=5 P-value = 0.5818

458

459

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F.2 BMDS Wizard Output Report - Number of Mice Infected

The benchmark dose (BMD) modeling of dichotomous data was conducted with the EPA's BMD
software (BMDS (version 2.7) via BMDS Wizard (version 1.11). All reasonably available dichotomous
models (Gamma, Logistic, Dichotomous-Hill, Logistic, Log-Logistic, Probit, Log-Probit, Weibull,
Multistage, and Quantal Linear) were fit to the incidence data for mortality due to introduced infection
in mice following inhalation exposure to TCE. BMRs of 1%, 5%, and 10% extra risk were used in the
BMD modeling, per technical direction. Adequacy of model fit was judged based on the %2 goodness-
of-fit p-value (p> 0.1), magnitude of scaled residuals, and visual inspection of the model fit.

All models except for the Probit and Logistic provided adequate overall fit to the data, based on the %2
goodness-of-fit p-value (p> 0.1). Among the remaining models, the Quantal Linear, Multistage,
Weibull, Gamma and Log-Logistic models all showed poor fit at the 25 ppm data point, based on scaled
residuals ranging from > | 1.5 | to > | 2 |. This was the data point closest to the BMD for the Quantal
Linear at BMR = 10% and for the rest of these models at BMR = 5%. Regardless of whether the models
with poor fit at 25 ppm are included or not, the BMDLs at BMR = 10% or 5% are sufficiently close
(within 3-fold), so that the model with the lowest AIC was selected; this is the Log-Probit. At BMR =
P/o, however, the BMDLs are no longer within 3-fold; the results at this BMR show model-dependence.
This reflects the lack of information reasonably available for the models to use in the data for the low-
dose region of the dose-response curve (responses were similar in the control, 5, 10 and 25 ppm groups)
and signifies increased uncertainty in selecting an appropriate BMDL at this BMR. Excluding the
models with high scaled residuals at 25 ppm as less reliable leaves the Log-Probit and Dichotomous-Hill
models. BMDLs for these models are sufficiently close, so the model with the lower AIC, the Log-
Probit, was selected.

F.2.1 BMDS Summary of Infected at 72 hours - BMR - 10%

Table Apx F-4. Summary of BMD Modeling Results for Number of Mice Infected at 72 Hours
after Infection Following Inhalation Exposure to TCE (Selgrade and Gilmour 2010); BMR = 10%
Extra Risk

Model"

Goodness of fit

BMDioPct
(ppm)

BMDLioPct
(ppm)

Basis for model selection

/>-value

AIC

Gamma

0.190

23.637



4t34

All models provided adequate fit
to the data (based on the yl
goodness-of-fit p-value), although
a BMDL could not be calculated
for the Dichotomous-Hill model.
The BMDS Wizard recommended
the Probit model because it had
the lowest AIC. BMDs and
BMDLs from all models are well
below the lowest data point and
cannot be considered reliable.

Dichotomous-Hill

0.164

23.965



error^

Logistic

0.428

21.584



g 3g

LogLogistic

0.164

23.965





Probit

0.448

21.445





LogProbit

0.383

21.877



(5 gg

Weibull

0.189

23.606

±43

4-r2£

Multistage 2°

0.202

23.480



432

Multistage 3°

0.228

23.267

12 g

4t43-

Quantal-Linear

0.425

21.639

g 55

4t34

a Selected model in bold; scaled residuals for selected model for doses 0, 50, 100, and 200 ppm were -0.23, 0.86, -0.82, 0.38,
respectively.

b BMD or BMDL computation failed for this model.

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Probit Modei. with BMR of 10% Extra Risk for the BMD and 0-95 Lower Confidence Limit for the BMDL

TableApx F-5. Plot of Incidence by Dose (ppm) with Fitted Curve for Probit Model
for Number of Mice Infected at 72 Hours after Infection Following Inhalation
Exposure to TCE (Selgrade and Gilmour 2010); BMR = 10% Extra Risk

494

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Appendix G WEIGHT OF EVIDENCE FOR CONGENITAL HEART
DEFECTS

G.J_ EPA Review of the Charles River ( ) Study

G.l.l Study Methodology and Results

In a study sponsored by the Halogenated Solvents Industry Alliance (HSIA), Charles River Laboratories
Ashland, LLC performed "An Oral (Drinking Water) Study of the Effects of Trichloroethylene (TCE)
on Fetal Heart Development in Sprague Dawley Rats". The study was based on general accordance with
OPPTS 870.3700 and OECD Test Guideline 414 with the stated purpose of replicating the findings of
(Dawson etai. 1993) and (Johnson et al. 2003). which observed increased cardiac malformations in the
fetuses of pregnant female Sprague Dawley rats administered TCE in drinking water.

The study utilized 6 test groups, including negative and positive controls. Retinoic acid (RA) served as a
positive control and was administered daily via gavage. TCE was administered via drinking water. See
details in TableApx G-l, which is adapted from Text Table 4 in the study.

Table Apx G-l. Experimental Design

(Iroup

TiViilmcnl

Tsir»ei
(onccnlnilion

Route of
Ailminisli'iilion

Nil in ho r ol'
l-'cmsilcs (l)itms)

1

Vehicle (water)

0 ppm

Drinking Water

25

2

Retinoic Acid

3 mg/ml

Gavage

25

3

TCE

0.25 ppm

Drinking Water

25

4

TCE

1.5 ppm

Drinking Water

25

5

TCE

500 ppm

Drinking Water

25

6

TCE

1000 ppm

Drinking Water

25

In order to reduce TCE loss due to evaporation, drinking water formulations were prepared at volumes
large enough to minimize headspace and a connected nitrogen source was used to backfill headspace
during dosing. Despite this effort, 24-hour loss monitoring indicated that 30% to 49% of average
measured TCE concentration was lost over the course of a day.

Interventricular septal defects (VSDs) were the only cardiac malformation observed in TCE-treated
groups. Additional types of defects were observed in the positive control RA-treated group, including
malformations of the aorta and arteries, small ventricle, and situs inversus (transposition of the heart and
great/major vessels). Situs inversus was also observed in a single vehicle control fetus. The study
authors did not observe a statistically significant increase in VSDs among TCE-treated fetuses compared
to vehicle. Additionally, all VSDs observed in TCE-exposed fetuses were smaller than 1mm, in contrast
with vehicle and RA-treated groups. Results are shown in Table Apx G-2 below, which is adapted from
Text Table 14 in the study, with a few small edits. The Charles River study described the statistical
estimate used as "summation per group (%)", which appears to be the sum of viable fetuses affected per
litter (%) / number of litters per group". EPA determined that while this method is appropriate, the
description is unclear and would be better described as "Mean % Affected / Litter per Group". EPA
therefore replaced the descriptor "% per litter" with the above descriptor. EPA also identified that the

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RA-treated group actually had 41.2% affected, as opposed to 42.2% as was presented in Text Table 14
of the study.

Table Apx G-2. Summary of C

Observed Interventricular E

defects

Dosage:

0 ppm
(Vehicle)

15 mg/kg-day
RA

0.25 ppm
TCE

1.5 ppm
TCE

500 ppm
TCE

1000 ppm
TCE

# Affected
Fetuses (Litters)

7(5)

112 (23)

4(4)

5(3)

13 (8)

12(6)

Mean % Affected
/ Litter per Group

2.4%

41.2%
(p < 0.01)

1.4%

1.5%

3.8%

3.7%

Size of Opening
(Number of
Fetuses)

2mm (1)


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1.5 ppm

9/181
(5.0%)

5/13
(38.5%)

(Johnson et
aL 2003)

5/321
(1.5%)

3/24
(12.5%)

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

500 ppm

N/A

N/A

N/A

13/330
(3.9%)

8/24
(33.3%)

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

1000 (Charles River) or
1100 (Johnson) ppm

11/105
(10.5%)

6/9
(66.7%)

(Johnson et
aL 2003)

12/342
(3.5%)

6/24
(25.0%)

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

The Johnson study clearly shows greater incidences of cardiac defects at 0.25 ppm, 1.5 ppm, and 1100
ppm compared to the same or similar doses (1000 ppm in Charles River). Of note however, VSDs, and
specifically only membranous VSDs, were the only type of heart malformation identified by the Charles
River study in TCE-treated fetuses. In contrast, the Johnson study identified a broad variety of defects in
exposed fetuses. The Johnson study observed VSDs at only a slightly greater incidence per fetus than by
Charles River at higher doses, while (peri)membranous VSDs were observed at a similar or lower
incidence than by Charles River. Additionally, Charles River observed substantially higher incidences of
VSDs in the control and 0.25 ppm groups. The data comparing the incidence of VSDs only is presented
in Table Apx G-4, with the incidence of membranous VSDs displayed in parentheses.

Table Apx G-4. Incidence of VSDs in Johnson and Charles River studies.



Johnson 2003

Charles River 2019

Dose

% fetuses
affected
(mem. only)

Source

%
fetuses
affected

Source/Notes

0 ppm

0.66%
(0.33%)

(Johnson et al.. 2003).
Table 2

2.5%

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

2.5 ppb

0%

(Johnson et al. 2003).
Table 2

N/A

N/A

0.25 ppm

0%

(Johnson et al. 2003).
Table 2

1.4%

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

1.5 ppm

2.21%
(1.66%)

(Johnson et al. 2003).
Table 2

1.5%

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

500 ppm

N/A

N/A

3.9%

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

1000 (Charles River) or
1100 (Johnson) ppm

3.81%
(2.86%)

(Johnson et al. 2003).
Table 2

3.5%

(Charles River
Laboratories. 2019).
Table 15
(soft tissue), p. 86

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562	G.l.2.2 Differences in Types of Malformations Observed

563	The majority of cardiac malformations observed in the Johnson study were not VSDs (see Table 2 in

564	(Johnson et al.. 2003). while the Charles River study only identified VSDs in controls and TCE-treated

565	offspring. Of note, two major categories of heart malformations identified in the Johnson study that are

566	absent from even the positive control group of the Charles River study are atrial septal defects and valve

567	defects. The Charles River study methodology appeared to be focused primarily on identification of VSDs

568	over other heart defects, which may explain the observed positive bias toward detection of VSDs in

569	vehicle control and low-dose fetuses as compared to both the Johnson study and historical control data.

570	Table Apx G-5 compares the heart defects observed across all in vivo oral studies. Fisher at al. (20011 a

571	gavage study that also did not find a statistically significant association of TCE exposure with congenital

572	cardiac defects, is also included for comparison. Of note, the (Fisher et al.. 2001) study utilized the same

573	dissection and evaluation methodology as the (Johnson et al.. 2003) studies. There is substantial overlap in

574	the many type of defects identified in the three studies, while only membranous VSDs were observed in

575	TCE-treated animals in (Charles River Laboratories. 2019) (great blood vessel variation was identified in a

576	few TCE-treated pups but was considered incidental by the study authors). When comparing the results

577	from (Fisher et al.. 2001) and (Charles River Laboratories. 2019). EPA acknowledges that differences in

578	dosing method, vehicle volume, and other variables may also contribute to any observed differences.

579

58	0	Table Apx G-5. Heart and Cardiovascular Defects Observed in Oral TCE studies

Cardiac Malformations Observed Across Select Oral TCE and Retinoic Acid (RA) Developmental Toxicity Studies in Rats

Trichloroethylene (TCE)

Retinoic Acid (RA)

Johnson et al. (2003)a

Charles River (2019)

Fisher et al. (2001)

Charles River (2019)

Fisher et al. (2001)

Septal defects

Ventricular septal defect
(VSD) (perimembranous,
subaortic, muscular)

Ventricular septal
defect (VSD)
(membranous)



Ventricular septal
defect (VSD)
(membranous,
subaortic, muscular)

Ventricular septal defect
(VSD) (membranous,
aortic, muscular)

Atrial septal defect (ASD)



Atrial septal defect (ASD)



Atrial septal defect (ASD)

Valve defects

Mitral valve defect



Mitral valve defect



Mitral valve defect

Tricuspid valve defect



Tricuspid valve defect



Tricuspid valve defect

Pulmonary valve defect







Pulmonary valve defect

Aortic valve defects
(multiple)





Aortic stenosis

Aortic stenosis

Atrium, ventricle, and miscellaneous structural abnormalities

Atrioventricular septal
defect (endocardial
cushion defects)



Endocardial cushion
defects









Right ventricle enlarged



Right ventricle enlarged





Left ventricle aneurysm
dissecting

Heart ventricle, small

Left atrial hypertrophy









Cleft, apex of heart

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Cardiac Malformations Observed Across Select Oral TCE and Retinoic Acid (RA) Developmental Toxicity Studies in Rats

Great vessel structural abnormalities







Transposition of the
great vessels

Transposition of the
great vessels







Aortic arch effects

Aortic arch effects







Major blood vessel
variation

Major blood vessel
variation

Pulmonary artery
hypoplasia







Pulmonary artery
hypoplasia

Aortic hypoplasia













Innominate artery short



Innominate artery effect

Coronary artery/sinus





Stenotic carotid

Truncus dilated

Positional abnormalities of the heart and great vessels





Situs inversus

Situs inversus

Dextrocardia

Abnormal looping







Overriding aorta

a Includes data from Dawson et al. (1993).

Bold text indicates defects observed across multiple studies (both TCE and RA treatment).
Red bold text indicates defects only observed with RA treatment across multiple studies.

581

582	EPA's conclusion that the Charles River study insufficiently sensitive to non-VSD defects was supported

583	by the limited variety of malformations observed in the RA positive control based on a compiled literature

584	search:

585	1. EPA searched HERO and PubMed for studies investigating heart defects and malformations that

586	occur during prenatal exposure to all-trans retinoic acid (RA). Of the 37 studies reviewed, 12

587	studies were excluded from analysis because they were abstracts, book chapters, reviews, or

588	studies that did not expose animals to all-trans RA. Thus, EPA reviewed 25 studies and

589	compared the results of these studies to those reported by the Charles River and Johnson studies.

590	2. In all species examined, a total of 35 heart defects were associated with prenatal exposure to RA

591	in the identified literature.

592	3. The Charles River study reported 10 types of heart defects in animals exposed to RA.

593	4. Heart defects associated with TCE exposure partially overlap defects associated with RA

594	exposure. The Johnson study identified 10 types of cardiac defects in TCE-exposed fetuses.

595	Charles River only identified one defect (membranous VSDs) associated with TCE exposure

596	(major blood vessel variation was observed in 1-2 TCE-treated fetuses, but this effect was not

597	considered treatment-related).

598	5. All 35 defects associated with RA exposure were observed in rodents in the literature review. If

599	we limit the analysis to studies examining only rats, 31 of the total 35 defects were observed.

600	Only 6 of the 35 defects were noted in chickens, and 2 of the 35 were noted in zebrafish.

601	Therefore, the differences between defects captured in the Charles River study and the general

602	literature cannot be explained simply by inclusion of additional experimental species in the

603	general literature.

604

605	EPA therefore concludes that Charles River did not capture the entirety of cardiac defects that were

606	expected upon exposure to RA.

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EPA searched HERO using the following keywords:

•	Retinoic Acid

•	Retinoic Acid + Cardiac

EPA also searched PubMed using the following keywords:

•	retinoic acid (RA)-induced cardiac defects

•	retinoic acid AND (cardiac defects OR cardiac malformations OR heart defects OR heart
malformations OR cardiac teratogenesis OR aorta OR ventricle OR endocardial cushion OR
pulmonary valve OR mitral valve OR aortic valve OR ventricular septum OR atrial septum OR
tricuspid valve OR aneurysm).

TableApx G-6 presents all of the cardiac defects found in the literature search.

TableApx G-7 compares the types of defects observed across the Johnson and Charles River studies
with those identified in the literature search. Several defects associated with TCE exposure as well as
several RA-induced defects in the Charles River study were not associated with RA exposure in the
literature. Overall, the spectrum of heart defects observed upon RA exposure in the literature largely, but
not entirely, overlaps with heart defects associated with TCE exposure. Of note, atrial septal defects,
which were the most common type of malformation identified in the Johnson study, were identified in 5
other RA studies but not in the Charles River study.

Table Apx G-6. Cardiac Defects O

jserved in Literature



Number of

( iinliiic IkTed

Studies

VSD

12

ASD

5

Tetralogy Fallot

1

Hypoplastic Left Heart Syndrome

1

Tricuspid Atresia

1

Aortic Valve Stenosis

1

Pulmonary Trunk Stenosis

3

Right Ventricular Hypertrophy

2

Left Ventricular Hypertrophy

1

Right Atrial Hypertrophy

2

Left Atrial Hypertrophy

1

CAVC

1

Situs Inversus

2

Dextrocardia

5

d Transposition

12

I Transposition

1

Cleft Apex

1

CoA

1

ARSA

2

IAA

1

Left Circumflex Aorta

1

Right aortic arch defect (RAA)

4

Double Aortic Arch

1

Cervical Aortic Arch

1

Hypoplastic Aortic Arch

1

Truncus Arteriosus

7

PDA

1

Innominate Artery Absent

1

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Innominate Artery Short

1

Right Carotid Off Aorta

1

Right Subclavian Artery Absent

1

DORV

10

Endocardial Cushion Defect

3

Abnormal Heart Looping

7

Other*

14

628

629		Table Apx G-7. Cardiac Defects Observed After Exposure to RA or TCE

Chemical:

TCE

TCE

RA

RA

RA

Malformation Class

Malformation Name

Charles
River
2019

Johnson
2003

Charles
River
2019

Other
Literature

(No.
Studies)

Other
Literature
Species1

Atrium, Ventricle and Valve
Defects

VSDs2

a/

a/

a/

V (12)

C. H. M.
R

Atrium, Ventricle and Valve
Defects

Atrial Septal Defect



a/



V(5)

H.R

Atrium, Ventricle and Valve
Defects

Double outlet ventricle
(DORV)







a/(10)

C. H. M.
R

Atrium, Ventricle and Valve
Defects

Tetralogy of Fallot







Vd)

M

Atrium, Ventricle and Valve
Defects

Hypoplastic Left Heart
Syndrome







V(1)

R

Atrium, Ventricle and Valve
Defects

Tricuspid defects



a/



V(1)

H

Atrium, Ventricle and Valve
Defects

Aortic valve defects



a/3



V(1)

R

Atrium, Ventricle and Valve
Defects

Mitral valve defects



a/







Atrium, Ventricle and Valve
Defects

Right ventricular hypertrophy







V (2)

R

Atrium, Ventricle and Valve
Defects

Left ventriclular hypertrophy







V(1)

R

Atrium, Ventricle and Valve
Defects

Right atrial hypertrophy







V (2)

R

Atrium, Ventricle and Valve
Defects

Left atrial hypertrophy







V(1)

R

Atrium, Ventricle and Valve
Defects

Small ventricle





a/





Atrium, Ventricle and Valve
Defects

Complete Atrioventricular
Canal defect (CAVC)



a/



V(1)

R

Symmetry

Situs Inversus





a/

V(2)

C.R

Symmetry

Dextrocardia







V (5)

M.R

Symmetry

d-Transposition of the great
arteries





a/

a/(12)

C. H. M.
R

Symmetry

1-Transposition of the Great
Arteries







V(1)

R

Symmetry

Cleft, apex of heart







V(1)

R

Aortic Arch Defects

Coarctation of the Aorta
(CoA)





a/

V(1)

R

Aortic Arch Defects

Left aortic arch with aberrant
right subclavian artery
(ARSA)





a/4

V(2)

R

Aortic Arch Defects

left circumflex aorta







V(1)

M

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Chemical:

TCE

TCE

RA

RA

RA

Malformation Class

Malformation Name

Charles
River
2019

Johnson
2003

Charles
River
2019

Other
Literature

(No.
Studies)

Other
Literature
Species1

Aortic Arch Defects

Right aortic arch defects
(RAA)



a/



V (4)

H. M.R

Aortic Arch Defects

Double aortic arch







V(1)

R

Aortic Arch Defects

Cervical aortic arch







V(1)

R

Aortic Arch Defects

Interruption of the aortic arch





a/

V(1)

M

Aortic Arch Defects

Hypoplastic aortic arch







V(1)

R

Aortic Arch Defects

Stenotic aortic arch





a/





Other vessel defects

Pulmonary trunk stenosis







V(3)

H.R

Other vessel defects

Truncus Arteriosus (dilated
truncus)







V(7)

H. M.R

Other vessel defects: incomplete
postnatal development

Patent Ductus Arteriosus







V(1)

R

Other vessel defects

Innominate artery absent







V(1)

R

Other vessel defects

Innominate artery short







V(1)

R

Other vessel defects

Right carotid off aorta







V(1)

R

Other vessel defects

Stenotic carotid





V





Other vessel defects

Right subclavian artery absent







V(1)

R

Other vessel defects

Pulmonary artery hypoplasia



a/







Other vessel defects

Coronary artery/sinus defects



V







Other early developmental
defect

Endocardial cushion defects







V (3)

M.R

Other early developmental
defect

Abnormal heart looping



V



V (7)

C. H. R, Z

Other5







a/7

V (14)

C. H. M.
R.Z

1	Chicken (C), Hamster, (H), Mouse (M), Rat (R), Zebrafish (Z).

2	Most studies reviewed did not specify among perimembranous, muscular or subarterial VSDs, so these were included all as "VSDs" for the
literature review comparison.

3	Aortic valve defects included aortic valve defect with fenestrated leaflets and aortic valve stenosis described as aortic valve defect with fused
leaflets creating aortic valvular stenosis.

4Chicken (C), Hamster, (H), Mouse (M), Rat (R), Zebrafish (Z).

4Retroesophageal aortic arch described in Charles River study was tagged as ARSA defect.

5 Major blood vessel variation (right carotid and subclavian arteries arose independently from the aortic arch [no brachiocephalic trunk] or right
subclavian artery coursed retroesophageal and joined the aortic arch adjacent to ductus arteriosus [no brachiocephalic trunk]) tagged to RAA
defects.

5 If EPA was unsure of the general malformation class, the defect was categorized as "other".

0 "Other" defect in HSIA study (RA exposure groups) was a major blood vessel variation (an elongated brachiocephalic trunk or a missing
brachiocephalic trunk due to right carotid and right subclavian arising independently from the aortic arch, or due to a retroesophageal right
subclavian; or (right carotid and subclavian arteries arose independently from the aortic arch [no brachiocephalic trunk] or right subclavian
artery coursed retroesophageal and joined the aortic arch adjacent to ductus arteriosus [no brachiocephalic trunk]).

630	G.l.2.3 Methodology Differences

631	There are likely several contributing factors explaining why the Charles River study failed to identify

632	atrial or valve defects. In the Johnson study, the materials and methods section described examination of

633	the internal structure of the heart for all fetuses. The dissection methodology allows detailed

634	examination of the atrial septum. In contrast, the Charles River study states that the fetal evaluation

635	methods were conducted according to Stuckhardt and Poppe (1984). which does not include

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examination of atrial septal defects. Therefore, the methodology used by the Charles River study was
likely to miss this important category of cardiac malformations. As shown in
Table Apx G-7, five other studies were identified in the literature that observed atrial septal defects
following RA exposure, while none were observed in the Charles River study.

The Stuckhardt and Poppe method (1984) does includes visualization of the valves (the tricuspid, mitral,
aortic, and pulmonary valves) but the methods as described in the Johnson study and supporting
information are more likely to reveal valvular defects as compared to the Stuckhardt and Poppe
methodology. The Stuckhardt and Poppe method specifies that two cuts are made in the fresh fetal heart.
This allows visualization of the tricuspid valve, between the right atrium and right ventricle, the three
cusps of the semilunar valve of the pulmonary artery, and the interventricular septum. In comparison,
the Johnson study clearly specified that the fetal hearts were to be examined in situ for external defects
and then excised, preserved with glutaraldehyde, and dissected. The examination of the internal structure
of the heart for all fetuses specifically included removing tissue to expose the pulmonary, aortic,
tricuspid, and mitral valves. The location of the coronary ostium was noted, each valve was probed for
patency, and the formation of each valve leaflet was examined.

EPA believes that there is a certain amount of tissue elasticity in fresh fetal hearts that can obscure the
detection of valvular defects during fetal morphological evaluation. Because the Johnson study evaluated
the internal structure of the fetal hearts post-fixation, examination of the valvular structures would have
been facilitated. Additionally, valve defects may be overlooked during examination unless the technician
is directly focusing on evaluating the cardiac valves in all fetuses (not just those, for example, in which
external cardiac morphological differences, such as a collapsed ventricle, might suggest a potential valve
problem). No indication is given in the Charles River report whether a directed effort was made to
identify valvular abnormalities.

Other identified differences and uncertainties in the methodology between the two studies may or may
not have contributed to the differences in results. These factors could potentially make either the Johnson
or the Charles River data more precise. These include the following:

1.	Variations in TCE loss over time. While the Charles River study made extensive efforts to
minimize TCE loss, the 24-hour loss monitoring indicated that average loss across all
measurements was actually greater than that in the Johnson study (42% vs 35%). The Johnson
study did not provide analytical measurements for close comparison, but it is possible that on
average the delivered dose was greater in the Johnson study.

2.	Possible differences in criteria for fetuses selected for examination. In the Johnson study, it is not
explicitly stated whether all or only viable fetuses were examined. The Charles River study
indicates that only viable fetuses were examined. For the Charles River study, this is a moot
point as there were no dead fetuses in the entire study. However, this aspect of study design is
not documented in the Dawson or Johnson studies.

3.	Randomization methods. Differences in incidences at the litter level could potentially result from
non-randomized groups of animals at different dose levels. Different randomization strategies
were used in Johnson 2003 compared to the HSIA study. Dam assignments to exposure groups
was randomized in Johnson 2003, whereas the HSIA study used stratified randomization. Details
of the stratified randomization strategy were not presented, except to indicate that the goal was to
achieve similar group mean body weights. Given that there were six treatment groups and many
racks have six cages per row, it raises the possibility that treatment group was confounded with
cage position, i.e., Group 1 in one column, Group 2 in the next column, etc. The Dawson and

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Johnson methods of randomization did not include consideration of, or stratification by, body
weight.

4.	Husbandry differences, the Charles River study individually housed the pregnant females,
whereas the Dawson and Johnson studies group-housed the females, so several dams were
consuming treated drinking water from the same bottle. Thus, there would be greater precision in
the Charles River dose calculations.

5.	Source and strain of rats. The rats used in all the studies conducted as part of the TCE research
program at the University of Arizona that included (Dawson et al. 1993) and (Johnson et al.
2003) were Harlan Sprague-Dawley rats purchased from Harlan Laboratories Inc., Indianapolis,
IN. The Charles River rats were Crl:CD(SD) Sprague-Dawley rats from Charles River
Laboratories in Raleigh, NC. It is unknown what influence the source or strain differences might
have had on the response to treatment with TCE. Additional information from both groups of
researchers would be needed to ascertain whether the source, sub strain or genetic drift of the test
animals influenced the incidences of cardiac malformations.

6.	Technical confirmation of diagnosis. The Charles River report did not specify whether cardiac
abnormalities were confirmed by other technical staff or the Study Director. There is no
opportunity to re-examine fetuses because the report states that all carcasses were discarded
following completion of the internal examination of the fetuses. In comparison, the three
principle authors of the Dawson and Johnson studies (P. Johnson, S. Goldberg, and B. Dawson),
each examined every identified fetal cardiac anomaly, and they only included findings for which
there was unanimous agreement on diagnosis (as described in (Makris et al.. 2016)). Therefore,
there is high confidence in the determination of observed defects in the Dawson and Johnson
studies. Of note, neither study was designed to confirm diagnoses of normal fetal morphology.

G.l.2.4 Adversity of Small VSDs

In addition to the lack of a statistically significant increase in cardiac defects, the Charles River study
claims that the 
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of defect size. More significantly, the study concluded that muscular VSDs are much more likely to
close spontaneously than membranous VSDs (which were the only VSD type associated with TCE
exposure in the Charles River study). The incidence in humans of spontaneous closure in cited studies
examining only muscular VSDs ranges from 22% to 84%, while for studies examining only
membranous or perimembranous VSDs the incidence ranges from only 4% to 47%. Additionally, the
morphological characterization of closure of the membranous VSD seems to most commonly involve
the use of a leaflet of the tricuspid valve, which would be expected to impact the functional ability of
that heart valve. Therefore, even if a membranous VSD is able to spontaneously close, there are likely
functional impacts of that closer, resulting in an adverse health effect.

Overall, it is impossible to speculate whether the specific VSDs identified in these studies would have
closed during lactation. Congenital heart defects of any kind are considered to be an adverse medical
event in humans, whether they eventually close naturally or need to be surgically repaired. When
considering the uncertainty over the likelihood of VSD closure and the preponderance of additional
types of defects observed in other studies, this consideration is not relevant to the significance of this
endpoint.

G.2 WOE Analysis for Congenital Cardiac Defects

G.2.1 Methodology

1) EPA identified, collected and reviewed a sampling of recent literature on systematic approaches
to performing weight-of-evidence evaluation. Relevant articles were identified by simple Google
searches and by tree searching references listed in these publications. References included the
following:

a.	Weed. 2005. Weight of Evidence: A Review of Concept and Methods. Risk Anal 25(6):
1545-1557 (Weed. 2005).

b.	Gough. 2007. Weight of Evidence: A Framework for the Appraisal of the Quality and
Relevance of Evidence. Research Papers in Education 22(2): 213-228 (Gough. 2007).

c.	Rhomberg et al. 2013. A survey of frameworks for best practices in weight-of-evidence
analyses. CritRev Toxicol 43(9): 753-784 (Rhomberg et al.. 2013).

d.	Rooney et al. 2014. Systematic Review and Evidence Integration for Literature-Based
Environmental Health Science Assessments. Env Health Perspect 122 (7): 711-718
(Rooney et al. 2014).

e.	NTP. 2015. Handbook for Conducting a Literature-Based Health Assessment Using
OHAT Approach for Systematic Review and Evidence Integration (	).

f.	EPA. 2016. Weight of Evidence in Ecological Assessment. Risk Assessment Forum.
EPA/100/R16/001 (U.S. EPA. 20161).

g.	EPA. 2015. EDSP: Weight of Evidence Analysis of Potential Interaction with the
Estrogen, Androgen or Thyroid Pathways. Chemical: Glyphosate. Office of Pesticide
Programs (\ ^ \ :01 \t).

h.	US Army Corps of Engineers. 2018. Weight-of-Evidence Concepts: Introduction
and Application to Sediment Management (Engineers. 2018).

i.	European Commission. 2018. Memorandum on weight of evidence and uncertainties.
Revision 2018. Scientific Committee on Health, Environmental and Emerging Risks
(SCHEER) (EC. 2018).

j. EFSA. 2017. Guidance on the use of the weight of evidence approach in scientific
assessments. EFSA Journal 15(8): 4971 (1-69) (EFSA. ).

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k. Linkov et al. 2015. From "Weight of Evidence" to Quantitative Data Integration using
Multicriteria Decision Analysis and Bayesian Methods. Altex 32(1): 3-8 (Linkov et al..

2015).

1. Smith et al. 2002. Weight of Evidence (WOE): Quantitative Estimation of Probability of
Impact. Manuscript (Smith et al.. 2002).

m. Bridges et al. 2017. Framework for the quantitative weight-of-evidence analysis of
'omics data for regulatory purposes. Reg Tox Pharm 91: S46-S60 (Bridges et al.. 2017).

n. Dekant and Bridges. 2016. Assessment of reproductive and developmental effects of
DINP, DnHP and DCHP using quantitative weight of evidence. Reg Tox Pharm 81: 397-
406 (Dekant and Bridges. 2016).

o. Bridges and Solomon. 2016. Quantitative weight-of-evidence analysis of the persistence,
bioaccumulation, toxicity, and potential for long-range transport of the cyclic volatile
methyl siloxanes. J Toxicol Environ Health Part B 19(8): 345-379 (Bridges and Solomon.

2016).

p. Gangwal et al. 2012. Incorporating exposure information into the toxicological

prioritization index decision support framework. Sci Total Environ 435-436: 316-325
(Gangwal et al.. 2012).

q. Reif et al. 2013. ToxPi GUI: an interactive visualization tool for transparent integration
of data from diverse sources of evidence. Bioinformatics 29(3): 402-403 (Reif et al..
2013).

r. Klimisch et al. 1997. A Systematic Approach for Evaluating the Quality of Experimental
Toxicological and Ecotoxicological Data. Reg Tox Pharm 25: 1 -5 (Klimisch et al.. 1997).

2) Upon review of the various weight-of-evidence approaches that have been proposed, EPA chose
to adopt the method presented by EPA Risk Assessment Forum (	Q16i). This method

was originally designed for ecological assessment and offers some flexibility in its
recommendations, so it has been adapted as fit-for-purpose to perform the weight-of-evidence
analysis for TCE cardiac defects. Benefits of this method are as follows:

a.	The distinguishing feature of this method is that pieces of evidence are scored not just for
reliability (quality) and relevance, as in most methods reviewed, but also strength of the
evidence. EPA concurs with (	2016t) that explicitly scoring the strength of the
individual pieces of evidence (e.g., magnitude, dose-response, etc.) is crucial to
performing a weight-of-evidence assessment.

b.	The scoring system presented is qualitative and uses intuitive and easily understood
symbols to convey both the implication of a piece of evidence (+, -, 0 for positive,
negative, none, or supports, weakens, neutral/ambiguous) and the weight attached to it (+,
++, +++ or -, —, — for low, medium and high). EPA believes that symbols are preferable
to numerical scores because their use correctly implies that they cannot be numerically
combined. They simply signify semi-quantitative levels of confidence, strength, and
directionality of the results for the different qualitative properties.

c.	Assessment results are presented as weight-of evidence tables that show a visual picture
of the findings. The tables capture nuances in the evidence being weighed and yet remain
understandable. Seeing patterns in the frequencies of +, - and 0 symbols that indicate the
weight of evidence is easier than if words or numbers are used to score evidence.

d.	The method is flexible. Although developed for use in ecological assessment, it is easily
adaptable to use in human health assessment and to different approaches (e.g., individual
pieces of evidence can be assessed and weighed for a line or type of evidence based on

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source, such as inhalation toxicity studies, or for a line of evidence for a particular
property (e.g., temporal association or other Hill consideration).

3) For our implementation of the (	) weight-of-evidence method, EPA developed an

Excel spreadsheet [EPA, 2019. Data Table for Congenital Heart Defects Weight of Evidence
Analysis. Docket: EPA-HQ-OPPT-2019-0500], as follows:

a.	The pieces of evidence are studies (or distinct experiments within studies). They are
organized into lines of evidence based on study type: epidemiological, in vivo animal),
and mechanistic. Within each line of evidence, pieces of evidence are further organized
into subsets based on route of exposure (oral, inhalation, other) and test material (TCE or
metabolite) for toxicological studies or vertebrate class of tissue, embryo or animal
studied (mammalian, avian, fish) for mechanistic studies. WOE determinations are made
in succession, first for subsets of a line of evidence, then for the full lines of evidence,
and then for the overall database, each building on the assessments that came before.

b.	Each piece of evidence (study) was graded in 3 areas: reliability (quality),
outcome/strength, and relevance. The rationale for each grade was recorded.

i.	Reliability is defined in (	0161) as inherent properties that make
evidence convincing. For our implementation, because each piece of evidence is
a study, this refers primarily to aspects of study design, execution, and
transparency.

1.	Possible scores for reliability were 0, +, ++, or +++ for unusable, low,
medium and high.

2.	In contrast to the study quality evaluations performed in Distiller, which
included >20 specific quality criteria for each study, here each study was
given only a single overall grade. We considered the same issues, but we
did not formally go through and assign grades on each one individually.
Instead, focus was on key attributes. Noteworthy deficiencies were
recorded and grades were assigned based on the number and nature of the
specific deficiencies identified.

ii.	Outcome/strength is defined in (	ji) as degree of differentiation
from control, reference, or randomness. This is based on study results and may be
influenced by magnitude, dose-response, number of related elements changed
(e.g., consistent changes in histopathology and serum chemistry), temporal
concordance, etc.

1. Possible scores for outcome/strength were —, —, -, 0, +, ++, or +++ for
results ranging from strongly negative to no effect/ambiguous to strongly
positive.

iii.	Relevance is defined in (	i) as degree of correspondence between
the evidence and the assessment endpoint. This can be thought of as the degree of
extrapolation that would be needed to use the data in question for developing a
toxicity value.

1.	Possible scores for relevance were 0, +, ++, or +++ for none, low, medium
and high.

2.	Maximum values based on study type were +++ for epidemiology studies,
++ for in vivo animal studies by natural route of exposure, and + for in
vivo animal studies by other route of exposure and in vitro studies.

Starting from these maximum scores, deductions were made for issues

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such as testing of TCE metabolites rather than TCE for in vivo animal
studies and poorly defined exposures in epidemiology studies,
iv. The grades for reliability, outcome/strength, and relevance for each piece of
evidence (study) were integrated across each area (horizontally) into an overall
grade for that study. In deriving the overall grade, low area scores were
considered to have more weight than higher scores, as per (U.S. EPA. 20.1.60. In
other words, if any one of the three grading areas was low, then even if other
aspects of the study were rated highly, the study still contributed lower weight
overall to the WOE analysis (e.g., a great study with a compelling result
performed using DCA rather than TCE). Based on this methodology, overall
grades for each study were always in the same direction as the strength score (i.e.
+ vs -) at a value defined by the lowest amplitude (+ vs ++ vs +++) of the three
factors. Rationale for the overall grade was provided, as it was for the individual
area grades.

c.	When integrating overall study scores from all studies within a line of evidence (or subset
of a line of evidence) or across lines of evidence (vertically), overall summary scores
were determined as a the best semi-quantitative representation of all overall study grades
within that line of evidence, with considerations given to both the amplitude of the
overall study grades along with the consistency of the strength direction across studies.
When results were mixed, overall summary scores for a line of evidence gave greater
weight to overall study grades of greater amplitude (e.g., ++ vs +). Similarly, studies with
non-ambiguous results (not a strength score of 0) were considered more informative than
ambiguous studies. Additionally, consistent overall study grades of lower amplitude (e.g.,
all +) may have resulted in a summary score of a higher amplitude (++). In this way,
WOE determination was most influenced by studies with the strongest, clearest effects
and/or lines of evidence with the most consistent results. This differs from how the
individual area grades were combined into overall study grades (See Section b(iv),
above), where the lowest amplitude value determined the overall weight.

d.	Evidence areas were also integrated as a mathematical average (e.g., ++ = 2, 0/- = -0.5),
in order to summarize the evidence areas for all studies. In contrast with the overall
summary score however, for individual evidence areas, the integrated area scores
represented a true average and were not adjusted upward for consistency or in order to
favor non-ambiguous results (which was specific to strength score). Of note, these are
included for presentation purposes only and were not used to determine the overall
summary score for a line of evidence. The overall summary scores were determined by
integrating the overall grades for each study, in the manner as described in Section c.
Because of these different methodologies and the fact that overall study grades are
defined by the lowest amplitude evidence area, the overall summary score may differ
from the integrated area scores.

Note: This analysis was performed in parallel with the systematic review data evaluation of the
individual studies. The WOE analysis had a greater focus on relevance to the specific endpoint while the
data evaluation metrics aimed to evaluate the utility of a study for dose-response analysis. Therefore, the
conclusions of the WOE analysis for individual studies occasionally differed from the results of the
systematic review data evaluation. The results of both are presented together in [EPA, 2019. Data Table
for Congenital Heart Defects Weight of Evidence Analysis. Docket: EPA-HQ-OPPT-2019-0500.]. Of
note, studies that scored Unacceptable in data quality evaluation were not considered in the WOE
analysis. Their evaluation is included for reference, but their scores had no impact on the overall grades

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for each line of evidence or subset. Unacceptable studies are indicated by red text in the below tables
and the supplemental data table. Studies that were not rated (NR) because EPA determined that they
were not pertinent are indicated by blue text in the supplemental data table, however they are not
included in the tables below.

G.2.2 WOE Results By Study Type

Data evaluated to assess the weight-of-evidence for congenital heart defects from exposure to TCE
include studies from three lines of evidence: epidemiology studies, in vivo animal toxicity studies, and
mechanistic studies. For this analysis, the three lines of evidence will be considered both individually
and collectively.

Table Apx G-8 shows the weight-of-evidence for the various epidemiology studies that were considered
in this review. Ruckart et al. ( ) was identified in previous reviews but was graded as NR (not
relevant) and dropped from the analysis because the study did not include cardiac defects as an assessed
endpoint. All of the other TCE studies were considered to be of (++) relevance scores because they
examined associations of TCE exposure in humans, however quantitative exposure to TCE was assessed
indirectly in all of them. One study that examined exposure to TCE degradants (Wright et al.. 2017)
scored only (+) for relevance because the degradants may also have originated from a different source.
The high potential for misclassification of exposure was a limiting factor for all of these studies, which
were otherwise generally adequate ecological or case-control studies (reliability rated as + for all
studies). Of the relevant studies, four reported results suggestive of a positive association between
maternal TCE exposure and congenital cardiac defects in offspring, one reported a lack of an
association, and two reported ambiguous results. Of the three studies with a positive association,
(Goldberg et al. 1990) was rated Unacceptable in data quality evaluation and therefore did not
contribute to the WOE. The Bove reports (1996; 1995) (considered here as a single study because the
two papers contain the same data on cardiac defects) reported elevated but nonsignificant increases in
odds ratios. Yauck et al. (2004) reported a positive association between congenital heart defects and
TCE exposure only in older mothers, while younger mothers and the overall population had a null
association. The finding of a negative association in the study by (Lagakos et al.. 1986) has some
ambiguity because it was based on a very small number of cases, exposure was not classified based on
TCE specifically, and there was atypical directionality of confounder effects. Gilboa et al. Q ) did not
find any positive association with TCE exposure in a large but limited study. Three studies showing
positive associations of varying strength (Brender et A JO I I; h >t and et al.. 2012; Wright et al.. 2017)
also had some limitations but collectively provide suggestive evidence for an association between
maternal TCE exposure and cardiac defects in offspring. In evaluating all studies and giving greater
weight to studies with non-ambiguous results, the resulting overall summary score for epidemiology is
(+), indicating a positive association between TCE exposure and congenital cardiac defects.

Table Apx G-8. Weight-of-Evidence Table for Epidemiology Studies

Kvidenee Area

Reliability

Strength

Relevance

Overall Grade

TCE

(Lagakos et al.. 1986)

+

0/-

++

0/-

(Bove. 1996; Bove et al..
1995)

+

0

++

0

(Yauck et al., 2004)

+

0/+

++

0/+

(Forand et al., 2012)

+

++

++

+

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Evidence Area

Reliability

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Summary Score (all epidemiology)

+

Possible scores for reliability and relevance were 0, +, ++, or +++ for unusable, low, medium and high.

Possible scores for strength and overall weight were —, —, -, 0, +, ++, or +++, with ranges inbetween, for results ranging from

strongly negative to ambiguous to strongly positive.

Red text identifies studies that scored Unacceptable in data quality evaluation and a 0 for reliability. Hie WOE scores are
provided for reference but were not incorporated into the overall score for the line of evidence.

Table Apx G-9 shows the weight-of-evidence for the various in vivo animal studies that were
considered in this review. The four TCE oral studies were considered of (++) relevance because they
used a natural route of exposure (drinking water or gavage) in a mammallian study. Dawson et al.
(1993) and the Charles River Laboratories study (2019) were rated as (++) reliability, while Fisher et al.
(2001) and Johnson et al. (2003) were rated as (+) reliability. The score was downgraded for (Fisher et
al.. 2001) because only a single dose group was used and the negative control for TCE demonstrated a
very elevated prevalence of heart and cardiovascular defects. Johnson et al. (2003) was rated as lower
reliability due to the small group sizes, poor data reporting (somewhat mitigated by subsequent errata
and personal communications), and the pooling of data from multiple trials into a single experiment.
Increased incidence of cardiac defects were observed in pups from the (Dawson et al.. 1993) and
(Johnson et al.. 2003) studies. The Strength scores for these studies were characterized as (++) for
(Johnson et al.. 2003) and (+) for (Dawson et al.. 1993). influenced by the low magnitude of effect in the
high dose groups and uncertainty surrounding the precision of estimated doses. The incidence of cardiac
defects were not increased by TCE oral gavage in the (Fisher et al.. 2001) study; however, this study
used only a single dose group and the incidence of heart defects was elevated in the soybean oil controls
compared to drinking water controls, therefore the strength score was (0/-). The recent study by Charles
River Laboratories (2019) also did not find any statistically significant increase in developmental
cardiac defects following TCE administration in drinking water, however this study appeared to be of
reduced sensitivity in its ability to detect all types of cardiac defects (see Appendix G.l). It therefore
also scored (0/-) for Strength. The overall summary for the TCE oral studies was characterized as
ambiguous to weakly positive (0/+) due to conflicting study results, with a lean toward positive based on
the ambiguity of the negative studies.

Six oral experiments using TCE metabolites (TCA or DCA) were rated as lower relevance (+), because
a metabolite was administered (not TCE) and the relevance of these effects to humans likely dependent
upon individual toxicokinetic variability and the administered dose. These studies were considered
mostly reliable with ratings of (+++) (Smith et al.. 1989) and (++) (Fisher et al.. 2001; Epstein et al..
1992). Only (Johnson et al.. 1998) received a lower reliability score (0/+) due to concerns about source
of the test substance and sharing of bottles among animals. Both TCA and DCA were convincingly
shown to produce strong dose-related cardiac defects (strength score of ++) in the (Smith et al.. 1992.
1989) studies (downgraded for use of relatively high doses that produced other embryo/fetotoxic effects

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or even maternal effects), with weaker positive strength scores (+) in the (Johnson et al.. 1998) and
(Epstein et al.. 1992) studies. The (Fisher et al.. 2001) study (also reviewed separately for TCE
administration) only showed a small, non-statistically significant increase in cardiac defects for both
TCA and DC A, but the single dose level used in these studies was too low to rule out effects at higher
doses based on results of the other studies. The overall summary score for the oral metabolite studies
was (+).

Three inhalation studies using TCE were considered relevant (natural exposure route) and reliable.
Reliability ratings were reduced for studies with a single exposure group and poor reporting (+,

(Schwetz et al.. 1975)) in addition to small group sizes and high negative control responses with a lack
of dose-responsiveness (0/+, (Dorfmueller et al.. 1979)). These studies were also reduced in relevancy
score (+) because they were general teratology studies and the focus on cardiac effects was unclear. Two
studies scored an Unacceptable in data quality and a 0 in reliability for limited reporting of study details
(Hardin et al.. 1981) and use of a nonstandard exposure duration with insufficient details on exposure
method (Healy et al.. 1982). These studies did not contribute to the WOE. Among acceptable inhalation
studies, the results were consistently negative, however with varying scores in the three evidence areas.
Carney et al. (2006) was the best inhalation study, scoring the maximum (+++) for reliability and
showing a strong negative response (--). Based on these results, the summary score for the inhalation
studies was (-), primarily driven by the weight of the (Carney et al.. 2006) data but reduced by the
weaknesses of the other studies and the limited number of acceptable studies with non-ambiguous
results.

As for other exposure routes, Dawson et al. (1990) administered TCE via intrauterine instillation in rats.
This relevance of this study was rated as lower (+) due to the unnatural exposure route and the study
reliability was low (0/+), because of sampling inadequacy, small group sizes, and poor reporting. The
strength of this study was (+) due to several factors, including the use of fetuses (not litters) as the
experimental unit, the small magnitude of the response seen in the high dose group only (which was a
very high dose considering the exposure route). The overall summary score for animal studies across all
exposure routes suggests an unclear/ambiguous relationship between TCE exposure during gestation and
the incidence of cardiac defects in offspring. This ambiguity is based on weakly positive evidence from
oral or intrauterine TCE administration, positive evidence from oral TCE metabolites, and a negative
evidencewith TCE inhalation. The WOE from in vivo animal toxicity studies therefore does not either
support or refute the association of TCE exposure with developmental cardiac defects.

Table Apx G-9. Weight-of-Evidence Table for In Vivo Animal Toxicity Studies

Evidence Area

Reliability

Strength

Relevance

Overall Grade

ORAL

TCE

(Dawson et al.. 1993)

++

+

++

+

(Johnson et al.. 2003)

+

++

++

+

(Fisher et al.. 2001)

+

01-

++

01-

(Charles River
Laboratories. 2019)

++

01-

++

01-

Integrated Area Scores

+/++

01+

++



Summary Score (TCE)

01+

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Evidence Area

Reliability

Strength

Relevance

Overall Grade

METABOLITES (TCA, DCA)

(Smith etal.. 1989)

+++

++

+

+

(Smith etal.. 1992)

+++

++

+

+

(Johnson et al.. 1998)

0/+

+

+

0/+

(Fisher et al.. 2001)

++

-

+

-

(Epstein et al.. 1992)

++

+

+

+

Integrated Area Scores

++

+

+



Summary Score (Metabolites)

+

Integrated Area Scores
(all oral studies)

++

+

++



Summary Score (all oral studies)

+

INHALATION

TCE

(Schwetz et al.. 1975)

+

0/-

+

0/-

(Dorfmueller et al..
1979)

0/+

01-

+

01-

(Carnev et al.. 2006)

+++

—

++

—

(Hardin et al.. 1981)

0

-

++

0

(Healv et al.. 1982)

0

-

++

0

Integrated Area Scores
(all inhalation studies)

+/++

-

+/++



Summary Score (all inhalation studies)

-

OTHER ROUTES (Uterine Infusion)

(Dawson et al.. 1990)

0/+

+

+

01+

Integrated Area Scores
(in vivo - all routes)

+/++

0/+

+/++





Summary Score (in

vivo - all routes)



0

Possible scores for reliability and relevance were 0, +, ++, or +++, with ranges inbetween, for unusable, low, medium and high.
Possible scores for strength and overall weight were —, —, -, 0, +, ++, or +++, with ranges inbetween, for results ranging from
strongly negative to ambiguous to strongly positive.

Red text identifies studies that scored Unacceptable in data quality evaluation. The WOE scores are provided for reference but
were not incorporated into the overall score for the line of evidence.

1023

1024	Mechanistic studies that inform the weight-of-evidence for developmental heart defects include

1025	evaluations of cardiac structure and function in chick and rodent embryos and mode-of-action or key

1026	event data focused on processes and pathways that contribute to the observed valvulo-septal defects

1027	(e.g., altered calcium flux, inhibition of stem cell differentiation and endothelial cell proliferation) as

1028	well as altered expression of oxidative metabolism enzymes. A mechanistic study from Palbykin et al.

1029	(2011) was graded as not relevant and was dropped from the analysis because it merely examined

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molecular mechanisms underlying the results observed in (Caldwell et ai. 2008) without contributing
any additional WOE to the endpoint. The remaining mechanistic studies in mammalian cells/tissues,
chick embryos and zebrafish embryos were generally rated as lower relevance in comparison to human
studies and in vivo animal studies using a natural route of administration except for studies on ex vivo
whole rat embryos or in vivo data from rodents or humans, which were assigned a relevance score of
(+/++). All other studies were rated as (+) relevance.

Mechanistic studies in mammalian systems included an occupational worker study (Green et ai. 2004).
in vivo rat studies (Collier et ai. 2003; Dow and Green. 2000). studies using rat and mouse whole
embryo cultures (Hunter et ai. 1996; Saillenfait et ai. 1995) and in vitro studies using cell lines (Jiang et
ai. 2015; Caldwell et ai. 2008; Selmin et ai. 200S; Ou et ai. 2003). Ou et ai (2003) and Jiang et ai
(2015) were rated as highly reliable (+++) because they were well-designed and well-conducted studies
with a full reporting of the results. Most of the remaining mammalian studies were rated as (++) for
reliability, because there were minor deficiencies noted in study design, performance or reporting. Dow
and Green (2000) was rated as low (0/+) for reliability, with flaws including pooling of experiments,
poor data reporting, and insufficient justification of dose selection. In mammalian systems, higher
strength (++) was ascribed to studies that demonstrated structural changes in the embryonic heart
(Hunter et ai. 1996). suppression of endothelial cell proliferation in cell culture ( et ai. 2003). and
inhibition of cardiac differentiation from embryonic stem cells (Jiang et ai. 2015). Studies that
demonstrated precursor events that contribute to altered cardiac development (i.e., changes in gene
expression, altered calcium flux, folate deficiency) were rated as weakly positive (+) for strength. These
included changes in gene expression relating to cardiac development and calcium flux (Jiang et ai.
2015; Caldwell et ai. 2008; Selmin et ai. 2008; Collier et ai. 2003) and in vivo folate deficiency (Green
et ai. 2004; Dow and Green. 2000) (which has been associated with congenital heart defects in humans
(Mao et ai. 2017)). Saillenfait et ai (1995) did not observe morphological cardiac changes in whole rat
embryos exposed to TCE in culture, although only morphological features were examined and the
results were not explicitly discussed in the text. This study was rated as moderately negative (-/--) for
strength.

With the exception of the Saillenfait study (which did not describe its procedure for evaluation of
malformations in whole rat embryos), the other mammalian mechanistic studies all reported positive
results. Several of these studies demonstrated a clear dose-response, although in others the results were
less clear (e.g., suggestive of a biphasic dose-response, with change at the lower doses but not the higher
doses, see discussion in Section 3.2.4.1.6). The overall summary score for mammalian mechanistic
studies was (+).

The chick embryo is a valid model system for studying embryonic development, and in particular,
cardiac development. Eight studies investigated development of cardiac defects and associated effects
in chick embryos exposed to TCE and metabolites. These were all generally well-designed, conducted
and reported. All chick embryo studies received a (++) rating for reliability except for (Loeber et ai.
1988). which was downgraded slightly to (+/++) due to missing reporting details and a potentially
insensitive evaluation procedure. Two studies reported significant increases in incidences of a variety of
cardiac defects (Rufer et ai. 2010; Loeber et ai. 1988). resulting in a a strength rating of (++). The
remaining studies showed various mechanistic changes thought to be involved in cardiac development
or function and scored less positive for strength, (+). The only study that did not produce a clear
positive result featured an earlier exposure window than the others and obtained ambiguous results with
mixed results on endocardiocyte proliferation and no changes in cardiac output was rated as (0) for

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strength (Drake et al.. 2006b). The overall summary score for chick embryo studies was (++) based on
the relatively large number of studies demonstrating consistently positive effects.

The zebrafish embryo is also a valid model for evaluating cardiac development. Two of the three
zebrafish embryo studies were well designed and well documented with few notable limitations (rated as
highly reliable, +++). The reliability rating for (Williams et al.. 2006) was reduced to (++) due to the use
of a single exposure level. All three studies gave positive results indicating the potential for TCE (or its
metabolite DCA) to effect cardiac development in zebrafish. The study by Wirbisky et al. (2016) was
the most comprehensive study of the three (rated as +++ for strength), identifying multiple dose-
responsive cardiovascular effects as well as associated gene changes. The other two studies received a
(++) for strength because of observed severe changes in heart rate but at concentrations associated with
other toxicities (Hassoun et al.. 2005) or because only a single, elevated dose was used (Williams et al..
2006). The overall summary score for zebrafish embryo studies was (+). The overall summary score for
mechanistic studies across all species and study designs was (++) due to consistent positive outcomes
observed in all study types. The WOE from mechanistic studies therefore provides stronger positive
evidence of an association between TCE exposure and congenital cardiac defects.

Table Apx G-10. Weight-of-Evidence Table for Mechanistic Studies

Evidence Area

Reliability

Strength

Relevance

Overall Grade

MAMMALIAN CELLS/TISSUE

TCE

(Saillenfait et al.. 1995)

++



+/++



(Collier etal.. 2003)

++

+

+

+

(Selmin et al.. 2008)

++

+

+

+

(Caldwell et al.. 2008)

++

+

+

+

(Ouetal.. 2003)

+++

++

+

+

(Jians et al.. 2015)

+++

++

+

+

(Dow and Green. 2000)

0/+

+

+/++

0/+

(Green et al.. 2004)

++

+

+/++

+

METABOLITES (TCA, DCA, Trichloroethanol, Chloral)

(Saillenfait et al.. 1995)

++



+/++



(Collieretal.. 2003)

++

+

+/++

+

(Hunter et al.. 1996)

++

++

+/++

+

(Selmin et al.. 2008)

++

+

+

+

(Dow and Green. 2000)

++

+

+

+

Integrated Area Scores

++

+

+



Summary Score (all mammalian tissue studies)

+

CHICK EMBRYO

TCE

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Evidence Area

Reliability

Strength

Relevance

Overall Grade

(Loeber et al.. 1988)

+/++

++

+

+

(Bover et al.. 2000)

++

+

+

+

(Mishima et al.. 2006)

++

+

+

+

(Drake et al.. 2006a)

++

+

+

+

(Drake et al.. 2006b)

++

0

+

0

(Rufer et al.. 2010)

++

++

+

+

(Makwana et al.. 2010)

++

+

+

+

(Makwana et al.. 2013)

++

+

+

+

METABOLITES (TCA)

(Harris et al.. 2018)

++

+

+

+

(Drake et al.. 2006a)

++

+

+

+

(Drake et al.. 2006b)

++

0

+

0

Integrated Area Scores

++

+

+



Summary Score (all chick studies)

++

ZEBRAFISH EMBRYO

TCE

(Wirbiskv et al.. 2016)

+++

+++

+

+

METABOLITES (DCA)

(Hassoun et al.. 2005)

+++

++

+

+

(Williams et al.. 2006)

++

++

+

+

Integrated Area Scores

+++

++/+++

+



Summary Score (all zebrafish studies)

+

Integrated Area Scores
(all mechanistic studies)

+++

+/++

+



Summary Score (all mechanistic studies)

++

Possible scores for reliability and relevance were 0, +,
Possible scores for strength and overall weight were -
strongly negative to ambiguous to strongly positive.

++, or +++, with ranges inbetween, for unusable, low, medium and high.
-, —, -, 0, +, ++, or +++, with ranges inbetween, for results ranging from

1095

1096	In summary, the database contains a large and diverse set of studies pertinent to assessing congenital

1097	heart defects from TCE exposure (overall relevance was rated as ++). Well-designed, conducted and

1098	reported studies were located for all categories, although the epidemiology studies were limited to

1099	ecological or case-control study designs with high potential for misclassification of exposure and the

1100	many of the in vivo animal studies contained at least one major limitation (overall reliability rating of

1101	+/++). The integrated strength area score was (+), indicating a suggestive positive association of TCE

1102	with congenital cardiac defects. The epidemiology studies as a group provide suggestive evidence for an

1103	effect of TCE on cardiac defects in humans (summary score of +). Oral in vivo studies provided

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1104	ambiguous to weakly positive (0/+) results for TCE itself, but positive results for its TCA and DC A

1105	metabolites (+), while inhalation studies contributed negative evidence (-). Mechanistic studies provided

1106	solid, consistent supporting information for effects of TCE and metabolites on cardiac development and

1107	precursor effects (summary score of ++). Overall, the database is both reliable and relevant and

1108	provides positive overall evidence that TCE may produce cardiac defects in humans (based on positive

1109	evidence from epidemiology studies, mixed evidence from animal toxicity studies, and stronger positive

1110	evidence from mechanistic studies).

1111

1112	Table Apx G-ll. Overall Weight-of-Evidence Table and Summary Scores	



Evidence Area

Reliability

Strength

Relevance

Summary
Score

Epidemiology studies

+

+

++

+

In vivo animal toxicity studies

+/++

0/+

+/++

0

Mechanistic studies

+++

+/++

+

++

Integrated Area Scores

++

+

++

+

Possible scores for reliability and relevance were 0, +, ++, or +++, with ranges inbetween, for unusable, low, medium and high.
Possible scores for strength and overall weight were —, —, -, 0, +, ++, or +++, with ranges inbetween, for results ranging from
strongly negative to ambiguous to strongly positive.

1113

1114

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1115	Appendix H META-ANALYSIS FOR CANCER

1116	H.1 Study Screening and Selection

1117	All epidemiologic studies included in the U.S. EPA 2011 IRIS assessment of TCE (Appendix C, (

1118	) were considered to be informative and carried forward for meta-analysis. Informative

1119	epidemiologic studies of non-Hodgkin lymphoma (NHL), kidney cancer or liver cancer and exposure to

1120	TCE published since the 2011 IRIS assessment were identified through a systematic literature search.

1121	Studies examining only other cancer types were excluded from consideration.

1122	H.l.l Data Quality and Inclusion/Exclusion Criteria Screening

1123	Relevant studies were evaluated for data quality and were additionally screened through

1124	inclusion/exclusion criteria developed based on the criteria established in the 2011 IRIS assessment

1125	(Appendix C, (U.S. EPA. 201 lb)), as described in TableApx H-l. Results of this criteria screening are

1126	presented in

1127	Table Apx H-2.

1128

1129	Table Apx H-l. Meta-Analysis Inclusion/Exclusion Criteria for Considering Cancer Studies

1130	Identified in EPA's Literature Search

Inclusion ( l ileriit

Kxclusion C i ilci iit

Study Design

Cohort and case control studies.

Geographic-based, ecological, or proportionate mortality ratio
(PMR) study design.

Participant Selection

Adequate selection in cohort studies of exposure and
control groups and of cases and controls in case-control
studies.

Inadequate selection in cohort studies (exposed and control
groups were not similar, and differences were not controlled
for in the statistical analysis). Controls were drawn from a
very dissimilar population than cases or recruited within very
different time frames (case control studies).

Exposure

TCE exposure potential inferred to each subject and
quantitative assessment of TCE exposure for each
subject by reference to industrial hygiene records
indicating a high probability of TCE use, individual
biomarkers, job exposure matrices (JEMs), water
distribution models, or obtained from subjects using
questionnaire (case-control studies).

TCE exposure potential not assigned to individual subjects
using JEM, individual biomarkers, water distribution models,
or industrial hygiene data indicating a high probability of TCE
use (cohort studies).

Reports as least 2 levels of exposure (e.g.,
exposed/unexposed).

The range and distribution of exposure are not adequate to
determine an exposure-response relationship. No description is
provided on the levels or range of exposure.

Outcome Assessment

Evaluation of incidence or mortality from kidney cancer,
liver cancer, or NHL. RR estimates and corresponding
CIs (or information to allow calculation).

Data for non-cancer health outcomes or incidence or mortality
reported for cancers other than kidney, liver, or NHL. All
hemato- and lymphopoietic cancer reported as broad category.

Statistical Power (sensitivity)

The number of participants or cases and controls are
adequate to detect an effect in the exposed population
and/or subgroups of the total population.

The number of participants or cases and controls are inadequate
to detect an effect in the exposed population and/or subgroups
of the total population.

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1131

1132	TableApx H-2. Screening Results of Cancer Studies Identified in EPA's Literature Search Based

1133	on Inclusion/Exclusion Criteria

Studies recommended for inclusion in quantitative meta-analvsis:

Studies

Primary reason(s)

(Bove et al.. 2014a)
(Bove et al.. 2014b)
(Buhaeen et al.. 2016)
(Christensen et al.. 2013)
(Cocco et al.. 2013)
(Hansen et al.. 2013)
(Limvorth et al.. 2011)
(Purdue et al.. 2016)
(Silver et al.. 2014)
(Vlaanderen et al.. 2013)

Analytical study designs of cohort or case-control; evaluation
of incidence or mortality; adequate selection in cohort studies
of exposure and control groups and of cases and controls in
case-control studies; TCE exposure potential inferred to each
subject and quantitative assessment of TCE exposure
assessment for each subject by reference to industrial hygiene
records indicating a high probability of TCE use, individual
biomarkers, JEMs, water distribution models, or obtained from
subjects using questionnaire (case-control studies); RR
estimates for kidney cancer, liver cancer, or NHL with
confidence intervals

Studies NOT recommended for inclusion in Quantitative meta-analysis:

Studies

Primary reason(s)

(Alanee et al.. 2015)

Weakness with respect to analytical study design (i.e.,
geograpliic-based, ecological orPMR design).

(Alanee et al.. 2015)

TCE exposure potential not assigned to individual subjects
using JEM, individual biomarkers, water distribution models,
or industrial hygiene data from other process indicating a high
probability of TCE use (cohort studies).

(Bassis et al.. 2016)
(Ruckart et al.. 2013)

Examined noncancer health outcomes or cancer incidence or
mortality for cancers other than kidney, liver, or NHL. All
hemato- and lymphopoietic cancer reported as broad category.

(Bahretal.. 2011)

EPA reviewer scored the study as Unacceptable (Rationale:
Repeated examples of poor quality, study design and execution
and ignorance of potential biases that went umnentioned even
in the discussion indicate inexperience and poor quality
control).

1134	H.1.2 Screening results

1135	Data quality and inclusion/exclusion criteria screening identified ten studies suitable for use in meta-

1136	analysis. Of these, there were nine new studies with suitable informative data on the association of

1137	exposure to TCE and NHL (Bove et al.. 2014a; Bove et al.. 2014b; Christensen et al.. 2013; Cocco et al..

1138	2013; Hansen et al.. 2013; Lipworth et al.. 2011; Purdue et al.. 2016; Silver et al.. 2014; Vlaanderen et

1139	al.. 2013). eight new studies with informative data for kidney cancer (Bove et al.. 2014a; Buhagen et al..

1140	2016; Christensen et al.. 2013; Hansen et al.. 2013; Lipworth et al.. 2011; Purdue et al.. 2016; Silver et

1141	al.. 2014; Vlaanderen et al.. 2013). and six new studies with informative data for liver cancer (Bove et

1142	al.. 2014a; Christensen et al.. 2013; Hansen et al.. 2013; Lipworth et al.. 2011; Silver et al.. 2014;

1143	Vlaanderen et al.. 2013). All of these studies scored Acceptable for data quality except (Bahr et al..

1144	2011). which was excluded for scoring Unacceptable. Every study scored at least a Medium except for

1145	(Buhagen et al.. 2016). which scored a Low but was recommended for inclusion by inclusion/exclusion

1146	criteria. The respective data quality scores were considered in sensitivity analyses of the meta-analyses

1147	results (see Appendix H.2.2.2).

1148

1149	All studies from the 2011 IRIS meta-analysis were Acceptable in data quality and scored at least a

1150	Medium. Therefore, data from the ten new studies that passed the criteria screening were extracted along

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1159

1160

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with results from previous studies identified in the 2011 IRIS assessment (U.S. EPA. 201 le). When
more than one report was available for a single study population, only the most recent publication or the
publication reporting the most informative data for TCE was selected for inclusion in the meta-analysis
(see TableApx H-3). This resulted in a smaller set of data included in the meta-analysis as compared to
the total list of studies.

H.1.3 Pooled Cohorts

Two of the new papers pooled data from earlier studies included in the 2011 IRIS meta-analysis.

(Hansen et al.. 2013) pooled and updated three Nordic national cohort studies of workers biologically
monitored for exposure to TCE (Anttila et al.. 1995; Axelson et al.. 1994; Hansen et al.. 2001).

Similarly, (Cocco et al.. 2013) pooled earlier case-control studies of NHL including (Cocco et al.. 2010).
(Miligi et al.. 2006). and (Purdue et al.. 2011). Two other new studies provided updated data on
populations included in the U.S. EPA 2011 IRIS assessment: (Lipworth et al.. 2011) updated a cohort
study of aircraft workers (Boice et al.. 1999) and (Christensen et al.. 2013) updated an earlier
population-based case-control study (Siemiatvcki. 1991). After removing these overlapping and
superseded studies, a total of 18 studies of NHL, 18 studies of kidney cancer, and 11 studies of liver
cancer were available for meta-analysis.

Among the included studies, up to about 800 of the approximately 40,000 Danish workers studied by
(Raaschou-Nielsen et al.. 2003) may have also been included in the Nordic pooled study of 5553
biomonitored workers (Hansen et al.. 2013). However, both studies were retained in the analysis because
any overlap would have been minor. There was also minor overlap between the cohorts studied by
(Zhao et al.. 2005) and (Boice et al.. 2006). but those papers reported data for different outcomes. These
results are summarized in Table Apx H-3.

Table Apx H-3. Cancer Studies Covering the Same Cohort as Previous Studies from either the
2011 IRIS Assessment or EPA Literature Search

Study reviewed

Other assessed studies with participants from the same cohort

2011 IRIS Assessment

(Anttila et al.. 1995) (Finland onlv)

Included in (Hansen et al.. 2013)

(Axelson et al.. 1994) (Sweden onlv)

Included in (Hansen et al.. 2013)

(Boice et al.. 1999)

Undated in (Limvorth et al.. 2011)

(Boice et al.. 2006)

(Zhao et al.. 2005) (partial)

(Briinine et al.. 2003)

None

(Charbotel et al.. 2006)

None

(Cocco et al.. 2010)

Included in (Cocco et al.. 2013)

(Dosemeci et al.. 1999)

None

(Greenland et al.. 1994)

None

(Hansen et al.. 2001) (Denmark onlv)

(Raaschou-Nielsen et al.. 2003) (partial): Included in (Hansen et al.. 2013)

(Hardell et al.. 1994)

None

(Miliei et al.. 2006)

Included in (Cocco et al.. 2013)

(Moore et al.. 2010)

None

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1179

1180

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1182

1183

1184

1185

1186

1187

1188

1189

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Study reviewed

Other assessed studies with participants from the same cohort

(Morean et al.. 1998)

None

(Nordstrom et al.. 1998)

None

(Persson and Fredrikson. 1999)

None

(Peschet al.. 2000)

None

(Purdue et al.. 2011)

Included in (Cocco et al.. 2013)

(Raaschou-Nielsen et al.. 2003)

Partial overlap with (Hansen et al.. 2001)

(Radican et al.. 2008)

None

(Siemiatvcki. 1991)

Undated in (Christensen et al.. 2013)

(Wans et al.. 2009)

None

(Zhao et al.. 2005)

(Boice et al.. 2006) (partial)

New Studies Identified in EPA Literature Search

(Bove et al.. 2014a)

None

(Bove et al.. 2014b)

None

(Buhaeen et al.. 2016)

None

(Cocco et al.. 2013)

(Cocco et al.. 2010); (Miliei et al.. 2006); (Purdue et al.. 2011)

(Christensen et al.. 2013)

(Siemiatvcki. 1991)

(Hansen et al.. 2013)

(Hansen et al.. 2001); (Anttila et al.. 1995); (Raaschou-Nielsen et al.. 2003)
(partial)

(Limvorth et al.. 2011)

(Boice et al.. 1999)

(Purdue et al.. 2016)

None

(Silver et al.. 2014)

None

(Vlaanderen et al.. 2013)

None

H.2 Meta-Analysis Methods and Results

H.2.1 Methods
Data abstraction

Data for each pertinent study identified, including measures of the association (including rate ratio (RR),
odds ratio (OR), hazard ratio (HR), etc.) of each cancer of interest with exposure to TCE, their
confidence intervals (CI) and if reasonably available, standard errors, identification of the type of
measure (RR, OR, etc), the study design and the exposure metric (ever/never exposed, cumulative
exposure, duration of exposure, etc.) were abstracted for meta-analysis. All types of epidemiologic ratio
measures of association, including RR, OR, HR and standardized mortality or incidence ratios (SMR,
SIR), were considered to be equivalent and are collectively referred to below as RRs. The preferred
estimates of association for meta-analysis were based on contrasts within the study population and were
either 1) comparisons of groups exposed and not exposed to perchloroethylene or 2) comparisons of
groups with the highest and lowest level of exposure to perchloroethylene, in that order. For NHL,
estimates of association for the most highly exposed group were also abstracted, when they were
reasonably available. For each comparison, the most fully adjusted risk estimate was selected.

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Estimates of association based on cumulative exposure were preferred to those based on other exposure
metrics.

Data for studies included in the U.S. EPA 2011 IRIS assessment (I v < < \ IVI I were abstracted
from tables in Appendix C of that assessment. The measures of association, confidence limits and
estimates of SE listed in those tables were utilized for consistency with the previous assessment.

For newer studies not included in the IRIS assessment, log-relative risks and their standard errors were
estimated from the extracted data; the data for the newer studies are provided in tables in Section H.2.3.
If the standard error (SE) of RR was reported in the publication, the standard error of ln(RR) was taken
as ln(SE). If SE was not reported and the CI was reasonably symmetric around the point estimate (< 5%
difference between upper and lower half CI), it was approximated as (ln(upper bound CI)-ln(lower
bound CI))/3.92. Different approaches in the event of more substantial CI asymmetry. If the measure
of RR was a SMR or SIR, SE was approximated by (1/0)1/2, where O is the observed number of cases
(Greenland & O'Rourke, 2008). If RR was 1 or >1, SE was estimated from the upper half CI, as
(ln(upper bound CI) - ln(RR))/l .96. For RR < 1, SE was estimated from the lower half CI in an
equivalent manner. Despite these varying approaches, differences in the method of estimating SE are
unlikely to substantially affect the point estimate or CI of a meta-RR.

Data analysis

Meta-analyses were performed using the metan procedure in Stata (Stata Corp, College Station TX).
The metan procedure also provides options for utilizing a user-provided estimate of SE or estimating SE
from input confidence intervals assuming approximate symmetry.

For each cancer type of interest, the initial analysis included all of the selected studies in a fixed-effects
model. Models were specified using the logs of RR and SE as input parameters, allowing the software
to estimate study-specific and overall 95% CIs. Heterogeneity was assessed using the I2 statistic
(Biggins et al. 2003) and visual inspection of the plots. If no important heterogeneity was indicated, the
fixed-effects meta-estimate was taken as the measure of overall association. Fixed effects models are
preferred for this purpose, as they are generally unbiased (Poole and Greenland! I ^ V). Where notable
heterogeneity was indicated, a random-effects model using the DerSimonian-Laird estimators was
applied to estimate the overall association. EPA's preferred approach is to estimate SE according to the
methods described above. With this procedure, the study-specific CIs displayed on forest plots were
estimated by the software and may differ slightly from those reported in the original publications.

The influence of individual studies was assessed in a "leave one out" meta-analysis using the metaninf
procedure in Stata. Each study was omitted in turn and the meta-estimate was re-calculated without that
study to gauge its effect on the overall association. Meta-analyses stratified by the quality score
assigned in the initial reviewer were carried out to assess whether effects differed in high versus
medium- or low-quality studies.

The potential for publication bias was assessed by visual inspection of funnel plots.

Sample Stata commands are provided in Section H.2.4.

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H.2.2 Results

H.2.2.1 Initial Meta-Analyses
Non-Hodgkin lymphoma

In the fixed-effects model for NHL (Figure Apx H-l), the meta-RR for overall exposure to TCE was
1.02 (95% CI 0.97-1.08) with moderate heterogeneity between studies (I2 38.4%, p 0.05). The large
study by Vlaanderen et al. (2013) was heavily weighted in the fixed-effects model. Fitting a random-
effects model (Figure Apx H-2) to the same set of studies reduced the weight of the (Vlaanderen et al..
2013) study and gave a meta-estimate of 1.14 (95% CI 1.00-1.30).

In the 2011 TCE meta-analysis of NHL, there was some indication of heterogeneity (I2-value was 26%,
suggesting low-to-moderate heterogeneity). Little to no heterogeneity was found for kidney or renal
cancers. Additional analyses focused on the studies with the highest exposure, because if TCE exposure
increases the risk of NHL, the effects should be more apparent in the highest exposure groups. Analysis
showed that the summary effect estimate of the highest exposed groups was stronger, a finding that lent
support to the conclusion that TCE exposure increased the risk of NHL. Since moderate heterogeneity
(greater than in 2011) was identified for the overall set of studies, EPA additionally analyzed results
from populations identified as receiving "high exposure" to TCE in order to parallel the analyses
performed in the 2011 IRIS Assessment. Fixed- and random-effects models comparing the highest to
lowest exposure groups in each study also weighted the (Vlaanderen et al.. 2013) study heavily and
produced meta-RRs of 1.03 (95% CI 0.93-1.15) and 1.33 (95% CI 0.98-1.80), respectively (Figure_Apx
H-3 and Figure Apx H-4). Extracted RR estimates and confidence intervals from each NHL study are
presented in TableApx H-7, TableApx H-8, and TableApx H-9.

Figure Apx H-l. Fixed-effects model, overall association of NHL and exposure to TCE.

Study
ID

RR (95% CI)

%

Weight

Bove 2014a
Bove 2014b
Hansen 2013
Lipworth 2011
Silver 2014
Vlaanderen 2013
Christensen 2013
Cocco 2013
Greenland 1994
Morgan 1998
Raaschou-Nielsen 2003
Radican 2008
Zhao 2005
Hardell 1994
Nordstrom 1998
Persson 1999
Purdue_2011
Wang_2009

Overall {l-squared = 38.5%, p = 0.049)

1,15(0,56,

2.38)

0.63

0.33 (0.14t

0.80)

0.43

1.21 (0.85,

1.72)

2.66

1.02(0.54,

1.91)

0.84

0,87 (0,56,

1.34)

1.78

0.97(0.91,

1.04)

74.48

1.20(0.37,

3.89)

0.24

1.40(0,97,

2.04)

2.38

0.76 (0.24,

2.42)

0.25

1.01 (0,53,

1.94)

0.78

1.24 (1.01,

1.52)

7.96

1.36 (0.77,

2.40)

1.03

1.44 (0.90,

2.30)

1.51

- 7.17(1.26,

40.79)

0.11

1.50(0.69,

3.26)

0.55

1.20 (0.55,

2.63)

0.54

1.40(0.81,

2.42)

1.10

1.20 (0.85,

1.70)

2.75

1.02(0.97,

1.09)

100.00

~1~
10

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FigureApx H-2. Random-effects model, overall association of NHL and exposure to TCE.

1265

1266

1267

Study
ID

Bove 2014a
Bove 2014b
Hansen 2013
Lipworth 2011
Silver 2014
Vlaanderen 2013
Christensen 2013
Cocco 2013
Greenland 1994
Morgan 1998
Raaschou-Nielsen 2003
Radican 2008
Zhao 2005
Hardell 1994
Nordstrom 1998
Persson 1999
Purdue_2011
Wang_2009

Overall (l-squared = 38.5%, p = 0.049)

NOTE: Weights are from random effects analysis

	1	T"

.1 .2

RR (95% CI)

%

Weight

1.15(0.56,

2.38)

2.84

0.33 (0.14,

0.80)

2.01

1.21 (0.85,

1.72)

8.40

1.02 (0.54.

1.91)

3.64

0.87 (0.56,

1.34)

6.46

0.97 (0.91,

1.04)

20.23

1.20 (0.37.

3.89)

1.18

1.40 (0.97,

2.04)

7.86

0.76 (0.24,

2.42)

1.22

1.01 (0.53,

1.94)

3.40

1.24 (1.01,

1.52)

14.09

1.36 (0.77,

2.40)

4.29

1.44 (0.90,

2.30)

5.74

- 7.17(1.26,

40.79)

0.56

1.50 (0.69,

3.26)

2.52

1.20 (0.55,

2.63)

2.48

1.40 (0.81,

2.42)

4.51

1.20 (0.85,

1.70)

8.57

1.14(1.00,

1.30)

100.00

Figure Apx H-3. Fixed-effects model, association of NHL and high exposure to TCE.

Study
ID

Hansen 2013
Vlaander«n 2013
Chiislenaen 2013
Cocco 2013

Morgan 1998	—

naaschou-Nielseri 2003

Radican 2008

Zhao 2005

Purdue 2011

Wang_2009

Owall 

3.30(1.09.10.01)

0.90



2.20 (
1.0® (

0.90. 5,39)
0.93,1.15)

1.38
100,00

1268

1269

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FigureApx H-4. Random-effects model, association of NHL and high exposure to TCE.

Sludy
10

Weight

Hansen 2013
Vlaanderen 2013
Chrtstenseo 2013
COCCO2013

Mwgan 1998	-

ftaaschou-f^elsen 2003

Radican 2000

Zhao 2005

Purdue 2011

Wang_2009

Overall (l-squared = 50.7%, p = 0.032)

NOTE: Weights are irom random effects analysis

	1	

o



0.66 <0.25,1.75)

7.12



0.95 (0.85,1.07)

26.85



1.00 (0.29, 3.44)

4.95



2.20 (0 71,6 87)

566



0.81 (0.10, 6.47)

1.97



1.60(1.12, 2.29)

20.08



1,40 (0.71,2.78)

11.48



1.30 (0.52, 3.24)

7.89



3.30(1.00,10.01)

5.68



2.20 (0.90, 5.39)

8.11



1.33 (0.98, 1.00)

100.00

Kidney Cancer

For kidney cancer, the fixed effects model (Figure Apx H-5) gave a meta-RR of 1.06 (95% CI 1.00-
1.11) for overall exposure, with moderate, statistically-significant heterogeneity (I2 41.1%, p 0.04). As
for NHL, the study of (Vlaanderen et al.. 2013) was heavily weighted. In the random-effects model
(Figure Apx H-6), the meta-RR was 1.22 (95% CI 1.07-1.38). Extracted RR estimates and confidence
intervals from each kidney cancer study are presented in TableApx H-10 and TableApx H-l 1.

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FigureApx 11-5. Fixed-effects model, overall association of kidney cancer and

exposure to TCE.

Study
ID

Bove 2014a
Buhagen 2016
Hansen 2013
Llpworth 2011
Silver 2014
Vlaanderen 2013
Chrislensen 2013
Purdue 2016
Greenland 1994
Morgan 1998
Radican 2008
Zhao 2005
Bruning 2003
Charbotel 2006
Dosemeci 1999
Moore 2010
Pesch 2000

Raaschou-Nlelsen 2003

Overall (l-squared = 41.1%, p = 0,036)



%

RR {95% CI)

Weight

1.52 (0.64, 3.60)

0.35

1.70 (0.94, 3.06)

0.76

1.04 (0.73, 1.48)

2.11

0.85 (0.33, 2.18)

0.30

1.24(0.87, 1.76)

2.11

1.00 (0.94, 1.06)

75,79

0.90 (0.36, 2.21)

0.32

0.80 (0.41, 1.56)

0.59

0.99 (0.30, 3.29)

0.18

1.14(0.51,2.58)

0.40

1.18(0.47, 2.95)

0.31

1.72 (0.38, 7.85)

0.11

2.47 (1.36, 4.49)

0.73

1.88 (0.89, 3.97)

0.47

1.30(0.89, 1.89)

1.87

2.05(1.13, 3.73)

0.73

1.24(1.03, 1.49)

7.72

1.20 (0.96,1.50)

5.16

1.06 (1.00,1.11)

100.00

Figure Apx H-6. Random-effects model, overall association of kidney cancer and

exposure to TCE.

Study
ID

Bove 2014a
Buhagen 2016
Hansen 2013

Lipworth 2011		

Silver 2014
Vlaanderen 2013

Chrislensen 2013		

Purdue 2016		

Greenland 1994		

Morgan 1998	—

Radican 2008	—

Zhao 2005		

BrQnlng 2003

Charboiel 2006

Dosemeci 1999

Mooce 2010

Pesch 2000

Raaschou-Nielsen 203

Overall {l-squared = 41.1 %, p = 0.036)

NOTE: Weights are from random effects analysis



~r

o



%

RR (95% CI)

Weight

1,52 (0.64, 3.60)

1.97

1.70 (0.94, 3.06)

3.83

1.04 (0.73,1.48)

8.09

0,85 (0.33, 2.18)

1.68

1,24(0,87,1.76)

8.09

1.00(0.94,1.06)

20,59

0,90(0,36, 2.21)

1.82

0,80(0.41,1.56)

3.11

0.99 (0,30, 3.29)

1.06

1.14(0.51,2,58)

2.19

1.18(0.47, 2.95)

1.76

1.72 (0,38, 7.85)

0.68

2.47 (1,36, 4.49)

3.73

1.88 (0,89, 3.97)

2.54

1,30(0,89, 1.89)

7.50

2.05 (1.13, 3.73)

3.73

1,24(1,03, 1.49)

14.82

1.20(0.96,1.50)

12.83

1.22 (1.07,1.38)

100.00

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Liver cancer

Fixed- and random-effects models for liver cancer showed a similar pattern of results, with meta-RRs of
1.08 (95% CI 0.99-1.18) and 1.18 (95% CI 0.98-1.43), respectively (Figure_Apx H-7 and Figure_Apx
H-8). Heterogeneity was moderate and not statistically significant (I2 36.5%, p 0.107). Extracted RR
estimates and confidence intervals from each liver cancer study are presented in TableApx H-12 and
TableApx H-13.

Figure Apx H-7. Fixed-effects model, overall association of liver cancer and

exposure to TCE.

Weight

Bove 2014a
Hansen 2013
Llpworth 2011
Sliver 2014
Vlaandefen 2013
Chrisiensen 2013
Bo*cc 2006

Greenland 1994	—

Morgan 1998

Radican 2008

Raaschou-Nialsen 2003

Overall (l-squared = 36.5%, p = 0.107)

o

0.66 (0.37, 2.00)
1.83 (1,29, 2,69)
0.83(0,36,1.92)
0.99(0.50,1.97)
1.00(0.90,1.11)
1.10(0.13, 9.50)
1.2B (0.48, 3.41)
0.54 (0.11, 2.64)
1.48(0.56, 3.91)
1.12(0.57, 2.19)
1.35(1.04,1.75)
1.08 (0.99,1.18)

1,15

6.79

1.15

1.74

72.94

0.18

0.85

0.32

0.87

1.81

12.21

100.00

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FigureApx H-8. Random-effects model, overall association of liver cancer and

exposure to TCE.

Bove 20i4a
Hansen 2013
Llpworth 2011

Sliver 2014
Vlaanderen 2013

Chnslensen 2013		

Boco 2006

Greenland 1994		

Morgan 1998

Radican 2008

Raaschou-Nielsan 2003

Overall (l-squared = 36.5%, p = 0.107)

NOTE; Weights are from random effects analysis

$

RR {95% CI)

%

Weight

0.86 (0.37, 2.00)

4.49

1.83 (1.29, 2.59)

16.23

0.83(0.36, 1.92)

4.49

0.99(0.50,1.97)

6.35

1.00(0.90,1.11)

31.50

- 1.10(0.13,9,50)

0.77

1.28(0.46, 3.41)

3.43

0.54(0.11,2.64)

1.39

1.48(0.56. 3.91)

3.50

1.12(0.57, 2.19)

6.57

1.35 (1.04,1.75)

21.28

1.18(0.98,1.43)

100.00

1307

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1309	H.2.2.2 Sensitivity analyses

1310	Removal of Vlaanderen et al. (2013)

1311	In analyses of influential observations, the study of (Vlaanderen et al.. 2013) strongly influenced the

1312	meta-RRs for all three cancers (TableApx H-4, TableApx H-5, and TableApx H-6). No other single

1313	study had an appreciable impact on the overall association. Further meta-analyses were conducted to

1314	characterize the sensitivity of the results to the influence of that study.

1315

	Table Apx H-4. Analysis of influential studies: NHL	

Study omitted

Estimate

95% CI



Bove et al. 2014a

1.02

0.97

1.08

Bove et al. 2014b

1.03

0.97

1.09

Hansen et al. 2013

1.02

0.96

1.08

Lipworth et al. 2011

1.02

0.97

1.09

Silver et al. 2014

1.03

0.97

1.09

Vlaanderen et al. 2013

1.20

1.07

1.34

Christensen et al. 2013

1.02

0.97

1.08

Cocco et al. 2013

1.02

0.96

1.08

Greenland et al. 1994

1.02

0.97

1.09

Morgan etal. 1998

1.02

0.97

1.09

Raaschou-Nielsen 2003

1.01

0.95

1.07

Radican et al. 2008

1.02

0.96

1.08

Zhao et al. 2005

1.02

0.96

1.08

Hardelletal. 1994

1.02

0.96

1.08

Nordstrom et al. 1998

1.02

0.96

1.08

Persson and Fredrikson 1999

1.02

0.97

1.08

Purdue etal. 2011

1.02

0.96

1.08

Wang et al. 2009

1.02

0.96

1.08

Table Apx H-5. Analysis of influential studies: Kidney cancer

Study omitted

Estimate

95% CI



Bove et al. 2014a

1.06

1.00

1.11

Buhagen et al. 2016

1.05

1.00

1.11

Hansen et al. 2013

1.06

1.00

1.11

Lipworth et al. 2011

1.06

1.01

1.11

Silver et al. 2014

1.05

1.00

1.11

Vlaanderen et al. 2013

1.26

1.14

1.40

Christensen et al. 2013

1.06

1.01

1.11

Purdue et al. 2016

1.06

1.01

1.12

Greenland et al. 1994

1.06

1.00

1.11

Morgan etal. 1998

1.06

1.00

1.11

Radican et al. 2008

1.06

1.00

1.11

Zhao et al. 2005

1.06

1.00

1.11

Briining et al. 2003

1.05

1.00

1.11

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Table Apx H-5. Analysis of influential studies: Kidney cancer

Study omitted

Estimate

95% CI



Charbotel et al. 2006

1.05

1.00

1.11

Dosemeci et al. 1999

1.05

1.00

1.11

Moore et al. 2010

1.05

1.00

1.11

Pesch et al. 2000

1.04

0.99

1.10

Raaschou-Nielsen et al.







2003

1.05

1.00

1.11

Table Apx H-6. Analysis of influential studies: Liver cancer

Study omitted

Estimate

95% CI



Bove et al. 2014a

1.09

0.99

1.19

Hansen et al. 2013

1.04

0.95

1.14

Lipworth et al. 2011

1.09

0.99

1.19

Silver et al. 2014

1.08

0.99

1.19

Vlaanderen et al. 2013

1.34

1.13

1.59

Christensen et al. 2013

1.08

0.99

1.18

Boice et al. 2006

1.08

0.99

1.18

Greenland et al. 1994

1.08

0.99

1.19

Morgan etal. 1998

1.08

0.99

1.18

Radican et al. 2008

1.08

0.99

1.19

Raaschou-Nielsen et al.







2003

1.05

0.95

1.16

Meta-RRs for each cancer were re-estimated by omitting that study from the fixed-effects model. For
NHL, omitting the study of (Vlaanderen et ai. 2013) from the analysis of overall exposure to TCE
(Figure_Apx H-9) substantially reduced between-study heterogeneity (I2 9.7%, p 0.34) and yielded a
meta-RR of 1.20 (95% CI 1.07-1.34). In the model for NHL using only the high exposure groups
(FigureApx H-10), no heterogeneity remained when the (Vlaanderen et ai. 2013) study was omitted (I2
0.0%), p 0.56); the meta-RR for high exposure was 1.53 (95% CI 1.19-1.97). Omitting the study of
(Vlaanderen et ai. 2013) from the model for kidney cancer (Figure Apx H-l 1), gave a meta-RR of 1.26
(95% CI 1.14-1.40) with no indication of heterogeneity (I2 0.0%, p 0.57). Dropping that study from the
analysis of liver cancer (

Figure_Apx H-12) similarly eliminated the heterogeneity among studies (I2 0.0%, p 0.56) and gave a
meta-RR of 1.34 (95% CI 1.13-1.59). Meta-RR values for all three tissues increased without the
(Vlaanderen et ai. 2013) study and achieved statistical significance.

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FigureApx H-9. Fixed-effects model, overall association of NHL and exposure to TCE, study of

Vlaanderen et al. (2013) omitted.

Study
ID

Bove 2014a
Bove 2014b
Hansen 2013
Lipworth 2011
Silver 2014
Christensen 2013
Cocco 2013
Greenland 1994
Morgan 1996
Raaschou-Nielsen 2003
Radlcan 2006
Zhao 2005
HarcJell 1994
Nordstrom 1993
Persson 1999
Purdue_2011
Wang_2009

Overall {l-squared = 9,7%, p = 0.340)



%

RR (95% CI)

Weight

1.15 {0.56, 2.38)

2.46

0.33 {0.14, 0.80)

1.67

1.21 {0.85,1.72)

10.41

1.02 {0.54,1.91)

3.29

0.87 {0.56, 1.34)

6.97

1.00 {0.31, 3.24)

0.94

1.40 {0.97, 2.04)

9.35

0,76 {0.24, 2.42)

0.97

1.01 {0.53, 1.94)

3.04

1.24 {1.01, 1.52)

31.19

1,36 {0.77,2.40)

4.04

1.44 {0.90, 2.30)

5.91

— 7.17 {1.26, 40.79}

0.43

1.50 {0.69, 3.26)

2,15

1.20 {0.55, 2.63)

2.11

1,40 {0.81,2.42)

4.30

1.20 {0.85,1.70)

10.77

1.20 {1.07,1.34)

100.00

~~r~

10

Figure Apx H-10. Fixed-effects model, association of NHL and high exposure to TCE, study of

Vlaanderen et al. (2013) omitted.

Hansen 2013

Ctirisl

Cocco 2013
Morgan 1990
Raaschou-Welsan 2003
Radican 2006
Zhao 2005
Purdue 2011
Wang 2009

Overall (l-squarsd = 0,0%, p = 0.5J



0.68 (0.25,1.76)
1.00 {0.29. 3.44)
2,30 {0.71. 6.67)
0.61 {0.10. 6.47)
1.60 {1.12, 2.29)
1.40 {0.71, 2.78)
1.30(0.52,3.24)
3.30 {1-09.10-01)
2,20 {0,90. &.»)
1.S»{1.19. 1,97)

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FigureApx II-11. Fixed-effects model, overall association of kidney cancer and
exposure to TCE, study of Vlaanderen et al. (2013) omitted.

Study
ID

Bove 2014a
Buhagen 2016
Hansen 2013
Lfpworth 2011
Silver 2014
Christensen 2013
Purdue 2016
Greenland 1994
Morgan 1998
Radican 2008
Zhao 2005
Briining 2003
Charbotef 2006
Dosemed 1999
Moore 2010
Pesch 2000

Raaschou-Nielsen 2003

Overall (I-squared = 0.0%, p = 0,566)

O



%

RR (95% Cf)

Weight

1.52 (0.64,3.60)

1.46

1.70 (0.94,3.06)

3.13

1.04 (0.73, 1.48)

8.69

0.85 (0.33, 2.18)

1.22

1.24 (0.87. 1.76)

8.69

0,90 (0.36, 2.21)

1.33

0.80 (0.41,1,56)

2.44

0.99 (0.30,3.29)

0.75

1.14(0.51,2.58)

1.64

1.18 (0.47,2.95)

1.29

1.72 (0.38, 7.85)

0.47

2.47(1.36, 4.49)

3.03

1.88 (0.89, 3.97)

1.93

1.30 (0.89, 1.89)

7.72

2.05 (1.13, 3.73)

3.03

1.24(1.03, 1.49)

31.88

1.20 (0.96, 1.50)

21.30

1.26(1.14,1.40)

100,00

Figure Apx H-12. Fixed-effects model, overall association of liver cancer and
exposure to TCE, study of Vlaanderen et al. (2013) omitted.

Bova 2014a

Hanson 2013

Lipworth 2011

SHver 2014

Christensen 2013

Bonce 2006

Greenland 1994

Morgan 1996

Radican 2008

Raaschou-Nwlswi 2003

Overall |l*squar«f» 0,0%, p = 0.557)

o

RR <96% CO

%

Weight

0.06 (0.37, 2.00)

4.25

1.03 (1.29, 2.59)

25.09

0.83 (0.36,1.92)

4.25

0.99 (0.50, 1.97)

6.42

- 1.10(0.13,9.50)

0-65

1.28 (0.48, 3.41)

3.14

0.54 (0.11.2.64)

1.20

1.48(0.56, 3.91)

3.21

1.12(0.57, 2.19)

6.68

1.35 (1.04, 1.75)

45.11

1.34 (1.13,1.59)

100.00

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Stratification by Data Quality

Fixed-effects meta-analyses for each cancer were also stratified by the study quality score assigned in
EPA's review to assess whether the strength of association varied between highest- and lower-quality
studies. In this manner, the meta-RR was compared among studies scoring High in data quality to those
scoring Medium or Low. For NHL (Figure Apx H-13), there was no heterogeneity among studies
scored as high quality (I2 0.0%, p 0.78) and the meta-RR was 1.29 (95% CI 1.04-1.59), while among
studies scored medium or low the meta-RR was 1.01 (95% CI 0.95-1.07) with moderate heterogeneity
(I2 40.0%, p 0.06). Studies of kidney cancer (

Figure Apx H-14) that scored high for data quality gave a meta-RR of 1.14 (95% CI 0.85-1.53) with no
indicated heterogeneity (I2 0.0% p 0.45), whereas lower-ranked studies gave a meta-RR of 1.06 (95% CI
1.00-1.11) with significant heterogeneity (I2 50.0% p 0.02). In contrast, moderate, non-significant
heterogeneity (I2 36.0% p 0.21), remained among the three studies of liver cancer (Figure Apx H-15)
scored high for data quality; the meta-RR among those studies was 1.59 (95% CI 1.17-2.16). Lower
scoring studies showed no heterogeneity (I2 0.0% p 0.56) and a meta-RR of 1.04 (95% CI 0.95-1.15).
Fitting a random-effects model reduced the meta-RR for highly scored studies to 1.42 (95% CI 0.88-
2.30) but did not change the estimate for lower-scored studies. For all three tissues, the meta-RR was
greater among the high quality studies compared to medium or low quality studies. Statistical
significance was not always achieved due to the low number of studies scored High, however this
stratification demonstrates stronger associations of cancer with TCE exposure among higher-quality
data.

Figure Apx H-13. Fixed-effects model, overall association of NHL and
exposure to TCE stratified by study quality score.

Study
ID

Medium/Low
Bove 2014a

Bove 2014b		

Silver 2014
Vlaanderen 2013
Christensen 2013

Greenland 1994	—

Morgan 1998

Raaschou-Nielsen 2003

Radican 2008

Hardell 1994

Nordstrom 1998

Persson 1999

Purdue_2011

Wang 2009

Subtotal (l-squared = 40.0%, p = 0.061)
High

Hansen 2013
Lipworth 2011
Cocco 2013
Zhao 2005

Subtotal (l-squared = 0.0%, p = 0.784)

Heterogeneity between groups: p = 0.027
Overall (l-squared = 38.5%, p = 0.049)

RR (95% CI)

%

Weight

1.15(0.56,
0.33(0.14,
0.87 (0.56,
0.97(0.91,
1.20(0.37,
0.76 (0.24,
1.01 (0.53,
1.24(1.01,
1.36 (0.77,
7.17(1.26,
1.50(0.69,
1.20 (0.55,
1,40(0.81,
1.20 (0.85,
1.01 (0.95,

2.38)

0.80)

1.34)

1.04)

3.89)

2.42)

1.94)

1.52)

2.40)

40.79)

3.26)

2.63)

2.42)

1.70)

1.07)

1.21 (0.85, 1.72)
1,02(0.54, 1.91)
1,40(0.97, 2.04)
1.44(0.90, 2.30)
1.29(1.04, 1.59)

0.63

0.43

1.78

74.48

0.24

0.25

0.78

7.96

1.03

0.11

0.55

0.54

1.10

2.75

92.61

2.66
0.84

2.38
1.51

7.39

1,02(0.97,1.09) 100,00

~~r~

10

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FigureApx H-14. Fixed-effects model, overall association of kidney cancer and
exposure to TCE stratified by study quality score.

1388

1389

1390

Study
ID

Medium/Low
Bove 2014a
Buhagen 2016
Silver 2014
Vlaanderen 2013

Christensen 2013	—

Purdue 2016

Greenland 1994		

Morgan 1998
Radican 2008
Bruning 2003
Dosemeci 1999
Moore 2010
Pesch 2000

Raaschou-Nielsen 2003

Subtotal (l-squared = 50.0%, p = 0.017)

High

Hansen 2013

Lip worth 2011	—

Zhao 2005
Charbotel 2006

Subtotal (l-squared = 0.0%, p = 0.453)

Heterogeneity between groups: p = 0.614
Overall (l-squared = 41.1%, p = 0.036)

<>

RR (95% CI)

%

Weight

1.52(0.64, 3.60)
1.70 (0.94, 3.06)
1.24(0.87, 1.76)
1.00 (0.94, 1.06)
0.90 (0.36, 2.21)
0.80(0.41, 1.56)
0.99 (0.30, 3.29)
1.14(0.51,2.58)
1.18(0.47, 2.95)
2.47 (1.36, 4.49)
1.30 (0.89, 1.89)
2.05(1.13, 3.73)
1.24 (1.03, 1.49)
1.20 (0.96, 1.50)
1.06(1.00, 1.11)

0.35

0.76

2.11

75.79

0.32

0.59

0.18

0.40

0.31

0.73

1.87

0.73

7.72

5.16

97.02

1.04 (0.73, 1.48) 2.11
0.85(0.33,2.18) 0.30
1.72 (0 38, 7.85) 0.11
1.88(0.89,3.97) 0.47
1.14(0.85,1.53) 2.98

1.06(1.00, 1.11) 100.00

—r~

10

Figure Apx H-15. Fixed-effects model, overall association of liver cancer and

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1400

1401

1402

1403

1404

1405

1406

1407

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exposure to TCE stratified by study quality score.

Sludy
ID

Medium/Low
Bove 2014a
Silver 2014
Vlaanderen 2013

Christensen 2013		

Greenland 1994		

Morgan 1998

Radican 2008

Raaschou-Nielsen 2003

Subtotal (l-squared = 0.0%, p = 0.557)

High

Hansen 2013
Lipworth 2011
Boice 2006

Sublolal (l-squared = 36.0%, p = 0.209)

Heterogeneity between groups: p = 0.009
Overall (l-squared = 36.5%, p = 0.107)

O

RR (95% CI)

0.86 (0.37, 2.00)
0.99 (0.50,1.97)
1.00 (0.90,1.11)
1.10(0.13. 0.50)
0.54 (0.11,2.64)
1.48(0.56, 3.91)
1.12(0.57, 2.19)
1.35 (1.04. 1.75)
1.04 (0.95, 1.15)

1.83 (1.29, 2.59)
0.83 (0.36. 1.92)
1.28 (0.48, 3.41)
1.59(1.17, 2.16)

Weight

1.15

1.74

72.94

0.18

0,32

0.87

1.81

12.21

91.21

6.79
1.15
0.85
8.79

1.08(0.99,1.18) 100.00

~I
10

Assessment of Publication Bias

Funnel plots can be used to assess publication bias, a systematic error that occurs if statistically significant
studies are more likely to be submitted and published than nonsignificant studies. One feature of publication
bias is that smaller studies tend to have larger effect sizes than larger studies, since smaller studies need
larger effect sizes in order to be statistically significant. To measure this, funnel plots plot standard error (SE)
vs natural log of the RR (LnEst) to compare study size and effect size. If there is no relationship, the studies
should be symmetrically distributed around the summary RR estimate (the vertical line), while publication
bias is indicated by the points veering towards higher RR estimates with increasing SEs (i.e. toward the
lower right).

Funnel plots including all studies (Figure Apx H-16, a-c) were consistent with modest publication bias,
with a possible tendency toward omission of moderate-sized studies with weak or null associations.

With the ("Vlaanderen et al.. 2013) study omitted, however, the plots became more symmetrical,
consistent with an absence of publication bias among the remaining studies (Figure Apx H-16, d-f).

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a.

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

FigureApx H-16. Funnel plots for publication bias.

All studies: a. NHL; b. kidney cancer; c. liver cancer;

Omitting Vlaanderen et al. (2013): d. NHL; e. kidney cancer; f. liver cancer.

b.

Funnel plot with pseudo 95% confidence limits

Funnel plot with pseudo 95% confidence limits

/	\

/	*

/	• \

/ \

/ «	V N

-1	0	1

LnEst

Funnel plot with pseudo 95% confidence limits

Funnel plot with pseudo 95% confidence limits

1417

1418

1419

1420

e.

Funnel plot with pseudo 95% confidence limits

/ \

/ \

' i N
/ • \

/ \

/ • \
/ ' \

/ / •

0

LnEst

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1421	H.2.3 Selected RR estimates and confidence intervals by study and cancer type

1422	Table Apx H-7. Selected RR estimates for NHL associated with TCE exposure (overall effect) from cohort studies published after

1423	U.S. EPA (2011)			

Study

RR

95%
LCL

95%
UCL

RR

type

In
RR

SE
(In
RR)

Alternate RR
estimates (95% CI)

Comments

Bove et al.

(2014a)

(2799547)

1.15

0.56

2.34

HR

0.140

0.37

None

Adjusted hazard ratio for males and females;
cumulative exposure for high exposure in enlisted
personnel; reference group had no exposure to TCE;
10-year lag time; specific ICD codes were not
reported.

Bove et al.

(2014b)

(2800329)

0.32

0.05

2.10

HR

-1.1

0.45

None

Adjusted hazard ratio for males and females, Camp
Lejeune cohort; cumulative exposure to TCE,
>median vs 5 yr exposure in workers, routine and
intermittent exposure; referent category was
nonexposed factory workers

Silver et al

(2014)

(2799800)

0.87

0.57

1.35

HR

-0.14

0.22

None

Hazard ratio at 5 modified exposure years for males
and females; cumulative exposure; adjusted for sex
and paycode; 10-year lag time; specific ICD codes
not reported.

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Study

RR

95%
LCL

95%
UCL

RR

type

In
RR

SE
(In
RR)

Alternate RR
estimates (95% CI)

Comments

Vlaanderen
et al (2013)
2128436

0.97

0.91

1.04

HR

-0.030

0.034

0.95 (0.84-1.06) HR for
men and women;
cumulative exposure for
high exposure groups
only (n=353 cases)

ICD-7 200 + 202; hazard ratio for men and
women; third tertile of cumulative exposure
(n=1211 cases); occupationally unexposed
individuals were used as the reference group;
unlagged exposure (up to 20 years of lag time had
a negligible impact on HR)

1424

1425	TableApx H-8. Selected RR estimates for NHL associated with TCE exposure (overall effect) from case-control studies

1426	published after U.S. EPA (2011)	^		

Study

RR

95%
LCL

95%
UCL

In RR

SE
(In RR)

Alternate RR
estimates (95% CI)

Comments

Christensen
et al. (2013)
(2127914)

1.2

0.5

2.9

0.18

0.45

1.0(0.3-3.5) OR for
substantial exposure

ICD-9 200 + 202; odds ratio for males and females;
any exposure; adjusted by age, census tract median
income, educational attainment (years), ethnicity,
questionnaire respondent (self vs. proxy) and,
smoking using population and cancer controls
weighting proportionately

Cocco et al.

(2013)

(2129584)

1.4

0.9

2.1

0.34

0.22

1.0 (0.8-1.2); any vs no
exposure in all subjects

Specific ICD codes not reported; odds ratio for
males and females; all study subjects with high
probability of exposure ; adjusted by age, gender,
and contributing study (50 cases, 38 controls).

1427

1428

1429	Table Apx H-9. Selected RR estimates for NHL associated with TCE exposure (effect in the highest exposure group) studies

1430	published after U.S. EPA (2011)				

Study

RR

95%
LCL

95%
UCL

log RR

SE
(log RR)

Alternate RR
estimates (95% CI)

Comments

Cohort Studies

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Hansen et al.

(2013)

(2128005)

0.66

0.21

2.03

HRR

-0.42

0.50

None

Vlaanderen et al
(2013)2128436
Nested Case-
control

0.95

0.84

1.06

HR

-0.051

0.059

0.96 (0.84-1.09) HR for men and women; intensity x prevalence
for high exposure groups only (n=269 cases); occupationally
unexposed individuals were used as the reference group; unlagged
exposure

Case-Control Studies

Christensen et
al. (2013)
(2127914)

1.0

0.3

3.5

0.00

0.63

NA

ICD-9 200 + 202; odds ratio for males and females; substantial
exposure; adjusted by age, census tract median income,
educational attainment (years), ethnicity, questionnaire respondent
(self vs. proxy) and, smoking using population and cancer controls
weighting proportionately.

Cocco et al.

(2013)

(2129584)

2.2

0.7

6.7

0.79

0.58

1.4 (1.0-2.1) OR for
>150 ppm intensity
level among all
subjects.

Specific ICD codes were not reported; odds ratio for males and
females; >75 ppm intensity level for study subjects with high
probability of exposure (9 cases, 5 controls); adjusted by age,
gender, and study.

1431

1432	TableApx H-10. Selected RR estimates for kidney cancer associated with TCE exposure (overall effect) from cohort studies

1433	published after U.S. EPA (2011)		^		

Study

RR

95%
LCL

95%
UCL

RR

type

In RR

SE (In
RR)

Alternate RR
estimates (95% CI)

Comments

Bove et al

(2014a)

(2799547)

1.52

0.64

3.61

HR

0.419

0.44

None

Adjusted hazard ratio for males and females; cumulative
exposure for high exposure in enlisted personnel;
reference group had no exposure to TCE; 10-year lag
time

Buhagen et al
(2016)3502047

1.7

1.0

3.0

SIR

0.53

0.30

None

14 cases had confirmed occupational exposure to TCE.

Hansen et al.

(2013)

(2128005)

1.04

0.71

1.50

SIR

0.039

0.18

1.11 (0.67-1.73)
SIR for 20-year lag
time; 1.01 (0.70-
1.42) SIR for no
lag

Standard incidence ratio for males and females in three
populations (Denmark, Sweden, and Finland); 10-year
lag time; study also reports hazard rate ratios for kidney
cancer based on urinary TCE metabolite

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95%

95%

RR



SE (In

Alternate RR



Study

RR

LCL

UCL

type

In RR

RR)

estimates (95% CI)

Comments

Lipworth et

0.85

0.33

2.19

RR

-0.16

0.48

0.42 (0.13-1.42)

Relative risk; sex and race combined; >5 yr exposure in

al (2011)













RR for 1-4 yr

workers, routine and intermittent exposure; referent

(1235276)













exposure; 0.52
(0.21-1.30) RR for
<1 yr exposure;
0.66 (0.38-1.07)
SMR for routine
and intermittent
exposure for at
least 1 yr
(compared with
general population)

category was nonexposed factory workers

Silver et al

1.24

0.87

1.77

HR

0.215

0.18

None

Hazard ratio at 5 modified exposure years for males and

(2014)















females; cumulative exposure; adjusted for sex and

(2799800)















paycode; 10-year lag time

Vlaanderen et

1.00

0.95

1.07

HR

0.00

0.030

0.86 (0.75-0.98) HR for

Hazard ratio for males and females; third tertile of

al (2013)













men and women;

cumulative exposure (n=1372 cases); occupationally

(2128436)













cumulative exposure for
high exposure groups
only (n=251 cases)

unexposed individuals were used as the reference
group; unlagged exposure (up to 20 years of lag time
had a negligible impact on HR)

1434

1435	TableApx H-ll. Selected RR estimates for kidney cancer associated with TCE exposure (overall effect) from case-control studies

1436	published after U.S. EPA (2011)			

Study

RR

95%
LCL

95%
UCL

In
RR

SE (In
RR)

Alternate RR estimate
(95% CI)

Comments

Christense
n et al.
(2013)
(2127914)

0.9

0.4

2.4

-0.11

0.46

0.6 (0.1-2.8) OR for
substantial exposure

Odds ratio for males and females; any exposure, adjusted
by age, census tract median income, educational attainment
(years), ethnicity, questionnaire respondent (self vs. proxy),
smoking, and coffee, beer, wine, and spirit intake using
population and cancer controls weighting proportionately

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Purdue et

0.8

0.4

1.5

-0.22

0.34

OR 0.9 (0.5- 1.9) for third

Odds ratio for kidney cancer in group with highest

al. (2016)











tertile of cumulative hours

probability of exposure (>90%; 32 cases, 32 controls);

(3482059)











exposed, any exposure

adjusted for age, sex, race, study center, education level,













intensity (23 cases, 19

smoking status, BMI and













controls).

history of hypertension

1437

1438	TableApx H-12. Selected RR estimates for liver cancer associated with TCE exposure (overall effect) from cohort studies

1439	published after U.S. EPA (2011)				

Study

RR

95%
LCL

95%
UCL

RR

type

In RR

SE (In
RR)

Alternate RR
estimates (95% CI)

Comments

Bove et al

(2014a)

(2799547)

0.86

0.37

1.97

HR

-0.15

0.43

None

Adjusted hazard ratio for males and females;
cumulative exposure for high exposure in
enlisted personnel; reference group had no
exposure to TCE; 10-year lag time

Hansen et
al. (2013)
(2128005)

1.83

1.24

2.56

SIR

0.604

0.177

2.09(1.34-3.11) SIR for
20-year lag time; 1.77
(1.24-2.45) SIR for no
lag

Liver and biliary passages; standard incidence
ratio for males and females in three populations
(Denmark, Sweden, and Finland); 10-year lag
time; study also reports hazard rate ratios for
liver and biliary passages cancer based on
urinary TCE metabolite

Lipworth et
al (2011)
(1235276)

0.83

0.36

1.91

RR

-0.19

0.43

0.69 (0.28-1.71) RR for
1-4 yr exposure; 0.67
(0.32-1.42) RR for <1 yr
exposure

0.89 (0.57-1.33) SMR
for routine and
intermittent exposure for
at least 1 yr (compared
with general population)

Liver and biliary passages; relative risk; sex and
race combined; >5 yr exposure in workers,
routine and intermittent exposure; referent
category was nonexposed factory workers

Silver et al

(2014)

(2799800)

0.99

0.50

1.95

HR

-0.010

0.35

None

Liver, biliary passages, and gallbladder; hazard
ratio at 5 modified exposure years for males and
females; cumulative exposure; adjusted for sex
andpaycode; 10-year lag time

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Study

RR

95%
LCL

95%
UCL

RR

type

In RR

SE (In
RR)

Alternate RR
estimates (95% CI)

Comments

Vlaandere
n et al
(2013)
2128436

1.00

0.90

1.11

HR

0.00

0.054

1.02 (0.82-1.25) HR for
men and women;
cumulative exposure for
high exposure groups
only (n=106 cases)

Hazard ratio for males and females; third
tertile of cumulative exposure (n=422 cases);
occupationally unexposed individuals were
used as the reference group; unlagged
exposure (up to 20 years of lag time had a
negligible impact on HR)

1440

1441

1442

TableApx H-13. Selected RR estimates for liver cancer associated with TCE exposure (overall effect) from case-control studies
published after U.S.

Study

RR

95%
LCL

95%
UCL

In
RR

SE (In
RR)

Alternate
RR estimate
(95% CI)

Comments

Christensen et
al. (2013)
(2127914)

1.1

0.1

8.5

0.095

1.1

2.1 (0.2-18) OR
for substantial
exposure

Odds ratio for males and females; any exposure, adjusted by age,
census tract median income, educational attainment (years),
ethnicity, questionnaire respondent (self vs. proxy), smoking, and
beer, wine, and spirit intake using population and cancer controls
weighting proportionately

1443

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H.2.4 Sample Stata commands for meta-analysis

Notes: the variables LnEst and SE are the natural log(RR) and its estimated standard error,
respectively; Author date labels studies on forest plots.

Basic fixed-effects analysis with axis labels:

metan LnEst SE, eform label(namevar=Author_date) effect(RR) xlabel(0.1, 0.2, 0.5, 1.0,
2.0,5.0,10)

Basic random-effects analysis with axis labels:

metan LnEst SE random, eform label(namevar=Author_date) effect(RR) xlabel(0.1, 0.2, 0.5, 1.0,
2.0,5.0,10)

Basic fixed-effects model omitting one study (indicated by NAME):

metan LnEst SE if Author!="NAME", eform label(namevar=Author_date) effect(RR) xlabel(0.1,
0.2, 0.5, 1.0,2.0,5.0,10)

Fixed-effects model stratifying by quality score (HiQ):

metan LnEst SE, eform label(namevar=Author_date) effect(RR) xlabel(0.1, 0.2, 0.5, 1.0,
2.0,5.0,10) by(HiQ)

Basic "leave one out" analysis of influence:

metaninf LnEst SE, eform label(namevar=Author_date) effect(RR)

Basic funnel plot:
metafunnel LnEst SE

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Appendix I APPROACH FOR ESTIMATING WATER

RELEASES FROM MANUFACTURING SITES
USING EFFLlJENT GUIDELINES

This appendix presents a methodology for estimating water releases of TCE from manufacturing
sites using effluent guidelines (EGs). This method uses the maximum daily and maximum
average monthly concentrations allowed under the Organic Chemicals, Plastics and Synthetic
Fibers (OCPSF) Effluent Guidelines and Standards (	). EGs are national regulatory

standards set forth by EPA for wastewater discharges to surface water and municipal sewage
treatment plants. The OCPSF EG applies to facilities classified under the following SIC codes:

•	2821—Plastic Materials, Synthetic Resins, and Nonvulcanizable Elastomers;

•	2823—Cellulosic Man-Made Fibers;

•	2865—Cyclic Crudes and Intermediates, Dyes, and Organic Pigments; and

•	2869—Industrial Organic Chemicals, Not Elsewhere Classified.

Manufacturers of TCE would typically be classified under SIC code 2869; therefore, the
requirements of the OCPSF EG are assumed to apply to manufacturing sites. Subparts I, J, and K
of the OCPSF EG set limits for the concentration of TCE in wastewater effluent for industrial
facilities that are direct discharge point sources using end-of-pipe biological treatment, direct
discharge point sources that do not use end-of-pipe biological treatment, and indirect discharge
point sources, respectively (	;). Direct dischargers are facilities that discharge

effluent directly to surface waters and indirect dischargers are facilities that discharge effluent to
publicly-owned treatment works (POTW). The OCPSF limits for TCE in each of the Subparts
are provided in Table Apx 1-1.

Table Apx 1-1. Summary of OCPSF Effluent Guidelines for Trichloroethylene

0( PSI- Subpart

.Maximum
for Any
One Day
(u«/L)

.Maximum
for Any
Monthly
Average
(tig/1.)

Basis

Subpart I - Direct Discharge Point Sources
That Use End-of-Pipe Biological Treatment

54

21

BAT effluent
limitations and NSPS

Subpart J - Direct Discharge Point Sources
That Do Not Use End-of-Pipe Biological
Treatment

69

26

BAT effluent
limitations and NSPS

Subpart K - Indirect Discharge Point
Sources

69

26

Pretreatment Standards
for Existing Sources
(PSES) and
Pretreatment Standards
for New Sources
(PSNS)

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BAT = Best Available Technology Economically Achievable; NSPS = New Source Performance Standards; PSES =
Pretreatment Standards for Existing Sources; PSNS = Pretreatment Standards for New Sources.

Source: (	)

To estimate daily releases from the EG, EPA used Equation 1-1 to estimate daily releases and
Equation D-2 to estimate annual releases using the parameters in TableApx 1-2. The prevalence
of end-of-pipe biological treatment is unknown; therefore, EPA used the discharge limits for
direct discharge point sources that do not use end-of-pipe biological treatment (Subpart J) and
indirect discharge point sources (Subpart K). EPA estimated a central tendency daily release
using the limit for the maximum monthly average (26 |ig/L) from Subparts J and K, a high-end
daily release using the limit for the maximum for any one day (69 |ig/L) from Subparts J and K,
and an annual release using the maximum monthly average from Subparts J and K.

Equation 1-1

DLxPWx PV
DR ~ 1,000,000,000 x OD

Equation 1-2

DLxPW x PV

AD = 	

1,000,000,000

Table Apx 1-2. Default Parameters for Estimating Water Releases of Trichloroethylene
from Manufacturing Sites			

Parameter

Parameter Description

Default Value

1 nit

DR

Daily release rate

Calculated from
equation

kg/site-day

DL

Discharge limita

Max Daily: 69
Average Daily: 26
Annual: 26

^g/L

PW

Produced waterb

10

L/kg

PV

Annual TCE production volume

Site-specific

kg/site-yr

OD

Operating Days0

350

days/yr

AR

Annual release rate

Calculated from
equation

kg/site-yr

a Discharge limits are based on the maximum discharge limits allowed in the OCPSF EG, which correspond to the
discharge limits for direct discharge point sources with no biological end-of-pipe treatment (Subpart J) and indirect
discharge points sources (Subpart K) (citation for 40 C.F.R. 414). There is no "average" daily discharge limit set by
the EGs; therefore, EPA assumed that the average daily discharge concentration would be equal to the maximum
monthly average discharge limit.

b The amount of produced water per kilogram of TCE produced is based on the SpERC developed by the European
Solvent Industry Group for the manufacture of a substance, which estimates 10 m3 of wastewater generated per
metric ton of substance produced and converted to 10 L/kg (European Solvents Indi	) (ESIG1

2012).

0 Due to large throughput, manufacturing sites are assumed to operate seven days per week and 50 weeks per year
with two weeks per year for shutdown activities.

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EPA did not identify TCE-specific information on the amount of wastewater produced per day.
The Specific Environmental Release Category (SpERC) developed by the European Solvent
Industry Group for the manufacture of a substance estimates 10 m3 of wastewater generated per
metric ton of substance produced (equivalent to 10 L water/kg of substance produced) (European
Solvents Industry Group (ESIG). 2012). In lieu of TCE-specific information, EPA estimated
wastewater flow using the SpERC specified wastewater production volume and the annual TCE
production rates for each facility. TableApx 1-3 provides estimated daily production volume
and wastewater flow for each facility that EPA used the EG to assess water releases.

Table Apx 1-3. Summary of Facility Trichloroethylene Production Volumes and
Wastewater Flow Rates

Site

Annual Production
Volume
(kg/site-yr)

Annual
Operating Days
(days/yr)

Daily
Production

Volume
(kg/site-day)

Daily
Wastewater

Flow
(L/site-day)

Solvents &
Chemicals,
Pearland, TXa

20,382,094

350

58,234

582,345

Occidental
Chemical Corp.
Wichata, KSa

20,382,094

350

58,234

582,345

a The 2015 annual production volumes in the 2016 CDR for these sites was either claimed as CBI or withheld. EPA
estimate the production volume by subtracting known site production volumes from the national production volume
and averaging the result over all the sites with CBI or withheld production volumes and converting from pounds to
kilograms.

b Annual production volume for this site is based on the 2015 production volume reported in the 2016 CDR and
converting from pounds to kilograms.

EPA estimated both a maximum daily release and an average daily release using the OCPSF EG
limits for TCE for maximum on any one day and maximum for any monthly average,
respectively. Prevalence of end-of-pipe biological treatment at TCE manufacturing sites is
unknown; therefore, EPA used limits for direct discharges with no end-of-pipe biological
treatment and indirect dischargers as conservative. EPA estimated annual releases from the
average daily release and assuming 350 days/yr of operation.

Example max daily, average daily, and annual water release calculations for TCE at
manufacturing sites based on the estimated production volume for Solvents & Chemicals
(44,934,862 lbs/yr or 20,382,094 kg/yr):23

69^x10-^x 20,382,094^	hn

L kq yr	kg

Max DR =	2	_^L_ = o.04- M

1,000,000,000^ x 350

kg	yr

day

23 This estimated production volume is equal to the estimated production volume assessed for all manufacturing sites.

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26^r- X IQj— X 20,382,094—	hn

L kq	yr	_ kg

1560	Average DR =	-j	= 0.015

1,000,000,000^ x 350	day

kg	yr

1561

26^X10-^X 20,382,094^ hn
L kq	yr kg

1562	AR=			777J	— =5.3 —

i,ooo,ooo,ooo^|	yr

1563

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Appendix J SAMPLE CALCULATIONS FOR

CALCULATING ACUTE AND CHRONIC (NON-
CANCER AND CANCER) INHALATION
EXPOSURE

Sample calculations for high-end and central tendency acute and chronic exposure
concentrations for one setting, Manufacturing, are demonstrated below. The explanation of the
equations and parameters used is provided in [Environmental Releases and Occupational
Exposure Assessment. Docket: EPA-HO-OPPT-2019-0500\. The final values will have two
significant figures since they are based on values from modeling.

J.l Example High-End AC, ADC, and LADC

Calculate AChe:

Calculate ADChe:

CHE x ED

ACHE =

AT,

acute

2.6 ppm x 8 hr/day
AChe =	2A~hrJday	= °"87 Ppm

CHE x ED xEFx EWY
ADC HE = —	—	

Ht	AT

hv	days

2.6 ppm x 8^— x 250—x 40 years

ADC in =					j—						= 0. 59 ppm

0 ^ _ days „.hours\

(40 years x 365 ^ x 24

Calculate LADChe:

CHE x ED xEFx EWY

ladche =

AT

LADC

hv	days

2.6 ppm x 8^— x 250 —^ x 40 years

LADChe =	7			j—		z			= 0.30 ppm

0 ^ _ days „.hours\

(78 years x 365^ x 24-^)

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J.2 Example Central Tendency A EC, ADC, and LADC

Calculate ACct:

Cct x ED
ACct = 	

AT

ri1 acute

0.03 ppm x 8 hr/day
AC"= 24 hr I day = °**PP
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Appendix K VAPOR DECREASING AND COLD CLEANING

NEAR-FIELD/FAR-FIELD INHALATION EXPOSURE
MODELS M'I'KOU'll \M) l>\K\ME IEKS

This appendix presents the modeling approach and model equations used in the following models:

•	Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation Exposure Model;

•	Conveyorized Degreasing Near-Field/Far-Field Inhalation Exposure Model;

•	Web Degreasing Near-Field/Far-Field Inhalation Exposure Model; and

•	Cold Cleaning Near-Field/Far-Field Inhalation Exposure Model.

The models were developed through review of the literature and consideration of existing EPA exposure
models. These models use a near-field/far-field approach (Nicas. 2009). where a vapor generation source
located inside the near-field diffuses into the surrounding environment. Workers are assumed to be
exposed to TCE vapor concentrations in the near-field, while occupational non-users are exposed at
concentrations in the far-field.

The model uses the following parameters to estimate exposure concentrations in the near-field and far-
field:

•	Far-field size;

•	Near-field size;

•	Air exchange rate;

•	Indoor air speed;

•	Exposure duration;

•	Vapor generation rate; and

•	Operating hours per day.

An individual model input parameter could either have a discrete value or a distribution of values. EPA
assigned statistical distributions based on reasonably available literature data. A Monte Carlo simulation
(a type of stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 7.0.0. The Latin hypercube sampling method is a statistical method for generating a sample of
possible values from a multi-dimensional distribution. Latin hypercube sampling is a stratified method,
meaning it guarantees that its generated samples are representative of the probability density function
(variability) defined in the model. EPA performed the model at 100,000 iterations to capture the range of
possible input values (i.e., including values with low probability of occurrence).

Model results from the Monte Carlo simulation are presented as 95th and 50th percentile values. The
statistics were calculated directly in @Risk. The 95th percentile value was selected to represent high-end
exposure level, whereas the 50th percentile value was selected to represent typical exposure level. The
following subsections detail the model design equations and parameters for vapor degreasing and cold
cleaning models.

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K.1 Model Design Equations

FigureApx K-l through FigureApx K-3 illustrate the near-field/far-field modeling approach as it was
applied by EPA to each vapor degreasing and cold cleaning model. As the figures show, volatile TCE
vapors evaporate into the near-field, resulting in worker exposures at a TCE concentration Cnf. The
concentration is directly proportional to the evaporation rate of TCE, (denoted by "G" in Figure 2-7),
into the near-field, whose volume is denoted by Vnf. The ventilation rate for the near-field zone (Qnf)
determines how quickly TCE dissipates into the far-field, resulting in occupational non-user exposures
to TCE at a concentration Cff. Vff denotes the volume of the far-field space into which the TCE
dissipates out of the near-field. The ventilation rate for the surroundings, denoted by Qff, determines
how quickly TCE dissipates out of the surrounding space and into the outside air.

Far-Field

Figure Apx K-l. The Near-Field/Far-Field Model as Applied to the Open-Top Vapor Degreasing
Near-Field/Far-Field Inhalation Exposure Model and the Cold Cleaning Near-Field/Far-Field

Inhalation Exposure Model

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FigureApx K-2. The Near-Field/Far-Field Model as Applied to the Conveyorized Degreasing

Near-Field/Far-Field Inhalation Exposure Model

Far-Field

CL

Q 	W

NF	^

Near-Field

\lSj











1

1

•¦¦1

_W Q

N

Figure Apx K-3. The Near-Field/Far-Field Model as Applied to the Web Degreasing Near-

Field/Far-Field Inhalation Exposure Model

The model design equations are presented below in Equation K-l through Equation K-18. Note the
design equations are the same for each of the models discussed in this appendix.

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Near-Field Mass Balance
Equation K-l

Far-Field Mass Balance

Vnf Jt — CffQnf ~ CNFQNF + G

dt

Equation K-2

Where:

V,

dC,

FF

FF'

dt

CnfQnf CffQnf CffQff

Vnf =

near-field volume;

Vff =

far-field volume;

Qnf =

near-field ventilation rate;

Qff =

far-field ventilation rate;

Cnf =

average near-field concentration;

Cff =

average far-field concentration;

G

average vapor generation rate; and

t

elapsed time.

Both of the previous equations can be solved for the time-varying concentrations in the near-field and
far-field as follows ("Micas. 2009):

Equation K-3
Equation K-4

Where:

Equation K-5

CNF = G(k1 + k2eXlt - k3eX2t)

CFF = G (^— + k4eXlt -

fci =

Equation K-6

Equation K-7

Equation K-8

Equation K-9

kn =

ko =

(<1nf +'<2 J Qff

QnfQff + ^-2^nf(.Qnf + Qff)
QnfQff^nf^i ~ ^2)

QnfQff + A.1Vnf(.Qnf + Qff)
QnfQff^nf(^i ~ ^2)

, MiVnf + Qnf\ ,

4 = ( q7f > 2

_ /A2Vnf + Qnf\ j

5 V qnf ) 3

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Equation K-10

= 0.5

( Qnf^ff + Vnf(Qnf + Qff)

V ^NF^FF ,

+

/ Qnf^ff + Vnf(Qnf + Qff)\
\	Vnf^ff	J

^ (QnfQff\
V VpjpVpp /

Equation K-ll

^ _ q 5 _ / Qnf^ff + Vnf(Qnf + Qff)



VNFVFF

/Qnf^ff + Vnf(Qnf + Qff)\ _ . /QnfQff\
\	^nf^ff	) \VNFVFF)

EPA calculated the hourly TWA concentrations in the near-field and far-field using Equation M-1221
and Equation M-13, respectively. Note that the numerator and denominator of Equation M-1221 and
Equation M-132 use two different sets of time parameters. The numerator is based on operating times
for the scenario (e.g., two or eight hours for OTVDs, 8 to 24 hours for conveyorized degreasers, 8 hours
for web degreasers, and 3 to 8 hours for cold cleaning, see Appendix M.2) while the denominator is
fixed to an average time span, t avg, of eight hours (since EPA is interested in calculating 8-hr TWA
exposures). Mathematically, the numerator and denominator must reflect the same amount of time. This
is indeed the case since the numerator assumes exposures are zero for any hours not within the operating
time. Therefore, mathematically speaking, both the numerator and the denominator reflect eight hours
regardless of the values selected for ti and t2.

Equation K-12

j^2 CNFdt j^2 G{kx + k2eXlt — k3eX2t)dt

CnF TWA = 77	=	I	=

f aV9 dt	tavg

J\J

r(i <- i MAlt2 MA2t2\ r (l + i MAltl k2eX^\

G ^,t2 + 	a_j _ G + -2^	

tavg

Equation K-13

;t'2 Crrdt J,'' '¦ + kte^' - k5e^') dt
~ ~ ^ "

n(t2 , k4eXlt2 kseX2t2\ _ / t± k4eXltl k5eX2tl\

G(g^ + ~	IT)-G{
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Equation K-14

FSA = 2{LnfHnf) + 2 (WnfHnf) + (LnfWnf)

Where: Lnf, Wnf, and Hnf are the length, width, and height of the near-field, respectively. The near-
field ventilation rate, Qnf, is calculated in Equation M-154 from the near-field indoor wind speed, vnf,
and FSA, assuming half of FSA is available for mass transfer into the near-field and half of FSA is
available for mass transfer out of the near-field:

Equation K-15

1

Qnf — — vnfFSA

The far-field volume, Vff, and the air exchange rate, AER, is used to calculate the far-field ventilation
rate, Qff, as given by Equation M-25:

Equation K-16

Qff = VppAE R

Using the model inputs described in Appendix E.2, EPA estimated TCE inhalation exposures for
workers in the near-field and for occupational non-users in the far-field. EPA then conducted the Monte
Carlo simulations using @Risk (Version 7.0.0). The simulations applied 100,000 iterations and the Latin
Hypercube sampling method for each model.

K.2 Model Parameters

TableApx K-l through TableApx K-4 summarize the model parameters and their values for each of
the models discussed in this Appendix. Each parameter is discussed in detail in the following
subsections.

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TableApx K
Inhalation Ex

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1. Summary of Parameter Values and Distributions Used in the Open-Top Vapor Degreasing Near-Field/Far-Field
posure Model

Input
Parameter





Deterministic Values

Uncertainty Analysis Distribution Parameters



Symbol

Unit

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distribution
Type

Comments

Far-field
volume

Vff

ft3

10,594

Midpoint

10,594

70,629

17,657

Triangular

See Section K.2.1

Air

exchange
rate

AER

hr"1

2

Mode

2

20

3.5

Triangular

See Section K.2.2

Near-field
indoor wind
speed

VNF

ft/hr

1,181

50th
percentile

154

23,882

—

—

See Section K.2.3

cm/s

10

50th
percentile

1.3

202.2

—

—

Near-field
length

Lnf

ft

10

—

—

—

—

Constant
Value



Near-field
width

Wnf

ft

10

—

—

—

—

Constant
Value

See Section K.2.4

Near-field
height

Hnf

ft

6

—

—

—

—

Constant
Value



Starting
time

tl

hr

0

—

—

—

—

Constant
Value

Constant.

Exposure
Duration

t2

hr

8

—

2

8

—

—

See Section K.2.5

Averaging
Time

tavg

hr

8

—

—

—

—

Constant
Value

See Section K.2.6

Vapor

generation

rate

G

mg/hr

2.34E+07

Average

4.54E+02

4.67E+07

—

Discrete

See Section K.2.7

lb/hr

51.50

Average

0.001

103.00

—

Discrete

Operating
hours per
day

OH

hr/day

8

—





—

Discrete

See Section E.2.8

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TableApx K-2. Summary of Parameter Values and Distributions Used in the Conveyorized Degreasing Near-Field/Far-Field
Inhalation Exposure Model 			

Input
Parameter

Symbol

Unit

Deterministic Values

Uncertainty Analysis Distribution Parameters

Comments

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distribution
Type

Far-field
volume

Vff

ft3

10,594

Midpoint

10,594

70,629

17,657

Triangular

See Section K.2.1

Air

exchange
rate

AER

hr"1

2

Mode

2

20

3.5

Triangular

See Section K.2.2

Near-field
indoor
wind speed

VNF

ft/hr

1,181

50th
percentile

154

23,882

—

—

See Section K.2.3

cm/s

10

50th
percentile

1.3

202.2

—

—

Near-field
length

Lnf

ft

10

—

—

—

—

Constant
Value

See Section K.2.4

Near-field
width

Wnf

ft

10

—

—

—

—

Constant
Value

Near-field
height

Hnf

ft

6

—

—

—

—

Constant
Value

Starting
time

tl

hr

0

—

—

—

—

Constant
Value

Constant.

Exposure
Duration

t2

hr

24

—

24

8

—

Constant
Value

See Section K.2.5

Averaging
Time

tavg

hr

8

—

—

—

—

Constant
Value

See Section K.2.6

Vapor

generation

rate

G

mg/hr

1.6E+07

Average

3.63E+05

3.29E+07

—

Discrete

See Section K.2.7

lb/hr

36.6

Average

0.80

72.5

—

Discrete

Operating
hours per
day

OH

hr/day

24

—

—

—

—

Constant

See Section E.2.8

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TableApx K-3. Summary of Parameter Values and Distributions Used in the Web Degreasing Near-Field/Far-Field Inhalation
Exposure Model					

Input
Parameter

Symbol

Unit

Deterministic Values

Uncertainty Analysis Distribution Parameters

Comments

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distribution
Type

Far-field
volume

Vff

ft3

10,594

Midpoint

10,594

70,629

17,657

Triangular

See Section K.2.1

Air

exchange
rate

AER

hr"1

2

Mode

2

20

3.5

Triangular

See Section K.2.2

Near-field
indoor
wind speed

VNF

ft/hr

1,181

50th
percentile

154

23,882

—

—

See Section K.2.3

cm/s

10

50th
percentile

1.3

202.2

—

—

Near-field
length

Lnf

ft

10

—

—

—

—

Constant
Value

See Section K.2.4

Near-field
width

Wnf

ft

10

—

—

—

—

Constant
Value

Near-field
height

Hnf

ft

6

—

—

—

—

Constant
Value

Starting
time

tl

hr

0

—

—

—

—

Constant
Value

Constant.

Exposure
Duration

t2

hr

8

—

8

8

—

Constant
Value

See Section K.2.5

Averaging
Time

tavg

hr

8

—

—

—

—

Constant
Value

See Section K.2.6

Vapor

generation

rate

G

mg/hr

—

—

1.12E+05

1.12E+05

—

Discrete

See Section K.2.7; Single Data
Point

Operating
hours per
day

OH

hr/day

24

—

—

—

—

Constant

See Section M.2.8

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TableApx K-4. Summary of Parameter Values and Distributions Used in the Cold Cleaning Near-Field/Far-Field Inhalation

Input
Parameter

Symbol

Unit

Deterministic Values

Uncertainty Analysis Distribution Parameters

Comments

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distribution
Type

Far-field
volume

Vff

ft3

10,594

Midpoint

10,594

70,629

17,657

Triangular

See Section K.2.1

Air

exchange
rate

AER

hr"1

2

Mode

2

20

3.5

Triangular

See Section K.2.2

Near-field
indoor
wind speed

VNF

ft/hr

1,181

50th
percentile

154

23,882

—

—

See Section K.2.3

cm/s

10

50th
percentile

1.3

202.2

—

—

Near-field
length

Lnf

ft

10

—

—

—

—

Constant
Value

See Section K.2.4

Near-field
width

Wnf

ft

10

—

—

—

—

Constant
Value

Near-field
height

Hnf

ft

6

—

—

—

—

Constant
Value

Starting
time

tl

hr

0

—

—

—

—

Constant
Value

Constant.

Exposure
Duration

t2

hr

—

—

3

8

—

Discrete

See Section K.2.5

Averaging
Time

tavg

hr

8

—

—

—

—

Constant
Value

See Section K.2.6

Vapor

generation

rate

G

mg/hr

5.14E+05

Average

6.28E+02

1.02E+06

—

Discrete

See Section K.2.7

lb/hr

1.13

Average

0.001

2.26

—

Discrete

Operating
hours per
day

OH

hr/day

—

—

—

—

—

—

See Section M.2.8

1789

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K.2.1 Far-Field Volume

EPA used the same far-field volume distribution for each of the models discussed. The far-field volume
is based on information obtained from (Von Grote et al. 2003) that indicated volumes at German metal
degreasing facilities can vary from 300 to several thousand cubic meters. They noted that smaller
volumes are more typical and assumed 400 and 600 m3 (14,126 and 21,189 ft3) in their exposure models
(Von Grote et al.. 2003). These are the highest and lowest values EPA identified in the literature;
therefore, EPA assumes a triangular distribution bound from 300 m3 (10,594 ft3) to 2,000 m3 (70,629 ft3)
with a mode of 500 m3 (the midpoint of 400 and 600 m3) (17,657 ft3).

K.2.2 Air Exchange Rate

EPA used the same air exchange rate distribution for each of the models discussed. The air exchange
rate is based on data from (Hellwee et al.. 2009) and information received from a peer reviewer during
the development of the 2014 TSCA Work Plan Chemical Risk Assessment Trichloroethylene:
Degreasing, Spot Cleaning and Arts & Crafts Uses (I v « « \ _^13a). (Hellwee et al.. 2009) reported
that average air exchange rates for occupational settings using mechanical ventilation systems vary from
3 to 20 hr"1. The risk assessment peer reviewer comments indicated that values around 2 to 5 hr"1 are
likely (	), in agreement with the low end reported by (Hellwee et al.. 2009). Therefore,

EPA used a triangular distribution with the mode equal to 3.5 hr"1, the midpoint of the range provided by
the risk assessment peer reviewer (3.5 is the midpoint of the range 2 to 5 hr"1), with a minimum of 2 hr"1,
per the risk assessment peer reviewer (	i) and a maximum of 20 hr"1 per (Hellwee et al..

2009).

K.2.3 Near-Field Indoor Air Speed

(Baldwin and Mavnard. 1998a) measured indoor air speeds across a variety of occupational settings in
the United Kingdom. Fifty-five work areas were surveyed across a variety of workplaces.

EPA analyzed the air speed data from (Baldwin and Mayna 8a) and categorized the air speed
surveys into settings representative of industrial facilities and representative of commercial facilities.
EPA fit separate distributions for these industrial and commercial settings and used the industrial
distribution for facilities performing vapor degreasing and/or cold cleaning.

EPA fit a lognormal distribution for both data sets as consistent with the authors observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed. Since lognormal distributions are
bound by zero and positive infinity, EPA truncated the distribution at the largest observed value among
all of the survey mean air speeds from (Baldwin and Mavn; )8a) (1998).

EPA fit the air speed surveys representative of industrial facilities to a lognormal distribution with the
following parameter values: mean of 22.414 cm/s and standard deviation of 19.958 cm/s. In the model,
the lognormal distribution is truncated at a maximum allowed value of 202.2 cm/s (largest surveyed
mean air speed observed in (Baldwin and Mayng >8a) (1998)) to prevent the model from sampling
values that approach infinity or are otherwise unrealistically large.

(Baldwin and Mavnard. 1998a) only presented the mean air speed of each survey. The authors did not
present the individual measurements within each survey. Therefore, these distributions represent a
distribution of mean air speeds and not a distribution of spatially variable air speeds within a single
workplace setting. However, a mean air speed (averaged over a work area) is the required input for the
model.

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K.2.4 Near-Field Volume

EPA assumed a near-field of constant dimensions of 10 ft x 10 ft x 6 ft resulting in a total volume of 600

ft3.

K.2.5 Exposure Duration

EPA assumed the maximum exposure duration for each model is equal to the entire work-shift (eight
hours). Therefore, if the degreaser/cold cleaning machine operating time was greater than eight hours,
then exposure duration was set equal to eight hours. If the operating time was less than eight hours, then
exposure duration was set equal to the degreaser/cold cleaning machine operating time (see Appendix
E.2.8 for discussion of operating hours).

K.2.6 Averaging Time

EPA was interested in estimating 8-hr TWAs for use in risk calculations; therefore, a constant averaging
time of eight hours was used for each of the models.

K.2.7 Vapor Generation Rate

For the vapor generation rate from each machine type (OTVD, conveyorized and cold), EPA used a
discrete distribution based on the annual unit emission rates reported in the (U.S. EPA. 2018a). No web
degreasers were reported in the 2014 NEI, therefore, (U.S. EPA. 2011a) data was used for web
degreasers. Annual unit emission rates were converted to hourly unit emission rates by dividing the
annual reported emissions by the reported annual operating hours (see Appendix E.2.8). Reported annual
emissions in NEI without accompanying reported annual operating hours were not included in the
analysis. Emission rates reported as zero were also excluded as it is unclear if this is before or after
vapor controls used by the site and if the vapor controls used would control emissions into the work area
(thus reducing exposure) or only control emissions to the environment (which would not affect worker
exposures). TableApx K-5 summarizes the data available in the 2014 NEI.

TableApx K-5. Summary of Trichloroethylene Vapor Degreasing and Cold Cleaning Data from

the 2014 NEI





Units with Zero
Emissions

Units without

Units Used

Unit Type

Total Units

Accompanying
Operating Hours

in

Analysis3

Open-Top Vapor Degreasers

149

29

62

76

Conveyorized Degreasers

8

0

5

3

Web Degreasersb

1

0

0

1

Cold Cleaning Machines

17

1

6

10

a - Some units with zero emissions also did not include accompanying operating hours; therefore, subtracting the units with
zero emissions and the units without operating hours from the total units does not equal the units in the analysis due to double
counting.

b - No web degreasers reported in the 2014 NEI. One web degreaser reported in the (U.S. EPA. 201 la) was used in this
analysis.

Source: (U.S. EPA. 2018a): (U.S. EPA. 2011a)

Table Apx K-6 through Table Apx K-9 summarize the distribution of hourly unit emissions for each
machine type calculated from the annual emission in the 2014 NEI.

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1873 TableApx K-6. Distribution of Trich

oroethylene Open-Top Vapor Degreasing Unit Emissions

Count

of
Units

Unit
Emissions
(lb/unit-hr)

Fractional
Probability

1

103.00

0.0132

1

63.95

0.0132

1

19.04

0.0132

1

13.20

0.0132

1

12.18

0.0132

1

9.47

0.0132

1

9.21

0.0132

1

8.14

0.0132

1

7.30

0.0132

1

6.93

0.0132

1

6.64

0.0132

1

6.61

0.0132

1

6.44

0.0132

1

6.40

0.0132

1

6.32

0.0132

1

5.10

0.0132

1

5.06

0.0132

1

4.89

0.0132

1

4.85

0.0132

1

4.14

0.0132

1

3.96

0.0132

1

3.82

0.0132

1

3.77

0.0132

1

3.68

0.0132



3.66

0.0263

1

3.64

0.0132

1

3.43

0.0132

1

3.40

0.0132

1

2.88

0.0132

1

2.79

0.0132

1

2.64

0.0132

1

2.61

0.0132

1

2.48

0.0132

1

2.37

0.0132

1

2.20

0.0132

1

1.97

0.0132

1

1.96

0.0132

1

1.73

0.0132

1

1.62

0.0132

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Count

of
Units

Unit
Emissions
(lb/unit-hr)

Fractional
Probability

1

1.59

0.0132

1

1.44

0.0132

1

1.33

0.0132

1

1.22

0.0132

1

1.09

0.0132



0.93

0.0263

1

0.90

0.0132



0.84

0.0263

1

0.83

0.0132

1

0.79

0.0132



0.79

0.0395

1

0.70

0.0132

1

0.62

0.0132

1

0.60

0.0132

1

0.43

0.0132

1

0.42

0.0132

1

0.39

0.0132

1

0.38

0.0132

1

0.38

0.0132

1

0.35

0.0132

1

0.23

0.0132

1

0.18

0.0132

1

0.15

0.0132

1

0.15

0.0132

1

0.14

0.0132

1

0.11

0.0132

1

0.10

0.0132



0.10

0.0263

1

0.07

0.0132

1

0.03

0.0132

1

0.001

0.0132

1874

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TableApx K-7. Distribution of Trichloroethylene Conveyorized Degreasing Unit Emissions



Unit



Count

Emissions

Fractional

of Units

(lb/unit-hr)

Probability

1

72.48

0.3333

1

1.51

0.3333

1

0.80

0.3333

1876

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TableApx K-8. Distribution of Trichloroethylene Web Degreasing Unit Emissions

Count
of Units

Unit
Emissions
(lb/unit-hr)

Fractional
Probability

—

0.247

1.00

TableApx K-9. Distribution of Trichloroethylene Cold (

Count
of Units

Unit
Emissions
(lb/unit-hr)

Fractional
Probability

1.00

2.26

0.1000

1.00

0.83

0.1000

1.00

0.83

0.1000

1.00

0.83

0.1000

1.00

0.83

0.1000

1.00

0.05

0.1000

1.00

0.01

0.1000

1.00

0.01

0.1000

1.00

0.01

0.1000

1.00

0.00

0.1000

leaning Unit Emissions

K.2.8 Operating Hours

For the operating hours of each machine type (OTVD, conveyorized, web, and cold), EPA used a
discrete distribution based on the daily operating hours reported in the 2014 NEI. It should be noted that
not all units had an accompanying reported daily operating hours; therefore, the distribution for the
operating hours per day is based on a subset of the reported units. Table Apx K-10 through Table Apx
K-13 summarize the distribution of operating hours per day for each machine type.

Table Apx K-10. Distribution of Trichloroethylene Open-Top Vapor Degreasing Operating Hours

Count of
Occurrences

Operating
Hours
(hr/day)

Fractional
Probability

—

24

0.4048

—

16

0.0952

—

8

0.2381

—

6

0.0476

—

4

0.0714

—

2

0.1429

Table Apx K-ll. Distribu

ion of Trichloroethylene Conveyorized Degreasing Operating Hours

Count of
Occurrences

Operating
Hours
(hr/day)

Fractional
Probability

—

24

1.0000

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1892 TableApx K-12. Distribu

ion of Trichloroethylene Web Degreasing Operating Hours

Count of
Occurrences

Operating
Hours
(hr/day)

Fractional
Probability

—

24

1.0000

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Table Apx K-13. Distribution of Trichloroethylene Cold Cleaning Operating Hours



Operating



Count of

Hours

Fractional

Occurrences

(hr/day)

Probability

—

24

0.4000

—

8

0.5000

—

3

0.1000

1895

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Appendix L BRAKE SERVICING NEAR-FIELD/FAR-FIELD

INHALATION EXPOSURE MODEL APPROACH AND
PARAMETERS

This appendix presents the modeling approach and model equations used in the Brake Servicing Near-
Field/Far-Field Inhalation Exposure Model. The model was developed through review of the literature
and consideration of existing EPA exposure models. This model uses a near-field/far-field approach
CNlcas. 2009). where an aerosol application located inside the near-field generates a mist of droplets, and
indoor air movements lead to the convection of the droplets between the near-field and far-field.

Workers are assumed to be exposed to TCE droplet concentrations in the near-field, while occupational
non-users are exposed at concentrations in the far-field.

The model uses the following parameters to estimate exposure concentrations in the near-field and far-
field:

•	Far-field size;

•	Near-field size;

•	Air exchange rate;

•	Indoor air speed;

•	Concentration of TCE in the aerosol formulation;

•	Amount of degreaser used per brake j ob;

•	Number of degreaser applications per brake job;

•	Time duration of brake j ob;

•	Operating hours per week; and

•	Number of j obs per work shift.

An individual model input parameter could either have a discrete value or a distribution of values. EPA
assigned statistical distributions based on reasonably available literature data. A Monte Carlo simulation
(a type of stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 7.0.0. The Latin hypercube sampling method is a statistical method for generating a sample of
possible values from a multi-dimensional distribution. Latin hypercube sampling is a stratified method,
meaning it guarantees that its generated samples are representative of the probability density function
(variability) defined in the model. EPA performed the model at 100,000 iterations to capture the range of
possible input values (i.e., including values with low probability of occurrence).

Model results from the Monte Carlo simulation are presented as 95th and 50th percentile values. The
statistics were calculated directly in @Risk. The 95th percentile value was selected to represent high-end
exposure level, whereas the 50th percentile value was selected to represent central tendency exposure
level. The following subsections detail the model design equations and parameters for the brake
servicing model.

L.l Model Design Equations

In brake servicing, the vehicle is raised on an automobile lift to a comfortable working height to allow
the worker (mechanic) to remove the wheel and access the brake system. Brake servicing can include

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inspections, adjustments, brake pad replacements, and rotor resurfacing. These service types often
involve disassembly, replacement or repair, and reassembly of the brake system. Automotive brake
cleaners are used to remove oil, grease, brake fluid, brake pad dust, or dirt. Mechanics may occasionally
use brake cleaners, engine degreasers, carburetor cleaners, and general purpose degreasers
interchangeably (CARB. 2000). Automotive brake cleaners can come in aerosol or liquid form (CARB.
2000): this model estimates exposures from aerosol brake cleaners (degreasers).

FigureApx L-l illustrates the near-field/far-field modeling approach as it was applied by EPA to brake
servicing using an aerosol degreaser. The application of the aerosol degreaser immediately generates a
mist of droplets in the near-field, resulting in worker exposures at a TCE concentration Cnf. The
concentration is directly proportional to the amount of aerosol degreaser applied by the worker, who is
standing in the near-field-zone (i.e., the working zone). The volume of this zone is denoted by Vnf. The
ventilation rate for the near-field zone (Qnf) determines how quickly TCE dissipates into the far-field
(i.e., the facility space surrounding the near-field), resulting in occupational non-user exposures to TCE
at a concentration Cff. Vff denotes the volume of the far-field space into which the TCE dissipates out
of the near-field. The ventilation rate for the surroundings, denoted by Qff, determines how quickly
TCE dissipates out of the surrounding space and into the outside air.

Figure Apx L-l. The Near-Field/Far-Field Model as Applied to the Brake Servicing Near-

Field/Far-Field Inhalation Exposure Model

In brake servicing using an aerosol degreaser, aerosol degreaser droplets enter the near-field in non-
steady "bursts," where each burst results in a sudden rise in the near-field concentration. The near-field
and far-field concentrations then decay with time until the next burst causes a new rise in near-field
concentration. Based on site data from automotive maintenance and repair shops obtained by CARB
(CARB. 2000) for brake cleaning activities and as explained in Sections L.2.5 and L.2.9 below, the
model assumes a worker will perform an average of 11 applications of the degreaser product per brake
job with five minutes between each application and that a worker may perform one to four brake jobs
per day each taking one hour to complete. EPA modeled two scenarios: one where the brake jobs
occurred back-to-back and one where brake jobs occurred one hour apart. In both scenarios, EPA

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assumed the worker does not perform a brake job, and does not use the aerosol degreaser, during the
first hour of the day.

EPA denoted the top of each five-minute period for each hour of the day (e.g., 8:00 am, 8:05 am, 8:10
am, etc.) as tm,n. Here, m has the values of 0, 1, 2, 3, 4, 5, 6, and 7 to indicate the top of each hour of the
day (e.g., 8 am, 9 am, etc.) and n has the values of 0, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11 to indicate the top
of each five-minute period within the hour. No aerosol degreaser is used, and no exposures occur, during
the first hour of the day, to,o to to,n (e.g., 8 am to 9 am). Then, in both scenarios, the worker begins the
first brake job during the second hour, ti,o (e.g., 9 am to 10 am). The worker applies the aerosol
degreaser at the top of the second 5-minute period and each subsequent 5-minute period during the hour-
long brake job (e.g., 9:05 am, 9:10 am,... 9:55 am). In the first scenario, the brake jobs are performed
back-to-back, if performing more than one brake job on the given day. Therefore, the second brake job
begins at the top of the third hour (e.g., 10 am), and the worker applies the aerosol degreaser at the top
of the second 5-minute period and each subsequent 5-minute period (e.g., 10:05 am, 10:10 am,... 10:55
am). In the second scenario, the brake jobs are performed every other hour, if performing more than one
brake job on the given day. Therefore, the second brake job begins at the top of the fourth hour (e.g., 11
am), and the worker applies the aerosol degreaser at the top of the second 5-minute period and each
subsequent 5-minute period (e.g., 11:05 am, 11:10 am,... 11:55 am).

In the first scenario, after the worker performs the last brake job, the workers and occupational non-users
(ONUs) continue to be exposed as the airborne concentrations decay during the final three to six hours
until the end of the day (e.g., 4 pm). In the second scenario, after the worker performs each brake job,
the workers and ONUs continue to be exposed as the airborne concentrations decay during the time in
which no brake jobs are occurring and then again when the next brake job is initiated. In both scenarios,
the workers and ONUs are no longer exposed once they leave work.

Based on data from CARB (CARB. 2000). EPA assumes each brake job requires one 14.4-oz can of
aerosol brake cleaner as described in further detail below. The model determines the application rate of
TCE using the weight fraction of TCE in the aerosol product. EPA uses a uniform distribution of weight
fractions for TCE based on facility data for the aerosol products in use (	,000).

The model design equations are presented below.

Near-Field Mass Balance
Equation L-l

Far-Field Mass Balance
Equation L-2

Where:

Vnf
Vff
Qnf
Qff
Cnf
Cff

near-field volume;
far-field volume;
near-field ventilation rate;
far-field ventilation rate;
average near-field concentration;
average far-field concentration; and

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t = elapsed time.

Solving the above equations in terms of the time-varying concentrations in the near-field and far-field
yields Equation L-3 and Equation L-4, which EPA applied to each of the 12 five-minute increments
during each hour of the day. For each five-minute increment, EPA calculated the initial near-field
concentration at the top of the period (tm,n), accounting for both the burst of TCE from the degreaser
application (if the five-minute increment is during a brake job) and the residual near-field concentration
remaining after the previous five-minute increment (tm,n-i; except during the first hour and tm,o of the first
brake job, in which case there would be no residual TCE from a previous application). The initial far-
field concentration is equal to the residual far-field concentration remaining after the previous five-
minute increment. EPA then calculated the decayed concentration in the near-field and far-field at the
end of the five-minute period, just before the degreaser application at the top of the next period (tm,n+i).
EPA then calculated a 5-minute TWA exposure for the near-field and far-field, representative of the
worker's and ONUs' exposures to the airborne concentrations during each five-minute increment using
Equation L-13 and Equation L-14. The k coefficients (Equation L-5 through Equation L-8) are a
function of the initial near-field and far-field concentrations, and therefore are re-calculated at the top of
each five-minute period. In the equations below, where the subscript "m, n-1" is used, if the value of n-1
is less than zero, the value at "m-1, 11" is used and where the subscript "m, n+1" is used, if the value of
n+1 is greater than 11, the value at "m+1, 0" is used.

Equation L-3

Cnf t _li — C^l t eXlt ^2 t

iyir>Lm,n+1 v	z>Lm,n J

Equation L-4

CpF t ^=(^3t eXlt-k4t eX2t)

rr>Lm,n+1 v 3,im,n	^>Lm,n J

Where:
Equation L-5

Equation L-6

/Cl £ 	

1>Lm,n

2, tm,n

Qnf (CFF,o(.tm,n) CWF 0(tmn)^ A2VNFCNF,o(tm,n)
VnfVi ~ ^2)

Qnf	— CfF,0 {tm,rS) + ^l^NF^NF.oiSm.n)

Vnf&i ~ ^2)

Equation L-7

(.Qnf + ^-1^Nf)(QnF {^FF.oiSm.n} CNF,o{im,n)) ^I^NF^NF.oiSm.n})

3}tm,n

Qnf^nf (^1 — ^2)

Equation L-8

4
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Equation L-9

= 0.5

(QnfVff + Vnf(.Qnf + Qff)\ /QnfVff + ^nf(Qnf + Qff)\ _ . /QnfQff\

\ ^NF^FF ) J V ^NF^FF ) ^ ^NF^FF '

Equation L-10

^ _ q 5 _ / Qnf^ff + Vnf(Qnf + Qff)



VirpVi

NFV FF

(Qnf^ff + Vnf(Qnf + Qff) \ _ . /QnfQff\
Vnf^ff	/ V VNpVpp)



Equation L-ll

CNF,o{pm,n) — j—f1,000——+ CWF(tmn_1) , n > 0 for all m where brake job occurs
I 'vp	.Q '

0, m = 0

Equation L-12

Equation L-13



r	0, m = 0

FF,o\tm,n) — {CFF(trriin^1), for all n where m > 0

^	^	\ /k	k	N

I	j — I	| 2.trn,n-l rX-,U

. g/Llcl -|	" g'

^1	^2

NF, 5-min TWA, tm rl

^2

Equation L-14

kz.tm.n-l CX,U j k4,tm,n-l	_ (^}tm,n-l £A1t1 | ^4tm,n-1

Ai	A2	/ \ Ai	A2

CfF, 5-min TWA, tm „	. .

I? — ll

After calculating all near-field/far-field 5-minute TWA exposures (i.e., C«f, 5-min TWA,tmn and

Cpp 5.min TWA tmn) for each five-minute period of the work day, EPA calculated the near-field/far-field

8-hour TWA concentration and 1-hour TWA concentrations following the equations below:

Equation L-15

C,

Sm=0 2j71=o[^NF,5-i

NF, 8-hr TWA ~

min TWA,tm rl

x 0.0833 hr\

8 hr

Equation L-16

C,

Hm=oHn=o[^FF,

5-min TWA,tn

x 0.0833 hr]

NF, 8-hr TWA ~

8 hr

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Equation L-17

r	_ I!r! = o[C/VF,5-min TWA,tm,n X 0-0833 hr\

CNF, 1-hr TWA =	~\\xr

Equation L-18

r	_ hn=o[CFF,5-mmTWA,tmn X 0.0833 hr\

CFF, 1-hr TWA =	Yhr

EPA calculated rolling 1-hour TWA's throughout the workday and the model reports the maximum
calculated 1-hour TWA.

To calculate the mass transfer to and from the near-field, the free surface area (FSA) is defined to be the
surface area through which mass transfer can occur. The FSA is not equal to the surface area of the
entire near-field. EPA defined the near-field zone to be a hemisphere with its major axis oriented
vertically, against the vehicle, and aligned through the center of the wheel (see Figure Apx L-l). The
top half of the circular cross-section rests against, and is blocked by, the vehicle and is not available for
mass transfer. The FSA is calculated as the entire surface area of the hemisphere's curved surface and
half of the hemisphere's circular surface per Equation L-19, below:

Equation L-19

FSA = x	x TcRftF^j

Where: Rnf is the radius of the near-field

The near-field ventilation rate, Qnf, is calculated in Equation M-1520 from the indoor wind speed, vnf,
and FSA, assuming half of the FSA is available for mass transfer into the near-field and half of the FSA
is available for mass transfer out of the near-field:

Equation L-20

1

Qnf — 2 vnfFSA

The far-field volume, Vff, and the air exchange rate, AER, is used to calculate the far-field ventilation
rate, Qff, as given by Equation M-21:

Equation L-21

Qff = R

Using the model inputs described in Appendix F.2, EPA estimated TCE inhalation exposures for
workers in the near-field and for occupational non-users in the far-field. EPA then conducted the Monte
Carlo simulations using @Risk (Version 7.0.0). The simulations applied 100,000 iterations and the Latin
Hypercube sampling method.

L.2 Model Parameters

Table Apx L-l summarizes the model parameters and their values for the Brake Servicing Near-Field/
Far-Field Inhalation Exposure Model. Each parameter is discussed in detail in the following subsections.

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TableApx L-l. Summary of Parameter Values and Distributions Used in the Brake Servicing Near-Field/Far-Field Inhalation

	Exposure Model	

Input
Parameter

Symbol

Unit

Constant Model
Parameter Values

Value

Basis

Variable Model Parameter Values

Lower
Bound

Upper
Bound

Mode

Distributio
n Type

Comments

Far-field volume

Vff

in'

206

70,679

3,769

Triangular

Distribution based on data
collected by CARB (CARB.
2000). 	

Air exchange
rate

AER

lir1

20

3.5

Triangular

(Demou et al.. 2009) identifies
typical AERs of 1 lir1 and 3 to 20
lir1 for occupational settings
without and with mechanical
ventilation systems, respectively.
(Hellweg et al.. 2009) identifies
average AERs for occupational
settings utilizing mechanical
ventilation systems to be between
3 and 20 lir1. (Golsteiinet al..
2014) indicates a characteristic
AER of 4 lir1. Peer reviewers of
EPA's 2013 TCE draft risk
assessment commented that
values around 2 to 5 lir1 may be
more likely (U.S. EPA. 2013a). in
agreement with (Golsteiinet al..
2014). A triangular distribution is
used with the mode equal to the
midpoint of the range provided by
the peer reviewer (3.5 is the
midpoint of the range 2 to 5 hr').

Near-field indoor
wind speed

Mir

23,882

Lognonnal

Vnf

cm/s

202.2

Lognonnal

Lognormal distribution fit to
commercial-type workplace data
from (Baldwin and Mavnard.
1998a).	

Near-field radius

R.

m

1.5

Constant
Value

Constant.

Starting time for
each application
period	

lir

Constant
Value

Constant.

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Input
Parameter

Symbol

Unit

Constant Model
Parameter Values

Variable Model Parameter Values

Comments

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distributio
n Type

End time for
each application
period

t2

hr

0.0833

—

—

—

—

Constant
Value

Assumes aerosol degreaser is
applied in 5-minute increments
during brake job.

Averaging Time

tavg

hr

8

—

—

—

—

Constant
Value

Constant.

TCE weight
fraction

wtfrac

wt frac

—

—

0.40

1.00

—

Discrete

Discrete distribution of TCE-
based aerosol product
formulations based on products
identified in EPA's Preliminaiy
Information on Manufacturing,
Processing, Distribution, Use, and
Disposal for TCE (U.S. EPA.
2017c). Where the weieht fraction
of TCE in the formulation was
given as a range, EPA assumed a
uniform distribution within the
reported range for the TCE
concentration in the product.

Degreaser Used
per Brake Job

wd

oz/job

14.4

—

—

—

—

Constant
Value

Based on data from CARB
(CARB. 2000).

Number of
Applications per
Job

Na

Applications/
job

11

—

—

—

—

Constant
Value

Calculated from the average of
the number of applications per
brake and number of brakes per
job.

Amount Used
per Application

Amt

g TCE/
application

—

—

14.8

37.1

—

Calculated

Calculated from wtfrac, Wd, and
Na.

Operating hours
per week

OHpW

hr/week

—

—

40

122.5

—

Lognonnal

Lognormal distribution fit to the
operating hours per week
observed in CARB (CARB.
2000) site visits.

Number of
Brake Jobs per
Work Shift

Nj

jobs/site-shift

—

—

1

4

—

—

Calculated from the average
number of brake jobs per site per
year, OHpW, and assuming 52
operating weeks per year and 8
hours per work shift.

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L.2.1 Far-Field Volume

The far-field volume is based on information obtained from (	) from site visits of 137

automotive maintenance and repair shops in California. (GARB. 2000) indicated that shop volumes at
the visited sites ranged from 200 to 70,679 m3 with an average shop volume of 3,769 m3. Based on this
data EPA assumed a triangular distribution bound from 200 m3 to 70,679 m3 with a mode of 3,769 m3
(the average of the data from (GARB. 2000)).

CARB measured the physical dimensions of the portion of the facility where brake service work was
performed at the visited facilities. CARB did not consider other areas of the facility, such as customer
waiting areas and adjacent storage rooms, if they were separated by a normally closed door. If the door
was normally open, then CARB did consider those areas as part of the measured portion where brake
servicing emissions could occur (CARB. 2000). CARB's methodology for measuring the physical
dimensions of the visited facilities provides the appropriate physical dimensions needed to represent the
far-field volume in EPA's model. Therefore, CARB's reported facility volume data are appropriate for
EPA's modeling purposes.

L.2.2 Air Exchange Rate

The air exchange rate (AER) is based on data from (Demou et al. 2009). (Hellwee et al. 2009).
(Golsteiin et al. 2014). and information received from a peer reviewer during the development of the
2014 TSCA Work Plan Chemical Risk Assessment Trichloroethylene: Degreasing, Spot Cleaning and
Arts & Crafts Uses (	.). (Demon et al.. 2009) identifies typical AERs of 1 hr"1 and 3 to 20

hr"1 for occupational settings without and with mechanical ventilation systems, respectively. Similarly,
(Hellwee et al.. 2009) identifies average AERs for occupational settings using mechanical ventilation
systems to vary from 3 to 20 hr"1. (Golsteiin et al.. 2014) indicates a characteristic AER of 4 hr"1. The
risk assessment peer reviewer comments indicated that values around 2 to 5 hr"1 are likely (U.S. EPA.
2013a). in agreement with (Golsteiin et al.. 2014) and the low end reported by (Demou et al.. 2009) and
(Hellwee et al.. 2009). Therefore, EPA used a triangular distribution with the mode equal to 3.5 hr"1, the
midpoint of the range provided by the risk assessment peer reviewer (3.5 is the midpoint of the range 2
to 5 hr"1), with a minimum of 1 hr"1, per (Demon et al.. 2009) and a maximum of 20 hr"1 per (Demon et
al.. 2009) and (Hellwee et al.. 2009)).

L.2.3 Near-Field Indoor Air Speed

(Baldwin and Mavnard. 1998a) measured indoor air speeds across a variety of occupational settings in
the United Kingdom. Fifty-five work areas were surveyed across a variety of workplaces.

EPA analyzed the air speed data from (Baldwin and Mavna 8a) and categorized the air speed
surveys into settings representative of industrial facilities and representative of commercial facilities.
EPA fit separate distributions for these industrial and commercial settings and used the commercial
distribution for facilities performing aerosol degreasing or other aerosol applications.

EPA fit a lognormal distribution for both data sets as consistent with the authors observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed. Since lognormal distributions are
bound by zero and positive infinity, EPA truncated the distribution at the largest observed value among
all of the survey mean air speeds from (Baldwin and Maym )8a).

EPA fit the air speed surveys representative of commercial facilities to a lognormal distribution with the
following parameter values: mean of 10.853 cm/s and standard deviation of 7.883 cm/s. In the model,

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the lognormal distribution is truncated at a maximum allowed value of 202.2 cm/s (largest surveyed
mean air speed observed in (Baldwin and Mavm ?8a) to prevent the model from sampling values
that approach infinity or are otherwise unrealistically large.

(Baldwin and Mavnard. 1998a) only presented the mean air speed of each survey. The authors did not
present the individual measurements within each survey. Therefore, these distributions represent a
distribution of mean air speeds and not a distribution of spatially-variable air speeds within a single
workplace setting. However, a mean air speed (averaged over a work area) is the required input for the
model.

L.2.4 Near-Field Volume

EPA defined the near-field zone to be a hemisphere with its major axis oriented vertically, against the
vehicle, and aligned through the center of the wheel (see FigureApx L-l). The near-field volume is
calculated per Equation L-22. EPA defined a near-field radius (Rnf) of 1.5 meters, approximately 4.9
feet, as an estimate of the working height of the wheel, as measured from the floor to the center of the
wheel.

Equation L-22

1 4

VNF = 2 X g

L.2.5 Application Time

EPA assumed an average of 11 brake cleaner applications per brake job (see Section F.2.9). CARB
observed, from their site visits, that the visited facilities did not perform more than one brake job in any
given hour (	30). Therefore, EPA assumed a brake job takes one hour to perform. Using an

assumed average of 11 brake cleaner applications per brake job and one hour to perform a brake job,
EPA calculates an average brake cleaner application frequency of once every five minutes (0.0833 hr).
EPA models an average brake job of having no brake cleaner application during its first five minutes
and then one brake cleaner application per each subsequent 5-minute period during the one-hour brake
job.

L.2.6 Averaging Time

EPA was interested in estimating 8-hr TWAs for use in risk calculations; therefore, a constant averaging
time of eight hours was used.

L.2.7 Trichloroethylene Weight Fraction

EPA reviewed the Preliminary Information on Manufacturing, Processing, Distribution, Use, and
Disposal: Trichloroethylene report (	) for aerosol degreasers that contain TCE. EPA

(2017) identifies 16 aerosol degreaser products that overall range in TCE content from 40 to 100 weight
percent. The identified aerosol degreasers include a brake cleaner as well as general purpose degreasers,
machine cleaners, electronic/electrical parts cleaners, and a mold cleaner. EPA includes all of these
aerosol degreasers in the estimation of TCE content as: 1) automotive maintenance and repair facilities
may use different degreaser products interchangeably as observed by (	'00); and 2) EPA uses

this brake servicing model as an exposure scenario representative of all commercial-type aerosol
degreaser applications.

EPA used a discrete distribution to model the TCE weight fraction based on the number of occurrences
of each product type. In some instances, the concentration of TCE was reported as a range. For these
product types, EPA used a uniform distribution to model the TCE weight fraction within the product

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type. Table Apx L-2 provides a summary of the reported TCE content reported in the safety data sheets
identified in (U.S. EPA. 2017c). the number of occurrences of each product type, and the fractional
probability of each product type.

Table Apx L-2. Summary of Trichloroethylene-Based Aerosol Degreaser Formulations

Name of Aerosol
Degreaser Product
Identified in fU S. EPA,
2017c)

Trichloroethylene
Weight Percent

Number of
Occurrences

Fractional
Probability

C-60 Solvent Degreaser

90-100%

1

0.063

Fusing Machine Cleaner

40-60%

1

0.063

Solvent Degreaser

> 90%

1

0.063

Electro Blast

90-100%

1

0.063

Electro Solv

90-100%

1

0.063

Pro Tools NF Solvent
Degreaser

60-100%

1

0.063

Aerosolve II

>90%

1

0.063

Power Solv II

90-100%

1

0.063

Zep 45

40-50%

1

0.063

Super Solv

90-100%

1

0.063

Parts Cleaner

45-55%

1

0.063

Electronic Contact Cleaner &
Protectant - Aerosol

97%

1

0.063

Flash Free Electrical Degreaser

98%

1

0.063

Chlorinated Brake & Parts
Cleaner - Aerosol

98%

1

0.063

MR 351 - Mold Cleaner

69%

1

0.063

C-60 Solvent [TCE Cleaner]
Degreaser

90-100%

1

0.063

Total

16

1.000

L.2.8 Volume of Degreaser Used per Brake Job

(CARB. 2000) assumed that brake jobs require 14.4 oz of aerosol product. EPA did not identify other
information to estimate the volume of aerosol product per job; therefore, EPA used a constant volume of
14.4 oz per brake job based on (CARB. 2000).

L.2.9 Number of Applications per Brake Job

Workers typically apply the brake cleaner before, during, and after brake disassembly. Workers may
also apply the brake cleaner after brake reassembly as a final cleaning process (CARB. 2000).

Therefore, EPA assumed a worker applies a brake cleaner three or four times per wheel. Since a brake
job can be performed on either one axle or two axles (CARB. 2000). EPA assumed a brake job may
involve either two or four wheels. Therefore, the number of brake cleaner (aerosol degreaser)
applications per brake job can range from six (3 applications/brake x 2 brakes) to 16 (4
applications/brake x 4 brakes). EPA assumed a constant number of applications per brake job based on
the midpoint of this range of 11 applications per brake job.

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L.2.10 Amount of Trichloroethylene Used per Application

EPA calculated the amount of Trichloroethylene used per application using Equation L-23. The
calculated mass of Trichloroethylene used per application ranges from 14.8 to 37.1 grams.

Equation L-23

Where:

Amt
Wd

Wtfrac
Na

Amt =

Wd x wtfrac x 28.3495^-

oz

Na

Amount of TCE used per application (g/application);

Weight of degreaser used per brake job (oz/job);

Weight fraction of TCE in aerosol degreaser (unitless); and
Number of degreaser applications per brake job (applications/job).

L.2.11 Operating Hours per Week

(( 2000) collected weekly operating hour data for 54 automotive maintenance and repair facilities.
The surveyed facilities included service stations (fuel retail stations), general automotive shops, car
dealerships, brake repair shops, and vehicle fleet maintenance facilities. The weekly operating hours of
the surveyed facilities ranged from 40 to 122.5 hr/week. EPA fit a lognormal distribution to the surveyed
weekly operating hour data. The resulting lognormal distribution has a mean of 16.943 and standard
deviation of 13.813, which set the shape of the lognormal distribution. EPA shifted the distribution to
the right such that its minimum value is 40 hr/week and set a truncation of 122.5 hr/week (the truncation
is set as 82.5 hr/week relative to the left shift of 40 hr/week).

L.2.12 Number of Brake Jobs per Work Shift

(C 2000) visited 137 automotive maintenance and repair shops and collected data on the number of
brake jobs performed annually at each facility. CARB calculated an average of 936 brake jobs
performed per facility per year. EPA calculated the number of brake jobs per work shift using the
average number of jobs per site per year, the operating hours per week, and assuming 52 weeks of
operation per year and eight hours per work shift using Equation L-24 and rounding to the nearest
integer. The calculated number of brake jobs per work shift ranges from one to four.

Equation L-24

Where:

Nj

OHpW

N,=

936^M£_x8

site-year shift

r„weeks	...

52	x OHpW

yr	r

Number of brake jobs per work shift (j obs/site-shift); and
Operating hours per week (hr/week).

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Appendix M SPOT CLEANING NEAR-FIELD/FAR-FIELD

INHALATION EXPOSURE MODEL APPROACH AND
PA.RAMETERS

This appendix presents the modeling approach and model equations used in the Spot Cleaning Near-
Field/Far-Field Inhalation Exposure Model. The model was developed through review of relevant
literature and consideration of existing EPA exposure models. The model uses a near-field/far-field
approach (	309), where a vapor generation source located inside the near-field leads to the

evaporation of vapors into the near-field, and indoor air movements lead to the convection of vapors
between the near-field and far-field. Workers are assumed to be exposed to TCE vapor concentrations in
the near-field, while occupational non-users are exposed at concentrations in the far-field.

The model uses the following parameters to estimate exposure concentrations in the near-field and far-
field:

•	Far-field size;

•	Near-field size;

•	Air exchange rate;

•	Indoor air speed;

•	Spot cleaner use rate;

•	Vapor generation rate;

•	Weight fraction of TCE in the spot cleaner; and

•	Operating hours per day.

An individual model input parameter could either have a discrete value or a distribution of values. EPA
assigned statistical distributions based on reasonably available literature data. A Monte Carlo simulation
(a type of stochastic simulation) was conducted to capture variability in the model input parameters. The
simulation was conducted using the Latin hypercube sampling method in @Risk Industrial Edition,
Version 7.0.0. The Latin hypercube sampling method is a statistical method for generating a sample of
possible values from a multi-dimensional distribution. Latin hypercube sampling is a stratified method,
meaning it guarantees that its generated samples are representative of the probability density function
(variability) defined in the model. EPA performed the model at 100,000 iterations to capture the range of
possible input values (i.e., including values with low probability of occurrence).

Model results from the Monte Carlo simulation are presented as 95th and 50th percentile values. The
statistics were calculated directly in @Risk. The 95th percentile value was selected to represent a high-
end exposure, whereas the 50th percentile value was selected to represent a central tendency exposure
level. The following subsections detail the model design equations and parameters for the spot cleaning
model.

M.l_ Model Design Equations

Figure Apx M-l illustrates the near-field/far-field modeling approach as it was applied by EPA to spot
cleaning facilities. As the figure shows, TCE vapors evaporate into the near-field (at evaporation rate G),
resulting in near-field exposures to workers at a concentration Cnf. The concentration is directly
proportional to the amount of spot cleaner applied by the worker, who is standing in the near-field-zone
(i.e., the working zone). The volume of this zone is denoted by Vnf. The ventilation rate for the near-

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field zone (Qnf) determines how quickly TCE dissipates into the far-field (i.e., the facility space
surrounding the near-field), resulting in occupational non-user exposures to TCE at a concentration Cff.
Vff denotes the volume of the far-field space into which the TCE dissipates out of the near-field. The
ventilation rate for the surroundings, denoted by Qff, determines how quickly TCE dissipates out of the
surrounding space and into the outdoor air.



Figure Apx M-l. The Near-Field/Far-Field Model as Applied to the Spot Cleaning Near-

Field/Far-Field Inhalation Exposure Model

The model design equations are presented below in Equation M-l through Equation M-16.

Near-Field Mass Balance
Equation M-l

Vnf ^ = CffQnf ~ CNFQNF + G

Far-Field Mass Balance
Equation M-2

dCFF

Vff ^ = CnfQnf ~ CFFQNF — CFFQFF

Where:

Vnf =

near-field volume;

Vff =

far-field volume;

Qnf =

near-field ventilation rate;

Qff =

far-field ventilation rate;

Cnf =

average near-field concentration;

Cff =

average far-field concentration;

G

average vapor generation rate; and

t

elapsed time.

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Both of the previous equations can be solved for the time-varying concentrations in the near-field and
far-field as follows (	09):

Equation M-3
Equation M-4

Where:

Equation M-5

Equation M-6

Equation M-7

Equation M-8

Equation M-9

Equation M-10

= 0.5

CNF = G(k1 + k2eXlt - k3e^2t)

CFF = G (—	1- k4eXlt - k$eX2t

\Qff

)

fci =

k7 =

ko =

(qnf + e J Qff

QnfQff + ^-2^nf(.Qnf + Qff)
QnfQff^nf(^i ~ ^2)

QnfQff + A.1Vnf(.Qnf + Qff)
QnfQffVnf(.^i ~ ^2)

, MiVnf + Qnf\ ,

_ /A2Vnf + Qnf\ j
5 V	) 3

/ QnfQff + Vnf(Qnf + Qff)

V ^/vf^ff ,

+

/QnfQff + Vnf(Qnf + Qff)\ _ . (QnfQff\

V	^/VF^FF	/	^ ^/VF^FF /

Equation M-ll

Az = 0.5

( QnfQff + ^nf(Qnf + Qff)\

V ^/VF^FF /

/ QnfQff + ^nf(Qnf + Qff)\

' \	^/VF^FF	/

^ /QnfQff\
V K/vf^Vf '

EPA calculated the hourly TWA concentrations in the near-field and far-field using the following
equations. Note that the numerator and denominator of Equation M-12 and Equation M-1313, use two

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different sets of time parameters. The numerator is based on the operating hours for the scenario while
the denominator is fixed to an averaging time span, t avg, of 8 hours (since EPA is interested in
calculating 8-hr TWA exposures). Mathematically, the numerator and denominator must reflect the
same amount of time. This is indeed the case: although the spot cleaning operating hours ranges from
two to five hours (as discussed in Section A.2.8), EPA assumes exposures are equal to zero outside of
the operating hours, such that the integral over the balance of the eight hours (three to six hours) is equal
to zero in the numerator. Therefore, the numerator inherently includes an integral over the balance of the
eight hours equal to zero that is summed to the integral from ti to t2.

Equation M-12

j^2 CNFdt j^2 G{kx + k2eXlt — k3eX2t)dt

Cnftwa = t	=	=

'	f*avg dt	tavg

/	k2ex& _ k2ex^\ _ ( k2ex^ _ k3ex^\

" ykit2 ~i~ Ai	Az J Cr^jti+ Ai	J

tavg

Equation M-13

J",*2 Cppdt £ a (^- + k,e^c - k5e^') dt

n ( t2 , k4eXlt2 kseX2t2\ n ( t1 , k4eXltl kseX2tl\
b[QFF+	A2 ) b[QFF+ Ax h. )

^avg

To calculate the mass transfer to and from the near-field, the Free Surface Area, FSA, is defined to be
the surface area through which mass transfer can occur. Note that the FSA is not equal to the surface
area of the entire near-field. EPA defined the near-field zone to be a rectangular box resting on the floor;
therefore, no mass transfer can occur through the near-field box's floor. FSA is calculated in Equation
M-14, below:

Equation M-14

FSA = 2{LnfHnf) + 2 (WnfHnf) + (LnfWnf)

Where: Lnf, Wnf, and Hnf are the length, width, and height of the near-field, respectively. The near-
field ventilation rate, Qnf, is calculated in Equation M-15 from the near-field indoor wind speed, vnf,
and FSA, assuming half of FSA is available for mass transfer into the near-field and half of FSA is
available for mass transfer out of the near-field:

Equation M-15

1

Qnf — 2 vnfFSA

The far-field volume, Vff, and the air exchange rate, AER, is used to calculate the far-field ventilation
rate, Qff, as given by Equation M-:

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Equation M-16

Qff = VffAER

Using the model inputs in Table H-l, EPA estimated TCE inhalation exposures for workers in the near-
field and for occupational non-user in the far-field. EPA then conducted the Monte Carlo simulations
using @Risk (Version 7.0.0). The simulations applied 100,000 iterations and the Latin hypercube
sampling method.

M.2 Model Parameters

Table Apx M-l summarizes the model parameters and their values for the Spot Cleaning Near-
Field/Far-Field Exposure Model. Each parameter is discussed in detail in the following subsections.

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TableApx M-l. Summary of Parameter Values and Distributions Used in the Spot Cleaning Near-Field/Far-Field Inhalation







Constant











Input
Parameter

Symbol

Unit

Model
Parameter
Values

Variable Model Parameter Values

Comments







Value

Basis

Lower
Bound

Upper
Bound

Mode

Distributio
n Type



Floor Area

A

ft2

—

—

500

20,000

—

Beta

Facility floor area is based on data
from the (C ARB, 2006) and King
Countv (Whittaker and Johanson,
2011) studv. ERG fit a beta function
to this distribution with parameters: ai
= 6.655, oi2 = 108.22, min = 500 ft2,
max = 20,000 ft2.

Far-field
volume

Vff

ft3

—

—

6,000

240,000

—

—

Floor area multiplied by height.
Facility height is 12 ft (median value
per (CARB, 2006) studv).

Near-field
length

Lnf

ft

10

—

—

—

—

—



Near-field
width

Wnf

ft

10

—

—

—

—

—

EPA assumed a constant near-field
volume.

Near-field
height

Hnf

ft

6

—

—

—

—

—



Air exchange
rate

AER

hr1

—

—

1

19

3.5

Triangular

Values based on (von Grote et al.,
2006). and (U.S. EPA, 2013a). The
mode represents the midpoint of the
range reported in (U.S. EPA, 2013a).

Near-field



cm/s

—

—

0

2022

—

Lognormal

Lognormal distribution fit to the data

indoor wind
speed

VNF

ft/hr

—

—

0

23,882

—

Lognormal

presented in (Baldwin and Mavnard,
1998a).

Starting time

tl

hr

0

—

—

—

—

—

Constant value.

Exposure
Duration

t2

hr

—

—

2

5

—

Uniform

Equal to operating hours per day.

Averaging time

tavg

hr

8

—

—

—

—

—

Constant value.

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Constant











Input
Parameter

Symbol

Unit

Model
Parameter
Values

Variable Model Parameter Values

Comments







Value

Basis

Lower
Bound

Upper
Bound

Mode

Distributio
n Type



Use rate

UR

gal/yr

8.4

—

—

—

—

—

(IRTA, 2007) used estimates of the
amount of TCE-based spot cleaner
sold in California and the number of
textile cleaning facilities in California
to calculate a use rate value.





mg/hr

—

—

2.97E+03

9.32E+04

—

Calculated

G is calculated based on UR and

Vapor
generation rate

G

g/min

—

—

0.05

1.55

—

Calculated

assumes 100% volatilization and
accounts for the weight fraction of
TCE.

TCE weight
fraction

wtfirac

wt firac

—

—

0.1

1

—

Uniform

(IRTA, 2007) observed TCE-based
spotting agents contain 10% to 100%
TCE.

Operating
hours per day

OH

hr/day

—

—

2

5

—

Uniform

Determined from a California survey
performed bv (Morris and Wolf,
2005) and an analvsis of two model
plants constructed by the researchers

Operating days
per year

OD

days/yr

—

—

249

313

300

Triangular

Operating days/yr distribution assumed
as triangular distribution with min of
250, max of 312, and mode of 300.

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Input
Parameter

Symbol

Unit

Constant

Model
Parameter
Values

Variable Model Parameter Values

Comments

Value

Basis

Lower
Bound

Upper
Bound

Mode

Distributio
n Type

Fractional
number of
operating days
that a worker
works

/

Dimensionles

s

1

—

0.8

1.0

—

Uniform

In BLS/Census data, the weighted
average worked hours per year and per
worker in the dry cleaning sector is
approximately 1,600 (i.e., 200 day/yr
at 8 hr/day).

The BLS/Census data weighted
average of 200 day/yr falls outside the
triangular distribution of operating
days and to account for lower exposure
frequencies and part-time workers,
EPA defines/as a uniform distribution
ranging from 0.8 to 1.0. The 0.8 value
was derived from the observation that
the weighted average of 200 day/yr
worked (from BLS/Census) is 80% of
the standard assumption that a full-
time worker works 250 day/yr. The
maximum of 1.0 is appropriate as dry
cleaners may be family owned and
operated and some workers may work
as much as every operating day.

2434

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M.2.1 Far-Field Volume

EPA calculated the far-field volume by setting a distribution for the facility floor area and multiplying
the floor area by a facility height of 12 ft (median value per (CARB. 2006) study) as discussed in more
detail below.

The 2006 CARB California Dry Cleaning Industry Technical Assessment Report (CARB, 2006) and the
Local Hazardous Waste Management Program in King County A Profile of the Dry Cleaning Industry in
King County, Washington (Whittaker and Johanson. 2011) provide survey data on dry cleaning facility
floor area. The CARB (2006) study also provides survey data on facility height. Using survey results
from both studies, EPA composed the following distribution of floor area. To calculate facility volume,
EPA used the median facility height from the CARB (2006) study. The facility height distribution in the
CARB (2006) study has a low level of variability, so the median height value of 12 ft presents a simple
but reasonable approach to calculate facility volume combined with the floor area distribution. Results
are provided in TableApx M-2

TableApx M-2. Composite Distribution of Dry Cleaning Facility Floor Areas



Percentile



Floor Area

(as



Value (ft2)

fraction)

Source

20,000

1

King County

3,000

0.96

King County

2,000

0.84

King County

1,600

0.5

CARB 2006

1,100

0.1

CARB 2006

500

0

CARB 2006

EPA fit a beta function to this distribution with parameters: ai = 6.655, a.2 = 108.22, min = 500 ft2, max
= 20,000 ft2

M.2.2 Near-Field Volume

EPA assumed a near-field of constant dimensions of 10 ft wide by 10 ft long by 6 ft high resulting in a
total volume of 600 ft3.

M.2.3 Air Exchange Rate

(von Grote et al.. 2006) indicated typical air exchange rates (AERs) of 5 to 19 hr"1 for dry cleaning
facilities in Germany. (Klein and Kurz. 1994a) indicated AERs of 1 to 19 hr"1, with a mean of 8 hr"1 for
dry cleaning facilities in Germany. During the 2013 peer review of EPA's 2013 draft risk assessment of
TCE, a peer reviewer indicated that air exchange rate values around 2 to 5 hr"1 are likely (U.S. EPA.
2013a). in agreement with the low end of the ranges reported by von Grote et al. and (Klein and Kurz.
1994a). A triangular distribution is used with the mode equal to the midpoint of the range provided by
the peer reviewer (3.5 is the midpoint of the range 2 to 5 hr"1).

M.2.4 Near-Field Indoor Wind Speed

(Baldwin and Mavnard. 1998a) measured indoor air speeds across a variety of occupational settings in
the United Kingdom. Fifty-five work areas were surveyed across a variety of workplaces.

EPA analyzed the air speed data from (Baldwin and Mavnard. 1998a) and categorizing the air speed
surveys into settings representative of industrial facilities and representative of commercial facilities.

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EPA fit separate distributions for these industrial and commercial settings and used the commercial
distribution for dry cleaners (including other textile cleaning facilities that conduct spot cleaning).

EPA fit a lognormal distribution for both data sets as consistent with the authors observations that the air
speed measurements within a surveyed location were lognormally distributed and the population of the
mean air speeds among all surveys were lognormally distributed. Since lognormal distributions are
bound by zero and positive infinity, EPA truncated the distribution at the largest observed value among
all of the survey mean air speeds from (Baldwin and Mavm >8a).

The air speed surveys representative of commercial facilities were fit to a lognormal distribution with
the following parameter values: mean of 10.853 cm/s and standard deviation of 7.883 cm/s. In the
model, the lognormal distribution is truncated at a maximum allowed value of 202.2 cm/s (largest
surveyed mean air speed observed in (Baldwin andMavnard. 1998a) to prevent the model from
sampling values that approach infinity or are otherwise unrealistically large.

(Baldwin and Mavn 98a) only presented the mean air speed of each survey. The authors did not
present the individual measurements within each survey. Therefore, these distributions represent a
distribution of mean air speeds and not a distribution of spatially-variable air speeds within a single
workplace setting. However, a mean air speed (averaged over a work area) is the required input for the
model.

M.2.5 Averaging Time

EPA is interested in estimating 8-hr TWAs for use in risk calculations; therefore, a constant averaging
time of eight hours was used.

M.2.6 Use Rate

EPA used a top-down approach to estimate use rate based on the volume of TCE-based spotting agent
sold in California and the number of textile cleaning facilities in California.

(IRTA. 2007) estimated 42,000 gal of TCE-based spotting agents are sold in California annually and
there are approximately 5,000 textile cleaning facilities in California. This results in an average use rate
of 8.4 gal/site-year of TCE-based spotting agents.

The study authors' review of safety data sheets identified TCE-based spotting agents contain 10% to
100% TCE.

M.2.7 Vapor Generation Rate

EPA set the vapor generation rate for spot cleaning (G) equal to the use rate of TCE with appropriate
unit conversions. EPA multiplied the spotting agent use rate by the weight fraction of TCE (which
ranges from 0.1 to 1) and assumed all TCE applied to the garment evaporates. EPA used a density of
1.46 g/cm3 (U.S. EPA. 2018d). To calculate an hourly vapor generation rate, EPA divided the annual use
rate by the number of operating days and the number of operating hours selected from their respective
distributions for each iteration.

M.2.8 Operating Hours

(Morris and Wolf. 2005) surveyed dry cleaners in California, including their spotting labor. The authors
developed two model plants: a small PERC dry cleaner that cleans 40,000 lb of clothes annually; and a
large PERC dry cleaner that cleans 100,000 lb of clothes annually. The authors modeled the small dry

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cleaner with a spotting labor of 2.46 hr/day and the large dry cleaner with a spotting labor of 5 hr/day.
EPA models a uniform distribution of spotting labor varying from 2 to 5 hr/day.

M.2.9 Operating Days

EPA modeled the operating days per year using a triangular distribution from 250 to 312 days per year
with a mode of 300 days per year.24 The low-end operating days per year is based on the assumption that
at a minimum the dry cleaner operates five days per week and 50 weeks per year. The mode of 300 days
per year is based on an assumption that most dry cleaners will operate six days per week and 50 weeks
per year. The high-end value is based on the assumption that the dry cleaner would operate at most six
days per week and 52 weeks per year, assuming the dry cleaner is open year-round.

M.2.10 Fractional Number of Operating Days that a Worker Works

To account for lower exposure frequencies and part-time workers, EPA defines a fractional days of
exposure as a uniform distribution ranging from 0.8 to 1.0. EPA expects a worker's annual working days
may be less than the operating days based on BLS/Census data that showed the weighted average
worked hours per year and per worker in the dry cleaning sector is approximately 1,600 (i.e., 200 day/yr
at 8 hr/day) which falls outside the range of operating days per year used in the model (250 to 312
day/yr with mode of 300 day/yr).

The low end of the range, 0.8, was derived from the observation that the weighted average of 200 day/yr
worked (from BLS/Census) is 80% of the standard assumption that a full-time worker works 250 day/yr.
The maximum of 1.0 is appropriate as dry cleaners may be family owned and operated and some
workers may work as much as every operating day. EPA defines the exposure frequency as the number
of operating days (250 to 312 day/yr) multiplied by the fractional days of exposure (0.8 to 1.0).

24 For modeling purposes, the minimum value was set to 249 days per year and the maximum to 313 days per year; however,
these values have a probability of zero; therefore, the true range is from 250 to 312 days per year.

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Appendix N BENCHMARK DOSE MODELING UPDATE FOR
NESTED FETAL DATA FROM ( _

BMD modeling of the nested fetal data for cardiac defects from (Johnson et al. 2003) was done to verify
the BMD modeling results reported in Appendix F.4.2.1 of the EPA 2011 IRIS Toxicological Review
for TCE Appendices (U.S. EPA. 2 ).

1)	BMD modeling was performed using the nested logistic model in BMDS (v3.1.1) with and
without a litter specific covariate to account for intra-litter similarity (litter effects) based on pre-
treatment condition and with and without modeling of intra-litter correlation to account for intra-
litter similarity based on effects during treatment. IRIS also used the nested logistic model with
and without litter specific covariate and intra-litter correlation. Previous modeling from (U.S.
EPA. 201 le) was performed with and without the high dose group dropped, however the model
based on dropping the highest dose was used in the assessment because it had smaller scaled
residuals and predicted expected response values were closer to observed. Therefore, current
modeling was performed without the high dose group. Modeling in (\ v « « \ JO I I e) was
performed using applied dose and two alternative internal dose metrics based on PBPK modeling
(avg amount of TCE metabolized by oxidation/kg3/4-day and AUC for TCE in blood). The same
3 sets of doses were modeled for the current effort. BMRs used for both the IRIS and current
modeling were 10%, 5% and 1% extra risk.

2)	Total weight gain during pregnancy (TWtGn) was used as the litter specific covariate in the
modeling performed for the IRIS assessment. The individual animal data reasonably available
for the current effort included TWtGn for the treated groups, but not for the control group. Based
on the data available, litter size was used as the covariate for the current modeling effort instead
of TWtGn.

3)	P-values reported by an older version of the BMDS software as presented in Table F-6 (U.S.

) for the nested models are incorrect, apparently due to a problem with the software
used at that time, suggesting that the models did not have adequate fit to the data. The exercise
reported in Section F.4.2.1.2 of (	) was performed to show that the p-values were

much higher than indicated in the raw modeling results and that model fit was acceptable.
Calculation of p-values for the nested models in the current version of BMDS follows a
bootstrap methodology similar to that described in Section F.4.2.1.2. of the IRIS
assessment. Because the original p-values in presented in (\ v « « \ JO I I were incorrect,
comparisons of current modeling results to IRIS were only made for AIC, BMD and BMDL. The
p-values from the updated BMD modeling runs are presented for context.

4)	In the previous BMD modeling, the best fitting model as determined by lowest AIC was the
model without litter-specific covariate but with intra-litter correlation. This was true for the
current modeling as well.

5)	Results from the models without litter-specific covariate, including the best-fitting model,
closely matched the results from the IRIS assessment (see Table Apx N-l).

6)	Results for the models that included the litter-specific covariate differed from the IRIS results,
because a different covariate was used (litter size rather than TWtGn, due to missing data).

7)	Model fits (AICs) and BMD/BMDL values are identical (within rounding error) between the
updated modeling results and those reported in (	)

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TableApx N-l. Results for Best-Fitting Model in Comparison to Results
Reported in IRIS (U.S. EPA. 201 le) (Highlighted)

Model

Covariate

Intra-litter
Correlation

Dose Metric

BMR

AIC

p-valued

BMD

BMDL

Nested
Logistic

Not Used

Modeled

Applied Dose3

0.10

243.815

0.665

0.71114

0.227675











243.815

NR

0.71114

0.227675









0.05

243.815

0.641

0.336856

0.107846











243.815

NR

0.336856

0.107846









0.01

243.815

0.661

0.064649

0.020698











243.815

NR

0.064649

0.020698







T otOxMetabBW 3 4b

0.10

243.816

0.642

0.489388

0.156646











243.815

NR

0.489442

0.156698









0.05

243.816

0.642

0.231816

0.074201











ND

NR

ND

ND









0.01

243.816

0.636

0.04449

0.014241











243.815

NR

0.0444948

0.0142453







AUCCBldc

0.10

243.816

0.656

0.022279

0.00713











243.816

NR

0.0222789

0.00712997









0.05

243.816

0.656

0.010553

0.003377











ND

NR

ND

ND









0.01

243.816

0.656

0.002025

0.000648











243.816

NR

0.00202535

.000648179

a0, 0.00045, 0.048, 0.218 mg/kg-day

bTotal oxidative metabolism scaled by body weight to the 3/4-power: 0, 0.00031, 0.033, 0.15
°AUC of TCE in blood: 0, 0.0000141, 0.00150254, 0.00682727

d p-values from the 2011 IRIS Assessment are not reported because the original values were incorrect.
ND = no data

NR = not relevant; original p-values as calculated by BMDS software in 2011 were incorrect

2587

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Appendix O CONSIDERATIONS FOR BMD MODELING AND
APPLICATION OF UNCERTAINTY FACTORS

A set of dose-response models were applied to empirically model the dose-response relationship in the
range of the observed data. The models in EPA's Benchmark Dose Software were applied. Consistent
with EPA's Benchmark Dose Technical Guidance Document (	2012a). the benchmark dose

(BMD) and 95% lower confidence limit on the BMD (BMDL) were estimated using a benchmark
response (BMR) to represent a minimal, biologically significant level of change, when possible. The
BMR is represented by a specified percentage change, or relative deviation (RD), for continuous data.
The BMR for dichotomous data is represented by a specified incidence, or extra risk (ER). In the
absence of information regarding the level of change that was considered biologically significant, a
BMR of 1 standard deviation (SD) from the control mean for continuous data or a BMR of 10% ER for
dichotomous data was used to estimate the BMD and BMDL, and to facilitate a consistent basis of
comparison across endpoints, studies, and assessments. Endpoint-specific BMRs are described further
below. Where modeling was feasible, the estimated BMDLs were used as points of departure (PODs).
Further details, including the modeling output and graphical results for the model selected for each
endpoint, can be found in the 2011 EPA IRIS Assessment (	) and Appendix G (for

(Selerade and Gilmour. 2010)). A comparison of results from updated BMDL modeling runs with
results from (	) for (Johnson et ai. 2003) are provided in Appendix N. Where dose-

response modeling was not feasible, NOAELs or LOAELs were also identified and are summarized.

O.l Selecting the BMD model to use for POD computation

The following approach is recommended for selecting the model(s) to use for computing the BMDL to
serve as the POD for a specific dataset according to EPA Benchmark Dose Guidance (

2012a).

1)	Assess goodness-of-fit, using a value of a = 0.1 to determine a critical value (or a = 0.05 or a = 0.01)
if there is reason to use a specific model(s) rather than fitting a suite of models.

2)	Further reject models that apparently do not adequately describe the relevant low- dose portion of the
dose-response relationship, examining residuals and graphs of models and data.

3)	As the remaining models have met the recommended default statistical criteria for adequacy and
visually fit the data, any of them theoretically could be used for determining the BMDL. The remaining
criteria for selecting the BMDL are necessarily somewhat arbitrary and are suggested as defaults.

4)	If the BMDL estimates from the remaining models are sufficiently close (given the needs of the
assessment), reflecting no particular influence of the individual models, then the model with the lowest
Akaike's Information Criteria (AIC)25 may be used to calculate the BMDL for the POD. This criterion is
intended to help arrive at a single BMDL value in an objective, reproducible manner. If two or more
models share the lowest AIC, the simple average or geometric mean of the BMDLs with the lowest AIC
may be used. Note that this is not the same as "model averaging", which involves weighing a fuller set
of adequately fitting models. In addition, such an average has drawbacks, including the fact that it is not
a 95%) lower bound (on the average BMD); it is just the average of the particular BMDLs under
consideration (i.e., the average loses the statistical properties of the individual estimates).

25

Akaike's Information Criteria—a measure of information loss from a dose-response model that can be used to
compare a set of models. Among a specified set of models, the model with the lowest AIC is considered the best. If two or
more models share the lowest AIC, an average of the BMDLs could be used, but averaging was not used in this assessment
because for the one occasion in which models shared the lowest AIC, a selection was made based on visual fit.

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5)	If the BMDL estimates from the remaining models are not sufficiently close, some model dependence
of the estimate can be assumed. Expert statistical judgment may help at this point to judge whether
model uncertainty is too great to rely on some or all of the results. If the range of results is judged to be
reasonable, there is no clear remaining biological or statistical basis on which to choose among them,
and the lowest BMDL may be selected as a reasonable conservative estimate. Additional analysis and
discussion might include consideration of additional models, the examination of the parameter values for
the models used, or an evaluation of the BMDs to determine if the same pattern exists as for the
BMDLs. Discussion of the decision procedure should always be provided.

6)	In some cases, modeling attempts may not yield useful results. When this occurs and the most
biologically relevant effect is from a study considered adequate but not amenable to modeling, the
NOAEL (or LOAEL) could be used as the POD. The modeling issues that arose should be discussed in
the assessment, along with the impacts of any related data limitations on the results from the alternate
NOAEL/LOAEL approach.

0.2 Uncertainty Factor Selection

After the PODs were determined for each study/endpoint, uncertainty factors (UFs) were used to derive
acceptable benchmark margins of mxposure (MOEs). UFs are used to address differences between study
conditions and conditions of human environmental exposure. These include:

(a)	Extrapolating from laboratory animals to humans (UFa):

If a POD is derived from experimental animal data, it is divided by an UF to reflect pharmacokinetic and
pharmacodynamic differences that may make humans more sensitive than laboratory animals. For oral
exposures, the standard value for the interspecies UF is 10, which breaks down (approximately) to a
factor of 3 for pharmacokinetic differences (which is removed if the PBPK model is used) and a factor
of 3 for pharmacodynamic differences. For inhalation exposures, ppm equivalence across species is
generally assumed or other cross-species scaling is performed, in accordance with U.S. EPA inhalation
dosimetry guidance (	)), in which case, residual pharmacokinetic differences are

considered to be negligible. Therefore, the standard value used for the interspecies UF is 3, which is
ascribed to pharmacodynamic differences. These standard values were used for all of the PODs based on
laboratory animal data in this assessment.

(b)	Human (intraspecies) variability (UFh):

Sensitive humans could be adversely affected at lower exposures than a general study
population; consequently, PODs from general-population studies are divided by an UF to address
sensitive humans. Similarly, the animals used in most laboratory animal studies are considered to be
typical or average responders, and the human (intraspecies) variability UF is also applied to PODs from
such studies to address sensitive subgroups. The standard value for the human variability UF is 10,
which breaks down (approximately) to a factor of 3 for pharmacokinetic variability (which is removed if
the PBPK model is used) and a factor of 3 for pharmacodynamic variability. This standard value was
used for all of the PODs in this assessment.

(c)	Uncertainty in extrapolating from subchronic to chronic exposures (UFs):26

Chronic risk estimates apply to long-term exposure over decades, but sometimes the best (or only)
reasonably available data come from less-than-lifetime studies. Lifetime exposure can induce effects

26 Chronic exposure covers > 10% of expected lifetime. Rodent studies exceeding 90 days of exposure are considered
chronic, and rodent studies covering from 4 weeks to 90 days of exposure are considered subchronic. For human studies,
chronic exposure exceeds 7-8years, on average (U.S. EPA. 1994b').

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that may not be apparent or as large in magnitude in a shorter study; consequently, a dose that elicits a
specific level of response from a lifetime exposure may be less than the dose eliciting the same level of
response from a shorter exposure period. Thus, PODs based on subchronic exposure data are generally
divided by a subchronic-to-chronic UF, which has a standard value of 10. If there is evidence suggesting
that exposure for longer time periods does not increase the magnitude of an effect, a lower value of 3 or
one might be used. For some reproductive and developmental effects, chronic exposure is that which
covers a specific window of exposure that is relevant for eliciting the effect, and subchronic exposure
would correspond to an exposure that is notably less than the full window of exposure.

(d) Uncertainty in extrapolating from LOAELs to NOAELs (UFl):

PODs are intended to be estimates of exposure levels without appreciable risk under the study
conditions so that, after the application of appropriate UFs for interspecies extrapolation, human
variability, and/or duration extrapolation, the absence of appreciable risk is conveyed. Under the
NOAEL/LOAEL approach to determining a POD, however, adverse effects are sometimes observed at
all study doses. If the POD is a LOAEL, then it is divided by an UF to better estimate a NOAEL. The
standard value for the LOAEL-to-NOAEL UF is 10, although a value of 3 is sometimes used if the
effect is considered minimally adverse at the response level observed at the LOAEL or is an early
marker for an adverse effect. For NOAEL or BMDL values, the UFl is 1.

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Appendix P OCCUPATIONAL INHALATION EXPOSURE AND
WATER RELEASE ASSESSMENT

P.l Manufacturing

P.l.l Exposure Assessment

EPA assessed inhalation exposures during manufacturing using identified inhalation exposure
monitoring data. TableApx P-l summarizes 8-hr TWA samples obtained from data submitted by the
Halogenated Solvents Industry Alliance (HS1A) via public comment for one company (Halosenated
Solvents Industry Alliance.	) listed as "Company B". HS1A also provided "General 12-hr"

full-shift exposure data from "Company A". However, "Company A" data points were listed as "Not
detected <0.062 ppm. Two additional studies with monitoring data for manufacturing were identified;
however, the data from these studies were not used as the data were from China and almost 30 years old
and are unlikely to be representative of current conditions at U.S. manufacturing sites. No data was
found to estimate ONU exposures during TCE manufacturing. EPA estimates that ONU exposures are
lower than worker exposures, since ONUs do not typically directly handle the chemical.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 16 data points from 1 source, and the
data quality ratings from systematic review for these data were high. The primary limitations of these
data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium to high.

Table Apx P-l. Summary of Worker Inhalation Exposure Monitoring Data from TCE
Manufacturing	

SiTiuirio

8-hr TWA
(ppm)

AC
(ppm)

ADC
(ppm)

LADC
(ppm)

Nil m ho
i- ol"

Diilii
Points

CoiiIkIciht
killing of Air
Concent nilion
D;il:i

High-End

2.59

0.86

0.59

0.30

16

High

Central
Tendency

0.38

0.13

0.09

0.03

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.
Source: (Halogenated Solvents Industry Alliance. 20.1.8 5176415")

P.1.2 Water Release Assessment

In general, potential sources of water releases in the chemical industry may include the following:
equipment cleaning operations, aqueous wastes from scrubbers/decanters, reaction water, process water
from washing intermediate products, and trace water settled in storage tanks (OE	). Based on

the process for manufacturing TCE, EPA expects the sources of water releases to be from aqueous
wastes from decanters used to separate catalyst fines, caustic neutralizer column, and caustic scrubbers;

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and water removed from the TCE product in drying columns (Most 1989). Additional water releases
may occur if a site uses water to clean process equipment; however, EPA does not expect this to be a
primary source of water releases from manufacturing sites as equipment cleaning is not expected to
occur daily and manufacturers would likely use an organic solvent to clean process equipment.

Of the five manufacturing sites assessed, three reported in the 2016 TRI (one of these three sites
reported zero water releases to TRI). Additionally, one of these sites also reported to 2016 DMR. For the
sites that reported water releases, EPA assessed water releases as reported in the 2016 TRI and 2016
DMR. For the remaining two sites, EPA assessed water releases at the maximum daily and maximum
average monthly concentrations allowed under the Organic Chemicals, Plastics and Synthetic Fibers
(OCPSF) Effluent Guidelines (EG) and Standards (40 C.F.R. Part 414) (U.S. EPA. 2019g). The OCPSF
EG applies to facilities classified under the following SIC codes:

•	2821—Plastic Materials, Synthetic Resins, and Nonvulcanizable Elastomers;

•	2823—Cellulosic Man-Made Fibers;

•	2865—Cyclic Crudes and Intermediates, Dyes, and Organic Pigments; and

•	2869—Industrial Organic Chemicals, Not Elsewhere Classified.

Manufacturers of TCE would typically be classified under SIC code 2869; therefore, the requirements of
the OCPSF EG apply to these sites. Subparts I, J, and K of the OCPSF EG set limits for the
concentration of TCE in wastewater effluents for industrial facilities that are direct discharge point
sources using end-of-pipe biological treatment, direct discharge point sources that do not use end-of-
pipe biological treatment, and indirect discharge point sources, respectively 40 C.F.R. Part 414 (U.S.
EPA, 2019»). Direct dischargers are facilities that discharge effluents directly to surface waters and
indirect dischargers are facilities that discharge effluents to publicly-owned treatment works (POTW).
The OCPSF limits for TCE are provided in Table Apx P-2.

Table Apx P-2. Summary of OC

>SF Effluent Limitations for Trichloroethylene

OCPSF Subpart

Maximum
for Any One
Day
(^g/L)

Maximum for
Any Monthly
Average
(^g/L)

Basis

Subpart I - Direct Discharge
Point Sources That Use End-of-
Pipe Biological Treatment

54

21

BAT effluent limitations and
NSPS

Subpart J - Direct Discharge
Point Sources That Do Not Use
End-of-Pipe Biological Treatment

69

26

BAT effluent limitations and
NSPS

Subpart K - Indirect Discharge
Point Sources

69

26

Pretreatment Standards for
Existing Sources (PSES) and
Pretreatment Standards for New
Sources (PSNS)

BAT = Best Available Technology Economically Achievable; NSPS = New Source Performance Standards; PSES =
Pretreatment Standards for Existing Sources; PSNS = Pretreatment Standards for New Sources.

Source: (U.S. EPA. 2019a)

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EPA did not identify TCE-specific information on the amount of wastewater produced per day. The
Specific Environmental Release Category (SpERC) developed by the European Solvent Industry Group
for the manufacture of a substance estimates 10 m3 of wastewater generated per metric ton of substance
produced (ESIG. 2012). In lieu of TCE-specific information, EPA estimated water releases using the
SpERC specified wastewater production volume and the annual TCE production rates from each facility.

EPA estimated both a maximum daily release and an average daily release using the OCPSF EG
limitations for TCE for maximum on any one day, and maximum for any monthly average, respectively.
Prevalence of end-of-pipe biological treatment at TCE manufacturing sites is unknown; therefore, EPA
used limitations for direct discharges with no end-of-pipe biological treatment and indirect dischargers
to address the uncertainty at these sites. EPA estimated annual releases from the average daily release
and assuming 350 days/yr of operation.27

TableApx P-3 summarizes water releases from the manufacturing process for sites reporting to TRI and
TableApx P-4 summarizes water releases from sites not reporting to TRI. The estimated total annual
release across all sites is 60.5 - 453.6 kg/yr discharged to surface water or POTWs.

Table Apx P-3. Reported Water Releases of Trichloroethylene from Manufacturing Sites
Reporting to 2016 TRI						

Site

Annual

Release3
(kg/site-yr)

Annual
Release

Days
(days/yr)

Average

Daily
Release3
(kg/site-day)

NPDES Code

Release
Media

Olin Blue Cube, Freeport,
TX

24

350

0.07

TX0059447

non-POTW
WWT

Geon Oxy Vinyl Laporte
Plant,

Laporte, TX

0

N/A

0

TX0070416

N/A

Axiall Corporation dba
Eagle US 2 LLC,
Westlake, LAb

49.9-443°

350

0.14-1.27

LA0000761d

Surface
Water

POTW = Publicly-Owned Treatment Works; WWT = Wastewater Treatment; N/A = Not applicable
a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual
release rate and assuming 300 days of operation per year.

b Axiall was purchased by Westlake Chemical in 2016. The site at 1300 PPG Drive Westlake, LA dba Eagle US 2 LLC.
°First value based on 2016 TRI, second value based on 2016 DMR data (U.S. EPA. 2016a).
dBased on Eagle US 2 LLC NPDES Permit provided in DMR Data (U.S. EPA. 2016a).

27 Due to large throughput manufacturing sites are assumed to operate seven days per week and 50 weeks per year with two
weeks per year for shutdown activities.

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2797

2798	TableApx P-4. Estimated Water Releases of Trichloroethylene from Manufacturing Sites Not

2799	Reporting to 2016 TRI						

Site

Annual
Operating

Days
(days/yr)

Daily
Production
Volume3
(kg/site-
day)

Daily
Wastewater

Flowb
(L/site-day)

Maximum

Daily
Release0
(kg/site-
day)

Average

Daily
Released
(kg/site-
day)

Average
Annual
Release6
(kg/site-
yr)

NPDES
Code

Release
Media

Solvents &
Chemicals,
Pearland,
TX

350

58,234

582,345

0.04

0.02

5.3

Not
available

Surface
Water

or
POTW

Occidental

Chemical

Corp.

Wichita,

KS

350

58,234

582,345

0.04

0.02

5.3

Not
available

Surface
Water

or
POTW

2800	POTW = Publicly-Owned Treatment Works

2801	a Daily production volume calculated using the annual production volume and dividing by the annual operating days per year

2802	(300 days/yr).

2803	b The estimated wastewater flow rate is calculated assuming 10 m3 of wastewater is produced per metric ton of TCE

2804	produced (equivalent to 10 L wastewater/kg of TCE) based on the SpERC for the manufacture of a substance (ES1G. 2012).

2805	0 The maximum daily release is calculated using the maximum daily concentration from the OCPSF EG, 26 |ig/L. and

2806	multiplying by the daily wastewater flow.

2807	d The average daily release is calculated using the maximum monthly average concentration from the OCPSF EG, 69 |ig/L.

2808	and multiplying by the daily wastewater flow.

2809	e The average annual release is calculated as the maximum monthly average concentration multiplied by the daily wastewater

2810	production and 350 operating days/year.

2811

2812	P.2 Processing as a Reactant

2813	P.2.1 Exposure Assessment

2814	EPA did not identify inhalation exposure monitoring data related processing TCE as a reactant.

2815	Therefore, EPA used monitoring data from the manufacture of TCE as surrogate. EPA believes the

2816	handling and TCE concentrations for both conditions of use to be similar. However, EPA is unsure of

2817	the representativeness of these surrogate data toward actual exposures to TCE at all sites covered by this

2818	condition of use.

2819

2820	EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results

2821	to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths

2822	include the assessment approach, which is the use of surrogate monitoring data, in the middle of the

2823	inhalation approach hierarchy. These monitoring data include 16 data points from 1 source, and the data

2824	quality ratings from systematic review for these data were medium. The primary limitations of these

2825	data include the uncertainty of the representativeness of these surrogate data toward the true distribution

2826	of inhalation concentrations for the industries and sites covered by this scenario. Based on these

2827	strengths and limitations of the inhalation air concentration data, the overall confidence for these 8-hr

2828	TWA data in this scenario is medium to low.

2829

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The surrogate data was obtained from (HSIA) via public comment (Halogenated Solvents Industry
Alliance. 2018 51764151 presented in Table_Apx P-5 below. No data was found to estimate ONU
exposures during use of TCE as a reactant. EPA estimates that ONU exposures are lower than worker
exposures, since ONUs do not typically directly handle the chemical.

TableApx P-5. Summary of Worker Inhalation Exposure Surrogate Monitoring Data from TCE
Use as a Reactant

Scenario

8-hr TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Numbe
r of
Data
Points

Confidence
Rating of
Associated Air
Concentration
Data

High-End

2.59

0.86

0.59

0.30

16

Medium

Central
Tendency

0.38

0.13

0.09

0.03

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

P.2.2 Water Release Assessment

In general, potential sources of water releases in the chemical industry may include the following:
equipment cleaning operations, aqueous wastes from scrubbers/decanters, reaction water, process water
from washing intermediate products, and trace water settled in storage tanks (OECD, 2019). Based on
the use as a reactant, EPA expects minimal sources of TCE release to water.

Two of the three sites reporting to TRI did not report any water releases of TCE; the other TRI site
reported 13 lb/yr (5.9 kg/yr) released to water. For the two sites found through DMR data, total water
releases were calculated to be approximately 11 lb/yr (5 kg/yr). Based on the information for these 5
sites, an average annual release of approximately 2.2 kg/site-yr was calculated. Using this estimate, and
assuming 440 sites as a high-end estimate, the total TCE water discharge from these 440 sites equal
approximately 968 kg/yr. Table Apx P-6 summarizes the low and high end water release estimates.

Table Apx P-6. Water Release Estimates for Sites Using TCE as a I

teactant

Number of Sites

Annual
Release
(kg/site-yr)

Annual
Release Days
(days/yr)

Daily

Release
(kg/site-day)

NPDES
Code

Release Media

Low End Number of Sites

Arkema Inc., Calvert City, KY

5.9

350

0.02

KY0003603

Surface Water

Honeywell International -
Geismar Complex, Geismar,
LA

4.5

350

0.01

LA0006181

Surface Water

Praxair Technology Center,
Tonawanda, NY

0.6

350

1.7E-03

NY0000281

Surface Water

High End Number of Sites

440 unknown sites

2.2a

350

6.3E-03

N/A

Surface Water
orPOTW

a Calculated from the total yearly water releases of TCE from DMR and TRI data, and diving by the number of reporting sites
(5 sites). Mexichem Fluor Inc. and Halocarbon Products Corp reported no water releases to TRI.

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P.3 Formulation of Aerosol and Non-Aerosol Products

P.3.1 Exposure Assessment

EPA did not identify inhalation exposure monitoring data related using TCE when formulating aerosol
and non-aerosol products. Therefore, EPA used monitoring data from repackaging as a surrogate, as
EPA believes the handling and TCE concentrations for both conditions of use to be similar. However,
EPA is unsure of the representativeness of these surrogate data toward actual exposures to TCE at all
sites covered by this condition of use.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of surrogate monitoring data, in the middle of the
inhalation approach hierarchy. These monitoring data include 33 data points from 1 source, and the data
quality ratings from systematic review for these data were high. The primary limitations of these data
include the uncertainty of the representativeness of these surrogate data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium.

TableApx P-7 summarizes the 8-hr TWA from monitoring data from unloading/loading TCE from bulk
containers. The data were obtained from a Chemical Safety Report (DOW Deutschland. 2014b). No data
was found to estimate ONU exposures during formulation of aerosol and non-aerosol products. EPA
estimates that ONU exposures are lower than worker exposures, since ONUs do not typically directly
handle the chemical.

Table Apx P-7. Summary of Worker Inhalation Exposure Monitoring Data for Unloading TCE

Scenario

8-hr TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of
Data Points

Confidence
Rating of Air
Concentration
Data

High-End

1.1

0.4

0.3

0.1

33

Medium

Central
Tendency

4.9E-4

1.6E-4

1.1E-4

4.5E-5

AC= Acute Exposure and ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

P.3.2 Water Release Assessment

In general, potential sources of water releases in the chemical industry may include the following:
equipment cleaning operations, aqueous wastes from scrubbers/decanters, reaction water, process water
from washing intermediate products, and trace water settled in storage tanks (OECD. 2019). Based on
the use in formulations and the amount of TCE used for this condition of use, EPA expects minimal
sources of TCE release to water.

None of the sites reporting to TRI reported any water releases of TCE. All releases were to off-site land,
incineration or recycling. Based on this information, EPA does not have enough information to estimate
water releases of TCE for this condition of use.

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P.4 Repackaging

P.4.1 Exposure Assessment

EPA identified inhalation exposure monitoring data related unloading/loading TCE into/from bulk
transport containers. TableApx P-8 summarizes the 8-hr TWA from monitoring data from
unloading/loading TCE from bulk containers. The data were obtained from a Chemical Safety Report
(DOW Deutschland. 2014b). It should be noted that this study indicates that the filling system uses a
"largely automated process" (DOW Deutschland. 2014b). Therefore, EPA is unsure of the
representativeness of these data toward actual exposures to TCE for all sites covered by this condition of
use.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 33 data points from 1 source, and the
data quality ratings from systematic review for these data were high. The primary limitations of these
data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium to high.

No data was found to estimate ONU exposures during formulation of aerosol and non-aerosol products.
EPA estimates that ONU exposures are lower than worker exposures, since ONUs do not typically
directly handle the chemical.

Table Apx P-8. Summary of Worker Inhalation Exposure Monitoring Data for
Unloading/Loading TCE from Bulk Containers			

Scenario

8-hr TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of
Data Points

Confidence
Rating of Air
Concentration
Data

High-End

1.1

0.4

0.26

0.1

33

Medium to High

Central
Tendency

4.9E-4

1.6E-4

1.1E-4

4.5E-5

AC= Acute Exposure and ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

P.4.2 Water Release Assessment

EPA expects the primary source of water releases from repackaging activities to be from the use of
water or steam to clean bulk containers used to transport TCE or products containing TCE. EPA expects
the use of water/steam for cleaning containers to be limited at repackaging sites as TCE is an organic
substance and classified as a hazardous waste under RCRA. EPA expects the majority of sites to use
organic cleaning solvents which would be disposed of as hazardous waste (incineration or landfill) over
water or steam.

Water releases during repackaging were assessed using data reported in the 2016 DMR and 2016 TRI.
One of the 20 sites reporting to TRI reported water releases of TCE to off-site wastewater treatment. All
other sites reporting to TRI reported releases to off-site land or incineration. EPA assessed annual

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releases as reported in the 2016 DMR and assessed daily releases by assuming 250 days of operation per
year. A summary of the water releases reported to the 2016 DMR and TRI can be found in TableApx
P-9.

Table Apx P-9. Reported Water Releases of Trichloroethylene from Sites Repackaging TCE

Site Identity

Annual
Release
(kg/site-
yr)a

Annual Release
Days (days/yr)

Daily Release
(kg/site-day)a

NPDES
Code

Release
Media

Hubbard-Hall Inc. Waterbury,
CT

277

250

1.1

Not
available

Non-POTW
WWT

St. Gabriel Terminal, Saint
Gabriel, LA

1.4

250

5.5E-03

LA0052353

Surface
Water

Vopak Terminal Westwego
Inc, Westwego, LA

1.2

250

4.7E-03

LAO 124583

Surface
Water

Oiltanking Houston Inc,
Houston, TX

0.8

250

3.3E-03

TX0091855

Surface
Water

Research Solutions Group Inc,
Pelham, AL

0.01

250

3.3E-05

AL0074276

Surface
Water

Carlisle Engineered Products
Inc, Middlefield, OH

1.7E-3

250

6.8E-06

OH0052370

Surface
Water

release rate and assuming 250 days of operation per year.
Sources: (U.S. EPA. 2016a) and "(U.S. EPA. 2017c)'

, daily releases are back-calculated from the annual

P.5 Batch Open Top Vapor Degreasing

P.5.1 Exposure Assessment

EPA identified inhalation exposure monitoring data from NIOSH investigations at twelve sites using
TCE as a degreasing solvent in OTVDs. Due to the large variety in shop types that may use TCE as a
vapor degreasing solvent, it is unclear how representative these data are of a "typical" shop. Therefore,
EPA supplemented the identified monitoring data using the Open-Top Vapor Degreasing Near-
Field/Far-Field Inhalation Exposure Model. The following subsections detail the results of EPA's
occupational exposure assessment for batch open-top vapor degreasing based on inhalation exposure
monitoring data and modeling.

Table Apx P-10 summarizes the 8-hr TWA monitoring data for the use of TCE in OTVDs. The data
were obtained from NIOSH Health Hazard Evaluation reports (HHEs). NIOSH HHEs are conducted at
the request of employees, employers, or union officials, and provide information on existing and
potential hazards present in the workplaces evaluated (Daniels et al.. 19881 (Ruhe et al.. 1981). (Barsan.
1991). (Ruhe. 1982). (Rosensteel and Lucas. 1975). (Seitz and Driscoll. 1989). (Gorman et al.. 1984).
(Gilles et al.. 1977). (Vandervort and Polakoff. 1973). and (Lewis. 1980).

Data from these sources cover exposures at several industries including metal tube production, valve
manufacturing, jet and rocket engine manufacture, air conditioning prep and assembly, and AC motor
parts (Ruhe et al.. 1981). (Barsan. 1991). (Rosensteel and Lucas. 1975). (Gorman et al.. 1984).
(Vandervort and Polakoff. 1973). and (Lewis. 1980). Except for one site, sample times ranged from
approximately five to eight hours (Ruhe et al.. 1981). (Barsan. 1991). (Rosensteel and Lucas. 1975).
(Gorman et al.. 1984). and (Lewis. 1980). The majority of samples taken at the other site were taken for
2 hours or less (Vandervort and Polakoff. 1973). Where sample times were less than eight hours, EPA
converted to an 8-hr TWA assuming exposure outside the sample time was zero. For sample times

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greater than eight hours, EPA left the measured concentration as is. It should be noted that additional
sources for degreasing were identified but were not used in EPA's analysis as they either: 1) did not
specify the machine type in use; or 2) only provided a statistical summary of worker exposure
monitoring.

TableApx P-10. Summary of Worker Inhalation Exposure Monitoring Data for Batch Open-Top
Vapor Degreasing 						

Scenario

8-hr
TWA
(PPm)

AC
(PPm)

ADC

(ppm)

LADC

(ppm)

Number
of Data
Points

Confidence Rating
of Air
Concentration
Data

Workers

High-End

77.8

25.9

17.8

9.1

113

Medium

Central Tendency

13.8

4.6

3.2

1.3

Occupational non-users

High-End

9.1

3.0

2.1

1.1

10

Medium

Central Tendency

1.1

0.4

0.3

0.1

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 123 data points from 16 sources, and
the data quality ratings from systematic review for these data were medium. The primary limitations of
these data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium.

EPA also considered the use of modeling, which is in the middle of the inhalation approach hierarchy. A
Monte Carlo simulation with 100,000 iterations was used to capture the range of potential input
parameters. Vapor generation rates were derived from TCE unit emissions and operating hours reported
in the 2014 National Emissions Inventory. The primary limitations of the air concentration outputs from
the model include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Added uncertainties
include that the underlying methodologies used to estimate these emissions in the 2014 NEI are
unknown. Based on these strengths and limitations of the air concentrations, the overall confidence for
these 8-hr TWA data in this scenario is medium to low.

Figure Apx P-l illustrates the near-field/far-field model that can be applied to open-top vapor
degreasing (ATHA. 2009). As the figure shows, volatile TCE vapors evaporate into the near-field,
resulting in worker exposures at a concentration Cnf. The concentration is directly proportional to the
evaporation rate of TCE, G, into the near-field, whose volume is denoted by Vnf. The ventilation rate
for the near-field zone (Qnf) determines how quickly TCE dissipates into the far-field, resulting in
occupational non-user exposures to TCE at a concentration Cff. Vff denotes the volume of the far-field
space into which the TCE dissipates out of the near-field. The ventilation rate for the surroundings,

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denoted by Qff, determines how quickly TCE dissipates out of the surrounding space and into the
outside air.

	Far-Field	

FigureApx P-l. Schematic of the Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation
Exposure Model

To estimate the TCE vapor generation rate, the model developed a distribution from the reported annual
emission rates and annual operating times reported in the 2014 NEI. NEI records where the annual
operating time was not reported were excluded from the distribution.

Batch degreasers are assumed to operate between two and 24 hours per day, based on NEI data on the
reported operating hours for OTVD using TCE. EPA performed a Monte Carlo simulation with 100,000
iterations and the Latin Hypercube sampling method in @Risk to calculate 8-hour TWA near-field and
far-field exposure concentrations. Near-field exposure represents exposure concentrations for workers
who directly operate the vapor degreasing equipment, whereas far-field exposure represents exposure
concentrations for occupational non-users (i.e., workers in the surrounding area who do not handle the
degreasing equipment).

Table Apx P-l 1 presents a statistical summary of the exposure modeling results. These exposure
estimates represent modeled exposures for the workers and occupational non-users. For workers, the
50th percentile exposure is 34.8 ppm 8-hr TWA, with a 95th percentile of 388 ppm 8-hr TWA.

Both of these values are an order of magnitude higher than identified in the monitoring data. This may
be due to the limited number of sites from which the monitoring data were taken whereas the model is
meant to capture a broader range of scenarios. It is also uncertain of the underlying methodologies used
to estimate emissions in the 2014 NEI data.

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Percentile

8-hr TWA

(PPm)

ACa

(PPm)

ADC

(PPm)

LADC

(PPm)

Confidence Rating of Air
Concentration Data

Workers (Near-field)

High-End

388

129.3

88.5

35.3

N/A - Modeled Data

Central
Tendency

34.8

79.0

8.0

3.0

Occupational non-users (Far-Field)

High-End

237

79.0

54.0

21.1

N/A - Modeled Data

Central
Tendency

18.1

6.0

4.1

1.5

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.
a Acute exposures calculated as a 24-hr TWA.

P.5.2 Water Release Assessment

The primary source of water releases from OTVDs is wastewater from the water separator. Water in the
OTVD may come from two sources: 1) Moisture in the atmosphere that condenses into the solvent when
exposed to the condensation coils on the OTVD; and/or 2) steam used to regenerate carbon adsorbers
used to control solvent emissions on OTVDs with enclosures (Durkee. 2014; Kanegsberg and
Kanegsberg. 2011; NIOSH. 2002a. b, c, d). The water is removed in a gravity separator and sent for
disposal (NIOSH. 2002a. b, c, d). The current disposal practices of the wastewater are unknown;
however, a 1982 EPA (Gilbert et al.. 1982) report estimated 20% of water releases from metal cleaning
(including batch systems, conveyorized systems, and vapor and cold systems) were direct discharges to
surface water and 80% of water releases were discharged indirectly to a POTW.

Water releases for OTVDs were assessed using data reported in the 2016 TRI and 2016 DMR. Due to
limited information in these reporting programs, these sites may in fact not operate OTVDs, but may
operate other solvent cleaning machines or perform metalworking activities. They are included in the
OTVD assessment as EPA expects OTVDs to be the most likely condition of use. EPA assessed annual
releases as reported in the 2016 TRI or 2016 DMR and assessed daily releases by assuming 260 days of
operation per year, as recommended in the 2017 ESD on Use of Vapor Degreasers, and averaging the
annual releases over the operating days. A summary of the water releases reported to the 2016 TRI and
DMR can be found in TableApx P-12.

TableApx P-12. Reported Water Releases of Trichloroethylene from Sites Using TCE in Open-
Top Vapor Degreasing					

Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)

NPDES
Code

Release Media

US Nasa Michoud Assembly
Facility, New Orleans, LA

509

260

1.96

LA0052256

Surface Water

GM Components Holdings LLC,
Lockport, NY

34.2

260

0.13

NY0000558

Surface Water

Akebono Elizabethtown Plant,
Elizabethtown KY

17.9

260

0.07

KY0089672

Surface Water

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Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)

NPDES
Code

Release Media

Delphi Harrison Thermal
Systems, Dayton. OH

9.3

260

0.04

OH0009431

Surface Water

Chemours Company Fc LLC,
Washington. WV

6.7

260

0.03

WV0001279

Surface Water

Equistar Chemicals LP, La
Porte, TX

4.4

260

0.02

TX0119792

Surface Water

GE Aviation, Lynn, MA

2.6

260

0.01

MA0003905

Surface Water

Certa Vandalia LLC, Vandalia,
OH

2.1

260

0.01

OHO 122751

Surface Water

GM Components Holdings LLC
Kokomo Ops, Kokomo, IN

1.7

260

0.01

IN0001830

Surface Water

Amphenol Corp-Aerospace
Operations, Sidney, NY

1.6

260

0.01

NY0003824

Surface Water

Emerson Power Trans Corp,
Maysville, KY

1.6

260

0.01

KY0100196

Surface Water

Olean Advanced Products,
Olean NY

1.4

260

0.01

NY0073547

Surface Water

Texas Instruments, Inc.,
Attleboro, MA

1.3

260

5.18E-03

MA0001791

Surface Water

Hollingsworth Saco Lowell,
Easley, SC

1.2

260

4.69E-03

SC0046396

Surface Water

Trelleborg YSH Incorporated
Sandusky Plant, Sandusky, MI

0.9

260

3.60E-03

MI0028142

Surface Water

Timken Us Corp Honea Path,
Honea Path, SC

0.9

260

3.55E-03

SC0047520

Surface Water

Johnson Controls Incorporated,
Wichita, KS

0.6

260

2.28E-03

KS0000850

Surface Water

Accellent Inc/Collegeville
Microcoax, Collegeville, PA

0.6

260

2.22E-03

PA0042617

Surface Water

National Railroad Passenger
Corporation (Amtrak)
Wilmington Maintenance
Facility, Wilmington, DE

0.5

260

2.03E-03

DE0050962

Surface Water

Electrolux Home Products
(Formerly Frigidaire),
Greenville, MI

0.5

260

2.01E-03

MI0002135

Surface Water

Rex Heat Treat Lansdale Inc,
Lansdale, PA

0.5

260

1.94E-03

PA0052965

Surface Water

Carrier Corporation, Syracuse,
NY

0.5

260

1.77E-03

NY0001163

Surface Water

Globe Engineering Co Inc,
Wichita, KS

0.5

260

1.74E-03

KS0086703

Surface Water

Cascade Corp (0812100207),
Springfield, OH

0.3

260

1.17E-03

OH0085715

Surface Water

USAF-Wurtsmith AFB, Oscoda,
MI

0.3

260

1.15E-03

MI0042285

Surface Water

AAR Mobility Systems,
Cadillac, MI

0.3

260

1.12E-03

MI0002640

Surface Water

Eaton Mdh Company Inc,
Kearney, NE

0.3

260

1.07E-03

NE0114405

Surface Water

Motor Components L C, Elmira,
NY

0.3

260

9.64E-04

NY0004081

Surface Water

Salem Tube Mfg, Greenville, PA

0.233

260

8.97E-04

PA0221244

Surface Water

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Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)

NPDES
Code

Release Media

Ametek Inc. U.S. Gauge Div.,
Sellersville, PA

0.227

260

8.72E-04

PA0056014

Surface Water

GE (Greenville) Gas Turbines
LLC, Greenville, SC

0.210

260

8.06E-04

SC0003484

Surface Water

Parker Hannifin Corporation,
Waverly, OH

0.194

260

7.47E-04

OH0104132

Surface Water

Mahle Enginecomponents USA
Inc, Muskegon, MI

0.193

260

7.42E-04

MI0004057

Surface Water

General Electric Company -
Waynesboro, Waynesboro, VA

0.191

260

7.33E-04

VA0002402

Surface Water

Gayston Corp, Dayton, OH

0.167

260

6.43E-04

OHO 127043

Surface Water

Styrolution America LLC,
Channahon, IL

0.166

260

6.37E-04

IL0001619

Surface Water

Remington Arms Co Inc, Ilion,
NY

0.159

260

6.12E-04

NY0005282

Surface Water

Lake Region Medical, Trappe,
PA

0.1

260

5.06E-04

Not available

Surface Water

United Technologies
Corporation, Pratt And Whitney
Division East Hartford, CT

0.1

260

4.80E-04

CT0001376

Surface Water

Atk-Allegany Ballistics Lab
(Nirop), Keyser, WV

0.1

260

4.70E-04

WV0020371

Surface Water

Techalloy Co Inc, Union IL

0.1

260

4.27E-04

IL0070408

Surface Water

Owt Industries, Pickens, SC

0.1

260

3.14E-04

SC0026492

Surface Water

Boler Company, Hillsdale, MI

0.1

260

2.69E-04

MI0053651

Surface Water

Mccanna Inc., Carpentersville,
IL

0.1

260

2.68E-04

IL0071340

Surface Water

Cutler Hammer, Horseheads,
NY

0.1

260

2.38E-04

NY0246174

Surface Water

Sperry & Rice Manufacturing
Co LLC, Brookville, IN

8.54E-02

260

3.28E-04

IN0001473

Surface Water

US Air Force Offutt Afb Ne,
Offutt A F B, NE

4.14E-02

260

1.59E-04

NE0121789

Surface Water

Troxel Company, Moscow, TN

3.49E-02

260

1.34E-04

TN0000451

Surface Water

Austin Tube Prod, Baldwin, MI

2.96E-02

260

1.14E-04

MI0054224

Surface Water

LS Starrett Precision Tools,
Athol, MA

2.65E-02

260

1.02E-04

MA0001350

Surface Water

Avx Corp, Raleigh, NC

2.30E-02

260

8.83E-05

NC0089494

Surface Water

Handy & Hannan Tube Co/East
Norriton, Norristown, PA

1.61E-02

260

6.17E-05

PA0011436

Surface Water

Indian Head Division, Naval
Surface Warfare Center, Indian
Head, MD

1.08E-02

260

4.16E-05

MD0003158

Surface Water

General Dynamics Ordnance
Tactical Systems, Red Lion PA

6.34E-03

260

2.44E-05

PA0043672

Surface Water

Trane Residential Solutions -
Fort Smith. Fort Smith. AR

3.46E-03

260

1.33E-05

AR0052477

Surface Water

Lexmark International Inc.,
Lexington KY

3.23E-03

260

1.24E-05

KY0097624

Surface Water

Alliant Teclisystems Operations
LLC, Elkton MD

3.02E-03

260

1.16E-05

MD0000078

Surface Water

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Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)

NPDES
Code

Release Media

Daikin Applied America, Inc.
(Formally Mcquay
International), Scottsboro, AL

2.15E-03

260

8.26E-06

AL0069701

Surface Water

Beechcraft Corporation
Wichita, KS

2.04E-03

260

7.86E-06

KS0000183

Surface Water

Federal-Mogul Corp, Scottsville,
KY

1.50E-03

260

5.78E-06

KY0106585

Surface Water

Cessna Aircraft Co (Pawnee
Facility), Wichita, KS

1.36E-03

260

5.24E-06

KS0000647

Surface Water

N.G.I, Parkersburg, WV

3.43E-04

260

1.32E-06

WV0003204

Surface Water

Hyster-Yale Group, Inc,
Sulligent, AL

2.35E-04

260

9.03E-07

AL0069787

Surface Water

Hitachi Electronic Devices
(USA), Inc., Greenville, SC

6.58E-05

260

2.53E-07

SC0048411

Surface Water

WWT = Wastewater Treatment

a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual

release rate and assuming 260 days of operation per year.

Sources: 2016 TRI (U.S. EPA. 2017c): 2016 DMR (U.S. EPA. 2016a)

Data from TRI and DMR may not represent the entirety of sites using TCE in OTVDs. EPA did not
identify other data sources to estimate water releases from sites not reporting to TRI or DMR. However,
sites operating degreasers are regulated by the following national ELGs:

•	Electroplating Point Source Category Subparts A, B, D, E, F, G, and H (U.S. EPA. 2019d);28

•	Iron and Steel Manufacturing Point Source Category Subpart J (U.S. EPA. 2019e);

•	Metal Finishing Point Source Category Subpart A (U.S. EPA. 2019f);29

•	Coil Coating Point Source Category Subpart D (U.S. EPA. 2019b);

•	Aluminum Forming Point Source Category Subparts A, B, C, D, E, and F (U.S. EPA. 2019a);
and

•	Electrical and Electronic Components Point Source Category Subparts A and B (U.S. EPA.
2019c).

All above ELGs set discharges limits based on the total toxic organics (TTO) concentration in the
wastewater stream and not a specific TCE limit. TTO is the summation of the concentrations for a
specified list of pollutants which may be different for each promulgated ELG and includes TCE for the
above referenced ELGs. Therefore, the concentration of TCE in the effluent is expected to be less than
the TTO limit.

The operation of the water separator via gravity separation is such that the maximum concentration of
TCE leaving the OTVD is equal to the solubility of TCE in water, 1,280 mg/L (Durkee. 2014). In cases
where this concentration exceeds the limit set by the applicable ELGs, EPA expects sites will perform
some form of wastewater treatment for the effluent stream leaving the OTVD to ensure compliance with

28	The Electroplating ELG applies only to sites that discharge to POTW (indirect discharge) that were in operation before
July 15, 1983. Processes that began operating after July 15, 1983 and direct dischargers are subject to the Metal Finishing
ELG (40 C.F.R Part 433).

29	The Metal Finishing ELG do not apply when wastewater discharges from metal finishing operations are already regulated
by the Iron and Steel, Coil Coating, Aluminum Forming, or Electrical and Electronic Components ELGs.

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the ELG prior to discharge. EPA did not identify information on the amount of wastewater generated
from OTVDs to estimate releases from sites not reporting to TRI or DMR.

P.6 Batch Closed-Loop Vapor Degreasing

P.6.1 Exposure Assessment

EPA identified inhalation exposure monitoring data from a European Chemical Safety report using TCE
in closed degreasing operations. However, it is unclear how representative these data are of a "typical"
batch closed-loop degreasing shop. TableApx P-13 summarizes the 8-hr TWA monitoring data for the
use of TCE in vapor degreasers. The data were obtained from a Chemical Safety Report (DOW
Deutschland. 2014a).

Data from these sources cover exposures at several industries where industrial parts cleaning occurred
using vapor degreasing in closed systems. It should be noted that additional sources for degreasing were
identified but were not used in EPA's analysis as they either: 1) did not specify the machine type in use;
or 2) only provided a statistical summary of worker exposure monitoring.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 19 data points from 1 source, and the
data quality ratings from systematic review for these data were high. The primary limitations of these
data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium to high.

Table Apx P-13. Summary of Worker Inhalation Exposure Monitoring Data for Batch Closed-
^oop Vapor Degreasing					

Scenario

8-hr
TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of Data
Points

Confidence
Rating of Air
Concentration
Data

High-End

1.4

0.5

0.3

0.2

19

High

Central
Tendency

0.5

0.2

0.1

0.04

AC = Acute Concentration. ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

P.6.2 Water Release Assessment

Similar to OTVDs, the primary source of water releases from closed-loop systems is wastewater from
the water separator. However, unlike OTVDs, no water is expected to enter the system through
condensation (Durkee. 2014). The reason for this is that enclosed systems flush the work chamber with
water-free vapor (typically nitrogen gas) after the parts to be cleaned are added to the chamber and the
chamber is sealed but before the solvent enters (Durkee. 2014). Multiple flushes can be performed to
reduce the concentration of water to acceptable levels prior to solvent cleaning (Durkee. 2014).
Therefore, the primary source of water in closed-loop systems is from steam used to regenerate carbon
adsorbers (Durkee. 2014; Kanegsberg and Kanegsberg. 2011; NIOSH. 2002a. b, c, d). Similar to

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OTVDs, the water is removed in a gravity separator and sent for disposal (NIOSH. 2002a. b, c, d). As
indicated in the OTVD assessment, current disposal practices of the wastewater are unknown with the
latest available data from a 1982 EPA (Gilbert et al.. 1982) report estimating 20% of water releases were
direct discharges to surface water and 80% of water releases were discharged indirectly to a POTW.

EPA assumes the TRI and DMR data cover all water discharges of TCE from closed-loop vapor
degreasing. However, EPA cannot distinguish between degreaser types in TRI and DMR data; therefore,
a single set of water release for all degreasing operations is used for OTVDs.

P.7 Conveyorized Vapor Degreasing

P.7.1 Exposure Assessment

EPA identified inhalation exposure monitoring data from NIOSH investigations at two sites using TCE
in conveyorized degreasing. Due to the large variety in shop types that may use TCE as a vapor
degreasing solvent, it is unclear how representative these data are of a "typical" shop. Therefore, EPA
supplemented the identified monitoring data using the Conveyorized Degreasing Near-Field/Far-Field
Inhalation Exposure Model. The following subsections detail the results of EPA's occupational
exposure assessment for batch open-top vapor degreasing based on inhalation exposure monitoring data
and modeling.

TableApx P-14 summarizes the 8-hr TWA monitoring data for the use of TCE in conveyorized
degreasing. The data were obtained from two NIOSH Health Hazard Evaluation reports (HHEs)
(Crandall and Albrecht 1989). (Kinnes. 1998).

Table Apx P-14. Summary of Worker Inhalation Exposure Monitoring Data for Conveyorized
Vapor Degreasing 						

Scenario

8-hr
TWA
(ppm)

AC
(ppm)

ADC
(ppm)

LADC
(ppm)

Number of
Data Points

Confidence Rating of Air
Concentration Data

High-End

48.3

16.1

11.0

5.6

18

Medium

Central Tendency

32.4

10.8

7.4

2.9

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 18 data points from 2 sources, and the
data quality ratings from systematic review for these data were medium. The primary limitations of
these data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium to low.

EPA also considered the use of modeling, which is in the middle of the inhalation approach hierarchy. A
Monte Carlo simulation with 100,000 iterations was used to capture the range of potential input
parameters. Vapor generation rates were derived from TCE unit emissions and operating hours reported
in the 2014 National Emissions Inventory. The primary limitations of the air concentration outputs from
the model include the uncertainty of the representativeness of these data toward the true distribution of

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inhalation concentrations for the industries and sites covered by this scenario. Added uncertainties
include that emissions data available in the 2014 NEI were only found for three total units, and the
underlying methodologies used to estimate these emissions are unknown. Based on these strengths and
limitations of the air concentrations, the overall confidence for these 8-hr TWA data in this scenario is
medium to low.

FigureApx P-2 illustrates the near-field/far-field model that can be applied to conveyorized vapor
degreasing. As the figure shows, TCE vapors evaporate into the near-field (at evaporation rate G),
resulting in near-field exposures to workers at a concentration Cnf. The concentration is directly
proportional to the evaporation rate of TCE, G, into the near-field, whose volume is denoted by Vnf.
The ventilation rate for the near-field zone (Qnf) determines how quickly TCE dissipates into the far-
field (i.e., the facility space surrounding the near-field), resulting in occupational non-user exposures to
TCE at a concentration Cff. Vff denotes the volume of the far-field space into which the TCE dissipates
out of the near-field. The ventilation rate for the surroundings, denoted by Qff, determines how quickly
TCE dissipates out of the surrounding space and into the outdoor air.

Far-Field

Figure Apx P-2. Belt/Strip Conveyorized Vapor Degreasing Schematic of the Conveyorized
Degreasing Near-Field/Far-Field Inhalation Exposure Model

To estimate the TCE vapor generation rate, the model uses the annual emission rate and annual
operating time from the single conveyorized degreasing unit reported in the 2014 NEI. Because the
vapor generation rate is based a limited data set, it is unknown how representative the model is of a
"typical" conveyorized degreasing site.

EPA performed a Monte Carlo simulation with 100,000 iterations and the Latin Hypercube sampling
method in @Risk to calculate 8-hour TWA near-field and far-field exposure concentrations. Near-field
exposure represents exposure concentrations for workers who directly operate the vapor degreasing
equipment, whereas far-field exposure represents exposure concentrations for occupational non-users
(i.e., workers in the surrounding area who do not handle the degreasing equipment).

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TableApx P-15 presents a statistical summary of the exposure modeling results. These exposure
estimates represent modeled exposures for the workers and occupational non-users. For workers, the
50th percentile exposure is 40.8 ppm 8-hr TWA, with a 95th percentile of 3,043 ppm 8-hr TWA.

The high-end value is two orders of magnitude higher than identified in the monitoring data, but the
central tendency is comparable to the monitoring data. This may be due to the limited number of sites
from which the monitoring data were taken or that limited data for conveyorized degreaser were
reported to the 2014 NEI data (data were only found for three total units). It is also uncertain of the
underlying methodologies used to estimate emissions in the 2014 NEI data.

Table Apx P-15. Summary of Exposure Modeling Results for TCE Degreasing in Conveyorized
Degreasers					

Scenario

8-hr TWA
(ppm)

ACa
(ppm)

ADC
(ppm)

LADC
(ppm)

Data Quality Rating

of Associated Air
Concentration Data

Workers (Near-field)

High-End

3,043

1,014.4

694.8

275.2

N/A - Modeled Data

Central
Tendency

40.8

13.6

9.3

5.3

Occupational non-users (Far-Field)

High-End

1,878

626

428.8

168.3

N/A - Modeled Data

Central
Tendency

23.3

7.8

5.3

3.6

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.
a Acute exposures calculated as a 24-hr TWA.

P.7.2 Water Release Assessment

Similar to OTVDs, the primary source of water releases from conveyorized systems is expected to be
from wastewater from the water separator with the primary sources of water being: 1) Moisture in the
atmosphere that condenses into the solvent when exposed to the condensation coils on the system;
and/or 2) steam used to regenerate carbon adsorbers used to control solvent emissions (Durkee. 2014;
Kanegsberg and Kanegsberg. 2011; NIOSH. 2002a. b, c, d). The current disposal practices of the
wastewater are unknown; however, a 1982 EPA (Gilbert et al.. 1982) report estimated 20% of water
releases from metal cleaning (including batch systems, conveyorized systems, and vapor and cold
systems) were direct discharges to surface water and 80% of water releases were discharged indirectly to
a POTW.

EPA assumes the TRI and DMR data cover all water discharges of TCE from conveyorized degreasing.
However, EPA cannot distinguish between degreaser types in TRI and DMR data; therefore, a single set
of water release for all degreasing operations is presented in Section P.5.2 for OTVDs.

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P.8 Web Vapor Degreasing

P.8.1 Exposure Assessment

EPA did not identify inhalation exposure monitoring data related to the use of TCE in web degreasing.
Therefore, EPA used the Near-Field/Far-Field Model to estimate exposures to workers and ONUs. The
following details the results of EPA's occupational exposure assessment for use in web degreasers based
on inhalation exposure modeling.

FigureApx P-3 illustrates the near-field/far-field model that can be applied to web degreasing. As the
figure shows, TCE vapors evaporate into the near-field (at evaporation rate G), resulting in near-field
exposures to workers at a concentration Cnf. The concentration is directly proportional to the
evaporation rate of TCE, G, into the near-field, whose volume is denoted by Vnf. The ventilation rate
for the near-field zone (Qnf) determines how quickly TCE dissipates into the far-field (i.e., the facility
space surrounding the near-field), resulting in occupational non-user exposures to TCE at a
concentration Cff. Vff denotes the volume of the far-field space into which the TCE dissipates out of the
near-field. The ventilation rate for the surroundings, denoted by Qff, determines how quickly TCE
dissipates out of the surrounding space and into the outdoor air.

Far-Field

Figure Apx P-3. Schematic of the Web Degreasing Near-Field/Far-Field Inhalation Exposure
Model

To estimate the TCE vapor generation rate, the model uses the annual emission rate and annual
operating time from the single web degreasing unit reported in the (U.S. EPA. 2011). Because the vapor
generation rate is based a limited data set, it is unknown how representative the model is of a "typical"
web degreasing site.

EPA performed a Monte Carlo simulation with 100,000 iterations and the Latin Hypercube sampling
method in @Risk to calculate 8-hour TWA near-field and far-field exposure concentrations. Near-field
exposure represents exposure concentrations for workers who directly operate the vapor degreasing

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equipment, whereas far-field exposure represents exposure concentrations for occupational non-users
(i.e., workers in the surrounding area who do not handle the degreasing equipment).

Table Apx P-16 presents a statistical summary of the exposure modeling results. These exposure
estimates represent modeled exposures for the workers and occupational non-users. For workers, the
50th percentile exposure is 5.9 ppm 8-hr TWA, with a 95th percentile of 14.1 ppm 8-hr TWA.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of modeling, in the middle of the inhalation approach
hierarchy. A Monte Carlo simulation with 100,000 iterations was used to capture the range of potential
input parameters. Vapor generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of the air concentration
outputs from the model include the uncertainty of the representativeness of these data toward the true
distribution of inhalation concentrations for the industries and sites covered by this scenario. Added
uncertainties include that emissions data available in the 2011 NEI were only found for one unit, and the
underlying methodologies used to estimate the emission is unknown. Based on these strengths and
limitations of the air concentrations, the overall confidence for these 8-hr TWA data in this scenario is
medium to low.

Table Apx P-16. Summary of Exposure Mode ing Results for TCE Degreasing in Web Degreasers

Scenario

8-hr TWA
(ppm)

ACa
(ppm)

ADC
(ppm)

LADC
(ppm)

Confidence Rating
of Air
Concentration
Data

Workers (Near-field)

High-End

14.1

4.7

3.2

1.4

N/A - Modeled Data

Central
Tendency

5.9

2.0

1.4

0.5

Occupational non-users (Far-Field)

High-End

9.6

3.2

2.2

0.9

N/A - Modeled Data

Central
Tendency

3.1

1.0

0.7

0.3

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.
a Acute exposures calculated as a 24-hr TWA.

P.8.2 Water Release Assessment

Similar to OTVDs, the primary source of water releases from web systems is expected to be from
wastewater from the water separator with the primary sources of water being: 1) Moisture in the
atmosphere that condenses into the solvent when exposed to the condensation coils on the system;
and/or 2) steam used to regenerate carbon adsorbers used to control solvent emissions (Durkee. 2014;
Kanegsberg and Kanegsberg. 2011; NIOSH. 2002a. b, c, d). The current disposal practices of the
wastewater are unknown; however, a 1982 EPA (Gilbert et al.. 1982) report estimated 20% of water
releases from metal cleaning (including batch systems, conveyorized systems, and vapor and cold
systems) were direct discharges to surface water and 80% of water releases were discharged indirectly to
a POTW.

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EPA assumes the TRI and DMR data cover all water discharges of TCE from web vapor degreasing.
However, EPA cannot distinguish between degreaser types in TRI and DMR data; therefore, a single set
of water release for all degreasing operations is used for OTVDs.

P.9 Cold Cleaning

P.9.1 Exposure Assessment

EPA did not identify inhalation exposure monitoring data for the Cold Cleaning condition of use.
Therefore, EPA used the Cold Cleaning Near-Field/Far-Field Inhalation Exposure Model to estimate
exposures to workers and ONUs. The following details the results of EPA's occupational exposure
assessment for cold cleaning based on modeling.

FigureApx P-4 illustrates the near-field/far-field model that can be applied to cold cleaning. As the
figure shows, TCE vapors evaporate into the near-field (at evaporation rate G), resulting in near-field
exposures to workers at a concentration Cnf. The concentration is directly proportional to the
evaporation rate of TCE, G, into the near-field, whose volume is denoted by Vnf. The ventilation rate
for the near-field zone (Qnf) determines how quickly TCE dissipates into the far-field (i.e., the facility
space surrounding the near-field), resulting in occupational non-user exposures to TCE at a
concentration Cff. Vff denotes the volume of the far-field space into which the TCE dissipates out of the
near-field. The ventilation rate for the surroundings, denoted by Qff, determines how quickly TCE
dissipates out of the surrounding space and into the outdoor air.

Far-Field

NF

Near-Field

NF

-> Q,

NF

Figure Apx P-4. Schematic of the Cold Cleaning Near-Field/Far-Field Inhalation Exposure Model

To estimate the TCE vapor generation rate, the model developed a distribution from the reported annual
emission rates and annual operating times reported in the 2014 NEI (U.S. EPA. 2018a). NEI records
where the annual operating time was not reported were excluded from the distribution. Because the
vapor generation rate is based a limited data set (ten total units), it is unknown how representative the
model is of a "typical" cold cleaning site.

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Cold cleaners are assumed to operate between 3 to 24 hours per day, based on NEI data on the reported
operating hours for cold cleaners using TCE. EPA performed a Monte Carlo simulation with 100,000
iterations and the Latin Hypercube sampling method in @Risk to calculate 8-hour TWA near-field and
far-field exposure concentrations. Near-field exposure represents exposure concentrations for workers
who directly operate the vapor degreasing equipment, whereas far-field exposure represents exposure
concentrations for occupational non-users (i.e., workers in the surrounding area who do not handle the
cold cleaning equipment).

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of modeling, in the middle of the inhalation approach
hierarchy. A Monte Carlo simulation with 100,000 iterations was used to capture the range of potential
input parameters. Vapor generation rates were derived from TCE unit emissions and operating hours
reported in the 2014 National Emissions Inventory. The primary limitations of the air concentration
outputs from the model include the uncertainty of the representativeness of these data toward the true
distribution of inhalation concentrations for the industries and sites covered by this scenario. Added
uncertainties include that emissions data available in the 2014 NEI were only found for ten total units,
and the underlying methodologies used to estimate these emissions are unknown. Based on these
strengths and limitations of the air concentrations, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

TableApx P-17 presents a statistical summary of the exposure modeling results. Estimates of AC,
ADC, and LADC for use in assessing risk were made using the approach and equations described in
Appendix B. These exposure estimates represent modeled exposures for the workers and occupational
non-users. For workers, the 50th percentile exposure is 3.33 ppm 8-hr TWA, with a 95th percentile of
57.2 ppm 8-hr TWA.

Table Apx P-17. Summary of Exposure Modeling Results for Use of Trichloroethylene in Cold
Cleaning	

Scenario

8-hr TWA
(ppm)

AC
(ppm)

ADC
(ppm)

I.AIK
(ppm)

ConrillciHT

killing of Air
C'oiHTiilmlion
D;itii

Workers (Near-field)

High-End

57.2

19.1

13.1

5.2

N/A - Modeled
Data

Central
Tendency

3.33

1.11

0.8

0.3

Occupational non-users (Far-Field)

High-End

34.7

11.6

7.9

3.1

N/A - Modeled
Data

Central
Tendency

1.8

0.6

0.4

0.2

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

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P.9.2 Water Release Assessment

Similar to OTVDs, the primary source of water releases from cold cleaners is expected to be from
wastewater from the water separator with the primary source of water expected to be from moisture in
the atmosphere that condenses into the solvent. Water may also enter vapor degreasers via steam used to
regenerate carbon adsorbers; however, it is unclear if carbon adsorbers would be used in conjunction
with cold cleaning equipment. The current disposal practices of the wastewater are unknown; however, a
1982 EPA (Gilbert et al.. 1982) report estimated 20% of water releases from metal cleaning (including
batch systems, conveyorized systems, and vapor and cold systems) were direct discharges to surface
water and 80% of water releases were discharged indirectly to a POTW.

EPA assesses water release using TRI and DMR data. However, EPA cannot distinguish between
degreasers and cold cleaners in TRI and DMR data; therefore, a single set of water release for all
degreasing and cold cleaning operations is used for OTVDs.

P. 10 Aerosol Applications: Spray Degreasing/Cleaning, Automotive
Brake and Parts Cleaners, Penetrating Lubricants, and Mold
Releases

P.10.1 Exposure Assessment

EPA did not identify inhalation exposure monitoring data related to the use of TCE in aerosol
degreasers. Therefore, EPA estimated inhalation exposures using the Brake Servicing Near-field/Far-
field Exposure Model. EPA used the brake servicing model as a representative scenario for this
condition of use as there was ample data describing the brake servicing use and it is a significant use of
TCE-based aerosol products. The following details the results of EPA's occupational exposure
assessment for aerosol degreasing and aerosol lubricants based on modeling.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of modeling, in the middle of the inhalation approach
hierarchy. A Monte Carlo simulation with 100,000 iterations was used to capture the range of potential
input parameters. Various model parameters were derived from a CARB brake service study and TCE
concentration data for 16 products representative of the condition of use. The primary limitations of the
air concentration outputs from the model include the uncertainty of the representativeness of these data
toward the true distribution of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the air concentrations, the overall confidence for
these 8-hr TWA data in this scenario is medium.

Figure Apx P-5 illustrates the near-field/far-field for the aerosol degreasing scenario. As the figure
shows, TCE in aerosolized droplets immediately volatilizes into the near-field, resulting in worker
exposures at a concentration Cnf. The concentration is directly proportional to the amount of aerosol
degreaser applied by the worker, who is standing in the near-field-zone (i.e., the working zone). The
volume of this zone is denoted by Vnf. The ventilation rate for the near-field zone (Qnf) determines how
quickly TCE dissipates into the far-field (i.e., the facility space surrounding the near-field), resulting in
occupational non-user exposures to TCE at a concentration Cff. Vff denotes the volume of the far-field
space into which the TCE dissipates out of the near-field. The ventilation rate for the surroundings,
denoted by Qff, determines how quickly TCE dissipates out of the surrounding space and into the
outside air.

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In this scenario, TCE mists enter the near-field in non-steady "bursts," where each burst results in a
sudden rise in the near-field concentration, followed by a more gradual rise in the far-field
concentration. The near-field and far-field concentrations then decay with time until the next burst
causes a new rise in near-field concentration.

Based on site data from maintenance and auto repair shops obtained by CARB (CARB. 2000) for brake
cleaning activities, the model assumes a worker will perform 11 applications of the degreaser product
per brake job with five minutes between each application and that a worker may perform one to four
brake jobs per day each taking one hour to complete. EPA modeled two scenarios, one where the brake
cleaning jobs occurred back-to-back and one where braking cleaning jobs occurred one hour apart.

Based on data from CARB (CARB. 20001 EPA assumes each brake job requires 14.4 oz of aerosol
brake cleaner. The model determines the application rate of TCE using the weight fraction of TCE in the
aerosol product. EPA uses uniform distribution of weight fractions for TCE based on facility data for the
aerosol products in use (CARB. 2000). It is uncertain whether the use rate and weight fractions for brake
cleaning are representative of other aerosol degreasing and lubricant applications.

FigureApx P-5. Schematic of the Near-Field/Far-Field Model for Aerosol Degreasing

EPA performed a Monte Carlo simulation with 1,000,000 iterations and the Latin hypercube sampling
method to model near-field and far-field exposure concentrations in the aerosol degreasing scenario. The
model calculates both 8-hr TWA exposure concentrations and acute 24-hr TWA exposure
concentrations. Table_Apx P-18 presents a statistical summary of the exposure modeling results.

For workers, the exposures are 7.63 ppm 8-hr TWA at the 50th percentile and 23.98 ppm 8-hr TWA at
the 95th percentile. For occupational non-users, the model exposures are 0.14 ppm 8-hr TWA at the 50th
percentile and 1.04 ppm 8-hr TWA at the 95th percentile.

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TableApx P-18. Summary of Worker and Occupational Non-User Inhalation Exposure Modeling
Results for Aerosol Degreasing	

Scenario

8-hr TWA
(ppm)

AC
(ppm)

ADC
(ppm)

I.AIK
(ppm)

Confidence Killing

ol Air
C'onccnlriilion Dsitsi

Workers (Near-field)

High-End

24.0

8.0

5.5

2.2

N/A - Modeled Data

Central Tendency

7.6

2.5

1.7

0.6

Occupational non-users (Far-Field)

High-End

1.0

0.4

0.2

0.1

N/A - Modeled Data

Central Tendency

0.1

0.05

0.03

0.01

AC = Acute Concentration; ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

P.10.2 Water Release Assessment

EPA does not expect releases of TCE to water from the use of aerosol products. Due to the volatility of
TCE the majority of releases from the use of aerosol products will likely be to air as TCE evaporates
from the aerosolized mist and the substrate surface. There is a potential that TCE that deposits on shop
floors during the application process could possibly end up in a floor drain (if the shop has one) or could
runoff outdoors if garage doors are open. However, EPA expects the potential release to water from this
to be minimal as there would be time for TCE to evaporate before entering one of these pathways. This
is consistent with estimates from the International Association for Soaps, Detergents and Maintenance
Products (AISE) SpERC for Wide Dispersive Use of Cleaning and Maintenance Products, which
estimates 100% of volatiles are released to air (Products. 2012). EPA expects residuals in the aerosol
containers to be disposed of with shop trash that is either picked up by local waste management or by a
waste handler that disposes shop wastes as hazardous waste.

P.ll Metalworking Fluids

P.ll.l Exposure Assessment

EPA identified inhalation exposure monitoring data from OSHA facility inspections (OJ	) at

two sites using TCE in metalworking fluids. Due to small sample sizes, it is unclear how representative
these data are of "typical" MWF use. Therefore, EPA supplemented the identified monitoring data with
an assessment of inhalation exposures using the ESD on the Use of Metalworking Fluids (
2( ). The following subsections detail the results of EPA's occupational exposure assessment for
TCE use in MWFs based on inhalation exposure monitoring data and modeling.

Table Apx P-19 summarizes the 8-hr TWA monitoring data for the use of TCE in MWFs. No data was
found to estimate ONU exposures from use in metalworking fluids. Data from this source covers
exposures at a facility that produces various electrical resistors (Gilles and Philbin. 1976). The data were
provided as full-shift TWAs.

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TableApx P-19. Summary of Worker Inhalation Exposure Monitoring Data for TCE Use in
Metalworking Fluids						

Scenario

8-hr
TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number
of Data
Points

Confidence Rating of
Air Concentration
Data

High-End

75.4

25.1

17.2

8.8





Central
Tendency

69.7

23.2

15.9

6.3

3

High

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of monitoring data, the highest of the inhalation
approach hierarchy. These monitoring data include 3 data points from 1 source, and the data quality
ratings from systematic review for these data were high. The primary limitations of these data include
limited dataset (3 data points from 1 site), and the uncertainty of the representativeness of these data
toward the true distribution of inhalation concentrations for the industries and sites covered by this
scenario. Based on these strengths and limitations of the inhalation air concentration data, the overall
confidence for these 8-hr TWA data in this scenario is low.

EPA also considered the use of modeling, which is in the middle of the inhalation approach hierarchy.
Data from the 2011 Emission Scenario Document on the Use of Metalworking Fluids was used to
estimate inhalation exposures. The primary limitations of the exposure outputs from this model include
the uncertainty of the representativeness of these data toward the true distribution of inhalation for all
TCE uses for the industries and sites covered by this scenario, and the difference between the modeling
data and monitoring data. Added uncertainties include that the underlying TCE concentration used in the
metalworking fluid was assumed from one metalworking fluid product. Based on these strengths and
limitations of the air concentrations, the overall confidence for these 8-hr TWA data in this scenario is
medium.

The ESD estimates typical and high-end exposures for different types of metalworking fluids. These
estimates are provided in Table Apx P-20 and are based on a NIOSH study of 79 small metalworking
facilities (OECD. 2011b). The concentrations for these estimates are for the solvent-extractable portion
and do not include water contributions (OECD. 2011b). The "typical" mist concentration is the
geometric mean of the data and the "high-end" is the 90th percentile of the data (OECD. 2011b).

Table Apx P-20. ESD Exposure Estimates for Metalworking Fluids Based on Monitoring Data

Type of Metalworking Fluid

Typical Mist Concentration
(mg/m3)a

High-End Mist Concentration
(mg/m3)b

Conventional Soluble

0.19

0.87

Semi-Synthetic

0.20

0.88

Synthetic

0.24

1.10

Straight Oil

0.39

1.42

a The typical mist concentration is the geometric mean of the data (OECD. 2011b)
b The high-end mist concentration is the 90th percentile of the data (OECD. 2011b)
Source: (OECD. 2011b)

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The recommended use of the TCE-based metalworking fluid is an oil-based cutting and tapping fluid;
therefore, EPA assesses exposure to the TCE-based metalworking fluids using the straight oil mist
concentrations and the max concentration of TCE in the metalworking fluid. Straight oils are not diluted;
therefore, the concentration of TCE specified in the SDS (98%) (U.S. EPA. 2017b) is equal to the
concentration of TCE in the mist. TableApx P-21 presents the exposure estimates for the use of TCE-
based metalworking fluids. The ESD estimates an exposure duration of eight hours per day; therefore,
results are presented as 8-hr TWA exposure values. It should be noted that these estimates may
underestimate exposures to TCE during use of metalworking fluids as they do not account for exposure
to TCE that evaporates from the mist droplets into the air. This exposure is difficult to estimate and is
not considered in this assessment.

Table Apx P-21. Summary of Exposure Results for Use of TCE in Metalworking Fluids Based on
ESD Estimates

Scenario

8-hr TWA

(PPm)a

ADC
(ppm)

LADC
(ppm)

Data Quality

Rating of
Associated Air
Concentration Data

High-End

0.3

0.1

0.03

N/A - Modeled Data

Central Tendency

0.1

0.02

6.0E-3

ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

a The TCE exposure concentrations are calculated by multiplying the straight oil mist concentrations in Table Apx P-20 by
98% (the concentration of TCE in the metalworking fluid) and converting to ppm.

The monitoring data obtained is two orders of magnitude higher than the modeling data. It is uncertain if
the limited monitoring data set (three sample points), or the age of the monitoring data (1976) is
representative of exposures to TCE for all sites covered by this condition of use.

P.11.2 Water Release Assessment

The ESD states that water releases from use of straight oil metalworking fluids may come from disposal
of container residue and dragout losses from cleaning the part after shaping (OECD. 2011b). Facilities
typically treat wastewater onsite due to stringent discharge limits to POTWs (OECD. 2011b). Control
technologies used in onsite wastewater treatment in the MP&M industry include ultrafiltration, oil/water
separation, and chemical precipitation (OECD. 2011b). Facilities that do not treat wastewater onsite
contract waste haulers to collect wastewater for off-site treatment (OECD. 2011b).

EPA assesses water release using TRI and DMR data. However, EPA cannot distinguish between sites
using metalworking fluids and sites using TCE in degreasers in TRI and DMR data; therefore, a single
set of water release for degreasing and metalworking fluid operations is used for OTVDs.

P.12 Adhesives, Sealants, Paints, and Coatings

P.12.1 Exposure Assessment

EPA identified inhalation exposure monitoring data from a NIOSH a Health Hazard Evaluation report
(HHE) (Chrostek. 1981) using TCE in coating applications and from OSHA facility inspections (OSHA.
2017) at three sites using TCE in adhesives and coatings. The following details the results of EPA's
occupational exposure assessment for coating applications based on inhalation exposure monitoring
data.

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TableApx P-22 summarizes the 8-hr TWA monitoring data for the use of TCE in coatings. The data
were obtained from a HHE (Chrostek. 1981) and from OSHA data (OSHA. 2017). The HHE data also
provided two data points where the worker job description was "foreman." EPA assumed this data is
applicable to ONU exposure. However, due to the limited data set and the various types of application
methods that may be employed, EPA is unsure of the representativeness of these data toward actual
exposures to TCE for all sites covered by this condition of use.

Table Apx P-22. Summary of Worker Inhalation Exposure Monitoring Data for
Adhesives/Paints/Coatings	

Scensirio

8-hr TWA
(ppm)

AC
(ppm)

ADC
(ppm)

I.ADC
(ppm)

Number
ol' Dili:t
Points

Con riclciHT
killing of Air
ConceiKriilion
Dsilsi

Workers

High-End

39.5

13.2

9.0

4.6

22

Medium

Central
Tendency

4.6

1.6

1.1

0.4

Occupational non-users

High-End

1.0

0.3

0.2

0.1

2

Medium

Central
Tendency

0.9

0.3

0.2

0.1

AC = Acute Concentration, ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 22 data points from 2 sources, and the
data quality ratings from systematic review for these data were medium to high. The primary limitations
of these data include the uncertainty of the representativeness of these data toward the true distribution
of inhalation concentrations for the industries and sites covered by this scenario. Based on these
strengths and limitations of the inhalation air concentration data, the overall confidence for these 8-hr
TWA data in this scenario is medium to low.

For the ONU inhalation air concentration data, the primary strengths include the assessment approach,
which is the use of monitoring data, the highest of the inhalation approach hierarchy. These monitoring
data include 2 data points from 1 source, and the data quality ratings from systematic review for the data
point was high. The primary limitations of this data is the limited dataset (two data points from 1 site),
and the uncertainty of the representativeness of this data toward the true distribution of inhalation
concentrations for the industries and sites covered by this scenario. Based on these strengths and
limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data in
this scenario is medium to low.

EPA did not find data to provide inhalation exposure estimates for commercial adhesive, sealant, paint
and coating applications. Therefore, EPA uses the industrial data discussed above as surrogate for

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commercial coatings, as EPA believes the activities and exposures will be similar between industrial and
commercial sites covered by this condition of use.

P.12.2 Water Release Assessment

In general, potential sources of water releases from adhesive, sealants, and paints/coatings use may
include the following: equipment cleaning operations, and container cleaning wastes (OECD, 2011a).

Water releases for adhesives, sealants, paints and coating sites were assessed using data reported from
three sites in the 2016 TRI and 2016 DMR. For the sites in the 2014 NEI (where release information is
not provided), an average release per site was calculated from the total releases of the three
aforementioned sites reporting water releases to DMR and TRI, and dividing the total release by the
total number of sites in TRI and DMR (17 sites). This average release per site was used to estimate
releases from the sites provided in the 2014 NEI. EPA assessed daily releases by assuming 250 days of
operation per year, as recommended in the 2011 ESD on the Application of Radiation Curable Coatings,
Inks, and Adhesives via Spray, Vacuum, Roll and Curtain Coating, and averaging the annual releases
over the operating days (OECD, 2011a). A summary of the water releases can be found in TableApx
P-23.

Table Apx P-23. Reported Water Releases of Trichloroethylene from Sites Using TCE in
Adhesives, Sealants, Paints and Coatings				

Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)a

NPDES
Code

Release Media

Able Electropolishing Co Inc.
Chicago. IL

74.4

250

0.30

Not available

POTW

Garlock Sealing Technologies,
Palmyra, NY

0.08

250

3.3E-04

NY0000078

Surface Water

Ls Starrett Co, Athol, MA

9.1E-04

250

3.6E-06

MAR05B615

Surface Water

Aerojet Rocketdyne, Inc., East
Camden, AR

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Best One Tire & Service,
Nashville, TN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Bridgestone Aircraft Tire
(USA), Inc., Mayodan NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Clayton Homes Inc, Oxford, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Cmh Manufacturing, Inc. Dba
Schult Homes - Plant 958,
Richfield, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Delphi Thermal Systems,
Lockport, NY

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Green Bay Packaging Inc - Coon
Rapids, Coon Rapids, MN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

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Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)a

NPDES
Code

Release Media

Mastcrcraft Boat Company,
Vonore, TN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Michelin Aircraft Tire
Company, Norwood, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

M-Tek, Inc, Manchester, TN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Olin Corp, East Alton, IL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Parker Hannifin Corp - Paraflex
Division Manitowoc, WI

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Parrish Tire Company,
Yadkinville, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Republic Doors And Frames,
Mckenzie, TN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Ro-Lab Rubber Company Inc.,
Tracy, CA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Royale Comfort Seating, Inc. -
Plant No. 1, Taylorsville, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Snider Tire, Inc., Statesville, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Snyder Paper Corporation
Hickory, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Stellana Us, Lake Geneva, WI

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Thomas Built Buses - Courtesy
Road, High Point, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Unicel Corp, Escondido, CA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Acme Finishing Co Lie, Elk
Grove Village, IL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Aerojet Rocketdyne, Inc.,
Rancho Cordova, CA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

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Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)a

NPDES
Code

Release Media

Allegheny Cnty Airport
Auth/Pgh Intl Airport,
Pittsburgh, PA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Amphenol Corp - Aerospace
Operations, Sidney, NY

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Aprotech Powertrain Asheville,
NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Clayton Homes Inc, Oxford, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Coating & Converting Tech
Corp/Adhesive Coatings,
Philadelphia, PA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Corpus Cliristi Army Depot,
Corpus Cliristi, TX

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Electronic Data Systems Camp
Pendleton Camp Pendleton, CA

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Florida Production Engineering,
Inc., Ormond Beach, FL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Goodrich Corporation,
Jacksonville, FL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Kasai North America Inc,
Madison Plant, Madison MS

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Kirtland Air Force Base,
Albuquerque, NM

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Marvin Windows & Doors,
Warroad, MN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Mcneilus Truck &
Manufacturing Inc, Dodge
Center, MN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Metal Finishing Co. - Wichita (S
Mclean Blvd), Wichita, KS

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Michelin Aircraft Tire
Company, Norwood, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Murakami Manufacturing Usa
Inc, Campbellsville, KY

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Page 728 of 748


-------
PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Silo l(k'ii(i(>

Amiiiiil
Kck'iisc
(kii/si(e-\ n

Amiiiiil
Kok'.iso

l);i\ s
(il;i\s/\ n

l);iil\
Ki'loiiso
(k*i/si(e-
d;i\) 1

SIMMS
Cock'

Kcloiiso Modiii

Peterbilt Motors Denton Facility,
Denton, TX

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Portsmouth Naval Shipyard,
Kittery, ME

4.4

250

1.8E-02

Not available

Surface Water or
POTW

R.D. Henry & Co., Wichita, KS

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Raytheon Company,
Portsmouth, RI

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Rehau Inc, Cullman, AL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Rotochopper Inc, Saint Martin,
MN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Rubber Applications, Mulberry,
FL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Sapa Precision Tubing
Rockledge, Lie, Rockledge, FL

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Thomas & Betts, Albuquerque,
NM

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Thomas Built Buses - Fairfield
Road, High Point, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Timco, Dba Haeco Americas
Airframe Services, Greensboro,
NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Trelleborg Coated Systems Us,
Inc - Grace Advanced Materials,
Rutherfordton, NC

4.4

250

1.8E-02

Not available

Surface Water or
POTW

U.S. Coast Guard Yard - Curtis
Bay, Curtis Bay, MD

4.4

250

1.8E-02

Not available

Surface Water or
POTW

Viracon Inc, Owatonna, MN

4.4

250

1.8E-02

Not available

Surface Water or
POTW

3574	POTW = Publicly Owned Treatment Works

3575	Releases of 4.4 kg/site-yr for NEI sites estimated from total releases fromTRI andDMR sites and divided by the 3 sites
3 576	reporting water releases and the 14 sites reporting zero water releases in TRI).

3 577	a Daily releases are back-calculated from the annual release rate and assuming 250 days of operation per year.

3578	Sources: (U.S. EPA. 2018a. 2017c. 2016a)

3579

Page 729 of 748


-------
3580

3581

3582

3583

3584

3585

3586

3587

3588

3589

3590

3591

3592

3593

3594

3595

3596

3597

3598

3599

3600

3601

3602

3603

3604

3605

3606

3607

3608

3609

3610

3611

3612

3613

3614

3615

3616

3617

3618

3619

P.13

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
Other Industrial Uses

P.13.1 Exposure Assessment

EPA did not identify inhalation exposure monitoring data related to using TCE for other industrial uses.
Therefore, EPA used monitoring data from loading/unloading TCE during manufacturing as a surrogate.
See section P. 1.1 for additional information on the data used. EPA assumes the exposure sources, routes,
and exposure levels are similar to those during loading at a TCE manufacturing facility. However, EPA
is unsure of the representativeness of these surrogate data toward actual exposures to TCE at all sites
covered by this condition of use.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA inhalation air concentrations. The primary strengths
include the assessment approach, which is the use of surrogate monitoring data, in the middle of the
inhalation approach hierarchy. These monitoring data include 16 data points from 1 source, and the data
quality ratings from systematic review for these data were medium. The primary limitations of these
data include the uncertainty of the representativeness of these surrogate data toward the true distribution
of inhalation concentrations for the industries and sites covered by this scenario. Based on these
strengths and limitations of the inhalation air concentration data, the overall confidence for these 8-hr
TWA data in this scenario is medium to low.

TableApx P-24 summarizes the 8-hr TWA from monitoring data from TCE manufacturing. The data
were obtained from obtained from data submitted by the Halogenated Solvents Industry Alliance
(HSIA) via public comment for one company (Halogenated Solvents Industry Alliance.	).

No data was found to estimate ONU exposures during other industrial uses of TCE. EPA estimates that
ONU exposures are lower than worker exposures, since ONUs do not typically directly handle the
chemical.

Table Apx P-24 Summary of Occupational Exposure Surrogate Monitoring Data for Unloading
TCE During Other Industrial Uses	

Scciiiirio

8-hr
TWA
(ppm)

AC
(ppm)

ADC
(ppm)

I.ADC
(ppm)

Nil ill her of D;it;i
Points

Confidence killing of Air
Concenlnilion D;il;i

High-End

2.6

0.9

0.6

0.3

16

Medium

Central
Tendency

0.4

0.1

0.1

0.03

AC = Acute Concentration; ADC = Average Daily Concentration; and LADC = Lifetime Average Daily Concentration.

P.13.2 Water Release Assessment

Specifics of the processes and potential sources of release for other industrial uses are unknown.
However, general potential sources of water releases in the chemical industry may include the
following: equipment cleaning operations, aqueous wastes from scrubbers/decanters, reaction water,
process water from washing intermediate products, and trace water settled in storage tanks (

2019V

EPA assessed water releases using the annual discharge values reported to the 2016 TRI and the 2016
DMR by the 49 sites using TCE in other industrial uses. In the 2016 TRI, all 28 reported zero discharge
to water. In the 2016 DMR, twenty-one sites reported a direct discharge to surface water (indirect
discharges not reported in DMR data).

Page 730 of 748


-------
3620

3621

3622

3623

3624

3625

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

To estimate the daily release, EPA assumed a default of 250 days/yr of operation and averaged the
annual release over the operating days. Table Apx P-25 summarizes the water releases from the 2016
TRI and DMR for sites with non-zero discharges.

Table Apx P-25. Reported Water Releases of Trichloroethylene from Other Industrial Uses

Site Identity

Annual
Release
(kg/site-yr)

Annual
Release

Days
(days/yr)a

Daily

Release
(kg/site-
day)a

NPDES
Code

Release
Media

Eli Lilly And Company-Lilly Tech Ctr,
Indianapolis, IN

388

250

1.6

IN0003310

Surface
Water

Oxy Vinyls LP - Deer Park Pvc, Deer Park,
TX

37

250

0.15

TX0007412

Surface
Water

Solvay - Houston Plant, Houston, TX

8.3

250

0.03

TX0007072

Surface
Water

Washington Penn Plastics, Frankfort, KY

8.0

250

0.03

KY0097497

Surface
Water

Natrium Plant, New Martinsville, WV

5.5

250

2.2E-02

WV0004359

Surface
Water

Leroy Quarry, Leroy, NY

4.8

250

1.9E-02

NY0247189

Surface
Water

George C Marshall Space Flight Center,
Huntsville, AL

2.6

250

1.0E-02

AL0000221

Surface
Water

Whelan Energy Center Power Plant, Hastings,
NE

2.4

250

9.4E-03

NE0113506

Surface
Water

Akzo Nobel Surface Chemistry LLC, Morris,
IL

0.1

250

4.6E-04

IL0026069

Surface
Water

Solutia Nitro Site, Nitro, WV

0.1

250

4.4E-04

WV0116181

Surface
Water

Amphenol Corporation - Columbia,
Columbia, SC

0.1

250

2.8E-04

SC0046264

Surface
Water

Army Cold Regions Research & Engineering
Lab, Hanover, NH

0.1

250

2.3E-04

NH0001619

Surface
Water

Corning - Canton Plant, Canton, NY

0.1

250

2.2E-04

NY0085006

Surface
Water

Keeshan And Bost Chemical Co., Inc.,
Manvel, TX

0.03

250

1.3E-04

TX0072168

Surface
Water

Ames Rubber Corp Plant #1, Hamburg Boro,
NJ

0.03

250

1. 1E-04

NJG000141

Surface
Water

Gorham Providence, RI

0.02

250

9.2E-05

RIG85E004

Surface
Water

Emerson Power Transmission, Ithaca, NY

0.02

250

6.9E-05

NY0002933

Surface
Water

Chemtura North and South Plants,
Morgantown, WV

8.3E-03

250

3.3E-05

WV0004740

Surface
Water

Indorama Ventures Olefins, LLC, Sulphur,
LA

5.1E-03

250

2.0E-05

LA0069850

Surface
Water

William E. Warne Power Plant, Los Angeles
County, CA

3.1E-03

250

1.2E-05

CA0059188

Surface
Water

Raytheon Aircraft Co (Was Beech Aircraft),
Boulder, CO

2.3E-03

250

9.2E-06

COG315176

Surface
Water

3626	a Annual release amounts are based on the site reported values. Therefore, daily releases are calculated from the annual

3 627	release rate and assuming 250 days of operation per year.

3628	Sources: (U.S. EPA. 2017c. 2016a)

3629

Page 731 of 748


-------
3630

3631

3632

3633

3634

3635

3636

3637

3638

3639

3640

3641

3642

3643

3644

3645

3646

3647

3648

3649

3650

3651

3652

3653

3654

3655

3656

3657

3658

3659

3660

3661

3662

3663

3664

3665

3666

3667

3668

3669

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE
P.14 Spot Cleaning, Wipe Cleaning and Carpet Cleaning

P.14.1 Exposure Assessment

EPA identified minimal inhalation exposure monitoring data related to the spot cleaning using TCE.
Therefore, EPA supplemented the identified monitoring data using the Near-field/Far-field Exposure
Model. The following subsections detail the results of EPA's occupational exposure assessment for spot
cleaning based on inhalation exposure monitoring data and modeling.

TableApx P-26 summarizes the 8-hr TWA monitoring data and acute TWAs from the monitoring data
for the use of TCE in in spot cleaning. No data was found to estimate ONU exposures during spot
cleaning. The data were obtained from NIOSH a Health Hazard Evaluation report (HHE) (Burton and
Monesterskev. 1996). as well as a NIOSH Report on Control of Health and Safety Hazards on
Commercial Drycleaners document (NIOSH 1997). NIOSH HHEs are conducted at the request of
employees, employers, or union officials, and provide information on existing and potential hazards
present in the workplaces evaluated. NIOSH Health and Safety documents represents NIOSH research
in collaboration with industry, labor and other government organizations to protect the health of workers
in industry.

For full shift values, sample times ranged from approximately seven to nine hours (Burton and
Monesterskev. 1996). Where sample times were less than eight hours, EPA converted to an 8-hr TWA
assuming exposure outside the sample time was zero. For sample times greater than eight hours, EPA
left the measured concentration as is. Because of the limited data set, EPA is unsure of the
representativeness of these data toward actual exposures to TCE for all sites covered by this condition of
use.

Table Apx P-26. Summary of Worker Inhalation Exposure Monitoring Data for Spot Cleaning
Using TCE 						

Scenario

8-hr TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of 8-
hr TWA Data
Points

Confidence
Rating of Air
Concentration
Data

High-End

2.8

1.0

0.7

0.3

8

Medium

Central
Tendency

0.4

0.1

0.1

0.04

AC = Acute Concentration; ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 8 data points from 2 sources, and the
data quality ratings from systematic review for these data were medium. The primary limitations of
these data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths
and limitations of the inhalation air concentration data, the overall confidence for these 8-hr TWA data
in this scenario is medium to low.

EPA also considered the use of modeling, which is in the middle of the inhalation approach hierarchy. A
Monte Carlo simulation with 100,000 iterations was used to capture the range of potential input

Page 732 of 748


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3670

3671

3672

3673

3674

3675

3676

3677

3678

3679

3680

3681

3682

3683

3684

3685

3686

3687

3688

3689

3690

3691

3692

3693

3694

3695

3696

3697

3698

3699

3700

3701

3702

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

parameters. Various model parameters were derived from a CARB study. The primary limitations of the
air concentration outputs from the model include the uncertainty of the representativeness of these data
toward the true distribution of inhalation concentrations for the industries and sites covered by this
scenario. Added uncertainties include that the underlying methodologies used to obtain the values in the
CARB study, as well as the assumed TCE concentration in the spot cleaning product. Based on these
strengths and limitations of the air concentrations, the overall confidence for these 8-hr TWA data in this
scenario is medium to low.

Despite these limitation, the modeling and monitoring results match each other very closely. Therefore,
the overall confidence is medium.

Wolf and Morris (IRTA. 2007) estimated 42,000 gal of TCE-based spotting agents are sold in California
annually. Review of SDS's identified TCE-based spotting agents contain 10% to 100% TCE. The study
also estimated approximately 5,000 textile cleaning facilities in California. Results in average of 8.4
gal/site-yr of TCE-based spotting agents used.

FigureApx P-6 illustrates the near-field/far-field modeling approach that EPA applied to spot cleaning
facilities. As the figure shows, chemical vapors evaporate into the near-field (at evaporation rate G),
resulting in near-field exposures to workers at a concentration Cnf. The concentration is directly
proportional to the amount of spot cleaner applied by the worker, who is standing in the near-field-zone
(i.e., the working zone). The volume of this zone is denoted by Vnf. The ventilation rate for the near-
field zone (Qnf) determines how quickly the chemical of interest dissipates into the far-field (i.e., the
facility space surrounding the near-field), resulting in occupational non-user exposures at a
concentration Cff. Vff denotes the volume of the far-field space into which the chemical of interest
dissipates out of the near-field. The ventilation rate for the surroundings, denoted by Qff, determines
how quickly the chemical dissipates out of the surrounding space and into the outdoor air.

	Far-Field	

Figure Apx P-6. Schematic of the Near-Field/Far-Field Model for Spot Cleaning

EPA performed Monte Carlo simulations, applying one hundred thousand iterations and the Latin
hypercube sampling method. Table Apx P-27 presents a statistical summary of the exposure modeling
results. The 50th and 95th percentile near-field exposures are 0.96 ppm and 2.77 ppm 8-hr TWA,

Page 733 of 748


-------
3703

3704

3705

3706

3707

3708

3709

3710

3711

3712

3713

3714

3715

3716

3717

3718

3719

3720

3721

3722

3723

3724

3725

3726

3727

3728

3729

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

respectively. These results are comparable to the monitoring data. For occupational non-users (far-field),
model 50th and 95th percentile exposure levels are 0.48 ppm and 1.75 ppm 8-hr TWA, respectively. EPA
assumes no engineering controls are used at dry cleaning shops, which are typically small, family owned
businesses.

The modeling results are comparable to the monitoring data. However, EPA is unsure of the
representativeness of these data toward actual exposures to TCE for all sites covered by this condition of
use.

Table Apx P-27. Summary of Exposure Modeling Results for Spot Cleaning Using TCE

Scenario

8-hr TWA
(ppm)

AC (24-hr)
(ppm)

A IK

(ppm)

I.AIK
(ppm)

Qiiiililv Killing of
Associated Air Concent nil ion

Workers (Near-field)

High-End

2.8

0.9

0.6

0.3

N/A - Modeled Data

Central Tendency

1.0

0.3

0.2

0.1

Occupational non-users (Far-Field)

High-End

1.8

0.6

0.4

0.2

N/A - Modeled Data

Central Tendency

0.5

0.2

0.1

0.04

AC = Acute Concentration; ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

P.14.2 Water Release Assessment

TCE releases to water from spot cleaning will depend upon whether the stained surface is washed with
water after spotting. For example, TCE-based cleaners used to pre-spot garments prior to cleaning in
water or hydrocarbon-based machines would be a source of TCE in wastewater.

Water releases for spot cleaning were assessed using data reported in the 2016 DMR. No sites
discharging TCE from spot cleaning activities were found in the 2016 TRI. EPA assessed annual
releases as reported in the 2016 DMR and assessed daily releases by assuming 300 days of operation per
year. A summary of the water releases reported to the 2016 DMR can be found in TableApx P-28. The
annual release for each of the unknown sites is calculated by taking the average annual release of the
two sites reporting to DMR.

Table Apx P-28. Reported Water Releases of Trichloroethylene from Sites Using TCE Spot
Cleaning	

Silc

Annual

Release11
(kg/silc-vcar)

Annual
Release

Days
(davs/vr)

Dailv Uclcasc
(kg/sitc-dav)11

Media of Uclcasc

Boise State University, Boise, ID

0.02

300

8.0E-05

Surface Water

Venetian Hotel And Casino, Las
Vegas, NV

8.8E-3

300

2.9E-05

Surface Water

Page 734 of 748


-------
3730

3731

3732

3733

3734

3735

3736

3737

3738

3739

3740

3741

3742

3743

3744

3745

3746

3747

3748

3749

3750

3751

3752

3753

3754

3755

3756

3757

3758

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

Site

Annual

Release3
(kg/site-year)

Annual
Release

Days
(days/yr)

Daily Release
(kg/site-day)a

Media of Release

63,746 Unknown Sites

0.02

300

5.4E-05

Surface Water or POTW

POTW = Publicly Owned Treatment Works

a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual
release rate and assuming 300 days of operation per year.

Sources: 2016 DMR (U.S. EPA. 2016a)

P. 15 Industrial Processing Aid

P.15.1 Exposure Assessment

EPA did identify inhalation exposure monitoring data related using TCE when used as an industrial
processing aid from one site. The following details the results of EPA's occupational exposure
assessment for use of TCE as an industrial processing aid based on inhalation exposure monitoring data.

Table Apx P-29 summarizes the 12-hr TWA monitoring data and acute TWAs from the monitoring data
for the use of TCE as a processing aid for both workers and for ONUs. The data were obtained from a
European Commission (EC) Technical Report (EC. 2014). The data was supplied to the EC as
supporting documentation in an application for continued use of TCE under the REACH Regulation.
The data indicate a full shift is 12 hours. Therefore, all exposures were calculated using a 12-hr shift.
Because of the limited data set, EPA is unsure of the representativeness of these data toward actual
exposures to TCE for all sites covered by this condition of use.

Table Apx P-29. Summary of Exposure Monitoring Data for Use as a Processing Aid

Scenario

12-hr
TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of 12-
hr Data Points

Confidence
Rating of Air
Concentration
Data

Workers

High-End

12.8

6.4

4.4

2.2

30

Medium to High

Central Tendency

4.2

2.1

1.5

0.6

Occupational non-users

High-End

2.9

1.4

1.0

0.5

4

Medium

Central Tendency

1.3

0.7

0.4

0.2

AC = Acute Concentration; ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 12-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 30 data points from 1 source, and the
data quality ratings from systematic review for these data were high. The primary limitations of these
data include the uncertainty of the representativeness of these data toward the true distribution of
inhalation concentrations for the industries and sites covered by this scenario. Based on these strengths

Page 735 of 748


-------
3759

3760

3761

3762

3763

3764

3765

3766

3767

3768

3769

3770

3771

3772

3773

3774

3775

3776

3777

3778

3779

3780

3781

3782

3783

3784

3785

3786

3787

3788

3789

3790

3791

PEER REVIEW DRAFT. DO NOT CITE OR QUOTE

and limitations of the inhalation air concentration data, the overall confidence for these 12-hr TWA data
in this scenario is medium to high.

For the ONU inhalation air concentration data, the primary strengths include the assessment approach,
which is the use of monitoring data, the highest of the inhalation approach hierarchy. These monitoring
data include 4 data points from 1 source, and the data quality ratings from systematic review for the data
point was high. The primary limitations of this single data point include the uncertainty of the
representativeness of these data toward the true distribution of inhalation concentrations for the
industries and sites covered by this scenario. Based on these strengths and limitations of the inhalation
air concentration data, the overall confidence for these 12-hr TWA data in this scenario is medium to
low.

P.15.2 Water Release Assessment

In general, potential sources of water releases in the chemical industry may include the following:
equipment cleaning operations, aqueous wastes from scrubbers/decanters, reaction water, process water
from washing intermediate products, and trace water settled in storage tanks (OECD, 2019). Based on
the use as a processing aid and the amount of TCE used for this condition of use, EPA expects minimal
sources of TCE release to water.

Water releases during use as a processing aid were assessed using data reported in the 2016 TRI as well
as 2016 DMR. Four of the 16 sites reporting to TRI provided water releases. The remaining 12 sites
reported all releases were to off-site land, incineration or recycling. EPA assessed annual releases as
reported in the 2016 TRI and assessed daily releases by assuming 300 days of operation per year. A
summary of the water releases reported to the 2016 DMR and 2016 TRI can be found in TableApx
P-30.

Table Apx P-30. Reported Water Releases of Trichloroethylene from Industrial Processing Aid
Sites Using TCE						

Site Identity

Annual
Release
(kg/site-yr)a

Annual
Release

Days
(days/yr)

Daily Release
(kg/site-day)a

NPDES
Code

Release
Media

Entek International LLC, Lebanon, OR

113

300

0.4

Not
available

POTW

Occidental Chemical Corp Niagara
Plant, Niagara Falls, NY

5.8

300

0.02

NY0003336

Surface
Water

National Electrical Carbon Products Dba
Morgan Adv Materials, Fostoria, OH

2.3

300

7. 6E-03

Not
available

POTW

Daramic LLC, Corydon, IN

2.3

300

0.01

Not
available

Surface
Water

PPG Industries Inc Barberton,
Barbcrton. OH

1.4

300

4.5E-3

OH0123897

POTW

Stepan Co Millsdale Road, Elwood, IL

0.2

300

5.5E-04

IL0002453

Surface
Water

a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual
release rate and assuming 300 days of operation per year.

POTW = Publicly Owned Treatment Works
Sources: (U.S. EPA. 2017c. 2016a)

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P.16 Commercial Printing and Copying

P.16.1 Exposure Assessment

EPA identified inhalation exposure monitoring data from a NIOSH a Health Hazard Evaluation report
(HHE) (Finely and Page. 2005) using TCE in high speed printing presses. The following details the
results of EPA's occupational exposure assessment for printing applications based on inhalation
exposure monitoring data. TableApx P-31 summarizes the 8-hr TWA monitoring data for the use of
TCE in printing. The data were obtained from a HHE (Finely and Page. 2005).

EPA considered the assessment approach, the quality of the data, and uncertainties in assessment results
to determine a level of confidence for the 8-hr TWA data. For the inhalation air concentration data, the
primary strengths include the assessment approach, which is the use of monitoring data, the highest of
the inhalation approach hierarchy. These monitoring data include 20 data points from 1 source, and the
data quality ratings from systematic review for these data were medium. The primary limitations of
these data include a limited dataset, and the uncertainty of the representativeness of these data toward
the true distribution of inhalation concentrations for the industries and sites covered by this scenario.
Based on these strengths and limitations of the inhalation air concentration data, the overall confidence
for these 8-hr TWA data in this scenario is medium to low.

Table Apx P-31. Summary of Worker Inhalation Exposure Monitoring Data for High Speed
Printing Presses						

Scenario

8-hr TWA

(PPm)

AC

(PPm)

ADC

(PPm)

LADC

(PPm)

Number of
Data Points

Confidence Rating of
Air Concentration
Data

High-End

2.1

0.7

0.5

0.2

20

Medium

Central
Tendency

0.1

0.03

0.02

8.0E-3

AC = Acute Concentration. ADC = Average Daily Concentration and LADC = Lifetime Average Daily Concentration.

No monitoring data were available to estimate ONU exposures. EPA estimates that ONU exposures are
lower than worker exposures, since ONUs do not typically directly handle the chemical.

P.16.2 Water Release Assessment

A potential source of water releases from Printing/copying use would come from clean-out of printing
equipment if the ink is water-based (OECD. 2010). Based on the use in printing/copying and the amount
of TCE used for this condition of use, EPA expects minimal sources of TCE release to water.

Water releases during use in printing and copying were assessed using data reported in the 2016 DMR.
One site provided water releases. EPA assessed annual releases as reported in the 2016 DMR and
assessed daily releases by assuming 250 days of operation per year. A summary of the water releases
reported to the 2016 DMR can be found in Table Apx P-32.

Table Apx P-32. Reported Water Releases of Trichloroethylene from Commercial Printing and

C°Pying						



Annual
Release
(kg/site-yr)a

Annual







Site Identity

Release

Days
(days/yr)

Daily Release
(kg/site-day)a

NPDES
Code

Release
Media

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Printing and Pub Sys Div, Weatherford,
OK

0.05

250

2.0E-4

OK0041785

Surface
Water

a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual

release rate and assuming 250 days of operation per year.

As only one site was identified with water releases for this condition of use, EPA acknowledges this site
does not represent the entirety of commercial printing and copying sites using TCE. However, data is
not reasonably available to estimate water releases from additional sites. Based on reasonably available
EPA models releases from containers may be up to: 1) 0.3% to 0.6% for small containers (<20 gal) or
drums that are emptied via pouring; or 2) 2.5% to 3% for drums emptied via pumping; however, not all
sites are expected to dispose of container residues to water. Additional water release sources of TCE at
these sites may exist and will vary depending on the use rate of the TCE-based products.

P. 17 Other Commercial Uses

P.17.1 Exposure Assessment

EPA did not identify any inhalation exposure monitoring data related to TCE use in other commercial
uses. See Section P. 14.1 for the assessment of worker exposure during spot cleaning activities. EPA
assumes the exposure sources, routes, and exposure levels are similar to those for spot cleaners.

P.17.2 Water Release Assessment

Specifics of the processes and potential sources of release for these uses are unknown. Based on the
volatility of TCE, EPA expects the majority of TCE used for these applications to evaporate and be
released to air. EPA expects residuals in containers to be disposed of with general site trash that is either
picked up by local waste management or by a waste handler that disposes wastes as hazardous waste.

TableApx P-33 summarizes non-zero water releases from sites using TCE in other commercial uses
reported in the 2016 DMR. To estimate the daily release for the sites in Table Apx P-33, EPA assumed
a default of 250 days/yr of operation and averaged the annual release over the operating days. These data
are not expected to capture the entirety of water releases from these uses; however, EPA does not have
information to estimate water releases from sites not reporting to DMR.

Table Apx P-33. Reported Water Releases of Trichloroethylene from Other Commercial Uses in

the 2016 DMR

Site Identity

Annual
Release
(kg/site-
yr)

Annual
Release

Days
(days/yr)

Daily

Release
(kg/site-
day)

NPDES
Code

Release
Media

Corning Hospital, Corning, NY

3.2

250

0.013

NY0246701

Surface
Water

Water Street Commercial Bldg, Dayton OH

0.7

250

2.8E-03

OHO 141496

Surface
Water

Union Station North Wing Office Building, Denver, CO

1.0E-01

250

4.0E-04

COG315293

Surface
Water

Confluence Park Apartments, Denver, CO

7.1E-02

250

2.8E-04

COG315339

Surface
Water

Park Place Mixed Use Development, Annapolis, MD

6.7E-02

250

2.7E-04

MD0068861

Surface
Water

Tree Top Inc Wenatchee Plant, Wenatchee, WA

9.0E-03

250

3.6E-05

WA0051527

Surface
Water

Wynkoop Denver LLCP St, Denver, CO

7.8E-03

250

3.1E-05

COG603115

Surface
Water

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Greer Family LLC, South Burlington, VT

1.3E-03

250

5.0E-06

VT0001376

Surface
Water

John Marshall III Site, Mclean, VA

4.7E-04

250

1.9E-06

VA0090093

Surface
Water

a Annual release amounts are based on the site reported values. Therefore, daily releases are calculated from the annual
release rate and assuming 250 days of operation per year.

Sources: (U.S. EPA. 2016a)

P.18 Process Solvent Recycling and Worker Handling of Wastes

P.18.1 Exposure Assessment

EPA did not identify any inhalation exposure monitoring data related to waste handling/recycling. See
Section P.4.1 for the assessment of worker exposure from chemical unloading activities. EPA assumes
the exposure sources, routes, and exposure levels are similar to those at a repackaging facility.

P.18.2 Water Release Assessment

Potential sources of water releases at disposal/recycling sites may include the following: aqueous wastes
from scrubbers/decanter, trace water settled in storage tanks, and process water generated during the
disposal/recycling process.

EPA assessed water releases using the values reported to the 2016 TRI and DMR by the 30
disposal/recycling sites. In the 2016 TRI, three of sites reported non-zero indirect discharges to off-site
wastewater treatment; one site reported discharges to both off-site wastewater treatment as well as
discharge to a POTW. All sites in TRI for this condition of use reported zero direct discharges to surface
water.

To estimate the daily release, EPA used a default assumption of 250 days/yr of operation as and
averaged the annual release over the operating days. Table Apx P-34 summarizes the water releases
from the 2016 DMR and 2016 TRI for sites with non-zero discharges.

Table Apx P-34. Estimated Water Releases of Trichloroethylene from Disposal/Recycling of TCE

Site Identity

Annual
Release
(kg/site-
yr)a

Annual Release
Days (days/yr)

Daily Release
(kg/site-day)a

NPDES
Code

Release Media

Veolia Es Technical
Solutions LLC,
Middlesex, NJ

6035

250

24.1

Not
available

POTW WWT (0.02%)
and Non-POTW WWT

(99.98%)

Clean Harbors Deer Park
LLC, La Porte, TX

87.1

250

0.3

TX0005941

Non-POTW WWT

Clean Harbors El Dorado
LLC, El Dorado, AR

9.1

250

0.04

AR0037800

Non-POTW WWT

Clean Water Of New
York Inc, Staten Island,
NY

0.9

250

3.8E-03

NY0200484

Surface Water

Reserve Enviromnental
Services, Ashtabula, OH

3.9E-04

250

1.6E-06

OH0098540

Surface Water

POTW = Publicly-Owned Treatment Works; WWT = Wastewater Treatment

a Annual release amounts are based on the site reported values. Therefore, daily releases are back-calculated from the annual
release rate and assuming 250 days of operation per year.

Sources: (U.S. EPA 2017c) and "(U.S. EPA 2016a)'

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