Toxic solvents underneath IBM building defy cleanup

Buildings on contaminated soil may
expose workers to harmful chemicals
through soil vapor intrusion: Experts.

ENDICOTT – After 35 years, IBM Corp. contractors have stanched the flow of industrial solvents into a commercial and residential district in the heart of the village, but they have yet to find a solution for the source of the problem at the company's former flagship manufacturing plant.

Officials recently reported that efforts to intercept and remove the subterranean flow of hazardous chemicals coming from the industrial complex — now owned by Huron Real Estate Associates — have been successful.

Consequently, health risks to a nearby neighborhood have been eliminated.

Yet they have no remedy for a concentrated pool of solvents directly under the manufacturing site, where at least 1,500 people still work.

It may take years before a proven remedy is found, according to Alex Czuhanich, an engineering geologist with the state Department of Environmental Conservation, although the agency has no timetable for the project.

The pollution, discovered in 1979, includes trichloroethylene (TCE) and other solvents used as industrial degreasers that have been linked to maladies ranging from cancer to birth defects.

IBM used vast quantities of the solvents to manufacture printed circuit boards during the company's heyday from the 1950s through the 1970s.

The contaminated hot spot — known as "the source area" on DEC records — lies under an area the size of eight village blocks, and it was once bustling with the delivery, handling, storage, transport and liberal use of solvents.

The source area encompasses a railroad corridor where chemicals arrived in bulk, loading docks where they were handled, and a network of tanks and pipelines that stored and transported virgin chemicals and chemical waste to and from various manufacturing lines throughout the campus, according to DEC records.

Situated over and near the source area, and blocking access to cleanup, are dozens of buildings, most of them massive, bunker-like, cement structures built during the Cold War era and some well before.

The contaminated ground is dense with tunnels, boiler rooms, tank rooms, crawl spaces, cables, pipes and conduits.

"There is just so much infrastructure there," Czuhanich said. "Trying to get anything in there (to remedy the problem) is difficult, at best."

To date, nearly 70,000 gallons of solvent — more than 40 tons — have been pumped from the ground. Officials don't know how much is left, according to DEC spokesman Peter Constantakes.

Court records filed by attorneys representing residents suing IBM for damages from the pollution put the solvent pool up to 1 million gallons "that had apparently collected over many years from leaking pipes and tanks."

Reluctance by IBM and the DEC to publicly discuss the source area has added to uncertainty about its status. IBM spokesman Todd Martin did not reply to phone calls or written inquires on the subject.

Safety debated

IBM sold the plant in 2002 to Huron Real Estate Associates, which now rents space to BAE Systems Electronics, i3 Electronics (formerly Endicott Interconnect), Binghamton University and other smaller firms that collectively employ between 1,500 and 2,000 workers.

TCE, the main contaminant under the campus, is not commonly used in bulk by industry in the U.S. anymore, though it is a pervasive contaminant at many Cold War-era industrial and military sites throughout the country.

In addition to the former IBM site, notorious TCE legacy sites in the Southern Tier include the CAE Electronics site in Hillcrest, and the Morse Industrial site in Tompkins County, both linked to contamination of nearby residential neighborhoods.

The TCE problem is as stubborn as it is complex. TCE is one of a class of chemicals that tend to be heavier than water, so they sink through the water table and adhere stubbornly to soil particles.

They also give off toxic fumes that rise from the ground, ending up in basements, crawl spaces and — ultimately — circulating into living spaces through a process known as vapor intrusion.

There is no national standard to limit TCE exposure in air, although there has been a political push to develop one since the federal Environmental Protection Agency determined in 2011 that the chemical was a carcinogen and a "non-cancer health hazard."

Just how much exposure presents a risk remains a controversial topic. Levels that might not affect one person could make another seriously ill. Pregnant women are particularly vulnerable.

According to the latest EPA assessment — challenged by the chemical industry — risks for non-cancer illnesses, such as birth defects, from short-term TCE exposure in residential settings are found to increase statistically at levels at or above 2 micrograms per cubic meter.

The agency has set the threshold for risks from short-term exposure in an industrial setting at 7, based on the assumption that people spend less time at work than in their homes.

Cancer risks become discernible for chronic exposure — the type people might experience in homes — at levels beginning at 0.43 micrograms, according to an EPA assessment.

New York state has set a broad guideline of 5 for residential and commercial exposure. But the agency often requires action at levels below the threshold when feasible.

Feasibility remains the issue at the Huron campus. Indoor air samples at 42 buildings collected in 2005 — the last time the state oversaw testing — ranged from zero to 17 micrograms per cubic meter in some areas that tended to be occupied. Levels were much higher in other areas — often registering between 50 and 300 micrograms in tunnels and tank rooms below Building 18, for example.

Concentrations in the soil directly below the buildings often exceeded 10,000 and sometimes were over 100,000 micrograms.

In 2005, the state health department determined that the TCE levels at the Huron campus present a "low" health risk to people working there, according to a report at the time. That means state health officials "do not expect to be able to associate health effects" from exposure.

Health department spokesman Jeffrey Hammond said the guideline remains "under review" as more information comes to light "to ensure that previous decisions and recommendations continue to protect public health."

In 2005, a health department study found elevated rates of testicular and kidney cancers, and birth defects that were "statistically significant" in an area affected by solvent pollution in the area south of the former IBM plant, and several blocks to the southwest of the plant polluted by an undetermined source. (The area has since been cleaned by the IBM remediation efforts.)

The results of a study by NIOSH and the health department evaluating birth outcomes of women who worked at the plant is expected to be released later this year.

By the numbers
• 35: Number of years IBM has been cleaning the pollution.
• 70,000: Number of gallons of concentrated chemicals removed so far.
• 1,500: Approximate number of employees who work at the site.
• 470: Number of structures off-site that have been fitted with vent systems to divert toxic fumes.
• 5: Safety threshold, in micrograms per cubic meter, for TCE exposure in air in New York state.
• 2: Level, in micrograms per cubic meter, at which risks associated with short-term TCE exposure increase statistically.

Source: PressConnects; This article has been edited for length.

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IBM to settle toxic spill suit

Company and plaintiffs announce a settlement over TCE releases from the former plant

The settlement ends a six-year saga.

IBM Corp. will settle a lawsuit brought by 1,000 plaintiffs who alleged that toxic spills from the company's former Endicott manufacturing plant caused illnesses and deaths, damaged property values and hurt businesses.

Both sides announced the settlement without revealing details of the agreement.

"IBM and the plaintiffs' counsel have reached this agreement in an effort to resolve these cases without further burdensome and expensive litigation," said the joint statement from the litigants.

The settlement brings to a close a more-than six-year saga in which IBM and those who claim they were harmed by the toxic releases waged a fierce legal battle on monetary rewards.

Affected residents, in a multi-million-dollar liability lawsuit against IBM, claimed the company should pay for the damage caused to residents around what once was the company's main domestic manufacturing facility.

From 1935 to the mid-1980s, IBM used TCE (trichloroethylene) to clean metal parts in degreasers at its industrial campus in the Village of Endicott. In 1979, the company discovered some of the TCE had pooled in groundwater beneath the facility and appeared to be migrating.

Soil vapor intrusion

Contamination from soil vapor intrusion was detected by the late 1990s, and by 2002, IBM began testing the air at the request of state health and environmental agencies. Basement ventilation systems were eventually installed in more than 400 homes.

Settlement negotiations between the parties began last July, when state Supreme Court Justice Ferrous D. Lebous requested that representatives of both sides start meeting about an out-of-court settlement. Negotiations were apparently successful, culminating with Tuesday night's release that the parties agreed to a settlement that satisfied both sides.

Lawyers of those who brought the suit against IBM said they will conduct meetings with clients over the coming weeks to present terms of the settlement.

IBM representatives said the company will continue the environmental cleanup that has been ongoing since the widening toxic plume was discovered.

Pumps spread throughout Endicott pull pollution from the ground through structures called recovery wells.

Over time, these wells have grown in number from four to more than 22, and to date, they have recovered more than 815,000 pounds of trichloroethylene and other toxic chemicals, with an unknown amount remaining beneath the village.

Company officials have never publicly explained IBM's role in the disaster, and their legal position was that the company always handled chemicals responsibly and in accordance with standards of the day.

They have not denied their former operations were a primary contributor to the pollution. They have not admitted it, either, nor have they offered a detailed explanation of the source of the problem.

Cleaning up industrial solvents

Representatives of the company said it was cleaning up the solvents from multiple industries that have operated in the region's industrial corridor for generations. Endicott was also home to the vast shoe manufacturing empire of Endicott Johnson Corp., once the region's largest employer.

However, the toxic-liability suit named only IBM as the source of the chemicals that tainted parts of Endicott's commercial district and nearby residences.

IBM sold the 140-acre campus to Huron Real Estate Associates in 2002. Current tenants include i3 Electronics (formerly Endicott Interconnect), BAE Systems and Binghamton University, among others.

Lawyers for IBM have long contended it was following the responsible path, picking up the sizable costs for cleaning the spill and providing venting systems for properties designated at-risk for vapor intrusion.

Both sides scored initial victories as the case wound its way through the courts. Lower courts ruled against IBM's motion to have the case dismissed, and ruled in favor of a plaintiff's motion to have charges of negligence — the underpinnings of the case — tried before a jury.

But lower court rulings also eliminated or limited some aspects of the litigation, including the charge that the pollution constitutes a trespass in all cases, and the claim that IBM should be held accountable for monitoring the medical condition of all plaintiffs, including non-property owners.

IBM was also able to limit claims for medical monitoring to only people claiming other damages, such as illness or property loss. That eliminated claims for a potentially large group of plaintiffs — renters and children, for example — who may have been exposed but did not develop illnesses or suffer property damage.

Source: PressConnects

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TCE to be regulated by EPA, unless industries take action

TCE is often used in degreasing
operations and dry cleaning.

The Environmental Protection Agency will regulate uses of trichloroethylene that pose health risks to workers or consumers unless companies voluntarily stop using the solvent or find ways to reduce exposures, according to a senior agency official.

“Voluntary efforts are frequently quicker and more cost-effective than regulations,” Wendy Cleland-Hamnett, director of EPA's Office of Pollution Prevention and Toxics (OPPT), said during a recent workshop. “But where we can't do it through voluntary efforts, we will pursue regulations.”

In the U.S., most trichloroethylene is used in refrigerant manufacturing, which poses minimal exposure risks and isn't an application the EPA is focusing on.

The EPA is concerned about worker exposure in commercial degreasing operations and dry cleaning, as well as consumer exposure through various products that contain TCE.

The EPA held a workshop July 29-30 to discuss alternatives to trichloroethylene use as a degreaser. Participants also discussed ways to reduce exposures if the solvent must be used. In future forums, the agency will address TCE alternatives for dry cleaners.

Companies make about 250 million pounds of trichloroethylene in the U.S. or import it into this country annually, said Tala Henry, director of OPPT's Risk Assessment Division. The vast majority, 83.6 percent (209 million pounds), is used to make refrigerants in well-controlled and contained workplace environments, Henry said.

The EPA estimates 14.7 percent (36.75 million pounds) of the remaining trichloroethylene is used as a commercial degreasing solvent, and 1.7 percent (4.25 million pounds) has consumer applications such as automotive degreasing products, home office toner aids, home mirror edge sealant and arts and crafts fixatives or cleaners, Henry said.

Risk assessment identified health concerns

OPPT organized the workshop as its initial response to its analysis of risks TCE poses when used in degreasing, dry cleaning and some arts and crafts applications.

Thousands of workers in small commercial degreasing shops and dry cleaning facilities face an increased risk of contracting cancer and giving birth to children with cardiac or other health problems, OPPT concluded.

Employees who don't work with TCE directly, but work near where it is used, also faced increased health risks, the assessment said.

The offspring of pregnant consumers who inhale brief high concentrations of TCE-containing arts and crafts sprays or other materials may also face risks, the assessment found, although many companies have stopped using TCE in consumer goods, according to information presented at the workshop.

Trichloroethylene is found at more than half of the nation's superfund sites, according to the Agency for Toxic Substances and Disease Registry, which focuses on human health risks of hazardous waste sites.

TCE also is a volatile organic compound and hazardous air pollutant, said Margaret Sheppard, an environmental scientist with EPA's Office of Air and Radiation.

Alternatives for degreasers

Alternative ways of degreasing equipment include water-based cleaners that may contain small amounts of surfactants, rust inhibitors and other compounds; acetone; a coating that could be peeled off to remove contaminants; and frozen crystals of carbon dioxide called “snow.”

Source: Bloomberg News
This article has been edited for length.

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EPA warns of TCE exposure

Agency releases final risk assessment on Trichloroethylene (TCE), begins process to address potential human health risks

Many dry cleaners and other small
businesses use toxic chemicals daily.

The U.S. Environmental Protection Agency (EPA) released a final risk assessment for trichloroethylene (TCE). The assessment identified health risks from TCE exposures to consumers using spray aerosol degreasers and spray fixatives. 

It also identifies health risks to workers when TCE is used as a degreaser in small commercial shops and as a stain removing agent in dry cleaning.

“EPA calls on Congress to enact legislation that strengthens our current federal toxics law,” said Jim Jones, assistant administrator for chemical safety and pollution prevention.

“Until that time, we are using the best available science to assess and address chemical risks of TCE that now show that it may harm human health and the environment.”

The final TCE risk assessment was developed as part of the agency’s Toxic Substances Control Act (TSCA) Work Plan, which identified chemicals for review and assessment of potential risks to people’s health and the environment.

EPA developed the draft TCE risk assessment based on the best available information and finalized the assessment after careful consideration of comments from the public and experts during an independent, scientific peer review of the assessment.

TCE is the first chemical to complete the work plan risk assessment process under TSCA.

EPA is conducting a workshop from July 29-30, on potential TCE degreaser alternatives and risk reduction approaches.

EPA will also conduct other activities to address TCE uses as a stain removing agent in dry cleaning and as a clear protective spray fixative.

In the meantime, EPA recommends that people take precautions that can reduce exposures, such as using the product outside or in an extremely well-ventilated area and wearing protective equipment to reduce exposure.

For more information on the TCE risk assessment, the July 29-30 public workshop, and TSCA workplan chemicals, click here.


Source: EPA

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Chemical exposure at work may be linked to health problems: IBM study

Massive study tracked thousands of
IBM workers and their health.

While former workers at IBM in Endicott show lower mortality rates than the general population, exposure to certain chemicals could be related to health problems, according to a recent government statistical analysis.

The National Institute for Occupational Safety and Health announced the findings of a massive, five-year study of the health of 34,494 workers who were employed at IBM’s Endicott facility between 1969 and 2001.

Among the study’s key findings:

• The total number of deaths from all causes, and the total number of deaths from cancer, were lower among the former workers than what would be expected from the general population. Just over 17 percent of the sampled workers — a total of 5,966 — had died through 2009. 

• Deaths from specific types of cancer including non-Hodgkin lymphoma, mesothelioma, pleural cancer, rectal cancer and testicular cancer were more frequent in some groups than would be expected from the general population. 

• “A positive, statistically significant relation” was observed between exposure to tetrachloroethylene, or PCE, and nervous system diseases. Exposure scores for trichloroethylene, or TCE, were positively statistically correlated with a certain type of leukemia.

Like most statistical studies related to the health of a group, the data do not show that exposure caused any disease found in that group.

Rather, the statistics can show only stronger relationships or correlation in one group compared to what might be found in the population as a whole.

“We’re definitely not in a position to say anything is causal,” NIOSH research epidemiologist Sharon Silver said.

TCE, an industrial solvent, was used at the IBM facility beginning in the mid-1960s as part of the printed circuit board manufacturing process and discontinued by 1985.

Although few potential ties between exposure and health outcomes were observed in the local group of IBM workers studied, the report concludes that “risks from occupational exposures cannot be ruled out due to data limitations and the relative youth of the cohort.”

The study has been long-anticipated by Endicott residents, who pushed for it for years before $3.1 million in federal funding was appropriated for the effort.

Limitations with the data

Yet the authors of the report are the first to admit that constraints in the available data mean nothing conclusive can be said about the effects of exposure to chemicals at IBM.

“There are a number of limitations with the data,” said Silver, the lead author. “We don’t have measurements on who was exposed to what, when.”

Researchers began working on the study in spring 2009, using electronic IBM human resources records to reconstruct work histories of employees and conduct an in-depth analysis of industrial hygiene records showing where chemicals were used.

But the study could not take into account possible chemical exposures at other jobs, and lifestyle factors like smoking. And the workers in the sample are relatively young, meaning some potential adverse health effects may have not yet developed.

IBM spokesman Todd Martin said the study’s finding that IBM workers had a lower mortality rate than the general population was among the key points. He emphasized that the findings regarding PCE and TCE represented a statistical correlation, not an proven causal relationship.

“Health, safety and wellness of IBM employees is, and has always been, the top priority for IBM, and it is integrated into every aspect of our operations,” he said.

NIOSH, the federal agency that conducts research and makes recommendations for preventing work-related injuries, illnesses and deaths, conducted the study at the request of the state Department of Health and other stakeholders.

This article has been edited for length. 
Source: Press Connects

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Residents sue General Mills over TCE soil pollution

Soil vapor intrusion fears for Minneapolis homeowners

Two class-action lawsuits were filed against General Mills by residents in the Como neighborhood of southeast Minneapolis, where state-ordered testing has shown troubling concentrations of the pollutant TCE in soil below their homes.

Updated results have been published as of Friday morning for 58 of roughly 200 homes in the target area, southwest of a former General Mills facility where solvents containing TCE (trichloroethylene) were dumped decades ago and filtered into soil and groundwater. Thirty-seven have turned up with higher-than-acceptable levels of the chemical.

Testing has been completed at another 16 properties, but results haven’t been released, and has been arranged but not completed at another 65 properties, according to a map published by the Minnesota Pollution Control Agency (MPCA), which is overseeing the cleanup project.

TCE exposure has been linked to
cancer and other health concerns.

Three property owners refused testing.

Prolonged exposure to high TCE levels has been linked to elevated risks of cancer and other health problems.

A contractor funded by General Mills is installing ventilation systems — commonly used to remove radon from homes — in the problem properties to prevent the harmful buildup of TCE.

Since the public disclosure of TCE contamination in soil gas in the neighborhood last month, only half of the property owners have scheduled testing of the soil gas below their basements.

The high number of rental homes in the area — many occupied by University of Minnesota students — has added to the challenge of securing testing agreements from the property owners.

However, three attorneys from Minneapolis and Chicago jointly sued in U.S. District Court on behalf of two residents of the Como neighborhood, Karl Ebert and Carol Krauze. And a Minneapolis firm filed a similar suit in Hennepin County District Court on behalf of resident Jill Ruzicka.

Both cases seek class-action status to represent all residents affected by TCE contamination below their homes.

Both were filed ahead of a high-profile community meeting arranged Saturday by Integrated Resource Management, a California firm tied to pollution crusader Erin Brockovich that investigates industrial contamination.

A General Mills representative could not be reached in time for publication.

Source: Star Tribune

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California plans to add TCE to toxic chemicals list

Exposure to TCE can lead to reproductive problems.

California's Office of Environmental Health Hazard Assessment has announced plans to add trichloroethylene to the list of reproductive toxicants maintained under Proposition 65.

In a Nov. 27 notice of intent, the agency proposed listing the volatile organic compound based on U.S. Environmental Protection Agency findings that trichloroethylene (CAS No. 79-01-06) caused male reproductive toxicity and developmental toxicity in laboratory animals.

Under the Safe Drinking Water and Toxic Enforcement Act of 1986, better known as Proposition 65, the state must maintain a list of chemicals known to cause cancer, birth defects or reproductive toxicity.

Businesses must provide clear warnings whenever the public is exposed to an unsafe level of a listed substance.

TCE is used as an industrial solvent and is found in several consumer products, including paint removers and adhesives.

TCE - Trichloroethylene
- In the vapor degreasing of metal parts.
- An extraction solvent for greases, oils, fats, waxes, and tars, a chemical intermediate in the
   production of other chemicals, and as a refrigerant.
- In consumer products such as typewriter correction fluids, paint removers/strippers,
   adhesives, spot removers, and rug-cleaning fluids
Source: EPA

In 1988, California added the chemical to the Proposition 65 list of carcinogens.

Findings in the EPA's 2011 Integrated Risk Information System (IRIS) document and the Toxicological Review of TCE in support of the IRIS entry meet the criteria for listing the chemical as a reproductive toxicant under the Proposition 65 authoritative bodies mechanism, the OEHHA said.

The authoritative bodies mechanism is an administrative process that requires the OEHHA to add substances to the Proposition 65 list once the EPA or another official body formally identifies a chemical as causing reproductive harm, birth defects or cancer.

Along with the notice of intent, the agency posted its response to comments from the Halogenated Solvents Industry Alliance Inc. and another group questioning whether TCE was eligible for listing via the administrative process.

Source: Bloomberg

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TCE soil vapor intrusion fears in Como

Soil vapor intrusion allows contaminants
to enter homes and businesses.

Minnesota health and pollution officials are holding community forums to discuss efforts to discuss efforts to handle TCE, a degreasing solvent that may be invading homes in the Como area of southeast Minneapolis.

TCE, which stands for trichloroethylene, had been dumped from 1947 to 1962 in a pit behind a now-defunct General Mills plant.

The state is asking some 200 property owners near Van Cleve Park to allow testing in their basements to determine whether TCE vapors in the soil below their foundations are finding a way into their homes.

Prolonged, substantial exposure to TCE has been linked to certain cancers such as non-Hodgkin’s lymphoma as well as birth defects.

While there is no evidence that cancer or other health problems are more prevalent in the neighborhood, state officials said they are acting out of caution as science has revealed more about the way TCE can evaporate from groundwater and rise through soils.

The neighborhood’s TCE problem has been known since the early 1980s, when the old General Mills property at 2010 E. Hennepin Av. was declared a federal Superfund cleanup site.

General Mills agreed to pay for the pumping and treatment of groundwater to remove traces of the chemical.

Groundwater treatment continued until 2010, when the Minnesota Pollution Control Agency declared it was safe to halt the cleanup — but monitoring since that time found TCE in the soil gas below the surface.

Forty tests were conducted on the soil under sidewalks and streets in a wide section of the Como neighborhood near the old General Mills site. Thirteen sites showed TCE rates above residential air safety standards, allowing health officials to pinpoint a 16-block area trailing southwest from the plant to Van Cleve.


Tests and remedies

General Mills has agreed to arrange and pay for testing for TCE, at a cost of about $1,000 per property, as well as the $2,000-per-property cost of fixing homes or businesses if TCE is found. In most cases, the solution will be a ventilation system similar to the ones used in homes to remove radon.

The company previously paid to remove contaminated soil from the site of its former food and chemical research plant, which has since been sold and redeveloped into small-business offices.

To assess any potential health problems, the Health Department has reviewed data from its registries of all birth defects and cancer cases in the state. The 55414 ZIP code, which includes the Como neighborhood, does not have a higher rate of birth defects.

A review of the cancer database is ongoing.


Editor's note: This article has been edited.

Source: Star Tribune

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Dry-Cleaning Solvent TCE linked to increased liver cancer

Trichloroethylene (TCE) exposure has possible links to increased liver cancer risk, according to a study published this week in the Journal of the National Cancer Institute.

TCE is a chlorinated dry-cleaning solvent and degreaser that has been widely used over the last 100 years and has shown carcinogenicity in rodents. Previous epidemiologic studies have shown a reported increase in cancer risk in humans for the kidney, cervix, liver and biliary passages, non-Hodgkin lymphoma, and esophageal adenocarcinoma.

In order to determine the link between TCE exposure and increased cancer risk, Johnni Hansen, Ph.D., of the Danish Cancer Society Research Center in Copenhagen, and colleagues looked at workers that had individual documentation for exposure to TCE in Finland, Sweden, and Denmark, where the individuals were monitored for urinary TCE metabolite trichloroacetic acid during 1947-1989 and followed for cancer.

The researchers found statistically significant elevated ratios for primary liver cancer and cervical cancer, but did not find a statistically significant risk of either non-Hodgkin lymphoma or esophageal or kidney cancer.

"Our pooled study of documented TCE-exposed workers provides some evidence for an increased risk of liver cancer, although confounding by other exposures cannot be ruled out. Evaluation of a possible modest risk for kidney cancer and non- Hodgkin lymphoma requires studies with greater statistical power," the authors write.

In an accompanying editorial, Mark P. Purdue, Ph.D., of the Division of Cancer Epidemiology and Genetics at the National Cancer Institute writes that there has been concern with workers exposed to TCE since the early 1970s and that even though it is now classified as a human carcinogen, further research is needed and safer options should be explored.

"Where possible, TCE should be substituted by safer alternative chemicals and/or emissions should be reduced. Conversion from conventional vapor degreasers to new low-emission equipment such as enclosed vapor degreasing systems can greatly reduce solvent exposures in the workplace, and aqueous cleaning systems may also be feasible alternatives in certain applications."