This statement is submitted as a supplement to and update of an earlier statement by the Industrial Gas Cleaning Institute dated April 29, 1975.

The IGCI presently numbers 37 member companies. Eleven of seventeen current suppliers of flue gas desulfurization systems are IGCI members.

Lime/limestone or throwaway systems have continued to predominate in FGD systems awarded during the past two years. A tabulation of FGD units comparing the time of the earlier IGCI statement with current date is listed below.

Further reductions in corrosion, erosion, plugging and scaling problems have resulted from continued refinement in process chemistry controls, equipment design and maintenance practices. Improved availability of operating units, as set forth in recent PedCo bi-monthly FGD Status Reports are a measure of the effectiveness of these actions. Both suppliers

and users have come to recognize the radically different nature of these chemical process installations as contrasted with the predominantly electrical/mechanical character of a conventional power generating station. Difficulties in learning to accomodate and manage these unfamiliar processes must be seen as a real barrier to more rapid industry acceptance. Operating systems are now demonstrating anticipated SO2 removal efficiency. While site specific aspects of sludge disposal continue to be an important consideration in FGD system design, nevertheless favorable experience with fly ash and sludge blending has demonstrated acceptable waste manage

ment.

Cholla I, Arizona Public Service, cited in the IGCI 1975 statement is still operating at efficiency and availability in excess of 90%. Other plants have also achieved high performance levels. On high sulfur coal LaCygne No. 1, Kansas City Power and Light has reported progressive availability of 1974-76.3%, 1975-84.3% and 1976-91.3%. Bruce Mansfield No. 1, Ohio Edison Co. burning 4.7% sulfur coal achieved 94% availability for the last half of 1976.

During the period from April 1975 to the present, continued design and cost reducing process improvements have successfully offset the effects of inflation. Costs have also been controlled by the competitive pressures of the market place, which have increased during the period as additional suppliers have entered the field. Thus contract costs in the range of $50 per kilowatt (equating to $65-70 per kilowatt installed) are still typical. Process improvements have also reduced operating costs through improved limestone utilization and lower energy requirements.

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Low sulfur coal is a satisfactory alternative to FGD in some situations but limits on availability prevent widespread adoption of this approach. Improved beneficiation processes can reduce the size of FGD systems required and in special circumstances can eliminate the need for FGD. Alternative clean coal technologies (gasification, liquefaction and fluid bed combustion) are in developmental stages and still some years away from commercial availability.

Since

From this we

The IGCI 1975 statement cited adequate capacity of the industry. then additional suppliers have entered the field and in fact for one recent bid invitation, eleven responses were submitted. conclude that national FGD needs as now projected by EPA can be met in the early 1980's by the present supplier industry, given an orderly timing of commitments.

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February 17, 1977

Hon. Edmund S. Muskie
Chairman, Subcommittee on
Environmental Pollution

Committee on Public Works
Room 4200 Dirksen Building
Washington, D. C. 20510

Attention: Mr. Haven Whiteside

Dear Senator Muskie:

We are taking this opportunity to express our concern about certain provisions contained within S. 253, Clean Air Act Amendments of 1976. The Interstate Natural Gas Association of America (INGAA) is a national organization representing virtually all of the major interstate natural gas transmission lines in the United States. Our companies account for 90 percent of all gas transported and sold in interstate commerce. All of our companies are subject to the jurisdiction of the Federal Power Commission under the Natural Gas Act (15 USC 717, et seq.). The recently enacted Emergency Natural Gas Act of 1977 (P. L. 95-2) is also directly applicable to INGAA's members. Every one of the lower 48 states with the exception of Vermont is served in whole or in part with natural gas transported by one or more of our companies.

The interstate pipeline companies have about 160,000 miles of transmission lines in operation today. The number of compressor stations on each system will vary from system to system and by the amount of gas being transported in each, but as a general rule of thumb a station is installed about every 80 - 90 miles along the system and more than one pipeline may feed into or come out of a particular compressor station. We estimate that there are over 1,000 compressor stations on major

Hon. Edmund S. Muskie

Page Two

February 17, 1977

interstate lines spread across the country. These stations are necessary to maintain pressure in the pipelines to pump the gas from the producing fields to markets. For the most part, compressor stations are located in remote rural areas and they are chiefly dependent on natural gas being pumped through the line for their fuel. Indeed, few, if any, stations are equipped to burn any other fuel. As you can readily understand, compressor stations are an integral part of a major long-distance pipeline operation and they provide the power for the most efficient and pollutantfree energy system operating in the United States today.

INGAA is concerned with Section 121(a), Section 124 (d) and Section 302(a) adding new Subsection (m).

The basic cause of our concern stems from proposed Section 302(m) which defines the terms "major emitting facility" and "major stationary source" as, except for the purposes of Subtitle C of Title 1 of the Act, "any stationary source or facility which emits, or has a potential to emit one hundred tons per year or more of any air pollutant". The compressor stations along interstate natural gas transmission lines emit more than one hundred tons per year of NOx emissions. Furthermore, the technology is not presently available to construct or operate a compressor to meet the standard outlined in this bill. If such a standard is to govern the operation of compressor stations on natural gas pipeline systems it could have a seriously adverse impact on the continued operation of these pipelines.

During the present winter heating season every American has witnessed the adversities of reduced natural gas deliveries. Thousands of people

have been out of work and an unknown social and economic strain has been experienced by communities throughout the country. Additionally, the lack of a sufficient supply of natural gas this winter has resulted in heavier demands for other less clean fuels. Any arbitrary emission standard such as that proposed in S. 253 could further aggravate an already serious situation. Since natural gas is our least polluting fuel, we believe that its positive contribution to the economic, social welfare and environment far exceeds the possible adverse effects of compressor station exhausts emitting relatively small amounts of NOx to the atmosphere. Natural gas is a clean burning fuel and its contribution to air pollution is insignificant.