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Re: GP sampling
At 12:04 PM 7/29/97 -0400, email@example.com 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
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
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
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
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
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.
>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
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
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
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.
Alex J. Sagady & Associates Email: firstname.lastname@example.org
Environmental Consulting and Database Systems
PO Box 39 East Lansing, MI 48826-0039
(517) 332-6971 (voice); (517) 332-8987 (fax)