outlook Industri; a t last, s Newly proposed El by no means the fin but industry now h Pollution control requiren dustrial processes are ( rather sharper focus this n are two important de First, the Environmenta Agency (EPA) has pub1 of emission performanc which will apply to all i from certain types of ne plants. Second, EPA is 1 its regional offices, a set reference guides covering ity of controlling liquia wastes. Air emission standards
Of the two developmei mulgation of air emissio has the weightier push of law behind it. The standards are required by the recent amendments to the federal Clean Air Act (ES&T, February 1970, page 106). These standards-numerically as shown on page 749, if they are not modified as a result of industry comments-will become effective in mid-November. What the performance standards mean to industry is that any new plants in the first five industries specified (see box) must a t least meet the level of emissions control specified in the standards. It is important t o recognize, of course, that these standards in no way apply to emissions of plants that are presently operating (though such plants will sooner or later be forced to operate so that their air emissions do not violate an applicable air qualify standard). The performance standards were proposed by EPA on Aug. 17, with a 45-day period provided for comments from interested parties. One comment being leveled at the proposed standards, according to Robert Walsh of the Division of Compliance in EPA’S 748 Environmental Science & Technology
Referenceguide-liquid
effluents
Beginning this month, the Division of Technical Support in EPA’S Water Programs Office is sending t o all EPA regional offices, a series of effluent reference guides for water-using industries. Although the guides were drawn up under programs mandated by current federal water pollution law, EPA officials take pains to explain that the guides are nor the same as standards. The immediate purpose of the guides is to assist regional EPA offices which, under an agreement between EPA and the Corps of Engineers, will be asked to make a determination regarding the acceptability of applications for discharge permits. T h e permits are required for compliance with the newly resurrected Refuse Act program. According tn Michael La Graff of the Water Programs Office, the guides establish “realistically achievable” levels of control for waste streams in different segments of industry. What the reference guidelines mean to the 20 water-using industries speci-
fied (see box) is that their present levels of discharge will probably be judged in the light of what they realistically could achieve using technology that is relatively well-established for each particular industry. The guides apply to most presently operating plants in the U.S. The guides for each industry segment consist of two separate groups of waste water constituents. The first group contains the key constituents for which discharge levels are given and which should be regulated. For instance, in a food processing plant, these constituents would be COD, BOD, pH, and suspended solids. In petroleum refining, the constituents would be ammonia, BOD, chromium, COD, oil, pH, phenol, sulfide, suspended solids, temperature, and total dissolved solids. The numbers and possibly the actual constituents might, however, vary for the various types of plants within a single industry. (Tbe petroleum industry, for example, is divided
cal manufacturing process most representative of actual manufacturing conditions. It also allows differentiation between old and new technolog>- used to make the same product. NEW POWER PLANTS 0.2 Ib particulate matter per million btu ( 2 0 9 , opacity limit) Gas fired: 0 . 2 Ib NO, per million
btu Oil fired: 0.3 Ib ,NO,, 0.8 Ib SO, per
million btu fired: 0.7 b NO,, 1 . 2 Ib SO, per miliion btu
Coal
NEW I NCI NER.ATORS 0.1 grain per s1:andard cu ft, cor. rected to 129; CO:: NEW NITRIC ACID PLANTS 3 Ib NO, per ton of icid produced
(no visible emission) NEW SULFURIC ACID PLANTS 4 Ib SO, per ton of acid produced 0.15 Ib acid mist per ton of acid
produced (no visible emission) NEW CEMENT PLANTS From kiln: 0.3 Ib particulate rnatter per ton solid:; fed to kiln (10% opacit:,, limit:)
From clinker caoler: 0.1 Ib particulate matter per ton solids fed to kiln (no visible emission) No mass limit for discharges from other pieces of equip. ment, but there must be no visible emission S.ource: €PA
inlo fi\c ilitfereiit plant clasifications.)
The second group of waste water con\titueiit, is m o i e in the nature of a "laundr! list," to use La Graff's uords. It would contain all the constituents that could conceivably be discharged by the particular industry in question. but no numbers are specificd in i t . Actual decisions as to permissible di\charge .evels of these constituents will be made by EP.4 regional officials with reference to the applicable water q tiality standard for thi: receiving stream. The reference guides for the 20 industriej were developed under a series of federal contracts, totaling $1 million in value, that were let earlier this year. La Graff explains that not all water-using industries were C O Y ered, some exceptions being the elect r i a I e q ti i p men t ii n d pharmaceutic a1 industries. The induqtries were studied on a manufacturing basis rather than plant by plant. This made it easier to define wa\te characteristic!; for the typi-
Interpretations There is a possible danger that the efiluent reference guides (which E P A will make available to industry representatives) and published perforniance stafidards for air emissions could be interpreted as the absolute last word in control regulations. To make this misinterpretation would be to disregard the overriding importance of water and air cjrrrrlity standards which still are at the very heart of current federal legislation. In a sense, the guides for water discharges and staiidards for air emissions discussed i n this story merely reflect minimum requirements: in many practical instances, they may be insufficiently stringent to be acceptable. At plant sites in remote locations, t h s e guides and performance standards very probably would be acceptable and represent the level of treatment or control required by federal regulations. However. i n most other locations, and particularly in densely populated or industrialized areas. a higher level of control will almost certainly be required to meet the applicable water quality or air quality standard. For example, if an industry installed effluent controls corresponding to EPA'S etjluent reference guide foI that industry, i t would still be faced with a requirement to meet a particular water quality standard, cautions Richard Nalesnik, director of EPA'S Water Quality Standards Office. Of course, this requirement is built right into the discharge permit program so that any company holding a valid permit would presumably be in coniplia x e with the standard or under a timetable to become so. Likewise, an industry that builds a new stationary source of air emissions might find that the new performance standards suffice when a plant is built out in the country, but that they are insufficient to meet air quality standards if the same plant were built in an urban area. What specific use E P A will make of its newly developed guidelines and standards is still somewhat uncertain I t press time: the agency is still formulating policy. But i t is more than like]>- that they will be of use to state
and local pollution control official>. .And the effluent reference guides will definitely be useful in administration of the discharge permit program. 5ayj Bert Printz of EP;\'S Permits Pi-ogram Office. Printz admits, that the permit program is complicated. involving as it does, five federal agencies, 50 states. Lilid at least four pieces of legimilation. But he is optimistic: H e says the permit program is the first new legislative thrust given the E P A with an adequate number of personnel to do the job. The agency's supplemental funding request for 300 people has been approved by Congress, and 150 are on board today. SSM ' D H M B
Volume 5, Number 9, September 1971
749
Pollution-the whole world’s problem ronmental Problems ( S C E P ) , an interdisciplinary project sponsored by the Massachusetts Institute of Technology, that “approximately 2 million tons of oil are introduced into the oceans every year through ocean shipping, offshore drilling, and accidents.” The SCEP group also expressed concern over the increased concentration of carbon dioxide in the atmosphere that has resulted from burning fossil fuels. A doubling of the carbon dioxide content of the atmosphere could “lead to long-term warming of the planet,” warned the group. International cooperation
Within the last decade, pollution has become one of the foremost topics of concern and causes of legislative action in the U.S. But this country is not alone in its interest in environmental improvement. Developed countries the world over are currently establishing regulations, monitoring air and water pollution, and setting up dataacquisition systems. Now, statesmen are rightfully concerned about the impact that all present and upcoming environmental legislation will have on international trade and relations. Just as pollution honors n o state boundaries within the US., it also has no respect for international borders. Man now realizes that international pollution is of two types-regional (involving only a few nations) o r global (with worldwide monetary or social effects). Many environmental problems involve two or more countries and, therefore, can be classified as international. For example, the increasing pollution of the Baltic Sea involves eight countries, four of which are communist controlled, including one (East Germany) which has such an unsettled status that any international agreement would be hard to achieve. Several serious environmental situations involve the earth on a global basis. Oceans are continually being barraged by oil spills or widespread dumping of waste. Scientists reported at the 1970 Study of Critical Envi750 Environmental Science & Technology
The question remains, of course, whether nations which previously have had difficulties communicating in relatively straightforward international matters can cooperate on a global problem as serious as pollution. Nevertheless, if the focus of international action is kept within certain specialized areas and nations do not try to solve every problem at hand, “I think the possibilities for effective cooperation are quite good,” stresses Christian A. Herter, special assistant to the Secretary of State for Environmental Affairs and the U.S. official who could be described as the foremost diplomat in international environmental affairs. However, obstacles to international cooperation on environmental quality control are indeed formidable. The strict standards in the U.S. and other developed countries are resulting in more costly pollution abatement measures which will influence the price of goods in international trade. If this fact were to lead to stricter regulations for the richer countries and less strict for the poorer, it could seriously affect international trade. Ian MacGregor, chairman of American Metals Climax, Inc., sums up the apprehensions of American businessmen: “We all favor the objective of a cleaner environment. But the problem is that the rest of the world is lagging behind the U.S. in pollution control, and I fear the added financial burden to American industry could weaken our competitiveness in world trade.” Chase Manhattan Bank economists also warn that costly, locally mandated, environmental protection methods could be
disruptive to world trade patterns. Richard E. Spaid, vice president and group executive, American-Standard, adds that “industry in other countries may not be forced to make substantial antipollution investments.” “This is clearly a serious problem for certain industries,” Herter agrees. “However, we don’t know the effect of pollution abatement measures on U.S. exports taken as a whole. We are not sure that, in the aggregate, there is a substantial effect on trade. Nonetheless, it is a serious enough problem that we are giving it the highest priority in our discussions in the Organization for Economic Cooperation and Development (OECD) ,” explains Herter. The 23-nation OECD is the forum in which matters of trade, nontariff barriers, standards, and the harmonization of these are discussed to the fullest extent possible. Another problem, equally serious, is that of the developing countries of the world which, if they adopt strict environmental quality practices, may find that the additional cost will affect the rate of their economic growth. Timothy J. Adams, director of public affairs for the Conservation Foundation, explains, “the wealthy nations are sensitive. . . . about asking the developing nations to embrace practices which, if they had been adopted at a similar stage in their (the wealthy nations’) development, would have meant less material wealth for them today. The developing nations, on the other hand, are sensitive . . . about any obstacles that might be placed on the road toward national economic well-being.” The representative of a developing country sums it up, “It’s hard to focus on environmental quality with a per capita income of $90 a year.” Bilaterals
In some areas, great strides have been and are being made in bilateral cooperation. For example, the International Joint Commission ( I J C ) is the result of a bilateral agreement between the U.S. and Canada in 1911. Although the IJC did and still does deal with obstructions to navigation on boundary waters between the two countries, the original treaty specifically mentions the commitment of each nation not to pollute the water.
The IJC recently submitted a series of recommendations to the U S . and Canada on specific action for the pollution of the lower section of the Great Lakes and the international section of the St. Lawrence Seaway. Since the commission has no regulatory or enforcement powers, both countries must act separately on this matter. Presently, Canada and the US. are negotiating an international executive agreement (which may be signed this fall) designed to clean up the Great Lakes. The IJC may be given a surveillance function, but it will be up to the enforcement agencies of each country to follow through on enforcement procedures. This action is a foremost example of cooperation between two nations for environmental improvement, and “for the first time there is a real chance that something will be done,” emphasizes Herter, who is chairman of the U S . section of the IJC. The U S . and Japan also have decided to form a bilateral arrangement for environmental improvements. Two US.-Japan ministerial level conferences have taken place within the past year. As a result, the two countries have agreed to compatible approaches for pollution control to minimize adverse effects on trade. Other “bilaterals” are in the making. The US. has science and technology exchange agreements with France and Germany (which include
environmental cooperation). In addition to an “informal understanding” with the United Kingdom, negotiations are pending in a number of countries including Romania and Yugoslavia. Discussions are under way with Mexico. And “I wouldn’t be surprised if we would eventually have an environmental agreement with Russia,” continues Herter. M u l t i l a t e r a l elforts
Several organizations are encouraging cooperation among a number of nations. The Economic Commission for Europe (ECE), a semiautonomous subsidiary of the United Nations, is searching for joint East-West action on environmental problems. The ECE includes communist countries as well as western nations. OECD members have adopted an early warning and confrontation system whereby countries about to take national action that might affect international trade will notify the OECD at the earliest possible moment. The OECD, in turn, will notify other member countries. In this way, the nation taking action may have to justify its move to its peers. Thus far, this activity is confined t o national action on the release of chemicals; however, “we hope to expand this t o many other aspects (auto emission standards, etc.) ,” says Christian Herter, wearing yet another hat, as chairman - r .-.-, n~ ~ ~ . . . ~ . ~. 01 O ~ L O s Lommirree on nnviTonmeni. The North Atlantic Treaty Organization (NATO) is also supporting international environmental cooperation. The Committee on the Challenges of Modern Society (within NATO) was formed at the suggestion of President Richard M. Nixon in 1969. “The United States is not only taking an interested role but a leadership role as far as international cooperation is concerned,” summarizes Herter. ~~
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UN conference
Environmental diplomat Herter “This is clearly a serious problem”
Perhaps the beginning of global cooperation on the environment will originate at the United Nations Conference on the Human Environment which will be held in Stockholm, Sweden, on June 5-16, 1972. This conference will try to set international guidelines to cope with environmental pollution and manage resources. Hopefully, results of the conference will include action on marine pollution and monitoring physical, chemical, and biological effects of pollutants. “These are the kinds of
results we can expect from international cooperation,” says Herter. Nations can agree on the impact of pollution on human beings, vegetation, animals, and the level at which that impact becomes dangerous. In the future, common criteria may be adopted, but common standards will probably never be set globally (climate, geography, and weather differences). All 127 nations in the U N will be invited, although 90-100 are expected to attend. Each nation. will be allowed six official delegates, although there may be 15 participants per nation. The ‘ U S . delegation. consistine of administ rators, congressmen, scientists, and members of the public at large, will be chosen in early 1972. ..-C-.tenis a r c more ex pe n < i \ c th a t i o Iil i: r , le\ s efii c i e 11t , biological methods. Lincl are likely a w a l s to rem:iin so. Unless there is l'edern1 pressure to incre'ise the strinycnc! of ei'iluent standards. there will he no real r:eeil to :ipply the newer tiitthoii\. I t seems certain, however. that thi\ pressure i\ intcn\ifying. a n d \\ th the co:igres\ional penchant for \s.riting ;I requirenient for the latest an,l hc\t pollution control technolog!, 11111) feclera1 la~v.the prospect of :i major re\ oItition in the disposal oi don1e.t c s c \ 4 agc is more than just pie in the
\L>..
D H h I I3
Yolumr 5, \ u m b e r 9. 'ie[,tcmhcr 1971
757
Lake Erie group strives for actia Lake Erie Congress passes resolutions which it hopes will spur key decision-makers into taking steps to improve quality of the Lake Erie Basin
__
“There is a burgeoning n-1mh-r l_.nf meetings, conferences, symposia, round tables, seminars, c:onventions, and forums dealing with the Great Lakes,” the program introduction hegan. “Many are of limited value. They retread old ground and recycle old words-while reaching old ’verdicts.” Not so the Lake Erie Cqmgress, according to its codirectors Harold S . Williams and Robert E. H[ansen. The Congress, recently conve:ned under the joint sponsorship of t’he Institute on Man and Science (‘Rensselaerville, N.Y.) and the Great Lakes Research Institute (Erie, Pa.,), was designed “to make a differenc:e,” according to its organizers-“to stretch our minds and lift our horiz ons.” The mind stretching a nd horizon lifting was to climax in a’ction. “The program is a Congress uiith a mission,” delegates were told, That mission: “to chart an explici t course of . action for dealing with Lanc mir s prospects and problems.” The vehicle for action was a hicameral pseudolegislature-consist ing of a House of Context and a Hause of Interventions. Each house was f ur~ P ther split into three committees whL.jobs were to draft preliminary resolutions dealing with specific issues in their areas of competence.
....
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had committees on Social Context, Environmental Context, and Economic and Industrial Context. The House of Interventions had committees on Technical, Institutional, and Present Practice Interventions. Each committee was assigned a “rapporteur’-a Harvard, Wellesley, or M.I.T. student-to help polish resolutions, cope with the paperwork, and keep things running smoothly. As background for their work, delegates were expected to draw upon their particular areas of expertise as well as the International Joint Commission Report on pollution of Lakes Erie and Ontario and the St. Lawrence River (see “Rx for ailing lakesa low phosphate diet,” ES&T, Decemher 1969, page 1243). Additional information was provided by an anthology of interviews, abstracts, and literature summaries prepared for the 1n . . : . .
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entire Congress for ratification. Among the more innovative resolutions passed by the Congress were those calling for: - A Lake Erie Basin Fund to receive and administer donated money to initiate and implement action programs of benefit t o the Lake Erie Basin; * A n environmental trust fund to provide access to capital (not solely on an economic basis) by devices such as low interest or partially guaranteed loans; An international Great Lakes Basin Authority (OLBA) which would have power to set standards for water quality, establish and enforce sanctions against polluters, and fund research and development projects. (Such an authority would have a testing laboratory associated with it.); A federal-state matching fund
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tems, Inc. (Newton, Mass.) and distrihuted t o delegates at registration.
capital CIJS1!s of implementing immediate state-iJf-the-art technology to reduce poll ut ants to an environmentally accevtabl’e level; .A pro,totype “environmental town” ~n the T ... _.__ -ake Erie Basin for research, development, and demonstration of techniques for pollution abatement, water recycling technology, and relief of urban and suburban sprawl; A professional referral service based on a talent bank of qualified consultants. Now that the Congress has adjourned, was it more than just a hunch of people playing games? Hansen says yes. Proceedings of the Congress will roll off the presses this month and when they d o they’ll he distributed to legislators and other key decision-makers in industry and pollution control. The format will he “punchy enough,” Hansen says, so that “even at the highest desk, the re-
Recommendations
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After preliminary resolutions were P
sented the p. t i. l. ld tn ..._rll.i l ._minliitinm . __I_._.._. ._ .”the ..._
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by their respective houses, joint Context-Intervention committees hammered out the final drafts and pre-
Congress. Institutional Interventions committee thrashes out resolutions
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Its contents perused.” That, the Congreys hopes will, at least begin to HMM “make a difference.”
