Dioxin emissions
from incineration (an EPA regulated industry) have been reduced
from 10,397 grams/year TEQ (toxic equivalents) in 1987 to 1,589
grams in 1995 (Source: EPA). New EPA regulations are projected
to reduce dioxin emissions from incineration to165 grams by 2003.
EPA estimates
that medical waste incinerators (MWIs) emit a total of 150 grams/year
TEQ of dioxin. EPA's new MWI regulations are projected to reduce
these emissions by 95 percent, down to 5-7 grams/year TEQ. Along
this line, attempts to ban the production and use of polyvinyl
chloride (PVC, or vinyl) medical solution bags, blood bags and
tubing are dangerous and alarmist. These products have helped
save countless millions of lives for decades.
The proposed
alternatives to incineration would require massive capital expenditures,
lifestyle changes on a huge scale, and, in the case of industrial
energy, cause industries to burn other fossil fuels (mostly imported)
to make up for the energy deficit. The suggestion that there is
no role for waste incineration is meaningless because the proposed
alternatives are not economically viable in the foreseeable future.
The suggestion that natural gas is available in sufficient quantities
at competitive prices to replace waste-to-energy and other fuel
uses in U.S. industry is absolutely absurd.
Clearly, for
municipalities, industry and medical facilities, the best route
is to depend on well-run incinerators using new technology and
the modification of older incinerators with new technology. Numerous
studies have concluded that this is the way to go, so EPA supports
the technology. A well run incinerator produces virtually no dioxin
regardless of how much chlorine-containing material is burned.
Incinerator ash is required to be disposed of in permitted landfills
and does not represent environmental or human exposure. EPA's
new rules will result in major ongoing reduction of dioxin without
disrupting jobs and industrial/municipal/health care budgets.
2. Pulp
and Paper
The EPA's
new cluster rule, regulating pulp and paper plants, will virtually
eliminate dioxin discharges from U.S. mills by changing them from
elemental chlorine to elemental chlorine free (ECF) technology
using chlorine dioxide. This EPA rule was strongly supported by
the unionized workers of the U.S. pulp and paper industry because
it would achieve the environmental improvement desired with a
relatively smaller impact on U.S. pulp and paper jobs. The alternatives
supported by environmentalists would have cost many thousands
more U.S. jobs with virtually zero environmental gain according
to EPA.
EPA notes
that its new cluster rule will permit all dioxin-related fish
advisories downstream of U.S. mills to be lifted.
Claims that
market demand for totally chlorine free (TCF) paper is increasing
are false. The TCF market is stagnant at 6 percent of world demand.
Meanwhile, demand for ECF paper produced with chlorine dioxide
has now reached 54 percent of world demand and continues to grow.
TCF mills
need more trees to make the same amount of paper. TCF mills can
require up to 10 percent more wood. The trade off is not worth
it from an environmental perspective.
3. Pesticides
There are
many effective pesticides that contain chlorine. Very few of the
thousands of chlorine based products potentially contain trace
amounts of dioxin. In the past, phenoxy herbicides and hexachlorobenzene
have been found to contain dioxins at the parts per million level.
Either by phasing out specific products (e.g., the herbicide 2,4,5-T
and hexachlorobenzene) or by changing the manufacturing processes,
worker, consumer and environmental exposure has been virtually
eliminated in North America and Europe. These manufacturing changes
and bans in developed countries are also causing exposures to
be reduced world-wide.
4. PVC
Recommendations
The entire
ethylene dichloride/vinyl chloride monomer industry that creates
polyvinyl chloride (PVC) emits about 18 grams of dioxin/year TEQ
while producing over 13 billion pounds of PVC annually. This translates
into roughly one-half of one percent of the approximately 3,000
grams of dioxin emitted annually.
PVC production
has skyrocketed during the period when dioxin levels in the environment
and human tissue have dramatically declined. Over 125,000 Americans
work in U.S. PVC fabrication facilities. PVC has many vital, beneficial
and economical uses in building, siding, windows, piping, medical
devices, molded forms and casings, auto parts, etc.
Identifying
actual PVC/chlorine substitutes is not easy in most cases. Some
groups like to talk about alternative materials but finding them
in commercial supply can prove difficult or impossible.
Efforts should
be intensified to find ways to recycle PVC more effectively instead
of calling for its elimination.
5. Coal
Fired Power Plants
Coal contains
chlorine (the 11th most abundant element on earth).
Coal is a critical, domestically-available part of the U.S. energy
supply.
6. General
Employment Information and Political Considerations
The
chlorine industries provide over 300,000 high-wage U.S. manufacturing
jobs and 180,000 service sector jobs. Chlorine chemistry is the
building block of 85 percent of pharmaceuticals, providing 260,000
U.S. jobs. The new chlorine dioxide technology will virtually
eliminate dioxin discharges from U.S. pulp and paper mills, and
help preserve the competitiveness of over 600,000 U.S. pulp and
paper industry jobs. Chlorine chemistry provides the building
block for 60 percent of U.S. chemical production. The U.S. chemical
industry provides one million U.S. jobs paying wages 33 percent
higher than the industrial average.
Chlorine
and chlorine chemicals are used to disinfect 98 percent of drinking
water systems in the U.S. Chlorine chemistry provides disinfectants
that prevent sickness. Chlorine chemistry is essential to modern
agriculture, providing a safe, inexpensive and abundant supply
of food. Chlorine chemistry is essential to the production of
semiconductors, compact disks, other advanced electronic components,
metals, paper, pharmaceuticals, auto parts and other goods affecting
hundreds of thousands of jobs as well.