recognizing the wide variety in terrain, meteorology, and land use that exists between various areas.

In previous statements to the House Subcommittee on Health and Safety and your committee, I have expressed concern lest the enforcement provisions of the Clean Air Act result in Federal intereference with the functions being adequately handled by local and State agencies. I don't intend to repeat in full the comments previously given to your committee. I do, however, find encouragement in the revisions made in the act before final passage and in my conversations with the chairman, the Surgeon General, and members of his staff, giving assurance that there is no desire to have the Federal Government step in except where the need for such a step is clearly urgent.

You may be certain that Con Edison will continue to cooperate with local authorities and others who may have jurisdiction, to assure that we all do our part in the fight for cleaner air. Thank you again for the privilege of appearing before your committee.

Senator MUSKIE. I am impressed by the extent of Con Edison's activities here on this island. I was not aware that these skyscrapers were so helpless.

Mr. MINASIAN. I think the commissioner would say that he is glad. Senator MUSKIE. The idea of all these tremendous buildings being heated from one source captures the imagination. I think that you are to be complimented for what you have done to control your own pollution sources.

I have just one question that I would like to ask, and that is, What, if anything, have you been able to do, or, what are you doing, if anything, to control the emission of sulfur oxides?

Mr. MINASIAN. Well, fortunately, on the situation here in New York, that has not been a serious problem for us; and, when I say "fortunately," there is sulfur, naturally, in our fuels, in our coal and in our oil.

However, with our high stacks and with our relatively high velocities and temperatures of our stacks, we have been unable to determine-and we have made many tests; we measure SO2 and, also, we have been monitoring SO, content-but we have not been able to hardly detect SO2 as a source at the areas or at the levels where people live.

But, again, you don't just sit back and say that you are not going to look forward to what may happen in the future. This is not a dead city. We are still growing, not only up, but in many, many ways, and tremendously in the use of electricity.

We believe that we should be part of all research to find ways of cutting down on any of the pollutants that may be attributed to us as the city grows and as concentrations increase.

But, so far, it has not been a problem for us. Our answer has been the high stacks and the diffusion.

Senator MUSKIE. How high do your stacks go?

Mr. MINASIAN. They are 400 feet. That is generally a minimum. They go to over 500 feet. The one exception is Astoria, which is near La Guardia Airport, and they are 300 feet. They have special nozzle arrangements to increase the velocity at the top of the stacks.

Senator MUSKIE. With that stack velocity are you able to stop a thermal inversion?

Mr. MINASIAN. So far, we have. You are probably familiar with what has been done over in London and perhaps the experiments that they made with the penetrating of the ceiling on the inversion.

They have this Operation Smoke Plume, which was very interesting to me; and, also, having been over there, they had the sulfur removal processes on their stacks, and then, when they had one of these very bad inversion periods with the ceiling right down at a very low level, they had arranged for planes from outside the area to fly in and take pictures.

So that they could identify the plants, they colored the effluent from the stacks. One was a purplish color and one was a red and a sort of orange color, various colors.

As they went over London following the Thames, the only ones that penetrated were those which did not have the control, the sulfur control equipment in it.

The answer was, obviously, that in the cooling process of the methods that they were then using, why, whatever did come out stayed down, whereas the relatively warmer and higher velocity gases penetrated. They have those colored pictures, and you can see them punching right through.

That must be about what the situation is here, although, fortunately, inversions are rare.

Senator MUSKIE. You make no efforts to remove the sulfur from your stack gases or from your fuel?

Mr. MINASIAN. No. We have not found any method that seems to work. We do get relatively good low sulfur coals for use here in the city, and we are certainly interested in that.

Senator MUSKIE. It seems to me that in the testimony in Boston yesterday from the Edison Co. there, that they testified-it might have been some other company-that they were using dolamite to try to control the sulfur in the stack gases. That is, they blew it in the combustion chamber and found that this did give them some reduction of the sulfur oxides.

Do you know anything about that?

Mr. MINASIAN. Well, I do, just from reading about it, and also in talking to our engineers. There are two of our engineers who are going to one of the plants in Florida that has used some of these methods of additives and what not to see how that works out.

We certainly want to be up to date on anything that comes along in that field, again, being forewarned to look ahead.

I did not know that Boston Edison had actually used it, but we have tried some things just on an experimental basis, but it is not a regular practice and, I must confess, because the need has not been demonstrated.

Senator MUSKIE. We are interested in getting as much useful information here for use in other areas, too, as we can.

Would you say that the most fruitful area for research dealing with the sulfur oxide problem would be methods of dealing with the stack gases rather than further reduction of the fuel itself?

Mr. MINASIAN. So far, again, from reading the material, including the document that came out of Cincinnati on various methods of sulfur removal-I guess that is almost a year and a half or 2 years ago it still seems that the concentration on the reduction of the sulfur content in the fuels would be, perhaps, the one that would come along first.

But, they indicated then, and it seems to be so today, that this does not seem to be any quick answer.

The methods so far have so greatly increased costs of the fuelwhich, of course, in our case, is eventually borne by the customer; but we are interested. I think it is the Bituminous Coal Institute, together with the Edison Electric Institute and the Association of Edison Cos. who have been interested in research on coal and the possible lower cost methods of removing that.

Again, as some of us have mentioned in the research field, which we feel the Federal Government has done a remarkable job in, I am sure that they are well aware of the fact that they must avoid duplication in that field because a great deal has been done.

Senator MUSKIE. What fuels do you use?

Mr. MINASIAN. We use the term that we burn something over 10 million equivalent tons of coal a year; and, of that, about half is in actual coal, bituminous coal, and all of that is a powdered fuel, which is easiest to control from an air pollution standpoint.

In our electric stations, we no longer have stokers. Even in the old plants that we took over from the city, those have all been converted to other fuels. There are no stokers left in them.

Senator MUSKIE. Why do you use the two? Why do you use both fuel oil and coal?

Mr. MINASIAN. Well, the cause of it is the economy and, also, to have the ability to change from one to the other. At present, as you know, we have a tug strike in New York City, so that we have to plan our supply of fuel so that we can go rather easily from one to another.

I was just going to say that, of the other half of the fuel that we use, about half of the remainder or 25 percent of the total-this is in round figures-is in fuel oil, and the other is in natural gas.

Now, the trouble with natural gas is that we could not depend on it the year round. You get cold days, and it is needed for our gas days. But in the days of relatively low use, we can burn that in our boilers. It so happens that from a purely British thermal units per kilowatt-hours the gas is the least efficient, but it is also the easiest to handle and the cleanest.

Senator MUSKIE. Thank you, Mr. Minasian, very much for your testimony.

Now, I will go along to Mr. Chalker. Do you have a prepared statement to submit?

STATEMENT OF WILLIAM R. CHALKER, MEMBER, AIR QUALITY COMMITTEE, MANUFACTURING CHEMISTS' ASSOCIATION

Mr. CHALKER. Yes, sir.

Mr. Chairman, my name is William R. Chalker. I work for a chemical company as a consultant in the field of air pollution prevention, and will speak as a member of the Air Quality Committee of the Manufacturing Chemists' Association.

Our association is a nonprofit trade organization representing 186 U.S. firms, large and small, which, together, represent more than 90 percent of the productive capacity of the chemical industry in the United States.

I intend to speak about industry from two standpoints: One, how the chemical industry is meeting its responsibility in the control of

air pollution; and, two, how the Clean Air Act will assist the chemical industry in meeting its responsibilty.

Let us consider, first, the chemical industry's responsibility. I would like to give you some examples of our activities and accomplishments in protecting air quality.

For instance, the chemical industry uses about 20 percent of the bag dust collectors and catalytic combustion units sold in the United States. We use about 35 percent of all liquid scribbers, and about 20 percent of all electrostatic precipitators.

The Manufacturing Chemists' Association established an air quality committee 15 years ago. This has helped to focus our attention and gives us a constructive viewpoint toward recognition of the research. technical, and administrative problems that must be solved if our public control programs are to be reasonable and scientifically based. In 1951 our committee wrote an air pollution abatement manual, which covered all facets of air pollution measurement, analysis, and control. Its purpose was to accumulate the then current knowledge about air pollution under one cover where it could be applied readily to anyone's problems.

Over 85,000 copies have been distributed. For a number of years. this privately published manual filled a gap in available information on the subject.

From the time of the enactment of the first Federal air pollution law in 1955, our association has maintained a liaison with the Public Health Service.

Our members have attended their conferences, participated in their training sessions at the Robert Taft Sanitary Engineering Center, held joint meetings with them to exchange views, and, in some cases, Public Health Service officials have visited chemical companies to acquaint their managements with the Federal programs and, in turn, to hear about the programs that these companies have.

As an outgrowth of these mutual activities, Manufacturing Chemists' Association asked Mr. Vernon G. MacKenzie, Chief of HEW's Division of Air Pollution, what we could do to help. He suggested that Manufacturing Chemists' Association and Public Health Service undertake a joint study of the air pollution situation associated with the manufacture of several chemical products.

Agreement was reached and a joint study was undertaken. We are now nearing completion of a report covering atmospheric emissions from sulfuric acid manufacturing plants.

Our association has recently compiled some figures on the air pollution prevention efforts of 125 of our member companies. This study determined that we have invested about one-quarter of a billion dollars in air pollution control facilities, and spend $34 million per year to operate the equipment.

I think the manpower used is highly significant. For each of our plants, there is, on the average, one to two men whose full-time job it is to operate and maintain these air quality protection facilities.

In addition to the quarter-billion-dollar investment in direct control equipment referred to above, our industry has carried on extensive development efforts and engineering studies, and made substantial investments in equipment to avoid the creation of potential pollutants. For example, substitutions have been made in raw materials which have necessitated design changes in the equipment.

It is impossible to separate this type of investment from the production facilities themselves, but it is believed they are of the same magnitude as the quarter-billon-dollar investment in control equipment.

In my own company, this effort has been given the same high priority as we give to our employee safety and fire prevention programs. In the 1960 report by the Surgeon General's ad hoc task group on air pollution research goals, the committee recommended that by 1963-64 industry should be spending about $6 million per year on air pollution research.

The chemical industry certainly appears to be holding up its end on this score. Our study shows that the same 125 companies in the chemical industry are, in fact, spending $3 million per year, or about 50 percent of the total industry goal called for.

I would guess that the total industry expenditure at present for air pollution research is probably considerably above the $6 million goal set by the Surgeon General's committee in 1960.

As an example of how these research dollars are spent, I have chosen two significant studies that my own company has sponsored. As a matter of fact, these were carried out right here in town in the wind tunnel at New York University. I draw your attention to the charts here [indicating].

When gases, even if they are only air or steam, are discharged from short vents located on buildings, the air can be caught up in the wind eddies generated by the wind blowing over the building.

Here is a picture [indicating], for instance, that depicts a very common occurrence. The path of the wind is made visible with an oil smoke. The gas in this lower smoke plume is caught by the eddies, and we see it being carried down to the ground.

The second or upper plume shows the stack height needed on this building to prevent the smoke coming out of a chimney from curling down to the ground. This particular model could be a home, for instance, with a peaked roof.

This particular information has significance not only in the design of chimneys for factories, but also in judging the significance of pollution from a private home.

The model shows that the chimney would have to be two and a half times the height of the roof to prevent smoke and gases from descending back to ground level. Needless to say, because of aesthetic reasons or, perhaps, cost, we don't build homes with chimneys that high.

Actually, this is but one model we studied in the wind tunnel. There were many other shapes characteristic of chemical manufacturing operations.

The additional point I want to make is that even if these chimney gases had been scrubbed to a high degree, this eddy effect would still cause the gases to come down too quickly and could cause annoyances. Thus, the routine use of these study results help us to choose the proper chimney height to prevent this annoyance from occurring to our neighbors.

Another interesting and perplexing problem is the dispersive behavior of dense stack gases. This problem was studied also in the New York University wind tunnel. Here is a picture of the model showing three gases of different densities [indicating].