they're back: oh happy days!!

[charlie.cray@green2.greenpeace.org]

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Original-TO:      dioxin-l@essential.org
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assertion:
We think you didn't read carefully. The incineration of PVC
production-waste is counted as (the largest) part of the dioxin
emissions from PVC production, wich is accused by Greenpeace to
emit enormous quantities of dioxins, wich is obvious not thrue.
 
reply:
"Obvious" ???  Who says?  What level of dioxin do the
chlorophools suggest is safe?  
 
We do not have exact figures for dioxin emissions from US EDC/VCM
production incinerators...the industry has refused to submit that

data to EPA for the Dioxin Reassessment, though EPA TWICE called
in for data on a voluntary basis, and if they have tested their
BIF's they have not publicly released that data either. 
(Industry chose a delay tactic: test the smallest sources first:
pipe resin, water discharge, etc. ... so that the incinerator/BIF
and fugitive emissions data doesn't get into the reassessment).
 

Industry argues that dioxin in the wastes from incineration are
destroyed when incinerated.  And yes, Virginia there is a Santa

Claus...
Tests on Dow's Edmonton, Canada facility show that -- to the
contrary -- incinerators burning VCM wastes are emitting

substantial amounts of dioxin.  And that's under carefully
controlled circumstances which do not reflect everyday operations
-- upset conditions, etc.
 
Although considerable emissions occur from direct discharges from
incinerator stacks, an even greater amount may be released
through diffuse emissions to the air.  Diffuse emissions result
from leaking valves, pipe connections, storage tanks, and
especially unregulated combustion devices -- flares, thermal
oxidizers, etc.
 
Suspecting that diffuse organochlorine emissions pose an even
greater threat than direct discharges, the Norwegian Institute
for Air Analysis conducted a comprehensive study in 1990 of
diffuse emissions from a Norsk Hydro plant in Norway.  A similar
study was conducted in Sweden. (Vurdering av Difffuse utslipp fra
VCM fabrikken pa Hydro Rafnes;  Niklasson, R. 1992,
Samanstallning av utslapp til luft og vatn under 1990 fra Hydro
Plast AB.) 
 
The Instutute reported that diffuse emissions of organochlorines
(including ethylene chloride, VCM and EDC) at the Norwegian plant
were 65 times higher than direct discharges.  At the Swedish
plant, diffuse organochlorine emissions were over 12 times higher
than direct discharges.
 
Chlorophools assertion:
The amount of dioxins emitted from the incineration of the entire
amount of PVC pipes at the end of their usefull life was counted
separately, because that differs very much between Europe and the
US/Canada, entirely due to the quality of the incinerators...
In reality it is still near zero now, because near zero PVC pipe
is incinerated, it is still in use! And after that time, you even
can reuse or recycle it... There are at this moment no
indications - even after fifty years of use - that it is
degrading in any way, which is a good property for this kind of
application.
 
Response:
In June 1992 the Kansas Department of Health and Enivornment
(KDHE) detected Vinyl Chloride Monomer (VCM) in water in Doniphan
County Rural Water District #5.  VCM was found in later tests
from 2.9 to 7.4 ppb.  Industry later admitted that 23 year old
pipe was the source of VCM in the water.  
 
Anyone who is interested in the PVC pipe issue should get a copy
of the PVC pipe report put out by the City of Toronto's Public
Health Dept.
 
Assertion:
There have been many, many tests that disprove the connection
between chlorine in the input and dioxins in the output, compared
with a few wich prove it... and a few wich prove the contrary.
That means that any burnable material gives the same amount of
dioxins in the same incinerator under the same circumstances, no
matter what the chlorine or carbon content is, as long as there
is some present, wich is unavoidable.
 
Response:
It is avoidable: simply don't burn garbage (common sense),
because it turns mostly perfectly good materials into ash and
toxic gases.
 
assertion:
And we haven't seen any peer-reviewed scientific comment yet from
the scientific community that this claim is not thrue, neither
that replacing PVC by other materials will give less persistent,
bioaccumulating, hazardous pollution...
 
reply:
The Clean Combustion Technology Laboratory undertook the
experiment I cited in my last posting in response to the
Chlorophools  to answer the question: "Is there a relationship
between PVC input and the chlorinated hydrocarbon emissions from
incineration? ... These results, contrary to the prevailing
opinion lead to the physically reasonable conclusion that
decreases in the levels of organically bound chlorine (PVC) in
the input leads to decreases in chlorinated organic emissions.
... Thus we are convinced that, when all other factors are held
constant, there is a direct correlation between input PVC and

output PCDD/PCDF and that it is purposeful to reduce chlorinated
plastics input to incinerators."  (John C. Wagner and Alex ES

Green, Correlation of Chlorinated Organic Compound Emissions From
Incineration With Chlorinated Organic Input; Chemosphere, Vol.
26, No. 11, pp2039-2054, 1993)

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