More on Dioxin and PVC Production

[charlie.cray@green2.greenpeace.org]

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Original-TO:      dioxin-l@essential.org
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I feel compelled to respond to a posting put up by Dr. Bill Carroll of the
Chlorine Chemistry Council (and employee of Occidental Chemical, one of the
biggest makers of vinyl chloride in the US)
 
His posting:
 
In an earlier posting, Charlie Cray wrote:
 
<<While the Vinyl Institute and its members claim VCM production is a small
source of dioxins, they have yet to produce any data to substantiate their
claim.   In fact, limits in analytical methods make this virtually
impossible.>>

 
I suggest he review the papers from Dioxin '96, which at least two of his
colleagues attended.  There are two articles which contain exactly such data.
And, in fact, it is not impossible to make these determinations at sub ppt
levels.  And VCM production is a small source of dioxins.
 
Bill Carroll 
Chlorine Chemistry Council
 
It is true that the CCC/Vinyl Institute has completed studies of dioxins in
PVC product and wastewater discharges.  They are doing this as part  of a
"voluntary self-characterization assessment" for the EPA's much-awaited dioxin
reassessment.  But as they know very well, those are not the media where the

greatest dioxin emissions from VCM plants occur.  (The greatest emissions are
from incinerators,  boilers and  halogen acid furnaces, where light and
especially heavy ends/distillation tars from the oxychlorination process are
burned.  As ICI and other companies admit, the oxychlorination process is where
the highest levels of dioxin are formed, and indeed oxychlorination cannot be
conducted without forming dioxin).
 
Looking for dioxin in other emissions is important, but by prioritizing these
and delaying submission of air emissions data,  the industry is using a tactic
perfected  by the tobacco industry: delay, deny and hide.
 

Or, if you  prefer, it's like walking onto a bloody crime-scene and seeing
bullet ridden bodies, and beginning an investigation by searching for the
missing butter knives.
 
Even if we look at the studies the industry has done thus far, you can see
problems.  With the  product samples, for instance, they suggest they have
virtually no dioxins (some furans) in PVC.  This is contradicted by studies
done by the Swedish EPA and the British MAFF, both of which found higher
levels.  Moreover, in 1991, the Midwest Research Institute did an analysis of
Chlorinated PVC Samples for BF Goodrich where they found measurable quantities
of both dioxins and furans in various CPVC samples (again, the furan levels
were higher). Of  course, Goodrich did not submit this study to EPA.  Neither
did the Vinyl Institute, as part of its program, though  they discussed it at
one of their board meetings (and therefore all of their members knew of it
since at least 1992).
 
As for water discharges, numerous studies in Europe by Evers have identified
VCM plants as a major source of dioxins in the North Sea.  (Perhaps part of
that is a legacy from the Ocean dumping days - god knows what's in the Gulf of
Mexico!)...There are fishing restrictions around numerous VCM Plants in the
Gulf of Mexico which suggests they are anything but "minimal" sources of dioxin
and other organochlorines.  High levels of dioxin have led to long-standing
fish advisories around the Lower Brazos river where Dow operates one of the
biggest VCM plants in the US.  A major metaanalysis conducted by NOAA of
different studies in the Lake Charles  area shows high levels of PCBs, HCBs and
other chemical cousins of dioxin around the PPG facility and the Vista Chemical
facility.  
 
Dr. Bill mentioned Dioxin 96.  Perhaps he missed the one paper which shows that
the highest levels of dioxin found in the Galveston Bay area were found at the
entrance to the Ship Channel, not far downstream from Occidental's VCM plant as
well as one owned by Geon (as well as the Rollins incinerator which burns VCM
production waste and Shell,  which makes dioxin in its  epichlorohydrin unit).
(Pieo R. Gardinali and Terry  L. Wade, "Levels of Toxic Polychlorinated
Biphenyls,  Dibenzo-p-dioxins and  Dibenzofurans in Biotic and Abiotic Samples
from Galveston Bay,  Texas U.S.A., Geochemical and Environmental Research
Group, Texas A & M, College Station, TX - in  Organohalogen Compounds, Vol. 29
(1996))
 
For those who haven't seen it, last year we published the results of a sampling
investigation of the VCM industry which we conducted on our own since the
industry has perfected the tobacco strategy.  (I.e. denounce your opponents for
not having data, then delaying the day when you cough up any data you may
have-maybe even cooking the results).  In it we reveal that one  sample had 6
ppm TEQ of dioxins, as  high as the levels in Agent Orange!  
 
It will be interesting to see what they say about their incinerator emissions,
and HOW those studies are conducted.
 
-END- 

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