probably would result in less techni­cally efficient plants.

Although OTA doesn't specifically say so, its ratings seem to indicate that the 400,000 bbl-per-day level of development would achieve an opti­mum mix of trade-offs. π

Ciba-Geigy sues Industrial Bio-Test In yet another salvo fired at Indus­trial Bio-Test Laboratories, the be­leaguered Northbrook, 111., firm has been sued by Ciba-Geigy Corp. The suit, filed in the Circuit Court of Cook County, Illinois, seeks more than $10 million in damages for an alleged breach of contract, warranty, and gross negligence in connection with toxicity evaluation tests that IBT performed for Ciba-Geigy between 1966 and mid-1977.

IBT is expected to contest the ac­tion, which concerns some 100 pesti­cides and related compounds that were tested for Ciba-Geigy's agricul­tural division.

The suit also names I B T s parent company, Nalco Chemical, as code-

EPA, industry overestim An argument between an industry and the Environmental Protection Agency over how much implementa­tion of a new regulation will cost is not unusual in Washington, D.C. The industry sets one figure and EPA another, usually lower, figure. Both are likely to be too high, a new study has found.

The study conducted for EPA by the Cambridge, Mass., consulting firm of Putnam, Hayes & Bartlett compared EPA and industry esti­mates with the actual cost of complying with water pollution standards for the iron and steel, pe­troleum refining, pulp and paper, and electric utility industries and with air pollution standards in the automobile and electric utility industries.

For four of the five industries ex­amined, EPA's estimates of the cap­ital costs associated with complying with a given regulation were lower than the industry estimates. How­ever, "both EPA and industry fore­casts tend to overestimate compliance costs more often than they underes­timate" them, according to the study. EPA's forecasts ranged from 26% below to 156% above reported ex­penditures, and industry forecasts ranged from 25% below to 247% above reported expenditures.

For example, both EPA and the petroleum industry estimated the

fendant. Nalco says it did not perform any of these tests and should not be named in the suit. It also plans to contest the court action.

The suit accuses IBT and Nalco of "inadequate, careless, and sloppy practices" in carrying out toxicity tests and evaluations. In particular, it alleges that IBT/Nalco:

• Failed to keep complete and ac­curate records of test studies.

• Changed data on records without accompanying explanation or docu­mentation.

• Misrepresented the number of animals they used in such tests.

• Maintained inadequate facilities for the care of rodents used in tests.

• Employed untrained and in­competent personnel to conduct and monitor the studies.

The present litigation is just one more legal headache added to the suits filed last year against IBT and Nalco by Xttr ium Laboratories, Wesley-Jessen, and Sandoz. These actions, still in the pretrial stage, also arise out of past work done by IBT.

Also, IBT is a subject of a federal grand jury investigation in connection with its past work and has produced documents under subpoena. D

te compliance costs costs of complying with EPA's best practicable technology effluent guidelines at $1.4 billion, far above the actual cost of $586 million. The iron and steel industry estimated the cost of complying with its effluent guidelines at $1.6 billion, and EPA estimated it at $832 million; both es­timates were far higher than the ac­tual cost of $513 million. For electric utilities the industry estimate of $2.6 billion was above the actual cost of $1.9 billion, but the EPA estimate of $1.7 billion was too low although closer. On the other hand, the pulp and paper industry estimate of $1.1 billion was below the actual cost of $1.4 billion, and the EPA estimate was high at $1.6 billion.

Neither EPA nor utilities did well on estimating the cost of installing sulfur dioxide scrubbers for electric power plants. According to the study, the industry underestimated costs of scrubbers on new plants 16%, whereas EPA underestimated costs 30%. The industry's estimate of retrofit costs agreed quite closely, however, with actual reported expenditures, but EPA's estimate was only 77% of ac­tual expenditures.-

According to the study, EPA's es­timate of price increases for automo­tive pollution control was much closer to actual sticker price increases than were the industry's estimates. D

Nader charges CMA hid unfavorable survey Charges last week by Ralph Nader that the Chemical Manufacturers Association was "covering up" an opinion survey that was uncompli­mentary to the chemical industry are "sheer nonsense," says a spokesman for the industry association.

The survey in question was con­ducted earlier this year by Cambridge Reports Inc. for CMA. More than 1200 politically active individuals were interviewed for the survey, in­cluding persons living near chemical plants and opinion leaders from gov­ernment, academe, and the media.

According to the survey report, the objectives were to assess the aware­ness of these people of the chemical industry's efforts to communicate public policy issues, to gauge public attitudes toward the industry, and to get a baseline for monitoring opinions to determine the effectiveness of CMA's current chemical communi­cations campaign.

Data from the survey indicate that the chemical industry indeed has some serious public relations prob­lems. In comparison to five other in­dustries—nuclear, oil, banking, in­surance, and retail (which Nader de­scribes, except for retail, as the least accountable industries in the world)—the chemical industry was rated fourth in favorability and truthfulness. Media opinion leaders rated the chemical industry as the least truthful of the six.

In response to other questions, a majority of those surveyed said they were primarily worried about air and water pollution, believed that the chemical industry was unconcerned about the welfare of the average per­son, and perceived proper waste dis­posal as the least concern of the in­dustry. A majority also were unable to recall any recent news reports or stories about chemicals or the chem­ical industry. Those who could mostly remembered stories about Love Canal.

It was because of these uncompli­mentary results that Nader claims CMA was hiding the survey. He says CMA was "covering up its opinion survey so that the chemical industry's current drive to stop the modestly adequate toxic waste dump legisla­tion could go forward unimpeded."

CMA disagrees and says that it is publishing the survey in its own in-house publication, already in press. The survey, likened to readership surveys done by newspapers and magazines, was intended only as a guide for CMA's communications program, a spokesman says. D

6 C&EN June 30, 1980