Document nkGN2Ov00gBObbbXpQ72w4R8m

Law Offices ELLER AND HECKMAN 1001 G Street. N.W. Suite 500 West Washington. D.C. 20001 Telephone (202) 434-4100 Telex 4-e 93551 "KELMAN" Telecopier (202) 434-464S Boulevard Louis Schmidt 67 B-1040 Bruisel* Telephone 32(2) 732 52 60 TsLEcopiet 32(2) 732 53 22 JOSERM t KELLER JEROME H HECKMAN W'LUAM H BOROMESANI. JR. MALCOLM O MaCARTHUN wayncv slack Terrence O JONES MARTIN w. BERCOV'Ct s.jomn cloned WILLIAM L KOVACS CANOLC C. HARRIS KATMONO A. KOWALSKI* MICHAEL F. MONNONE MARK POX EVENS JOHN B. RICHARDS JEAN SAVIONY*0 JOMN S. OUBCCK RCTCR L. DC la CRUZ Christine m. oill MELVIN S. DROZEn SHIRLEY S. PUJIMOTO LAWRENCE R HALRRIN October 20, 1993 RALRH A. SIMMONS RCTCR A. SUSSCR C. OOUOLAS JARRCTT Sheila a. millar RATRlCK j huro GEORGE O MiSKO OAREN c. OODOE DAVID I. RCAOCR S. CRAIG TAUTPCST MARK A SICVCRS MICHAEL A. SENNET THOMAS R MOUNTCER DAVID G. SARVADl* CATHCRINC R. NIELSEN KRIS ANNC MONTCITH ELLIOT SCLILOS MARK L. ITZKOrr JCAN.RHILIRRC MONTPONT'O ARCHIC L. HARRIS. JR BRIAN T ASHBY T. RMILLIRS SCCK NOT ADMITTED IN D.C ORCSJDCNT BRUSSELS ARTHUR S. GARRETT m RICK D. RHODES LESLIE C. SILVERMAN FRANK C. TORRES III BRYANT ROBINSON III JOSEPH M SANORl, JR ELIZABETH F. NEWBILL'O TAMARA . DAVIS ROBERT M. O. LOCKWOOO KENNETH O. WOODROW* CAROL MOORS TOTH JOAN C. SYLVAIN* MARTHA RCLLCORINI* BARRY J OHLSON* DONALD T. WURTH DAVID B BERRY STEPHEN V. KENNEY S. DEBORAH ROSEN* OAVID R. JOY* SCIENTIFIC STAft DANIEL S. DlXLER. Rh. O. CHARLES V. BRCDCR. Rh. D ROBERT A. MATHEWS. Rh. O. JOHN R. MOODCRMAN. Rh. O. MOLLY HUTMIRC FOLEY JUSTIN C. ROWELL. Rh. D. JANETTE HOUK. Rh. D. LESTER BORODINSKY. Rh. D TELECOMMUNICATIONS ENGINEER CHARLES F. TURNER WRITER'S DIRECT DIAL NUMBER (202) 434-4141 ru. Frank Bcrrelli Georgia Gulf Corporation 42C Read's Way New Castle Corp. Commons New Castle, Delaware 19720 Re: Draft Letter to EPA on Greenpeace Dear Frank: As you requested, enclosed is a draft letter from the Vinyl Institute to Carol Browner, Administrator of the U.S. Environmen tal Protection Agency (EPA). The letter responds to an April 1992 letter to EPA from Greenpeace alleging that PVC facilities are "dioxin factories" posing serious and new environmental hazards. I understand that this draft letter will be used for discus sion purposes as part of the Vinyl Institute's deliberations on whether it wishes to send the letter to Ms. Browner. I look forward to seeing you at the VI Issues Management Committee meeting tomorrow. ily yours, / /-f- Peter L. de la Cruz Enclosure cc: Fred E. Krause Ronald McCreedy Beverly V. Gholson, Esq. Larry Thomas Lewis R. Freeman, Jr. Maureen Healey Meredith Scheck SP1-07706 ru_ Mct-feeay - i ne uow i,,nemicai company THEM 2 I'EThLS TSiE' TO 3 ot 10 P. 02 regulations govern the release of vinyl chloride to the air, water and soils, impose stringent controls on workplace exposure to vinyl chloride, and require the installation of advanced pollution control equipment at vinyl chloride and PVC manufacturing facilities. The Greenpeace report is dangerously misleading because it's conclusions are based on several incorrect fundamental assumptions. Greenpeace asserts that the PVC industry is a "major new dioxin source" and implies that the dioxin produced by the PVC industry will add significantly to dioxin in the environment. Greenpeace wrongly assumes that because large amounts of chlorine are used in PVC production, large amounts of dioxin necessarily are produced as wastes. Greenpeace's conclusions are based on four fundamental, but flawed, assumptions. (1) Greenpeace assumes that analytical data from a single vinvl chloride monomer (VCMV facility_are representative of data from all VCM/PVC facilities. Much of the Greenpeace report is based on analytical data from a single vinyl chloride manufacturing facility: the Norsk Hydro plant in Rafnes, Norway. Greenpeace extrapolates data from a 1989 survey of dioxin emissions from this plant and applies the data to the entire universe of PVC manufacturing facilities. The 1989 data from the Norsk Hydro plant is not characteristic of industry-wide emissions on a global scale because production processes and emissions control technology differ materially at individual facilities. Greenpeace ignores the emissions control technology and regulatory emissions limitations on all vinyl chloride and PVC facilities in the United states. (2) Greenpeace assumes that generation of dioxin during VCM manufacturing,is svnonomous with the release of dioxin into the environment. Greenpeace mistakenly correlates the incindental production of dioxin with the release of dioxin and alarmingly asserts that "manufacture of PVC may be the world's largest single source of dioxin." This statement is without justification or support. PVC manufacture is neither a large source of dioxin production, nor a large source of dioxin emissions into the environment. Very little dioxin goes into wastes, and an even smaller amount is released into the environment. For example, data recorded in 1993 at the Norsk Hydro facility in Rafnes, Norway indicate that while 6.6 grams of dioxins were produced during the manufacture of 425,000 metric tons of VCM, only 0.025 grams were emitted to the atmosphere and 0.006 grams were emitted to the water. Greenpeace ignores countless other sources of dioxin emissions into the environment, and overlooks several independent studies that conclude that non point source emissions from automobiles and other internal combustion engines are a major source of dioxin emissions into the environment SPI-07708 WORKING DRAFT 2 October 20, 1993 -1 'rr.. i-l:lb Fkl-M '.HE! I ... t'ETHLS T j TO ol 10 P.133 (3) Greenpeace assumes that vlnvl chloride facilities in avllv Industrial areas necessarily were the source of dioxin j.ound in. environmental media in those areas. Greenpeace utilizes analytical data from several "case studies" showing the presence of dioxins in environmental media in regions near vinyl chloride facilities to conclude that the vinyl chloride facilities were the source of the dioxins. This conclusion is implausible because it ignores the countless other sources of dioxins in the industrial areas where the samples were taken. Greenpeace's inaccurate reporting of facts (including misstating the location of a vinyl chloride facility) and mischaracterization of the studies' results further undermines Greenpeace's conclusions. (4) Greenpeace assumes that clinical, studies showing an association between chemlcal_worker exposure and increased mortality prove that dioxin caused the increased mortality. Greenpeace mischaracterizes the results of clinical studies of the health risks of dioxins. Greenpeace prematurely concludes that dioxin is a human carcinogen based on evidence from clinical studies that demonstrate an association between chemical worker exposure and increased mortality. Greenpeace's conclusion is fundamentally flawed because none of the cited studies concluded that dioxin was the cause of the increased mortality. Indeed, recent evidence suggests that it dioxin likely is not a human carcinogen at the low doses found in environmental exposures. ***** Responsive to the Clean Air Act Amendments of 1990, EPA is reviewing the vinyl chloride standard and ensuring that maximum achievable control technology (MACT) is required. Current Agency rulemakings, together with continued industry commitment to environmentally responsible manufacturing, will provide ample protection against potential health threats. The fundamental flaws in the Greenpeace report cast doubt on its credibility and obviate the need for additional Agency action. The Vinyl institute and the industry it represents remain committed to working with the Agency to provide essential PVC consumer products in an efficient, environmentally safe manner. We welcome your questions and look forward to continued cooperation in the future. Sincerely yours. Attachments WORKING DRAFT SPI-07709 3 October 20, 1993