Document ZB86XDZ7aexNZqOOZwzLbqy7

, DELUDE AMSTERDAM * ANCHORAGE AUCKLANO BRUSSELS BUENOS AIRES CHICAGO COPENHAGEN DUBLIN . GOTfoSNJSM HAMBURG * LSW5J--UK. LUXEMBOURG MADRID MONTREAL NEW YORK CITY * OSLO WLMA PE MALLORCA PARI* ROME SAN FRANCISCO SAN J05I-C0STA RICA SEATTLI STOCKHOLM SYDNEY * TORONTO * VANCOUVER,* VIENNA . r, . . WASHINGTON'ZURICH .- rZi?T?i7i\TT>T?Arn GrwnPMCe 1435 U$tr* NW' WssHlnatofl OC 20009 ?TH (202) 452-1177 T!x 89-2359 Fax'(2S2) 4624507'' > -. . April 23,. 1932 -Ms/Car'ol Browner Administrator (A-iO'0). V, S,. -Environmental Protection'Agenoy 401 M', Street' SW Washington/DC 20460 . / ' .` Dear Mr Browneri * * i" '. '. . . . flew data fr6m several.-studies by ..European governments . indicate .that huge quantities' of dioxin-ana, related'-compounda are produced in the manufacture of feedstocks for-the'plastlo polyvinyl chloride (.PVC)--, . 'Assuming- that the facilities, atudied are representative of other plants'.-- including those-in. the U.S. .manufacture of PVC may be the world's largest single source-of dioxin.' ;(To' our' knowledge, the only dioxin source that would . rival;Pyc production would be' incineration. ) ' These data- are -'Summarised in. the-enclosed -report., '"DIOXIN FACTORIES i- A study of-.* the Creation.and Discharge 'of Dioxins and Othe'r .Orgariochiorines from the Production of PVC,"'-. Dioxin, related.compounds, and other highlytoxieorgano- ohlorinea'.were-fduhd in.very large'quantities, in .air emissions, water discharges, and wastes-from the production of ethylene-'. dichloride and vinyl chloride, the monomers from which, pyc is produced.' .Currently,. the bulk-of-the wastes frim'these' processes are bu.rnid in-incinerators- that are-not- licensed-to burn dioxin- contaminated wastes,' . . '. This information-.has extraordinary, implications for'health'. ., and the environment in the-U.d'. and'for BPA regulatory policy.in particular! As you are.aware, yoUxr agenoyiis currently engaged' ' in 'a re-evaluation-`of the- health' and environmental; threats'* associated..with dioxin pollution'of.the environment. To-date, that effort-:has revealed the-following? *, Dioxin contamination, and human ` exposure are .'.ubiquitous iii . . the.U.-'S./' . * . V / - ' ' ` +< There appears t$*be no, safe doiefor many of dioxin'.s-health' effeatii, " '* Current; exposures for the general U.ar`. population are in.the range at which;reproductive, developmental, immunological, -. and*carcinogenic-health effects are likely.to occur. The ' revelation of -a major new. dioxin sour.c is thus, of profound . import in the development f SPA's.' policy .and information, pn. CTL014675 '* dioxin sources, in general and in the permitting of .specific facilities. For' instance, EPA is currently considering permitting the construction of one of the world'slargest new PVC-feedstock facilities,- owned- by Formosa plastics, in Point Comfort, TX\ .We are thus requesting U.s-.. epa to take the following actions: * Launch an' investigation of the- production of undasired .organochlorine by-products including dioxins --in the manufacture of fFVC- chemical feedstocks. The results of these tests should be published and released, and should Include * -data on quantities of organochlorine by-products formed and released through all potential-discharge pathways. * Include this information in the source identification effort 'in the agency's ongoing dioxin reassessment; * Inform the communities surrounding these '.facilities o.f the likelihood of previously unknown dioxin exposures and tho possibility af swiaui to public Kealtk; * Declare a moratorium on new or expanded EDC/VCM/PVC facilities, until all questions relating to releases of and exposures to organochlorine. by-piroduots are resolved; * Immediately classify wastes from the production of PVC feedstocks as dioxin-containing wastes and require their ' disposal in- facilities licensed to handle them; * Ifthe European' results are confirmed for U.a. facilities, . formulate plans , for the phasa-'out of existing PVC-feedstock % production facilities.:' Because of the extraordinary health implications of this information, we. request an expedited reply. ' .Thank you for your ' attention to this .matter, and do nob hesitate to contact us for further information. For the Earth, Pat Costnef. . Research'Director US Toxics Campaign * CTL014676