warning: EPA again closing down input on PVC dioxins

[ttweed@wildrockies.org (Tony Tweedale)]

Scanning EPA's generally impressive (for its scope & detail)  'Inventory of
Sources of Dioxin in the U.S.' (4-'98, external review draft), in sec.
'8.3.4 -- PVC'  [production, not incineration] they state:

"However, this study [Stringer, Costner et al. in  _Organohalogen
Compounds_] acknowledges that because EDC/VCM production technologies and
waste-treatment/disposal practices are very site-specific, the limited
information currently available on CDD/CDF generation and emissions makes
it diffucult to quantify amounts"

and conclude:

"EPA anticipates that this information, along w/ the information from
previously cited sources, should be adequate to make a reasonable emission
estimate for this inventory."

"this information" refers to the (U.S.) Vinyl Institutes coming final
report on the subject, using their own sampling and analysis.  "info from
prev. cited sources" refers to the VI's & Greenpeace's sampling and
analysis.  Those two data source's emission factors give an annual
emissions inventory CDD/F of 0.56-28.3 g TEq/yr (VI) and 283-565 g TEq/yr
(Greenpeace), says EPA.  Quite a range.

Reading the large font between-the-lines, EPA is obviously intending to
rely on VI data for an important part of its critical, regulation-driving
dioxins emissions estimate.  EPA summarizes VI's '96 preliminary data:

22 samples from 14 of 24 U.S. PVC manuf's: ND at a (high!) D.L of 2 ppt!).

Six samples from 4 of 7 PVC dispersion plants: 0.4 ppt TEq (mean, w/ same 2
ppt DL and assuming ND's are 1/2 the DL).

Five samples from 5 of 15 EDC (VC building block) plants:  ND except for
one 0.03 ppt TEq sample; DL was 1 ppt

10 sites had wastewater samples, mean of 4.5 pg/L TEq assuming a ND is half
the DL of 10 pg/L.  (VERY roughly, 4.5 pg/L is 4.5 ppq).  VI calculated
total CDD/F release to water from U.S. PVC & EDC plants as 0.043 - 0.36
g/yr.

plant incinerators:  gee, I wonder why VI's preliminary report doesn't
sample incinerators (or flares, etc.)


It is a fundamental principle of toxicology that (valid) positive or higher
results must be given equal or even more initial consideration than a valid
negative or lower result.  Greenpeace discovered CDD/F levels ***millions
and even billions of times higher*** than the ethically conflicted VI's
data had.

EPA is strongly hinting they are planning to close the door to independant
data and ignore GP's limited (of necessity) data in favor of VI's
conflict-of-interest data.  That's a stinking outrage.

This draft report originated at least in part from EPA's Science Advisory
Board's recommendation to better estimate sources of dioxins, when SAB
reviewed the draft of EPA's dioxin reassessment.  The SAB will again be
reviewing the reassessment.  All concerned over this politically motivated
(witnessed by EPA's refusal to consider PVC as a source in the draft
reassessment), shabby 6th grade effort at science and  honesty by EPA
should tell the SAB so.  Or, if EPA opens another comment period on this
draft emissions report.

As evidenced yet again in the VI's reponse to Nike's recent PVC phase-out
decision, the industry is focusing on a strategy that cites the fact that
dioxin emissions seem to be going down even as PVC production is increasing
significantly.  This affects both the PVC production and incineration
questions   Given the large gap between known emissions and known
environmental levels, this, EPA's second failure to consider PVC as a
source, seems a very relevant counter-argument.

No credible party I know of disputes that incineration dioxins are created
in slightly exponential relation to the amount of Cl in the feed, while
PVC's growing and significant fraction in the municipal waste stream is
indisputable.  Though I have never researched the chemistry of EDC & PVC
manufacture, I know it involves heat and chlorine ... duh.  I myself cannot
imagine that dioxin levels would be as low as the VI's preliminary sampling
& analysis claim.  Levels may not be as high as Greenpeace's sampling &
analysis indicate (though they stand as a fact), but are we going to let
those shits at EPA get away with using only the VI's data?

The country's whole environmental protection paradigm relies on data
generated by  industry w/ a direct conflict of interests, the overiding
interst being to minimize regulation.  Are we going to let EPA and industry
get away with it one more time?  Or are we going to demand, on this very
important question, through SAB real scientists, that EPA collect and
analyze its own samples, taken during *unannounced* plant visits, and whose
sampling plan (units sampled, DL's etc.) are representative enough to give
confident data?

Another contention is EPA's unscientific/careless (or deliberate)
assumption that dioxin generation & emissions are "very site-specific".
Especially for generation, this is a very questinable assumption.

Tony Tweedale

Causality is a concept not subject to empirical demonstration. -David Hume
(1711-'76)