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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 equipment. Question 5: What do you believe, from the viewpoint of the paper ändustry, 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 polJution 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:

(1) The primary problem exists for companies less favorably located. They will be penalized in competition with other mills.

(2) Of secondary, but not insignificant importance, and dependent upon the extent of treatment required, paper could be

come less competitive with plastics and other substitutes. Broadly speaking, our industry position is described fully in the statement of the American Paper Institute for the Committee on Public Works of the House, Congress of the United States, which was submitted on July 13, 1966. I refer you particularly to page 4 of the statement which is attached under the heading “Comments by Mr. Hickey on Financial Considerations in Constructing Water Treatment Facilities."

Question Ya: Do you believe that tax incentives would help in achievement of pollution abatement techniques that would permit substantial improvement in stream quality standards?

Answer: Water quality standards should be realistically established and the best pollution abatement techniques which can be developed should be utilized based on the merits of such standards and techniques and without regard to tax incentives. Financial incentives are a different aspect of the massive problem facing industry.

The entire program of pollution abatement will be facilitated and accelerated if meaningful financial incentives are provided. In fact, it is doubtful if proposed programs are feasible over a reasonably short period of years if financial assistance is not available. Government and industry working together should explore various financial incentives, such as: Federal, State and local tax relief, grants in appropriate circumstances, and loans. These should be evaluated and compared and a workable solution achieved just as technical personnel are expected to provide optimum solutions on standards and techniques.

Question 76: Would facilities not now considered economically feasible be feasible with a tax incentive program?

Answer: A major expense in many facilities not now considered economically feasible is the operating cost. This includes material costs, power, equipment maintenance, and manpower. Unless a tax incentive program covered these operating costs, it would do little to make the presently prohibitive methods economically attractive. Rather research must find reasonable solutions with reasonable operating costs.

Additionally, there is further reference to this question in Ur. Hickey's statement to which reference is made in the answer to question 6 above.

Question 8: Can you give examples of other improvements resulting from research and demonstration efforts of your organization? Answer:

(1) Improved utilization of waste clarifying equipment.
(2) Development of improved retention aids has reduced losses.

(3) Methods have been developed for disposal of resiches obtained as a result of treating waste waters, for instance, centrifugal dewatering of sludge has been proved practical. This has improved the potential for disposal by burning, low nuisance landfill, and “byproduct” reutilization.

(4) Adapted the activated sludge process and a number of modifications thereof to the removal of BOD from papermill wastes.

(5) Aerated lagoons for improved waste treatment have provided a good degree of secondary treatment in some instances at reduced costs. Continued progress in this area is expected.

(6) Developed parameters for effective use of land disposal for liquid papermill wastes.

(7) Development of improved trickling filter media has successfuly handled several difficult treatment situations.

(8) Development of adequate sampling techniques for mill, stream and air surveys. The testimony contains other examples.

Question 9: Is the pulp and paper industry doing anything to combat the problems of air pollution?

Answer. The National Council has researched air pollution problems for better than 15 years. Definite progress has resulted from their work and the work of the larger corporations. For example, in the kraft industry a recent survey indicated that approximately half the mills have installed equipment or processes to reduce odorous emissions.

Air pollution problems are more confined to specific localities than are those of stream pollution. Most pa permills are cognizant of goodneighbor responsibilities and have installed control equipment where possible. These consist of:

(1) High stacks.
(2) Black liquor oxidation.
(3) Scrubbers.
(4) Precipitators and dust collectors.

(5) Catalytic furnaces. Technology is limiting further progress in this area. Odor level measurement is expensive and not as precise as necessary. Odor abatement is impossible for many of the problem gases. Solutions are not known and so research is required before additional progress can be made. New methods of testing for odor pollutants have been developed at considerable cost as a necessary step toward finding specific solutions.

In April 1966, the National Council, along with the U.S. Public Health Service and the University of Florida, jointly sponsored a conference attended by scientists, engineers, and representatives of enforcement authorities from six countries whose objective was the assessment of the total current technology in the field of air pollution problems within the kraft pulp industry. The compilation of all presently known knowledge should provide an excellent base for determination of the direction of future research in this field.

Question 10: What type of legislation can the Federal Government pass to help the paper industry deal with its pollution problems?

Answer: The American Paper Institute has presented testimony this year before the appropriate Subcommittee of the Senate Public Works Committee (on May 12), and before the House Public Works Committee (on July 13), concerning proposed water pollution abatement legislation. In this testimony the institute has set forth in detail its position regarding the type of legislation which it supports at the

Federal level to assist the industry in its pollution abatement efforts.

Legislation will not solve problems where solutions are not known. Research grants to find better and more economical solutions must be the primary step. Recognition of the problems which face industry must be a guide for any legislation. Reasonable legislation would consider the particular situation with a variable enforcement pattern geared to technical progress. Enforcement can be best handled at the State and local level since they are most familiar with the individual situation.

Question 11. Can you give any specific examples of plants that have been forced to move or go out of business, of proposed plants that have not been built in localities that had been selected for other reasons, because of inability to economically meet State-imposed quality standards for the plant?

Answer: There are some examples of plants that have been forced to go out of business; in fact I know of two instances in New York State, one in which this factor was the principal cause and another in which the pollution abatement requirements were so stringnt that a plant was not rebuilt after a disastrous fire. In addition, I am aware of a large company that operates nationally that has shut down at least three mills where the effluent problem was critical, and the correction was great enough to be a factor in the final decision to close them down. Broadly speaking, the liberal application of the guidelines recently proposed for the control of water pollution would unquestionably require some mills, especially older ones, so to modify their operations as to be economically noncompetitive.

There are many locations which are otherwise suitable for pulp and papermaking facilities which can no longer be considered because of the increasing stringency of water and air pollution abatement requirements.



Question 1: In the course of your testimony on August 3, you made reference to a papermill that was to have been built in California on the upper reaches of the Sacramento River, plans for which were abandoned when the cost of providing the necessary water treatment was taken into account. Can you give more details on the proposed plant? Was it relocated elsewhere? Is the process finally adopted for a plant on the Sacramento Rivera more efficient process than the original plant? Any other specific information you can provide with respect to this case will be helpful to the coinmittee.

Answer: The plant originally proposed for location on the upper Sacramento River some 10 years ago eventually located in Virginia, and on a river, I believe. The plant process proposed would have wasted about 60 percent of the raw material (logs) to the stream. About 3 years ago, a different company built a plant on the upper Sacramento River. This plant, which produces bond paper, wastes only about 40 percent of the raw material and this waste is much more amenable to treatment than that from the plant process originally proposed.

There is also another pulpmill on the upper Sacramento River located on the exact site originally proposed 10 years ago. This second plant produces cardboard and brown paper, as well as some pulp, which is transported to other plants for finishing.

Quite stringent waste discharge requirements have been imposed on the two pulpmills on the upper Sacramento River. Similar restrictions have been applied to pulping operations on the Pacific Ocean in California's north coastal area. In the latter case, a limited dilution zone is allowed in the immediate vicinity of the submerged outfall.

Question 2: With reference to the problem of brine disposal from desalting plants referred to in your statement, have any studies or research been performed by the State of California on how these wastes can be disposed of? If so, will you furnish details on the findings? How are the wastes from the Coalinga plant disposed of ?

Answer: To my knowledge, no research or studies have been performed by the State of California on the problems of brine disposal from desalination plants.

The 28,000-gallon-per-day electrodialysis plant at Coalinga produces sufficient water only for drinking and culinary purposes, and a separate supply system is necessary for the main flow of water, which is not desalted and which is used for all other consumer purposes. Twenty gallons per minute of waste water from the desalination plant containing about 3,700 parts per million dissolved solids is discharged to the supply reservoir for the main water system. The total dissolved solids content of the other system is increased only about 1 percent, by this concentrated solution.

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