slow to intervene. In any event, however, expanded use of coal does presently appear to be a major part of the answer to energy independence, and the railroads are prepared to be a key link in carrying the coal from mine to point of use. The Santa Fe will handle its share of this expanding transportation requirement in the Southwest just as we plan to continue to meet the transportation needs of all of our cus tomers. STATEMENT OF SOUTHERN CALIFORNIA EDISON COMPANY BEFORE THE COMMITTEE ON PUBLIC WORKS OF THE UNITED STATES SENATE NATIONAL PETROLEUM AND NATURAL GAS CONVERSION AND COAL SUBSTITUTION ACT OF 1975 S. 1777 July 1. 1975 STATEMENT OF SOUTHERN CALIFORNIA EDISON COMPANY UNITED STATES SENATE, CONGRESS OF THE UNITED STATES July 1, 1975 S. 1777 Southern California Edison Company (Edison) hereby respectfully submits its comments and suggestions concerning S. 1777 in response to Senator Randolph's May 20, 1975 invitation. Senate Bill 1777, as proposed, would require all new and, to the extent practical, all existing power plant boilers to be capable of utilizing coal as their primary energy fuel, in conformity with the applicable environmental requirements by 1985. As Senator Randolph indicates, this would require. at a minimum opening 250 major coal mines within the next ten years and doubling the current coal production by 1985 at a cost approaching $25 billion while industry estimates approach $43 billion. Additional billions would be required to construct the necessary transportation facilities and for utilities to make the required conversions from oil and gas to coal fuel. Introduction Edison is an electric utility engaged in the generation, transmission and distribution of essential electric service to nearly eight million people in Southern California covering an area of approximately 50,000 square miles. The electricity to supply such essential electrical service to Edison's customers is generated by hydro-electric plants; nuclear-powered plants; coalfired plants, as well as plants burning low-sulfur residual fuel oil; and natural gas when available. Edison's oil and gas-fired plants represent approximately 9.8 million kilowatts or 77% of the currently installed generating capacity. The design of these oil and gas-fired boilers and related facilities -2 precludes them from being converted to use coal fuel without making major modifications which are both physically impractical or economically infeasible. The overall cost impact upon Edison would be significant, approaching $3 billion to convert all existing oil and gas-fired units to coal and to replace lost capacity. There would be major environmental concerns with possible adverse effects, such as an increase in the emissions of air pollutants, increases in solid-waste generation, potential increases in land requirements, increases in water pollution, increases in transportation problems and administrative authority conflicts over jurisdiction with respect to air pollution regulations and the California Coastal and Energy Commissions. Environmental Considerations Implementation of the National Petroleum and Natural Gas Conversion and Coal Substitution Act of 1975 could create several potential, severe, environmental concerns in conjunction with the promotion of greater coal utilization. For example. Edison would require nearly 18 million tons of coal (at 11 000 BTU per pound) per year. The resultant annual volume of ash production (nearly two million tons) would present several problems with the collection. storage and disposal of such a quantity of ash. Abatement equipment and methods for controlling the emissions of air pollutants from coal-fired steamelectric generating stations in order to comply with the applicable emission standards are currently in various stages of development. In comparison with oil- and gas-fired power plants, techniques for controlling emissions from a coal-fired plant are in the early development stage. Most of the equipment and control methods presently being utilized for coal -3 fired control are extensions of similar techniques used on oil- and gas-fired systems. Conversion of most gas and oil-fired units to coal would present enormous problems as far as arrangement and operation of emission-control equipment. Available particulate- and sulfur-dioxide removal equipment for coalfired application normally must be placed strategically in the total layout of the station in order to operate effectively. Also, a disposal site must be provided for the flyash and scrubber-sludge waste products. Since most existing plants are size-limited, this could be a large constraint on conversion to coal. Existing equipment, retrofit to accommodate coal firing, would be extremely costly, time-consuming, and most impractical. Other environmental concerns associated with the conversion of Edison's oil and gas-fired units to coal would be the increased land requirement for use as active storage for the coal units and for the air-pollution-abatement equipment. in addition to the increased amount of land required as a buffer zone and access area. This increased land requirement would require Edison to acquire and, if necessary. to condemn large amounts of property presently being used for commercial light industry and residential purposes. Lack of cooling water is also a severe problem in the Southwest. Precious, fresh water should be used for power plant cooling only when ocean cooling is not available or otherwise impractical, as in the case of California, due to local air-quality regulations and the California Coastal Commission's jurisdiction over all developments on the sea coast. A national development program should provide for associated water development in the western United States and provisions for access to ocean cooling if the national public interest |