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RESPONSES TO QUESTIONS OF THE SUBCOMMITTEE ON SCIENCE, RESEARCH, AND DEVELOPMENT BY MR. BERTRAM C. RAYNES, RAND DEVELOPMENT CORP.

Question 1: In your testimony before the Subcommittee on Science, Research, and Development, Committee on Science and Astronautics, on July 28, in answering questions about the coal process in treating sewage, you made reference to the increased efficiency possible with this process when the coal could be burned after use and the energy of the coal recovered. You mentioned that this step was only feasible in the larger size plants; how is the coal to be disposed of after use in smaller plants if it is not to be burned? If it has to be buried or otherwise disposed of on land, does this not add to the pollution of the soil? In the larger plants where the used coal is burned does not this process merely transfer the polluted material absorbed by the coal from water into the atmosphere?

Answer: My reference is to increased economy possible when the coal-sewage solids mixture is burned with recovery of the thermal energy it possesses. Plant effluent quality remains the same regardless. of the fate of this material. Incineration is the disposal means we favor. Incineration can be carried out regardless of the size of treatment plant involved and at some scale of operation (perhaps for a plant serving 25,000 to 50,000 persons), recovery of the energy becomes economically attractive in-plant. If the plant is situated near an already existing boiler it is entirely possible the coal mixture from even a very small plant can be used economically.

By no means are we interested in substituting one pollution problem for another. We do not want to pollute the air in the process of helping to control pollution of surface waters. Sewage treatment plants which produce sludges both primary and secondary treatment plants often incinerate those sludges for disposal. The coal-based sewage treatment process does not eliminate the air pollution problem, but it can decrease it because higher incineration temperatures and afterburner temperatures can be used than with sludge. I'd like to work on air pollution problems, but haven't yet.

Question 2: In your statement you made reference to the Federal Government forcing industry to take care of its wastes. Do you feel that if the Government does, through legislation, force this step to be taken, that the necessary technology will be produced by this action? Answer: Necessity has always been the father of technology.

Question 3: In urging that the Federal Water Pollution Control Administration set up a troubleshooting group of experts to help work out the practical problems of operation of sewage treatment plants in smaller towns, does this not put the Federal Government in direct competition with sewage plant engineering firms?

Answer: I don't believe so. Engineering firms are not sewage plant operators. If equipment fails, engineering firms can help, or the

equipment manufacturer can help. My suggestion concerns plant operation and technique.

Question 4: Do you believe it is realistic to force industry to return "pure" water to streams regardless of the cost of necessary treatment? Are you not afraid that lack of capital will hinder any such effort?

Answer: Sir, a chemical engineer can never ignore costs. Granted that cleaning up pollution is expensive. But not cleaning up pollution is expensive, too. Industry pays to clean up its water supply. Municipalities pay to clean up their water supplies. There are damages to public and private property caused by filth and corrosion. And there are other costs, the esthetic losses. It may be, in fact, unrealistic not to require industry to return clean water to streams-on a cost basis alone. I haven't seen a balance sheet on these costs; some say it will cost too much, and some say it will be worth the cost. A good, complete balance sheet would be useful in permitting an objective assessment of which approach will actually cost less. Perhaps this committee could authorize the development of such a balance sheet.

Question 5: Your statement suggests that you are unwilling to consider use of streams for disposal of any waste material. Would you propose to eliminate even natural accumulation of wastes in streams? Is not a certain amount of organic waste healthy for a stream in providing the necessary food for the life cycle of plants and lesser species of living organisms that provide food for fish? How would you propose to set standards for what is permissible in streams to be used for various purposes, such as drinking water, recreation, industry, in the absence of studies of the problems and analytic techniques and the like which you suggest should be eliminated?

Answer: I'm proposing that the standards be set for effluents entering streams. These effluents should be as pure as present science and technology can make them, with aggressive technological and business management seeing to it that the cleanup is conducted efficiency and skillfully and that cleanup operations are upgraded just as constantly as production operations are.

I do not propose eliminating all studies. Meaningful studies suggest solutions and attractive suggested solutions should be tried in realistic programs. I endorse meaningful studies.

Question 6: Do you believe we should install devices to control emissions into the atmosphere even if the emissions are found to be harmless?

Answer: Well, if emissions are found harmless through the expedient of putting them out into our atmosphere and seeing who complains or what the environment suffers, then I'd certainly prefer prior control. Prior understanding at the very least.

Question 7: What kind of legislation do you believe is needed to bring about an upgrading of our pollution control efforts?

Answer: I think that uniform, countrywide enforcement of past and presently proposed legislation would upgrade pollution control efforts. Ways should be found to permit increasing use of pollution abatement field evaluation programs and funds to prosecute them forcefully should be provided.

I think that the approach to and the philosophy of pollution control has to be changed, as I suggested in my prepared statement.

Question 8: How much has been spent and is available for develop

ment of the coal process for sewage treatment? Where did the money come from?

Answer: The development of the coal-based waste water treatment process is sponsored by the Office of Coal Research, U.S. Department of the Interior. All funds have been provided by that Office. The first effort was funded at about $200,000, and the present 2-year pilot program is funded at about $667,000.

Question 9: What percentage of total funds expended by your organization on pollution abatement research comes from Government? From industry?

Answer: While the funds for the pollution abatement research my company is doing at present come from Government, I should add that industry in general has been cooperative in supplying samples of their effluents at their expense, and in other ways. We would be glad to work directly for industry in this area of research and development. RESPONSES TO QUESTIONS OF THE SUBCOMMITTEE ON SCIENCE, RESEARCH, AND DEVELOPMENT BY DAVID C. KNOWLTON, KNOWLTON BROS., Inc. Question 1a: What has been the estimated savings to the industry through making these improvements in papermaking processes? Answer: If the question relates to the recovery of usable values by waste treatment processes of any kind, such values are usually nonexistent or negligible. The references in the statement to improvements in the water economy and the fiber economy within our pulping and papermaking processes refer primarily to in-process changes which were economically justified by the resulting savings. However, it should be noted that such in-process changes have had significant collateral benefits in reducing the industry's waste discharges. There are a few exceptions where heat, water, or material savings are possible but only to a very limited degree.

Question 1b: Does the industry tend to make the changes in process to eliminate pollution only when there is an economic savings in the cost of producing paper?

Answer: With respect to the industry's attitude toward process changes or the installation of waste treatment processes to avoid pollution, such changes are made as needed to the extent it is practicable to do so in order to conform with applicable receiving water quality regulations.

Question 2: Can you develop figures on how much the industry itself is expending in its own laboratories on pollution abatement?

Answer: The current budget for the National Council is $428,000. In addition to the National Council expenditures for research and development directed at the abatement of air and water pollution-as well as those of the North West Pulp & Paper Association, the Sulphite Pulp Manufacturers' Research League, and the Institute of Paper Chemistry-individual companies of the industry are currently spending in their own laboratories in excess of $2,500,000 per year on air and water pollution abatement investigations. This amount does not include capital or operating expenses connected with waste treatment installations.

Question 3a: Can you give more quantitative estimates of the re

sults of NCSI research and any actions which have been taken to alleviate pollution based on this research to date?

Answer: Although this question has been answered by the testimony and the annotated material submitted with the corrected testimony, the most important phase of the National Council work is in the distribution of the information and the assistance of technical service. Most of the findings from the Council research work are implemented by the member mills to make them suitable for their particular conditions or situations. Furthermore, equipment evaluation and treatment studies by member mills or groups of mills working cooperatively with the National Council are distributed to all member mills. This proves especially beneficial to small mills which are not able to afford major research programs.

Question 3b: Do you have any estimates of what else needs to be done or what other research must be carried on to completely eliminate the problems of pollution caused by papermill effluent?

Answer: Although this question was answered in the original testimony, it is acknowledged that much more needs to be done in new and novel processes for effluent handling and treatment. In addition to the projects mentioned in the testimony, i.e., decolorization and sluge disposal, much more needs to be done in new and novel processes for effluent handling and treatment. Greatly increased expenditures for research will be necessary in order to accomplish these objectivesvariously estimated at 4 to 10 times the present rate.

Question 4a: In general, has the paper industry conducted research in response to regulatory action when its own sources of water are being imperiled or as part of a long-range program to return water to the streams in the condition it was before use?

Answer: In general, the industry has conducted research in response to the will of the people as expressed by the applicable law and regulations.

Research in these areas by the paper industry was started before regulatory action became the factor it is today. Both the Sulfite League and the National Council were begun more than 20 years ago.

There is no doubt that the research conducted by industry has been in response to long-range programs aimed at overall reduction of existing pollution problems. However, the approach to any program is composed of individual steps. These steps have varying importance and are assigned priorities in accordance with need, available money, and technical manpower. Since both trained personnel and capital can be limiting, pure research is ruled out in favor of practical research with immediate solutions to immediate problems.

In response to the question, then, work on an imperiled water supply would certainly proceed before research on effluent treatment could, especially in light of the limiting factors mentioned above.

Question 46: What other reasons have motivated research carried on by the paper industry?

Answer: Going beyond the above and looking to the future, the industry, through the National Council, is still conducting research in attempting to develop more advanced waste treatment processes which will produce treated waste waters suitable for reuse without dilution.

Specifically, research in the paper industry has been motivated by: (1) Need to solve problems detrimental to pulp and paper manufacturing.

(2) Need to conserve water supply.

(3) Required to meet stream standards in regard to downstream use, protection of aquatic life, and as a responsible citizen to preserve the esthetic values of our streams.

(4) To effect process economies where practical.

(5) To optimize existing treatment and abatement facilities. (6) To explore, develop, and evaluate new and better equip

ment.

Question 5: What do you believe, from the viewpoint of the paper industry, should be the goals of pollution abatement legislation?

Answer: The pulp and paper industry of the United States is deeply conscious of the need to conserve the water resources of this country for the use of all the people. This is in keeping with the enlightened multiple-use concepts applicable in the case of water resource management. Some streams are best suited for recreation and water supply, while others best serve less stringent requirements. It should be our purpose to make the totality of our streams capable of serving the multiple interests of our society.

Thus in our opinion the desired goals and objectives of stream pollution legislation should be

(1) To conserve water as a natural resource.

(2) To protect legitimate water users.

(3) To provide the needed incentive by economic measures. (4) To develop individual master plans for each river basin. (5) To provide money and facilities for long range practical research, in methods of treatment.

(6) To provide financial assistance to industries through grants or industry-municipal projects and tax relief for internal industrial abatement facilities.

(7) To be impartial and accurate in the analysis of individual problems so that costs are reasonable and livable. (Do not require treatment just for treatment's sake.)

(8) To be reasonable in enforced schedules by considering the depth of the problem, the cost for an adequate solution, and the reasonable approach to proceeding with the necessary work. Question 6: With reference to certain aspects of pollution abatement being economically unfeasible, what is meant?

Answer: Each situation is different. Any situation requiring 100 percent treatment is impossible to meet. In many instances, complete treatment based on existing technology would not completely solve the problem. This depends upon the type and size of the mill and its location.

Stringent enforcement of standards without regard for the situation could and would discriminate against smaller companies or those companies unfavorably located on small tributaries or in highly industrialized areas. Expansion and growth at these existing mill sites can be greatly limited or prevented. For example, an older mill may be geographically situated where this is no land available for holding ponds, etc. This means that:

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