Technology
Controversy envelopes environment standards "Unrealistic" deadlines, insufficient data cited by industry representatives at national conference on environmental standards Current efforts toward environmental control and improvement, says Dr. Joseph T. Ling, director of environmental engineering and pollution control for 3M Co., recall the story of an airliner that was flying around in heavy fog. Finally, the pilot of the long overdue aircraft announced to his passengers, "Folks, I have some good news and some bad news. The bad news is that we are lost. But the good news is that we are making record time." "We are making record time in establishing various [environmental] laws and regulations," Dr. Ling explains. "But we are lost in our direction." Furthermore, adds Robert A. Baker, executive vice president of Public Service Electric and Gas Co., "Politics and emotions have been all too important factors in setting regulatory standards. Standards have been developed in the abstract without sufficient attention to the real world of today's technology, today's costs, and overall national goals. Environmental standards have been subject to varying interpretations by courts and regulatory agencies, leading to delays, conflicting and confusing interpretations, and unwise spending of money." In these and harsher terms, industry representatives, such as Dr. Ling and Mr. Baker, attacked current environmental standards and the methods by which they are set at the first National Conference on Standards for Environmental Improvement, held late last month in Washington, D.C. Sponsored by the American National Standards Institute (ANSI), American Society for Testing and Materials (ASTM), and the American Society of Mechanical Engineers (ASME), the two-day conference brought together some 300 participants, mainly from industry but also including representatives of federal, state, and local environmental agencies, and of labor and consumer interests. Amidst occasional clashes of viewpoint—particularly between regulators and regulated—conference discussions focused on the thinking and planning
behind environmental standards and on how standards should be developed. Among the questions discussed: • What problems are being caused by current federal standards for air and water quality and solid waste disposal? • What steps are being taken to overcome these problems and to balance the need for environmental improvement against economic, social, and energy needs? • What are "standards" and what processes should be used to develop them in the environmental field? • What should be the role of the private sector vis-a-vis government in developing environmental standards? "In the past decade, more legislation has been enacted requiring mandatory standards than in the entire history of the United States," points out Roy P. Trowbridge, president of ANSI and director of engineering standards for General Motors' engineering staff. New laws require federal and state agencies to set standards safeguarding the public, for example, in environmental quality, occupational safety and health, and product safety. A host of new environmental standards—specifying maximum permissible levels of each pollutant—must be developed and officially adopted, accompanied by reliable standard methods of measuring those levels. However, many speakers at the conference charged, current environmental standards, and the processes by which they are set, are far from satisfactory. "Unrealistic" Congressionally mandated deadlines, requiring issuance of standards by a certain time limit, force an "expedient approach" and unjustified technical shortcuts by federal and state regulatory agencies. Standards are written despite insufficient study and incorrect, incomplete, or even nonexistent data. Furthermore, many conference participants emphasize, satisfactory agreed-upon standard methods of measuring pollutant levels are generally lacking (C&EN, March 5, 1973, page 13). "We are constantly butting up against the limits of environmental knowledge," says William R. Smith, manager of environmental control for Kaiser Aluminum and Chemical. One example is cited by Charles 0 . Velzy, head of a consulting engineering firm based in Elmsford, N.Y. Mr. Velzy describes how the Environmental Protection Agency set a new source emission standard for municipal-type incinerators using a test method for
particulate emissions that gives variations of 200 to 400% or more in results —because of EPA's need to issue a standard within a legislated time limit. However, explains Dr. Richard Carpenter, executive director of the National Research Council's Commission on Natural Resources, there are strong reasons why Congress adopted specific goals and deadlines, including the most controversial of all—an objective of "zero discharge" in water by 1985. Legislation establishing what currently seem like unachievable deadlines was "born of disillusion, passed out of a sense of frustration and real pressure from the electorate. That is, if Congress doesn't establish definite time limits and set 90% reductions in pollution by law, there'll never be any action." Sen. Edmund S. Muskie (D.-Me.), sponsor of several of the environmental laws passed in recent years, emphasized to the conference that Congress is "confident that the combination of specific standards and deadlines will
Ling: lost in direction
Train: too much in too short a time March 4, 1974 C&EN
15
provide incentives for the development of new technology." Environmental policy, Sen. Muskie stresses, must "re flect public demands, rather than ad justing the public interest to present technological capabilities, economic limitations, and institutional inade quacies." These views were reinforced by EPA administrator Russell E. Train, who told the conference that he sees emis sion and effluent limits as "a driving force for improved technology. The very essence of environmental protec tion regulation demands that we con tinually refine our requirements as our capability improves." However, Mr. Train admits, "The time frames set by law for achieving various standards are providing in some cases as much of a problem as the standards themselves. In some in stances it is simply a case of there being too much to do in too short a time." Mr. Train does not expect, for example, to achieve, on time, goals set by the 1972 amendments to the Feder al Water Pollution Control Act: general adoption by 1977 of the "best practica ble control technology" for industrial waste water treatment, and adoption by 1983 of the "best available technol ogy economically achievable." A prin cipal reason, he says, is heavy cutbacks in federal funding for research and de velopment in this area. Mr. Train and Allen Cywin, director of EPA's effluent guidelines division, stress that they are trying to be "rea sonable." They are prepared to consid er the legitimate interests of industry. An essential feature of Congressional thinking, incorporated into legislation setting environmental standards, is "continuous reappraisal of these stan dards and substantial research pro grams," Sen. Muskie points out. A number of studies are now under way to examine possible "midcourse correc tions" to the standards. A National Academy of Sciences panel, for exam ple, is studying the health effects of major air pollutants, under contract to the Senate Public Works Committee. And a national study commission, chaired by former New York governor Nelson Rockefeller, is making a broad study of the economic and social ef fects—the total cost/benefit picture— of the 1972 amendments to the Water Pollution Control Act. A central complaint by industry rep resentatives at the conference was that the private sector is not adequately in volved in development of environmen tal standards. Participants stress that the voluntary consensus standards sys tem developed by ANSI, ASTM, ASME, and other organizations is a great reservoir of expertise, knowledge, and capability. Government agencies are generally not using the services of this consensus system in development of environmental standards. Indeed, Mr. Trowbridge, ANSI's president, be lieves that required environmental 16
C&EN March 4, 1974
standards would best be developed in a consensus organization, or should at least be submitted to a consensus re view before promulgation for public comment in the Federal Register. Dr. Robert J. Moolenaar, associate scientist for environmental affairs at Dow Chemical, adds that what is need ed is "earlier interaction between gov ernment agencies and affected parties." And more time than the 30 days now allowed should be given for comment on proposed EPA standards. In their remarks at the conference, Russell Train and other federal offi cials expressed their desire to work with industry and consensus organiza IBM researchers observe operation of tions, and to take more advantage in new source of tunable coherent light the future of their capabilities for de veloping methodology—for example, In addition to the interest in the testing, sampling, storage, and calibra tion techniques. Many scientists at phenomenon itself, the developers, Dr. EPA and the National Bureau of Stan Rodney T. Hodgson, Dr. Peter P. Sodards are members of consensus stan rokin, and Dr. James T. Wynne, be lieve that their development will inter dards working groups. However, Mr. Train explains, the re est workers in several areas of photo lationship between EPA and industry chemistry, since the photon energies "must of course be on an arm's length involved are appropriate to the study basis." EPA will not automatically of individual chemical bonds. In their adopt standards developed by consen estimation, a new order of precision in sus groups, even when EPA scientists photochemical studies now can be participate in those groups. As the rep achieved. In particular, the new source resentative of the public, "we have a of coherent light will permit spectrosstatutory responsibility. We should copists and photochemists to study in communicate with everybody, but we new ways the electronic, vibrational, and rotational properties of atoms and have to be the ultimate decider." And the EPA head stresses in partic molecules, and the ways in which these ular the problem of credibility in deal entities gain and lose energy. Operationally the ultraviolet sources ings with interested industries: "The public must not feel there is some pri for the new system function in about vate deal. From the standpoint of pub the same way as those from the tun lic confidence, decisions must be ar able, coherent infrared sources in the wave-length range from 20,000 to rived at as openly as possible." 300,000 A. that were developed by IBM last year. Both types depend on inter actions between two input laser beams and atomic vapors. The input beams are obtained from tunable organic dye lasers. A new source of coherent light, tunable Two lasers, each tuned to a different in wave length over the approximate frequency, provide the input for stron range of 1500 to 2000 Α., has been de tium vapor in the latest series of exper veloped by scientists at International iments. One of the lasers is tuned to a Business Machines' Thomas J. Watson frequency corresponding to one half the Research Center. This is the first time energy of a two-photon transition in such light sources have been available the strontium vapor. This particular with tunable lasers in the vacuum ul transition was selected because it has a traviolet region. high probability of occurring by ab-
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