Re: warning: EPA again closing down input on PVC dioxins

[DrBillC@aol.com]

I'd like to take just a moment to respond to Tony's analysis of the Vinyl
Institute sampling program.

I'll start by noting that I understand that if I counted my toes and reported
the number many on the list would argue that I had a proprietary interest in
there being ten, so my number is unreliable.  Let's not even discuss that for
the moment.  Let's discuss process AND results.

Here's what we did.  We looked at emissions.  That is, where it enters the
environment, whether product or waste, measure it. Samples were analyzed at
independent labs, sometimes more than one.  The results were reviewed by an
outside validator.  We commissioned four independent scientists to act as
referees on design, collection and analysis.  They watched the process,
visited plants, visited laboratorys, read and quality controlled the report,
commented on it,  and wouldn't sign off until their comments were satisfied.

Now, for comparison, Greenpeace broke into plants in the dead of night, stole
samples, analyzed them in their own laboratories and reported the results at a
press conference.  Who's ethically conflicted?

Most of the large streams are done, and here's a summary. We got samples of
commercial resin and analyzed them.  The detection limit was about 1 ppt for
the first ten.  The rest were better-about 0.2 ppt.  23 of 27 samples were
non-detect.  The NDs are reported as DL/2.  This extrapolates to about 3 grams
TEQ per year.

We collected EDC samples that would get sold outside the process.  Four of
five ND across the board at detection limits below 1 ppt.  That's less than a
gram.

We took water samples and analyzed them.  Many of them were ND across the
board, but with DL/2 ranged between about 2 and 6 ppq.  This extrapolates to
about 0.5 grams TEQ/year.

We took wastewater treatment solids (sludge) samples.  The data ranged from
about 100 ppt to about 10 ppb.  This material is generally landfilled, and the
best estimate is it extrapolates to about 12 grams TEQ/yr.  If you take the
worst single sample and use it to characterize the entire industry's material,
landfilled or not, analyzed and found to have a lower number or not, it
amounts to about 28 grams TEQ.

We looked at stacks and also collected data that was in the files.  We counted
backup incinerators that run occasionally as running all the time.  The
central case estimate is about 11 grams per year.  The worst case is about 31
grams.  No, we didn't look at upsets since we couldn't convince everyone to
run four hours under "upset" conditions with no action taken to fix it so we
could get a sample.

Add it all up, you get a central estimate to land, water and surface
impoundment of 16 grams.  Add the landfilled material in, it's 28 grams.  Take
the worst case, it's 63 grams.

We published this at Dioxin '96 and Dioxin '97.  We provided copies of the
final report-recently done, and all seven inches of it to EPA and Rick Hind
and Pat Costner of Greenpeace.  It represents about twenty times as many
samples as had ever been done on the industry up to this time.

So why don't our results match Greenpeace's?  One reason is that the samples
they've analyzed-the ones obtained during the "secret" actions-are of
materials that are not emitted.  They are burned.  And we sampled the stacks.
The sediment sample from outside the Geon plant was barely above background.

So that's it.  This was an honest attempt to provide data where there was none
and do it in the sunshine.  If I was going to lie about the results, why would
I go to all this trouble?  Sometimes, Tony, even people you disagree with do
an honest job.

Incidentally-a Russian paper at Dioxin '98 that looked at similar streams got
similar results.  Go figure.

Bill Carroll
For the Vinyl Institute