The letter requesting for moratorium on tire pyrolysis was submitted to the DENR on February 27, 2012.

1. NOTRE DAME DE VIE INSTITUTE
383 Sentinela Road, Barangay Encanto
Angat, 3012 Bulacan
February 24, 2012
Honorable RAMON J.P. PAJE (CESO I)
Secretary, Department of Environment and Natural Resources
Visayas Ave., Diliman
Quezon City
Dear Secretary PAJE:
This refers to the Philpao Enterprises tire pyrolysis facility in Pulong Yantok, Angat, Bulacan
which has continued to operate without an Environmental Compliance Certificate (ECC)
since January 2011. We have already submitted numerous complaints to your office about
its continuing illegal operation which is causing various illnesses among residents of Encanto
and adjoining Barangays.
We recently obtained results of analysis conducted by the Hong Kong Polytechnic University
Air Laboratory on a grab air sample collected from NDV Encanto in September 2011.The
sampling canister was lent by Dr. Doris Montecastro, a DOST Balik Scientist with extensive
experience in air toxics who is detailed at the Ateneo de Manila University. Analysis in Hong
Kong was made possible through the Clean Air Initiative for Asia (CAI-Asia). Sampling was
done at the second floor veranda of the NDV Center, facing the South, in the direction of
Philpao. Odor of pyrolysis emission was weak at the time of sampling. The sampling location
is about 700 m from the Philpao Facility.
Analysis by GC MS detected several Volatile Organic Compounds (VOC’s) included in the US
EPA Hazardous Air Pollutants (HAPS) listing (Table 1). Benzene (1 ppb) and 1,3–Butadiene
(15 ppb) are among the eight (8) carcinogenic air pollutants responsible for 99% of
estimated cancer risk in the USA. These also have associated non-cancer risks like other
VOC’s detected in the sample:, toluene (5.5 ppb), xylenes (total of 14.7 ppb), styrene (0.69
ppb), ethyl benzene (8.8 ppb) etc. The levels in the sample are in the ppb (parts per billion)
range but could be higher during strong odor episodes. Levels at the facility itself and in its
immediate vicinity are expected to be orders of magnitude higher.
We are still studying the health implications of the data. Initial findings are disturbing. We
would like to cite 1,3-Butadiene present at 15 ppb as an example. It is much higher than
levels measured in LPG Taxis in a research being conducted by Dr. Montecastro. The US EPA
Technology Transfer Network Air Toxics Web Site reports the following symptoms on acute
exposure by inhalation in humans: irritation of the eyes, nasal passages, throat, and lungs.
High exposure levels caused neurological effects: blurred vision, fatigue, headache, and
vertigo. Chronic exposure has resulted in cardiovascular and haematological effects.
Respiratory effects have been observed in mice. Residents of Encanto have experienced one
or more of these symptoms. Other VOC’s can have similar effects.
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2. NOTRE DAME DE VIE INSTITUTE
383 Sentinela Road, Barangay Encanto
Angat, 3012 Bulacan
Table 1. Results of GC MS analysis of a grab air sample from Encanto, Angat
Data File Name: C:msdchem1DATATIREPYROSAMPLE.D
Acquired Date: 17 Feb 2012 12:38
Method Name: C:msdchem1METHODS111209.M
Sample Name: TIRE PYROLYSIS AIR
Comp # Compound Name RT (min) Area Amount Units Q-value
1 Freon-12 0 0 0 ppb 0
2 choromethane 0 0 0 ppb 0
3 Freon-14 0 0 0 ppb 0
4 chloroethene 0 0 0 ppb 0
6 Bromomethane 0 0 0 ppb 0
7 Ethylchloride 0 0 0 ppb 0
8 Freon-11 0 0 0 ppb 0
9 Acrylonitrile 0 0 0 ppb 0
11 Methylene chloride 0 0 0 ppb 0
12 3-Chloropropene 0 0 0 ppb 0
13 Freon-113 0 0 0 ppb 0
16 Chloroform 0 0 0 ppb 0
18 1,1,1-Trichloroethane 0 0 0 ppb 0
20 Carbon Tetrachloride 0 0 0 ppb 0
21 1,2-Dichloropropane 0 0 0 ppb 0
22 Trichloroethylene 0 0 0 ppb 0
23 cis-1,3-Dichloropropene 0 0 0 ppb 0
24 trans-1,3-Dichloropropene 0 0 0 ppb 0
25 1,1,2-Trichloroethane 0 0 0 ppb 0
28 Tetrachloroethylene 0 0 0 ppb 0
29 Chlorobenzene 0 0 0 ppb 0
37 1,3-Dichlorobenzene 0 0 0 ppb 0
15 cis-1,2-Dichoroethene 17.164 13224 0.036168 ppb 7
41 Hexachloro 1,3-Butadiene39.754 66648 0.046863 ppb 32
39 1,4-Dichlorobenzene 32.627 60999 0.081093 ppb 1
10 1,1-Dichloroethene 12.887 30150 0.096531 ppb 19
14 1,1-Dichloroethane 15.721 31138 0.110266 ppb 64
40 1,2,4-Trichlorobenzene 38.076 98135 0.221237 ppb 1
17 1,2-Dichloroethane 18.578 59815 0.231355 ppb 100
36 4-Ethyltoluene 30.875 277018 0.265477 ppb 54
32 Styrene 27.269 330208 0.688575 ppb 1
38 1,2-Dichlorobenzene 31.647 626751 0.769186 ppb 9
19 Benzene 19.631 413864 1.06958 ppb 1
33 o-Xylene 27.494 3938459 2.50917 ppb 99
26 Toluene RFC 23.297 3553782 5.45956 ppb 1
30 Ethylbenzene 26.385 7314507 8.80713 ppb 100
34 1,3,5-Trimethylbenzene 29.715 9557507 8.88449 ppb 1
35 1,2,4-Trimethylbenzene 29.715 9882251 9.43147 ppb 31
31 p-Xylene 26.619 9389924 12.2104 ppb 60
5 1,3-Butadiene 7.634 1678316 14.6185 ppb 100
27 1.2-Dibromoethane 24.454 10760990 46.3273 ppb 100
The average level of 1,3-Butadiene in US cities is about 0.4 ppb. The OSHA Short Term
Exposure Limit (STEL) is 5ppm while the chronic Permissible Exposure Limit (PEL) is 1ppm.
The Cancer Risk Level for a 1 in a million risk is 3 x 10-5 mg/cu m or 1.4 x 10-2 ppb. The
concentration of 1,3-Butadiene in the air sample is 1,071 times the cited Cancer Risk level.
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3. NOTRE DAME DE VIE INSTITUTE
383 Sentinela Road, Barangay Encanto
Angat, 3012 Bulacan
The data indicate that even at 700 m away from the facility, the levels of VOC’s
characteristic of rubber degradation are high enough to pose danger to human health. The
MMT monitoring conducted in Philpao in August 2010, measured TSP, carbon monoxide,
hydrogen sulfide, ozone and total VOC in ambient air. We have already submitted
comments on the monitoring results. We believe that not enough measurements were
taken considering that tire pyrolysis goes through several stages, each one with a
characteristic set and levels of air pollutants. In addition, we pointed out the need to
determine parameters causing perceived illnesses among exposed individuals.
Total VOC measured just outside Philpao was around 3 ppm. The value is high as compared
to health-related reference values of individual VOC’s. EMB then, could not initiate actions
based on total VOC data for which there is no local standard. No measurement of individual
VOC’s was made.
During a recent meeting at the DOST, it was also pointed out that the requirements defined
for Non-Burn Technologies in the IRR for the Clean Air Act must be applied for tire pyrolysis
notwithstanding the size of the facility. Thus all the parameters identified in Rule 28 of the
IRR must be measured and the standards cited must be applied. Among the parameters are
dioxins and furans.
There is an urgent need for an immediate moratorium on tire pyrolysis by crude facilities.
Appropriate EIA requirements for tire pyrolysis and the parameters for monitoring should
be defined. In the meantime operation by these substandard facilities must be stopped to
give immediate relief to people who have suffered long enough from the ill effects of their
emissions.
Very truly yours
Flora L. Santos
Technical Adviser, Notre Dame de Vie Institute
cc Hon. Jesse M. Robredo, Secretary, Department of Interior and Local Government
Hon. Mario Montejo, Secretary, Department of Science and Technology
Atty. Juan Miguel T. Cuna, Director Environmental Management Bureau
Atty. Jonas Leones, Board Secretary and Legal Counsel, Pollution Adjudication Board
Engr. Lormelyn Claudio, Regional Director, EMB Region III
Engr. Florida M. Dijan, Regional Director, DILG Region III
Dr. Victor B. Mariano, Regional Director, DOST Region III
Dr. Rio L. Magpantay, Regional Director, DOH Region III
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