Part 2 of Greenpeace summary of CHEMICAL WEEK chlorine conference

[IATP@iatp.org (IATP)]

ROBERT IULIUCCI, VP Env. Safety and Health, Sequa Corp.

(Sequa manufactures and repairs jet engines for missiles, cig.
lighters for autos, electro-optical devices for military, etc.,
coated steel for building construction, and tuxedos).

Sequa replaced 1,1,1-trichloroethane as a degreaser in metal
finishing because of the Montreal Protocol.  EPA urged them to go
to trichloroethylene, but they ran into a problem with
groundwater contamination after one incident when a worker
mistakenly put acetone into the degreaser varporizing device,
starting a fire. Water was used to put it out, and flooded the
area, spreading 20 gallons of trichlor, which quickly seeped into
the ground and cost $2.5 million to clean up.

He discussed problems of solvents and replacements. With many of
non-chlorinated solvents they need 3 tanks to replace one used
before in vapor system -- one for the solvent solution, one cold
water rinse and one hot water drying tank.  So capital cost and
extended cycle time are minuses, but reduced hazardous waste
disposal costs, cleanup liabilities, etc. are advantages. They
added ultrasonics with air and mechanical agitation (like
dishwasher) to the new system.  One problem is that it doesn't
get into tiny holes like vapor degreaser, need to check for
microscopic particles.  Different chemicals used for different
parts.

Inconsistencies between commercial and military specifications
are gradually being ironed out.


ADRIENNE PIERCE, Business Analyst with Molten Metal Technology,
Inc.

MMT Is promoting a new Pollution Control Technology called
Catalytic Extraction Processing (CEP), which they mistakingly
call a "pollution prevention technology."

Basically, her presentation was like a sales pitch to companies
to use their technology, instead of incineration.  Rumor has it
they have somehow been supported by a Massachusetts state
technical development program, and have used state Democratic
connections to received precommercial development support from
the Clinton Administration.

They tout process attributes the chlorine-producing and using
industry seeks.   CEP is supposedly "closed-loop," by which they
mean it's stack-less, flameless.

Solids, sludges, liquids and gases go in to a molten metal bath,
where they are broken down into elements that are gas purified
into separate constituents, and supposedly come out as saleable
products: metals, gases and inorganics.

CEP eliminates certain conditions required for dioxin formation,
including excess free O, and aromatic precursors.  They also
claim to control residence time and catalytic surfaces which also
aid in dioxin formation.  Chlorinated wastes are "converted into
HCl or condensed-phase chlorinated products, with no harmful by-
products."

They claim that cost is 20-40% less than combustion technologies.

Fluor-Daniel is their engineering/construction partner.
Targetting pulp and paper mills (cost comparable to 60% less for
30-50 KT/yr paper mills), PVC plants, where they say they can
handle light ends, gases.  They have no operating units at VCM
plants but will demonstrate it at Oak Ridge, TN by the end of the
year. (Gore connection?)

Commercialization strategy includes working with Martin Marietta
on joint venture for government contracts to treat mixed rad/haz
waste, commercial radwaste joint venture with Westinghouse, and
working on pilot plant with Hoechst in Bay City, TX (to handle
biosolid sludges from acetic acid facility), as well as Rollins.

ON THE FRONT LINE: CUSTOMER PERSPECTIVES

BILL FISHER, Sr. VP, Government Relations, International
Fabricare Institute

This guy wins the whiner-of-the day award.  Claims they are the
key point of attack for Greenpeace's chlorine campaign.
"Will Pulp and Paper please be willing to take this back from us
because we're not crazy for this kind of attention."

Much of his presentation was an exaggerated outline of the
history of attacks on the industry by GP, ACTWU and others.

Says that after they developed Title III Clean Air Act Air Toxics
NESHAP Standard with EPA through proper promulgation process,
ACTWU and Greenpeace pushed for a rehearing "despite the fact
that EPA had already met Congress's intent" with the previous
hearings.  Greenpeace, he claimed, "leafletted most of Manhattan,
Queens and the Bronx" to get people out for the rehearing. He
warned of the forthcoming report by Barbara Warren and Consumer's
Union (Consumer's Reports).

Calls the EPA report on alternatives "at best premature."  Says,
EPA report defies common sense:  somehow the alternatives
increase the amount of people by 25%, while labor costs drop.
Describes EPA's "Design for the Environment" multistakeholder
evaluation of the alternatives.  "Biggest issue at this point,
however, is the so-called Cleaner Technology Substitute
Assessment document ... it has taken on a life of its own."

He read from the recent GP/ACTWU/Ozonoff letter to Lynn Goldman
saying that the document must describe perc as a carcinogen.

He described David Ozonoff's epidemiological study as "probably
somewhat biased," though he could give no specifics as to how.

Worst situation is where you have dry cleaners below apartment
buildings, as in New York.

"We as an industry have a major Superfund problem.  We've been
quite public about this. 95% of perc-based facilities in the U.S.
are contaminated.  Under the current clean-up regimes, cleanup of
contamination will typically be in the $500,000 to two million
dollar range.  Under current laws the property owners --
including shopping centers -- can be jointly liable.  For this
reason we are proposing an amendment to the Superfund that would
require the average dry cleaner in the U.S. to contribute
approximately $5000 to a $150 million fund to help clean up those
sites."  (What about preventing the creation of new sites by not
using perc?)

Is there a middle ground?  There might be.  "I think Greenpeace
in particular realizes it's difficult when you're beating up on a
small business industry.  It's difficult because there can be
some degree of public sympathy for small businesses.  Certainly I
think Washington State apple growers established that precedent.

It's one that we have to be willing to bandy about as we talk to
regulators and others. We don't want to go the way of the apple
growers.  Again I think Greenpeace and some others are aware.  In
meetings with representatives from Greenpeace they acknowlege
that it's a problem for them.  But they want to see the use of
perc eliminated as quickly as possible in the dry cleaning
industry.  A possible direction and an issue that we have been
meeting is a retraction by Greenpeace and ACTWU in the way they
present their information on perc at least relative to dry
cleaning.  The problem is that the continuous statements on
perc's toxicity is inevitably leading to higher potential
liability.  The dry cleaner knows they are being saddled with
this liability and poitential consumer liability...we have no
difficulty with looking at alternatives.  In fact that is the
direction we are going.  Not because because we think that perc
is a human carcinogen.  We will be pushing for better science in
the meantime."



JOEL GRAYSON, Group Vice President for BIOLAB, responsible for
pool and spa chemicals.

Don't see a threat from environmentalists, but from device
sellers in the industry who have emphasized the toxic nature of
chlorine in ads. ("We don't need Greenpeace when we've got idiots
like that.")

Ridiculous to attack chlorine, when it's used in vinyl pipes and
pool liners.

Says red eye is from misuse of chlorine, and complaints about dry
skin are probably from people who swim 12 hours a day.

Sees customer base as potential political force for legislation,
etc.

Chloroform in pools potential weakness:  Prop 65 in California
(largest market for pools, spas) gives bounty law.  "Chloroform
in pools may be a big issue...the jury is still out on this
issue."


MEETING THE U.S. TOXICS CHALLENGE

JOANNA UNDERWOOD, INFORM, Inc.

Joanna's presentation essentially summarized the findings of
their new report, "Toxics Watch, 1995" which took on a CMA
challenge ("don't trust us, track us") by using cross-
disciplinary data from the Toxics Release Inventory (up to 1992),
the Toxic Substances and Control Act 1989 Chemical Review Program
database, and RCRA facility waste generation databases.  By doing
so, INFORM shies away from directly articulating a position on
phasing chlorine chemistry, though they provide information
useful in supporting our position.  ("It was Jefferson who said
you can really only trust a democracy to an informed public")
But one thing she said could be more of a summary of her position
on the chlorine issue:  "not only you in industry but all of us
who are working full time to try to solve environmental problems
are groping...the path is somewhat uncharted...we're groping for
a better overview and a new foothold that will take us in the
right direction."

Findings of the Report:

Much of what she had to say outlined evidence that the industry's
claims about waste reduction are flawed, that source reduction
may not be happening and, where it is happening, may not be
enough.
*  Industrial waste moving away from direct disposal to increases
in "recycling" and other waste management methods.

*  Of the ten companies with the largest waste generation, 7 went
up in amount generated, 3 went down.
*  Four of five of the top generators of carcinogens increased
their generation, while one went down.

Source Reduction:

*  Only 25% of 92 TRI forms indicate Source Reduction efforts
were even looked at.

*  Source Reduction is not enough since products themselves are a
major source of contamination at Superfund sites. Product use was
the major source of contamination at 18 of 36 Superfund sites
they examined in three states: Delaware, Michigan and New York.

*  TSCA does not deal with many chemicals since 99.98% were
already in production before 1979, when the law establishing the
Chemical Review Program went into effect.  TSCA also allows
chemicals to be considered innocent until proven guilty:  too
many value assumptions and the legal benefit of proof balance in
favor of chemicals proposed for introduction.

*  Products are the major source of air pollutants people are
exposed to.  E.g. paradichlorobenzenes from odorizers.
The lesson of lead in products (paint, gasoline) and CFC venting
from products also teaches us to look beyond wastes.

Questions emerge from the research which challenge industry's
Responsible Care program:

*  How do we ensure there's more progress made in source
reduction? If they don't self-regulate, then taxes, etc. may have
to happen.

*  How do you "track" product stewardship?  What data does the
public need?


RISK MANAGEMENT AND RISK COMMUNICATION

SUSAN SANTOS, Focus Group and Research Program Director, Columbia
University for Risk Communications

Santos has worked for government, industry and citizens groups on
risk assessments (including 3rd party review of Risk Assessment
at Holbrook, MA for a citizens group).  Now she is conducting an
analysis on breast cancer and the environment in Cape Cod for
Tufts University.

She covered a lot of ground in a short time, basically giving
advise on risk communication strategies.

With Risk Communication "there's no single truth, a lot of
scientific uncertainty".

She advises them to avoid using naturally-occurring
organochlorines, since that will instinctively breed mistrust and
only increase concern about organochlorines.

She says the public is very galvanized about xenoestrogens.
(including Chlormones).

Advises industry not to put stock in new risk legislation.  There
will be a public backlash once it comes out.

In risk assessment every thing is PR.  That is, Perception =
Reality.  The actual magnitude of the risk affects perceptions of
risk the least.  So it's a mistake to reassess the risks of
dioxin, for instance, without focusing on how to communicate that
risk.

Identifies three "Public"s which may require different messages
and channels of communication:
* Passive public -- largely unaware
* Attentive public -- relatively aware
* Active public -- seeking to affect decisions and make its views
known (people near facility, env. groups, others already engaged,
not necessarily activists).

"When you (industry) take on the media and environmental groups,
you only lose credibility.  You need to build trust and
credibility by making alliances with environmentalists and the
media"

"Special considerations are Needed to Target/Involve low income,
minority and/or other underrepresented communities which bear a
disproportionate burden of the nation's environmental problems."

Must do objective information gathering, rather than go on
personal hunches.  Surveys, focus groups, etc.

Difficulties in understanding "the science" explain only part of
the divergence between Experts' and Others' risk judgements.
Other factors:
*  Sources of information
*  Styles of presentation
*  Personal background
*  Cultural context
*  Outrage Factors

Demonstration of Trust and Empathy are far more valuable than
competence and expertise on a subject, which are valued at about
the same level as honest/openness/dedication/commitment.  Dryness
creates distrust.

"Credibility can be enhanced by coordinating your activities, for
example by issuing joing communications with other sources.
Among the top third most credible sources on health, safety and
environmental issues are
 * physicians and other health professionals
 * professors (esp. senior prof's from respected local
   universities)
 * local citizens who appear to be neutral and knowlegeable
 * non-profit voluntary health organizations (American
   Cancer Society)
 * non-management employees

Among middle third are:  media and environmental groups
Lowest third: government, industry officials.

Pitfalls in risk communication:

*  Jargon:  define all technical terms and acronyms. Use language
that is understandable by a 12-year-old.
*  Attacks:  attack the issue, not the person.
*  Humor: use only when directed at yourself.
*  Don't compare unrelated risks: e.g. chemicals and peanut
butter
*  Refute the allegation without repeating it.
*  Don't refer to national problems: ie, "this is not a Love
Canal"
*  Technical details and debates: focus on factors that enhance
credibility: empathy, competence, honesty, and dedication.
*  Don't shift blame or responsibility

Target messages to personal level: e.g.  women who breastfeed.

Symbols:

"What cooling towers were to nukes and rusting barrels to
hazardous waste is what dioxin is to chlorine."


UNIVERSITY-BASED RESEARCH

DR. LORENZ RHOMBERG, Assistant Professor of Risk Analysis,
Harvard Center for Risk Analysis (where they don't do new science
but "study science and policy and how they interact").

This guy gave eloquently garbled advice on how the industry can
deny, stall and baffle and befuddle us all.

E.g. "With conflicting opinions the point is not to get anwers or
get consensus, but to characterize uncertainty"  into its
specific components.  (Remember what Yosie said about building a
"scientific wall"?), then ask which questions are best to answer.

(I.e., which questions are not likely to receive answers during a
specific research funding cycle, so that the taxpayers can pay
for all this wait and see, and not receive anything that's
damaging to industry as a result).

Areas where there are scientific disagreements:  environmental
estrogens (sperm counts, etc.) and wildlife effects.
Issue of "trends".  E.g. in research on breast cancer there are
disagreements over how much there is over time and how much you
can attribute to screening, etc.

"It could be that the whole sperm count issue is a question of
methodology."


CARLOS SONNENSCHEIN, Tufts University, specialist on estrogen
action research.

He is a researcher who discovered the estrogenic effects of some
chemicals by accident when he found out that bisphenyl A leaked
out of a test tube made by Dow Corning, causing changes in in
vitro cellular experiments.

Sonnenschein has an article in press soon to come out in Env.
Health Perspectives on developing an E-Screen assay for
estrogenic xenobiotics.  About a third of the compounds so-far
tested, including many of the phthalates (the pasticizer
additives used in PVC), are on his list of estrogenic
xenobiotics.

Conclusion:

** Xenobiotics of widely diverse chemical structures are
estrogenic, therefore chemical formulas are not predictive of
estrogenic properties of the molecule.

** We need a bioassay to identify estrogenic xenobiotics.

** The E-screen assay is reliable, sensitive and inexpensive.

--------

Two other papers were included in the conference proceedings
which were not delivered:

Graedel, T. E. (AT&T Bell Labs, Murray Hill, NJ) and W.C. Keene,
(Deptartment of Environmental Sciences, University of Virginia,
Charlottesville), "Tropospheric budget of reactive chlorine", in
Global Biogeochemical Cycles, Vol., 9, No 1, Pages 47-77, March
1995.

"Reactive chlorine in the lower atmosphere (as distinguished from
chlorofluorocarbon-derived chlorine in the stratosphere) is
important to considerations of precipitation acidity, corrosion,
foliar damage, and chemistry of the marine boundary layer.  Many
of the chlorine-containing gases are difficult to measure, and
natural sources appear to dominate anthropogenic sources for some
chemical species...The principal sources of reactive chlorine are
volatilization from seasalt (enhanced by anthropogenically
generated reactants), marine algae, volcanoes, and coal
combustion (natural sources being thus quite important to the
budget).  It is anticipated that the concentrations of
tropospheric reactive chlorine will continue to increase in the
next several decades, particularly near urban areas in the
rapidly developing countries."

(Looks like they may have opened up a new can of worms here:
Global saturation with organochlorines.  If natural sources are
the biggest source then why are levels higher in urban areas?)

and

William Keene, Department of Env. Sciences, Univeristy of
Virginia, Charlottesville, VA "Proposal to Chemical
Manufacturers' Association," (to make a reactive chlorine
emissions inventory) October 28, 1994.

"This research effort will be conducted under the auspices of the
International Global Atmospheric Chemistry (IGAC) Program's
Global Emissions Inventory Activity (GEIA); the work involves
investigators from several institutions each with expertise in
specific fields.  We will draw on published and unpublished data;
no funds are requested for additional measurements.  Results will
yield the first integrated estimates for gridded emissions fluxes
of reactive chlorine on a global scale.  The inventory will allow
quantitative differentiation of the relative magnitudes and
associated environmental significance of major natural and
anthropogenic sources.  As part of the analysis, we will also
critically assess the reliability of the estimates and thereby
constrain overall uncertainties in the emission fluxes of
reactive chlorinated compounds.  Results will provide important
and currently unavailable information with which to make informed
decisions regarding proposed regulatory strategies."

DR. WILLIAM TOSCANO, Chairman, Department of Environmental Health
& Sciences, Tulane School of Public Health & Tropical Medicine.

Dr. Toscano gave a presentation on receptor-mediated actions of
TCDD.  The work in his laboratory has focused on using human skin
cells in culture as a model system to study the molecular action
of dioxins.

"In summary then, we have demonstrated that dioxins can modulate
enzymes in human cells, by interacting via the Ah receptor, with
DNA.  Further, dioxins modulate the expression of factors
involved in growth of human cells that can result in uncontrolled
proliferation of those cells.  So does TCDD cause cancer in
humans?  We do not know.  Does TCDD alter human cell function?
Yes.  Should we be worried about human exposure to TCDD and other
dioxins?  I believe we should."

END-USER WORKSHOPS

1) CHLORINATED SOLVENTS

I didn't attend this workshop, conducted by Daniel B. Pourreau of
Arco, but his overheads covered the following:

Description of 1990 world demand.

Description of why chlorinated solvents are under regulatory
pressure:  ozone depleting potentials, inhalation hazards, cancer
evidence.

Description of solvent uses:  metal cleaning, dry cleaning, paint
stripping; alternatives.

Why alternative solvents are here to stay:
* Lower environmental persistence
* water miscibility
* comparable performance
* lower exposure hazards
* recyclability
* lower usage
* comparable costs

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