Given the large discrepancy between simulations (US experience) and actual measurements (Australia, Spain, Canada) and the fact that the EC does not consider forest fires to be major dioxin sources, this text cannot be scientifically justified, despite the insistence of the chlorine industry. The draft should not contain a blanket statement that forest fires could be a major source of PeCB. Forest fires are simply not a major source of dioxins or PeCB in the world. Note the following evidence:1. A TNO report on dioxin emissions in several EU candidate countries does not list forest fires as major sources.23Countries examined included Bulgaria, Cyprus, Czech Republic, Estonia, Hungary, Latvia, Lithuania, Malta, Poland, Romania, Slovak Republic, Slovenia, and Turkey. The largest contributions of dioxin emissions to air were from incineration of wastes, cement kilns, and iron ore sintering. Forest fire emissions of dioxins were estimated at 5 ug I-TEQ/ton using the UNEP dioxin toolkit. In contrast, dioxin emissions from landfill fires were estimated at 1000 ug I-TEQ/ton.2. The European Commission does not regard forest fires as major dioxin sourcesMartinez et al. (2000) analyzed vegetation and soils in forest fire areas in Spain and concluded that“natural fires seem not to be an important source of dioxin-like compounds.” 24See these references:Wenborn, M., King, K., Buckley-Golder, D., Gascon, J., 1999. Releases of Dioxins and Furans to Land and Water in Europe. Final Report. Report produced for Landesumwaltamt Nordrhein-Westfalen, Germany on behalf of European Commission DG Environment. September 1999 Quass, U., Fermann, M., Broker, G., 2000. The European Dioxin Emission Inventory, Stage II. Vol. 3: Assessment of dioxin emissions until 2005. Nordrhein-Westfalen, Germany: Landesumweltamt NRW. December 2000 Quass, U., Fermann, M., 1997. Identification of Relevant Industrial Sources of Dioxins and Furans in Europe (The European Dioxin Inventory). Final Report No. 43, Essen, Germany: Landesumweltamt Nordrhein-Westfalen, Germany. 3. Studies from Canada indicate that forest fires are not major dioxin sourcesVan Oostdam (1995) found no detectable dioxins in three soil samples and four ash samples taken immediately after a forest fire in British Columbia, Canada. 253
Ikonomou et al. (1999) reported that “data do not show levels high enough and/or distinctpatterns that would suggest that the sediments in the streams examined have been impacted by PCDDs/Fs produced from the forest fires.” 26Gabos et al. (2001) reported only very low concentrations of dioxins in sediments following extensive forest fires in Canada.274. Studies from Australia indicate that forest fires and bush fires are not major dioxin sourcesA recent study of dioxin emissions from crop and bush fires in Australia revised the estimated contribution from these sources downwards by 70%.28An Australian government report notes that the measured dioxin emissions in the field were substantially different from laboratory tests used to estimate inventory values for various open burning sources.29
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