STATEMENT SUBMITTED TO THE SUBCOMMITTEE ON SCIENCE, RESEARCH, AND DEVELOPMENT, BY JAMES R. GARVEY, BITUMINOUS COAL RESEARCH, INC., SEPTEMBER 19, 1966.

My name is James R. Garvey. I am president of Bituminous Coal Research, Inc., which is the research affiliate of the National Coal Association. At our research laboratories at Monroeville, Pa., we are seeking through research to improve the means by which bituminous coal is mined, prepared, shipped, and utilized. A substantial portion of our research effort is devoted to finding means for controlling the pollution resulting from the mining and use of bituminous coal.

Our organization is supported by the bituminous coal industry, through the National Coal Association, and, in addition, receives financial contributions from the coal-hauling railroads, coal mining and utilization equipment manufacturers, and a number of the leading electric utility companies.

We believe the objective of the hearings by this committee, namely, to assess the technology for pollution abatement, to be a most laudable one. The coal industry, like many other industries, is alarmed by the rate at which legislative action commanding pollution abatement has accelerated well beyond the rate of development of feasible means for accomplishing that abatement; especially in light of the questionable need in some instances for abatement. The situation was well described by Dr. Abel Wolman of the Johns Hopkins University in his special report on pollution made to the Management Advisory Panel of this subcommittee.

A review of the present status of water, air and land pollution and proposals for abatement thereof make reasonably clear that corrective legislation has quite well outrun both factual basis for action and smooth machinery for development and regulation.

We appreciate the opportunity to present this material, and it is our intention, in line with the objectives of the hearings, to review the state of the art of abatement, primarily, of air pollution resulting from the combustion of bituminous coal, and, to a somewhat lesser extent, the abatement of water and land reclamation involved in the mining of coal. We will attempt to brief you on the research and control methods which are currently underway and the expectations we have for the attainment of improved pollution control methods which will enable a reduction in coal's contribution to air and water pollution and land reclamation problems, and at the same time, enable the coal industry to continue as a vital part of our industrial economy.

Bituminous coal is vital since it is the primary source of heat energy used in the generation of electricity and the carrying out of many industrial processes. It is estimated that during 1966 about 263 million tons will be used for electric generation, 106 million tons will be used directly by general industries, and 94 million tons will be used in the form of coke for the manufacture of steel. This 463 million tons, combined with somewhat lesser amounts used for other purposes,

including export, will bring the total bituminous coal production this year to about 534 million tons. This coal production, in addition to providing an important contribution to our industrial progress, also provides employment for more than 128,000 men and contributes $2.5 billion to the national economy.

When this bituminous coal is utilized for the generation of heat energy, whether for conversion to electricity or for direct use in industrial processing, a number of byproducts considered pollutants are produced. These include smoke, which is unburned carbon; ash, which is the noncombustible portion of the coal; and gaseous oxides of certain foreign elements in the coal, notably sulfur. The coal producers, in cooperation with those who use coal, have a long record of accomplishment in the development of means for controlling these pollutants. The emission of smoke from a coal-burning plant is, and should continue to be, a thing of the past. Through intensive research, carried out almost 20 years ago, the technology for coal combustion without smoke pollution was developed and the modern, coal-burning plant of today emits practically no unburned carbon.

A similar situation exists with regard to the uncombustible ash of coal. The development of mechanical and electrostatic collectors has progressed to where the stack emission of "fly ash" in modern plants can be reduced to less than 0.5 percent of the original ash in the coal. Because the development of this ash control equipment is more recent than that of smoke control, not all coal-burning plants are so equipped. But as old plants are phased out of use through obsolescence, and new plants are constructed to replace them, this high-efficiency ashcollection equipment is being installed. The electric utility industry, in particular, should be commended for their efforts in the development of such equipment and the investment of non-profit-making capital to the extent of millions of dollars per plant to enable this achievement in dust control. And the ultimate in the control of dust has not yet been achieved. Research still continues and the more recent development of bag filters, which remove almost 100 percent of the dust from the gas stream, are currently being tested by a number of large utility companies.

The third byproduct which I mentioned earlier, namely, the oxides of sulfur, are the cause of the most concern at the present time. The technology for controlling this so-called pollutant is by no means as advanced as that for control of smoke and fly ash. This is perhaps understandable because it has been apparent for many years that unburned carbon in the form of soot, and unburned other constituents of coal in the form of fly ash, were true pollutants. One could see them, feel them, and readily assess the damage being done. No such means for assessment of the damage of sulfur oxides has been possible. One cannot see them or feel them, and the only way one is aware of their existence is in extreme cases wherein the concentration rises to the point where one can smell them. But this is a rare instance, and the concentrations of sulfur oxides in the air are for the most part so low that we are not aware they exist. Whether their existence is detrimental to health is a matter which has not been resolved. As was pointed out in the report of the Environmental Pollution Panel of the President's Science and Advisory Committee, "Restoring the Quality of Our Environment":

While we all fear, and many believe, that long continued exposure to low levels of pollution is having unfavorable effects on human health, it is heartening to know that careful studies have so far failed to produce evidence that this is SO ***.

Further along this line, the report of the Research Advisory Panel of this Subcommittee on Science, Research, and Development, entitled "The Adequacy of Technology for Pollution Abatement," stated:

The facts on the physiological responses of man to long-term low-level exposure to pollutants are lacking, but are necessary for setting criteria and standards. No evidence has yet been produced that low levels of pollution have unfavorable effects on human health.

However, so that I will not be misunderstood and accused of quoting out of context for a special purpose, I want to hasten to add at this point that the same report from which the foregoing quotation was taken went on to say:

But abnormal changes in animal populations are considered to be warnings of potential hazard.

We, the coal industry, acknowledge that the danger of a potential hazard exists. We believe every effort should be made to define the extent to which such a hazard exists and at the same time to develop means for needed control of the pollution which causes it. We urge that criteria and standards for pollution control be based on factual information and not on emotions. We also urge that until the exact levels of pollution which are dangerous to man have been established, the criteria and standards be set with reason in accordance with the state of the art of the technology for their control.

What is being done by industry itself in line with the determination of the tolerable degree of exposure and the development of methods for control of sulfur oxide pollutants? Our organization has been engaged in research directed at the control of this pollutant for over 10 years. In the conduct of most of this research, we have had the financial support and technical guidance of the electric-utility industry through the Edison Electric Institute and the Association of Edison Electric Cos. This research has resulted in greater knowledge of the occurrence of sulfur in coals and the development of guides for removal prior to combustion, as well as increased knowledge of the complex chemistry necessary for the development of processes for recovery of sulfur oxides from the flue gases after combustion. And, as of January 1. 1966, our program has been expanded, again in cooperation with the utility industry. A projected 5-year program has been developed at an estimated cost of $4.3 million. This research, in summary, will include:

1. A thorough study of the physiological effects of sulfur oxides, both alone and in combination with other air contaminants. This work is being carried out by the Hazleton Laboratories of Falls Church, Va. In addition, our organization, in cooperation with the oil industry and the steel industry, is sponsoring another project at Mellon Institute, also directed at determining the physiological effects of sulfur oxides. While both of these research programs will utilize animals instead of humans to study these effects, it is anticipated that the results will provide guidelines for determining the susceptibility of man to low-level exposure of pollutants.

2. Our organization, in its own laboratories, is carrying out research directed at the development of equipment which will enable the removal of additional quantities of sulfur from bituminous coals before they are burned. In many bituminous coals, the sulfur occurs primarily as a mineral pyrite which, if the coal is crushed fine enough, can theoretically be removed. However, because of the extreme fineness of crushing required (to as fine as talcum powder) in order to free these pyrite particles, the development of the necessary technology and equipment is progressing slowly. But, progressing it is, and we expect some time late this year to have installed at a central Pennsylvania powerplant the first pilot unit for achieving this reduction in sulfur content of coal.

3. We are also carrying out accelerated research on the development of low-cost methods for recovering SO, from flue gases following combustion. Our present research is directed at the injection of chemicals into the flue gas stream, which will react with the oxides of sulfur and deposit them with the fly ash. Again, the development of the necessary knowledge of reaction rate of various chemicals, the most effective temperatures at which the reactions should be carried out, and other design data cannot be achieved immediately. It is our intention that the basic laboratory work will be completed some time early next year, and trial installations on a full scale can be started shortly thereafter.

In addition to the research which we are doing, a number of others, including both Government and private industry, are carrying out extensive investigations. Both the Bureau of Mines and the Public Health Service are investigating processes for sulfur oxide recovery. The Bureau of Mines work will move into the early pilot stages this year, and hopefully, a full-scale installation can be made sometime the latter part of next year. The Public Health Service work, we understand, includes an evaluation and possible erection in this country of a pilot unit incorporating a process which has been developed in Germany.

Investigations by the manufacturers of equipment includes the installation of wet gas scrubbing processes. One of these has already been installed for test at a powerplant, and another is projected for installation late this year.

And, in this overall effort directed at finding a means for economical control of sulfur oxide pollutants, one of the large chemical companies, a primary supplier of sulfuric acid to industry, in cooperation with a utility company, is constructing on a substantial scale the equipment necessary for recovering the sulfur oxides from flue gases in the form of sulfuric acid which that company then will market.

In summary, the state of the art of control of pollutants from the combustion of coal is moving forward on all fronts. As I pointed out earlier, the technology for control of smoke in fly ash is already available in an advanced state, and additional progress is being made. However, much still remains to be done, despite an expanded research effort by industry, in connection with the control of sulfur oxides. Those processes which are most advanced in technical feasibility are still at the present state of development far too expensive to install and operate, especially in light of the lack of knowledge regarding the degree of control which is necessary to protect human health.

But progress is being and will continue to be made, and as the work which I described earlier, passes through the large pilot stage of development, opportunities will be available for improvements in the technology which will make them economically as well as technically feasible.

The mining and preparation of coal for shipment to market also is the cause of pollution, including air, water, and land disturbance.

Air pollution results from the spontaneous ignition and subsequent combustion of the refuse discarded in the cleaning of coal for market. Since this refuse amounts to approximately 1 ton for every 2 tons of coal produced, the amount of this material which has accumulated since coal mining began in this country is substantial. The technology for prevention of spontaneous combustion in new refuse piles has been developed, and by means of careful compaction and selection of site, this source of air pollution can be eliminated in the future. However, a great deal more work is required in the development of means for extinguishing fires and prevention of reignition in old and abandoned refuse piles. Our organization has investigated a number of approaches, including the pumping of noncombustible material into the refuse pile. Other organizations, such as the Bureau of Mines as well as other industrial groups, are carrying out additional research, and while some progress has been made the complete answer is not yet available.

Water pollution results from two sources; namely, the fine coal particles suspended in the water used for coal washing, which is in turn discarded to streams; and the acid drainage from mining areas which ultimately by natural flow finds its way into the streams. The technology for control of "black water" discharge is well advanced, and by the use of settling ponds and filters the modern coal preparation plant is rapidly making black rivers a thing of the past.

Acid drainage, however, represents a far greater problem insofar as control is concerned. The mechanism for production of acid water in a coal mine is not completely understood, and the means for changing the acid drainage from a coal mine into so-called sweet water is not as simple as many would have us believe. A large coal mine may discharge as much as 10 million gallons of water each day. The equipment and chemicals necessary for rendering this water suitable as defined by some State laws for discharge into natural streams can be extremely complex and costly. But progress is being made.

The principal object of the coal industry's attention to the solution of acid drainage problems has been in the field of eliminating those areas of drainage in operating mines. The responsible coal producers are surveying the sources of ground water which pass through their mining operations in an effort to minimize the amount which becomes acid; sampling and analyzing the waters discharged from their mines so that they can determine the degree of acidity, and the mineral content as a basis for determining the best approach for neutralization and removal of these minerals; and planning their new operations in such a manner as to reduce to the minimum the water pollution potential. Again, as in the case of air pollution control, a great deal more must be learned about the pollutant itself, both its formation and its effects, before criteria and standards for water quality can be established. Hundreds of thousands of dollars are being spent by the coal industry