Greenpeace (Pat Costner) comments to EPA on PVC

[IATP@iatp.org (IATP)]

PVC Report Summary.  For full report, call 202/319-2444.
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      PVC:  A PRIMARY CONTRIBUTOR TO THE U.S. DIOXIN BURDEN

                         By  Pat Costner


            Comments on U.S. EPA Dioxin Reassessment
         "Estimating Exposure to Dioxin-Like Compounds"
               (External Review Draft, June 1994)


Greenpeace                                    February 1995

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EXECUTIVE SUMMARY



     Greenpeace launched a broad investigation of the PVC
industry in 1994, specifically targeting U.S. chemical companies
that manufacture the key chemicals for PVC production.

     To produce PVC, ethylene dichloride (EDC) is converted into
vinyl chloride monomer (VCM) which is then polymerized to form
polyvinyl chloride, also known as PVC or vinyl.  Collecting and
analyzing samples of process wastes and other materials,
Greenpeace confirmed the following facts:

*  U.S. EDC/VCM facilities are creating large quantities of
   dioxin and PCBs.  Waste samples from these facilities
   contained some of the highest dioxin concentrations ever
   reported in chemical processing wastes.

*  U.S. EDC/VCM facilities are releasing dioxin into the
   surrounding environment.  A sediment sample taken downstream
   from one facility's wastewater discharge carried an
   extraordinarily high dioxin concentration; a sediment sample
   taken downstream from another facility, although not analyzed
   for dioxin, contained a chemical that has been reported to
   be an indicator for dioxin.  No air, effluent or sludge
   samples were analyzed; however, dioxin has been identified in
   all of these media in industry and government studies of
   European EDC/VCM facilities, as well as in PVC itself.

     Industry documents obtained by Greenpeace confirm that PVC
production is inextricably linked to the formation and release of
dioxin and PCBs, as follows:

*  Dioxin is the unavoidable by-product of PVC manufacture,
   specifically including the oxychlorination process, which
   is crucial to EDC production; and

*  PCBs are also unavoidable by-products of PVC production
   processes.

     U.S. government documents reveal USEPA's responses to the
dioxin/PVC connection as follows:

*  USEPA first learned that dioxin is generated in PVC
   manufacture during the Reagan-Bush administrations.  Then, as
   now, the Agency had the power to require PVC manufacturers to
   prevent the generation and release of dioxin but did not do
   so;

*  After proposing to regulate dioxin in one PVC-related waste in
   1988, USEPA conceded to industry pressure and, in 1990,
   deleted dioxin from the list of chemicals to be regulated; and

*  USEPA's documentation of the dioxin/PVC connection from the
   1980s has not been acknowledged during the Agency's dioxin
   reassessment.

     PVC plastic is the largest single use of chlorine in the
U.S., accounting for about 34 percent of all chlorine production.
PVC is produced by combining chlorine and ethylene gases (or
ethylene, oxygen, and hydrochloric acid in a process called
oxychlorination) to produce the intermediate EDC, which is
then converted to VCM.  VCM is polymerized to form PVC.

     Eleven U.S. companies with fifteen facilities produce EDC.
The combined VCM capacity of U.S. companies is almost fourteen
billion pounds per year.  In 1994, total PVC production in the
U.S. was estimated at 10.88 billion pounds.  A large body of
evidence suggests that the greatest share of the nation's dioxin
burden stems from the manufacture, use, recycling, and disposal
of this enormous quantity of PVC plastic.


GREENPEACE'S SAMPLING AND ANALYSIS

     After making several requests to USEPA to investigate the
generation and release of dioxin during PVC feedstock
manufacture, Greenpeace launched its own independent study in the
summer of 1994.  Greenpeace obtained samples from areas for
production, storage, treatment and disposal of wastes at
Louisiana and Texas facilities where EDC and/or VCM are produced.

     Fifty-one grab samples were retrieved from these facilities,
25 of which are addressed in this report.  Samples were taken
from containers bearing labels with USEPA waste codes and other
content descriptions, from sediments in receiving streams for
wastewater discharges, etc.  All samples were shipped to an
analytical laboratory, where chemical analyses were conducted for
organic and metallic contaminants.  Due to the extraordinary
costs entailed, only four of these samples were selected for
dioxin analysis and two for PCB analysis.

Process Wastes

     Concentrations of dioxin in the three process waste samples
were extraordinarily high:

*  Vulcan Chemicals, Geismar, Louisiana:  A sample of heavy
   ends(1) from the distillation of EDC contained dioxin at a
   total concentration of 200,750 parts per billion (ppb);

*  Formosa Plastics, Point Comfort, Texas:  A sample of heavy
   ends from the distillation of VCM contained 761 ppb total
   dioxin; and,

*  Georgia Gulf, Plaquemine, Louisiana:  A waste sample,
   collected from a tank containing F024 waste, had a total
   dioxin content of 1,248 ppb.

     In comparison, wastes from the manufacture of Agent Orange,
which are regulated by USEPA as "F023 and F020 dioxin-listed
wastes," contain estimated total dioxin concentrations ranging
from 33 to 238 ppb and 24,000 to 50,000,000 ppb, respectively.

Dioxin concentrations found in the PVC-related wastes sampled by
Greenpeace exceed those of Agent Orange waste F023 and, in one
case, fall in the mid-range of Agent Orange waste F020.

     Twenty-five samples from nine EDC/VCM facilities contained
one or more of the following chemicals that signal the presence
of dioxin:  hexachlorobenzene, 1,1,2,3,4,4-hexachloro-1,3-
butadiene, tetrachlorobenzene, pentachlorobenzene, and 1,1,3,4-
tetrachloro-1,3-butadiene.  These nine facilities include the
three listed above, plus the following:

*  Geon Vinyl (formerly BFGoodrich), LaPorte, Texas;
*  Borden Chemical, Geismar, Louisiana;
*  Dow Chemical, Freeport/Oyster Creek, Texas;
*  Occidental Chemicals, Ingleside, Texas;
*  PPG Industries, Lake Charles, Louisiana; and
*  Vista Chemical, Lake Charles, Louisiana.

     These findings suggest that the 21 samples -- 20 waste
samples and one sediment sample -- that were not directly
analyzed for dioxin content also contained significant quantities
of dioxin.

Sediments

     In the fourth dioxin analysis, a sediment sample taken
slightly downstream from the discharge point of the Geon
Corporation (formerly BFGoodrich) in LaPorte, Texas, was found to
carry a total dioxin concentration of >2,911 parts per trillion
(ppt).  This dioxin concentration is approximately five times
higher than the average concentration reported for North American
sediments in USEPA's draft dioxin reassessment.  Another sediment
sample taken downstream from Dow Chemical's EDC/VCM facility in
Oyster Creek, Texas, also indicates that dioxin is present.

     Extrapolations from industry reports and academic studies of
European EDC/VCM production suggest that the quantity of dioxin
discharged into U.S. waterways from EDC/VCM facilities may rival
that discharged from all 104 U.S. pulp and paper mills.


USEPA BOWS TO INDUSTRY PRESSURE

     USEPA's failure during the Reagan and Bush administrations
to investigate and curtail the generation and release of dioxin
and PCBs during PVC production was due neither to ignorance nor
to negligence.

     The Agency has known since at least 1979 that very large
quantities of PCB-contaminated wastes are produced in the
production of EDC and VCM.  Rather than using its power under the
Toxic Substances Control Act (TSCA) to prohibit such PCB
manufacture, USEPA actively solicited EDC/VCM producers to apply
for special exemptions.

     USEPA knew prior to 1988 that dioxin is produced during
EDC/VCM production.  However, after initially proposing in 1988
to regulate dioxin in one EDC/VCM waste, the Agency came under
pressure from the Vinyl Institute and major producers.  In 1990,
USEPA deleted those portions of the regulations addressing
dioxin, citing the potential costs to the industry.  None of this
information was included in USEPA's draft dioxin reassessment.

     Since 1989, the published scientific and governmental
literature has contained numerous reports of dioxin in the
wastes, discharges and surroundings of EDC/VCM facilities in
Europe.  Recent Swedish studies have detected dioxin and PCBs in
the PVC product itself.

     The inventory of dioxin sources in USEPA's draft dioxin
reassessment serves as the basis for the Agency's dioxin
elimination policies.  However, the Agency has not included
EDC/VCM facilities among its major dioxin sources.  USEPA does
not provide its own estimates of dioxin releases from U.S.
EDC/VCM facilities but asserts that "monitoring efforts to
collect these data are highly recommended."  This situation
suggests that USEPA does not yet acknowledge the inseparability
of PVC, dioxin and PCBs, and the enormity of PVC's contribution
to the national dioxin burden both during its manufacture as well
as in the burning of associated wastes and discarded PVC
products.


PVC: THE COMMON CONTRIBUTING FACTOR AMONG LARGEST DIOXIN
SOURCES

    Without chlorine, dioxin cannot be created.  PVC is the
primary donor of chlorine for most of the dominant dioxin sources
identified by USEPA -- various kinds of incinerators and other
thermal processes.  Considering what is already known about the
dioxin output from various portions of the PVC lifecycle, this
plastic must be regarded as the largest contributor to the
nation's dioxin burden.

*  PVC accounts for the majority of dioxins emitted by
incinerators for medical and municipal wastes, the two largest
dioxin sources identified by EPA.  Disposable PVC products are
responsible for the vast majority of the chlorine fed to these
facilities and are thus the primary source of dioxin emissions.

*  Dioxin output from the burning of large quantities of
chlorine-rich EDC/VCM process wastes in on-site and commercial
hazardous waste incinerators is almost entirely unquantified.
Undoubtedly, however, it is considerably greater than the
estimate given in USEPA's dioxin reassessment.  Existing dioxin
emission data are almost entirely the product of trial burns
in which the stack testing method has been demonstrated to
achieve only a 26 percent recovery of the dioxin spiked into the
sample collection system during its evaluation with a full-size
incinerator.  Also these data do not reflect the higher dioxin
emissions associated with incinerator upsets and by-passing of
pollution control systems, both of which have been reported to
occur with considerable frequency.  In addition, Greenpeace
analyses of EDC/VCM wastes found high concentrations of metals,
including copper, which catalyzes the formation of dioxin during
burning in incinerators and other combustion systems.

*   PVC is the primary chlorine donor in recycling facilities for
copper, steel, lead and other metals.  These secondary smelting
facilities -- which receive PVC as residues on automobiles,
cables, electronic equipment, and batteries -- have been
identified by USEPA as major dioxin sources.

* PVC residues on scrap wood are the primary cause of dioxin
emissions from domestic and industrial wood burning, according to
European studies.  EPA has identified these sectors as major
dioxin sources.

* PVC burning in accidental home and building fires appears to be
a major source of dioxin.  PVC is now ubiquitous in modern
buildings, and high concentrations of dioxin have been found in
the residues from accidental fires in which uncontrolled PVC-
burning occurred in homes, schools, office buildings, and
industrial facilities.  The total contribution of PVC fires to
the national dioxin burden has not been estimated, but given the
hundreds of thousands of fires that occur each year, the dioxin
loadings are certain to be significant.


TIME FOR ACTION ON PVC AND DIOXIN

     According to USEPA's dioxin reassessment, dioxin is
extraordinarily toxic, persistent, and bioaccumulative.  Dioxin
is now distributed globally in the environment, food chain, and
human tissues, and EPA has found that current "background" levels
of dioxin are already at or near the range at which health
effects are known to occur.  These findings provide added weight
to recommendations such as the International Joint Commission
call for a phase-out of chlorine.

     PVC is the largest single contributor to the national
dioxin burden.  For the protection of public health and the
environment, a PVC phase-out must be a priority in the national
dioxin prevention program.  Important first steps include:

*  Prohibition of the oxychlorination process for the production
of EDC and other chemicals, along with the examination of all
other processes including direct chlorination for the generation
of dioxin;

*  Prohibition of new facilities or capacity expansions for the
production of EDC/VCM and PVC;

*  Modification of existing permits for EDC/VCM plants to bring
generation and releases of dioxin to zero;

*  Classification of relevant wastes from EDC/VCM production as
dioxin-listed and PCB-containing wastes, subject to all
appropriate regulatory requirements that have been revised to
reflect the inadequacies and limitations of incineration as a
treatment technology;

*  Prohibition of incineration of chlorine-rich wastes and/or
wastes from EDC/VCM production that contain dioxin and PCBs;

*  Rapid phase-out of PVC uses associated with the largest dioxin
releases, including short-life PVC uses (packaging and disposable
products sent to incinerators or otherwise burned), uses in areas
susceptible to fire (construction, appliances and automobiles),
and products recycled in smelters (cables and cars); and,

* A longer-term phase-out of other uses of PVC, with priorities
established according to environmental impact and the
availability of alternatives.

     Because the ultimate phase-out of PVC will have economic
impacts in the communities where manufacturing facilities are
located, transition planning processes must be an integral
component of any phase-out plan.  This process must be guided by
participation from labor, community and other stakeholders and
should seek to minimize the economic effects of the transition
and insure that costs and benefits are equitably distributed.
For instance, the Oil, Chemical, and Atomic Workers Union has
proposed a tax on chlorine and related chemicals; the revenue
would be used to encourage reinvestment in affected communities
and to provide income protection, continued health care, and
meaningful opportunities for higher education and re-employment
for workers and their families.



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1.  Heavy ends from distillation are the higher boiling residues
remaining after the chemical mixture generated by a specific
process or sequence of processes is heated to evaporate the
desired products, such as EDC or VCM, which are then captured by
condensation.


Jackie Hunt Christensen
Institute for Agriculture and Trade Policy
1313 5th St. SE, #303
Minneapolis, MN 55414 USA
phone: 612-379-5980
fax: 612-379-5982
e-mail: iatp@iatp.org