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sole supply in the emergency. During this past heating season, July 1, 1966 to June 30, 1967, approximately 75 per cent of all residual fuel oil consumed in the Washington Metropolitan Area was delivered through the Anacostia River inland terminal. Peak daily delivery was in excess of 1,500,000 gallons.

The balance, or approximately 25 percent, of the residual fuel oil consumed in the Washington Metropolitan Area during the 1966– 1967 heating season was delivered by truck from storage facilities located in Baltimore, including to the aforementioned 410,000 gallon storage located in the Washington Metropolitan Area.

The total residual fuel oil consumed in the Washington Metropolitan Area is approximately 250,000,000 gallons per year. This includes 71,400,000 gallons per year for Federal and D. Č. Government installations which were terminalled through the Anacostia River inland barge terminal.

How is 1 percent sulphur content residual fuel oil made? As stated before, 1 percent sulphur content residual fuel oil reduced from 3 percent or 2 percent, or even 1.5 percent, cannot be obtained by merely turning on a faucet or by any simple process. Excluding the Soviet Bloc, of the approximately 75,000,000 barrels per day residual fuel oil produced in the entire world, only 1,000,000 barrels daily is naturally-occurring 1 percent maximum sulphur content, and this is produced in Africa and Argentina. The East Coast of the United States alone consumes 1,170,000 barrels daily of residual fuel oil. Thus, the East Coast alone could consume the entire production of naturallyoccurring 1 percent sulphur content residual fuel oil, which would leave none available for the rest of the United States, or the rest of the entire world. New York City alone requires approximately 300,000 barrels of residual fuel oil daily.

The balance of the low sulphur content residual fuel oil is currently obtained through a refining and blending process.

The bulk of residual fuel oil consumed on the East Coast of the United States comes from Venezuela refineries and the sulphur content of this residual fuel oil runs about 3 percent. Currently, because of special handling techniques, 2 percent sulphur content residual fuel oil has been made available to the Washington Metropolitan Area for the heating year July 1, 1967 to June 30, 1968. This reduction is accomplished by a special refining process and by blending low sulphur residual from Africa or Argentina with the Venezuelan produced residual at the refineries located in the Caribbean area.

Another means of reducing the sulphur content of residual fuel oil is through vacuum distillation and hydrosulfrization. The only facility of this kind now in operation in Cities Service located at Lake Charles, Louisiana, capable of producing only 2,500 barrels daily, except this facility is not used primarily for desulfurization, but to upgrade residual fuel oil into synthetic crude oil. The desulfurization accomplished in the process is merely a by-product.

Shell Oil, in anticipation of the air pollution problems in the major East Coast cities and the possible restrictions to be involved in using lower sulphur content residual fuel oil, commenced more than three years ago to plan and construct in Venezuela a desulfurization plant at a cost of approximately $25,000,000, which will not be in operation until October, 1967 and will have an ability to manufacture approximately 60,000 barrels of residual per day. This plant, however, is currently geared to produce 2 per cent sulphur content residual fuel oil, and will not be able to produce 1 per cent sulphur content residual fuel oil until mid-1969. It is understood that Esso has plans to construct a desulfurization plant in the Caribbean, but construction is not yet commenced and it is estimated this will not be in operation until 1970. The only other desulfurization plants under way are located in Kuwait and Japan but these facilities will not be completed until 1968 and 1969, and in any event would not supply the U.S. consumer. Shell, however, has two other such desulfurization plants on the drawing board for possible installation in the Caribbean area.

In view of what has been stated here, it is our firm belief that 1 per cent sulphur content residual fuel oil just cannot be supplied to the entire Washington Metropolitan Area, or even to the entire District of Columbia, earlier than the heating year commencing July 1, 1969.

Aside from supply, what are the additional problems? In addition to supply, there are other problems with which the local industry would have to cope until a sufficient quantity of 1 per cent sulphur content residual fuel oil could be made available to the entire Washington Metropolitan Area.

This revolves around the fact that different percentages of sulphur content residual fuel oil cannot be commingled at any stage of handling.

For example, a recent Montgomery County Air Pollution Ordinance calls for 1 per cent sulphur content residual oil by January 1, 1968, just 5 months from now. Approximately 39,336, 500 gallons of residual fuel oil are consumed annually in Montgomery County. The Federal Government's supply contract for the heating year July 1, 1967 to June 30, 1968, which was let prior to the passage of the Montgomery County Ordinance, covering 71,400,000 gallons annually, of which 12,137,000 is in Montgomery County consumers, pursuant to contracts also let prior to the passage of the Montgomery County Ordinance, will be supplied 2 per cent sulphur content residual fuel oil for the heating year 1967–1968, commenced as of July 1, 1967. A Falls Church, Virginia proposed air pollution ordinance calls for 1 per cent sulphur content residual fuel oil by January 1, 1970.

If the Piney Point deep water terminal and the Anacostia barge terminal were to terminal 2 per cent and 1 per cent sulphur content residual fuel oil for consumers in the different areas of metropolitan Washington, it would have to construct two more tanks at Piney Point of approximately 270,000 barrels each for the 1 per cent residual plus a separate pipe system of more than 6,000 feet to transfer the 1 per cent residual separately from shipside to the separate storage tanks. This would be necessary so a tanker load of 10,000,000 gallons of 1 per cent residual could be received and stored at any time and still have a reserve. The cost of such additional facility would run approximately $600,000. In addition, at least one storage tank capable of receiving and handling at least 1,000,000 gallons of 1 per cent residual separately from the 2 per cent, would be required at the Anacostia barge terminal. Barge and truck facilities would have to be segregated just to handle the 1 per cent residual. Our company, as the owner and operator of these terminals does not see the point of making such an investment, which would be required only for a temporary period of less than two years, because if the Oil Industry's realistic gradual sulphur reduction program is adopted so that 1 per cent residual is available for the entire Washington Metropolitan Area by July 1, 1969, segregation by that time would not be necessary. Besides, and more importantly, there is no additional land available at the Anacostia barge terminal on which to construct such a segregated facility, nor is there known to be available any other location on the Anacostia or Potomac River within the District of Columbia to construct any segregated facility solely for the purpose of handling 1 per cent sulphur content residual fuel oil.

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It is further understood that there are probably no storage facilities available to Baltimore which would permit segregation of the 1 per cent sulphur residual.

It is also a mistake to assume that all 1 per cent sulphur content residual fuel oil on the market today can be used in the same facilities currently using 2 per cent residual. This depends entirely on the properties of the particular 1 per cent residual supplied, especially the pour point, which now averages about 35 degrees-45 degrees. Some 1 per cent residual has a pour point of 80 degrees or higher but this is used by large utility generating facilities which have specially constructed heating equipment, such as steam tracers on the pipelines, to handle such a high pour point. Apartments, office buildings, schools and hospitals do not have such special equipment. Thus, to simply designate 1 per cent sulphur content residual merely to require a low burning sulphur for air pollutant purposes is not the complete answer. Other specifications of the 1 per cent sulphur residual must also necessarily be considered.

There is also a misconception that the percentage of sulphur content in residual fuel oil controls the visible emission of the pollutant into the air. The sulphur content has little or nothing to do with the visible emission but sulphur content is one of the items in the air which can be measured. Visible emission is principally a problem of the quality, condition and maintenance of the fuel burning equipment.

The difference in smoke emission between 2 per cent and 1 per cent sulphur content residual would not be discernable to the naked eye. Nor could the difference in odor be detected. I would like to digress at the conclusion and have Mr. Via make a few remarks on stack emission.

In conclusion, and in view of the aforegoing, the Oil Industry in the Washington Metropolitan Area recommends that any Air Pollution Control law or regulation effective for any area or district of the Washington Metropolitan Area adopt a gradual sulphur content reduction program for residual fuel oil of a maximum of 2 per cent to July 1, 1968, 1.5 per cent for July 1, 1968 to June 30, 1969, and 1 per cent commencing July 1, 1969, in order to coincide with the realities of the supply and distribution problem for residual fuel oil in the area. It will be catastrophic for each individual local government in the area to adopt different effective dates for 1 per cent suphur content residual because, even if some supply were available segregation is not only economically infeasible but probably an impossibility.

It is also believed that under the proposed gradual reduction schedule, the Oil Industry can supply lower sulphur content residual fuel oil to its consumers at a limited increase in cost and without otherwise disrupting all related economic factors.

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Certainly the Oil Industry, as well as the consumer, should be permitted this relatively short time to meet regulatory standards, which are somewhat debatable.

We would therefore recommend that Section 9(c)2, of both H.R. 6981, by Gude, and H.R. 10017, by Horton, be amended to read as follows:

(2) No person shall use fuels the sulphur content of which exceeds the following percentages by weight: Effective Date. From effective date of law to June 30, 1968, maximum sulphur content, 2 per cent. July 1, 1968, maximum sulphur content, 1.5 per cent. July 1, 1969, maximum sulphur content, 1 per cent.

I thank you, gentlemen, for your patience. I would like to ask Mr. Via to make a few brief statements on stack emissions.

Mr. MULTER. We have three other witnesses whom we would like to hear, and time is running out.

Mr. Counts. This would take just a few minutes.
Mr. MULTER. I would appreciate it if you would be very brief.

Mr. Via. Gentlemen, residual oil-properly burned-does not smoke. Smoke is the result of incomplete combustion and is principally caused by an insufficient amount of air mixing with the fuel being burned. Smoke can occur with the burning of all fuels.

"Perfect" combustion is that in which all of the combustible is burned while supplying only the exact amount of air to complete the reaction. In actual practice this condition is never attained and additional air-beyond the theoretical requirement is supplied to insure that combustion is complete. If this additional air is not supplied in sufficient volume-incomplete combustion and smoke results. This is not the fault of the fuel, rather it is the fault of the equipment burning the fuel.

In practice, good combustion requires three things: A. proper proportioning of fuel and air, B. thorough mixing of fuel and air, and, C. initial and sustained ignition of the mixture.

Residual oil can, and is being burned completely, efficiently and with practically zero smoke. This is accomplished when quality equipment is being used, properly installed, and properly adjusted to supply sufficient combustion air

to burn all the fuel. The time of greatest potential for smoke emission occurs on a cold start-up. That is, when the burner first fires into a cold combustion chamber and stack.

But even here, if the combustion cycle is so designed so that the start-up occurs on "low fire” and remains on "low fire” until the combustion chamber refractory is heated to a point where it assists in supporting combustion—and then the burner switches to a "high fire” condition-incomplete combustion and smoke can virtually be eliminated.

Once the combustion chamber is hot-repeated cycles of the burner occur 'with a crisp, clean ignition--and produces no smoke. The combustion equipment, of course, inust be serviced and maintained at a high efficiency just as an automobile must be checked and serviced to keep it running well.

Last winter and spring, under the close supervision of a committee of Department of Health, Education, and Welfare-headed by Mr. Jack Copeland—a survey was taken by the Steuart Petroleum Company on some 20 installations of residual oil burning equipment

here in Washington, D.C. The results of that survey point out and prove that residual fuel oil can and does burn cleanly.

The amount of sulphur in a fuel has no bearing whatsoever on smoke emission. For example, a fuel with a high sulfur content-say 5 percent-can be made to burn without sufficient combustion air.

For a fuel with 2 per cent sulphur, only about .15 per cent of sulphur dioxide will be found in the stack gasses and only .002 per cent by volume of sulphur trioxide might be found.

This gas is normally invisible and only under rare cases can it be seen in the form of a white water vapor. Normally, however, the white vapor seen on a cold day coming from the top of a stack is the result of hydrogen burning which has no pollutant or detrimental effects. It is immediately reabsorbed by the atmosphere.

Quality equipment is available today from a variety of manufacturers which has been designed and field proven to be capable of burning residual oil completely, efficiently and cleanly. It must merely be installed and adjusted properly.

I repeat-residual oil properly burned-does not smoke.
Thank you.

Mr. MULTER. Is there any sulphur pollutant emitted in the air by the burning of gas?

Mr. Via. Yes, sir.
Mr. MULTER. How about coal?
Mr. VIA. Yes, sir.

Mr. MULTER. Do you have any figures on the different quantities of sulphur emitted by burning gas, oil and coal ?

Mr. VIA. I do not have them with me at the moment, sir, but I can submit them.

Mr. MULTER. Will you submit them to us?
Mr. Via. Yes.
Mr. MULTER. Thank you.

Mr. Winn. Mr. Via, you state that the local oil industry recognizes that the burning of fuel contributes to air pollution. At the same time you maintain it does not play a dominant role that some would lead us to believe.

I was going to ask Mr. Counts to enlarge on that. Most of the witnesses that we have heard at the last hearing felt that fuel did contribute to air pollution and they had some facts and figures to back this up.

Mr. Counts. We believe that motor vehicles, buses, diesel vehicles, gasoline, trash burning, and other things play a very dominant part and that the stack emissions from heating equipment in this area are not as dominant as has been represented.

Mr. Winn. Then we are to believe, in our opinion, that stack emissions are negligible compared to automobile and buses, and other methods of air pollution?

Mr. Counts. I don't know about "negligible.” But, I would say they are minor compared to these other sources. Particularly in good operating equipment.

Mr. WINN. Mr. Via's statement didn't lead me to believe that because he was so firm and so strong in it. He also had figures that mentioned "If.” If everything was working right. If everything was burned right. And if they had the right equipment. Then it could be controlled.

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