quate supply of electricity to meet the requirements of the public. As a case in point, we have experienced great difficulty in scheduling unit outages in order to meet schedules for installing precipitators-for which workable technology does exist on the TVA system.

In the limited time available today, we would like to focus on what we consider the most pressing questions raised by the Clean Air Act. That is a question of how much reliance should be placed on continuous emission limitations and upon stack gas scrubbers as a means of achieving clean air. We do not pretend to have final answers to these questions, but we believe TVA is in a unique position to continue its Federal leadership role in developing workable solutions.

In an effort to keep abreast of the status of developing scrubber technology and, indeed, to continue our participatory role in developing that technology, we have maintained a close working relationship with all of the major U.S. installations and we have investigated the work of others around the world. We maintain contact with, and have sent our technical personnel to, installations in nine foreign countries as well as those in this country. These continuing investigations and our own extensive experience convince us that scrubbers have not achieved the degree of operational reliability that could allow TVA to make a commitment in good faith now to install scrubbers on the TVA system beyond the experimental unit which we are adding at our Widows Creek plant. Time precludes giving a full analysis of our investigations of those scrubber installations now being installed or operating. But if it is agreeable to the committee, we would like to submit such an analysis for the record. [See p. 106.] In addition, I have with me today some of the principal TVA personnel who have made these analyses, and they are available to join me in answering any questions you may have at the conclusion of my

statement.

My statement briefly mentions two of these installations, the Japanese Mitsui Aluminum in Japan and by the Louisville Gas and Electric Co. I will not take the time to speak of those now, but we will answer to them later if you wish.

The key point is that it is not enough to have a scrubber installation that may work under special circumstances in isolated, special situations. If scrubbers are to be a reliable means of controlling SO, emissions, they must be workable in real world situations. They must be usable on very large, coal-fired generating units. They must be able to operate at near continuous levels on base-load units in order to maintain the reliability of the power system. They must work well enough to allow the use of high-sulfur coal resources as an alternative to oil and gas resources which will continue to be in increasingly scarce supply.

Here a related, critical point should be emphasized concerning the alternative method of using low-sulfur coal to protect the public health and welfare from the adverse effects of sulfur dioxide. In many areas, including the TVA area, this option is not available for broad-scale application. In other areas, such fuel switching can be enormously expensive, can make the United States more subject to foreign pressures associated with the energy crisis, and ignores the use of our most abundant form of energy-high sulfur coal.

As the problems associated with the scrubber, state of the art, today are resolved-and here let there be no misunderstanding that TVÄ thinks these problems should and will be resolved-serious environmental and economic questions concerning the use of scrubbers will remain.

For example, limestone scrubbers would consume between 5 and 10 percent of the power produced in the plants on which they are installed, and this additional consumption would further aggravate the Nation's energy problems. Such scrubbers would require the mining and the transportation of tremendous amounts of additional minerals, principally coal and limestone. That is about 10 million additional tons in our system alone. This additional mining and transportation would consume extra quantities of scarce fuel oil.

Manpower, natural resources, and other short supply materials would have to be devoted to the construction of both the scrubbers and the additional powerplant capacity needed to make up for that amount committed to a scrubber operation. Both resource and equipment commitments will add significantly to the national inflationary spiral in a seller's market.

Even after all these resources have been committed and consumed, further environmental problems-water pollution and land use—will have been created. Scrubbers would create literally mountainous problems of waste sludge, a very difficult substance to handle. To date, there are no satisfactory uses for sludge. It is highly unstable and under present technology, it cannot be used as landfill. Therefore, it must be ponded somewhere and continuous efforts must be taken to keep it from contaminating the ground or surface waters.

Scrubbers, besides incurring heavy environmental and energy costs, involve large economic expense. If TVA were to meet the currently applicable constant SO2 emission standards in the TVA area using the most optimum combination of scrubbers and low-sulfur coal, it would require the construction of over $1 billion of scrubbing equipment. The additional cost to the consumers of TVA power would be over $200 million a year. Even under the most relaxed constant emission standards which have been proposed for the TVA area, the optimum combination of scrubbers and low-sulfur coal would cost an additional $150 million each year.

Again, let there be no misunderstanding. We cite the problems associated with scrubbers to illustrate the magnitude of the problemsolving effort needed to make scrubbers a viable means of SO2 emission control. In those cases where scrubbers are the only way in which the public health can be protected, then the energy, environmental and economic costs just mentioned will be the price which may have to be paid to help achieve acceptable national air quality levels, once a workable technology has been proven.

It should be recognized, for example, that a clear distinction exists between existing plants and new sources. The concept of new source performance standards which require the best available technology should be continued.

Similarly, scrubber systems, once developed, may be the only answer in the near term for congested urban and other areas of multiplesource emissions.

But scrubbers are not necessary in all situations in all parts of the country. For example, the sulfur dioxide concentrations around all of TVA's plants are far below both the primary and secondary ambient standards prescribed on an annual basis. Only the short-term, or hourly, ambient standard requirements are ever exceeded, and these only infrequently.

For example, around TVA's very worst plant, burning the coal which we do, and without any kind of controls, the short-term ambient standards are exceeded no more than 5 percent of the time. Around most of our plants, these limits are exceeded less than 1 percent of the time, or not at all.

TVA's sulfur dioxide emission limitation program, an intermittent control technique, will prevent even these few occurrences and allow us to totally meet ambient air quality standards.

Given the fact that ambient standards will not be exceeded, it is also important to note that these intermittent control programs will not result in operations at or near the allowable ambient standard levels. Indeed, with or without such controls, most of the time the sulfur dioxide levels around TVA steamplants are only a fraction of the allowable levels.

The annual cost of this program at all TVA plants will be $17 million, and this includes amortizing the capital costs of new taller stacks at three plants and of the $42 million full-scale scrubber project at the Widows Creek plant.

TVA's method has been tested for almost 4 years at the Paradise steamplant, one of the largest in the world, and in this period ambient standards have been met. TVA has thus demonstrated that State and Federal standards for protecting public health and public welfare can be met by using sulfur dioxide emission limitations programs. TVA is now in the process of developing such programs for all of its plants where the public health or welfare standards can, on occasion, be exceeded and will have them in operation in 1975.

In summary, not only is TVA's plan the only way it can achieve health and welfare standards in time to meet the Clean Air Act deadlines but, as an air pollution control technique, it is also the most reliable and least costly and has the fewest adverse effects on energy conservation and other aspects of the environment.

In taking this position, we recognize that there is currently some concern that suspended sulfates in the atmosphere may be a more serious health problem than sulfur dioxide. However, a connection. between sulfur dioxide emissions and adverse health effects caused by suspended sulfates remains theoretical.

The whole problem of sulfates is a very complex one. Very little is known about how, why or where sulfates are produced, where they go, or how they travel. Many sulfates in the atmosphere are not the result of manmade sources, but occur naturally. Furthermore, it does not appear that all sulfates potentially pose a health problem, but only certain small sulfate particles. This fact alone makes analysis difficult since the total weight of a sulfate sample is not necessarily a good indicator of the amount of sulfate particles which could be harmful.

These conclusions are not just ours. They reflect scientific opinions expressed in a number of recent reports. A report prepared by the National Academy of Sciences for this committee concluded that the present knowledge of health effects affords no compelling basis for lowering the sulfur dioxide standards. Another report, prepared by the National Institute of Environmental Health Sciences, concluded that in order to prevent sulfur dioxide related pollution, more must be known of the atmospheric reactions of sulfur dioxide and other substances in the air because it is possible that further control of sulfur oxides alone could well yield no health benefit. Even two EPA technical reports have cautioned that very little is known about how to control or reduce sulfate levels and that simple control of sulfur dioxide may not be the most efficient way.

In fact, an important aspect of the sulfate problem which has been largely overlooked is whether scrubbers themselves will increase the amounts of sulfates in the atmosphere. The moist conditions characteristic of the scrubbing process will encourage sulfate formation. It could be that although the scrubber removes 80 percent of the SO2, the sulfate concentrations in the area are actually increased.

In short, the sulfate question is a classic illustration of the body of scientific and practical knowledge still lacking, and we believe it is premature to commit so much of this Nation's energy, environmental and economic resources to take an action which only might solve a problem which only might exist.

TVA scientists and others, however, are moving to fill this void of scientific knowledge. TVA is already undertaking extensive atmospheric chemistry studies, in both the field and the laboratory, to determine the nature and causes of the chemical reactions which take place in our powerplant gases. Through this research we hope to learn, among other things, how sulfate particles are produced, where they go, and how they can be controlled.

Finally, and overall, what we are suggesting is a broad scale approach to meeting the quest for clean air-an approach which does not exclude the use of alternate controls or scrubber technology; an approach that does not mandate scrubbers as a universal answer to the Nation's clean air problems but recognizes their potential usefulness to meet clean air standards; an approach that does not restrict the use of all workable and reliable methods of meeting those standards.

At the same time, this approach calls for continued and accelerated effort to make scrubber technology workable and reliable, to replace theory with fact concerning the atmospheric effects of sulfur dioxide emissions, and to develop the necessary clean fuels technology that will truly give us an across-the-board approach to achieving the ultimate goal. That goal is the clean air, now and for the future, in compatible tandem with a continued supply of energy to sustain the Nation. It is to this goal that TVA is committed.

Senator MUSKIE. How many coal-fired plants does TVA operate? Mr. WAGNER. Twelve.

Senator MUSKIE. With respect to how many has EPA mandated scrubbers?

Mr. WAGNER. We are working with EPA at the present time to find out what their specific proposals are. Scrubbers would have to be placed on most of these plants in order to meet the emission standards which the States have set and EPA has approved. We will have to burn essentially the same coal which we do now, and if we were to meet the continuous emission standards in our situation we believe it would take scrubbers at most of our plants. It may be at some of them we can do it with a combination of low sulfur coal and some other activities, but the best we can determine is the cost to us in our system would be $1 billion for the best combination of low sulfur coal and scrubbers we could put together and the annual cost would be $200 million.

Senator MUSKIE. I am still not clear on that point. I gathered from your statement that it was EPA's policy to require the installation of scrubbers on all your coal-fired plants. Is this the case or not?

Mr. WAGNER. We have recently had a conference with EPA and we have a group of people working with them now examining each plant to determine what precisely it is that they feel we would have to do. Senator MUSKIE. Specifically, how many of your plants have been ordered to install scrubbers, or with respect to how many of your plants has EPA in writing suggested that you need the scrubbers? Mr. WAGNER. We have had no suggestion for any number of them, either by order or in writing.

Senator MUSKIE. So at this point there is no such mandate?
Mr. WAGNER. No, sir.

Senator MUSKIE. Is it your impression, and if so on what basis, that within some short period of time you will be required to install scrubbers on all your plants?

Mr. WAGNER. We know the quality of coal that we burn and the amount of sulfur in it. In order to meet emission standards we would have to install scrubbers or use some technology which we think is not available. We simply couldn't meet the emission standards. We can meet the ambient standards.

Senator MUSKIE. Again you seem to be anticipating an eventuality that hasn't yet been spelled out. I would like to know precisely what EPA has said you are likely to be required to do with respect to these 11 plants. Are you just talking about ghosts in the closet or have you something specific that EPA has told you or written you or required of you that would give us some idea of the extent of the burden that EPA intends to impose on you?

Mr. WAGNER. The gentleman who has been handling this work with EPA for us most directly is Dr. T. L. Montgomery, who is here with me. Let me ask him if he can give you more specific information on that than I can. He is the chief of our Air Quality Branch in our Division of Environmental Planning.

Senator BAKER. Before he starts, could I ask Chairman Wagner a question?

Senator MUSKIE. Of course.

Senator BAKER. I have been trying to shuttle back and forth between this subcommittee hearing and the full committee executive session on the markup of a bill we have before us.