[Dioxin-l] Reply
Carl Larkins
carllark@olypen.com
Tue, 11 Jan 2000 18:13:56 -0800
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Greetings All,
in spite of my resolve not to get draged into this, I am in. I
offer the comments shown below.
Carl Larkins
----- Original Message -----
From: superjicb
To: dioxin-l@lists.essential.org
Sent: Monday, January 10, 2000 9:22 AM
Subject: [Dioxin-l] Reply
David,
Your comment:
> One of the interesting things is that erring on the side of
caution can have its costs. So currently, the US EPA estimates
daily intake of dioxin TEQs as 1-4 ng/kg, or 100-400 times
greater than the EPA recommended intake. It is not clear how
one would get the level of dioxin TEQ intake down by 400 fold;
it would certainly be an expensive undertaking. Some estimates
are that it would cost in excess of the US GNP to reduce dioxin
intakes to the US EPA
recommended levels; clearly you would only want to spend that
money if there were to be a tangible benefit.
My reply:
One of the interesting things is that erring on the side of
risk can have is costs, both to human health, shorter life
spans, and to the economy in the form of high medical bills,
lost productivity, etc. I cannot comment on the validity of
the EPAs numbers but plain old common sense tells me that here
we are not even talking about erring on the side of risk. If
scientists already think our dioxin intake is too high, then we
are talking about blatent disregard. This only makes it more
urgent that we move quickly to do what we can to stop from
increasing dioxin levels even further. The answer is not to
throw up our hands and give up.
=============================================
My comment:
If there have been benifits from products that spawn dioxin,
those benificaries should bear the cost of any harm caused by
dioxin and
the cost of preventing dioxin from causing additional harm.
Especially in those cases where alternatives exist, stock
hoders and others who reap chlorine profits are passing dioxin
related costs on to future generations.
=============================================
Your comment:
> > > Given the recent postings about production of dioxins
from uncontrolled burning, it may well be that the level of
dioxin in the 1800s largely stemmed from the incineration that
the local populace undertook. It clearly wasn't the chemical
industry.
My initial reply:
> >Why is it clear chemicals were not implicated?
Your reply:
> There was next to no organochlorine chemical industry in
the late 1800s, and
> precious little in America. Compare with hundreds of
millions of tons of
> organochlorines produced in the 60s; as far as I am aware,
there wasn't the
> technology to make, transport or a market to sell a million
tons of
> organochlorine compound in the 1800s. So where did the
environmental dioxin
> production come from in the 1800s? It still amounted to 10%
of current
> levels. I guess I can only think of uncontrolled burning;
all suggestions
> welcome.
My reply:
I can come up with a reason other than uncontrolled burning
that would implicate chlorine. When we talked about dioxin in
the late 1800s it was related to the Beaver Lake dioxin in
sludge study that you brought to our attention. We all know
chemical pulping occurs on large bodies of water. I think we
both agreed that the mid 1950s dioxin contamination of this
lake likely came from chlorine bleaching of pulp. What is in
contention is what occurred early on. Successful chemical
pulping began in about 1851 and to the best of my knowledge,
pulp was bleached with chlorine even before chemical pulping
became the standard. In the early 1800s British scientists
already knew how to produce chlorine electrochemically, but
because electricity was so expensive electrochemical chlorine
production did not occur until the 1900s, and in the 1800s
commercial chloirne was produced by oxidation of HCl with
manganese dioxide or air. I expect we'd all agree that early
pulping and bleaching was done with nearly total disregard for
the environment (not intentional disregard, but because
industry was likely unaware of the problem brewing). I don't
know the size of Beaver Lake, or how many if any mills it
supported, or if there was a chlorine plant on site to support
pulp bleaching, but logic suggests the whole thing is related
to pulp bleaching. You brought up this study as evidence of
some point. Would you please let us know what industry was on
this lake and when, so we can draw some intelligent conclusion
from the data?
Connie
================================
My comment:
Some of the recent postingson back yard burning are based on
test results that are skewed.
*The majority of backyard burning occurs in rural areas, but
the assumed contents of the burn barrel are based on studies
from urban areas.
*Conclusions were based on an incinerator based on a
destruction and removal efficiency that is rarely achieved (not
even during demonstration burns) with an unstated assumed fuel
mix that may or maynot be similar to that in the hypothetical
barrel.
*The study report was published (sponsored by?) the Journal
of the American chemical Society.
===============================
In response to the suggestion in the study report that the
"study could help resolve a long-standing discrepany as a
result of a 1994 EPA assesment that identified a "significant
gap" between estimates of dioxin estimates and actual
deposition measurements...";
I would suggest that EPA look at a source that they have
carefully ignored: The dioxins produced in wood-fired boilers
that include sludge and salty hogged fuel in their fuel mix.
Carl Larkins
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<DIV>Greetings All,</DIV>
<DIV> </DIV>
<DIV>in spite of my resolve not to get draged into this, I am in. =
I offer=20
the comments shown below.</DIV>
<DIV> </DIV>
<DIV>Carl Larkins</DIV>
<BLOCKQUOTE=20
style=3D"BORDER-LEFT: #000000 2px solid; MARGIN-LEFT: 5px; MARGIN-RIGHT: =
0px; PADDING-LEFT: 5px; PADDING-RIGHT: 0px">
<DIV style=3D"FONT: 10pt arial">----- Original Message ----- </DIV>
<DIV=20
style=3D"BACKGROUND: #e4e4e4; FONT: 10pt arial; font-color: =
black"><B>From:</B>=20
<A href=3D"mailto:superjicb@email.msn.com"=20
title=3Dsuperjicb@email.msn.com>superjicb</A> </DIV>
<DIV style=3D"FONT: 10pt arial"><B>To:</B> <A=20
href=3D"mailto:dioxin-l@lists.essential.org"=20
title=3Ddioxin-l@lists.essential.org>dioxin-l@lists.essential.org</A> =
</DIV>
<DIV style=3D"FONT: 10pt arial"><B>Sent:</B> Monday, January 10, 2000 =
9:22=20
AM</DIV>
<DIV style=3D"FONT: 10pt arial"><B>Subject:</B> [Dioxin-l] Reply</DIV>
<DIV><BR></DIV>
<DIV><FONT face=3DArial size=3D2>David, </DIV>
<P class=3DMsoNormal>Your comment:</P>
<P class=3DMsoNormal>> One of the interesting things is that erring =
on the=20
side of caution can have its costs. So currently, the US EPA estimates =
daily=20
intake of dioxin TEQs as 1-4 ng/kg, or 100-400 times greater than the =
EPA=20
recommended intake. It is not clear how one would get the level of =
dioxin TEQ=20
intake down by 400 fold; it would certainly be an expensive =
undertaking. Some=20
estimates are that it would cost in excess of the US GNP to reduce =
dioxin=20
intakes to the US EPA <BR>recommended levels; clearly you would only =
want to=20
spend that money if there were to be a tangible benefit.</P>
<P class=3DMsoNormal>My reply:</P>
<P class=3DMsoNormal>One of the interesting things is that erring on =
the side of=20
risk can have is costs, both to human health, shorter life spans, and =
to the=20
economy in the form of high medical bills, lost productivity, =
etc. I=20
cannot comment on the validity of the EPAs numbers but plain old =
common sense=20
tells me that here we are not even talking about erring on the side of =
risk. If scientists already think our dioxin intake is too high, =
then we=20
are talking about blatent disregard. This only makes it more =
urgent that=20
we move quickly to do what we can to stop from increasing dioxin =
levels even=20
further. The answer is not to throw up our hands and give =
up. =20
<BR><FONT =
size=3D2>=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D</FO=
NT></P>
<P class=3DMsoNormal><FONT size=3D2>My comment:</FONT></P>
<P class=3DMsoNormal>If there have been benifits from products that =
spawn=20
dioxin, those benificaries should bear the cost of any harm caused by =
dioxin=20
and<BR><FONT size=3D2> the cost of preventing dioxin from causing =
additional=20
harm. Especially in those cases where alternatives exist, =
stock=20
hoders and others who reap chlorine profits are passing dioxin related =
costs=20
on to future generations.</FONT></P>
<P =
class=3DMsoNormal>=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D</P>
<P class=3DMsoNormal><BR>Your comment:<BR>> > > Given the =
recent=20
postings about production of dioxins from uncontrolled burning, it may =
well be=20
that the level of dioxin in the 1800s largely stemmed from the =
incineration=20
that the local populace undertook. It clearly wasn't the chemical=20
industry.</P>
<P class=3DMsoNormal> My initial reply:<BR>> >Why is it =
clear=20
chemicals were not implicated?</P>
<P class=3DMsoNormal> Your reply:<BR>> There was next to no=20
organochlorine chemical industry in the late 1800s, and <BR>> =
precious=20
little in America. Compare with hundreds of millions of tons of =
<BR>>=20
organochlorines produced in the 60s; as far as I am aware, there =
wasn't the=20
<BR>> technology to make, transport or a market to sell a million =
tons of=20
<BR>> organochlorine compound in the 1800s. So where did the =
environmental=20
dioxin <BR>> production come from in the 1800s? It still amounted =
to 10% of=20
current <BR>> levels. I guess I can only think of uncontrolled =
burning; all=20
suggestions <BR>> welcome.</P>
<P class=3DMsoNormal>My reply:</P>
<P class=3DMsoNormal>I can come up with a reason other than =
uncontrolled burning=20
that would implicate chlorine. When we talked about dioxin in =
the late=20
1800s it was related to the Beaver Lake dioxin in sludge study that =
you=20
brought to our attention. We all know chemical pulping occurs on =
large=20
bodies of water.<SPAN style=3D"mso-spacerun: yes"> </SPAN>I =
think we both=20
agreed that the mid 1950s dioxin contamination of this lake likely =
came from=20
chlorine bleaching of pulp. What is in contention is what =
occurred=20
early on. Successful chemical pulping began in about 1851 and to =
the=20
best of my knowledge, pulp was bleached with chlorine even before =
chemical=20
pulping became the standard.<SPAN style=3D"mso-spacerun: yes"> =
In the=20
early 1800s British scientists already knew how to produce chlorine=20
electrochemically, but because electricity was so expensive =
electrochemical=20
chlorine production did not occur until the 1900s, and in the 1800s =
commercial=20
chloirne was produced by oxidation of HCl with manganese dioxide or =
air. =20
I expect we'd all agree that </SPAN>early pulping and bleaching was =
done with=20
nearly total disregard for the environment (not intentional disregard, =
but=20
because industry was likely unaware of the problem brewing). <SPAN=20
style=3D"mso-spacerun: yes"> I</SPAN> don't know the size =
of Beaver=20
Lake, or how many if any mills it supported, or if there was a =
chlorine plant=20
on site to support pulp bleaching, but logic suggests the whole thing =
is=20
related to pulp bleaching. You brought up this study as evidence =
of some=20
point. Would you please let us know what industry was on this =
lake and=20
when, so we can draw some intelligent conclusion from the data?</P>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">Connie</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">My=20
comment:</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN> </DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">Some=20
of the recent postingson back yard burning are based on test results =
that are=20
skewed.</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*The=20
majority of backyard burning occurs in rural areas, but the assumed =
contents=20
of the burn barrel are based on studies from urban areas.</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*Conclusions=20
were based on an incinerator based on a destruction and removal =
efficiency=20
that is rarely achieved (not even during demonstration burns) with an =
unstated=20
assumed fuel mix that may or maynot be similar to that in the =
hypothetical=20
barrel.</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">*The=20
study report was published (sponsored by?) the Journal of the American =
chemical Society.</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA">=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=3D=
=3D=3D=3D=3D=3D=3D=3D=3D=3D</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">In=20
response to the suggestion in the study report that the "study could =
help=20
resolve a long-standing discrepany as a result of a 1994=20
EPA assesment that identified a "significant gap" =
between=20
estimates of dioxin estimates and actual deposition=20
measurements...";</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">I=20
would suggest that EPA look at a source that they have carefully =
ignored: The=20
dioxins produced in wood-fired boilers that include sludge and salty =
hogged=20
fuel in their fuel mix.</SPAN></DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN> </DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: =
AR-SA"></SPAN> </DIV>
<DIV><SPAN=20
style=3D"FONT-FAMILY: 'Times New Roman'; FONT-SIZE: 12pt; =
mso-fareast-font-family: 'Times New Roman'; mso-ansi-language: EN-US; =
mso-fareast-language: EN-US; mso-bidi-language: AR-SA">Carl=20
Larkins</SPAN></FONT></DIV></BLOCKQUOTE></BODY></HTML>
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