A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 FEBRUARY 1995

“A compelling body of evidence suggests      “USEPA has been aware of the generation of   
that throughout its entire lifecycle, PVC    dioxin and PCBs during PVC manufacture for   
is responsible for a greater share of the    more than seven years in the case of dioxin  
nation’s annual dioxin burden than any       and more than fifteen years in the case of   
other industrial product.”                   PCBs....In 1990, at the request of the       
                                             Vinyl Institute and various PVC producers,”  
                                             the USEPA deleted dioxin from PVC-waste      
                                             from proposed RCRA regulation.               

* “PVC accounts for the majority of dioxins emitted by incinerators for medical and municipal wastes, the two largest dioxin sources identified by the EPA.

Excerpt from Greenpeace Press Release of February 21: “A surreptitious Greenpeace investigation into factories which produce the feedstocks for the production of polyvinyl chloride (PVC or vinyl) plastics was released today, revealing alarmingly high levels of dioxins and related compounds. Greenpeace covertly collected samples from nine facilities in the Gulf of Mexico region, where most of the nation’s PVC feedstock production is located. Laboratory analysis on the samples revealed that levels of dioxin in wastes created in the production of chemical feedstocks for PVC plastic are some of the most contaminated wastes produced, comparable to the levels found in wastes from the production of Agent Orange...”

“To produce PVC, ethylene dichloride (EDC) is converted into vinyl chloride monomer (VCM) which is then polymerized to form polyvinyl chloride, also known as PVC or vinyl....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. After making several requests to USEPA to investigate the generation and release of dioxin during PVC feedstock manufacture, Greenpeace launched its own independent study in the summer of 1994. Greenpeace obtained samples from areas for production, storage, treatment and disposal of wastes at Louisiana and Texas facilities 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 ends from the distillation of EDC contained dioxin (PCDD/PCDF total) at a 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 of dioxin (PCDD/PCDF total); and,

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

U.S. EDC and VCM Production

Companies/ Annual Capacity/ Companies/ Annual Capacity/

Locations Millions of Pounds Locations Millions of Pounds

Louisiana Texas

Borden Chemicals and Plastics, Geismar 1,695 Dow Chemicals, Freeport 2,820 (EDC only)

Dow Chemicals, Plaquemine 4,250 Dow Chemicals, Oyster Creek 900 (VCM only)

Formosa Plastics Corp., Baton Rouge 2,475 Formosa Plastics, Point Comfort 2,005

Georgia Gulf Corp., Plaquemine 3,355 Geon Vinyl (BF Goodrich), LaPorte 3,105

Occidental Chemical Corp., Convent 800 (EDC only) Occidental Chemical, Deer Park 2,687

PPG Industries, Lake Charles 3,325 Oxymar, Ingleside 3,710

Vulcan Chemicals, Geismar 300 (EDC only) Sub Total 15,227

Vista Chemical, Lake Charles 2,150

Sub total 18,350

Westlake Monomers, Calvert City, KY 2,300 Grand Total 35,877

“In comparison, wastes from the manufacture of Agent Orange, which are regulated by USEPA as ‘F023’ 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 concentration found in the PVC-related waste sampled by Greenpeace exceed those of Agent Orange waste F023 and, in one case, fall in the mid-range of Agent Orange waste F020...

* Both dioxin and dioxin-like chemicals, including polychlorinated biphenyls (PCBs), are by-products of EDC/VCM production processes. Both dioxin and PCBs are found in the PVC itself...

* In 1994, U.S. PVC manufacturers used 9.37 billion pounds of chlorine to produce 10.88 billion pounds of PVC...According to one industry spokesman, roughly three quarters of all PVC manufactured goes into the building and construction market for uses such as piping, siding, window frames, wallpaper, cabling, flooring, and other uses. As a result, any fire in a modern building is likely to be a source for dioxin....well-over 100 communities in European countries now have PVC bans or phase-out policies in place for PVC in public buildings due to concern over toxic releases resulting from accidental fires involving PVC, as well as persistent toxic pollution resulting [from] its production, use, and ultimate disposal.” - These communities are listed in Appendix 16 of the paper.

“Various studies have identified a relationship between PVC and dioxin formation from municipal and medical waste incinerators:

* “Ozvacic et al. have reported a direct relationship between the quantity of PVC burned and dioxin emissions. [1990. Biomedical Waste Incinerator Testing Program, Chemosphere 20: 1801-1808.]

* “The Danish EPA found that doubling the PVC content of an incinerator’s wastefeed increases dioxin emissions by 34 percent. [1993. Danish EPA. PVC and Alternative Materials. Copenhagen.]

* “A 1993 study for the Dutch Environment Ministry reported that reducing the PVC feed results n a corresponding reduction in dioxin emissions. [Borekamps-Kanters and Louw 1993. Final report of the RUL-VROM project: Green Waste Fraction, PVC, Waste Incineration and ‘Dioxins.” Centre for Chemistry and the Environment. Department of Chemistry, University of Leiden, report number CCESRS 93-09.]

* “In a 1993 study (a) by the U.S. Department of Energy, the addition of PVC at 10 percent by weight to a waste mixture, which increased waste chlorine content from 1.5 percent to 6 percent by weight, had the following results:

- Increases in the relative proportion of submicron particulates emitted (at 1832 F, 26 weight percent with no PVC versus 60 weight percent with PVC; at 1600 F, 26 weight percent with no PVC versus 60 weight percent with PVC);

- Increased emissions of volatile organic compounds (VOCs); and

- Increased emissions of dioxin -- PCDD/F emissions of 35,900 nanograms per kilogram (ng/kg) of waste feed including PVC at 10 percent by weight versus 3760 ng/kg with no PVC (or, expressed as TEQ, 430 ng/kg with PVC versus 46.5 ng/kg with no PVC.)

(a): Burns, D.B. Final Report Consolidated Incineration Facility Metals Partitioning Test (U). Aiken, S.C.: Savannah River Technology Center. WSRC-TR-93-623. August 31, 1993.

Editors: Ellen & Paul Connett, 82 Judson Street, Canton, New York 13617. Tel: 315-379-9200. Fax: 315-379-0448.