Neil Carman <neil_carman@greenbuilder.com> 
05/21/2008 08:30 AM	To
	<rcra-docket@epa.gov>rcra-docket@epa.gov
	cc
	Hilton Kelley <hiltonkelleycida@yahoo.com>, Jim Pew <jpew@earthjustice.org>
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	Subject
	PCB air releases by Plant site reported in TRI 1998-2006
	
	


Sierra Club
May 21, 2008

Stephen Johnson
Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Resource Conservation and Recovery Act (RCRA) Docket Center
Via electronic submission at <rcra-docket@epa.gov
Docket ID No.: EPA-HQ-RCRA-2008-0123
Re: US Polychlorinated Biphenyl Air releases by Plant Site from the Toxic 
Release Inventory 1998-2006

Dear Administrator Johnson:

The Sierra Club is submitting a series of additional public comments on 
the EPA's Proposed TSCA Import Exemption
rule for Veolia to import up to 40 million pounds of PCBs for incineration 
including information that the 2006 PCB releases nationwide were the 2nd 
highest since 1998 when PCBs were first reported in the EPA's Toxic 
Release Inventory program. The attached excel files from the Toxic Release 
Inventory (TRI) data for the PCB reporting years 1998-2006 shows all US 
plant sites with PCB airborne releases each year. These files support the 
May 20, 2008 Sierra Club letter confirming that Veolia led the nation in 
PCB airborne releases on a plant-by-plant basis. Veolia has also been 
among the largest PCB airborne discharge facilities each year since 1998 
when PCB environmental releases for incinerators began to be reported. In 
fact the hazardous nature of Veolia's incinerator operations is that the 
1,933 pounds of PCBs that Veolia reported by its Port Arthur, Texas TSCA 
permitted hazardous waste incinerator for the year 2006 ranks among the 
largest airborne releases of PCBs since 1998. Without Stack continuous PCB 
emissions monitoring systems during PCB incineration operations and a 
continuous PCB fugitive monitoring program in place as well, Veolia may be 
under reporting its PCB airborne releases.

Port Arthur does not have a community bio-monitoring program to test the 
community members for the presence of harmful environmental pollutants 
such as PCBs, dioxins and dibenzofurans as well as related dioxin-like 
chemicals being emitted from the Veolia facility. The EPA needs to address 
the lack of a Port Arthur community bio-monitoring program in light of the 
large volumes of polychlorinated biphenyls, chlorinated dibenzo-p-dioxins, 
and chlorinated dibenzofurans emitted by Veolia.

A disturbing finding is that Veolia's Port Arthur PCB incinerator ranked 
#1 in the US for PCB releases reported in the 2006 TRI and Veolia was 
responsible for a majority of the PCBs in 2006 with 1,933 pounds into the 
air of Port Arthur, Texas. Veolia released more than 64% of the airborne 
PCBs in the US in 2006, which is a disproportionate percentage of all US 
PCB airborne releases according to TRI data that are being dumped into the 
air supply, water supply, food supply and ecological systems of one 
community.

All data below obtained at EPA's Toxic Release Inventory website:  
http://www.epa.gov/triexplorer

Veolia released 1,933 pounds of PCBs or over 64% of US PCBs in 2006.
2006 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 2137.139958 + 
860.61978 = 2,997.75974 pounds

Veolia released 75.08 pounds of PCBs or about 36% of US PCBs in 2005.
2005 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 183.3787326 + 
25.4550945 = 208.8338271 pounds

Veolia released 0.16 pounds of PCBs or less than 1% of US PCBs in 2004.
2004 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 325.17959 + 
16.9050114 = 342.0846014 pounds

Veolia released 0.06 pounds of PCBs or less than 1% of US PCBs in 2003.
2003 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 396.5399 + 
39.007933 = 435.547833 pounds

Veolia released 1.0 pounds of PCBs or less than 1% of US PCBs in 2002.
2002 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 5037.319956 + 
163.5729555 = 5,200.8929115 pounds

Veolia released 0 pounds of PCBs in 2001.
2001 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 406.1300515 + 
954.32626 = 1,360.456312 pounds

Veolia released 0 pounds of PCBs in 2000
2000 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 330.11705 + 
823.7855 = 1,153.90255 pounds

Veolia released 5.0 pounds of PCBs or nearly 1% of US PCBs in 1999.
1999 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 517 + 14 = 
531 pounds

Veolia released 5.0 pounds of PCBs or less than 1% of US PCBs in 1998.
1998 Total U.S. TRI Polychlorinated Biphenyl Airborne releases for all 
industries of onsite Fugitive Air + onsite Point Source Air: 431 + 15 = 
446 pounds


Summary of all US PCB Releases reported in the Toxic Release Inventory 
1998-2006:
Veolia released a total of 2,019.30 pounds of PCBs or about 16% of US PCBs 
from 1998-2006.
Veolia releases 1,933 pounds of airborne PCBs in 2006 or 95.7% of its air 
PCB releases since 1998.
Total US PCB airborne releases reported from 1998-2006 = 12,676.477775 
pounds.

Veolia ranked #1 in Polychlorinated biphenyls releases in the nation in 
2006.  Polychlorinated biphenyls (PCBs) were released in 2006 into the air 
of Port Arthur, Texas by Veolia's commercial hazardous waste incinerator 
during its incineration activities.  Veolia reported to the U.S EPA as 
part of the Toxic Release Inventory reporting system that the Port Arthur 
facility discharged a total of 1,933 pounds of PCBs into the air.  The 
2006 PCB emissions total was higher than the previous 8 years put 
together.  2006 PCB air emissions from Veolia's Port Arthur incinerator 
were 95.7% of all PCB releases since 1998.  In addition, the 2006 PCB air 
releases represented 28% of Veolia's total toxic air pollution.  

PCBs reported to EPA in the TRI as released into the air by Veolia's Port 
Arthur incinerator since 1998:2006 = 1,933 pounds
2005 = 75.08 pounds
2004 =   0.16 pounds
2003 =   0.06 pounds
2002 =   1.00 pound
2001 =      0 pounds
2000 =      0 pounds
1999 =  5.00 pounds
1998 =    5.0 pounds
Total = 2,019.30 pounds

The TRI data from PCB releases suggests in 2006 that the community of Port 
Arthur, Texas is being used as a dumping ground for incineration of PCB 
wastes such as the request to import 40 million pounds of PCBs by Veolia 
even though a portion of the PCBs will be emitted as unburned air 
pollution and new dioxins and dibenzofurans formed in the cooling stack 
gases. Yet Veolia does not accurately measure and monitor all stack 
emissions of PCBs, dioxins and dibenzofurans as well as related 
dioxin-like chemicals from its facility.
 
Sincerely,

Neil J. Carman, Ph.D.
Clean air program director
Lone Star Chapter of Sierra Club
1202 San Antonio Street
Austin, Texas 78701
tel: 512-472-1767
fax: 512-477-8526
Neil_Carman@greenbuilder.com