Public Comment

In the obfuscation facts about Pacific Steel Casting’s (PSC) toxic air emissions, the City of Berkeley has a fine partner with Bay Area Air Quality Management District (BAAQMD). While Berkeley continues its history of favoring commercial interests over our health, PSC’s flagrant emission violations have become the norm. 

The public meeting on Feb. 15 at the West Berkeley Senior Center was graced by the presence of BAAQMD’s CEO, Jack P. Broadbent, as well as its director of engineering, Brian Bateman. At that meeting BAAQMD was asked if dioxin—actually a large group of similar chemicals—is listed as one of PSC’s toxic air pollutants billowing out of its foundry and associated incinerator that is deceptively renamed a “sand recycler.”  

Bateman explained that dioxin will not be monitored because they found no chlorine source at PSC, which is needed in order to produce dioxins. However, BAAQMD was not sure if the PSC’s “Non-Waste Hazardous Materials Inventory Spreadsheet” (NHMIS) had been studied yet. 

In any case, without even looking at the NHMIS, multiple sources of chlorine are easily found in and around PSC. All we need now is someone charged with the task of regulation to admit that they see them.  

Let’s remember that the $648,950 loan to help purchase the incinerator was facilitated by California Integrated Waste Management Board (CIWMB) as a means of reducing waste. Any residence caught burning such stuff in a backyard barrel would be fined, but it should be assumed that they burn anything and everything in their incinerator with the state’s permission. And don’t be duped into thinking that incinerators actually exist that can burn chlorine-containing objects without creating dioxin.  

Almost any scientist who is intimate with incinerators knows that dioxin is inevitable unless all sources of chlorine are eliminated. No amount of public relations hype will convince this writer that PSC’s incinerator is operated as a scientific lab in a way that eliminates chlorine sources. 

First, many industrial supplies come wrapped in plastic, paper or cardboard that are bundled atop wooden pallets and in turn wrapped extensively with polyvinylchloride (PVC) shrink wrap, which is composed of large amounts of chlorine. Much of this stuff—paper, wood, some plastic—become sources for dioxin when burned in an incinerator.  

Then, any city water used to mix and dilute PSC’s chemicals and production inputs is loaded with either chloramine or chlorine, depending on which city the water is from. Here in Berkeley, EBMUD uses chloramine and it shows up as a residual chemical at the Orinda Water Treatment Plant. 

Furthermore, being located almost directly on the San Francisco Bay, PSC is bathed on a 24/7 basis with its ocean mist and vapor. Since PSC insists that they will not close the big doors, we can assume that the interior spaces are also filled with that ocean breeze. Saltwater (brine) is what chlorine is made from. And top soil—think dust—contains goodly amounts of sodium chloride. In other words, there are limitless supplies of chlorine at PSC. And all of these sources are well-known to the EPA.  

EPA lists foundries and incinerators as sources of dioxin in many of its studies and documents. Just prior to joining BAAQMD, Broadbent spent more than two and a half years as the director of the Air Division at EPA Region IX. In that position, he was responsible for overseeing the implementation of the Clean Air Act. He and his chief engineer should know better than to state for the record that they can’t find a source of chlorine. Of course, if they don’t look, they won’t see it.  

And while dioxin is far from our only worry, it is one of the most potent poisons known to EPA. Amazingly, dioxin (2,3,7,8-TCDD) is more hormonally toxic at extremely low doses than at higher ones. While detectable in one’s blood, it is not traceable back to PSC production and incinerator stacks.  

The health effects from exposures that are probable from PSC would not be immediately perceivable, but would emerge over more than one generation and could include a very wide range of physical and psychological health problems. One quick example is that dioxin contributes to spontaneous abortions during the first four to eight weeks of pregnancy. During those first weeks, a woman might confuse a spontaneous abortion with a missed period, never knowing that she was pregnant at all. Because such incidences are not realized by women or their doctors, no record is kept. 

Perhaps these regulators honestly can’t find dioxin sources because they need everything presented on neat little lists. But BAAQMD’s avoidance of monitoring dioxin is just one more important example of the deception that passes for regulatory enforcement. Adding insult to injury, we taxpayers are expected to pay for this regulatory work as well as be thankful for it.  

Those who are most threatened by these unnoticeable dioxin emissions are young children, those yet-to-be-born and mothers-to-be. This unmonitored pollutant is most dangerous when bodies are still being formed within mothers. Even before pregnancy, dioxin can affect future children because it builds up in the fatty tissues of mothers. Dioxin can also be passed on to the fetus by fathers because it damages and coats their sperm. Ask Vietnam veterans about this. 

If PSC were properly registered as the single facility that it truly is rather than multiple facilities, then the sum of its emissions would classify it as a major polluter and force it to operate under Title V of the Clean Air Act, which contains much stricter requirements than it presently faces. Clearly, all of PSC is in this one large multiple-block site on Gilman Street and should be registered as a single facility. 

Instead of blowing more smoke at us with “royal” appearances of high-level people from BAAQMD, as well as with idle promises of full disclosure, what is sorely needed at this time is enforcement of PSC’s emissions as the single facility that it most obviously is, by an agency such as EPA that has adequate financial backing and that hopefully possesses the will to do the job properly.  

Paul Goettlich is a Berkeley resident. He writes and speaks on the health and socio-economic effects of technologies. Find more of his work at Mindfully.org. 

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