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Question 1: It is recognized that although pollution is caused by many different industries, it is a chemical problem. Therefore, regardless of source, how can industrial chemical technology best be brought to work on the solution?

Answer: The statement that "although pollution is caused by many different industries, it is a chemical problem” is an oversimplification. Actually, while all pollutants are chemical in character and amenable to chemical technology, it does not necessarily follow that the application of chemical technology is the most economic and practical answer to each pollution problem.

We believe the chemical technology of the industry can best be utilized along the following lines:

(a) The chemical industry voluntarily, as well as under incentive or pressure motivation, will devote additional attention to solving its own pollution problems. The solution to these problems in turn can be applied to other industries having similar problems. Motivation by incentive is probably the key to more rapid progress in this area.

(6) Chemically oriented companies who are in the business of water and/or air treatment can engage in pollution abatement effort for sale at a profit to any industry. This is currently going on and will be amplified and speeded up as the demand for this service develops.

(c) Establishment of chemical technology information exchange mechanisms via seminars and conferences along crossindustry lines. This involves the collection and dissemination of data so that maximum utility can be made of present information and new information as it is developed. The Manufacturing Chemists' Association, Inc., has for some years been fostering such information exchange. Currently the association has a program of 1-day workshops to assist in solving industrial pollution control problems in localized areas, with regulatory officials participating. In addition, week-long seminars have been arranged by MCA at five United States and one Canadian universities to provide instruction on the latest techniques for treating and controlling chemical wastes.

(d) By drawing on the counsel of chemically oriented people in devising control plans, developing control criteria, specifying research programs, and other areas related to pollution control, available chemical industry technology can be fully utilized. Members of MCA's Water Resources Committee are consulting with State agency officials with the objective of being helpful regarding the current development of water quality criteria under the Federal statute.

The history of the chemical industry demonstrates that it is alert to opportunities to engage in research along the lines of expanding technology, including that applicable to waste treatment and control. Hence as new ideas emerge, we do not believe there will be any lack of appropriate development by the chemical industry.

Question 2: What are your views on a policy that would conserve fossil fuels for chemical raw materials?

Answer: Much of the chemical industry as we know it today, both technically and economically, is based on ample supplies of fossil fuel raw materials. The very substantial known reserves of these materials, however, coupled with the adaptability of the chemical industry to changing circumstances would seem to indicate that any program of intentional limitation is unwarranted. If such limitation were unduly restrictive as to other fossil fuel uses, not only would this result in dislocation of other segments of the national economy, but it might react adversely on the economic base of the chemical industry as well. It may also be observed that the now established trend to wider application of nuclear fuels will of itself tend to conserve fossil fuels.

Answers to Question by Representative Weston E. Vivian During the

Hearings (See p. 410, Vol. I) Question: Do you find any place where joint sponsorship is desirable between the Federal Government and industry, such as pilot-plant operations?

Answer: In our prepared statement we mentioned approvingly “government-industry cooperative investigation," and would construe this to embrace jointly supported projects, also, where there is a mutuality of interest. In some instances this might be brought to bear at the pilot-plant stage; in others, either earlier or later stages of development might be logical for such consideration, depending on the nature of the research involved.

Response to the Remarks of Representative James G. Fulton During

the Hearings (See p. 411, Vol. I) It is regrettable that Congressman Fulton misunderstood the basic premises of our statement at several points, and we welcome this opportunity for appropriate clarification and reemphasis.

The chemical industry is committed to the desirability of preserving natural resources that have not been abused as well as restoring those which have been abused. It is incontrovertible, however, that many processes essential to the sustenance of life produce waste products for which there is no repository but the environment. Nevertheless, if esthetic values and beneficial uses of the environment are not impaired incident to such disposal, then there is neither measurable injury nor recognizable pollution.

In recommending that interim objectives be set at conservative lev. els, we primarily had in mind the situation where existing contamination is already in excess of anticipated quality standards. We would not propose to intentionally set requirements so loose that injury to

esthetic values or beneficial uses would occur or be continued. Still, it must be recognized as current fact that a clear definition of acceptable quality for various environmental uses is not now known. Accordingly, the derivation of quality objectives for any given situation must perforce rely to a considerable extent on expert opinion and judgment, weighing the requirements of what may be competing beneficial uses. If requirements go beyond those necessary to safeguard esthetic values and beneficial uses, the cost of meeting them may be, and in many instances certainly would be, unnecessarily expensive without compensating tangible benefits. Experience and changing circumstances may indicate the desirability of either stiffening or liberalizing controls, and the avenue to modification should remain open.

Uniform regulation is an illusory concept. One has only to contrast a large installation on a small stream to a small installation on a large stream to illustrate the lack of logic in having the same waste controls apply to both. Further, no matter what is permitted (short of complete prohibition), an unsatisfactory condition could result from too many separate installations located near one another. The notion is further confounded by wide differences in natural water quality and in the relative priority of various beneficial water uses from one locale to another.

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AND DEVELOPMENT BY THE TENNESSEE VALLEY AUTHORITY Question 1: What would be your views on a demonstration bringing certain TVA electric generating plants and the chemical plant to an essentially nonpolluting status, regardless of cost, with present technology

Answer: We would be glad to see certain TVA electric generating plants and our chemical plant used as demonstration facilities to develop pollution control methods as fully as possible. It is important to recognize, however, that present technology, even if costs should be disregarded, will not produce what the committee has described as an "essentially nonpolluting status" for all elements of operations of this kind. For some of the pollutants, further technology must first be developed.

In the case of coal-fired electric generating plants, the air pollutants involved are particulates and sulfur dioxide. The technological problem with respect to removal of particulates has been solved. This is not true of sulfur dioxide, however. Several recovery processes which would remove 80 to 90 percent of the sulfur dioxide are presently under consideration and development, but further pilot plant testing of these processes is necessary before a full-scale demonstration of any of them could be usefully undertaken.

Sulfur dioxide recovery has been subject to reviews by many different groups in and outside the United States within the past few years, and one or more of the processes so far studied may prove eventually to be technically feasible. The U.S. Public Health Service is planning to evaluate the processes which presently appear most promising by arranging for the construction of small-scale demonstration or pilot plants at which they can be applied and tested. TVA has agreed to cooperate by making one of our coal-fired electric generating plants available for the installation of some of these pilot plants. We have a meeting scheduled with the Public Health Service later this month with regard to selection of the processes to be used. Operational experience with these plants would provide information which is essential to the design and construction of equipment for fullscale application to large power units. As soon as a workable solution has been found, we would be glad to proceed with a demonstration involving such full-scale application to a large power unit.

At TVA's chemical plant, as pointed out by our witnesses in their testimony before the committee, we now have underway a multimillion-dollar program for improved pollution control. This program, which is scheduled for completion by the end of fiscal year 1968, will achieve very high standards. These standards are regarded by experts as more than adequate but they will not render the plant entirely pollution free.

The TVA chemical plant is basically a research facility. We are continually dropping old processes and facilities and adding new ones, and we cannot now be certain what the pollution problems in connection with future facilities and processes will be. In the case of some existing operations, present technology leaves a number of problems to be solved to achieve "essentially nonpolluting status.” We believe these problems can be overcome, although to do so might require replacement of some facilities. We cannot now estimate the costs which would be involved, but they would undoubtedly be substantial.

We would be glad to undertake a demonstration along the lines envisaged by the committee, but could do so only if we were provided with the necessary funds.

Question 2: How much of a "pollution abatement creditwould the best 80, removal process require today in order to sell the byproduct sulfur or other chemicals competitively?

Answer: As indicated in the answer to question 1, present technology leaves many questions unanswered, and we believe that the testing of small scale plants is necessary before answers can be provided. It is not possible, for example, to identify at the present time the "best" process for recovering SO, from power plant gases or to predict costs with accuracy. Subject to these reservations, we have averaged some very rough estimates made for what are generally regarded as the three leading processes for the recovery of sulfur dioxide from coal-fired generating plants, based on the present state of technology with respect to these processes. On this basis, we estimate that at a 1,000 megawatt coal-fired steam-electric generating plant, about 80 percent of the sulfur dioxide could be captured to produce about 700 tons per day of sulfuric acid, assuming full round-the-clock operation of the generating plant for that day. We further estimate, also on a very rough basis, that the cost of producing the sulfuric acid would be in the neighborhood of $25 per ton, and that it might be sold under contracts covering the large quantities involved for perhaps $16 per ton under present conditions. Obviously, there are many uncertainties surrounding these estimates. For example, if sulfuric acid were to be produced at a large number of coal-fired generating plants and offered for sale, the market for it would be glutted and the price would decline.

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