The manufacturing process for Vinyl is very hazardous to the environment releasing high amounts of dioxins each day as well as the use of chlorine which is a primary cause of Acid Rain. In short vinyl windows are helping to destroy our precious planet ona daily basis

PVC

A Primary Contributor to the U.S. Dioxin Burden

Pat Costner with Charlie Cray, Gail Martin, Bonnie Rice, David Santillo and Ruth Stringer

also with contributions by Paul Johnston and by Allan Vincent, whose technical and practical contributions were particularly crucial. published in conjunction with the Greenpeace International Science Unit

Greenpeace Feb95

EXECUTIVE SUMMARY

Greenpeace launched a broad investigation of the PVC industry in 1994, specifically targeting U.S. chemical companies that manufacture the key chemicals for PVC production: ethylene dichloride (EDC) is converted into vinyl chloride monomer (VCM) which is then polymerized to form polyvinyl chloride, also known PVC or vinyl. Collecting and analyzing samples of process wastes and other materials, Greenpeace confirmed the following facts:

U.S. EDC/VCM facilities are creating large quantities of dioxin and PCBs. Waste samples from these facilities contained some of the highest dioxin concentrations ever reported in chemical processing wastes.

U.S. EDC/VCM facilities are releasing dioxin into the surrounding environment. A sediment sample taken downstream from one facility's wastewater discharge carried an extraordinarily high dioxin concentration; a sediment sample taken downstream from another facility, although not analyzed for dioxin, contained a chemical that has been reported to be an indicator for dioxin. No air, effluent or sludge samples were analyzed; however, dioxin has been identified in all of these media in industry and government studies of European EDC/VCM facilities, as well as in PVC itself.

Industry documents obtained by Greenpeace confirm that PVC production is inextricably linked to the formation and release of dioxin and PCBs, as follows.

Dioxin is the unavoidable by-product of PVC manufacture, specifically including the oxychlorination process, which is crucial to EDC production; and

PCBs are also unavoidable by-products of PVC production processes.

U.S. government documents reveal USEPA's responses to the dioxin/PVC connection as follows:

USEPA first learned that dioxin is generated in PVC manufacture during the Reagan/Bush administrations. Then, as now, the Agency had the power to require PVC manufacturers to prevent the generation and release of dioxin but did not do so.

After proposing to regulate dioxin in one PVC-related waste in 1988, USEPA conceded to industry pressure and, in 1990, deleted dioxin from the list of chemicals to be regulated; and

USEPA's documentation of the dioxin/PVC connection from the 1980s has not been acknowledged during the Agency's dioxin reassessment.

PVC plastic is the largest single use of chlorine in the U.S., accounting for about 34 percent of all chlorine production. PVC is produced by combining chlorine and ethylene gases (or ethylene, oxygen, and hydrochloric acid in a process called oxychlorination) to produce the intermediate EDC, which is then converted to VCM. VCM is polymerized to form PVC.

Eleven U.S. companies with fifteen facilities produce EDC. The combined VCM capacity of U.S. companies is almost fourteen billion pounds per year. In 1994, total PVC production in the U.S. was estimated at 10.88 billion pounds. A large body of evidence suggests that the greatest share of the nation's dioxin burden stems from the manufacture, use, recycling, and disposal of this enormous quantity of PVC plastic.

GREENPEACE'S SAMPLING AND ANALYSIS

After making several requests to USEPA to investigate the generation and release of dioxin during PVC manufacture, Greenpeace launched its own independent study in the summer of 1994. Greenpeace representatives gained access to areas for production, storage, treatment and disposal of wastes at twelve facilities in Louisiana and Texas where EDC and/or VCM are produced.

Fifty-one grab samples were retrieved from these facilities, 25 of which are addressed in this report. Samples were taken from containers bearing labels with USEPA waste codes and other content descriptions, from sediments in receiving streams for wastewater discharges, etc. All samples were shipped to an analytical laboratory, where chemical analyses were conducted for organic and metallic contaminants. Due to the extraordinary costs entailed, only four of these samples were selected for dioxin analysis and two for PCB analysis.

Process Wastes

Concentrations of dioxin in the three process waste samples were extraordinarily high:

Vulcan Chemicals, Geismar, Louisiana: A sample of heavy ends1 from the distillation of EDC contained dioxin at a total concentration of 200,750 parts per billion (ppb);

Formosa Plastics, Point Comfort, Texas: A sample of heavy ends from the distillation of VCM contained 761 ppb total dioxin;

Georgia Gulf, Plaquemine, Louisiana: A waste sample, collected from a tank containing F024 waste, had a total dioxin content of 1,248 ppb.

In comparison, wastes from the manufacture of Agent Orange, which are regulated by USEPA as "7023 and F020 dioxin-listed wastes," contain estimated total dioxin concentrations ranging from 33 to 238 ppb and 24,000 to 50,000,000 ppb, respectively. Dioxin concentrations found in the PVC-related wastes sampled by Greenpeace exceed those of Agent Orange waste F023 and, in one case, fall in the mid-range of Agent Orange waste F020.

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1 Heavy ends from distillation are the higher boiling residues remaining after the chemical mixture generated by a specific process or sequence of processes is heated to evaporate the desired products, such as EDC or VCM, which are then captured by condensation.

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Twenty-five samples from nine EDC/VCM facilities contained one or more of the following chemicals that have been reported to signal the presence of dioxin: hexachlorobenzene, 1,1,2,3,4,4- hexachloro-1,3- butadiene, tetrachlorobenzene, pentachlorobenzene, and 1,1,3,4-tetrachloro-1,3-butadiene. These nine facilities include the three listed above, plus the following:

Geon Vinyl (formerly BFGoodrich), LaPorte, Texas; Borden Chemical, Geismar, Louisiana; Dow Chemical, Freeport/Oyster Creek, Texas; Occidental Chemicals, Ingleside, Texas; * PPG Industries, Lake Charles, Louisiana; and Vista Chemical, Lake Charles, Louisiana.

These findings suggest that the 21 samples - 20 waste samples and one sediment sample - that were not directly analyzed for dioxin content also contained significant quantities of dioxin.

Sediments

In the fourth dioxin analysis, a sediment sample taken slightly downstream from the discharge point of the Geon Corporation (formerly BFGoodrich) in LaPorte, Texas, was found to cant' a total dioxin concentration of >2,911 parts per trillion (ppt). This dioxin concentration is approximately five times higher than the average concentration reported for North American sediments in USEPA's draft dioxin reassessment. Also, dioxin-indicator compounds were found in the sediment downstream from Dow Chemical's EDC/VCM facility in Oyster Creek, Texas.

Extrapolations from industry reports and academic studies of European EDC/VCM production suggest that the quantity of dioxin discharged into U.S. waterways from EDC/VCM facilities may rival that discharged from all 104 U.S. pulp and paper mills.

USEPA BOWS TO INDUSTRY PRESSURE

USEPA's failure, during the Reagan and Bush administrations, to investigate and curtail the generation and release of dioxin and PCBs during PVC production was due neither to ignorance nor to negligence.

The Agency has known since at least 1979 that very large quantities of PCB-contaminated wastes are produced in the production of EDC and VCM. Rather than using its power under the Toxic Substances Control Act (TSCA) to prohibit such PCB manufacture, USEPA actively solicited EDC/VCM producers to apply for special exemptions.

USEPA knew prior to 1988 that dioxin is produced during EDC/VCM production. However, after initially proposing in 1988 to regulate dioxin in one EDC/VCM waste, the Agency came under pressure from the Vinyl Institute and major producers. In 1990, USEPA deleted those portions of the regulations addressing dioxin, citing the potential costs to the industry. None of this information was included in USEPA's draft dioxin reassessment but was not.

Since 1989, the published scientific and governmental literature has contained numerous reports of dioxin in the wastes, discharges and surroundings of EDC/VCM facilities in Europe. Recent Swedish studies have detected dioxin and PCBs in the PVC product itself.

The inventory of dioxin sources in USEPA's draft dioxin reassessment serves as the basis for the Agency's dioxin elimination policies. However, the Agency has not included EDC/VCM facilities among its major dioxin sources. USEPA does not provide its own estimates of dioxin releases from U.S. EDC/VCM facilities but asserts that "monitoring efforts to collect these data are highly recommended." This situation suggests that USEPA does not yet acknowledge the inseparability of PVC, dioxin and PCBs, and the enormity of PVC's contribution to the national dioxin burden both during its manufacture as well as in the burning of associated wastes and discarded PVC products.

PVC: THE COMMON CONTRIBUTING FACTOR AMONG LARGEST DIOXIN SOURCES

Without chlorine, dioxin cannot be created. PVC is the primary donor of chlorine for most of the dominant dioxin sources identified by USEPA - various kinds of incinerators and other thermal processes. Considering what is already known about the dioxin output from various portions of the PVC lifecycle, this plastic must be regarded as the largest contributor to the nation's dioxin burden.

PVC accounts for the majority of dioxins emitted by incinerators for medical and municipal wastes, the two largest dioxin sources identified by EPA. Disposable PVC products are responsible for the vast majority of the chlorine fed to these facilities and are thus the primary source of dioxin emissions.

Dioxin output from the burning of large quantities of chlorine-rich EDC/VCM process wastes in on-site and commercial hazardous waste incinerators is almost entirely unquantified. It is, however, considerably greater than the estimate given in USEPA's dioxin reassessment. Existing dioxin emission data were obtained almost exclusively during trial bums using the USEPA-approved stack testing method, which achieved only 26 percent recovery of dioxin spiked into the sample collection system during its evaluation with a full-size incinerator. Moreover, these data do not reflect the higher dioxin emissions associated with incinerator upsets and by-passing of pollution control systems, both of which have been reported to occur with considerable frequency. In addition, Greenpeace analyses of EDC/VCM wastes found high concentrations of metals, including copper, which catalyzes the formation of dioxin during burning in incinerators and other combustion systems.

PVC is the primary chlorine donor in recycling facilities for copper, steel, lead and other metals. These secondary smelting facilities - which receive PVC as residues on automobiles, cables, electronic equipment, and batteries - have been identified by USEPA as major dioxin sources.

PVC residues on scrap wood are the primary cause of dioxin emissions from domestic and industrial wood burning, according to European studies. EPA has identified these sectors as major dioxin sources.

PVC burning in accidental home and building fires appears to be one of the largest single sources of dioxin. PVC is now ubiquitous in modem buildings, and high concentrations of dioxin have been found in the residues from accidental fires in which uncontrolled PVC-burning occurred in homes, schools, office buildings, and industrial facilities. The total contribution of PVC fires to the national dioxin burden has not been estimated, but given the hundreds of thousands of fires that occur each year, the dioxin loadings are certain to be significant.

TIME FOR ACTION ON PVC AND DIOXIN

According to USEPA's dioxin reassessment, dioxin is extraordinarily toxic, persistent, and bioaccumulative. Dioxin is now distributed globally in the environment, food chain, and human tissues, and EPA has found that current "background" levels of dioxin are already at or near the range at which health effects are known to occur. These findings provide added weight to recommendations such as the International Joint Commission call for a phaseout of chlorine use in products such as PVC in order to eliminate on a rapid timetable the generation and release of dioxin into the environment.

PVC is the largest single contributor to the national dioxin burden. For the protection of public health and the environment, a PVC phase-out must be a priority in the national dioxin prevention program. Important first steps include:

Prohibition of the oxychlorination process for the production of EDC and other chemicals;

Prohibition of new facilities or capacity expansions for the production of EDC/VCM and PVC;

Modification of existing permits for EDC/VCM plants to bring generation and releases of dioxin to zero;

Classification of relevant wastes from EDC/VCM production as dioxin-listed and PCB-containing wastes, subject to all appropriate regulatory requirements that have been revised to reflect the inadequacies and limitations of incineration as a treatment technology;

Prohibition of incineration of chlorine-rich wastes and/or wastes from EDC/VCM production that contain dioxin and PCBs;

Rapid phase-out of PVC uses associated with the largest dioxin releases, including short-life PVC uses (packaging and disposable products sent to incinerators or otherwise burned), uses in areas susceptible to fire (construction, appliances and automobiles), and products recycled in smelters (cables and cars); and

A longer-term phase-out of other uses of PVC, with priorities established according to environmental impact and the availability of alternatives.

Because the ultimate phase-out of PVC will have economic impacts in the communities where manufacturing facilities are located, transition planning processes must be an integral component of any phase-out plan. This process must be guided by participation from labor, community and other stakeholders and should seek to minimize the economic effects of the transition and insure that costs and benefits are equitably

distributed. For instance, the Oil, Chemical, and Atomic Workers Union has proposed a tax on chlorine and related chemicals; the revenue would be used to encourage reinvestment in affected communities and to provide income protection, continued health care, and meaningful opportunities for higher education and reemployment for workers and their families.