Mr. COUNTS. We feel therefore the fuel is not as much at fault as the method of operation. In almost all industrial activities the use of energy-in the use of energy there can be pollution where there are improper methods used. We feel our fuel is somewhat being used as a "Whipping Boy" when it should not be.

Mr. WINN. I see. If all these stacks have perfect fuel burning equipment, and it operated perfectly, you have practically no contamination of the air through stack emission?

Mr. COUNTS. We could almost substitute "properly." "Perfectly" perhaps being a stronger word. In other words it is not too difficult, it is not impossible, it is not impractical to achieve such clean operations. Mr. Colkin of HEW I believe would bear us out on that.

Mr. WINN. I would like very much to have that HEW study. I recall you said it was made by Jack Colkin.

Mr. COUNTS. Yes.

Mr. WINN. I would like to have that made part of the record.
Mr. MULTER. We will request it.

Mr. GUDE. I think we are talking about two different air pollutants. One, sulphur dioxide and the other the question of emission from the stack, incomplete combustion carbon particles and other material. Isn't that right?

Mr. COUNTS. This is correct.

Mr. GUDE. What you are saying by "proper operation" Mr. Via is that if a plant is properly operated then there is no visible or neglible stack emission and there is no air pollution problem, but if the operators were burning high sulphur fuels, says four percent sulphur fuels you are still going to get the emission of sulphur dioxide.

There is no way the operator under the present facilities that are available can cut down on sulphur dioxide, but he can control the stack emission.

Mr. VIA. This is true.

Mr. GUDE. Sulphur dioxide is still there.

Mr. WINN. I appreciate the clarification. I don't believe it's that easy no matter how you break it down. I would like to ask how many plants are properly operated in the city in your opinion?

Mr. VIA. I would think basically Mr. Winn, certainly more than half of those plants operating are operating properly. I might go further to say that those installations which we installed and I don't mean that to sound commercial, but ours operate properly and it can be operated properly so there is no smoke emission.

Mr. WINN. I probably expect you, after your strong statement, to say yours are operating properly. Probably someone could go down and show you some aren't operating properly. Regarding stack emission, can't it be controlled by ordinances? Can't we require strict operation so that the operation can be controlled better?

Mr. COUNTS. There are certain codes available to control emissions. Just how stringent they are and how diligently they are enforced, I couldn't say.

Mr. VIA. The City of Pittsburgh has such codes which are vigorously enforced and they have made great strides in the elimination and reduction of smoke stack emission.

Mr. WINN. Doesn't the District have codes on this?
Mr. VIA. I think there are some, sir.

Mr. WINN. Thank you very much Mr. Chairman. I am completely confused now.

Mr. GUDE. Mr. Via, you are familiar with the legislation of the Ringelmann Smoke Test?

Mr. VIA. Yes.

Mr. GUDE. Wouldn't this require an operator to comply? He would then get the minimal stack emission we are seeking.

Mr. VIA. When a piece of equipment is adjusted and set up for proper firing one of the devices used to determine it's efficiency and proper firing is the Ringelmann Smoke Test along with a CO2 analyzer to measure the efficiency or the CO2 content or the fluid gases. These two tests are performed at all times when the burner is adjusted and the answer to your question is yes. It should be, and can be used to determine the amount of smoke being emitted at the stack.

Mr. GUDE. What we are really saying here is this: As far as the use of oil is concerned, it's not just the problem of getting low sulphur content but it's the problem of the operator of the apartment house to see to it that his equipment is burning properly so there is not this

emission.

Mr. VIA. Yes.

Mr. GUDE. So it goes back to the individual, just as the one burning trash in the backyard.

Mr. VIA. Yes, the oil will burn clean if it's properly burned.

Mr. GUDE. So this legislation, with its standards, will provide the means of seeing to it that the owner of the apartment house is complying with the law.

Mr. WINN. Are there standards provided in this bill that would guide the apartment house owner?

Mr. GUDE. That's what's provided in this legislation. There is a standard set up, they would have to follow it.

Mr. WINN. Aren't they operating under any codes now?

Mr. GUDE. There are certain codes here now and I imagine there is some enforcement going on in this area.

Mr. WINN. Is there a lack of enforcement of the codes?

Mr. COUNTS. I couldn't say that. I'm not familiar enough. Our expert on that is on vacation and neither Mr. Via nor I are entire familiar with the Bill. We are only vaguely familiar with it. I don't know whether it's the code in itself or the enforcement, but there is a smoke control or emission control in the District.

Mr. VIA. This states the emission shall not exceed a Number two Ringelmann Smoke Test.

Mr. GUDE. There is some regulation going on, but also it gets into the question of sulphur. Then there is the question of proper ignition

of fuels.

Mr. COUNTS. And combined with the fact that we don't think sulphur is the entire problem in pollution. We feel that the other polluting particulars being emitted play a role at least, in addition to sulphur.

Mr. GUDE. As far as the amount of fuel that is burnt here in the Metropolitan area, is there not a greater amount of oil burned than coal?

Mr. COUNTS. I'm sorry, but I couldn't give you a yes or no answer on that. You would have to confer to them to BTUs because of the difference of tonnage and gallons. I don't know the answer.

I would think there is.

Mr. GUDE. The principle Government heating plants use fuel oil? Mr. COUNTS. Yes.

Mr. GUDE. Very few burn coal.

Mr. COUNTS. Yes.

Mr. GUDE. I think the fuel industry is trying to reduce the amount of sulphur content because it recognizes the problem. In the research laboratories in Pittsburgh they are doing considerable research in sulphur reduction.

Mr. VIA. Mr. Gude, I am aware of these experiments as well as the research being made on the extensive use of the electronic precipitators and water precipitators and the removal of particular matter of smoke stacks, where these devices are used. These can only use the particular matter or the solid matter and have no ability to remove a gaseous substance such as sulphur dioxide or sulphur trioxide. The experiments that are being conducted to remove these gases are at a point now where considerable research is yet to be done and it would be fantastically expensive for normal histat, even now, to install an electronic precipitator to remove the particular matter. It would exceed twenty thousand dollars.

Mr. GUDE. I know there are several ways in which the sulphur can be reduced. For example, the coal people showed us one experiment where they gasified the coal, so to speak, and converted the sulphur into hydrogen sulphide; extracted the sulphur, which they could sell, and by the time they burned whatever it was they got from the coal, there was practically no emission at all of sulphur. It's an entirely new chemical process. As I recall, heat was cheaper this way then under the old process. Is there any kind of research going on in this area? Mr. VIA. There has been research that has been conducted on the removal of sulphur prior to burning the oil, which Mr. Counts covered in his presentation. But there is only one plant in Louisiana now conducting this actual process. The production of that type of oil is a byproduct. It's very limited and it's very expensive processes.

Mr. GUDE. You think it is feasible to reduce the sulphur emission by other means then by just reducing the sulphur in the oil when it arrives?

Mr. VIA. At the moment, not practical.

Mr. GUDE. But it is possible to do it in the laboratory?

Mr. VIA. Yes.

Mr. GUDE. In the legislation we have proposed, we provide for a svstem of exemptions whereby if an industry or an individual was unable to comply completely with this law, they could get an exemption for one year. Would you have any objections to this? You have given us some very comprehensive statements on this situation as you see it, and obviously, the industry is trying to comply.

Looking at other testimony and so on, I think maybe this Committee could accept it. I think the governing body would be in the same position. Would you have any objection to this exemption process until the industry was able to comply?

Mr. COUNTS. Yes, sir, I do. I don't think it would be practicable from the standpoint of when you consider the large volume of residual oil

used in the Washington area to attempt to rely upon individual exemptions; because the problems that I pointed out in the receiving and the storing and the making available of the lowest sulphur oil, I think would-nullify the relief afforded by the individual exemption. In other words if they can't get the oil where is the low sulphur oil, how is it going to be brought in, where is it going to be stored and how is it going to be made available to anyone is the question in my mind. In other words, if the law went into effect based on one percent, before industry could supply it I don't see how each individual consumer applying for relief would be the right answer.

Mr. GUDE. If this exemption applies to all users, of say grade six or grade five fuel, what would be the difficulty?

Mr. COUNTS. Perhaps I didn't entirely understand. I thought the exemption was to be applied for on an individual basis by each individual consumer.

Mr. GUDE. Well it could be the industry could apply for it, or the suppliers could apply for it.

Mr. COUNTS. If it were brought in to include this type of provision perhaps it could be workable.

Mr. GUDE. You mentioned in your testimony the contract the Government signed for two percent oil. Were there any bids for oil of a lower sulphur content?

Mr. COUNTS. They sent out written invitations and to their invitations specified two percent.

Mr. GUDE. Do you know of any offer made of fuel oil of a lower sulphur content?

Mr. COUNTS. I know of none.

Mr. GUDE. We were going to try to inquire of the GSA whether there were other suppliers.

Mr. COUNTS. They may have had their conversations or they may have had activities of which I am not familiar, but when they issued their invitation to bid, after their studies and after their investigation, they did then specify two percent.

Mr. GUDE. I think the Federal Government has a responsibility to use as low sulphur oil as possible.

Mr. COUNTS. I think they were convinced they could not get it.

Mr. GUDE. We are going to try to find out from these people. Thank you very much.

Mr. MULTER. Page nineteen. On the last page of your statement, page nineteen, have you made any changes or corrections to that since you submitted it, or is this statement submitted the same way you read it?

Mr. COUNTS. No. I would like it to remain as stated in the page. Mr. MULTER. What do you mean on "June 30, 1968 two percent and the next day one and a half percent."?

Mr. COUNTS. Up to June 30, 1968. In other words, whenever the law becomes effective until June 30, 1968 it would be two percent.

Mr. MULTER. What you are suggesting is that on July 1, 1968, it be reduced to one and a half percent, and July 1, 1969, it be reduced to one percent?

Mr. COUNTS. Yes, sir.

Mr. MULTER. Thank you.

(Subsequently, the following supplemental statements were filed for the record:)

SUPPLEMENTAL STATEMENT TO HOUSE COMMITTEE FOR THE DISTRICT OF COLUMBIA REGARDING H.R. 6981 (GUDE BILL) AND H.R. 10017 (HORTON BILL)

During the testimony submitted to the Committee on Wednesday, August 16, 1967 by Mr. R. L. Counts and Mr. L. T. Via, of Steuart Petroleum Company, additional information was requested by Congressman Multer and Congressman Winn appertaining to that testimony.

These requests for additional information concerned:

1. The percentage of coal to residual oil usage by the Federal Government in the Washington, D.C. area.

2. The sulphur content of available coal.

3. The project number and full name and address of Mr. J. O. Copeland concerning the survey of heating equipment made by the Department of Health, Education and Welfare.

The current G. S. A. contract calls for a usage of approximately 420,000 tons of coal. The Federal Government currently uses 48% coal-52% oil, calculated on a B. T. U. basis.

The total sulphur content of coal mined in the bituminous fields of Virginia. Kentucky and West Virginia varies from .4% to 5.5% by weight on a dry coal basis. However, the availability of the low sulphur coal is limited.

The HEW survey referred to by Mr. L. T. Via in his testimony was conducted by Mr. John O. Copeland, Department of Health, Education and Welfare, U.S. Public Health Center, 1055 Laidlaw Road, Cincinnati, Ohio 45237, and was referred to as Project No. 103-Central Development Program.

L. T. VIA, Sales Manager, Industrial Oil Burner Division, Steuart Petroleum Company.

ADDENDUM BY L. T. VIA, SALES MANAGER, INDUSTRIAL OIL BURNER DIVISION, STEUART PETROLEUM COMPANY

(Submitted by: Richard L. Counts, President Steuart Petroleum Company)

AUGUST 16, 1967.

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 combusion is complete. If this additional air is not supplied in sufficient volume-incomplete combusion and smoke results. This is not the fault of the fuel-but the fault of the equipment burning the fuel.

In practice, good combustion requires; 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 prac tically zero smoke. This is accomplished when quality equipment is 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 startup. 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 startup 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, must be serviced and maintained at a high efficiency just as an automobile must be checked and serviced to keep it running well.