What should I know about t-DCE and TCE?

PART FOUR: In May of 2019, Water Gremlin launched a site to educate the community on their pollution control fines and what they were doing for the future. This is the fourth in a series of NCCG responses to their Frequently Asked Questions.

From Water Gremlin: 
Q:  What should I know about t-DCE?
A:  t-DCE is non-hazardous, which is why most states do not have a permissible exposure limit for t-DCE. Minnesota’s limit is 35 times the limit set for TCE.

T-DCE is not well studied and, as such, is not classified as a “Hazardous Air Pollutant” by the EPA. This does not mean the substance is not a hazard to human health. In fact, t-DCE is listed on the TURI (Toxics Use Reduction Institute) list of toxic or hazardous substances.  Additionally in Stakeholder Meeting conversations with the MDH and the MPCA, they do not verbally endorse the language of “non-hazardous”  

However, you’ll see Water Gremlin using the term non-hazadous frequently.  (Their language has been clarified recently to denote that it is not listed as a Hazardous Air Pollutant by the EPA.)   Because of their instance of using non-hazardous language for a chemical that does have evidence from respected sources that suggests otherwise, it feels to community members as though this continues a culture of disregard for the toxicity of the chemicals their workers are handling and the emissions that result from their production. See below for details of t-DCE  (Trans 1,2-dichloroethene ) on human impact at high levels.

Human Toxicity.

• Lower human toxicity than some other halogenated solvents

• Is an immune system toxicant and a neurotoxin

• Acute exposure can cause central nervous system depression

• Chronic exposure can cause liver, circulatory, immune system and central nervous system damage

“How can 1,2-dichloroethene affect my health?

Breathing high levels of trans-1,2-dichloroethene can make you feel nauseous, drowsy, and tired. Breathing very high levels of its vapor can kill you. When animals breathed high levels of trans-1,2- dichloroethene for short or longer periods of time, their livers and lungs were damaged. The effects were more severe with longer exposure times. Animals that breathed very high levels of trans-1,2- dichloroethene had damaged hearts. Animals given extremely high doses of cis- or trans-1,2- dichloroethene by mouth died. Lower oral doses of cis-1,2-dichloroethene caused effects on the blood, such as decreased numbers of red blood cells, and effects on the liver.

Agency for Toxic Substances and Disease Registry (ATSDR)

The long-term human health effects after exposure to low concentrations of 1,2-dichloroethene are not known. Results of a recent animal study suggest that an exposed fetus may not grow as quickly as one that is not exposed. No studies have been done to see whether cancer in people or animals is caused by exposure to 1,2-dichloroethene; exposure has not been shown to affect fertility in people or animals.”

Hazardous products are used in manufacturing through the US.  And, in this writer’s opinion, so long as there is strict adherence to worker safety and environmental safety protocols, as well as an openness to evaluating lesser toxic options when they become available, those chemicals can have a value.

However, the risk to human and environmental health is severe when the company appears to not have a respect for the product they are using. In this case, we are concerned about Water Gremlin’s respect for chemicals, based on the years of toxic emissions; based on their repeated use of the phrase “non-hazardous’ to describe t-DCE and; based on other findings in both the Stipulation Agreement and the Work Plan.

FROM WATER GREMLIN: 
Q:  Why didn’t Water Gremlin start using a TCE alternative sooner?
A:  Most TCE alternatives are flammable, and TCE is not. Our search for a TCE replacement – which began in the spring of 2018 – required non-flammability, which ruled out many of the possible alternatives.

The rationale provided in past MPCA communications to concerned residents of White Bear Lake (in July 2000) was that using an acceptable alternative, would be “cost prohibitive”, and this is a theme that is heard across the industry.  Non-flammable alternative substances have been available for decades.

All referenced FAQs from Water Gremlin are copied and pasted directly from their website as of June 14, 2019. Our responses based on  facts (cited) and our point-of-view (POV) . Our POV is based on an assessment of facts, advice from independent third-party experts and our own experiences.