Industrial wastes reduction Last of a jve-part series
James W. Patterson Illinois Institute of Technology Chicago, IL 60616
The National Research Council recently sponsored a symposium on multimedia approaches to industrial pollution control (1). The overwhelming and disappointing consensus of the papers presented at the symposium was that the result of our ambitious, expensive national initiatives in environmental protection since the 1950s has been the transfer of toxic pollutants from one medium to another. Examples of transfers include the control of industrial air pollution that results in the generation of polluted scrubber water or solid wastes; treat ment of that air pollution scmbber wa ter to prevent water pollution, but in the process generating a toxic sludge; and disposal of that sludge to a landfill, which leaks (as they all eventually do) to contaminate the groundwater. This merry-geround of pollution relocation is traceable to the single-medium emphasis of our environmental protectioi legislation: the Clean Air Act (CAA), the Clean Water Act (CWA), and the Hazardous and Solid Waste Amendments OISWA) to the Resource Conservation and Recovery Act (RCRA). Yet the 1984 Hazardous and Solid Waste Amendments were the legislative genesis of a bold new concept of envi ronmental protection that has gaina broad acceptance and generated grea. controversy. This concept was “waste 1032 Environ. Sci. Technol., Vol. 23, NO.9,1989
minimization.” The concept grew from federal legislation intended to curb mismanagement of hazardous waste, and unfortunately the concept has by convention become linked primarily to hazardous-waste management programs. Nevertheless, the concept and goals of waste minimization are worthy and have been enthusiastically adopted by regulatory and other governmental agencies, industries, and the public.
Range of concerns Sustained publicity concerning toxic spills, beach contamination, ozone depletion, acid rain, and widespread toxics releases to the environment continues to rouse public skepticism regarding the effectiveness of regula-
LRA Title 111 Section 313 toxic releases reporting requirements Manufacturingfacilities are required lo report if they: have 10 or more full-time en PlOYWS, manufacture, process, or othe. wise use a toxic chemical listed in the law above a threshold quanti (the threshold is 10,000 Ibdye2 for toxic chemicals used; for toxi chemicals that are manufactured or processed the thresholds are 75.000 lbs!yt?ar in 1988; 50,W lbslyear in 1989; and 25,000 Ih year in subsequent years), or are in Standard Industrial Ciassii cation Codes 20-39.
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tory programs intended to protect the environment. Congressional ineffectiveness and foot dragging in rewriting and reauthorizing key environmental protection legislation such as the Clean Air Act (now before the IOlst Congress for reauthorization) exacerbates that skepticism and results in a loss of confidence in political commitment to a clean environment. However, a key section of the 1986 Superfund Amendments and Reauthorization Act (SARA) has caused industry to produce data on toxic releases to the environment which, by the sheer magnitude of the quantities of toxics involved, may ensure public demand for swift legislative action. The key section is Title III of SARA, the Emergency Planning and Community Right-toKnow Act (EPCRA). This bitterly controversial provision of SARA was a major victory for environmental activists and community right-to-how advocates. EPCRA is a direct result of the horrifying release of methyl isocyanate in Bhopal, India, and the consequent fatalities. Industry could not effectively deflect congressional concerns about a similar disaster in the United States, and EPCRA was incorporated into the act as Title III. EPCRA contains four major sections: emergency planning, emergency notification, community right-to-how reporting requirements, and toxic chemical release reporting. This last aspect is addressed in Title IJI, Section 313, and requires that certain manufacturing facilities provide EPA with data on releases of toxic chemicals to the environment (see box). The results
0013-936X18910923-1032$01.5010 @ 1989 American Chemical Societv
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from the first such reporting, for 1987, have now been tabulated (2). Although Section 313 requires reporting by only a limited subset of all US. industries that handle toxic chemicals or release hazardous wastes, over 17,500 facilities filed reports for 1987. About 75,000 reports were filed, one for each regulated chemical used, processed, or produced at the facility. The data base is certainly incomplete and probably inaccurate. Nevertheless, it is the first such data base describing Mtionwide releases of hazardous wastes to the environment; it describes over 22.5 billion pounds of toxic chemicals released into the environment in 1987 (Table I). Local media coverage of individual facility releases as reported under Section 313 has already triggered a rash of new corporate commitments to initiate waste reduction programs (3). Other facilities had effective waste reduction programs in place long before the 1986passage of SARA. The 1987 results from Section 313 reporting are not the first evidence of the magnitude of toxic releases into the environment. Between 1979 and 1982 the New Jersey Department of Environmental Protection conducted a landmark industrial toxic release survey, considered to be one of the first and most successful attempts by a state to use a cross-media approach to assess toxic substances’ use and release mechanisms (4). The project required industries to perform and report a modified mass balance, which provided a state-
wide chemical inventory and assisted in identifying sites of potential toxics contamination. Many believe that this state program laid the foundation for the development and incorporation of Title IIl in SARA. The success of the New Jersey program is demonstrated by the fact that their early survey for atmospheric emissions yielded results within 3.5% of the 1987 Section 313 data for New Jersey. Since 1981 the Chemical Manufacmrs Association (CMAI has tracked hazardous-wastes generation and management techniques for selected chemical-manufacturing facilities and has prepared annual reports. The most recent survey results, for 1986, involved 529 chemical plants (5). The results are interesting, particularly when compared to Table 1, which deals with specific chemicals. Under RCRA, a waste product may be deemed hazardous even when only a tiny fraction of its composition consists of toxic chemicals. Thus, the actual amount of “hazardous wastes” can exceed by many times the mass of toxic chemicals present. The 1986 CMA results revealed that 529 chemical plants surveyed produced 220.5 million tons of “hazardous wastes” but that 98% (216.2 million tons) was hazardous wastewater treated in wastewater treatment plants under the Clean Water Act. Sludges produced by such treatment are of course also hazardous wastes. The remaining 2% of the hazardous wastes reported by the
hnount of toxic chemlcalsreleased in United States in 1987
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___ 1034 Ennron. Sci. Technol., MI. 23. NO.9, ism
Genesis of waste reduction As cited above, with the 1984 Hazardous and Solid Waste Amendments to RCRA Congress first articulated a Mtional policy of waste minimization. Waste minimization as defined in HSWA means reduction of any solid or hazardous waste that is generated or subsequently treated, stored, or disposed of. It is generally agreed that waste minimization includes volume reduction as well as reduction in-the quantity of toxic constituents or of waste toxicity. Volume reduction is a less desirable goal than is reduction in the quantity or toxicity of wastes generated. Toxicity reduction may be achieved by a variety of methods, including chemical and thermal destruction. Reduction in the quantity of waste generated is usually achieved by measures applied at the source of generation, including modifications in manufacturine Dmesses. chanees in raw materials, or recycling and reuse (7). Waste minimization might consist of volume reduction or waste concentration by sludge thickening or dewatering, or by use of ion exchange to prcduce a concentrated regenerating agent from treatment of a dilute wastewater. There is still waste to manage, but it is more concentrated. Waste minimization might, alternatively, involve chemical, thermal, or other partial or complete detoxification. However, the principal thrust of national policy as established in HSWA by Congress and signed into law by &sident Reagan is not simply waste minimization but waste elimination or reduction. Quoting from Section 8002(r) of HSWA “The Congress hereby declares it to be the national policy of the United States that, wherever feasible, the generation of hazardouswastes is to be reduced or eliminated as expeditiously as possible [emphasis added].” Congress went on to say that when this goal could not be completely achieved, the generation of hazardous waste
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chemical plants, representing 4.3 million tons, was solid hazardous waste. Table 2 shows that 288,000 tons of hazardous wastes from the 569 chemical plants were placed in landfills. According to Table I , 1.2 million tons of equivalent pure toxic chemicals were put in landfills by the more than 17,500 facilities represented by that data. The ultimate tonnage of “hazardous wastes” requiring management far exceeds the tonnage of toxic chemicals in the waste material. The segregation of toxics from more benign bulk waste residues has been one of the most effective waste reduction initiatives undertaken by industry (6).
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should be “minimized” to the extent possible. In contrasting waste minimization with waste reduction or elimination, consider the actual genesis of industrial pollutants. The waste stream may be gaseous, liquid, or solid. Irrespective of the physical form of the waste stream, the constituent pollutants can be assigned to one of six broad sources: unrecovered raw materials; unrecovered products; useful by-products (including side reactants); useless byproducts (including side reactants); impurities in raw materials; and spent materials such as solvents, catalysts, acids, and spent baths. Waste elimination is achieved only through an identification of the genesis and properties of a pollutant or class of pollutants and the development of a targeted strategy predicated on this information. That strategy will be derived from one of three options: source avoidance, source Capture and return, and purification of spent materials for recycle and reuse. Source avoidance can encompass a variety of approaches. Among these are raw-material substitution, raw-material prepurification, operating modifications, equipment modifications, and equipment replacement (i.e., “clean manufacturing technologies”). Source capture and return is the second option for waste elimination. Applications include condensation and direct return of escaping solvent vapors, as contrasted with spent-solvent purification by distillation for solvent reuse. This latter approach is representative of the third option. Source avoidance plus source capture and return are usually grouped under the general category “source reduction.” Generally, the hierarchy of waste management options (8, 9) is as follows: source reduction, followed by recycling, treatment, and disposal (including land disposal). EPA defines these four elements as shown in the box. Land disposal is the least desirable option, an opinion generally shared by the public, regulators, and the regulated community. The HSWA call for EPA to phase out the land disposal of virtually all untreated hazardous substances by 1992 at the latest. The concept of waste minimization derives from legislation intended to regulate solid and hazardous wastes, and is still used primarily in the context of hazardous-waste management, There is a Waste Minimization Office within the EPA Offce of Solid Waste. However, the underlying concept of waste minimization is easily and effectively extended to address toxic releases to all medii, and this has pm-
Definitions of elements of waste management hierarchy Source Reduction means the reduction or elimination of waste at the source, usually within a process. Measures include process modifications, feedstock substitutions, improvements in feedstock purity, improvements in housekeeping and management practices, increases in the efficiency of machinery, and recycling within a process. Source reduction implies any action that reduces the amount of waste exiting from a process. Source reduction is waste avoidance. Recycling is the use or reuse of hazardous waste as an effective substitute for a commercial product or as an ingredient or feedstock in an industrial process. It includes the reclamation of useful constituent fractions within a waste material or the removal of contaminantsfrom a waste to allow it to be used. Recycling can include use of waste as a fuel supplement or fuel substitute. However, processes in which overall energy efficiencies are less than 60% are regarded as incineration (treatment), not energy recovery (recycling). Recycling can occur on- or off-site. lbatment is any method, technique, or process that changes the physical, chemical, or biological character of any hazardous waste so as to neutralize the waste, to recover energy or material resources from the waste, or to render such waste nonhazardous,less hazardous, safer to manage, amenable for recovery, amenable for storage, or reduced in volume. Disposal is the discharge, deposit, injection, dumping, spilling, leaking, or placing of hazardous waste into or on any land or water so that such waste or any constituents may enter the air or be discharged - into any waters, includ-
ing groundwater. Source: Reference 1
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ceeded under more generic terms such as “pollution prevention” or “waste reduction.” Waste reduction appears to be the more widely adopted terminology, although on August 5 , 1988, EPA created an Office of Pollution Prevention within their Office of Policy Planning and Evaluation. The concepts of waste minimization and waste reduction are inherently attractive environmental goals and have achieved enthusiastic support at local, state, and national levels. There is also strong international support for such concepts. For example, the province of Ontario, Canada, has waste minimization regulations that promote at least one of these elements: reduction, reuse, recycle, and recovery (the “four Rs” of waste management). The Science Advisory Board (SAB) of EPA recently stated, “We have learned that traditional end-of-pipe controls have tended to move pollution from one environmental medium to another, not eliminate it . . . the magniNde of [environmental] risks requires that we develop and maintain a national strategy that emphasizes [pollution] prevention. . .” (11). The SAB further emphasizes that our national programs on waste minimization and reduction should not be restricted solely to hazardous wastes, to wastes that are land disposed, or to substances traditionally viewed as wastes. Recognition of the potential impacts of waste reduction initiatives extends beyond the public, government, and industry to professional societies traditionally involved in environmental
management. The Air Pollution Control Association has recently extended its coverage to incolporate solid (and hazardous) waste management and has published a series of in-depth reviews on industrial hazardous-waste minimization and waste reduction measures (12-22). The American Institute of Chemical Engineers has reorganized its Environmental Division to include a section devoted to pollution prevention. The Water Pollution Control Federation adopted this year a set of principles addressing waste minimization and waste reduction (7). Despite the broad acceptance of such concepts and principles, there remain many obstacles to the implementation of waste reduction (23). These include the existing regulatory structure and inflexibility; lack of incentives, or economic or regulatory disincentives; and reluctance to abandon proven pollution control practices and the capital investment in existing end-of-pipe pollution control facilities.
Industry pressures and initiatives A few industries perceived the advantages of waste avoidance and reduction long before Congress addressed this matter. This perception was caused by concern about image in the community, increasingly restrictive environmental regulations, escalating costs of pollution control, and current and hture liability for past waste management practices. Since the 1984 HSWA reauthorization of RCRA and the 1986 passage of SARA, these pressures have escalated. Environ. Sci. Technol., MI. 23,NO. 9, 1989 1035
For example, environmental impairment insurance is effectively unavailable now to industry. The HSWA require that EPA impose a ban on the land disposal of liquid wastes and on many solid hazardous wastes. This narrows the disposal options available to industry and ensures that disposal costs will continue to rise. Export of U.S.-generated hazardous wastes abroad will be more tightly controlled under legislation recently proposed by President Bush (24). Present policy, in effect since November 1986, requires notification to EPA of intent to export hazardous wastes to any country. EPA reportedly receives up to 600 such requests annually (24). The proposed legislation will ban all exports of hazardous wastes except where the United States has an agreement with the receiving country providing for the safe handling and management of such wastes. The HSWA also require [Section 3002(b)] that each hazardous-waste generator certify on each waste shipment manifest that the generator has in place a waste minimization program, and has “selected the practicable method of [waste] treatment, storage or disposal . . . which minimizes the present and future threat to human health and the environment.” The unspoken threat is that EPA or Congress will force the generator to prove the substance of that signed certification. The forced reporting of toxics releases under SARA Title III Section 313 is intended to invoke public recognition of the magnitude of industrial release of toxics to the environment and to pressure industry to undertake voluntary source reduction. There are early indications that this congressional strategy has been effective. Media descriptions of major toxic emitters have encouraged some industrial facilities to announce major programs of waste reduction (3). Legislation currently being considered and prepared by Congress will further pressure industry. EPA administrator William Reilly has announced that his agency is preparing a broad waste reduction bill expected to be introduced this year. Rep. Howard Wolpe (D-MI) and 171 cosponsors have introduced a bill (H.R. 1457) that would establish an office in EPA to promote hazardous-waste reduction via mechanisms such as state grants and information clearinghouses. The bill would make mandatory and expand certain industry reporting practices now voluntary under SARA Title El Section 313. Sen. Max S. Baucus @-MT) favors mandatory source reduction requirements. The Baucus bill (S. 1113) incorporates 1036 Environ. Sci. Technol.. Vol. 23. No. 9.1989
t Imany of the features contained in the Wolpe bill, but would also impose “a [mandatory] national performance efficiency standard for industrial waste generators [in Standard Industrial Cat* gories 20-391 requiring within ten years that total hazardous residuals includmg emissions, effluents, spills and managed wastes will not exceed 5 per CenNm of production throughout.” The earliest formal corporate program of waste reduction is the 3M program unveiled in 1975. This “Pollution Prevention Pays” or 3P program has been immensely successful in reducing costs of pollution control, in avoiding future liability, in recovering the value of lost product and raw material, and in producing a positive corporate image. 3M reports that corporate facilities have reduced pollutant release to all medii by 450,000 tons. A secondary benefit has been a $420 million savings in operating costs (25). Many other industries have followed 3Ms lead. The Dow Chemical Company WRAP (Waste Reduction Always Pays) program won the 1989 Gold Medal for International Corporate Environmental Achievement from the World Environment Center. Amoco Chemical Company has reduced its disposal of hazardous wastes by 87 % over the past four years. The company now recycles more than 32,000 tonslyear of hazardous waste and d i e s a disposal savings of $1.5 million (26). Changes in manufacturing processes cut Amoco hydrocarbon losses in half between 1982 and 1986. Today the trend across industry is toward in-house waste reduction programs, most of which have been implemented within the past five Years.
Government programs Government support for industrial waste reduction was pioneered at the state and local levels through technical
assistance programs, demonstration grants, and waste exchanges. Federal efforts have lagged behind for a variety of reasons. Only in 1988 did EPA formally establish a Pollution Prevention Office within the agency. The first state program was launched in 1983 by North Carolina, and it remains one of the most active and successful. The North Carolii program demonstrates the concept of many of the state programs. It has funded research and educational projects in a variety of industries and operates an information clearinghouse. The program provides matching grants of up to $10,000 for developing waste reduction projects. The states exchange information and coordinate activities through the National Roundtable for State Waste Reduction Programs. At the state level, the technology transfer functions a p pear to be extremely effective. The city of Los Angeles recently established a pollution prevention newsletter to assist local industries. The newsletter is published through the Los Angeles Board of Public Works, Hazardous and Toxic Materials Project. Services available through this local project include an information clearinghouse, on-site tqhnical assistance, and outreach and training programs (27). One of the most creative grass roots programs to have developed is waste exchanges (see box). A waste exchange is an operation that transfers either information concerning the availability of or need for waste materials, or of the waste materials themselves (28). The former strategy is preferred to avoid potential liability associated with a transfer of a hazardous waste. The waste exchange goal is to inform and bring together waste generators and waste users by electronic bulletin boards or by regular published listings of wastes available and waste sought. The original prognosis for waste exchanges was pessimistic, but they have flourished, and regularly transfer large quantities of many kinds of wastes. The primary federal focus for waste reduction is EPA. The Department of Energy (DOE) recently announced a new R&D program that will focus in part on waste minimization (29). The Department of Defense (DOD) is the nation’s largest generator of hazardous wastes (20). DOD established a policy for waste reduction in 1987 that requires each service branch to develop and implement its own program. For example, the Air Force has set an annual goal of 10% waste reduction each fiscal year from FY88 through FY92. The Army’s goal is 50% reduction by 1992. The EPA program is directed toward
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US. wa
xchanges
CALIFORNIA WASTE EXCHANGE Robert McCormick Department of Health Services Toxic Substances Control Division 714 P Street Sacramento, CA .aC**d
INDUSTRIAL WASTE TlON EXCHANGE William E. Payne New Jersey Chamber 5 Commerce Street Newark, N J 071P
(916) 324-1807
(201) 623-7070
GREAT LAKES REGIONAL WASTE EXCHANGE. William Stough 470 Market SI., S.W. Suite 1OOA Grand Rapids, MI 49X
MONTANA IND EXCHANGE Don lngles Montana Cham PO. Box 1730 Helena, MT 5962 (406)442-2405
(616)451-8992
INDIANA WASTE EXCHANC Shelley Whitcomb Environmental Quality Contn 1220 Waterway Boulevard PO.Box 1220 Indianapolis, IN 4
NORTHEAST INDUSTRIAL WAST EXCHANGE' Lewis M. Cutler 90 Presidential Plaza
(317) 634-2142
INDUSTRIAL MATERIAL E) CHANGE SERVICE
SOUTHEASTWASTE EXCHANGE
Margo Siekerka
Institute UNCC Station Charlotte, NC 2 8 ~ 2 3
PO.Box 19276 Springfield, IL 62794-9276 (217) 762-0450
MaN McDaniel . ~ .-
ur&
(704) 547-2307
INDUSTRIAL MATERIALS RECYCLING PROGRAM Marion Mudar New York State Environmental Fac itiss Corporation 50 Wolf Road Albany, NY 12205
Florida State University Institute of Science & P Tallahassee, FL 32313
(518) 457-4138
(904) €44-5516
promotion of waste reduction within the private sector. Multimedia efforts are. focused through the new El?A Pollution Prevention Office, which helps coordinate pollution prevention activities across all EPA headquarters and regional offices. The agency has also established a Waste Minimization Branch in the Risk Reduction Engineering Laboratory in Cicinnati. That branch provides technical and research support to the agency's Pollution Prevention Program (30j and administers a variety of technology development, assessment, and demonstration programs. EPA is also developing an on-line electronic Pollution Prevention Information Clearinghouse. The clearinghouse can provide information on state waste reduction programs, waste reduction case histories, and abstracted waste reduction publication lists. This initiative reflects the current agency philosophy that waste reduction is best
SOUTHERN WASTE INFORMATlON EXCHANGE' Roy Herndon
I
EO. Box 6487
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achieved via education and technology transfer rather than through regulatory imposition of mandatory targets.
Conclusions The concepts of waste reduction and pollution prevention are enthusiastically endorsed by government, industry, the profession, and the public. The concepts are promoted and encouraged at all levels of government through educational and technology transfer and assistance programs, and there is little current regulatory interest in implementing mandatory waste reduction requirements. Industry, of course, opposes such mandatory requirements. Nevertheless, there already exists some congressional interest in mandatory waste reduction programs, and this interest is encouraged by some public interest groups. Industry can discourage the imposition of such mandatory requirements
by implementing effective voluntary waste reduction programs and by documenting and publically demonstrating the effectiveness of these eiforts. Our analysis of current initiatives and opportunities for waste reduction suggests that a number of patterns or trends will emerge. In the near term, industry will continue to emphasize waste m i n i m tion via volume reduction to the extent that it is technically feasible and eccnomidly attractwe. Although this initiative reduces volume and thus current costs, it does not reduce the actual mass of toxic wastes produced and accomplishes very little to control future liability. Toxicenussions reporting under SARA Title III Section 313 will ensure that industry achievements are not limited solely to volume reduction rather than toxics release reductions. Industry will continne to strongly favor chemical, thermal, or other detoxification technologies for organic toxicants. These technologies incorporate volume reduction and limitations on !iture liabilitv associated with diswsal of the detoxification technology residues. Waste reduction for inorganics must proceed via source avoidance or recycle and recovery svategies. Source avoidance will be actively pursued, including innovations in rawmaterial substitutions, raw-material prepurification. operatingequipment modification, wd the development of new, clean manufacturing technologies. However, we must recognize and accept that such activities are onen quite site-specific and impinge directly on manufacturing activities that are proprietary or are perceived by an industry to be confidential. Pragmatically, we do not anticipate that a useful data base detailing source avoidance opportunities will become generally available. Source avoidance initiatives are described by industry todaj in only the broadest terms, and we cannot anticipate that corporate self-interest will allow such accomplishments to ever be publicized in other than Conceptual terms. One bright spot in this rather pessimistic outlook is that government programs that subsidize or otherwise underwrite such source avoidance initiatives can and should be tailored to require public disclosure in order to promote technology transfer. Examples of such programs at the state level are those in North Carolina and Oregon. In my opinion, the trends with the widest implications for multimedia waste reduction involve source capture and return, and purification of spent materials for recycle and reuse. Feasibility studies have revealed OpporNniEnviron. Sci. Technol.. MI.23.NO. 9.1989 1037
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ties in these areas that cut across many categories of industry and types of manufacturing processes (31-34). In other words, there is a market opportunity available, which I believe the free market will exploit. Such exploitation has already occurred with distillation equipment, in the recovery for reuse of spent solvents. There are unquestioned additional opportunities for existing available technologies and hardware in innovative applications. Furthermore, there are major R&D programs underway to develop new or enhanced selective technologies and the hardware to implement such technologies (32. 34). The new challenge f o r industry in pollution management, particularly for toxics, is pollution avoidance. The impetus to not pollute derives from federal, state, and local environmental regulations as well as the desire to avoid future liability associated with current waste management practices. Mechanisms and strategies for industrialwaste avoidance require innovative a p proaches, most likely implemented within the industrial manufacturing process. Tfaditional end-of-pipe industrial pollution control has only limited relevance in implementing such strategies.
Acknowledgment Preparation of this paper was supported in part through the Industrial Waste Elimination Research Center. a national research center operated by Illinois Institute of Technology and sponsored in part by the US. Environmental Protection Agency O f f e e of Exploratory Research.
References ( I ) National Rcsesrch Council; Mvlrimcdia Approaches IO Pollvrion Control. A Symposium Plmeedings; National Academy Press: Washington. DC. 1987. (2) Bowman. J. A. Chcm. En8. P ~ o K 1989, . 85(6).48. (3) Steyer. R. "Making Sense of Emissions Disclosure Law": SI. Louis-Port-Dirpatch: July 10. 1989. El. E9. (4) Stevenson. E. e l al. "The New Jersey Industrial Survey Project N.J.A.C. 7:IF 1979-1982 Final Report"; Ollice of Science and Research: New Jersey Department of Environmental Protection: Trenton. NJ. 1986. ( 5 ) 1. Air Pollut. Comrol Assoc. 1988,989. (6) Worrc Minirnizorion: Environmmtal Qu&y with Economic B m c f t : U.S. Environmental Protection Agency. Ollicc ol Solid Waste and Emergency Response. U.S. Government Printing Ollice: Washington. DC. 1987: EPA1530-SW-87-026. (7) Patterson. J. W. J. Wc~rrrPollut. Cmrrol Fed. 1989,61. 184. Freeman. H. M. 3. Air Pollur. Comrol Assor. 1988.5942. Wolf. K . J. Air Pollur. Control Arsoc. 1988, 681-86. Grundahl. N. Hazordous Wru Minimization Echnicol Assislome: U.S. Environmental Protection Agency. Region 111. U.S. Government Printing Oflice: Philadelphia. PA. 1988. Future Rirk: R?.seorch Stratcgirs for the 19Y0.5: U.S. Environmental Protection
Agency Science Advisory Board. U S . Government Printine Ollice: WashingI&. DC. 1988: SAB-%,EC-88-040. (12) Hollod. G. J.: McCartney. R. E J. Air Pollur. Conrrol Aswr. 1988, 174-79. (13) Foecke. T. L. J. Air Polfur. Control Asso
