Re: GP sampling

[asagady@sojourn.com]

  At 12:04 PM 7/29/97 -0400, dbroten@rfu.org wrote:
  
  >To compare GP "stealing" samples of streams of waste which are going into
  >the public water and air, with industrial espionage for private profit, is
  >pure sophistry. 
  >
  
  There is one problem with this statement.   It is wrong!!
  
  Your  statement makes it seem like barrels of vinyl 
  production waste go into the water and the air.  
  
  It should be possible to find out through the hazardous waste manifest
  system precisely where vinyl production wastes go and how they are 
  handled, which is almost certainly  to either an onsite or commercial
  hazardous waste incinerator, 
  or commercial hazardous waste burning cement kiln or light weight aggregate 
  kiln.  
  
  The air and water discharges from these waste combustion devices ARE in
  the public domain but Greenpeace's report doesn't deal with 
  this issue;   it is really stretching it to say that a Greenpeace
  black bag job is somehow justified to see the content of a waste in storage
  that is NOT in the public domain.  These are distinctions that are not
  without a difference.
  
  Given that the performance of the universe of  hazardous waste incinerators
  and cement kilns
  in limiting dioxin/furan emissions (with many test conditions using spiked
  chlorine containing wastes) ranges over 4 orders of magnitude  (the stack 
  emission concentrations of the worst controlled/operated are 10,000 times
  the stack 
  emission concentration of the best controlled/operated),  it really does
  makes a difference
  where the waste is sent as far as the emissions to the environment.  
  
  To argue that it make no difference is again a flight away from the whole
  "worst first" approach that should guide efforts to limit the environmental and
  health impact of emissions of toxic air contaminants to the environment.
  Don't the public contributor's and the grantor dollars to environmental
  organizations deserve to be spent dealing with the worst problems first??
  
  
  >Unless, of course, the industry concerned had invited the public or public
  >interest groups to come do the unannounced inspections and sampling which
  >government no longer bothers to do. But I have never yet heard of such an
  >invitation. 
  >
  
  Collection of samples of waste and residuals occurs frequently during 
  waste inspections by federal and state officials.  Just go and
  review hazardous waste regulatory files on your local hazardous waste 
  site.  You will frequently encounter many samples taken during inspections
  and extensive analytical work.
  
  >We are in a situation where industry monitors itself and tells the rest of
  >us how much pollution it is emitting into our air and water.
  
  For the most part, on a day to day basis, this,  unfortunately, is true.   
  And this is a problem that this is not likely 
  to change anytime soon.   However, there are some improvements
  on the way.   We are close to having technology for  continuous emission
  monitors
  for toxic metal emissions from air discharge stacks.   This means
  continuous monitoring for toxic metals instead of a stack test for
  6-9 hours many once a year.  Although the continuous emission 
  monitors would still be operated by the industrial party, past experience
  with other types of continuous monitoring show that it regularly gets
  companies with problems into enforcement situations where their emissions
  are larger than permitted.
  
  
  >When anyone
  >questions this, men "of honour" get insulted. Except of course for those
  >emitting the unmarked brown envelopes!
  
  I don't really know what you are talking about here.   Unlike
  Sam, I  have never had any industrial clients (and I'm not looking for any)
  so it sure isn't me getting any of
  those "brown envelopes."   If you doubt this, talk with any environmental
  organization and many of the grassroots groups in Michigan.
  They'll know who I am and they'll tell you I've 
  been a major pain for industry for over two decades.
  
  I raise the issues about covert operations because I  think that the
  environmental movement
  always has to take the high road and maintain its credibility at all times;
  and the notion that it is somehow justified or politically correct
  (or even needed) to conduct the kind of covert operation that 
  Greenpeace wants to romanticize in its dioxin factories report and web pages
  allows our opponents to marginalize all environmentalists and reflects
  poorly on the entire movement..
  
  Greenpeace could have just as easily hired some chemists and chemical
  engineers to write an administrative petition to U.S. EPA seeking 
  a "data call-in" on all PVC production wastes and seeking an EPA
  on site hazardous waste inspection and waste characterization on 
  both the PVC production wastes and on the sites where the waste
  is disposed/combusted. 
  
  Greenpeace could have commissioned some bench scale chemical research
  to replicate process conditions in PVC plants and look at the yield
  of chlorinated dioxins/furans and other chlorinated organics to support
  such a petition to EPA.   We're talking about one of the most wealthy
  of all environmental groups so they should have the money to do these
  kinds of things.
  
  Collecting waste samples in a black bag operation means that 
  the information they derived will never be admissible in any kind
  of legal proceeding because they will never be able to make a "chain
  of custody" on the information stick.  It means that they will not be 
  able to use the information in a citizen suit against any environmental
  violator.
  
  So what is the point other than getting a publicity hit??   I
  don't think the environmental movement should allow its tactics
  to sink to those of G. Gordon Liddy.
  
  
  
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