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Table C-4

STATE-BY-STATE COUNT OF 1976 SO2 NON-ATTAINMENT STATIONS

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1.

Unconstrained by annual SO2 standard.

2. Includes 58 non-attainment stations with both TSP and SO2 violations. Those S02 non-attainment states with the greatest apparent potential are Illinois, Tennessee, Arizona, Ohio and Montana.

Source:

Based on data collected from Air Quality Data 1976 Annual
Statistics (Research Triangle Park, NC, U.S. Environmental
Protection Agency), March 1978.

C-6

S. 2470-AN AMENDMENT

Section 3 of the Powerplant Fuels Conversion Act of 1980 is amended as follows: "Renumber Section 301(d) of the Powerplant and Industrial Fuel Use Act as Section 301(d)(1).

"Add a new Section 301(d)(2), following Sec. 301(d)(1), the text of which is as follows: '(d)(2). SELECT USE OF NATURAL GAS IN CONJUNCTION WITH COAL TO OFFSET INCREASED EMISSIONS FROM COAL COMBUSTION. Nothing in the Powerplant and Industrial Fuel Use Act of 1978 or the Powerplant Fuels Conservation Act of 1980 shall be construed to prohibit the use of natural gas in electric powerplants, that are converted from oil or natural gas to coal as a primary fuel, to the extent that such use of natural gas in conjunction with coal use in a common facility, will offset increased emissions from coal combustion."

Justification

This amendment is carefully drawn to permit the powerplants listed in Phase I to convert from oil to the select use of natural gas in conjunction with coal, in order to prevent net increases in the levels of sulfur oxides and other air pollutants. Natural gas, which emits virtually no sulfur oxides or particulates when it is burned, can be used to offset increases in air pollutants that would otherwise be expected when the powerplants listed in Phase I are converted from oil to coal as a primary fuel. This new language gives the Phase I powerplants the option of burning just enough natural gas in their converted coal-fired units to prevent net increase in air pollutant emissions to the extent separately prescribed by law. Although coal would be the primary fuel of a converted Phase I powerplant, just enough natural gas could be burned-simultaneously in adjacent boilers, alternately in the same boiler, or in mixtures that physically combine the two fuels-to offset increases in air pollutants from coal conversion. This simple and efficient option can be invaluable in stabilizing the overall level of air pollutants, most particularly, sulfur oxides. It should be stressed that this amendment does not permit any Phase I powerplant currently burning oil to burn natural gas as a primary fuel. It is designed to enhance the prospects for coal conversion by allowing Phase I powerplants to burn coal in a way that minimizes environmental damage.

Senator DURKIN. Mr. Poundstone.

STATEMENT OF WILLIAM N. POUNDSTONE, EXECUTIVE VICE PRESIDENT, CONSOLIDATION COAL CO., PITTSBURGH, PA., ON BEHALF OF THE NATIONAL COAL ASSOCIATION

Mr. POUNDSTONE. I am William Poundstone, executive vice president of Consolidation Coal. I am here today as a witness for the National Coal Association.

I have a very detailed statement, so in recognition of the late hour, I will completely leave that text and try to make just a very few points and let the written testimony stand.

We have heard here today a number of people state that there are things yet unknown about the acid rain, but my own investigation of the situation leads me to believe that perhaps there is even less known than is generally conceived.

I heard a number of statements today that indicate knowledge in fields that, at least in my mind, I'm not sure are known facts. I would like to point out two or three of these things and show how the significance of the state of knowledge in arriving at what would be a sensible regulatory answer for the country.

Senator DURKIN. Well, it is sort of like the blind man feeling the elephant: I mean, we really don't know quite what we have brushed up against.

Mr. POUNDSTONE. I think that's right. The first one it seems to me is a very basic issue but, in my mind at least, is still in disagreement, and that is whether or not the rain is even becoming more acid.

We have heard a great deal of conversation about the fact that the rain is 500 times more acid, tenfold times more acid.

But an analysis made by both EPRI and ourselves of the data in this country and the data in Europe comes out far from being conclusive.

If you look at the only data that has been sampled from the same point by the same sampling method-and admittedly there is a relatively small amount of it-that would indicate a very steady amount of acidity over a period.

Senator DURKIN. Dating back to when?

Mr. POUNDSTONE. Well, the further back you go, the less good data. But we have attempted to go back into the literature and look for studies made.

One that we ran across, for instance, in Paris in the year 1852, long before a pH meter was invented, a chemist measured the levels of acidity.

And by taking his amounts and relating it to pH, it appears that the-that Paris, in 1872 had a pH of 4.

Senator DURKIN. But wasn't that somewhat contemporaneous with Pasteur's discoveries? I mean, I just have some fairly substantial problems with the thesis that it hasn't gone up in the age of the monks-

Mr. POUNDSTONE. I would ask, sir, what is your reason for saying that? It's because the mental process or it's because of the conceived notion that has been advanced to explain the problem of acid rain.

And when you look carefully at the

Senator DURKIN. But is not your base period beginning about the time Copernicus was burned at the stake for his teachings? I'm just wondering what-

Mr. POUNDSTONE. Well, all I can say is that when you look at the only good data both in this country and Europe, we can't find evidence that the rain is becoming more acid.

Now, admittedly, in Likens work, which is the principal source of this belief, he picked three 1-year periods and presented iso-pH

maps.

But there are only a handful of samples that were taken in the same place in these periods. And we know from other data that I could develop for you that a move of even 50 miles in the sampling point can result in an enormous change in the amount of acidity because of changes in the amount of rainfall that occurred at those points and because of other local sources of pollution that affect the rain.

The significance of what I'm saying the point I want to make is this: If, in fact, the rain has become, let's say, 500 times more acid over a 20-year period, then there is some urgency to the problem.

But in my mind, if, in fact, the rain is-has been uniform over the period-and we all, I think, have agreed-the EPA has agreed-that the new plants are very tightly controlled. We are using new plant control methods that are destined to see that what we build beyond this date has the thing under control.

It does bear in my mind on the importance of further control on the existing plant. So, I think one of the things that we must do is to determine is it more acid today than it was before.

The next one I have not heard one word mentioned here today about it. There has been a lot of discussion of the amount of sulfur emissions, but I have not heard one word of the amount of naturally occurring SO2 and NO.

And if, in fact, the cause of the rain is SO2 and NO,-and I don't deny that-the next question is how much of it comes from natural

sources.

Now, we have made a conscious effort to try to determine what are the amounts of SO2 and NO, that occur naturally. And there are a number of papers in the literature that would indicate, on a worldwide basis-that's not the subject we are discussing, but on a worldwide basis at least, the amounts of SO2 may be from twothirds to 70 percent from natural sources.

And in the case of nitric oxide, it's probably more on the order to 90 percent.

Lightning, alone, may be half of the NO, problem. Again, the signficance of this in my mind and why I think it is important that we find these things out is that we have been concerning ourselves with relatively small increases, but increases in only part of the total loading.

And I think the impact that you are going to expect is going to be somewhat influenced by how much natural is there.

Senator DURKIN. Well, I'm a little bit confused. I mean, New Hampshire is the granite State. There is a certain amount of radioactivity and radiation that are naturally in granite.

But you would not argue that we not be concerned with radiation?

Mr. POUNDSTONE. No, sir, but to the extent it affects your decision on control technology, I think it is important enough. We may be going at controlling the wrong thing is all I want to suggest to

you.

Senator DURKIN. Well, do you have any problems with the acid rain title in the conference report?

Mr. POUNDSTONE. I'm not sure I'm aware.

Senator DURKIN. I'm a bit confused, and maybe it is the hour. And we have all been here a long time. But, I mean, you are not arguing against studying the acid rain problem?

Mr. POUNDSTONE. No, sir, I am advocating a study, but I'm advocating a study before we elect control strategy. And what I'm concerned with I see the signs of us jumping to further control, SO2 on existing powerplants.

And I'm not at all confident that we fully understand the damage it is doing nor am I confident that the control is, in effect, going to make a significant reduction in the levels of acidity. Senator DURKIN. Then, what do you advocate?

Mr. POUNDSTONE. Well, I'm saying there are a number of key facts that need to be determined. Some of these I think perhaps can be determined by a very careful examination of existing data, worldwide, as well as in this country; some other things will need additional research undertaking, additional testing, additional sampling.

Senator DURKIN. Before any controls are recommended?
Mr. POUNDSTONE. In my judgment, yes, sir.

Senator DURKIN. I mean, you must admit that something is going on out there. Something is happening. And the acid levels are going up-

Mr. POUNDSTONE. Sir, I did not say that. I said they may not be going up. They apparently are going up. But if you look at, as I say, the only good data in this country and in Europe, there is no indication that they are going up.

So, you see the significance of the point I make.

Senator DURKIN. There is no indication they are going down, is there?

Mr. POUNDSTONE. No, sir. I didn't

Senator DURKIN. I didn't say that you said that. I mean, maybe-

Mr. POUNDSTONE. Would you agree with me that that is a significant thing to know, if it's going up or if it is staying level? Doesn't that seem to be a pertinent thing to know before we make a decision?

Senator DURKIN. Well, we have had testimony already today that some of the scientific community thinks there is an increase.

Mr. POUNDSTONE. Yes, sir. And what I'm doing here is challenging those statements.

Senator DURKIN. Yes, but on the basis of some French monk who was wandering around on the farm-

Mr. POUNDSTONE. No, sir, that's not correct.

Senator DURKIN [continuing]. With some sort of esoteric device. I have to question that just slightly.

Mr. POUNDSTONE. Well, if you will read my testimony in detail, you will find a good deal more reasoning in support of what I have said.

But the coal industry feels strong enough on this issue that I would say that they are in the process of establishing what will be the largest network of rain-sampling stations in the country; it will be in the number somewhere in between 45 and 70 stations that will be scattered throughout the country.

My own company has been sampling rain in three locations for some period of time, ourselves, in an effort to get verification or in an effort to understand this problem.

And I can assure you, sir, that the remarks I make are not facetious or not off the top of my head

Senator DURKIN. I don't think anyone sat here all day waiting to testify to make facetious remarks, and I am not suggesting that. And I wish Senator Domenici were here. I know he's got a busy schedule.

But I guess that what I perceive is the thrust of your testimony is that we not do anything to control a potential problem until it is full blown.

Mr. POUNDSTONE. At the heart of my argument, sir, is this: I think we must be satisfied that we have a problem. We must be satisfied that the solution we adopt for that problem can be expected to make a reasonable contribution to a solution.

And in my mind, both of those issues are somewhere in doubt. That is the basis of what I am saying.

Senator DURKIN. But on the basis of the best available technology, should we not utilize it? I mean, if Henry Ford waited until he

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