Re: DIOXIN-L digest 541

[ttweed@wildrockies.org (Tony Tweedale)]

  alex said:
  
  [i disagree strongly w/ your post, but i have a few specific comments too]:
  
  >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.
  
  hmmn...i recall some major reagan/gorsuch era industry undue influence in
  keeping heavily chlorinated industry specific (i.e. the listed ones) rcra
  wastes from being created.  it's hard to report wastes that don't
  'exist'...
  
  >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.
  
  again, i believe the operating assumption is that if g.p. feels perfectly
  comfortable making it as public as they did how they got the samples; then
  they must have some  moral justification.  if you read both the earlier &
  the current reports, they mention  repeated refusals by the companies to
  provide the data, and they emphasize that epa & the industry seem satisfied
  w/ the industry reporting no air pathway contributing to emissions for
  epa's dioxin reassesment (!).  that doesn't pass my smell test, therefore i
  believe gp's response, what is public of it, appropriate.
  
  >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
  
  hasn't been my experience in digesting several facility files here.
  occassional, at best.  state rcra programs are quite individualistic.
  
  >to change anytime soon.   However, there are some improvements
  >on the way.   We are close to having technology for  continuous emission
  >monitors
  
  the real goal line is direct telemetry of cem data to the agency.
  technically achievable for decades, only a couple states practice it, in
  very limited programs.  i can't imagine why there isn't more...
  
  >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
  >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.
  
  wealthy?  relative to industry?  to the amount of work they do?
  gimme a break--i don't know the success rate for such or similar petitions
  further back than a couple years, but the ones i have seen have mostly
  failed.
  
  >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.
  
  why would you guess they asked for it first?
  
  >So what is the point other than getting a publicity hit??   I
  
  for one, it is infinitly more data points that they got by playing patsy
  and asking nice.  and very potent data too, w/ all that implies.  imo, your
  ethical judgement model's event horizons need resetting to a broader scope.
  
  
  as to your practical reasons, you are making some kind of link between gp's
  action &  epa's proposal, which by regulating concentrations instead of
  mass emissions, will allow any mass amount of pollutant to be emitted.
  appreciate that, but how does it relate to your argument against gp's
  tactic?  i'd guess combustion at edc & pvc plants, is largely in bif, not
  hwi.  in any case, gp's main accomplishment (other than rebutting the bad
  science practised by rigo et al.), that you can't tolerate, seems to have
  been to document typical (small 'n', tho) cl feed concentrations to the
  burners.
  
  
  tony tweedale