Pollution Prevention: Status of DOD's Efforts (Letter Report, 11/09/94,
GAO/NSIAD-95-13).

This report provides information on the status of the Defense
Department's (DOD) pollution prevention efforts.  GAO discusses (1) the
extent to which DOD has collected and reported information on its
inventories and releases of toxic chemicals; (2) what progress DOD has
made in reducing the use of toxic chemicals; (3) the challenges DOD
faces in reducing the use of toxic chemicals, including the progress
that DOD has made in reviewing and revising military specifications; and
(4) the extent to which DOD has incorporated pollution prevention goals
in its procurement and inventory processes.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  NSIAD-95-13
     TITLE:  Pollution Prevention: Status of DOD's Efforts
      DATE:  11/09/94
   SUBJECT:  Toxic substances
             Waste disposal
             Military inventories
             Waste management
             Hazardous substances
             Inventory control systems
             Pollution control
             Environmental law
             Data collection operations
             Reporting requirements

             
**************************************************************************
* This file contains an ASCII representation of the text of a GAO        *
* report.  Delineations within the text indicating chapter titles,       *
* headings, and bullets are preserved.  Major divisions and subdivisions *
* of the text, such as Chapters, Sections, and Appendixes, are           *
* identified by double and single lines.  The numbers on the right end   *
* of these lines indicate the position of each of the subsections in the *
* document outline.  These numbers do NOT correspond with the page       *
* numbers of the printed product.                                        *
*                                                                        *
* No attempt has been made to display graphic images, although figure    *
* captions are reproduced. Tables are included, but may not resemble     *
* those in the printed version.                                          *
*                                                                        *
* A printed copy of this report may be obtained from the GAO Document    *
* Distribution Facility by calling (202) 512-6000, by faxing your        *
* request to (301) 258-4066, or by writing to P.O. Box 6015,             *
* Gaithersburg, MD 20884-6015. We are unable to accept electronic orders *
* for printed documents at this time.                                    *
**************************************************************************


Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Environment, Energy and
Natural Resources, Committee on Government Operations, House of
Representatives

November 1994

POLLUTION PREVENTION - STATUS OF
DOD'S EFFORTS

GAO/NSIAD-95-13

Pollution Prevention


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense
  EPA - Environmental Protection Agency
  DECIM - Defense Environmental Corporate Information Management

Letter
=============================================================== LETTER


B-258433

November 9, 1994

The Honorable Mike Synar
Chairman, Subcommittee on Environment, Energy
and Natural Resources
Committee on Government Operations
House of Representatives

Dear Mr.  Chairman: 

You requested that we provide information on the status of the
Department of Defense's (DOD) pollution prevention efforts. 
Specifically, you asked us to determine

the extent to which DOD has collected and reported information on its
inventories and releases of toxic chemicals;

what progress DOD has made in reducing the use of toxic chemicals;

the challenges DOD faces in achieving reductions in the use of toxic
chemicals, including the progress DOD has made in reviewing and
revising military specifications; and

the extent to which DOD has incorporated pollution prevention goals
in its procurement and inventory processes. 

On October 5, 1994, we briefed your staff on observations emerging
from our work.  This report presents the information that we provided
during the briefing. 


   BACKGROUND
------------------------------------------------------------ Letter :1

Pollution is caused by the release of wastes into the environment. 
Hazardous wastes result from the use of toxic materials found in a
variety of products, such as chemicals used in thinning paint, while
nonhazardous wastes, such as scrap paper, do not contain toxic
materials.  A glossary of terms is at the end of this report. 

In August 1993, the President signed Executive Order 12856, which
specifically requires federal agencies to take actions to reduce
pollution, including implementing the Pollution Prevention Act of
1990 and the Emergency Planning and Community Right-to-Know Act of
1986.  The Pollution Prevention Act of 1990 established a national
policy for reducing pollution at its source as the method of choice
in preventing pollution.  Other methods include recycling waste
materials, treating wastes, and disposing of wastes.  The Emergency
Planning and Community Right-to-Know Act of 1986 establishes a
requirement to, among other things, inventory toxic chemicals and to
measure and report certain releases of hazardous wastes into the
environment from certain public and private facilities.  This act had
initially excluded most government facilities. 

Executive Order 12856 specifically requires federal agencies to place
a high priority on funding to reduce pollution by identifying and
eliminating or reducing requirements for toxic chemicals in military
specifications and by incorporating pollution prevention objectives
into purchasing decisions.  Agencies are also required to monitor
compliance with the order and submit annual reports to the
Environmental Protection Agency (EPA) beginning on October 1, 1995. 
EPA is responsible for convening a high-level interagency task force
to assist agencies in implementing the order, providing technical
advice to agencies when requested, and providing guidance and
monitoring agency compliance with certain aspects of the order
related to reporting and emergency planning. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

DOD is in the process of gathering information on toxic chemical
inventories and releases and anticipates it will have this
information by July 1, 1995, the reporting date required by Executive
Order 12856.  To help DOD collect this information, a DOD-wide system
is being developed but it may not be ready in time to meet the
reporting requirement.  EPA has provided draft guidance to federal
agencies on collecting and reporting information on toxic chemicals. 
DOD and EPA are negotiating several of the proposed provisions in
EPA's draft guidance to reduce implementation costs.  EPA could not
be certain when final guidance would be issued.  (See app.  I.)

The extent that DOD has reduced the use of toxic chemicals cannot be
measured because that information is not now available.  DOD's past
efforts have focused on treating and controlling pollution generated
from processes rather than eliminating the use of toxic chemicals. 
DOD has reported progress in reducing the amount of hazardous waste
disposal and the use of toxic chemicals.  Much of the reported
reductions have been achieved through reducing the volume, but not
the toxicity of hazardous waste.  For example, while removing water
from hazardous waste reduces overall waste volume, it does not reduce
the amount of toxic substances in the waste.  (See app.  II.)

DOD believes that significant reductions in the use of toxic
chemicals will be difficult.  Making reductions in the use of toxic
chemicals will require more research, development, testing, and
evaluation to identify potential substitute processes and materials. 
The services believe their current estimates of about $2 billion
during fiscal years 1994 through 1999 for pollution prevention
efforts exclude potentially significant costs, such as the costs to
implement all the projects that are likely to be required to achieve
reductions, related changes in processes, and to identify and test
potential substitutes for toxic chemicals.  (See app.  III.)

As required by Executive Order 12856, DOD is reviewing military
specifications and standards that call for the use of toxic chemicals
in repairing and maintaining weapon systems and facilities.  DOD
needs to identify requirements for toxic chemicals as the first step
in revising these requirements to allow the use of proven substitute
materials and processes.  DOD will not likely meet the Executive
Order requirements to review and revise all military specifications
and related technical documents by the deadline.  This is because
each specification must be analyzed separately to determine whether
the requirements for toxic chemicals are necessary and whether a
suitable less toxic substitute is available or should be developed. 
This process also includes testing potential known substitutes,
conducting research and development to identify substitutes, the
administrative process of making the revisions, and modifying weapon
system hardware and maintenance facilities and equipment.  DOD is
emphasizing the use of commercial practices and performance-based
specifications to minimize the use of military specifications and
standards.  Such an emphasis could reduce the review and revision
effort because fewer military specifications and standards would need
to be reviewed.  (See app.  IV.)

The services have not comprehensively incorporated environmental
concerns in the design, development, and production of weapon
systems, but are beginning to take steps to do so.  DOD has not, on a
systematic basis, revised its procurement and acquisition regulations
to address environmental pollution concerns.  Also, DOD's supply
system is not designed to systematically provide visibility and
control over hazardous materials purchases, and acquisition
regulations do not provide guidance for addressing environmental
concerns in day-to-day purchasing decisions.  DOD is developing
approaches to provide better visibility and control over hazardous
materials inventories to help reduce the generation of hazardous
wastes.  (See app.  V.)


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

We collected data from DOD, the Air Force, the Army, the Navy, and
the Defense Logistics Agency to answer our objectives.  We also
discussed pollution prevention issues with representatives of 7 major
commands and 12 installations (see app.  VI) and EPA. 

We conducted our review from November 1993 to September 1994 in
accordance with generally accepted government auditing standards.  As
requested, we did not obtain written agency comments on this report. 
However, we discussed the results of our work with DOD officials and
incorporated their comments as appropriate. 


---------------------------------------------------------- Letter :3.1

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after its issue date.  At
that time, we will send copies to interested congressional committees
and Members of Congress; the Secretaries of Defense, the Army, the
Navy, and the Air Force; the Administrator, EPA; and the Director,
Office of Management and Budget.  We will also make copies available
to others on request. 

Please contact me at (202) 512-8412 if you or your staff have any
questions concerning this report.  Major contributors to this report
are listed in appendix VII. 

Sincerely yours,

Donna M.  Heivilin, Director
Defense Management and NASA Issues


INVENTORY AND USES OF TOXIC
CHEMICALS
=========================================================== Appendix I


   DOD IS IN THE EARLY STAGES OF
   GATHERING INFORMATION ON ITS
   INVENTORIES AND RELEASES OF
   TOXIC CHEMICALS
--------------------------------------------------------- Appendix I:1

The Department of Defense (DOD) anticipates that it will have
complete information on toxic chemical inventories and releases by
July 1, 1995, the reporting date required by Executive Order 12856. 
Some DOD facilities are already reporting inventories and releases of
toxic chemicals.  These facilities include government-owned,
contractor-operated facilities originally covered under the Emergency
Planning and Community Right-to-Know Act of 1986 and other
industrial-type facilities that had anticipated the requirement.  For
example, Tinker Air Force Base, Oklahoma, and Portsmouth Naval
Shipyard, Maine, reported inventories and releases for calendar year
1992. 

DOD issued initial implementing guidance on the Executive Order to
the services on February 15, 1994.  The Environmental Protection
Agency (EPA), which is responsible for implementation guidance on the
collection of this information, issued interim guidance to federal
agencies dated February 28, 1994.  As of September 1994, however, EPA
had not issued final guidance to federal agencies. 


   DOD IS DEVELOPING A SYSTEM FOR
   REPORTING TOXIC CHEMICAL
   INVENTORIES AND RELEASES, BUT
   IT MAY NOT BE READY IN TIME TO
   MEET THE REPORTING REQUIREMENT
--------------------------------------------------------- Appendix I:2

The Defense Environmental Corporate Information Management (DECIM)
office has been developing an automated hazardous materials
management system to be implemented DOD-wide.\1 The DECIM office
expects to have an interim system available early in 1995 and a final
system sometime later.  Both systems are expected to contain a wide
array of environmental information, including information on
inventories and releases of toxic chemicals, as required by Executive
Order 12856.  The systems are intended to eliminate about 53
redundant hazardous materials management information systems. 

According to DOD officials, several systems are being considered for
the standard system.  The officials told us that a decision has not
been made as to which or how many of these systems will ultimately be
deployed.  They said if a system is not deployed by late October
1994, the services will need to consider deploying their own systems
in order to meet reporting requirements of the Executive Order.  For
example, the Air Force has decided to modify the Joint Logistics
System Center's system, already installed at some DOD depots, for use
at its installations. 


--------------------
\1 The DECIM program office is staffed by defense personnel
temporarily detailed to the office.  The office is attached to the
Army Environmental Center and reports to the Deputy Under Secretary
of Defense for Environmental Security through a panel of high-level
service representatives.  DECIM received $13.5 million in funding for
fiscal year 1994.  It also has authority to request the services to
provide field staff for specific projects. 


   EPA IS CONSIDERING DOD CONCERNS
   IN ITS DRAFT GUIDANCE FOR
   IMPLEMENTING THE EXECUTIVE
   ORDER
--------------------------------------------------------- Appendix I:3

DOD and EPA are negotiating several of the proposed provisions in
EPA's draft guidance.  The discussions centered around ways to reduce
implementation costs.  For example, DOD has taken exception to
reporting emissions of toxic chemicals from mobile sources, such as
motor vehicles and aircraft, as a costly requirement that is outside
the scope of the 1986 act.  EPA has encouraged federal agencies to
report on mobile source emissions, but DOD will not be doing so. 
According to EPA officials, other agencies have indicated an interest
in conducting pilot tests for reporting emissions from mobile
sources.  EPA officials told us that they could not be certain when
final guidance would be issued. 

Also, on January 19, 1994, DOD advised EPA that expending limited
resources to develop pollution prevention plans and report releases
of toxic chemicals for installations to be closed in the near term is
unnecessary.  DOD proposed that installations closing by December 31,
1997, should not prepare plans or report releases.  DOD and EPA are
negotiating a separate agreement to resolve this issue. 


   DOD GUIDANCE FOR IMPLEMENTING
   THE EXECUTIVE ORDER DOES NOT
   ADDRESS TOXICITY
--------------------------------------------------------- Appendix I:4

According to the Executive Order, establishing priorities for
eliminating or reducing the unnecessary acquisition and use of toxic
chemicals should be developed by each federal agency in coordination
with EPA.  EPA is developing guidance to assist federal agencies in
developing prevention priorities.  According to draft EPA guidance
for implementing the Executive Order, federal agencies should
establish their own priorities for the elimination or reduction of
toxic chemicals based on factors such as toxicity of the chemicals
being used.\2 DOD's February 1994 implementing guidance does not
address toxicity.  Some service officials told us that unless
prevention priorities included toxicity in addition to quantities,
funding priorities could be misplaced.  According to these officials,
funding emphasis would likely be placed on reducing uses of reported
chemicals, whereas more highly toxic chemicals not meeting reporting
thresholds but presenting a greater risk to the environment may not
be addressed.  In September 1994, DOD officials told us that they
recently developed a proposal to conduct a study in fiscal year 1995
on tools addressing the toxicity of hazardous materials, which would
assist systems acquisition and maintenance officials in prioritizing
their efforts. 


--------------------
\2 Executive Order 12856 imposes the reporting thresholds of section
313 of the Emergency Planning and Community Right-to-Know Act, which
requires federal facilities with 10 or more full-time employees that
manufacture, import, or process 25,000 pounds or otherwise use 10,000
pounds of a listed toxic chemical to report annually (reporting is
required even if no release or transfer occurs).  DOD stated that
facilities will generally meet the use reporting threshold
requirement. 


   DOD REPORTING MEETS BASIC
   REQUIREMENTS
--------------------------------------------------------- Appendix I:5

Executive Order 12856 requires agencies to report releases of the 370
toxic chemicals and compounds subject to section 313 of the Emergency
Planning and Community Right-to-Know Act as of December 1993.  The
purpose of reporting is to ensure that federal agencies collect and
make information available to the public about the use, processing,
manufacture, disposal, and release of toxic chemicals. 

In January 1994, EPA proposed adding 313 toxic chemicals to the
required list for toxic release inventory reporting by public and
private facilities.  According to EPA, these chemicals were proposed
for addition based on their acute human health and environmental
effects.  EPA believes that the addition of these chemicals will
provide citizens with more comprehensive information to better assess
potential risks to health and the environment in their communities. 
However, the 1994 baseline reporting will not include these
chemicals.  Agencies have the option, under the Executive Order, to
report on other toxic chemicals, such as hazardous air pollutants
covered by the Clean Air Act Amendments of 1990.  As of September
1994, DOD has decided to report on the required list of toxic
chemicals. 


REDUCTIONS IN USE OF TOXIC
CHEMICALS
========================================================== Appendix II


   INFORMATION IS NOT NOW
   AVAILABLE TO MEASURE DOD'S
   PROGRESS IN REDUCING THE USE OF
   TOXIC CHEMICALS
-------------------------------------------------------- Appendix II:1

Because DOD is in the process of gathering information on its
inventories and releases of toxic chemicals, we could not precisely
measure DOD's progress in reducing its use of toxic chemicals.  Prior
laws (Resource Conservation and Recovery Act of 1976 as amended by
the Hazardous and Solid Waste Amendments of 1984) did not require
reporting of toxic chemical releases and inventories.  However, DOD
did report on its efforts to reduce the amounts of hazardous waste
disposal. 

DOD's past reporting on hazardous waste disposal does not measure how
much of the reductions in these disposals are due to reductions in
the use of toxic chemicals or other factors such as defense
downsizing.  Much of the hazardous waste generated in DOD is
industrial waste associated with the production, operation, and
maintenance of DOD weapon systems.  Defense downsizing has impacted
these activities.  For example, between 1985 and 1992, the Army
ammunition budget has declined by 40 percent, and depot labor hours
have declined by 27 percent.  Also, we recently reported significant
reductions in the Air Force's depot maintenance workload from 1987
through 1992, including an 11.3- percent reduction in the number of
aircraft with maintenance work completed, a 29.9-percent reduction in
the number of engines repaired, and a 46-percent reduction in the
number of weapon system subsystems and components repaired.\1
Although the relationship between funding or labor hours and the
amount of hazardous waste disposal may not be one-to-one, decreased
industrial activity could account for a significant portion of the
reported reductions.  The services plan to compare future releases to
measures of industrial activities, such as depot maintenance
operations, as required by EPA. 

Reported reductions in hazardous waste disposal also include
reductions in waste volume achieved through techniques, such as
dehydration of the waste.  While this process does reduce the volume
of hazardous waste that must be disposed of, it does not reduce the
amount of toxic chemicals in the waste.\2 For example, about 155,000
tons, or about 86 percent, of the Navy's reported reductions between
1988 and 1992 resulted from the dehydration of bilge wastes from
ships.  The Army and the Air Force have also used dehydration to
reduce the volume of hazardous wastes.  According to the services,
these projects have been beneficial in reducing waste volume and
disposal costs.  The services are not required and do not plan to
separately identify and report reductions due to dehydration and
other volume-reducing techniques. 


--------------------
\1 Air Logistics Center Indicators (GAO/NSIAD-93-146R, Feb.  25,
1993). 

\2 According to the Pollution Prevention Act of 1990, source
reduction does not include altering the physical, chemical, or
biological characteristics or volume of a hazardous substance,
pollutant, or contaminant through a process that is not integral to
or necessary for producing a product or providing a service. 


   SERVICES HAVE REPORTED
   REDUCTIONS IN HAZARDOUS WASTE
   DISPOSAL AND USE OF TOXIC
   CHEMICALS
-------------------------------------------------------- Appendix II:2

In establishing their hazardous waste minimization programs, the
services set a goal to reduce the amount of hazardous waste disposed
of by 50 percent by 1992.  Each of the services reported that it has
met this goal with the following reductions: 

the Air Force reported a 56-percent reduction in its disposal of
hazardous waste (from 50,678 tons in 1987 to 22,236 tons in 1992),

the Army reported a 62-percent reduction (from 72,728 tons in 1985 to
27,726 tons in 1992), and

the Navy reported a 63-percent reduction (from 288,232 tons in 1988
to 107,704 tons in 1992). 

The services told us that they had recently implemented many
successful projects to reduce their use of toxic chemicals, but do
not have a complete list of these projects because management reports
and budgets do not segregate them from other environmental projects
by purpose.\3 The services' past efforts to minimize hazardous waste
focused on treating and controlling pollution generated from
processes rather than eliminating the use of toxic chemicals that
generated hazardous waste.  The following are examples of each
service's projects that focus on eliminating the use of toxic
chemicals: 

Elmendorf Air Force Base, Alaska, has substituted the toxic chemicals
used in deicing runways with more benign chemicals and reduced the
use of the benign chemicals by placing sensors below runways to
better detect when deicing is needed.  Tinker Air Force Base,
Oklahoma, has eliminated cadmium, a highly toxic metal, from its
electroplating process used in the maintenance and repair of aircraft
parts and substituted a less hazardous material.  In addition, Tinker
reported over a 50-percent reduction in the use of methylene
chloride, a toxic chemical used to remove paint from aircraft and
rubber from aircraft engine parts, by substituting benzyl alcohol and
high-pressure water spray. 

The Lake City Army Ammunition Plant, Missouri, has replaced methyl
chloroform and other hazardous materials used in cleaning machine
parts and tooling with parts washing machines that use soap and
water.  As a result, the plant has reduced the generation of
hazardous waste by 6,000 gallons and is saving $12,000 annually.  The
Anniston Army Depot, Alabama, reduced its use of the highly toxic
metal, cadmium, by substituting a nontoxic aluminum ion vapor
deposition process for electroplating a variety of parts for weapon
systems.  The depot estimated that this process would reduce waste
treatment and disposal costs by $178,000 per year. 

Several Navy installations have replaced chemicals with water-based
processes for cleaning non-flight-critical aircraft components.  In
addition, the Charleston Naval Shipyard, South Carolina, has replaced
ozone-depleting chemicals with sodium bicarbonate for paint removal
and certain cleaning operations. 


--------------------
\3 The Pollution Prevention Act of 1990 defines source reduction as
reducing the amount of hazardous wastes entering the environment,
including fugitive emissions, prior to recycling, treatment, or
disposal and reducing the hazards to the public health and the
environment.  In practice, ambiguity exists in classifying and
reporting the purpose of various types of environmental projects. 
For example, a project to reduce toxic chemicals in paint could be
classified as either compliance with the Clean Air Act to reduce
emissions of hazardous materials into the air or prevention. 


   REPORTING RELEASES OF TOXIC
   CHEMICALS INTO THE AIR HAS NOT
   BEEN REQUIRED IN THE PAST
-------------------------------------------------------- Appendix II:3

Hazardous waste minimization goals and reporting have excluded
releases into the air because DOD's hazardous waste minimization
program did not require reporting these releases.  Since Executive
Order 12856 now requires the reporting of releases into the air, this
information will begin to be collected by defense installations. 
Data from Tinker Air Force Base indicates that air releases could be
significant:  it reported that about 1.6 million pounds, or 99.9
percent, of its toxic chemical releases, was released into the air
during calendar year 1992. 


SERVICES EXPECT TO MAKE ADDITIONAL
PROGRESS
========================================================= Appendix III


   DOD BELIEVES SIGNIFICANT
   REDUCTIONS IN USE OF TOXIC
   CHEMICALS WILL BE DIFFICULT
------------------------------------------------------- Appendix III:1

The Executive Order requires DOD to reduce its releases and disposal
of toxic chemicals by 50 percent by December 31, 1999.  Moreover, the
order requires that these reductions be achieved through source
reductions to the maximum extent practicable.  The services told us
that taking further significant steps to reduce hazardous waste would
be difficult.  For example, 78 percent of the Air Force's reported
reduction in hazardous waste disposal between 1987 and 1992 occurred
in 1988, and reported disposal actually increased by 13 percent from
1991 to 1992.\1

According to the services, making additional reductions in their use
of toxic chemicals will require more research, development, test, and
evaluation to identify potential substitute processes and materials
and capital investment for new equipment that the new processes are
likely to require.  For example, replacing cleaning processes that
use ozone-depleting chemicals with less hazardous materials often
requires additional processing steps and related new equipment.  In
another example, Tinker Air Force Base expects to spend about $21
million to replace a process using a hazardous material for stripping
paint from aircraft with a robotics system using high-pressure water. 


--------------------
\1 Much of the reduction in 1988 may have resulted from decreased
workload.  For example, over one-half of the 20.7-percent reduction
in direct production hours at Air Force depots from 1987 through 1992
occurred between 1987 and 1988.  According to the Air Force, the
increase in 1992 was due to a one-time cleanup of sludge ponds at
numerous waste water treatment plants. 


   FUNDING PRIORITY FOR POLLUTION
   PREVENTION EFFORTS COMPETES
   WITH OTHER BUDGET PRIORITIES
------------------------------------------------------- Appendix III:2

Service officials told us they are committed to giving priority to
pollution prevention efforts and they believe funding has generally
been adequate.  However, they also told us that funding these efforts
in the future would be a challenge in the current environment of
defense downsizing and declining budgets.  For example, pollution
prevention projects must compete with environmental cleanup and
compliance projects that are also required by environmental laws and
regulations and must be funded to avoid large fines and potential
criminal penalties.  DOD's fiscal year 1995 budget request included
$5.7 billion for environmental programs, of which $4.4 billion was
for environmental cleanup and compliance and $392 million for
pollution prevention.  Some pollution prevention activities are
included in other funding accounts, but the amount specifically spent
on these activities is not tracked.  For example, as previously
mentioned, portions of some projects funded with compliance money
could be for pollution prevention. 


   ESTIMATED FUTURE COSTS TO
   PREVENT POLLUTION EXCLUDE SOME
   POTENTIALLY SUBSTANTIAL COSTS
------------------------------------------------------- Appendix III:3

DOD's future costs to address pollution prevention under the
Executive Order will likely be higher than current estimates.  The
services' cost estimates for fiscal years 1994 through 1999 are shown
in table III.1. 



              Table III.1

 Services' Cost Estimates for Pollution
  Prevention Activities, Fiscal Years
                1994-99

