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LETTERS Water regulation cost Dear Sir: The need for economic impact statements as a part of the process leading to new or amended regulations is essentially recognized universally. However, it is also necessary to make the economic analysis realistic. In the case study presented in this article there are several factors that tend to inflate the final analysis ( E S & T ,June 1979, p 656). In the first instance, the selection of discharges was based upon an inadequate data base. In many cases the decision was based on the results of less than one sample per year without any consideration of the trend. Starting in 1969, there was a major effort nationwide to reduce mercury discharges to the absolute minimum. Thus, dis-
charges with effluent mercury concentrations greater than 0.5 p g / L in 1977 would be much more suspect than a discharge that exceeded the effluent standard in 1972 but never since. The result was the inclusion of some discharges that most probably were not violating the standard. The major failing though is the assumption that all discharges in violation of the mercury effluent standard (0.5 pg/L to 3.0 p g / L ) would have to provide a mercury removal process (ion exchange being cited) to achieve the standard. This is unrealistic since the dischargers would probably first initiate sampling programs (at some cost) to determine if they were still in violation. If violations still existed, then an evaluation of the source of the
mercury and possible corrective measures would be done. This could be anything from replacing the leaking seal on a trickling filter to cleaning sink traps and dilution chambers to changing to an alternative industrial process. The point is that. in most instances, the final decision (based on economics) would not have been to build a waste treatment system but rather to first find the mercury source and eliminate or reduce it as much as possible. Thus, the net result is an economic analysis that shows unrealistically high treatment costs and higher savings than achievable by changing the effluent standard. Fortunately, it is of no major consequence in this case since the environmental consequences of changing the mercurj effluent standard from 0.5 to 3.0 p g / L are negligible, but I can visualize similar applications where the erroneous use of the assumption that the only solution is additional waste treatment could make a regulation that is environmentally beneficial appear to be economically unsound. As in all cases, when one is forced to do an analysis with a paucity of data in a minimum of time, the results are most often unsatisfactory. C. M. Timm 18 a rte de Drize
1227 Carouge G E Switzerland
Environmental research journals Dear Sir: Studies of journal citation frequencies are always good fun with a computer, and the one on Journal Citation Frequency by Subramanyam and O’Pecko ( E S &T, 13, 927 ( 1 979) is no exception. On the other hand, like other studies of citation frequencies, it has limitations beyond the ones cited in the paper. The chief one is that it is an almost universal finding that, just as authors tend to cite their own work, authors publishing in a given journal tend to cite papers in that journal. Thus, I am quite sure that, for example, a similar study of Atmospheric Encironment would show a predominance of citaCIRCLE 11 ON READER SERVICE CARD
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Environmental Science & Technology
t i on s o 1_ '4 tri iosph (:,ric Eririroririient .
For that matter. I h.I\,e little doubt that t h e saine would be true of the Jouwzal OJ t h o LOI\.L'I. Sloho1.iar7 SocietJ, of L'pidopt eris 1 s . This in no \ \ a \ 1:lenigrates ES& T , +I hich is an excellent journal. However, I rather suspect t h a t a study of a number of journals could evolve a normaliring factor for this tendency to cite publications in the journal in +I hich one is publishing. I Lvonder-is t h i s an attempt t o "butter up" the Edit or '? The unquestioned acceptance of a computer printout also has: its hazards. 1 note that there u c r e seven citations of the ltitrrricitioriul /or,rrml of Air and Wcitrr Pollirtiori. This. in 1967, split into .4ti?iosp/icJri(,E/irirorinirrzt and M/Litcr Krsrtirih. respectively your sixth and seventh ranking journals. I t \\auld be instructive indeed to learn \\hother the seven (citationsof t h e Intrrri~tiori~il Jourriul' of' Air arid Water PoI/utioii (not a bad s h o n ing after I O iearx) \+erein the ficld of air or water. Quite posibl! the addition of those numbers to the nun-ibers from the two successor journals could change the ranking . This i h distinctl:, not sour grapes. Considering the cclmpetition. I think .4triio.cp/ic)rir, Etii.irori/iierit has made ;I good xhowing. James P. Lodge, Jr. Atniosphcric Environ nent Boulder. C'olo. XO303
Tar sands I \\auld like to thank Llr. Beamish (letter. ES& T, October 1979, p 1 177) for pointing out thi. confusion on the description of the '\I.'RD C S E M s!stem. I agree \\.it11 kin1 that the measurements are continuous from the CS1:M s>stem. However, the values of 1,arious parameter. i n question are recorded :it one minute intervals. Further. the error in Figure 3 is a typographical one and \vas not i n tended. Asholi Kumar Syncrutit Canada Lttl. Ednionlon. .2lberta T 5J 3E5 Can;id:i
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