The Great Scrubber Controversy

The Environmental Protection Agency may not resemble a David, and the American Electric Power System is not exactly a Goliath, but the size and seemingly antisocial stance of AEP, coupled with the lonely role of EPA as the appointed champion of the public interest, brings to mind the classic biblical confrontation.

This modern contest went on all through the year, and the telling rock has not yet been thrown. Unlike David, who at least had the support of his people, EPA has found consistent official encouragement only from the Council on Environmental Quality. The Federal Power Commission, the Federal Energy Administration, the Department of Commerce, the Department of the Interior, and the White House Office of Management and Budget were generally to be found, instead, in the AEP cheering section. The AEP giant, which is the largest conglomerate of private public utilities in the nation, is directed by Donald C. Cook, former chairman of the Securities and Exchange Commission, and now avowed protector of what he considers the true public interest—maintaining economic growth through reliance on the nation's huge reserves of coal. (AEP consumes a tenth of all the coal used by the electric utility industry, or one-fifteenth of the total for all uses.) The giant's weapon has been a continuing series of full-page newspaper advertisements, running in the New York Times, the Washington Post, Business Week, and other newspapers and periodicals, excoriating EPA both for its stupidity and for its misreading of the public mind.

Ostensibly the controversy revolves around stack gas "scrubbers." The EPA says they are essential and will work; AEP says they are unnecessary and a costly mistake. As antagonists will, each side has taken an aggressive stance and has made few concessions. That there should be this kind of out-and-out conflict over a piece of technology—presumably subject to resolution by science and engineering—is in itself remarkable, though hardly novel. That it has persisted so long attests to a remarkable amount of underlying complication in such a seemingly simple issue, making it far from certain who is hero and who villain.

Basically, there are two kinds of sulfur scrubbers, or "flue gas desulfurization" (FGD) systems, as they are technically known. One creates a major waste-disposal problem and the other creates a major by-product disposal problem. Each of the basic alternatives has variants both in equipment and in mode of operation, and each will probably develop further variants as time goes on.

The bulk of the experience so far has been with the waste-producing scrubbers, which usually depend upon lime or limestone slurries to absorb the sulfur. The result is a sludge that can be stored in ponds or chemically "fixated" to form an eventual solid usable as landfill or in other ways. Particularly (but not exclusively) in the nonsolid form, the waste can present its own problems of pollution, through seepage, and thus sometimes has to be stored in concrete-lined dumps.

In large metropolitan areas, where sludge-disposal sites are hard to come by, "regenerative" systems, which recover sulfur or sulfuric acid and reuse the recovery medium, are looked to as the more feasible type of FGD process, despite even sparser satisfactory experience. Little or no forethought seems to have been given to the problem of disposing of potentially vast amounts of by-product sulfur (or acid) in a market which, though currently "tight," is almost certain in the long run to be glutted by by-product from other sources (Canadian surpluses are already so large that sulfur is being experimented with as a construction material).

One of the issues, AEP proclaims, is EPA's interposition of obstacles to the maximum use of coal for power generation. This could be done with environmental safety, as AEP sees it, by the use of tall stacks and "intermittent control" techniques. Instead, AEP views EPA as making the use of coal conditional on either the installation of the expensive, "unproved" scrubbers or the burning of low-sulfur coal—and there is currently not enough of the latter to go around. Thus, utilities will have to burn scarce oil and natural gas longer than they would otherwise have to. It is this same objection which, of course, also carries weight with FEA.

This distorts EPA's position, which actually relates only to permanent reliance on tall stacks and intermittent controls. As a practical matter, EPA concedes that 1977 (the outside date set by Congress to meet prevailing standards) is too close a date by which to expect all coal-fired plants to have completed the full process of design, manufacture, and installation of scrubber systems on all their boilers. This means that some of the plants which have both coal and oil burning capacity, or which might be reconvertible from oil to coal, will be continuing on oil a while longer than might otherwise be necessary. Or, to the extent that it is impossible to place scubbers immediately onto plants wholly dependent upon coal, EPA is willing to grant temporary waivers, accept interim use of tall stacks and intermittent controls, and ask Congress to extend the date for full compliance with ambient air standards. Moreover, EPA has said that it is all in favor of using the low-sulfur western coal, if its mining includes adequate protection of the land surface. (It should be noted that not all western coal is necessarily low-sulfur, in terms of ratio of sulfur to Btus, because of its low Btu content per ton.)

AEP also sees EPA and other environmentalists as willing to sacrifice electric power output to the extent of lowering economic growth rates and causing "galloping unemployment." Just about all federal agencies, including FEA, have protested such scare tactics and insisted that none of these dire effects would ensue.

In the final analysis, both sides would probably agree that the real issue is the extent of economic justification for scrubber investments in the face of uncertain results and uncertain alternatives. AEP emphasizes scrubbers' high costs and undependability; EPA emphasizes the high risks and uncertain results of any other control technology. The argument, moreover, is only about discharges of sulfur. AEP has itself been a pioneer in the control of particulates (fly ash) and has been prodded by local regulations (which may exceed the federal in standards) to provide rather complete control of such emissions. Furthermore, both contestants see tall stacks and intermittent controls as an interim solution. So far as ARF is concerned, however, tall stacks and intermittent controls will suffice for an indefinitely long interim, until low-sulfur or desulfurized fuels are sufficiently available. The EPA, by contrast, sees that day as too far off and the interim risks too great to warrant avoiding a major immediate commitment to sulfur scrubbers.

Nor is there absolute disagreement on the still experimental status of the scrubbers. The EPA emphasizes the increasing number of installations and the relative successes among them. AEP emphasizes the fact that no scrubber has yet met National Academy of Engineering standards.

The same may be said of the waste disposal problem. AEP has cited such nightmares as having to bury an area the size of the original District of Columbia (10 square miles) in sludge 10 feet deep in order to dispose of five years of waste output from a coal-burning, 12,000-megawatt power system. The EPA suggests that 12,000 megawatts covers a lot of separate power plants (it is close to the size of the entire seven-state AEP system), that the sludge can thus be widely dispersed, that it can be put to good use as landfill in dumps of considerably greater depth than 10 feet, and that not all scrubber systems produce sludge anyway.

In at least one respect it seems fair to grant the weight of the argument to EPA. Naturally low-sulfur coals are almost certain not to be available in sufficient quantities to supply all fossil-fueled power plants, and economic technologies for the extraction of excess sulfur from coal before burning are unlikely to have achieved adequate development before well into the 1980s. The EPA has conceded the high cost of stack gas scrubbers and has urged automatic pass-through of the relevant costs by public utility commissions.

There is still not enough evidence to know which scrubber technology is best, and there is still not enough evidence to know how much risk there is in depending upon the tall-stack, intermittent-control technique. Ordinarly, before a new technology is applied on a broad scale, it undergoes a long period of experimentation on a laboratory, or at most a pilot-plant, scale in order to isolate the most feasible basic techniques and to eliminate the incidental bugs. Under EPA pressure, the application of scrubbers in the United States is proceeding much faster than that. As of last October, EPA itself estimated that twenty-two units would be in service by the end of 1974 and reported that another ten were planned for 1975, twelve for 1976, nineteen for 1977, and thirty more for other nearby years. Of these ninety-three, a total of forty-seven were to be installed in new plants, with start-up dates conditional on the actual scheduling of plant construction.

What needs to be balanced against the apparent haste in applying this developing technology—and what in EPA's view is controlling—are the greater risks of depending too long or too much on high stacks and intermittent controls. In AEP's view, by contrast, pollution is of consequence only where the people are—at ground level—and emissions from high stacks are of little concern since they are dispersed over great distances. Ground-level air quality can be continuously monitored, and whenever there is an unacceptable build-up, the offending unit can be shut down or switched over to low-sulfur fuel. Counters EPA: "There isn't enough information on pollution dispersion patterns to enable us to know where these pollutants would go. Recent evidence suggests that loading the atmosphere with sulfur oxides causes a build-up of sulfates—a pollutant believed to endanger human health even at low levels. In any event, if thousands of plants were to resort to this tactic, their overlapping pollution patterns would cancel out any benefits which might be gained by dispersion." Moreover, they point out, quick switches of steam or power sources are unlikely to be feasible.

There it is. A still virtually unevaluable environmental risk versus the rapid application of high-cost and possibly quickly obsolete control technology. At the end of 1974, it was still too soon to be rational about the great scrubber controversy.