19,375 pounds. "Efficiency" is the ratio of the releases (13,125 pounds) to the throughput (19,375 pounds), or 68 percent.

PURCHASE CARBON ADSORPTION DEVICE

If the firm purchases a carbon absorption unit instead of a new degreaser, the atmospheric emissions can be reduced by 80 percent, from 18,750 pounds to 3,750 pounds. In this case, releases are the remaining atmospheric emissions (3,750 pounds). Assuming the adsorbed METE is desorbed and reused,. then throughput is the sum of the releases (3,750 pounds), the amount sent off-site for recycling (7,000 pounds) and the amount reused on-site (15,000 pounds) or 25,000 pounds. "Efficiency" is therefore 15 percent.

Note here that carbon adsorption is extremely expensive and most plants would be unable to purchase it. It also takes significant expertise to operate. Furthermore, it is not dear that this method-which, in fact, is a treatment technology-would be allowed under the regulation.

SUMMARY OF SOURCE REDUCTION OPTIONS

It is doubtful that plants could reduce their atmospheric losses further than with the carbon adsorption device. The more cost-effective option would be to convert to another solvent not on the Section 313 list or to an aqueous cleaning system. As discussed in the text, this conversion may pose problems but simply in a different way from METH.

This example raises another point as well After the carbon adsorption device has been purchased, virgin purchases for the firm amount to 10,000 pounds annually. This includes the waste loss (6,250 pounds) and the atmospheric loss (3,750 pounds). Although the plant actually uses 25,000 pounds of solvent, the 15,000 pounds of solvent captured by the carbon adsorption device is reused in the cleaning process and substitutes for virgin solvent. Section 313 of SARA requires chemical users of 10,000 pounds annually to report. If the light fixture manufacturer lowered "use" one pound further, the plant would escape the reporting regime altogether and would no longer have to report. Because the regulation requiring "efficiency" of 5 percent in ten years is patterned on Section 313, this plant would escape the requirement after achieving an "efficiency" of 15 percent-not 5 percent. This is an anomaly of the regulation.

REFERENCES

Federal Register, "Toxic Chemical Release Reporting: Community Right-to-Know; Final Rule," 40 CFR Part 372, February 16, 1988, p. 4500.


H.R. 1457, March 15, 1989.


RCRA Reauthorization Bill, September 9, 1988.


Smith, Ned Clarence, "The Use of Mass Balance Data in the Natural Resources Defense Council's Proposed Model Waste Reduction Program," March 1988.


Wolf, Katy, "Source Reduction and the Waste Minimization Hierarchy," Journal of the Air Pollution Control Association, Vol 38, #5, p. 681, May, 1988.



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