EPA/600/A-86/051 U.S. RESEARCH TO CONDUCT LIFE-CYCLE STUDY TO EVALUATE ALTERNATIVE STRATEGIES FOR INTEGRATED WASTE MANAGEMENT Susan A. Thomeloe U.S. Environmental Protection Agency Air Pollution Prevention and Control Division Research Triangle Park, North Carolina 27711 Simon Friedrich U. S. Department of Energy Office Of Industrial Technologies Washington, D.C. 20585 Morton A. Barlaz and Ranji Ranjithaa North Carolina State University Raleigh, North Carolina 27695-7908 Keith A. Weitz, Emery J. Kong, and Subba Nishtala Research Triangle Institute Research Triangle Park, North Carolina 27709 Carlton Wiles and Philip B. Shepherd National Renewable Energy Laboratory Golden, Colorado 80401 Robert K. Ham University of Wisconsin Madison, Wisconsin 53706 ABSTRACT Conflicting or incomplete information exists regarding the benefits and effects of the management of source reduction, recycling, composting, landfilling, and combustion of municipal solid waste (MSW). Management professionals are often forced to mate decisions about waste management strategies without being able to look at the strategies in the context of the entire MSW system and factor in site-specific information regarding available markets, transportation, and environmental and energy impacts. Concern has been raised that strategies are being adopted that may not be environmentally or economically preferable when site-specific and regional considerations are included in the evaluation. Additionally, the implications of various waste management options on the potential releases to the environment at life-cycle stages have not been addressed. The United States Environmental Protection Agency (EPA) and the Department of Energy (DOE) are co-sponsoring a cooperative agreement with the Research Triangle Institute to use life^cyele assessment (LCA) principles to evaluate me upstream and downstream environmental impacts to evaluate alternative MSW management options. This research will provide the MSW decision-maker with more complete information on the environmental and economic impacts of MSW management alternatives. Data will be collected to develop a life-cycle inventory (LCI) for environmental and cost impacts associated with raw materials acquisition, manufacturing, use, and waste management. The LCI includes conducting material and energy balance calculations for multi-pollutants and media for the evaluation of different MSW management options. A working group of EPA and 5/9/95 9:31AM 1 ------- DOE experts has been formed to provide project direction and to help resolve technical issues associated with conducting the LCA. In addition, an external advisory group has been formed and includes representatives from both the public and private sectors including state and local governments, solid waste management firms, academia, trade associations, industry, environmental advocacy groups, and research institutes. A major goal of this research will be the development of a LCI. To accomplish this goal, the following research activities have been initiated: the (1) collection, review, and summary of data building on recent DOE and EPA research; (2) identification of major data gaps; (3) collection of field data; and (4) implementation of the LCA methodology. To facilitate the use of the data to apply to site- specific analyses, a decision support tool for use by solid waste management decision makers is to be developed. To help illustrate the objectives for this research, a LCI for three components of the MSW stream [i.e., old corrugated containers (OCC), old newsprint (ONP), and aluminum cans] is scheduled for completion by September 1995. This paper provides an overview of this research and the schedule for outputs, and discusses the potential applications. Introduction Efficient solid waste management plans are needed by virtually every community in the U.S. Communities are struggling to develop better strategies for integrated waste management to meet federal, state, and local goals regarding MSW management. Recent regulations for landfilling and combustion of waste have resulted in increased protection of human health and the environment. However, waste management costs have increased, and there is increased interest in more efficient management of waste. Integrated waste management may include source reduction, recycling, combustion, composting, and landfilling. Adoption of one approach or a combination of approaches may have impacts beyond the local community where these choices are being implemented. This research is to help provide data and a methodology for applying life-cycle principles for evaluating integrated waste management strategies. In addition, a decision support tool is to be developed that will enable the user to apply the data and information to specific strategies and variations that are often region specific. In addition to the research that is described by this paper, other countries are recognizing the need to evaluate waste management in a more holistic approach and are conducting life-cycle studies of waste management. These countries include the Canada, France, Germany, the Netherlands, Sweden and the United Kingdom. The EPA's Air Pollution Prevention and Control Division (the former Air and Energy Engineering Research Laboratory), with DOE cofunding, has entered into a 3-year cooperative agreement with the Research Triangle Institute (RTI). The EPA and DOE are collaborating with RTI to develop the technical information and the LCI, and applying LCA principles to compare MSW management options. RTI has several members on their research team including MSW experts at Franklin Associates, Ltd., Midwest Research Institute, North Carolina State University (NCSU), and University of Wisconsin (UW). In addition, representatives from DOE's National Renewable Energy Laboratory (NREL) are active participants in the internal advisory group. Other participants in the internal advisory group include representatives from EPA's Office of Air Quality Planning and Standards, Office of Health and Environmental Assessment, Office of Healfli Research, Office of Policy, Planning and Evaluation, Office of Prevention, Pesticides and Toxic Substances, Office of Research and Development, Office of Science, Planning and Regulatory Evaluation, and Office of Solid Waste. The external advisory group, to whom we refer as the stakeholders, includes representatives from both the public and private sectors including state and local governments, solid waste management firms, academia, trade associations, industry, environmental advocacy groups, and research institutes. RTI completed the research plan which has been approved and emphasizes year 1 activities. The emphasis of the first 2 years will be on data collection, review, and the development of the LCI. 5/9/95 9:31 AM ------- Research Objectives / Given the numerous components of MSW, the number of potential combinations of management alternatives, and the interrelationships among them, development of an effective MSW management plan for a given unit of government is complex. The objective of this research is to use life-cycle concepts and techniques to evaluate alternatives for MSW management. The major output from this research will be a LCI database which includes data on emissions, resource and energy consumption, representative costs of all unit operations involved in MSW management, and data on "upstream" life-cycle stages including raw materials acquisition, manufacturing (or remanufacturing), and consumer use/reuse/maintenance (Vigon et al., 1993 describes these stages). This database of LCI information can be used by other models or in other studies. The other major output from this research is the application of LCA principles for evaluating different integrated waste management strategies and the development of a MSW management decision support tool that will help users (i.e., municipal managers and other decision-makers) identify options that minimize resource and energy consumption, adverse environmental effects, and costs. This is the mathematical representation of the different unit operations (i.e., landfill, waste-to-energy facility, compost facility, recycling facility) and includes material and energy balance calculations. The final decision support tool will allow users to apply the data on a site-specific basis to compare MSW management strategies regarding energy and resource consumption, environmental releases, and costs. Figure 1 identifies the major research components and schedule for completion. To help illustrate the objectives for this research, a LCI for three components of the MSW stream [i.e., old corrugated containers (OCC), old newsprint (ONP), and aluminum cans] is scheduled for completion by September 1995. EPA will solicit feedback from the internal and external advisory groups on the technical approach and data sources. Comments that RTI receives from the EPA Project Officer will be used to refine the methodology for application to all MSW components. Defining the MSW System and Analysis Approach The system boundaries of the solid waste management system have been specified in terms of: • waste composition and generation rates, * unit operations involved in solid waste management (collection, separation, composting, combustion, refuse derived fuel (RDF), and landfill), • remanufacturing of products from recycled waste components, and • interrelationships between these unit operations. Figure 2 illustrates the major unit operations of the system. The system definition is being developed with the objective of being as flexible as possible. More detailed flow diagrams have been developed as part of a system definition document RTI has proposed that the components of MSW to be included in the LCI be consistent with EPA's characterization of MSW (Characterization of Municipal Solid Waste in the United States, EPA, 1994a). This definition includes waste generated in the residential, commercial, institutional, and industrial sectors but excludes industrial process waste, sludge, construction and demolition waste, pathological waste, agricultural waste, mining waste, and hazardous 5/9/95 9:31AM 3 ------- waste. Ash generated from the combustion of MSW will be included in the system. The MSW to be included in this system is divided into three categories: residential waste, waste generated in multifamily dwellings, and commercial waste. In analyzing a specific solid waste management system, it will be possible to consider a different composition for each type of waste. Lists of the components included within each category have been developed and documented in the system description that was developed for this research. The system will also allow for the recovery of combinations of components such as the recovery of mixed paper for use as either pulp or fuel. Task Name Kick-off Mtg LCI -Data fVhl fart inn & Review LCI - System Lietn LCI- Mathematical Represen- tation Interim Results forOCC,ONP, and aluminum cans LCI- ID Data Gaps Decision Support Tool Development Coordination - Internal & External Final LCI & LCA Results 1994 <^ 0 A ^— -•=''"" X> ...... ii.. < 1995 > ...'"...." ..:»5^ y\ '" " *? 1996 1997 1998 in j^ Figure 1. Timeline for LCA/MSW Research The major unit operations to be included as part of the MSW management system include: collection and transfer, separation (in material recovery facilities and drop-off centers), treatment (composting, combustion, and RDF), burial or land disposal, and remanufacturing (to the extent that a specific component of the waste stream is recycled). , Data on the cost, energy and resource consumption, and environmental releases corresponding to individual processes within each unit operation will be collected as part of this research. A list of LCI parameters has been developed and documented in a system description document that was developed for this research. 5/9/959:31 AM ------- Several refuse collection options are defined for each waste generation sector. In the residential sector, options include the collection of mixed refuse, the collection of recyclables as Raw Materials Acquisition — — Loop . i Manufacturing I Use/Reuse/Maintenanee (waste generation) Process Generated MSW i Waste Management Notes: —Transportation is embedded within each of the life-cycle stages. —Source reduction is embedded within each of the life-cycle stages and affects the flow of materials within and between stages. —Combustion Includes incineration and waste-to-energy. Figure 2. Life Cycle for Integrated Waste Management either commingled recyclables or recyclables sorted by the collection crew or waste generator, and co-collection of refuse and recyclables in the same vehicle. Collection alternatives for refuse generated in multifamily dwellings include the collection of mixed refuse and collection of either commingled or presorted recyclables. Collection options for the commercial sector include collection of both mixed refuse and presorted recyclables. Drop-off of recyclables at centralized facilities is also considered. Transfer stations serve as a central facility at which the waste is collected before shipping to a separation, treatment, or disposal facility. Several types of transfer stations will be included 5/9/95 9:31 AM ------- in the system to receive waste from any of the predefined refuse and recyclable collection alternatives. In addition, the potential to consolidate refuse for rail transport is included. In MSW management strategies where materials are recycled, recyclables will require processing in a materials recovery facility (MRF). The design of a MKF is dependent upon the manner is which refuse is collected and subsequently delivered to the MRF. Thus, the collection and recycling of MSW are interrelated and this interrelationship is captured in the system. Five MRFs, each capable of recovering a set of recyclables from the applicable collection alternative, are to be considered in this system. The recyclable material recovered from a MRF will ultimately be delivered to a remanufacturing process. The energy and resource consumption, and environmental releases corresponding to manufacturing of a product from recyclable material (remanufacturing) will be considered in the system. To compare a remanufacturing process with manufacturing the same product from virgin material, the energy and resource consumption, and releases which apply to a virgin manufacturing process will also be considered. Waste treatment options targeted for consideration include: combustion with energy recovery and conversion to electricity, composting of either mixed waste or yard waste, and anaerobic digestion. The combustion process will be assumed to have air pollution control devices which meet current regulations. In addition, two types of RDF facilities will be considered." one will separate the refuse stream to recover a relatively high heat value fraction for use as a fuel, and the other is co-combustion, in which particular components of MSW are recovered for combustion in industrial boilers such as utility boilers and hog fuel boilers in the paper industry. Two types of landfills will be considered in the system: one for the receipt of mixed refuse and the other for the receipt of combustion ash. All facilities will be designed in accordance with applicable state and federal regulations with respect to requirements such as liner design, leachate, and gas collection and control. Variations of these requirements, such as the type of liner design, are to be included in the evaluation. Source reduction is also to be considered in the system and will be analyzed in a more qualitative manner. Source reduction represents a reduction in mass or toxicity of the waste stream. The effects of source reduction are unique to very specific components of the waste stream. A framework for analysis of source reduction is included in the system. Various municipalities have recently implemented source reduction programs and have monitored their impact on MSW composition and management (see Waste Prevention, Recycling, and Composting Options' Lessons from 30 Communities, EPA, 1994b). The EPA Project Officer and the research team will consult with the internal and external advisory groups to gather existing source reduction studies that evaluate the impact of various source reduction activities on MSW management to the extent that readily available information is determined to be reliable. Developing a Life-Cycle Inventory EPA's recently published Life-Cycle Assessment: Inventory Guidelines and Principles (Vigon et al., 1993) defines a life cycle to include the stages of raw materials acquisition, manufacturing, use/reuse/maintenance, and waste management. Evaluating MSW management from a life-cycle perspective can provide decision-makers with a more complete picture of MSW management and can facilitate some management decisions (e.g., low-cost waste diversion programs for major components of the waste stream). Making more efficient decisions regarding integrated waste management requires a more detailed level of analysis; for example, comparing 5/9/95 9:31AM 6 ------- energy consumption, costs (capital, operational, long term care), and environmental releases of using recovered and virgin materials when making decisions on the scope of the recycling programs. / The major effort with developing an LCI is collecting data for conducting material and energy balance calculations. Data collection will be the major focus of the first 2 years with the focus of developing a LCI. Data in the LCI will be used in material and energy balance calculations to develop emission factors for each unit operation involved in solid waste management. In Year 1, available data will be collected, cataloged, and assessed to verify their use to the project. Several recently completed studies are being reviewed for available data and information including: * The Role of Recycling in Integrated Solid Waste Management to the Year 2000 (Keep America Beautiful, 1994), • Energy Implications of Integrated Solid Waste Management Systems (NYSERDA, 1994), » Mandated Recycling Rates: Impacts of Energy Consumption and MSW Volume (ANL, 1993), * Council of State Governments/Tellus Packaging Study (Tellus, 1992), and • Data Summary of Municipal Solid Waste Management Alternatives (SKL, 1992). Several other studies are nearing completion including research by Argonne National Laboratory, California Integrated Waste Management Board, DOE, EPA, Franklin Associates, Ltd., the New York State Energy Research and Development Authority, NREL, Solid Waste Association of North America, and Tellus Institute. In addition to publicly available data, the data that may be available in the private sector are also being identified. Several data gaps have been identified, and a plan will be developed to fill these gaps. Collection of field data is to begin late in year 1 and continue throughout year 2. RTI will develop a list of data gaps and prioritize them based on the sensitivity analysis. In addition to publicly available data, private sector data are to be collected, particularly where industries have conducted studies on enviromental releases and have documentation of major assumptions and material and energy balance calculations. The EPA Project Officer is contacting industry representatives to identify potential data sources for providing to the research team for evaluation. Companies and individuals who have data to contribute are urged to contact the Project Officer at the address provided at the end of this article to discuss arrangements for providing information. Data are required on energy consumption as well as gaseous, liquid, and solid emissions associated with all aspects of MSW collection, recycling, conversion to energy, composting, remanufacturing to new materials, and disposal. In addition, data are needed on the inputs to each of the unit operations involved in solid waste management. This could include the consumption of water or other raw materials. Finally, data on the economics of each unit operation are also being solicited. The data identification and collection effort is expected to produce a large variety of information (e.g., urban and rural, aggregate, and individual facility). As the available data are collected by the EPA Project Officer and provided to RTI, the research team will review them for their usefulness in developing emission factors and input for developing the LCI. Obtaining accurate and relevant data is important not only with regard to residuals emitted during MSW management, but also with regard to the material, both amount and composition, that flows through the various stages of the MSW management system. By the same token, price and cost data for all the unit operations usually vary tremendously with scale and often significantly with MSW composition. RTI will strive to collect accurate and relevant environmental and economic data for characterizing the different waste management activities. 5/9/959:31 AM ------- All data obtained for this project will be reviewed and evaluated by RTI to determine their applicability to the research and their quality. This review may include consultation with the internal and external advisory groups and the assignment of other reviewers outside the project team. As part of the data review process, RTI will assess the quality of major data sources using EPA's Guidelines for Assessing the Quality of Life-Cycle Inventory Data (EPA, 1994c). These guidelines provide a qualitative framework for RTI's assessing and reporting data quality based on the consistent application of data quality guidelines, data quality indicators, and data quality worksheets, Applying Life-Cycle Principles and Developing a Decision Support Tool The application of life-cycle principles is an evolving tool, and the EPA Project Officer is seeking input from the Society of Environmental Toxicology and Chemistry (SETAC), a leading organization in the development of LCA methodology and applications, on the research team's proposed approach. In addition, all interim output will be reviewed by both the internal and external advisory groups. Input will also be obtained from the external advisory group on how to tailor the outputs so that they will be of maximum benefit to waste management decision-makers in both rural and urban areas. It is clear from the feedback received to date from state and local government officials, that to develop data without a tool for applying it to specific situations will not be useful. Therefore, plans include RTFs developing a decision support tool that will meet the needs of potential users. However, the database that is being developed for the LCI will be able to be used as input to any other available model or life-cycle study. The ultimate product of the research will be the database of the LCI and a user-friendly decision support tool designed to assist state and local solid waste management personnel to evaluate the economics, energy and resource consumption, and environmental releases associated with alternate integrated solid waste management strategies. Together, the decision support tool (or expert system) and LCI database will allow the user to analyze a particular soHd waste management system and evaluate more efficient potential alternatives. However, the LCI database is being constructed so that it will be easily importable to other models or studies. Review by the Internal and External Advisory Groups The internal advisory group includes representatives from EPA's Office of Air Quality Planning and Standards, Office of Health and Environmental Assessment, Office of Health Research, Office of Policy, Planning and Evaluation, Office of Prevention, Pesticides and Toxic Substances, Office of Research and Development, Office of Science, Planning and Regulatory Evaluation, and Office of Solid Waste. As stated earlier, DOE is also an active participant in this research, and representatives from DOE and DOE's National Renewable Energy Laboratory are active participants in the internal advisory group. The EPA Project Officer has requested review comments on research outputs from the internal advisory group and external advisory group (i.e., stakeholders). Typically RTI revises outputs after receiving comments through the EPA Project Officer from the internal advisory group before the outputs are reviewed by the stakeholders. Internal advisory group meetings are held monthly via teleconference, and more often if needed. The purpose of these meetings has been to provide input to the development of the research plan, development of research outputs, and discussions regarding technical issues and concerns. The role of stakeholders is to review the research plan, system definition, and completed and on-going research; exchange ideas for future research approaches; and provide assistance in obtaining data. The National Association of Counties and the Conference of Mayors are active participants in this group in addition to industry, trade associations, and environmental advocacy groups. The stakeholders also provide input on how we can tailor outputs to best meet their needs. Two workshops a year (one every 6 months) are planned to provide a forum for direct 5/9/95 9:31AM 8 ------- input by the stakeholders. The internal advisory group is also invited to participate in these workshops. The first workshop was held on April 11,1995, in the Research Triangle Park, North Carolina, The purpose of this workshop was to provide an overview of the research goals, approach, schedule, and proposed system definition. In addition an overview of data collection efforts to date was provided. This workshop provided an opportunity to solicit input from the participants, discuss application of life-cycle concepts to MSW management, and identify sources of available data. In addition, feedback was obtained on how to structure the decision support tool so that it best meets the needs of potential users. A number of issues were identified including how to compare data for unit operations (such as MRFs, landfills, combustion facilities, compost facilities) where very different levels of reliable data are available, which may vary both spatially and temporally. Also there was concern about the level of information provided in the LCI and presented through the decision support tool (i.e., how will environmental data be presented?). In addition, concern was raised that the decision support tool needs to provide assistance to both urban and rural areas. Often issues from rural areas are not considered and are different from those from urban areas. There was also the concern by the external advisory group due to the limited resources available for field test measurements and field data collection in year 2. However, there appeared a strong consensus that this research is needed and will provide valuable input to waste management decision-makers and to other studies. To Receive and/or Contribute Information Quarterly project update newsletters will be prepared and distributed to an MSW project mailing list. To be placed on this mailing list, or if your organization would like to contribute data or potential models, please contact Susan Thorneloe, EPA Project Officer, Office of Research and Development, Air Pollution Prevention and Control Division, MD-63, Research Triangle Park, NC 27711, Phone: (919) 541-2709, Fax: (919) 541-2382. REFERENCES Argonne National Laboratory. 1993. Mandated Recycling Rates: Impacts on Energy Consumption and Municipal Solid Waste Volume. Work conducted for DOE's Office of Policy. ANL/ESD-25. December. Keep America Beautiful 1994. The Role of Recycling in Integrated Solid Waste Management " to the Year 2000. Prepared by Franklin Associates, Ltd. New York State Energy Research and Development Authority. 1994. Energy Implications of Integrated Solid Waste Management Systems. Prepared by Tellus Institute. SRI International. 1992. Data Summary of Municipal Solid Waste Management Alternatives. Prepared for DOE's National Renewable Energy Laboratory. Tellus Institute. 1992. CSG/Tellus Packaging Study. Prepared for The Council of State Governments, the U.S. EPA, and the New Jersey Department of Environmental Protection and Energy, May. U.S. Environmental Protection Agency. 1994a. Characterization of Municipal Solid Waste in the Untied States:!994 Update. EPA-530/R-94/042 (NTIS PB95-147690). Office of Solid Waste and Emergency Response, Washington, DC, November, 5/9/95 9:31AM 9 ------- U.S. Environmental Protection Agency. 1994b, Waste Prevention, Recycling, and Composting Options: Lessons from 30 Communities. EPA/530/R-92/015. Office of Solid Waste and Emergency Response, Washington, DC, February. ' U.S. Environmental Protection Agency. 1994c. Guidelines for Assessing the Quality of Life- Cycle Inventory Data. Final report. Office of Solid Waste, Washington, DC. Prepared by Research Triangle Institute. Vigon, B.W, et al. 1993. Life-Cycle Assessment: Inventory Guidelines and Principles. EPA/600/R-92/245 (NTIS PB93-139681). Risk Reduction Engineering Laboratory,, Cincinnati, OH. Prepared by Battelle-Columbus Laboratories and Franklin Associates, Ltd., January. 5/9/95 9:31AM 10 ------- AEERL-P-1291 TECHNICAL REPORT DATA (Please read Instructions on the reverse before completing) 1. REPORT NO. EPA/600/A-96/051 3. RECIf 4. TITLE AND SUBTITLE 5, REPORT DATE U.S. Research to Conduct Life-cycle Study to Evaluate Alternative Strategies for Integrated Waste Manage- ment B, PERFORMING ORGANIZATION CODE 7. AUTHOR*^ Thorneloe (EPA);S. Friedrich (DOE);M.Bar- laz, R. Ranjithan (NCSu)jK. Weitz, E. Kong, S. Nishtala (RTI);C. Wiles. P. Shepherd(NREL);R. Ham (UW) B. PERFORMING ORGANIZATION REPORT NO, 9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO. Research Triangle Institute P. O. Box 12194 Research Triangle Park, North Carolina 27709 11, CONTRACT/GRANT NO. CR 823052 (RTI) 12. SPONSORING AGENCY NAME ANO ADDRESS EPA, Office of Research and Development Air and Energy Engineering Research Laboratory Research Triangle Park, NC 27711 13. TYPE OF REPORT ANO PERIOD COVERED Published paper; 9/Q4-4/QS 14. SPONSORING AGENCY CODE EPA/600/13 is. SUPPLEMENTARY NOTES AEERL grOject officer is Susan A, Thorneloe, Mail Drop 63, 919/ 541-2709. Presented at 5th International Landfill Symposium, Cagliari, Italy, 10 /^~° is. ABSTRACT-j-jjg paper discusses usingllle-cycle assessment principles to evaluate up- stream and downstream environmental impacts to evaluate alternative municipal so- lid waste (MSW) management options. This research will provide the MSW decision- maker with more complete information on the environmental and economic impacts of MSW management alternatives. Data will be collected to develop a life-cycle inven tory (LCI) for environmental and cost impacts associated with raw materials acqui- sition, manufacturing, use, and waste management. The LCI includes conducting material and energy balance calculations for multi- pollutants and media for the eval- uation of different MSW management options. A major goal of this research will be the development of a LCI. To accomplish this goal, the following research activities have been initiated: the (1) collection, review, and summary of data, building on re- cent DOE and EPA research; (2) identification of major data gaps; (3) collection of field data; and (4) implementation of life-cycle assessment methodology. To facili- tate use of the data to apply to site specific analyses, a decision support tool is being developed for use by solid waste management decision-makers. The paper provides an overview of this research and the schedule for outputs, and discusses potential applications. 7. KEY WORDS ANO DOCUMENT ANALYSIS DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS c. COSATI Field/Group Pollution Wastes Waste Disposal Management Evaluation Circulation Composts Earth Fills Combustion Marketing Transportation Energy Pollution Control Stationary Sources Waste Management Recycling 13B 14G 15E 05A 02A 13 C 21B 05C 05E 18, DISTRIBUTION STATEMENT Release to Public 19. SECURITY CLASS (This Report) Unclassified 21. NO. OF PAGES 20. SECURITY CLASS fTMspage) Unclassified 22. PRICE EPA Form 2220-1 (9-731 ------- |