The Direct Use of Coal

April 1979

NTIS order #PB-295797 Library of Congress Catalog Card Number 79-600071

For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C. 20402 Stock No. 052-003 -00664-2

ii Foreword

Coal production in the United States will more than double by the year 2000, to as much as 2 bilIion tons per year. The investments in facilities, manpower, and technologies for the mining, transportation, and use of such vast quantities of coal will be immense.

This report assesses the benefits and risks of such a massive shift to coal and away from other fuels. It deals with the social, economic, physical, and biological impacts of such a shift. It examines the complete coal system, from extraction to combustion, including the key steps and institutions that policy can influence. The environmental impacts and possible effects on the public health are documented. Occupational and community impacts are examined. Technologies under development that might reduce costs, increase convenience of use, or mitigate negative impacts are reviewed.

This assessment was requested by the House Committee on Science and Technology. It is another in a series of assessments that are being provided to Congress to assist in the development of national energy policy.

The Project Director for this assessment was Mr. Alan T. Crane, who was supported by the Energy Group staff and Dr. Richard E. Rowberg, Group Manager. We are grateful for the assistance provided in this assessment by the Coal Advisory Panel, chaired by Mr. Harry Perry, and the overall guidance provided by OTA’s Energy Advisory Committee, chaired by Pro- fessor Milton Katz.

Daniel De Simone Acting Director

.. /// Acknowledgements

This report was prepared by the Energy Group staff of the Office of Technology Assessment. The staff wishes to acknowledge the assistance of the following contractors and consultants in the collection and analysis of data.

Teknekron Nancy Schuh Institute for Energy Analysis Citizens for a Better Environment Arthur Squires Lee Balliet University of Oklahoma Tetra Tech Georgia Institute of Technology William T Reid Environmental Law Institute J. Philip Bromberg A. V. Slack James L. Weeks Kendrick & Company Reginald Brown Brophy Associates, Inc. Harvard University The Academy for Contemporary Problems University of Denver Environmental Policy Institute Donald Lief Maeva Marcus Joseph Mohbat Martha Spence Lawrence Miike

The fo Iowing Government agencies also provided assistance:

The Environ mental Protection Agency The Department of Energy The Department of Labor The Department of Health, Education, and Welfare The Congressional Research Service

iv Direct Use of Coal Project Staff

Lionel S. Johns, Assistant Director Energy, Materials, and Global Security Division

Richard E. Rowberg, Energy Group Manager

Alan T. Crane, Project Director Marvin Ott, Policy Steven Plotkin, Environment and Public Health A. Jenifer Robison, Regulatory Issues Curtis Seltzer, Mining Implications and Community Impacts Joanne Seder, Research Associate

Lisa Jacobson Lillian Quigg Rosaleen Sutton

Supplements to Staff

Robert J i meson Barbara G. Levi W, Gene Tucker L. Wiliiam Richardson

Contributors

Lynda L. Brothers J. Bradford Hollomon

OTA Publishing Staff

John C, Holmes, Publishing Officer Kathie S. Boss Joanne Heming

v OTA Energy Advisory Committee

Milton Katz, Chairman Director, International Legal Studies, Harvard Law School

Thomas C. Ayers George E. Mueller President and Chairman of the Board President and Chairman of the Board Commonwealth Edison Company System Development Corporation

Kenneth E, Boulding Gerard Piel Professor of Economics Publisher Institute of Behavioral Science Scientific American University of Colorado John F. Redmond, Retired Eugene G Fubini Shell Oil Company Fubini Consultants, Ltd. John C. Sawhill Levi (J.M.) Leathers President Executive Vice President New York University Dow Chemical USA Chauncey Starr Wassily Leontief Electric Power Research Institute Department of Economics New York University Direct Use of Coal Advisory Panel

Harry Perry, Chairman Robert Lundberg Resources for the Future, Inc. Commonwealth Edison

Mike Clark Paul Martinka l-fighlander Research Center American Electric Power (Retired) David Comey* David Mastbaum Citizens for a Better Environment Environmental Defense Fund A W. Deurbrouck Ken Mills Department of Eneergy Tug Valley Recovery Center Michael E Enzi Michael Rieber Mayor, City of Gillette University of Arizona Don Gasper Steve Shapiro Consolidation Coal Company United Mine Workers of America, LU 6025 W. L. Johns Ronald Surdam E. 1. du Pent de Nemours & Co. University of Wyoming Lorin Kerr Joana Underwood United Mine Workers of America INFORM George Land Ralph Perhac A MAX Coal Corporation Electric Power Research Institute Ed Light Joseph Yancik West Virginia Citizens Action Croup National Coal Association

The Advisory Panel provided advice and constructive criticism throughout this project. The panel does not, however, necessarily approve, disapprove, or endorse this report. OTA assumes full responsibility for the report and the accuracy of its contents.

*Died January 1979. The OTA Coal Project staff expresses their sincere appreciation for the assistance and support that David Comey had contributed throughout this assessment. vi Summary

Coal can be America’s most productive domestic energy source well into the 21st century. No other fuel, however, evokes such memories of environmental damage and social disruption. Although new programs, practices, and legislation have addressed many of these problems, their adequacy and effectiveness are uncertain, and new concerns are emerging. Thus, coal’s future is a mixture of promise and risk.

This report analyzes the role that coal combustion may play in the Nation’s energy future, the factors that will shape that role, and the impacts that may result.

SUPPLY AND DEMAND

A tripling of coal production and use by need upgrading and expansion. Federal coal 2000 appears to be possible without either leasing may have to resume. Conflicts between substantial regulatory relaxation or major mine labor and management could escalate to technological innovations. Such rapid growth the point where national production is com- may be in the national interest even though promised. Some communities, particularly in total energy demand will probably grow more the East, may need assistance to accommo- slowly than it has in the past. However, several date the required development. Public con- factors might inhibit this rapid rate of develop- cerns about the siting of mines, powerplants, ment Primary among these is the likelihood and other facilities may delay expansion. that demand for coal will not rise this quickly. Coal is not normally the fuel of choice unless it In addition, questions have been raised offers a large cost advantage. Many users will about the reliability of available control prefer oil and natural gas as long as they are technologies and their ability to meet en- available, despite their higher prices, because vironmental regulations. Significant problems of their greater convenience and lower capital with these technologies could constrain future investment requirements. Recent regulations coal use. The technological viability of flue- have increased the cost of mining and burning gas desulfurization (FGD) to meet proposed air coal, thus reducing its attractiveness. The 1978 pollution emission standards is a focus of this National Energy Act discourages large new fa- controversy. A growing body of evidence, how- cilities from burning gas or oil, but additional ever, indicates that this technology wiII be ade- legislation or other incentives may be required quate though expensive. Safe disposal of FGD if coal’s share of the energy system is to be fur- sludge also appears to be feasible technologi- ther increased. If demand does triple, several cally, but expensive. Finally, requirements of potential supply constraints could still in- the Surface Mine Control and Reclamation Act terfere with achieving a tripling of coal supply. will raise the cost of coal but should not pose Mine-to-market transportation systems will technical barriers to meeting demand.

ENVIRONMENT AND PUBLIC HEALTH

This report does not identify any significant of conscious economic tradeoffs, tack of effi- violations of existing environmental standards cient control devices or insufficient enforce- that inevitably would result from a substantial ment of existing standards. For example, some rise in coal use. However, some adverse envi- underground mines wiII cause acid mine drain- ronmental impacts are likely to occur with in- age or subsidence problems long after their creased coal mining and combustion because abandonment; permanent controls for these

vii problems are not available for all mining situa- tect the public health from problems resulting tions. Some emissions may prove to be inade- from long-term exposure to low levels of quately regulated because of scientific uncer- pollutants. Some controversial analyses sug- tainty concerning the cause and significance gest that current exposure levels may be re- of their effects. Emissions of sulfur dioxide, sponsible for tens of thousands of premature nitrogen dioxide, carbon dioxide (COZ) and fine deaths annually. Increases in emissions of coal particulate will all increase significantly by combustion-related pollutants could aggra- the end of the century under a high coal vate existing problems. scenario and present or pending regulations.

Increases in coal-related air pollution may Third, acid rain, which has been linked to ex- cause or aggravate three potential environ- tensive damage to aquatic ecosystems and mental problems whose magnitude and impor- may also cause terrestrial damage, may in- tance cannot yet be evaluated adequately. Ad- crease as a result of increased emissions of ditional evidence of these problems could sulfur and nitrogen oxides from coal combus- force a reappraisal of our environmental con- tion. trol strategy or even our commitment to increased coal development. If additional evidence confirms current concerns, further reduction in air emissions may First, fossil fuel combustion (along with the be desirable to reduce the health and environ- clearing of forest land) appears to be causing mental risks associated with increasing U.S. an atmospheric CO buildup that may lead to Z coal use. Existing coal-burning facilities would significant changes in global climate. C0 is 2 be primary targets for emission regulations, not likely to become a serious problem before since many of these will not be stringently con- the next century, but if it does, a dramatic trolled under State air quality enforcement worldwide reduction in both fossil fuel com- plans. The technical and economic problems bustion and deforestation may be the only way of retrofitting capital-intensive control systems to halt or reduce climate change. Coal is the on existing plants can be severe. Thus, emis- fossil fuel of greatest concern because of its sion reductions may be most efficiently real- large reserves and high carbon content; pre- ized by supplying these facilities with cleaned sumably, the faster coal use increases the coal. The various techniques for coal cleaning sooner a critical point will be reached and the (physical desulfurization, solvent refined coal, more difficult it will be to switch to nonfossil and synthetic fluids) may become the primary fuels. component of a national strategy for achieving Second, there is a possibility that present the dual objective of increased use of coal and ambient air standards are inadequate to pro- an improved environment.

OCCUPATIONAL SAFETY AND HEALTH

Considerable improvement has been re- assumptions of this report, wilI result in ap- corded in reducing mine fatalities since the proximately 370 fatalities and 42,000 disabling enactment of the 1969 Federal Coal Mine injuries per year. Health and Safety Act, but there has been no The prevalence of coal workers’ pneumo- reduction in the rate of disabling injuries, and coniosis should be lower in 2000 than it was in the total number of injuries has been increas- 197o as a result of the Federal respirable dust ing. In 1977, 139 coal workers were killed and standard, but thousands of workers wilI never- about 15,000 suffered a disabling injury — each theless be disabled by various respiratory of which cost an average of almost two months diseases (collectively called black lung lost time. A tripling of production, under the disease). Furthermore, important questions

I/ill have been raised concerning the effectiveness and the adequacy of the research on which it is of enforcement of the existing dust standard based.

COMMUNITY IMPACTS

Coal development brings both beneficial expands too rapidly. States with underground and adverse social and economic conse- reserves are especially vulnerable. Develop- quences. Communities with diversified eco- ment of these reserves wilI require many new nomies are better equipped to deal with rapid workers and will bring substantial population development and are more likely to benefit. growth to sparsely populated areas. Mining of Where existing services are already under Indian coal may create significant social prob- severe stress, coal development is likely to lems on reservations. However, with some ex- bring additional social and economic prob- ceptions, the tax revenues that couId be gener- lems. Public services and facilities will not be ated by coal development can provide signifi- able to expand sufficiently to cope with in- cant opportunities for economic benefit. To creased demand. Tax revenues will not in- minimize economic dislocations, provision crease fast enough to finance needed im- wilI have to be made to overcome the initial provements. shortfalIs of funds that follow the onset of development. Also, mismatches between areas Some communities in Appalachia will be absorbing the impacts and those reaping the particularly vulnerable to these adverse im- economic benefits must be resolved. pacts, Stagnant coal demand and excess production capacity during the 1920-70 period led to depressed economic conditions in the min- Finally, the diversified economies of many ing industry and communities. Inadequate Midwestern coal counties will allow them to services and facilities are a legacy of these benefit from coal development. These coun- conditions. Increased coal production without ties combine the population and adequate substantial new revenues and technical aid service base needed to absorb development from the Federal or State governments is likely without severe stress. to exacerbate current inadequacies in housing, transportation, health care, and other public The following section describes some of the and private services, related policy issues that Congress may con- Some western communities may suffer seri- sider, A detailed summary of the entire report ous social and economic dislocations if mining is found in the overview of chapter 1.

ISSUES AND OPTIONS

Legislative activity bearing on coal will fall analysis can be used to reach a given end, the into three categories: further amelioration of desirability of which depends in part on the negative impacts; promotion of coal to reduce perspective of the policy maker. Cross refer- the use of other fuels; and oversight to ensure ences to the relevant sections of the main that existing legislation is being appropriately report are included. implemented, This section Iists the major steps discussed in this report that Congress may con- Control of Coal-Related Air Pollution sider, The options are not recommendations. Some, in fact, may be contradictory. The op- Coal combustion is accompanied by a risk tions are intended only to show how this of health damage (possible increased inci-

ix dence of illness and premature death) and If the public health and ecological risks are ecological disturbances (e. g., by acid rainfall) seen as sufficiently dangerous that further from air polIution. limitations should be applied before the risks are better defined by further research, the Although existing pollution sources are following actions should be considered: rapidly being controlled by State implementation plan (S1P) regulations and new sources wilI ● Establish emission and ambient standards be subject to new source performance stand- for fine particulate. ards and other regulations, ambient concentra- ● Revise the Clean Air Act to allow direct tions of fine particulate and nitrates could Federal control of existing sources of pol- rise rapidly (and those of sulfates more slowly) lution. Actions could range from requiring during the next few decades if coal develop- recently built facilities to comply with ment continues at the expected rate. The NSPS requirements, to selective emission reasons for these increases include: failure of reductions on large facilities when their particulate control requirements to distinguish State Implementation Plan requirements among different particle sizes, allowing the are lenient or when they are located in use of controls that are less effective in con- areas that are the source of problems trolling the smaller (and more dangerous) par- associated with long range transport of ticles; unavailability of efficient NOx controls; polIutants. and basing of S I P emission control require- ● Revise the Clean Air Act to allow regional ments on local impacts only, thus allowing cer- and/or Federal control of siting of major tain sources to escape tight controls because facilities when they might contribute to their pollution is widely dispersed. pre-existing long range transport problems. The tradeoff between emission requirements ● Give maximum priority to development of and costs of control is severely complicated by NO controls. the scientific controversy surrounding the ef- X fects associated with these pollutants. Scien- tists still do not agree on the existence or im- The Role of Cost Benefit Analysis in portance of some of the effects or their precise cause. Environmental Decisionmaking The need to weigh costs against benefits has Text discussions: recently become a critical topic of debate in Air Pollution Controls Ch.III regulatory decision making. An array of envi- Long range transport of ronmental decisions affectin coal develop- pollution ...... Ch. V g ment will be affected by the outcome of this Expected future emis- debate. For example, the Environmental Pro- sion levels . . . Ch. V tection Agency has recently proposed new Health effects . . . . . Ch. V source performance standards (NSPS) for sul- Acid rain ecosystem fur dioxide emissions from coal-fired utility effects . . Ch. V boilers. The additional cost of installing and Options . . . . . Ch. VIII operating the equipment (flue gas desulfurization) to meet these standards is of great con- Options cern to utilities. Alternative strategies have ● Increase Federal research emphasis on the been proposed that could grant utilities impacts and mechanisms of long-range somewhat relaxed standards that could be met pollutant transport. Increase Federal ef- at lower cost. No one, however, has produced

fort on development of more effective, a convincing analysis of the relative value of

less expensive controls for NOX, S0x, and the different strategies in ameliorating adverse fine particulate, Emphasize clean fuels impacts — public health risks, crop, ecological and low cost technological controls and material damage, etc. — to compare with suitable for retrofit. the costs. x The NSPS debate shares a common problem nor regulated. Hearing loss is another major with other environmental issues: the costs of occupational hazard. The present dust and controls are more easily computed than their noise sampling programs are of questionable environmental benefits. Thus, a fair balancing reliabiIity. Some mines may not be in com- of costs and benefits in setting environmental pliance even when their sample data say they standards is always difficult and frequently im- are. Even with current standards and diligent possible. compliance, it is likely that thousands of miners wilI show evidence of work-related lung Text discussions: disease in the future. Flue gas desulfurization argument. Ch.IV Text discussion . . ChVI Environmental Impacts. Ch.V Options Ch.VIII Options Option A: ● Reassess the inherent safeness of the current respirable dust standard. Maintain the status quo. The present reg- ● Consider alternatives to current dust ulatory emphasis is on the use of “Best Avail- sampling, including continuous in-mine able (polIution) Control Technology, ” although monitoring, and possibly more effective the agencies have used legislative language re- ways of carrying out sampling, such as quiring consideration of the cost of achieving miner- or MS HA-control of the program. the standards as a restraint on how expensive ● Encourage the establishment of health the required controls can be. (The degree of standards for other harmful substances — their “restraint" is of course a subject of some nonrespirable dust, trace elements, fumes, disagreement). etc. — that are now unreguIated. ● Consider lowering the Federal noise stand- Option B: ard for mining. Require regulatory agencies to develop and ● Promote occupational health training for publish "impact statements” that state their miners. estimates of the costs and benefits of proposed standards and regulations. Occupational Safety

Option C: Coal mining involves higher probabilities of Establish a mechanism to decide whether a occupational death and disabling injury than forthcoming standard must be set by an ex- almost any other trade. Although coal’s fatali- plicit balancing of costs and benefits. The ty rate has improved considerably with the im- basis for this decision would be the state of the plementation of the 1969 Federal Coal Mine art of impact assessment for the pollutant in Health and Safety Act, the frequency and question. number of disabling injuries — about 15,000 in 1977– has not improved. Both fatalities and injuries wiII rise in proportion to increases in Occupational Health production unless accident frequency rates are lowered. Despite a strict. standard for respirable coal mine dust mandated by Congress in 1969, Text discussion: Safety ...... Ch. VI miners continue to be exposed to harmful dusts and fumes. The current standard should Options greatly lower the number of miners disabled by coal workers’ pneumoconiosis if it is complied ● Consider the feasibility of requiring or en- with regularly, Exposure to nonrespirable dust couraging conversion to the “safest (associated with other respiratory diseases) available mining equipment” (adjusted to and other toxic substances is neither measured individual mine characteristics), consist-

xi .

ent with the intent of the 1969 and 1977 centive to use coal) to help finance Federal mine safety laws. needed improvement in impacted com- ● Establish Federal safety standards for munities. mine equipment. ● Provide loans or subsidies for programs to ● Require 90-day apprentice training before provide better public services in these a miner is allowed to operate an unfamil- places, possibly through a public, non- iar piece of mobile mine equipment. profit coalfield development bank. ● Clarify the right of individual miners to ● Develop programs that would encourage withdraw from conditions of imminent economic diversification in coal-dom- danger under Federal law. inated regions. ● Establish Federal limits on fatality and in- ● Require operators to submit a “communi- jury frequency for different kinds of ty impact statement” to local and Federal mines. Substantial penalties could be officials before mining begins. levied against mine operators exceeding ● Promote access to land in communities these limits. where it is presently unavailable for hous- ● Establish performance standards for the ing. Mine Safety and Health Administration. ● Improve flood control measures in Ap- Community Impacts palachian coalfields as a way of encouraging investment in coal and noncoal In communities where coal mining has dom- development and housing. inated local Iife, rapid coal growth tends to ● Maintain roads by enforcing coal truck produce a broad range of socio-economic weight limits and institute a highway coal problems. The chronic underdevelopment of haulage tax to fund road reconstruction. community services and facilities associated ● Institute a rural health care system for with earlier coal development has left a coalfields. substantial legacy of needs. Where mining has been a negligible factor in local affairs as in the West, rapid growth can easily overwhelm Labor-Management Relations existing institutions. The level of current need The history of coal’s labor-management rela- and ability to manage growth depends on site- tions is a chronicle of turmoiI caused by uncer- specific conditions, coal company policies and tain markets, hostile attitudes, and inequities. the local tax system, among other factors. Although lost time from strike activity in- Expanding mining communities suffer from a creased in the 1970s over the 1950s and 1960s, lack of housing, planning capability, ex- no enduring coal shortage has been experience with Federal programs, and money to perienced, even during the 3’/2 month UMWA develop services and facilities concurrently strike in 1977-78. Strikes disrupt normal pro- with mine development. Such needs can be ex- duction patterns, but experienced coal pur- pected to be met at the state and local level chasers take adequate precautions by accumu- after mining growth stabilizes if the local lating large stockpiles. As more and more coal economy is healthy. Chronically underdevel- is Iikely to be mined in non-UMWA operations, oped and temporarily overwhelmed com- strikes may decline in national importance. munities, however, would benefit from Federal Nevertheless, the potential for intermittent assistance if appropriate funding channels can disruption will exist as coal assumes a more be devised. central role in the Nation’s energy system. Text discussion: Eastern . . . . . Ch. VI Government intervention has generally been Western . . . . . Ch. VI resisted by both unions and operators, and it has not been effective. Harsh measures aimed Options at either party may do substantial long-term ● Enact a national severance tax on coal (or damage to labor-management relations even on other fuels to avoid an economic disin- when they work in the short term. xii Text discussion: improving the transportation systems Industry Profile ...... Ch. IV (IV-J). Labor Profile Ch. IV ● Reduce the costs and constraints of min- Collective Bargaining Ch. IV ing and combustion by easing regulatory Workplace and Commu- standards. Although this study has not nity Implications . Ch. VI found any fundamental incomparability Options . . . . Ch, VI II between increased coal use and existing environmental regulations, reclamation Options and emission controls are expensive. A ● Create contingency plans for emergency less drastic step would be to institute coal shortages. more flexible regulations designed to be ● Promote programs to improve social con- less stringent where the potential for ditions in the coalfields, thereby removing damage is less. sources of confIict. ● Plan for government seizure of the mines Oversight in the event of a crippling strike. Legislation has addressed many major im- # pacts created in the past by coal production Increasing the Use of Coal and use. Some issues and programs may require particularly intensive oversight to assure This report assumes coal use will grow that congressional intent is being carried out. substantialIy. Such growth is consistent with The list below identifies the most important present expectations of energy needs, supply such programs discussed in this report. of alternative fuels and potential constraints ● Development of long-range air-pollution on coal supply. National policy could seek to transport models and emplacement of further increase coal’s share of the total energy ambient air-quality monitoring to deter- supply, perhaps to reduce dependency on mine the effect of siting and energy policy foreign oil or nuclear power. Measures to decisions. Epidemiological and ecological stimulate demand would then be considered. studies to determine the impacts of air The mining industry is expected to be able to quality changes (V. B.). meet any plausible demand for at least the ● Enforcement of control of surface mine next decade, but thereafter, constraints on pro- runoff during operation and reclamation, duction could become serious, especially if de- especialIy for small mines. Development mand rises very rapidly, of ways to control acid mine drainage and subsidence from abandoned underground Options mines (V.C. and D.). ● Increase demand for coal by strengthen- • Enforcement of adequate dust control in ing penalties and incentives in the Na- mines through sampling or continuous tional Energy Act. Industrial users will be monitoring (V1.A. ). the most Iikely target for such initiatives ● Resumption of leasing of Federal coal (chapter I I). with appropriate safeguards (IV.A. and ● Improve technology to make coal com- VI 1. A.2.). bustion more attractive. Clean coal and ● Development of Federal strategies to synthetic fuels are essentially the only assist the upgrading of the coal transpor- ways of using coal in small furnaces and tation system (IV. j .). boilers while meeting clean air standards. ● Enforcement of current mine safety and Fluidized bed combustion may be an health standards through inspections and asset to industrial use of coal (1 I I-G and penalties. IV-L) ● Conversion of oil and gas burning ● Facilitate supply by ensuring an early facilities to coal under the National resumption of Federal leasing (IV-A), and Energy Act (1 I and VI 1. A.8. ).

. . . X111 Contents

Page Summary ...... vii Chapter 1. lntroduction and Overview ...... 3 I 1. Energy and the Role of Coal ...... 33 Ill. Coal Technology and Techniques ...... 53 Iv. Factors Affecting Coal Production and Use...... 109 v. Environmental Impacts...... 183 VI. Workplace and Community Implications . . . . 259 VII . Present Federal Coal Policy...... 337 VII 1. Policy Options...... 373 Glossary: Acronyms and Definitions ...... 407

xv — ——— -.

Chapter 1 INTRODUCTION AND OVERVIEW

● Chapter 1.- INTRODUCTION AND OVERVIEW

Page

Induction ● ****tid e*** **** **** **** ***. **** *e e******** 3

Overview v*** **** ***e **.9 **** **. **** **** *m** .*** *e*e9 4 Energy and the Role of Coal...... 4 Environmental Impacts and Controls...... 6 lmpacts on Air Quality...... 6 lmpacts on Land and Water ...... 12 Workplace and Community impacts ...... 15 Coal Worker HeaIth and Safety ...... 15 Community Impacts.. . . ., ...... 17 Social impacts of Transportation...... 20 - lmpacts on Coal-Using Communities ...... 20 Factors Affecting Coal Production and Use...... 2u- Coal Availability and Leasing...... 21 Industry Structure ...... 21 Labor Profile...... 21 Labor-Management Relations and Collective Bargaining. . . . 22 Productivity ...... 23 FederaI Coal Policy ...... 24 Implementation...... % ...... 26 Future Policy ...... :...... 26 Environmental Impacts ...... 28 Community and Social Impacts ...... 28 Labor/Management Relations ...... 29 Workplace Health and Safety ...... 29 Leasing of Federal Coal Reserves ...... 29 Chapter I INTRODUCTION AND OVERVIEW

INTRODUCTION

The increased use of coal has become the focus of a national debate over the need for energy and the desire to maintain a healthy physical and social environment,

U.S. reserves of coal are vast, and the technologies of coal production and combustion are welI developed Thus coaI offers a major aIternative to U.S. dependence on foreign supplies of oil However, coal development has a history of exploitation and turmoil in the coalfields of Appalachia, of cities laden with soot and noxious fumes, and of destruction of land and water resources Although an extensive regulatory system and other pressures have ameliorated many of coal’s historic problems, it stiII retains potential for damage Many believe that rapid development of U S. coal resources cannot be accomplished without unacceptable damage both to the natural environment and to the communities where coal mining and combustion occur

Federal policymakers face difficult choices This report presents the results of a broad in dealing with coal’s adverse impacts. On the study of the mining and direct combustion of one hand, strict controls almost always result coal. There are three major themes, The first is in higher costs of mining and using coal. These to determine coal’s potential contribution to costs may inhibit demand for coal and slow its future U.S. energy needs. Next is an assessment pace of development Also, efforts to control of the environmental and social impacts that one adverse impact sometimes cause another. may result from rapid coal development. Final- For example, the scrubbers used to reduce ly, there is a guide for policy initiatives that sulfur oxide (SOx pollution produce large Congress may consider in addressing a variety quantities of sludge that represent a land use of coal-related issues. I n addition, the report and potential water pollution problem. Finally, provides information on impacts and on new gaps in our knowledge of the importance and technologies that should be useful for legisla- causes of certain environmental effects create tive oversight of Federal energy and environ- doubt as to whether all required control meas- mental R&D programs. It identifies those im- ures are necessary or effective. Failure to ade- pacts that have escaped the regulatory system quately control an environmental or health im- and those that have been only partialIy con- pact, however, may result in adverse conse- trolled. In many cases, it also describes the quences that outweigh the costs of control, means available to eliminate or mitigate these These consequences may not be fully measur- impacts. able in dollars and may take years to occur. In addition, the public opposition to new coal Assessment of adverse environmental im- mines and powerplants aroused by a failure to pacts is particularly controversial because in- control environmental and health impacts may formation is lacking in critical areas. Many im- be a more significant deterrent to develop- portant issues will not be resolved conclusively ment than are high prices. On the whole, Fed- for many years. Nevertheless, decisions on eco- eral policy has tried both to encourage in- nomic, environmental, and social policy to be creased production and use of coal and to made over the next few years will be based on lower its environmental, occupational, and this incomplete information. Hence, some of social costs, The attempt to write legislation this report’s conclusions are tentative, based and regulations that balance these two goals on an evaluation of the existing evidence. For has been marked by controversy, with exten- those areas where the evidence is particularly sive Iitigation between environmental and coal controversial, alternative arguments are dis- development interests as one result. cussed. 4 ● The Direct Use of Coal quences of coal use with either the use of able to control air pollution from coal other fuels or with energy conservation. No combustion, alternative to coal development is free of ● Chapter IV analyzes the factors that will adverse consequences; these must be taken affect coal production and use, including into account before coal “place” in the leasing, industry structure, labor relations, overall U.S. energy picture can be determined. regulatory restrictions, physical and eco- Second, the report does not provide a com- nomic constraints, and public attitudes. plete and definitive accounting of the costs ● Chapter V describes the environmental and benefits associated with coal mining and and public health effects associated with combustion, Not all costs and benefits are mining and combustion under the current known or knowable, Often, they cannot be reguIatory system. measured in the same terms. Therefore, the ● Chapter VI describes the occupational report attempts to identify the uncertainties health and safety aspects of mining and surrounding the impacts described. The exist- the socioeconomic effects on communi- ence of high levels of uncertainty, as well as ties that can be expected from increased the strong role that personal values play in coal use. gauging the importance of impacts, clearly has ● profound implications for policymaking. Chapter VII reviews current legislation regulating coal production and use, The report is organized as follows: ● Chapter VII I analyzes policy dilemmas ● Chapter I I surveys U.S. energy patterns that accompany coal development and and alternative forecasts of national ener- outlines Federal policy options in the gy demand and coal supply. areas of environment and health, commu- ● Chapter I I I describes the coal resource nity impacts, labor-management relations, base and mining and combustion technol- occupational health and safety, and coal ogies. It also describes technologies avail- leasing,

OVERVIEW

This overview focuses on the elements of the a part. Both the demand for energy in general report most useful to policymakers. It dis- and the supply of other fuels wilI affect the use cusses the reasons for expecting coal use to of coal. Energy demand depends on the effi- grow rapidly and the manner in which that ciency of use and the level of demand for growth may occur. It then describes the ex- goods and services that consume energy. pected environmental and social impacts. Rising population and real gross national prod- These impacts have been addressed by a num- uct will increase demand, while increases in ef- ber of Federal policy initiatives. Because such ficiency of use in response to higher prices and Federal actions will influence future coal de- Government policies will reduce it. Most esti- velopment, they are discussed in the context of mates of energy demand in 2000 falI between all other factors that wilI affect coal produc- 100 and 150 quadrillion Btu (Quads), com- tion and use. Finally, policy options are out- pared with 73.1 Quads used in 1975, The upper lined that might be considered either to en- end of this range is becoming increasingly courage coal use or to curb remaining adverse unlikely because of a leveling off of popula- impacts. tion, rapidly increasing efficiency of use, and indications that many of the goods and services that consume energy are reaching satura- Energy and the Role of Coal tion levels.

The importance of coal must be gauged in Coal’s share of future energy demand will the context of the energy system of which it is depend on its availability, cost, and attractive- . Ch. I—Introduction and Overview ● 5 ness as compared to alternative fuels, Total Year 1977 1985 2000 U.S. petroleum and natural gas production Surface mines cannot expand much and may well decline by Appalachia 185 130-155 130-175 2000 unless ways are found to tap presently Midwest 91 75-95 95-135 uneconomical resources such as geopressur- West 141 415-495 700-1,005 ized gas Thus oiI and gas are Iikely to continue Total 417 620-745 925-1,315 to be discouraged as fuels for powerplants, Underground mines leaving coal and nuclear energy as the only Appalachia 205 225-260 380-505 two commercial options for electric utilities. Midwest 54 60-80 120-180 Nuclear power will expand rapidly as reactors West 13 50-60 80-110 on order are completed, but further growth Total 272 355-400 580-795 faces uncertainties in public acceptance, Total costs, scheduIes, and (possibly) uranium sup- Appalachia 390 355-415 510-680 plies. Specific site characteristics such as prox- Midwest 145 135-175 215-3-15 imity to coal and environmental factors will af- West 154 460-510 780-1,115 fect future selections As coal and nuclear are Grand total 689 955-1,145 1,505-2,110 generally competitive, policy decisions affect- The sharpest increases in coal consumption ing one may well influence the other. wiII be i n the West-Central and Mountain regions. All regions east of the Mississippi (ex- Oil, gas, and electricity will be coal’s major cept New England) will sustain a more gradual competitors in the industrial and residential/ growth in their already comparatively high commercial sectors. Solar energy and other consumption. By 2000, consumption will be new fuels have great potential, but economics much more evenly distributed than now with and the logistics of expansion may delay exten- all regions except New England and the Pacific sive use until the next century. Coal use by in- States burning large quantities, dustry will be increased by legal restrictions on future oil and gas use. Requiring smaller users The actual level and distribution of produc- to shift to coal will incur problems of high tion and combustion will depend largely on costs and less effective polIution control. New the costs of production, transportation, and technologies such as fluidized-bed combustion combustion. Surface mining is generally (FBC), thoroughly cleaned coal, and synthetic cheaper than underground mining. Large fuels may be necessary if small facilities are to mechanized mines exploiting thick seams en- increase greatly their use of coal The residen- joy substantial cost advantages over smaller tiallcommercial sector wilI be especially determines working thin seams. For example, new, red by the inconvenience of delivery, storage, western surface mines might produce coal at and ash disposal. Without rapid growth in cen- $5/ton while an Appalachian underground tral heating plants, the residential sector will mine could have production costs of $30. The only SIightly increase coal consumption as increasing share of Western coal will keep long as other fuels are available average coal costs down, but transportation costs can be significant if the shipping distance Achieving a 150-Quad energy supply by 2000 is more than a few hundred miles. Thus, West- wouId calI for a very successfuI oiI and gas dis- ern coal is not necessarily competitive with covery rate, substantiaI imports, an upsurge i n Eastern coal for a particular site. Combustion orders for nuclear powerplants, and an all-out costs depend on coal characteristics and the expansion of coal Problems with any of these technology to accommodate them. For exam- wouId preclude such a rapid expansion of supple, boilers burning high-sulfur or high-ash ply. coals require more expensive control equip- Most energy scenarios assume a rapid ex- ment. Coal characteristics vary widely even pansion of coal. By 2000, production could be within a seam, but can be characterized two to three times the present level. The re- roughly by region, In general, Eastern coal has gional distribution of production (in millions a high heat content but often has a high con- ot tons) for this range is estimated as follows: centration of sulfur. Midwestern coal is slight- 6 ● The Direct Use of Coa/

Iy lower in heat value and higher in sulfur, to be occurring now)— represent risks rather while Western coal is lowest in heat value and than certainties. Scientists disagree sharply on sulfur. These factors are weighed by potential the extent of the risks, greatly increasing the users. Policy initiatives affecting these costs difficulty of developing environmental (e. g., limits on sulfur emissions) influence deci- policies. Part of this disagreement involves sions of whether to use coal and where to pur- sharply differing opinions about the quality of chase it. data and the validity of analytical methodology. Part also involves more basic philosoph- ical differences about the nature of “proof.’: Environmental Impacts and Controls Because many environmental relationships are drawn from circumstantial and statistical if coal does indeed stage the comeback that evidence, considerable judgment must be used has been forecast, it will return to prominence in determining when a “postulated” relation- in a manner vastly different from the way it ship turns into a “probable” one, and finally, dominated national energy use in the past. The into a “proven” one. The long fight to con- availability of pollution controls, better com- clusively prove a relationship between smok- bustion techniques, and new mining methods, ing and cancer is a classic example; many en- coupled with enforcement of a wide range of vironmental cause-and-effect relationships environmentaI protect ion requirements, follow the same Iines. should prevent a repetition of much of the en- Finally, one additional problem with pre- vironmental degradation — soot-laden cities, dicting environmental impacts is that their scarred landscapes, ruined and discolored magnitude depends on the effectiveness of streams — that accompanied coal development in the past. However, despite the laws and new pollution control systems, and this can change. The regulatory systems often will respond to equipment and techniques, large-scale coal de- newly perceived environmental threats by re- velopment may still be accompanied by sub- quiring more stringent controls. Because it stantial environmental impacts. Some of these cannot be predicted how weiI the future envi- impacts could result from inadequacies in the ronment wilI be monitored, the extent to which enforcement of the laws or in the environ- ongoing research will discover new evidence mental controls. Other impacts may result linking particular pollutants to specific im- from the failure to regulate a damaging pollut- pacts, or how policy makers will respond to ant or to specify an adequate level of protec- such evidence, the discussion below focuses tion from a regulated pollutant. These kinds of on the effects of coal development under the failures usually result from inadequate knowl- current regulatory system and attempts to edge: the inability to recognize a subtle but im- place the postulated, probable, and proven en- portant impact, to connect a known impact to vironmental impacts into perspective. How- its correct source, or to determine properly the quantitative relationship between impact and ever, virtually all of the most severe of the im- source. pacts described below are capable of being mitigated or eliminated by controls that are This very real deficiency in our knowledge available today or are under active devel- of environmental processes makes it difficult opment. to determine whether current plans for coal development could cause unacceptable envi- Impacts on Air Quality ronmental impacts. Some of the more spectacular impacts that have been attributed to Although the mining and transportation of coal development — for example, the warming coal can cause local air pollution problems of the Earth’s atmosphere by increasing levels from fugitive dust (from mining operations, of carbon dioxide (COZ) (a possible long-term storage piles, and coal hauling) and noxious effect), or the thousands of premature deaths fumes (from smoldering mine fires), the major, attributed to the particulate sulfate products national air quality impacts from large-scale of sulfur dioxide (SOZ) emissions (an effect said coal development will come from the combus- Ch. I—Introduction and Overview 7 tion portion of the fuel cycle— from coal-fired Two key problems are created by this long- powerplants, industrial boilers and furnaces, range transport and transformation: and commercial space-heating plants. The air pollutants released in large quantities by com- 1. Areas can experience episodes of poor air bustion units include the oxides of sulfur, quality caused by pollution sources that nitrogen, and carbon, as well as particles of are outside their jurisdictional boundaries ash that become entrained in the hot flue and thus essentially beyond their control gases. Smaller quantities of trace inorganic under the current reguIatory system. elements, radionuclides, and hydrocarbons are 2. The pollutants that may be present in the also emitted; these are often adsorbed on the air and that may be doing the most dam- surface of the ash particles. age are not necessarily the same as the pollutants being regulated. Controls on the “primary” emitted pollutants may not Of the major pollutants, SOX and nitrogen be effective on the “secondary,” trans- oxides (NOx - in the form of S02 and nitrogen dioxide (NO,)– and particulate matter are con- formed pollutants. trolled directly by Federal law. The present strategy for regulating these pollutants under A major reason why Federal regulatory strat- the Clean Air Act combines a series of “local” egy does not explicitly take these factors into control levels— incorporated in State imple- account is that the analytical ability to trace mentation plan (S1P) requirements to meet Na- pollutants from source to “receptor,” through tional Ambient Air Quality Standards (NAAQS) both chemical transformation and long-dis- and Prevention of Significant Deterioration tance physical transport, is inadequate. More- (PSD) requirements–with New Source Per- over, the identification and measurement of formance Standards (NSPS) that set nation- the physical impacts of these secondary pollut- wide emissions limits on large new polIution ants are often disputed. To identify specific sources. In general, the regulations are problems, each of the major pollutants, its directed at the chemical form of the pollutants transformation products, and its impacts is as they are emitted from their source, and are examined in turn. focused on maintaining air quality requirements within a local air quality control region. Sulfur oxides have received more attention Unfortunately, the pollutants are neither than any other emission from coal combus- chemically nor physically static within the at- tion, primarily because of the large quantity of mosphere. Most are subject to complex chains emissions, the diversity and controversy sur- of chemical transformations, with the im- rounding its impacts (human health effects, portance of each reaction depending on the acid rain, crop damage, etc.), and the great ex- presence of catalysts, intensity of sunlight, pense involved in S0x controls. Coal combus- degree of humidity, and other factors. Physical tion is now, and is likely to continue to be, the processes are also at work, mixing the pollut- major source of SO emissions in the United ants and at times carrying them far from their X States. Although existing coal combustion source until they are removed from the atmos- sources will be coming into compliance with phere by settling, by colliding with terrestrial local regulations in the next few years and new surfaces, or by being “washed out” by rainfal1. sources will be subject to strict NSPS, the ex- Examples of long-range transport include in- pected expansion in coal combustion should stances of “hazy blobs” of urban pollutants prevent total S0x emissions from continuing to crossing the boundaries of several States and decline significantly in the next decade and persisting for periods of a week or more, and should cause them to rise (although slowly) elevated levels of sulfate particulate in Penn- thereafter. sylvania that originate with SOZ emissions from a cluster of coal-fired powerplants in the Ohio River Basin that are alined with the pre- The SO, that emerges from the stack of a vaiIing wirids. coal-fired boiler is either removed (primarily by impaction in an area close to its source) effects at high concentration levels or at low from the atmosphere or transformed into sul- levels over long periods of time. Human epide- furic acid or to some other form of sulfate ion. miological studies have tended to suffer from These sulfates tend to be transported over a problems with heterogeneous populations, wide area and are removed predominantly by poorly measured pollution exposures, and rainfall. Transport of sulfates over distances of muItiple polIutants. hundreds of miles is not uncommon. A series of epidemiologic analyses of the The major effect of the locally deposited relationship between mortality rates and air

S02 is to damage crops and forests during pollution in several American cities has linked meteorological conditions that cause the current levels of sulfate (and particulate) con- “plume” (column of exhaust gases from the centrations to tens of thousands of premature stack) to touch the ground. Lower plant species deaths yearly in this country. These analyses may suffer severe losses downwind of coal- suffer from the generai problems associated burning facilities, while a wide variety of crops above with most epidemiological studies as are damaged when other pollutants react with well as inadequate data on those population SO,. However, these effects should not in- characteristics that might affect the death crease greatly in severity on a-nationwide basis rate, and they have been rejected on these because of the relative stability of S02 emis- grounds by many health scientists. However, sions for the next few decades and because the arguments advanced by these scientists are new powerplants will operate with S02 scrub- inconclusive and have not invalidated the bers. analyses. It remains a possibility that existing levels of air pollution are causing significant The major effects of the sulfate transforma- numbers of deaths. (Sulfate should be con- tion products are continuation and possible sidered as a pollution indicator rather than as aggravation of the effects of acid rain (dis- necessarily the prime cause, although pre- cussed below) and the possibility of major sumably the causative polIutants are produced human health effects. Both of these are ex- in association with the sulfate precursor, SO .) cel lent examples of research inadequacies; Z If the relationship between current levels of air scientists as yet cannot credibly describe the pollution and large numbers of premature relationship between emissions and the am- deaths were proven, or if it were perceived as bient concentrations that may occur far from proven by a politically significant portion of the pollution source, and do not agree on the the population, future coal development magnitude of the impacts. Improvement and could be substantially affected by demands verification of some existing long-range air for restrictions on development, deliberate pollution models may soon allow acceptable shifts to alternative energy sources, or in- predictions of ambient concentrations caused creases in pollution control requirements and by distant sources. This would still leave cost. unresolved the prediction of the environmental and health impacts from these concentra- Although coal combustion is now secondary tions. to automobiles as a source of Nitrogen oxides, the present inabiIity of coal-fired boilers to re- The estimation of human health effects duce their uncontrolled emissions by more from sulfates or from any air pollutant is ex- than about half will yield a substantial in- traordinarily difficult. Short-term tests on crease— perhaps 20 percent by 1990— in total cultures and tests on animals can employ high U.S. NO, emissions (unless more efficient con- levels of pollutants and thus can measure easi- trols are developed and used) despite further ly identifiable acute effects; however, the cleanup of automobiIe exhausts. relevance of these effects to human beings is uncertain. Clinical studies utilize human sub- The threshold for almost all observed effects jects but only at low levels of concentration; on ecosystems is well above the NOZ levels in the impacts that are measured are not easily most U.S. cities, and the forecast increase in translatable into estimates of more dangerous emissions should not cause significant new Ch. 1—Introduction and Overview ● 9 damage from NO,. However, NO, is a precur- adsorbed on their surfaces. Although total par- sor of photochemical oxidants such as ozone ticulate emissions will be substantially re- and peroxyacyl nitrates (PAN). Oxidants are duced in the future as a result of strict controls the most damaging air pollutants affecting on new plants and progress in obtaining con- agriculture and forestry in the United States. formance with State regulations for existing Elevated ozone concentrations caused by plants, emissions of fine particulate may in- long-range transport from urban areas have crease unless controls are installed that are become a regional problem throughout the equally effective for al I particle size ranges. United States, causing widespread damage to crops on both coasts. However, the relation- The physical characteristics of fine par- ship between N02 emissions and oxidant for- ticulate make them candidates for potential mation is not well understood; thus, although ecosystem and health damages, but virtually increased N02 emissions may be expected to no data exist to verify such effects. Specula- cause some increased oxidant formation and tion about ecosystem damages is based on the subsequent ecosystem damages, the severity potential for alteration of normal soil proc- of this outcome is highly uncertain. esses associated with nutrient recycling and with soil micro-organisms, as well as a small The transformation of SO, and NO, into amount of evidence of trace hydrocarbon acid suIfate and nitrate and the long-range damage to aquatic systems. Similarly, there is transport of these acid products can damage a speculative potential for a human health im- the environment by producing acid rain. The pact based on the ability of fine particulate to transformation products of SO and NO may Z Z penetrate the lung’s defenses, and the coating be the major contributors to the current acidi- of toxic materials on the particles. The same ty of rainfall over most of the Eastern United types of controversial epidemiological studies States. The resulting increases in the acidity of that have implicated sulfate as being asso- lakes have seriously degraded some aquatic ciated with premature deaths have also im- ecosystems, Although acid rain has been plicated particulate. shown to affect individual components of the terrestrial ecosystem, it has not been proven to in recognition of the possible health im- affect that ecosystem to the same extent that plications of increasing fine-particulate emis- it clearly affects aquatic systems. However, sions, the 1977 Clean Air Act amendments re- postulated associations of acid rain with some quire the Environmental Protection Agency ominous trends (such as declining forest (EPA) to study the health effects of fine par- growth) and potential impacts (such as leach- ticulates, associated trace elements, and ing of toxic metals and damage to nitrogen-fix- polycyclic organic matter (POM) and to estab- ing bacteria from increasing soil acidity) sug- lish regulatory controls for these pollutants if gest an urgent need for more research on acid necessary. rain effects. The problem is especialIy important in the Northeastern United States. The Southwest, which will absorb substantial Both the fine particulate directly emitted amounts of acid sulfate and nitrate, will not be from coal combustion facilities and the partic- as troubled because its soil and water are pre- ulate sulfate that are the transformation products of SO emissions are effective in scatter- dominantly alkaline. Z ing Iight and thus causing a degradation of visi- Because of the widespread use of electro- bility. The Southwest in particular would ap- static precipitators (ESPS) that remove large pear to be vulnerable to this damage, because particles with high efficiency but are less effi- regional shifts in power generation will add cient in controlIing smalIer particles, any eco- considerably to its pollution burden, and its system impact of particulate emissions from vistas are an important resource. Although coal-fired powerplants will be caused almost Federal PSD restrictions are designed in part to exclusively by fine particulate and the associ- protect western visibility, the state of the art in ated trace elements and hydrocarbons that are predicting the visibility impacts of new coal- 10. The Direct Use of Coal

fired powerplants–or of any light-scattering matic change, because COZ in the Earth’s at- particles — is not well advanced. Although visi- mosphere has a “greenhouse effect, ” allowing bility impacts may occur hundreds of miles incoming sunlight to warm the Earth’s surface from a large source, EPA has specified 50 km but trapping outgoing heat radiation. Effects as the maximum distance over which current of such a climate change, if it occurred, could air quality models are credible for evaluating include massive shifts in the productivity of the effects of new pollution sources—and farmlands as well as partial melting of the most modelers would consider this an optimis- polar icecaps and flooding of coastal cities. tic assessment of the state of the art. Thus, the Current gaps in our understanding of how cli- restrictions on visibility reductions will be dif- mate is regulated and how COZ is cycled be- ficult to enforce, until acceptable long-range tween its sources and reservoirs leave this issue transport and visibility models are available. surrounded by considerable uncertainty. Although the problem is widely perceived by Most of the impacts discussed above would the scientific community as potentially ser- originate from large coal-fired powerplants or ious, some scientists believe that any effect industrial boilers. Few predictions of energy would be overwhelmed by the natural climatic growth expect major increases in coal combus- cycle that may be moving the Earth to a cooler tion by small residential and commercial future climate. A further critical aspect of the boilers or furnaces. Small boilers or furnaces, problem is the apparent lack of a practical if poorly maintained, can experience incom- CO, emission control technology for fossil plete combustion and generate elevated levels combustion. Should control of CO2 be judged of hydrocarbon emissions. A major worry in necessary, the available options are to reduce such a situation would be increased generation worldwide fossil fuel combustion (by energy of POM, some species of which are carcino- conservation and switching to alternative genic. Because these emissions would tend to energy sources) and to stop ecosystem changes come from low stacks, possibly in densely (especially deforestation) that might be ag- populated areas, special attention must be gravating the problem. paid to these units if larger than expected growth of direct coal use occurs in the residen- As discussed above, each of the pollutants tial and commercial sectors. generated by coal combustion will have proven or postulated environmental and/or Despite the serious uncertainties involved in health impacts, even with the level of pollu- identifying air pollution impacts and their tion control currently required by Federal, causes, all but one of the major pollutants State, and local regulations. Our inability to from coal combustion have sufficiently rec- assess accurately the level of impacts and their ognized impacts and means of control to have economic and social values leads to extreme warranted Federal regulation of their emis- difficulty in selecting appropriate levels ‘of sions. The exception is Carbon dioxide, which control. These inadequacies partially explain at current and expected ambient levels dis- the Federal strategy of choosing the “best plays no direct or immediate adverse impacts available control technology” instead of using on human health or on the biota but may con- an approach that would select control levels ceivably represent the greatest long-term more oriented to weighing costs and benefits. danger from an increase in the use of coal or Whichever approach is chosen, the selection other fossil fuels. Fossil fuel combustion over of controls clearly requires an understanding the past century appears to be a major cause of the control options and the associated costs

of increasing concentrations of COZ in the and difficulties. Earth’s atmosphere (deforestation may be

another major cause); C02 levels have in- Feasible control options are available for creased 5 percent since 1958 alone. Some pre- three of the four major pollutants generated dictions show CO, concentrations as doubling by coal combustion– particulate, SO2, and by the middle of the next century. This could NO,. The fourth, CO2 can theoretically be present a substantial risk of significant cli- scrubbed out of the flue gases, but the quanti- Ch. l—introduction and Overview ● 11 ty of absorbent required and volume of waste posed NSPS requirements for SO, removal effi- products generated appear to be too large for ciency and reliability. For instance, Japanese serious consideration. scrubber experience with medium-sulfur coal (the energy equivalent of 3 percent sulfur U.S. Control of SO emissions from large coal X coal) and operating conditions similar to those combustion sources can be accomplished by a in U.S. plants has been extremely successful, variety of measures, including selection of achieving reliabilities and control efficiencies low-sulfur coals, coal cleaning, flue-gas desul- in excess of 90 percent. furization (FGD), and several new combustion technologies. E PA’s proposed NSPS for coal- Alternative means of controlling S0x are fired electric utilities would guarantee that vir- available or under development for use on new tually all new powerplants would use FGD and existing coal-fired powerplants. Some of (scrubbers) to reduce S0, emissions. However, the alternatives offer reduction in NOX and/or stringent control of new plants and achieve- particulate in addition to S0x control. ment of full compliance with SIP requirements for existing plants will not substantially reduce Further control of existing powerplants can the 30 million or so tons of S0x emitted an- be accomplished by using low-sulfur coal or nualIy in the United States, because the S I P re- coal that has been physically or chemically quirements are often not very severe. Power- cleaned. Options that may become suitable piants, which have tall stacks, can in many cir- for new plants include solvent-refined coal cumstances emit very large amounts of pollut- (SRC-1, the solid form, which is the only one ants without seriously affecting local air quali- considered in this report), combined-cycle ty. In some instances, plants are burning rela- powerplants using liquid and gaseous fuels tively high-sulfur coal without controls even from coal, and fluidized-bed combustion though they are in full compliance with their (FBC). SRC-I and FBC may also become useful SIPs. Thus, there is considerable room for fur- in promoting environmentally sound coal use ther reduction of SOX emissions if such a in smaller industrial and commercial units. Ad- reduction were dictated by national policy. vanced electrical generation systems are undergoing R&D but do not appear to have the The scrubbers required on all new power- potential to make a serious impact on energy plants are expensive to build and operate. The use for at least the next several decades. scrubber system on a 500-MW powerplant might cost $50 milIion to $75 million out of a The extent of application of these alterna- total plant cost of $400 million, and add 0.4 to tives depends on their costs. Except for low- 0.8 cents to each kilowatthour of electricity sulfur coals, state-of-the-art FGD systems, and the plant produces. Furthermore, Iime/lime- mechanical cleaning systems now in use, the stone scrubbers, the systems that currently costs of the alternatives are specuIative. dominate the utility market, are throwaway processes and therefore generate wastes that Control of NOx is currently accomplished by are themselves considered a significant en- design modification and adjustment of oper- vironmental problem. This problem is dis- ating conditions rather than using “add-on” cussed in more detail in the next section. controls. Effective techniques for minimizing

NOX emissions are staged combustion, which Scrubber installations in this country have reduces excess air in the boiler, and burner been beset by many significant operating prob- designs which delay mixing of fuel and air. lems, including extensive scaling of surfaces, Combinations of these and other strategies failure of stack linings, corrosion and erosion have succeeded in lowering NOx emissions of critical components, and plugging of ori- from large utility boiIers by 40 to 50 percent. fices. The utility industry generally considers scrubbers to be an unreliable technology and Although gas-cleaning systems for NOx con- an inefficient means of achieving control of trol are not currently used in this country, a S0x. There is available evidence, however, that number of processes are under development. U.S. utility operators can comply with pro- The Japanese are the most advanced in this 12 . The Direct Use of Coal field. These processes included injection of about increased gaseous emissions caused by ammonia or various solids into the combustion these systems). chamber, and scrubbing of the flue gases using The proposed Federal requirements for par- absorbents such as magnesium oxide. Capital ticulate control are said to be too stringent to costs of these systems are said to be of the be universally met by ESPS. Compliance with same order of magnitude as FGD. the proposed requirements (a particulate NSPS

EPA is developing a IOW-NOX burner for of 0.03 lbs/million Btu of heat input) for utility coal-fired boilers that it hopes will be inexpen- boilers burning low-sulfur coal may require the sive and effective. (EPA hopes for an 85-per- use of baghouses. However, baghouses are a cent emission reduction relative to an uncon- relatively untried technology for large coal- trolled boiler. ) If successful, the burner could, fired boilers. A few systems have been in- by the late 1980’s, cut back sharply on pre- stalled or ordered for such plants. The experi- dicted rises in NOx emissions. ence of these plants will be influential in determining the future direction of particulate con- High efficiency control of particulate has trol in the utility industry. been a long-term practice in the electric utility industry, the dominant user of coal. Although The choice of technology is particularly im- mechanical or cyclone collectors were exten- portant in terms of controlling fine partic- sively used in the past, ESPs are the collection ulate and trace elements. ESPS are not effi- technology on most coal-fired utility boilers cient collectors of “respirable size” particles, today. ESPs collect particulate by charging and a continuation of current particulate-con- the individual particles and collecting them on trol technology could lead to substantial (and plates to which a powerful opposite charge has potentially dangerous) increases in fine-partic- been applied. They often can attain collection ulate emissions over the next several decades. efficiencies of over 99 percent. Baghouses, on the other hand, can be designed to collect fine particles at greater than 99-per- Requirements for control of SO emissions X cent efficiency. from coal combustion and resulting increased use of low-sulfur coal have created problems for ESPs. The ash particles from low-sulfur coal Impacts on Land and Water are usualIy of high resistivity and are not easily In contrast to the impacts of air pollution, charged and collected by the ESP. Degrada- most impacts of water pollution, solid waste tion of performance from a shift to low-sulfur disposal, and land disturbance are more con- coal can be extremely severe, with particulate centrated geographically. They are controlled emissions increasing tenfold or more. Design- less by technological devices than by adjust- ers of new powerplants have attempted to ments in operating procedures, and the degree solve this problem by increasing the size of the of control obtained is often extremely depend- ESPS or installing them at a hotter (lower resis- ent on local conditions. Thus, appropriate en- tivity) part of the exhaust cycle, or by using forcement and careful monitoring are espe- controls that depend on the mechanical rather cially important to the success of controlling than electrical properties of the particles. these impacts. These “mechanical” controls include wet scrubbers and baghouses (fabric filters). In the past, coal development in general, Although these options may be available to and mining in particular, were often devastat- some existing plants, many plants have space ing to both land and water ecosystems. The limitations or want to avoid large capital ex- major damage from mining was caused by the penditures because of their limited remaining acid drainage from both underground and sur- operating life. Flue gas conditioning, which in- face mines, the lack of adequate restoration of volves the injection of a chemical into the flue surface-mined Iand, and the subsidence of gas to coat the particles and reduce their resis- lands overlying underground mines. Ecological tivity, may be an attractive option for such damage also resulted from the heating of sur- plants (although questions have been raised face waters by powerplant cooling systems. Ch. I—Introduction and Overview . 13

All of these impacts are now addressed by closure, This problem may taper off as Federal legislation. As a result, some prob- shallower reserves are exhausted and new lems— in particular, acid mine drainage from mines begin to exploit coal seams that are large active mines, and powerplant thermal deeper than the water table. Many of these pollution — have been virtually eliminated as mines wilI be flooded, allowing the seams to significant problems for future development. be shut off from the oxidation that creates the All of the others have been reduced, although acid drainage. substantive problems of enforcement and/or Another impact of underground mining that availability of effective controls remain. Also, will not be fulIy controlled is subsidence of the some new problems may resuIt from the re- land above the mine workings. Unfortunately, gional shift of coal production to areas where there are no credible estimates of potential little experience can guide new operations, subsidence damage from future underground and from the generation of waste products mining. Subsidence, Iike acid drainage, is a from air pollution control measures. long-term problem. However, SMCRA does not Mining.–Approximately 60 percent of na- hold the developers responsible for sufficient tional coal production comes from surface time periods to ensure elimination of the prob- mines, and the proportion will not rise much. lem, nor does it specifically hold the developer The use of new mining methods that integrate responsible to the surface owner for subsi- reclamation into the mining process and en- dence damage. The major “control” for subsi- forcement of the Surface Mine Control and dence is to leave a large part of the coal re- Reclamation Act (SMCRA) should reduce the sources — up to 50 percent or more — in place importance of reclamation as a critical na- to act as a roof support, There is obviously a tional issue. However, concern remains that conflict between subsidence prevention and the combination of development pressures removal of the maximum amount of coal. and inadequate knowledge may lead to Moreover, the supports can erode and the roof damage in particularly vulnerable areas— CO I lapse over a long period of time. The re- alluvial valley floors in the West, prime sulting intermittent subsidence can destroy the farmland in the Midwest, and hardwood value of the land for development. A second forests, steep slope areas, and flood-prone “control” technique — IongwalI mining — actu- basins in Appalachia. Although most of these ally promotes subsidence, but in a swifter and areas are afforded special protection under more uniform fashion. Longwall mining is SMCRA, the extent of any damage will depend widely practiced in Europe but is in Iimited use on the adequacy of enforcement of the new in the United States. It is not suitable for all strip-mining legislation. Assuming strong en- situations, forcement of SMCRA, no major problems with Although all types of mining have the poten- acid mine drainage from active surface and tial to severely impact ground water quantity underground mines shouId result from in- and quality by physical disruption of aquifers creased coal development. However, inactive and by leaching or seepage into them, this mines may stiII present some technical control problem is imperfectly understood. The shift problems. Although a very small percentage of of production to the West, where ground water inactive surface mines may suffer from acid is a particularly critical resource, wilI focus in- seepage, problems with underground mines creased attention on this impact. As with other should be the primary problem. Despite a long sensitive areas, SMCRA affords special protec- history of Federal and State efforts aimed at tion to ground water resources, but the ade- controlIing acid drainage from inactive under- quacy of this protection depends on the state ground mines, some mining situations do not of knowledge about the problem and on the al low adequate permanent control once active level of enforcement, mining and water treatment cease. A significant percentage of the mines that are active at Impacts of Combustion and Waste Disposal. present or that will be opened in this century The major impact of coal-fired combustion will present acid drainage problems on sources on the land and water stems from the 14 . The Direct Use of Coa/ secondary effects of environmental controls — The impacts caused by the disposal of pow- the effects of cooling tower blowdown and erplant waste heat into the environment are water consumption, and those of the waste relatively independent of the fuel source, al- products collected by air pollution controls. though impacts from the current generation of nuclear powerplants will be somewhat higher Most powerplants built in the future will use per kilowatt than those of similarly sized fossil- closed-cycle cooling, so that thermal damage fired plants because of the nuclear plants’ from once-through cooling systems will not be lower efficiency. Thus, the effects of blow- an impact of future coal development. How- down and water consumption should be attrib- ever, the concentrated salts, or “blowdown,” uted to electricity demand rather than specifi- from these closed-cycle systems are dis- cally to coal use. charged into the Nation’s waterways. The dissolved solids discharged by coal-fired electric Both the particulate control devices and S02 utilities, of which blowdown is the predomi- scrubbers on coal combustion faciIities pro- nant source, are nearly 20 percent of the total duce massive quantities of wastes (projected national dissolved solids discharge. Although to be approximately 80 million tons of ash and effluent limitations have been established slag and 20 million tons of sludge by 1985, or under the Clean Water Act, increases in utility fully half of the Nation’s total noncombustible coal burning will play an important role in the solid waste and industrial sludge), which can expected substantial growth in the discharge cause land use problems and environmental of dissolved solids in the South Atlantic, Mid- damage unless properly managed. west, North-Central, and Central regions. A 1,000-MW powerplant may require a dis- An additional impact of closed-cycle cool- posal area of 500 acres or larger for a 30-year ing systems results from their water consump- period, even assuming that the sludge is dried tion, which is approximately double that at- and the wastes are 20 feet thick. However, the tributed to once-through cooling. Although the land use problem posed by this requirement is magnitude of consumption for a particular fa- eased by the Iikelihood that most new power- ciIity varies with location, a 3,000-MW powerplants will be built outside of densely popu- plant can be expected to consume between lated areas, where more land is available. 20,000 and 30,000 acre-feet per year (mostly for cooling). If a number of these plants are The major environmental problem associ- built in the arid portions of the West, their ated with waste disposal is the contamination water requirements could exacerbate existing of surface and ground waters by leaching of water problems in several river basins — for ex- trace elements from the ash and sludge. ample, in the Upper Colorado and Yellow- Although the ash contains by far the greater stone. Reduced flows can interfere with the amount of trace elements, the fluid that is rivers’ assimilative capacity and in some ex- trapped in the sludge also presents a signifi- treme cases damage or destroy ecosystems cant leaching problem for years after disposal. from sheer lack of water. This problem is as much institutional as physical, because much The actual environmental damage caused of the water consumption in the West results by disposal of these wastes will depend on the from existing water allocation and pricing pro- form of the regulations and the firmness of en- cedures that undervalue the water; the ab- forcement of the Resource Conservation and sence of a comprehensive Federal water policy Recovery Act (RCRA). Methods exist for reduc- hinders the resolution of these problems. Fur- ing or controlIing the potentialIy severe impact thermore, technological means (dry or wet-dry on ground water, but they are expensive and cooling systems) are available to sharply are likely to be applied only sporadically reduce powerplant water consumption, unless they are required by law; some may be although the systems are expensive and lower difficult to monitor and enforce. These meth- plant efficiency. ods range from lining of disposal ponds and Ch. I—Introduction and Overview ● 15

landfills, chemical stabilization of the scrub- sema, and other impairments— some of which ber sludge, and alteration of the chemistry of are caused, or worsened, by cigarette smoking. the scrubber (to create a more manageable The prevalence of respiratory disease is prob- waste), to utilizing regenerable scrubber sys- ably less today than it was 10 years ago be- tems and virtually eliminating the sludge por- cause about 50,000 older — and often dis- tion of the problem altogether. Designation of abled — miners have retired and about 150,000 ash and sludge as hazardous materials under new workers have been hired. RCRA would force use of these controls, but, To prevent CWP from disabling miners in according to the Department of Energy (DOE) the future, Congress mandated a 2-mg/m3 estimates, could almost double disposal costs standard for respirable dust (the small particles over present practices. (Industry thinks these that cause pneumoconiosis). This standard was estimates are too low. ) A side effect could be based on British research done in the 1960’s to eliminate some present uses of ash, such as and is lower than any other country ’s. How- its use in roadbeds. Twenty percent of the ash ever, critics now question the inherent safeness produced by the utility industry is construc- of this standard and the soundness of the Brit- tively used rather than being disposed. Even ish methodology. The safeness of the standard, without a “hazardous” designation, however, which was based on mathematical probabil- a rigorously enforced RCRA will force substan- ities, must stilI be confirmed by long-term tial changes in present disposal practices to epidemiological evidence. The Federal dust- protect ground water. sampling program, which is intended to measure compliance with the standard, is not a reliable indicator of daily dust exposure. Many Workplace and Community Impacts opportunities for intentional and inadvertent sampling errors exist. Sampling is so infrequent Coal Worker Health and Safety and the timelag in reporting the results back to the mine so great that sampling has Iimited rel- Coal mining has always been a hazardous evance to actual dust control. A monitoring occupation. The 1969 Federal Coal Mine program based on continuous sampling and Health and Safety Act addressed some work- immediate correction may prove to be a more related health and safety hazards, explosions useful approach. Because black lung compen- and dust control in particular. But coal work- sation is costly and because several hundred ers are likely to continue to suffer from occu- thousand more miners will be employed in the pational disease, injury, and death at a rate next 25 years, it may prove useful to reassess well above other occupations, and the total the safeness of the dust standard and to eval- magnitude of these impacts will grow along uate alternative dust-sampling procedures. with the growth in coal production. If respirable dust is controlled effectively, The mine-worker health issue that has re- CWP will be reduced and a major source of ceived most Congressional attention is black black lung disease will have been addressed. lung disease, the nonclinical name for a vari- However, other sources and potential sources ety of respiratory illnesses of which coal of miners’ respiratory disability may require at- workers’ pneumoconiosis (CWP) is the most tention. Other coal mine dust constituents— prominent. More than 420,000 Federal com- the large dust particles (that affect the upper pensation awards were made between 1970 respiratory tract) and trace elements — deserve and the end of 1977, costing the Government additional research. Toxic fumes from mine more than $5.5 billion. The industry will pay a equipment fires and diesel emissions are haz- greater share of the compensation costs in the ards that may deserve regulation. Cigarette future as a result of the 1977 black lung legisla- smoking increases breathing difficulties in dis- tion. Ten percent or more of working coal eased miners and probably shouId be discour- miners today show X-ray evidence of CWP, and aged in this work force. Under the most opti- perhaps twice that number show other black mistic assumptions, it is estimated that 11,000 lung illnesses— including bronchitis, emphy- to 18,000 working miners will show X-ray evidence of CWP in 2000 and at least an equal may conflict with improved health goals. The number will exhibit other respiratory impair- introduction of continuous miners in the ment. Even more retired miners will have CWP, 1950’s raised productivity and lowered fatal- and many will be disabled by it. If dust control ities and injuries because the work force was is not effective or adequate, disease preva- reduced by 70 percent. But the new machines lence will be higher and more cases of CWP produced higher dust levels, which caused and black lung wilI be found. higher rates of black lung. Longwall mining systems appear to be more productive than Mine safety — as distinct from mine health — other units and safer in terms of fatalities, but has shown a mixed record of improvement not in injuries. About half of the longwaIls since the 1969 Act was passed. The frequency surveyed recently did not meet the respirable of mining fatalities has decreased for both sur- dust standard. Speeding up the pace of work to face and underground mines, but no consistent increase output is likely to increase accident improvement has been seen in the frequency frequency. Improved workplace relations and of disabling injuries. Coal worker fatalities less absenteeism are likely to increase both numbered 139 in 1977, and disabling injuries productivity and safety. approached 15,000. Each disabling injury resulted in an average of 2 months or more of Mine-safety analysis is made difficult by lost time. The number of disabling injuries has weaknesses in the recorded Federal data. Re- been increasing as more workers are drawn to porting practices are not uniform throughout mining and accident frequency remains con- the industry. Some companies have adopted stant. light-duty policies (with respect to injured workers) that allow them to report fewer dis- On the whole, surface mining is several times safer than underground mining. But abling injuries. Some companies probably do some underground mines show safety records not report all injuries and illnesses. The Mine equal to or better than some surface mines. Safety and Health Administration (MSHA) has Generally, western surface mines are safer tightened its reporting requirements recently, than eastern surface mines. As western sur- and better reporting should result. face-mine production assumes increasing As more coal is mined and more miners are prominence, accident frequency industrywide hired, the number of coal worker fatalities and is Iikely to decline when expressed as acci- injuries is Iikely to increase even if accident dents per ton of output. But this statistical frequency improves somewhat. Depending on trend may conceal no improvement or even a future coal production levels, between 157 and worsening of safety in deep mines. 187 coal workers are likely to be killed and be- Post-1 969 mine safety performance is re- tween 17,400 and 20,800 injured in 1985. That lated to several factors. High-fatality mine dis- represents a 13- to 35-percent increase in fatal- asters have been reduced substantially. Oper- ities over 1977 and a 17- to 39-percent increase ator compliance with Federal safety standards in injuries. I n 2000, between 259 and 371 coal and frequency of inspection appear to be cor- worker fatalities are forecast and between related with improved safety. Big, new mines 29,200 and 41,800 injuries. These estimates that have been opened since 1970 tend to be represent an 86- to 167-percent increase in safer than older, smaller mines. Greatly im- fatalities over 1977 and a 95- to 180-percent in- proved coal profitability in 1974 and 1975 crease in injuries. These calculations assume coincided with the industry’s two best years in no underreporting and undercounting. The 25- reducing injuries. The emphasis on safe work year total (1976-2000) of mine fatalities may ex- by the United Mine Workers of America ceed 5,000 and injuries may exceed 500,000. (UMWA) and Federal agencies were other important factors. Reducing these numbers calls for action in several areas that may conflict with increased Labor-saving technology or different work productivity. Federal policy should address processes may or may not improve safety and three main issues: Ch. I—Introduction and Overview . 17

1. reducing the number and frequency of region and may impede rapid coal growth in disabling injuries, several dozen counties. 2. assessing the safety costs of increased production and productivity strategies, Coal development will occur in three dif- and ferent kinds of communities. Many Appalach- 3. reevaluating the effectiveness of existing ian communities are hampered by the legacy Federal enforcement programs. of historical underdevelopment. Coal-based growth will continue the pattern of a “one- Equipment can be designed with improved crop” economy with all of the costs and safety as a factor. Broader Federal equipment benefits of that mode of economic develop- standards could help. Western and Midwestern ment. In other Appalachian communities and surface mining could be encouraged by Fed- in the Midwest, coal will be mined in com- eral policy, but this emphasis would probably munities with diversified economies. The have severe employment and price impacts in social costs of coal development are likely to the East. Predictable growth in coal demand be the least substantial there. In the West, coal and steady profitability might be encouraged development will create boomtown growth in to further enable companies to devote time some counties and towns. The extent of coal’s and money to safety and . health. Federal social costs (both public and private) depends inspections —the factor apparently most di- on the rapidity of development, the adequacy rectly correlated with good safety— could be of existing public services, the ability of local increased. More severe sanctions against communities to manage growth, the level of chronic high-accident operations might be local public participation in coal develop- considered. More effective safety and job ment, the kinds of mines that are planned, and training, coupled with increased participation the attitudes of mine operators and the local of coal miners in safety and health efforts, may citizens toward development. also prove fruitfuI.

East.–The Appalachian coalfields have pro- Community Impacts duced more than 90 percent of all coal ever mined in the United States. Because they never Coal mining brings many diverse benefits experienced a sustained period of growth and and costs to coalfield communities. The profitability, operators were forced to cut private sector— mine operators, coal workers, costs simply to stay in business. Local jurisdic- and local business— benefits from steady coal tions were usually unable to raise sufficient tax output through profits, wages, and spendable revenue to provide adequate public services income, respectively. Private production costs because taxes on coal might have handi- are paid by the mine operator. But when costs capped the ability of local operations to com- are externalized, mine workers and local pete. Roads, schools, water and sewage facil- private interests often pay them. These costs ities, recreation, health care, and local public can be measured in dollars, human health, and administration suffered from this unwilling- environmental quality. Coal production also ness or inability to tax adequately coal produc- entails public costs and benefits. Local com- tion and undeveloped coal reserves. The munities will benefit from population growth cyclical nature of coal demand also made ra- (at a manageable pace), more tax revenues, in- tional, public financial planning difficult. The creased employment, and better services from lack of diversified economies made spendable wisely planned coal development. On the income and public revenue in coal towns other hand, if growth is too rapid, communities almost totally dependent on the whims of de- may be unable to expand services fast enough. mand for local coal. For most of the 1920-70 Even without much coal growth, the public period, overall coal demand stagnated, which costs of past mining in Appalachia are substan- meant that State and local tax revenues did tial and deserve redress. Chronic community not increase greatly even during the short-1ived underdevelopment exists throughout this booms. The company-town system, which was 18 The Direct Use of Coa/ the main form of community socialization shortcomings. I n communities where underde- throughout most of the Appalachian coal- velopment is least, boom conditions are likely fields, intensified community dependence on to be most readily accommodated. Several local coal sales. Many of today’s coal towns growth-related problems are worth identifying. began as company towns. They have yet to Housing is crucial to expanding coal produc- compensate for the public deprivations char- tion. Both the supply and adequacy of coal- acteristic of their earlier underdevelopment. field housing are deficient. Most coalfield land On the other hand, whatever public infrastruc- is owned by coal producers or land-owning ture exists today in these communities stems companies, which generally refuse to sell land from coal development. Had coal mining not suitable for housing. It is often uneconomic for begun 80 or 90 years ago, these counties might them to sell the surface rights to coal-bearing have even fewer public services than they do land, and future liability for subsidence is also today. They would have small populations and a constraint. Consequently, coal field housing little industry. But they would also have few of supply is deficient and many areas have experi- the social costs of coal development. enced severe congestion and inflated land and No significant net increase in Eastern coal housing prices. Private builders and mortgage production is anticipated before 1985, al- money are in short supply. The quick-fix “solu- though substantial production gains should oc- tion” to the lack of land and housing has been cur thereafter. This interval can be used to the mobile home. This is widely seen as less de- plan how coal development can be managed sirable than single-family construction. The best. Yet severe community overloads are al- lack of housing has made for long commutes ready apparent in much of Appalachian coal- between home and workplace, which may con- fields, where the combination of existing in- tribute to absenteeism. To increase housing adequacies and thousands of new miners has SUpply, land and mortgage money will have to . overwhelmed the ability of communities to be made available. In many places, a housing- provide services. construction industry must be assembled Appalachia will experience two contrasting almost from scratch. Increased flood-control patterns in the early 1980’s. Some communities measures are necessary to permit building on where metallurgical or high-sulfur coal is valIey fIoors. mined are likely to continue to stagnate be- Roads in the Appalachian coalfields are gen- cause of weak demand. Production will not in- erally in poor condition. Most were badly con- crease, although the coal-related population structed initially. The shortage of tax revenues may grow. Historical patterns of underdevel- and heavy coal-truck traffic have left them in a opment will continue. Two to three dozen constant state of disrepair. Illegal overloading counties may fit this pattern. For more than a of coal trucks is widespread and contributes year, 10,000 to 15,000 Appalachian miners heavily to roadway destruction. To upgrade have been working irregularly because of slack the 6,880 miles of coal-haul roads judged in- demand. Little has been done to encourage adequate to meet the current volume of coal coal demand from these hard-hit areas or to traffic would cost an estimated $4. I to $4.9 bil- plan the economic diversification of their I ion, with another $600 million to $700 million economies (an even sounder long-term ap- to replace inadequate bridges. Small fractions proach). of these sums are now spent on maintenance, The opposite case will find boom-like condi- and even less on reconstruction and rehabilitations imposed on underdeveloped communi- tion. Strict enforcement of maximum load ties. Production and population will increase standards is necessary to take full advantage rapidly. Spendable income and demand in con- of dollars used for road repair. Alternatives to sumer goods will rise. Demand for housing and coal-truck haulage such as overland trams, public services will increase sharply and may conveyor belts, and slurry pipelines would not be met. Local tax resources may not pro- limit future road damage and inconvenience. vide needed public services. Production and Increased appropriations for road repair productivity may be slowed because of these (whether raised by general taxes or user taxes) Ch. I—Introduction and Overview ● 19 are likely to be a less cost-effective— but a local level in the next few years, Congress may necessary — option. wish to consider this matter systematicalIy.

Other kinds of services and facilities are Midwest.–Coal counties in the Midwest are often inadequate. Many towns have limited Iikely to be in a better position to benefit from water and sewage treatment systems — if they increased coal development than either Appa- have any at all. This constrains the develop- lachia or the West. These counties generally ment of private housing. Health care services have diversified economies, which have made fall short of national standards. Recent refi- them less vulnerable to coal’s booms and nancing of the UMWA medical plan appears to busts. Because much of their tonnage will have weakened coalfield health delivery sys- come from surface mines, the rate of popula- tems. Public administration is competent in tion growth is not likely to be excessive. some places, but planning, familiarity with Because local tax revenues here were higher assistance programs and sol id local develop- than in Appalachian counties, community ment strategies are often lacking. Opportun- services are generally better. As a rule of ities for recreation and education are often thumb, it has been found that where coal min- limited. ing has been the single, dominant economic activity, communities are least prepared to While some Appalachian coal communities manage rapid coal development. Counties will be able to handle rapid coal growth with where mining has been less prominent and little difficulty, many will not. It is difficult to economics more diversified appear to be more quantify the implications for Eastern coal pro- able to benefit from rapid development. Most duction of community underdevelopment. of the Midwest fits into this category. Common sense, as well as several recent West.–Significant Western coal production studies, suggests that the ability of the East to is a recent phenomenon. Today, about 9,000 produce more coal rests in part on controlling miners produce more than 20 percent of na- the future social costs of increased production tional production. Future growth will be rapid. and dealing with present inadequacies. To in- Between 34,000 and 42,000 miners will be ternalize fully the social and environmental working in the West by 1985. Six States —Col- costs of coal mining, coal will have to be orado, Montana, New Mexico, North Dakota, priced to reflect its true costs of production. Texas, and Utah–are each expected to add 55 million to 61 million tons more annual capaci- Federal policy makers face difficult ques- ty by 1987, according to optimistic forecasts. tions with respect to Appalachian coal devel- Wyoming may be able to produce more than opment. The first is who should pay to rectify 270 million additional tons by that year, al- coal’s accumulated social deficit. The general though 147 million tons is a more plausible public? Current coal consumers? Coal oper- estimate. Depending on how much actual pro- ators out of their profits? State and local duction occurs, from 6 to 11 western counties governments through coal taxes and generaI will experience population growth rates ex- revenues? Second is the question of how to ceeding 5 percent annually. Four of these establish new patterns of economic development that will bring local social costs and counties are in Utah, where underground mining (with its comparatively high labor re- benefits into balance. Policy makers may wish to examine alternative ways of accomplishing quirements) will take place. Mercer County, N. Dak., and Campbell County, Wyo., are also this end, such as economic diversification plans financed by revenues from coal develop- vulnerable. If coal production matches optimistic Industry predictions, two Colorado ment, public regulation of coal development, counties and three Montana counties will also and better planning. No Federal policy now ad- show 5-percent growth rates. Towns in other dresses these complex issues, although the Ap- counties wilI also experience boom conditions. palachian Regional Commission and the Presi- dent’s Commission on Coal are examining Western towns have had varied degrees of them. If serious breakdowns develop at the success coping with rapid coal growth. Some, 20 ● The Direct Use of Coa/ like Rock Springs, Wyo., reflect a range of slurry pipelines are probably the least disrup- social problems and genera I community break- tive modes but can be used only under special down. Others, like Gillette, Wyo., have mud- conditions. An alternative to coal haulage is dled through the initial boom problems and electric transmission. Its major liabilities are are in the process of managing growth with the health and safety concerns of high-voltage some success. Western towns often find them- electric fields (as yet unquantified) and the selves short of housing, water and sewage visual impact of towers and rights-of-way. The treatment systems, health care facilities, and health issue is particularly controversial and front-end revenues. With some exceptions, requires considerable research. local tax revenues appear to be able to provide needed services in the long run, although revenue shortages may be felt during the first 5 Impacts on Coal-Using Communities years or more of rapid growth. Coal mining can easily dominate local com- Indian coal development presents special munities, but combustion facilities tend to be issues. Although considerable tonnage may be a much smaller— and more stable— part of mined from Indian reservations, relatively few community economic activity. When a coal- new miners — perhaps several thousand — are fired powerplant is built, several impacts likely to be employed there. Most are expected occur— increased wage income and employment, side by side with more air pollution and to be Indians already living on the reservations. Western tribes are now insisting on disruption from transport. As the literature on Indian-preference in mine employment in their the social impacts of powerplant operation is limited, this study surveyed public attitudes of reservations along with higher tonnage roy- residents near three large powerplants. In all alties. Boomtowns are not expected to occur cases, the respondents living within 3 miles of on the reservations, although several reservation towns may show high population growth. the pIants found them objectionable. This attitude diminished rapidly with distance. The Boomtown conditions are not likely to con- most widely perceived disadvantage was air strain Western coal production goals. But Fed- pollution. The major perceived advantages eral policymakers must face questions con- were employment and the availability of cerning equity of sacrifice, responsibility for energy. In general, slightly more than half the controlling the social costs of private energy respondents found the plants to be reasonably development, and responding to local de- acceptable neighbors. mands for assistance. As in much of Appalach- ia, many western towns will need to deal with one-crop economies, rapid population growth, Factors Affecting Coal and revenue shortages. Production and Use

All of coal’s major supply factors — reserves, Social Impacts of Transportation labor, capital, and industrial infrastructure— Coal transportation can be barely notice- must be available to support greatly increased able, or it can create a major disturbance — de- production. From time to time, each may be- pending on means used and the route chosen. come a short-term bottleneck, as in the case of About two-thirds of all coal is shipped by rail- a national strike. But none, either singly or road. More fatalities result from coal transport together, is expected to hamper the mining of than from mining. New routes may have to be as much coal as can be sold over the next 25 selected to avoid populated areas. Grade years. However, attainment of the highest coal crossings will have to be improved to prevent scenarios could be precluded by any of several accident and disruption. Trucks are used for factors. Many potential constraints will be short hauls, especially in Appalachia. They alleviated in the normal course of events. contribute greatly to road deterioration, dust, Others may require special attention. These and highway safety problems. Barges and factors are discussed below. Ch. /—/ntroducfion and Overview c 21

Coal Availability and Leasing and between 40 to 45 percent of alI utility consumption. Five of the top 15 producers are cap- Unlike other domestic fossil fuels, coal is tives, owned by steel companies or utilities. still plentiful. In the East, most coal reserves The others are owned by horizontally inte- are owned by producers or landowning cor- grated energy companies or conglomerates. porations. About 65 percent of all coal re- Only two are independent coal companies. In serves in the West, however, is owned by the the last 10 years, three trends have emerged Federal Government and can be mined by pri- and are Iikely to continue: 1 ) increasing con- vate companies only under Federal lease. The centration among companies selling in region- rest is owned by States, Indian tribes, or cor- al and specialized markets; 2) increasing porations. About 17 billion tons, or 5 percent utility-owned production (known as vertical in- federally owned coal resources have been tegration); and 3) growing ownership of coal competitively leased. This is far more than will production by horizontally integrated energy be mined over the next decade in the West, but companies. the characteristics of the tracts leased and the needs of the mining industry are such that fur- Competition, price, and coal supply are mat- ther leasing may be required soon to meet pro- ters directly affected by industry structure. induction projections for 2000, dustry advocates and critics disagree over A leasing moratorium is now in effect while whether or to what extent these factors have procedures are being devised to remedy past been affected by the changes in coal owner- abuses. The Carter administration plans to end ship. Although a number of recent studies have the moratorium in the early 1980’s. In the in- examined the competitive structure of the coal terim, only leases necessary to maintain an ex- industry, none has focused the quantitative isting mining operation or to meet existing con- analysis properly or developed the case study tracts are issued. The new leasing program will information that would justify definitive con- emphasize public participation and environ- clusions. As coal production from utility- mental acceptability in the context of multi- owned mines and energy-company mines is ple-use land management. In addition, leases likely to increase faster than coal production may be reorganized to reflect logical mining nationally, the competitive implications of units, and they may be required to meet such ownership patterns deserves close anal- criteria of diligent development and continued ysis and monitoring. operation. The terms of all existing leases will not be modified under the revised leasing pro- Labor Profile gram. This exclusion has drawn criticism from Today’s 237,000 coal workers are a diverse environmentalists, Indians, and others. With group. More than 140,000 work in underground the resumption of leasing, coal operators will mines, whiIe 65,000 work as surface miners. be able to plan with a degree of certainty that Others work on new mine construction proj- has been lacking in the recent past. Until ects, and in preparation plants, mine-related Federal leasing policy is finalized, it is not shops, or mine offices. About 2,000 are possible to determine the extent to which the women. More than 10,000 are Black, Hispanic, overall policy will encourage or constrain the or Indian. More than 90 percent Iive East of the development of coal reserves on public lands. Mississippi River, and most of those work in the Appalachian fields. Although about half of Industry Structure all coal production in 1985 and 2000 will come The structure of the bituminous coal in- from west of the Mississippi, more than 80 per- dustry is complicated and dynamic. Although cent of the labor force will work east of it. there are more than 6,000 operating mines, it Most of this group will work in underground has been estimated that there are only about mines and in Appalachia. The work force is 600 independent producers or producer young: the median age for underground miners groups. The 15 top coal operators mined about is about 33; for surface miners, about 37. As 40 percent of all domestic production in 1977, the current work force ages, job experience should increase. This should improve safety strikes more frequently when coal demand was and productivity. firm and employment security was high.

Between 65 and 70 percent of all coal work- Wildcat strikes occurred with unprece- ers are members of UMWA. They account for dented frequency between 1973 and 1978 about 50 percent of total national production. when coal prices more than doubled and de- The average annual income for most under- mand was growing. These strikes usually begin ground miners exceeds $1 7,000; for surface at a single mine. Sometimes they spread quick- miners, more than $20,000. (Some miners who ly to many others when a disputed condition log a great deal of overtime can earn $35,000 exists across the coal fields. Most wildcats are annually, but they are exceptions. ) Because of limited to one mine and arise over a disputed mining’s high wage rates and certain social fac- work condition, interpretation of the contract, tors, the turnover rate industrywide is probably or the miners’ perception of harassment. Sever- below average. However, where employment al were precipitated by widespread disgruntle is not steady or where community conditions ment over broader issues — compulsory shift- are perceived to be harsh, individual mines rotation, pending black lung legislation, con- have experienced high turnover. troversial school textbooks, gasoline ration- It is estimated that very little– if any– in- ing, the right to strike, the use of Federal increase in net mine employment wiII occur be- junctions against wildcat strikers, and cut- tween now and 1985. Although several thou- backs in medical benefits. Since the last con- sand miners will retire in these years, a suffi- tract strike, wildcat strikes have been much cient supply of younger workers appears to be less frequent. Poor market conditions, im- available. By 2000, however, mine employ- provement in the grievance procedure, and ment is estimated to increase by 45 percent to depleted savings are the probable reasons for 110 percent over 1977 levels. Most of these ad- the improvement. UMWA and mine manage- ditional workers will be needed in the East and ment appear to be improving their ability to should be available from indigenous coalfield resolve disputes, which should lead to less populations. Labor supply does not seem to be strike activity in the future. Many miners are as a problem in the boom areas of the West be- opposed to the recent level of wildcat strike cause of high wage rates. activity as are their employers because of the loss of income these shutdowns entail. But these strikes have always been a part of coal Labor-Management Relations and mining and may never be eliminated. There ap- Collective Bargaining pears to be little that Federal policy can – and Labor-management relations in the coal in- possibly should —do to stabilize this area of dustry have never been very good for very private enterprise. Harsh legal penalties long. This stormy relationship has been shaped against strikers do not seem to deter wildcat by the structure of the industry, the level of strikes in this industry. coal demand, the level of competition among coal producers, the nature of the underground Collective bargaining in the coal industry workplace, the social experience of the coal has usually been characterized by acrimony, camp, and the history of the effort to unionize strikes, cataclysmic rhetoric, and reluctant the work force. Federal involvement. The most recent contract impasse came in the winter of 1977-78, when One measure of the stability–if not the for 109 days, UMWA miners struck their em- quality–of day-to day relations in the work- ployers, their Government and, it can be said, place is the level of wildcat strike activity. their own negotiators. Miners engage in unauthorized work stoppages more than any other group of industrial The 1977-78 strike lasted almost 4 months workers; underground coal miners strike more because the Bituminous Coal Operator’s Asso- than any other group. Over the last 40 years, ciation (BCOA) insisted on a set of dramatic coal miners have participated in wildcat changes in the old contract. These changes— Ch. /—/ntroduction and Overview 23 involving health and pension benefits, the cerns. Western miners have had a tradition of future of the UMWA Funds, whether manage- militant unionism, and it may be premature to ment would have the right to fire and dis- conclude that western mines will necessarily charge strikers and absentee workers—were be nonunion operations. UMWA contract objectionable to rank-and-fiIe miners although strikes are Iikely to continue to affect most they were accepted by UMWA negotiators. metallurgical and export production, and BCOA members felt they were necessary to roughly half of Eastern steam coal output. achieve what they called “labor stability. ” The contract that was finally ratified incorporated Productivity many of the changes BCOA demanded. The Although productivity has declined since ramifications of this contract —the attempted 1969, the evidence suggests that it has not af- recall of UMWA President Arnold Miller, grass- fected the ability of the industry to produce as root discontent, and health care changes — are much coal as can be sold. Much of the ex- still working themselves out. It is likely that planation for the rise in productivity in the UMWA members will demand major revisions 1950’s and 1960’s has to do with mechaniza- in the current agreement in 1981. tion (which cut the work force by 70 percent by The executive branch has had little success 1969), the absence of workplace health and in mediating contract negotiations in this in- safety regulation, the lack of surface mining dustry, Both the union and the operators balk controls, the high level of job experience at Federal intervention, and miners have little among miners, and the ability of the industry respect for Taft-Hartley injunctions. Short of to externalize a variety of production costs. nationalization of the industry or draconian The hidden costs of rising productivity in labor controls, there is probably little that Con- these decades were unemployment, communi- gress can do to improve the negotiating/con- ty stagnation, black lung disease, unreclaimed tract ratification process. It is essentially a surface mines, and other environmental prob- private relationship in the private sector. Ris- lems. Several factors have combined to reduce ing coal demand and continued prosperity for productivity since 1970. A principal one is that mine operators should improve the climate of 44,500 UMWA miners– about half of the 1969 negotiations. As more and more production UMWA working membership, which repre- comes from non-UMWA mines, the national sented 74 percent of all miners — retired in the impact of UMWA contract strikes should de- 1970’s. These retireees had key production cline. This was clearly evident last year when, jobs, for the most part, and their productivity after the 3 ‘/z-month strike, no power shortages was high. Overall, about 60 percent of today’s were recorded and onIy 25,000 workers were coal workers have been hired in the 1970’s. laid off. State surface mining regulations cut productivity, as did Federal environmental controls. The dynamics of collective bargaining and The 1974 UMWA contract added an estimated labor-management relations are very much in 5,000 additional workers to the work force for flux. One factor behind the development of training and safety reasons. The 1969 Act western mines is the more tranquil labor situa- slowed down certain mining cycles to control tion in the West. Members of BCOA, which has methane, dust, explosions, and ground condi- negotiated industrywide contracts with tions. High prices in the mid-1970’s encouraged UMWA since 1950, may jointly or separately more than 1,000 small, low-productivity mines decide to begin negotiating regionally or on a to open. In addition, railcar shortages, ab- company-by-company basis. Observers dis- senteeism, and poor labor-management rela- agree about whether denationalization of col- tions contributed to low productivity. lective bargaining will reduce net lost time from contract strikes. High-income western The decline in productivity seems to have miners may become more inclined to unionize bottomed out. As more and more production is in the future as working conditions and job se- mined by western surface mines, larger mines, curity supplant wages as their main job con- and newer mines (both surface and under- 24 . The Direct Use of Coal ground), workers’ productivity should increase more attention should be paid to controlling gradually. Improved labor-management rela- the environmental, health, and safety costs of tions and more appealing community condi- doing so. Congress has enacted legislation to tions should reduce absenteeism, thus raising meet both objectives. Sometimes the objective productivity. An increasingly experienced of one legislative measure conflicts with the work force should boost efficiency. Stable objective of another. Compromises and trade- prices should discourage inefficient producers offs are often made, either as part of the regu- and prune inefficient mines. If the industry can latory process or in litigation. lower its injury experience, a contributing source of poor productivity would be ad- Much of the discussion about Federal coal dressed. No technological developments ap- policy quickly narrows to a discussion of pear to be on the horizon that will quickly and regulatory restrictions on supply and demand. dramatically raise productivity, although Lost in this process is the considerable effort several innovations, such as continuous face- given to helping industry produce coal and to-portal haulage and continuous roof support burn it. Federal research money for coal systems, should help. The most promising area amounted to about $73 million for the Bureau for productivity improvement is better job of Mines and about $669 million for the DOE training and restructuring work relations. fossil fuel program in FY 1979. Loan money has been made available to “small” underground Other Factors operators. Federal tax policy on depreciation and depletion encourages investment and Potential constraints on coal production in- reduces tax burdens. Millions of Federal tax clude supplies of water, capital, and equip- dollars are spent annually on highway con- ment, and transportation facilities. Although struction, inland waterways, and railroads that the United States appears to have an adequate benefit mine-to-market transportation. The Na- national water supply to meet projected tional Energy Act of 1978 promotes coal as a energy requirements in the near-term to mid- primary energy source. The Act significantly term future, severe local and regional short- strengthens Federal authority to order combus- ages as well as institutional constraints on tion facilities to convert to coal by prohibiting water availability could become problems. the use of oil or natural gas in new facilities as Although these problems could be alleviated well as the use of gas in existing facilities after through water conservation practices in a 1990. However, the impact of the prohibitions variety of sectors (e. g., energy, municipal, and may be difficult to ascertain because most agricultural uses), present water pricing and utilities are not planning new oil or gas units. water rights allocation systems do not encour- Where the prohibitions could have a major age these practices. impact —on smalIer industries — the amount of The availability of capital and equipment coal involved is not as great and exemptions for coal development are market factors that are more easiIy obtained. should not become constraints if the industry Significant Federal regulation of coal pro- remains economically sound. However, the duction and combustion is relatively recent, availability of transportation facilities could beginning in 1969 with the Federal Coal Mine impose local constraints on coal supply unless Health and Safety Act. Although mine safety track conditions are improved and the supply legislation had been enacted as early as 1910, of railroad cars is increased. Similar local it appears to have had little impact on fatal- transportation constraints are posed by inade- ities and injuries. The 1969 legislation im- quate coal haul roads and waterway systems. proved some mine conditions significantly, resulting in fewer high-fatality disasters and Federal Coal Policy lower dust levels. It did not, however, specifically address injury-prevention and little im- Federal coal policy emphasizes two goals: provement has been recorded since 1970 in more coal should be mined and burned, but this area. The 1977 amendments required train- Ch. /—/ntroduction and Overview 25 ing programs and tightened other aspects of Federal actions significantly affecting the the 1969 Act. To control respirable dust, quality of the human environment. Most major methane, poor roof conditions, explosive con- Federal coal-related programs (such as leasing) ditions, and other hazards, the 1969 Act re- and federalIy permitted activities (such as con- quired mine operators to take extra safety struction of a powerplant) are subject to the measures and hire more safety-related person- E IS requirement. Although the E I S process has nel, which contributed to declining productivi- increased institutional awareness of the need ty. However, this is a very complex issue and it to minimize adverse environmental impacts, it has not been demonstrated that the 1969 Act is has been criticized for its alleged attention to the principal cause of the decline, although it procedure over substance-and for the time it has been a factor. adds to the beginning of a project. In 1978 the Council on Environmental Quality promul- The Surface Mine Control and Reclamation gated new E I S regulations that are designed to Act of 1977 is designed to change coal mining reduce paperwork and delays, improve EIS practices that generate severe social and en- quality, and better integrate the E IS into agen- vironmental costs and to prohibit mining in cy decision making. These new procedures areas that cannot be reclaimed. The Act sets should remove most of the objections to NE PA performance standards intended to prevent and result in better decisions and greater en- adverse environmental impacts, such as vironmental protection. ground and surface water contamination and degradation of agricultural land quality. Federal policy toward air quality is imple- Operators must demonstrate, as a prerequisite mented under the Clean Air Act Amendments to obtaining a mining permit, that the land can of 1977, which will speed achievement of am- be restored to a postmining land use equal to bient standards and allow greater growth in the or better than the premining use. I n addition, future since each new facility will limit its significant constraints are placed on coal min- emissions as strictly as possible. However, the ing in the prime farmlands of the Midwest and amendments do not reflect a consistent uni- in the alluvial valleys of the arid and semiarid fied approach to some of the fundamental regions of the West. Enforcement of these problems, and the overall effect of the Act is standards wilI play a critical role in determin- difficult to assess. Exemptions for smaller ing the effect of the Act on coal production. sources and the Amendments’ failure to deal with pollutant transformation and transport Much controversy exists over whether and may undermine the air quality protection in- to what degree the 1977 Act will impede coal tended to accommodate new large coal-fired production. Certainly, it will increase the costs sources. Coal-fired facilities may also require of surface-mined coal. It may also hit small greater expenditures for pollution control operators harder than larger companies. Pro- equipment or be subject to stricter siting and ductivity may be affected as more worker time other preconstruction review procedures; thus and equipment are devoted to preventing en- they may be at a competitive disadvantage vironmental damage. It will be several years, relative to cleaner fuels. In addition to these however, before an accurate assessment of the increased costs, coal combustion may be pro- impact of this Act can be made. hibited near areas where air quality-related values are important, such as national parks The major concerns in managing the envi- and wiIderness areas. ronmental impacts of coal combustion are its effects on air, water, and land quality. General Similarly, water quality impacts of coal min- environmental management is regulated under ing and combustion are regulated under the the National Environmental Policy Act of 1969 Clean Water Act, which requires coal mine and (N EPA), which requires that all Federal agen- combustion facility operators to meet effluent cies include a detailed environmental impact limitations designed to achieve Federal water statement (E I S) in every recommendation or re- quality goals. The techniques for meeting port on legislative proposals and other major these limitations are available, but may re- 26 . The Direct Use of Coal

quire mine operators to institute waste water interstate or interregional pollution problems; treatment and may increase the costs of both and the focus on immediate problems to the mining and combustion. detriment of long-range planning. These could hamper increased coal use in the short-term The Resource Conservation and Recovery and midterm future. Act regulates the disposal of solid wastes from coal-related activities, including ash and In general, Federal policies that affect coal- scrubber sludge and mine wastes. If these related activities are not expected to constrain wastes are listed as hazardous, RCRA will im- increased coal use in the long term. The re- pose strict disposal and recordkeeping requirements of the Clean Air Act impose the quirements that will significantly increase coal most significant constraints in the short term, combustion costs. However, the environmen- both by limiting the number of available sites tal and health benefits from preventing the for combustion facilities and by substantially open dumping of these wastes are also sub- increasing the costs of combustion. However, stantial. the air quality benefits that will result should facilitate coal combustion in the long term. Implementation The cumulative effect of all other existing Numerous departments and agencies are re- regulations may delay the construction of new sponsible for implementing Federal policies facilities or the opening of new mines and will that affect the production and use of coal. make both mining and combustion more ex- Those with substantial roles include EPA, pensive. which regulates the byproducts of coal use through administration of the Clean Air and Water Acts and RCRA; the Department of La- Future Policy bor, which is responsible for miners’ health and safety; the Department of the Interior, which Each of the national energy supply and de- administers SMCRA; DOE, which has the au- mand scenarios in this report involves a sub- thority to order coal conversions and, in stantial increase in coal use over the next two cooperation with Interior, administers the decades. There is no doubt that the resource is Federal coal leasing program; and the Council physically present and accessible to sustain a on Environmental Quality, which has primary high level of use over that period. It is also oversight responsibility for NE PA. I n addition, clear from an engineering standpoint that coal numerous interagency consultation and coor- can be extracted, processed, and burned at a dination requirements involve a variety of cost that will make it very competitive with other departments and agencies in policy im- other fuels. What is not clear is how the exter- plementation. nal costs, institutional and social constraints, and other nonmarket factors associated with Some critics of Federal coal policy argue coal use will affect the validity of the econom- that energy development is overregulated. ic and technological analysis. At one extreme, Others contend that more regulation is increased coal use might pose such serious ex- needed, either because of the way agencies ternal costs to the environment and public have interpreted their mandates or because health that strict limits on its use would be re- conflicts or gaps among those mandates pre- quired. At a minimum, the process of reducing clude the existence of either a coherent na- external costs — by increasing, for example, tional coal policy or a coherent environmental pollution controls and coping with internal protection policy. The major factors affecting constraints (such as labor-management con- implementation of such policies, in addition to flicts)—will moderately increase the economic those mentioned above, include the lack of costs of coal utilization. Given the central comprehensive Federal programs for leasing, place of coal in future U.S. energy planning land use, and water resource management; the and projections, the stakes involved in formu- absence of workable mechanisms for resolving lating a national coal policy are substantial. Ch. /—/ntroduction and Overview ● 27

The task of policy analysis in this area is to than is supply. While demand will probably be identify the potential problems and constraints adequate to sustain all but very high energy and to examine the range of governmental pol- scenarios, this is far from certain. Several icies that offer some promise of amelioration. broad policy options are available to strength- There are three basic types of criteria for en the future market for coal. These include: 1 ) choosing among these Government policies: 1 ) tax pressures and incentives to induce utility national objectives concerning the timetable and industrial conversion to coal, 2) RD&D for and level of coal production and use, 2) support for technologies (e. g., FBC and SRC) political and normative values, and 3) prag- that can help make coal an acceptable fuel for matic calculations concerning the absolute small users, 3) RD&D support for improved, and relative efficacy of policies in stimulating less expensive emission control technologies, production and use and/or minimizing adverse 4) RD&D support for coal gasification and liq- impacts. uefaction technologies, and 5) higher prices for natural gas and fuel oiI through deregulation or surcharges. It is most likely, however, that National objectives concerning the magni- no significant policy initiatives will be required tude and timing of coal use set the context to reach plausible supply and demand projec- within which coal policy is formulated. The tions. In sum, the targets discussed in this mining industry should be able to double or report regarding coal production and use for triple its production by 2000 if current condi- the remainder of the century do not emerge as tions continue. Existing and pending environ- a critical basis for sorting among legislative mental, health and safety, leasing, and other and regulatory options; both rapid growth and legislative and regulatory requirements may be the current controls can be accommodated. costly but otherwise appear to be compatible with greatly increased coal production. The choice between conflicting courses of action will often require subjective judgments Nevertheless, there are actions that will pro- concerning what is desirable. With regard to vide an additional margin of safety against the coal policy, the most important value conflict possibility that these supply projections are involves the relative priorities to be assigned to overly optimistic or that it becomes necessary increasing production and to reducing adverse to raise coal’s fraction of U.S. total energy sup- impacts. The existing Iegislation and regula- ply above the levels posited in this report. tions define a rough but discernible balance Many of these measures have merit independ- between these two value sets. Future policy ent of their potential effect on coal supply. may maintain that balance or shift it in favor The list includes efforts to: 1) mitigate the of either production or impact amelioration. adverse community impacts that might con- This choice lies at the heart of national coal strain coal development, 2) address the causes policy. Specific dimensions of the choice in- of labor-management disputes, 3) anticipate clude tradeoffs between: coal extraction and and avert potential coal transportation bot- environmental quality, coal combustion and tlenecks by upgrading existing modes (e. g., rail- environmental quality and public health, coal roads) and facilitating the creation of new ones extraction and the well-being of coal field com- (e. g., slurry pipelines), 4) expedite the forma- munities, and coal extraction and workplace tion of a leasing policy and the designation of health and safety. A second value conflict eligible tracts, 5) streamline the permitting arises over whether increased Government process for new mines, and (6) develop proce- regulation is the appropriate way to achieve dures for anticipating and accommodating national energy policy goals, or whether the potential objections to new coal facilities in emphasis should be on broad guidelines (per- order to avoid extensive litigation and delay. formance standards), negotiation, and mediation. Finally, if regulation is determined to be Demand is more likely to be a constraint on necessary, value conflicts will result from the coal development over the next two decades allocation of decision making authority among the various levels of government: Federal, ● the performance and future prospects of State, local, and tribal. Value judgments and specific control technologies and the priorities, then, play an important role in shap- means of stimulating improvements, ing coal policy choices. ● omissions, inconsistencies, or disutilities Judging policy options also involves an in existing environmental laws and regula- assessment of the utility of different policies in tions, solving the specific production, utilization, ● implementation of laws and regulations, and impact problems associated with coal. and Five major areas of policy concern have been identified, each with a potential for significant ● promising new policy innovations or in- influence on efforts to expand the production struments. and use of coal. They are: 1 ) environmental impacts, 2) community and social impacts, 3) Community and Social Impacts labor-management relations, 4) workplace A comprehensive national energy program health and safety, and 5) leasing of Federal also may include policies designed to alleviate coal reserves. the adverse community impacts associated with coal development. These policies, if they Environmental Impacts are to be effective, must take into account two Environmental considerations are an impor- basic characteristics of the present situation. tant potential constraint upon a substantial in-, First, there is considerable uncertainty over the crease in coal production and combustion. The nature of future coal development impacts era of unregulated environmental impacts is and the balance of benefits and costs that will clearly past for coal, as for other fuels. An accompany them. Second, value disagree- elaborate, though still incomplete framework ments over what impacts are beneficial and of legislation, regulation, and implementing in- what are adverse occur even where the nature stitutions is in place. It constitutes a national of these effects is understood. Whether eco- policy system for managing the environmental nomic growth itself is to be viewed as a impacts of increased coal use. The relevant positive or negative phenomenon in particular control technologies are at various stages in localities is itself the subject of dispute. Never- their evolution from conception to maturity, theless, a number of potential adverse com- but most have at least reached the point where munity impacts can be identified including a first-generation technology can actually be overloaded public services, hyperinfIation, applied. Control technologies for combustion and various symptoms of social stress and in- emissions are particularly important, and al- stability. A number of general and specific though existing technologies are far from op- policy measures designed to cope with these timal, the outlook is promising. In short, after problems can be identified, ranging from, the investment of substantial economic, tech- Federal grants to coalfield communities for nological, and human resources over recent public works construction to studies of ways to years, the ingredients of a viable environmen- limit the corrosive impact of energy develop- tal policy for coal now exist. ment on Indian tribal culture. Given the uncertainties and value disagreements regarding Under these circumstances the paramount community impacts, there is a need for pol- task of policy analysis is to identify ways that icies that seek to deal with the concerns of in- the existing policy system might be upgraded terested parties in a context where compro- with regard to: mise is encouraged. This will occur if all parties affected by increased coal use participate ● gaps in present knowledge about the in decisions about the location, timing, and nature and magnitude of the risks to the scale of coal developments that directly affect environment associated with coal utiliza- them and if Federal policies are designed to tion, distribute the risks, costs, and benefits of in- Ch. I—Introduction and Overview ● 29 creased use equitably among al I affected par- Government involvement, 3) use of Taft-Hart- ties. ley with limited efforts at enforcement, 4) Taft- Hartley with vigorous enforcement, and 5) Government seizure of the mines. Each of Labor/Management Relations these options has opportunities and liabilities Although recent instability in labor-manage- that vary with the particular circumstances of ment relations in the coal industry has been a strike; however, as noted previously, past significant mainly at the local and subregional Federal intervention in coal field labor-man- level, future instability could have significant agement disputes has been counter-produc- implications for the nationaI economy. Conse- t ive. quently, Federal policy makers may try to actively influence the situation. If so, their task is Workplace Health and Safety twofold: deciding how to ameliorate the Mining, particularly underground, is a haz- causes of destructive labor-management conflict and lay the groundwork for a more con- ardous occupation as measured by the record structive long-term relationship, and planning of work-related accidents and diseases. Any ways to cope with future strikes, should they substantial increase in coal production in- occur. evitably will mean thousands of diseased and injured miners. The question facing policy- Under present legislation the Federal Gov- makers is what modifications in or additions to ernment can do Iittle to alter directly the terms existing standards and enforcement might of labor-management relations. The principal minimize that number? Efforts to answer this causes of wildcat and contract strikes are the question will focus on improved dust control, conditions of work and terms of employment. research related to the appropriate dust stand- They are essentially privately determined mat- ards, and research on the effects of new pollut- ters. However, some policies can alter the con- ants and the synergistic impacts of multiple text in which the unions and operators inter- pollutants in terms of mine health. The major act. These include measures designed to en- need in mine safety is to develop an accident- sure steady growth in the demand for coal in reduction strategy to Iimit the rising number of major sectors of the economy. The recently disabling injuries, which now amount to about passed National Energy Act contains a number 15,000 a year and result in 2 months or more of these provisions. A healthy market should lost time each, Improved safety and job train- ease the historic economic insecurity—of both ing, education in different work practices, operators and miners—that has been such a changes in management and worker attitudes, large factor in the industry’s labor problems. and new Federal safety standards for mine Other promising actions are equally indirect equipment are some approaches to this prob- and relate to the basic social, economic, and lem. environmental ills that contribute to the miners’ discontent. They include such diverse Leasing of Federal Coal Reserves measures as improving dust monitoring and control within underground mines to restoring Western coal comprises roughly half of the Appalachian trout streams. Nation’s coal reserves and the Federal Govern- ment owns 65 percent and indirectly controls In the event of another major coal strike the another 20 percent of that resource. Conse- Federal Government would have an interest in quently, Federal policy concerning the leasing promoting a settlement that is prompt and of those reserves can have a substantial in- noninflationary, and one that establishes the fluence on the future of coal use. The most basis for long-term labor-management stabili- basic policy question concerns whether addi- ty. In pursuit of these objectives, five major tional leasing of Federal coal lands will be re- strategies will be available: 1 ) reliance on col- quired to meet projected increases in demand, lective bargaining with Iimited Government in- and, if so, when and how much. The answer re- tervention, 2 collective bargaining with strong mains unclear; the 1977 amendments to the 30 ● The Direct Use of Coal

Clean Air Act may have reduced the attractive- cipal selection criteria are reducing planning ness of Western coal for utilities, and legal and administrative costs, minimizing environ- uncertainties surround the status of pending mental damage, increasing tonnage mined, lease applications. In any case, recent litiga- forestalling litigation, or controlling adverse tion means that no new leasing will be possible socioeconomic impacts. Whichever approach until the early 1980’s at best. Assuming that it ultimately is selected, a number of specific wilI become necessary at some point to re- issues will have to be clarified. They include sume leasing, the Federal Government will definition of logical mining units, status of have to decide to what extent private industry preference-right lease applications, require- should be allowed to determine which lands ments of diligent development and continued will be made available. One option would per- operation, estimated recoverable reserves, admit operators to nominate those Federal lands vance royalty payments, and the exchange of they desire to mine and the Government to ap- environmentalIy sensitive leased lands for prove or disapprove the proposed lease. Under other unleased Federal land. Some important a second option the Government would iden- institutional issues center on the division of tify areas eligible for leasing and industry leasing responsibility between the Depart- would nominate specific tracts. Still another ments of the Interior and Energy. The Depart- option would leave to the Government selec- ment of the Interior has the overall responsibil- tion of both the areas and specific tracts for ity for the leasing program, but DOE controls leasing. The comparative attractiveness of economic leasing terms and conditions. these options will depend on whether the prin- Chapter II ENERGY AND THE ROLE OF COAL Chapter II- ENERGY AND THE ROLE OF COAL

Page

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● 34

✎ 37

● 38 39

✎ 39

● 41 Electric Power Generation ...... ✎ 41 Decentralized Electric Power Generation: An Alternative Approach?...... ✎ 44 industrial Use of Coal ...... ✎ 45 Residential and Commercial Use of Coal ...... ✎ 47 Distribution of Coal Combustion and Production...... ✎ 47 ...... ✎ 50

TABLES

Page 1. Energy Demand Scenarios, Year 2000, and Their Determinants ✎ 36 2. Energy Supply and Demand Scenarios ...... ✎ 40 3. Coal Combustion Projections ...... < ...... ✎ 43 4. Powerplant and lndustry Coal Combustion...... , ...... 49 5. Coal Production Projections ...... ✎ 49

✎ 6. Coal Mine Employment Forecasts ...... ,,.0 ...... 50

FIGURES

Page 1. Combustion of Coal and Lignite by End-Use Sector ...... 42 2. Coal Combustion Distribution ...... ✎ 48 Chapter II ENERGY AND THE ROLE OF COAL

Coal is expected to rapidly become more important in the Nation’s energy system. Its abundance relative to domestic reserves of oil and gas should preclude the steep price increases that may be in store for oil and gas as their production becomes more expensive, and most observers conclude that our present heavy dependence on foreign oil is a grave political and economic Iiability.

Many of the functions served by the energy of oil and gas could also be served by coal, as they were in the past. Others, however, such as residential heating and transportation, seem less appropriate for coal to serve unless the coal is first converted to a more convenient form. It is necessary to examine energy demand in general, and the various sectors of energy consumption in particular, to determine the degree to which coal can rejoin the energy system and how. This chapter describes the factors that determine energy and coal demand Three energy scenarios are presented to demonstrate a range of possible coal growth requirements. These scenarios reflect the range of most current predictions, though recent projections have tended to be toward the lower end of this range. Thus the high development scenario serves to indicate the probable upper limit on the amount of coal that will be needed. If the actual level is lower than the low development scenario, both the challenge of meeting demand and the resulting impacts will be reduced. The coal production and combustion elements of the scenarios are described in detail to set the stage for the following chapters.

KEY FACTORS AFFECTING ENERGY DEMAND

Three primary factors are ultimately respon- within the total population. The labor force sible for determining future energy use: popu- will grow considerably faster than the popula- lation, economic activity as indicated by the tion as a whole. The shift in the median age gross national product (GNP), and efficiency of that this implies suggests not only that GNP energy use. Each factor is a complicated func- will increase as described below, but that tion of subfactors, which are often interre- households and drivers, both major energy- lated. Appendix I in volume II amplifies this consuming groups, will increase faster than abbreviated analysis. population. Changes in tastes, lifestyles, and habits, perhaps engendered by rising prices, People are the final consumers of the goods can also affect energy demand, but such shifts and services that use energy. The higher the cannot be confidently predicted. population, the more energy will be needed. Changes in population growth are determined GNP is a measure of overalI economic activ- by fertility, death, and immigration rates. Esti- ity, most of which consumes energy. A close re- mates of the former range from 1.7 to 2.1 births lationship has been observed in the past be- per woman over her lifetime (1.8 in 1975), but tween GNP and energy consumption. The re- the effects on energy consumption will not be cent charges in this relationship are discussed great before 2000. The death rate is not ex- in the next paragraph. GNP obviously depends pected to change significantly by 2000. Hence in part on the population size and the labor immigration is the least certain factor. Popula- force in particular. The number of persons in tion is expected to be between 246 million and the labor force age group (16 to 65) can be pre- 260 mill ion by 2000, an increase of 13 to 20 per- dicted quite accurately to the year 2000. The cent from the present 217 million. Of more im- number of persons actually working depends mediate concern are the demographic shifts on the labor participation rate and the unem-

33 44- 102 0 - 74 - 4 34 ● The Direct Use of Coal ployment rate. The former is expected to con- a given task or process to the quantity of tinue its upward trend, reflecting the increased energy required. Efficiency (or the conserva- participation of women. Unemployment is ex- tion measures implemented to enhance it) is pected to drop below 5 percent for most of the not to be confused with constraint, which im- rest of the century. The positive effect of a plies less consumption of the goods or services large population and a higher rate of partici- involved. Energy efficiency rises largely in pation in the labor force is partially offset by response to economic pressures — fuel prices in the expected continuation of the long-term de- particular— but also to tax benefits and other cIine in work hours; average hours worked per policies. History provides little help in esti- week dropped from 40.0 in 1948 to 37.1 in mating the response to energy price increases, 1973. The final element in estimating future as the cost of fuel was stable or slowly declin- GNP is labor productivity, the measure of out- ing in real terms throughout the century. Until put per worker, per hour worked. The replace- 1973 there was little incentive to design for ment of manpower with capital, materials, energy efficiency and almost none to change knowledge, and energy has been the historic an existing practice. The situation is quite dif- means of increasing productivity. It now ap- ferent now, and decisions based on cost esti- pears that industry is finding a more attractive mates will result in rising energy efficiency. return on its capital when it restructures this There will be exceptions. As resources become equation to reduce the use of energy. This is scarcer, more energy wiII be required to pro- one of several factors that have Ied to a long- duce them, and as energy conversions such as term decline in the rate of growth of labor pro- electricity and synthetic fuels assume a larger ductivity. If this rate continues to decline, a role, efficiency will be adversely affected. very low-growth economy with lower energy Nevertheless, recent economic and energy needs than this report assumes wilI emerge. Re- data imply that energy and GNP have been cent concern has led to tax law changes, indi- largely decoupled and a substantially different cating that a national commitment exists to re- ratio will be established. Measuring this verse the decline, which is the assumption of change is much more difficult than measuring this analysis. All these factors combine to yield the previous factors. Conservation will be a estimates of G N P in 2000 of $3,300 biIIion to function of fuel prices, which will depend in $3,600 billion (constant dollars) compared to part on factors such as domestic oil and gas $1,516 billion in 1975. This increase of 120 to reserves, foreign and domestic policy deci- 140 percent will about double real, per capita sions, and technology developments. Thus the income. uncertainty in projecting future energy efficiencies largely accounts for the wide range in Energy efficiency relates the performance of the scenarios to follow.

DEMAND SCENARIOS

Forecasting energy demand is a highly un- Rather than selecting existing scenarios or cre- certain art. As described in the previous sec- ating more, the following analysis simply tion, there are too many important variables assumes energy consumption levels in 2000 of that can only be speculatively quantified. De- 100, 125, and 150 Quads and then determines pending on assumptions, modelers can pro- the circumstances that would be consistent duce scenarios for 2000 predicting anywhere with arriving at each level and the patterns in l from 60 to 190 Quads (73.1 Quads in 1975). which these aggregate levels would be distrib- Both extremes are highly improbable. Most uted. forecasts fall between 100 and 150 Quads. The objective of these energy demand sce-

‘A Quad IS short for quadrllion Btu narios is to determine the impact of a given Ch. //—Energy and the Role of Coa/ . 35 level of aggregate energy demand on coal con- ing technology, resulting in increased energy sumption. Aggregate demand is the sum of efficiency. I n industry a 30-percent increase in residential/commercial, industrial, and trans- energy efficiency is assumed. Industrial use of portation demand, Most energy used in resi- petrochemical feedstocks is also forecast to dences and commercial establishments is for grow at a much slower rate as a result of high heating and cooling. Oil and gas are the pri- prices. In the transportation sector auto effi- mary fuels for direct heating and electricity for ciency increases from 14 miles per gallon cooling. The use of electricity for heating is in- (mpg) in 1975 to 27 mpg in 2000, small trucks creasing rapidly. The transportation sector is a and vans increase in efficiency from 11 to 18 major consumer of liquid fossil fuels. Industry mpg: heavy trucks, planes, and ships experi- and electric utilities, which use large quanti- ence a 20-percent increase in efficiency. I n the ties of energy to produce steam, are the prime residential/commercial sector it is assumed candidates for the substitution of coal for oil that 2 percent of old homes (pre-1975) and and gas. commercial structures are retrofitted with insulation each year, and 10 percent are fitted The 100-Quad demand scenario is a slow- with heat pumps by 2000, AlI new homes and growth scenario. An assumed fertility rate of commercial structures are insulated, and 25 1.7 births per woman marks the leveling off of percent of these are equipped with heat a long-term decline in U.S. fertility, and with pumps. moderate immigration results in a projected population of 246 million in the year 2000. This The breakdown of sectoral energy demand modest increase in population is accompanied resuIting from these assumptions is shown in by an equally modest average rate of GNP table 1. The increase in household/commercial growth: 3.8 percent between 1975-85, and 2.8 energy demand greatly exceeds popuIation percent between 1985-2000. growth because of demographic shifts and a substantial increase in per capita use; how- A key assumption in the 100-Quad scenario ever, it is much less than the assumed increase is a major increase in the price of oil and gas in the number of households and in commer- relative to coal because of a disappointing dis- cial footage, implying increased efficiency. covery rate. The price of oil is expected to in- The significant increase in industrial energy crease to $25/bbl in 1975 dollars by the year use is partially explained by the corresponding 2000, while natural gas increases to $4.30/1 ,000 growth in GNP, 120 percent between 1975 and ft’ at the wellhead. These dramatic price in- 2000. Energy consumption grows slower than creases reflect increased scarcity and deregu- GNP for two reasons: first, the achievement of lation of oil and gas. Long-term contracts and a increased energy efficiency already cited; and competitive industry wilI prevent coal prices second, a substantial shift in the composition from rising as rapidly: from $1 7.50/ton in 1975 of industrial production away from petro- to $28.88/ton in 2000. Accordingly, oil prices chemical products. Transportation energy de- increase by a factor of 2.4, gas prices by a fac- mand rises slightly faster than population, re- tor of 10, and coal prices by a factor of 1.65. flecting the increased gas mileage of automo- The price of energy to the consumer will not in- biles and offsetting increases in mileage driven crease as much because other determinants of per capita, air travel, etc. retail energy prices (refining costs, distribution costs, etc. ) will not rise at the same rate as fuel The 125-Quad scenario implies a more Iiber- costs. As a result, electric power increases al supply system but a less successful conser- from 2.7 cents/kWh to only 4.5 cents/kWh in vation effort. Thus energy prices are the same 2000. The basis for these increases is discussed as in the 100-Quad scenario. The key demo- in the Supp/y Alternatives section of this graphic and economic assumptions in the 125- chapter and in appendix I of volume II. Quad scenario are essentially the same as in the 100-Quad case, but the Nation has not These increases in absolute energy prices been as successful in implementing energy-ef- lead to major efforts to implement energy-sav- ficient technology, nor has there been a sub- 36 ● The Direct Use of Coa/

Table 1 .—Energy Demand Scenarios, Year 2000, and Their Determinants -. Demand scenarios/primary Resldentlal/commercial ‘- Industry Transportation assumptions Wads 06 change Slatlstlcs — Statistics Quads ‘ % change Statistics 1975 - - – 4 73.1 Quads 257 #of homes’ 72x 10* High energy consumption 18.8 Autos 104 X 10 Commercial ft ftz 252 x 1OS In petrochemicals MPG 14 MPG (trucks) 11 2000 Scenario A 100 Ouada 335 30 ”/0 #of homes 102 x 10’ ( + 420/. ) Shift composition away from 222 18.1 % Autos. 120 X 10” (15”/0) Old (pre. ’75) 434 x 10$ petrochemicals MPG 27 Ferttllty rate 17 New 586 X 10’ MPG (trucks) 18 Hours worked 198 x 10* Commercial ft It’ 946 x 10$(+ 2750/. ) Labor productwlty growth Old 152 x 10’ 30 ”/0 Increase in efficiency 20°/0 increase m efficiency 1970-80 1 8% annual New 294 X 10’ 1980.85 2 2% annual Retrofit rate 1985.2000.2 60/. annual Old 20/. !nsulatedlyear GNP growth per year 1OO/. heat pumps 1975.85: 3 8% New all Insulated 1985.2W3: 2 80/0 250/. heat pumps ~ 2000 Scenario B 125 Queda 444 72% #of homes same as Scenario A 525 101 % Shift composition away from 281 49.5% Autos. 152 X l@ (46%) Fertlllty rate 1.9 Commercial ft same as Scenario A petrochemicals MPG 27 f-fours worked 2(XI x 10” Retrofit rate MPG (trucks) 18 Labor produclwlty growth: Old 10/. insulated/year (Same as Scenario A) New 10°/0 heat pumps 20% increase in efficiency 10% increase In efficiency GNP growth per year’ (Same as Scenario A) — I 2000 1 Scenario C 150 Quada 542 11 1“0 64.3 147 ”/0 315 67 5% Autos: 170 X 10' (630/’) Fertll!ty Rate 19 Immlgratlon + 750,000 f-fours worked. 203 x 1OD Labor productlwfy growth 1975-80 2 O“A annual No change in efficiency factors increased consumption of energy IS the result of lowered energy prices 1960-85 2 40/. annual occasioned by increased avallablllty of Ilquld fuels and natural gas 1985-2000 2 80/. annual GNP growth per year’ 1975-85 40/0 1985-2000 3% stantial shift in industrial production away and electricity is unchanged from 1975 levels from petrochemicals. ’ The difference in ener- of $1 7.50/ton and 2.7 cents/kWh respectively. gy consumption in the two cases is primarily Oil and gas are priced much more favorably in attributable to the differences assumed in relation to coal and electricity than in the low- energy efficiency. I n industry the increase in and medium-demand scenarios. The automo- energy efficiency is 20 percent instead of 30 bile population in this high-growth scenario is percent. In transportation, the efficiency in- 170 million, much greater than in the previous crease for heavy trucks, planes, and ships is 10 scenarios. percent instead of 20 percent. In the residential/commercial sector the retrofit rate of in- Implications sulation into old homes is 1 percent instead of 2 percent, and only 10 percent of new homes The greatest growth in these scenarios is in and commercial structures have heat pumps. the use of electricity by the industrial and The only other significant departure from the residential/commercial sectors. All these in- 100-Quad scenario is the number of automo- corporate lower growth in electricity than the biles–l 52 million instead of 120 million. historical average, but this growth rate has The 150-Quad scenario may be character- been declining since about 1966 to the present ized as a high-growth, cheap-oil case. It as- 3.4 percent that is envisioned for the 100-Quad sumes no improvements in energy efficiency. scenario. The direct use of energy by industry Energy fuel prices are much lower than in the has grown slowly over the last three decades. Industrial consumption totaled 18.8 Quads in other two cases. Oil is only $12.48/bbl, natural gas is only $2.25/1 ,000 ft3, and the price of coal 1977, only 47 percent higher than in 1947 and actually lower than in 1968.3 A resumption of 2The population assumptions are slightly higher for this scenario — an estimated 254 milIion based on a fertil- ● ity rate of 1 9; however, no affect is assumed on GNP, 3Annual Report to Congress, 1977, Department of Ener- which is the same as i n the 100-Quad case. gy, Energy Information Administration. Ch. II-Energy and the Role of Coal ● 37

rapid growth by industry is unlikely. Opportu- Quad scenario and MOPPS is in the household/ nities for the substitution of coal for oil and commercial sector, 44.4 Quads compared to gas are limited and is discussed later in this 36 Quads in MOPPS. This relatively large dif- chapter under the section, Projections of Coal ference is accounted for by greater implemen- Production and Use. tation of energy-saving technology in the MOPPS scenario. In the commercial sector, total demand has increased in al I three scenarios, but the 100- The Energy Information Administration of Quad scenario actually lowers direct use of DOE, in its Annual Report to Congress for energy. EIectric power and synthetic fuels are 1977, projects a domestic consumption of clearly substitutable for oil and gas in this sec- about 100 to 110 Quads in 1990, with a sectoral tor. The extent to which direct combustion of distribution similar to this report’s 100-Quad coal is substitutable hinges upon a number of scenario. The EIectric Power Research Institute factors, which are examined subsequently. The (EPRI), in their report “Supply 77” of May 1978 transportation sector, for the most part, de- uses a reference case for 2000 of 159 Quads pends on liquid fuels, hence the direct com- and compares it to scenarios of 146 and 196 bustion of coal and electric power is limited as Quads. EPRI clearly expects a more favorable a substitute. Demand growth in this sector fuel supply situation, less public and govern- means demand growth for oil, natural or syn- mental intervention, and lower price elastici- thetic. The greater number of automobiles in ties than this report considers probable. At the the higher scenarios implies a continuing de- other extreme, the Committee on Nuclear and velopment of outlying suburbs, less mass tran- Alternative Energy Systems considered levels sit, and increased driving for recreation. of energy consumption as low as 58 Quads and up to 180 Quads in 2010.4 A word should be said about how these demand scenarios compare with other studies. In creating the three scenarios, various as- The Department of Energy (DOE) conducted sumptions have been stipulated regarding key its Market Oriented Program Planning Study factors and relationships. Little has been said (MOPPS) in 1977. Total primary energy de- about the implications of a given scenario for mand estimated by MOPPS in the year 2000 is lifestyles. The way people live and their atti- 117.25 Quads, which is bracketed by the 100- tudes have a great deal to do with their willing- and 150-Quad scenarios. The breakdown of the ness to accept constraints on their behavior MOPPS estimate by sector is 36 Quads for the that might be implied by energy resource con- household/commercial sector, 20.8 Quads for straints and high prices. Whether consumers transportation, 56.9 Quads for industry, and would resist conservation policies is a matter 3.5 Quads for metallurgical coal exports. of specuIation.

Comparing MOPPS to the 100-Quad scenar- Americans have traditionally duly complied io, the most significant difference is in the in- with requirements associated with emergency dustrial sector, where the MOPPS estimate ex- situations, but indefinite compliance is a dif- ceeds the 100-Quad scenario by 12.5 Quads. ferent matter. Most people are economically The MOPPS scenario projects increased use of rational, however, and if it is apparent that gas and oil as petrochemical feedstocks, and price increases are not contrived and are being the overall increase in energy efficiency is applied fairly, they will adjust their patterns of presumably lower than that assumed for the consumption appropriately. 100-Quad case. The MOPPS industrial energy The historical growth rate in per capita ener- demand more closely approximates the 52.5 gy consumption since 1950 has been 1.4 per- Quads estimated in the 125-Quad scenario, cent annualIy. The scenarios discussed here re- where overalI industrial energy efficiency in- suIt from 0.9-, 1 .7-, and 2.3-percent increases. creases are one-third less than in the 100-Quad case, and where petrochemical feedstocks continue at pre-1975 rates of use. The signifi- 4U.S. Energy Demand Some Low Energy Futures, ” cant source of difference between the 125- 5cience, Apr. 14,1978 38 . The Direct Use of Coal

Thus even 125 Quads implies an acceleration jected as contrary to the demands of the of per capita energy consumption growth. American people. On the other hand, if 150 Given expectations regarding increased energy Quads are available at sufficiently low prices, efficiency and higher fuel prices, there is no ways wilI be found to use them, and it is in- reason to assume that rational Americans can- cumbent on low energy-growth advocates to not adjust to a reduced rate of increase in suggest how consumers will be spending their energy use. There is no basis for concluding doubled real income, if not for energy-consum- that the lower per capita growth in energy use ing goods and services, or whether in fact eco- wiII result in deprivation. Hence low energy- nomic growth should be dropped as a national growth scenarios cannot automatically be re- goal.

SUPPLY ALTERNATIVES

Historical y, energy supply has risen to meet resource constraints. The same high price demand wi thout major increases in prices, structure could result from a high fuel tax largely because of the Nation’s vast resources policy, but such a policy is improbable unless and the increasing efficiency of production. impending resource constraints are widely per- The situation is quite different now. Few if any ceived to be real. The higher prices keep U.S. analysts expect the Nation’s production rates oil and gas production close to current levels of oil and gas to double at any price. Total ex- through enhanced recovery and exploitation haustion is not a near-term concern, but re- of less attractive sites, such as Alaskan, off- source depletion is sufficiently advanced that shore, and marginal fields. Oil imports are ex- major new discoveries are noticeably harder to pected to drop in response to policies aimed at make, and new production is significantly that end. Coal production is expected to more more expensive. As oiI and gas currently sup- than double and actually become the most imply 75 percent of national energy demand, an portant fuel. Nuclear power increases rapidly indefinite continuation of past trends is not an but more modestly than most recent projec- option for the future. These expectations are tions. Solar energy increases at a very rapid reflected in the price assumptions for the 100- rate, but the time frame is too short to do and 125-Quad scenarios. The 150-Quad scenar- much more than lay a significant base for the io incorporates much lower prices for natural 21st century. New technologies, such as the gas and oil on the assumption of major new production of liquid fuels from shale and bio- discoveries. mass, are not expected to make major contributions by 2000. The energy sources considered here are oil, gas, coal, nuclear, solar, and geothermal. The economic advantages of coal and nu- Hydropower is not expected to increase signifi- clear power become overwhelming for electric cantly because of the lack of economic sites utilities. Industry’s energy growth is derived en- not subject to significant environmental degra- tirely from coal and electricity. Transporta- dation. Each energy source presents a different tion’s relatively small growth comes mostly set of characteristics that are valued different- from oil. The residential/commercial sector ly by the various users. The most important grows mostly with electricity. The actual characteristics are price (including transporta- breakdown is shown in table 2 for all scenarios. tion), convenience, facility cost, cleanliness, and reliability of supply. 125-Quad Scenario

100-Quad Scenario The same general price structure is assumed to prevail as in the previous scenario, but the The essence of the 100-Quad scenario is the less elastic demand leads to higher consump- sharply higher price of oil and gas caused by tion. It is assumed that national policies result Ch. //—Energy and the Ro/e of Coa/ . 39

Table 2.— Energy Supply and Demand Scenarios

Type Coal Oil Gas Solar and other

Total Electric” Direct Total Electric Direct Total Electrlc Dlrect Total Electric * Total Electrlc Direct 1 1975 (actual)””...... 73.1 20.2 52.7 15.3 8.8 6.5 32.6 3.2 29.4 19.9 3.2 16.7 1.8 3.2 3.2 0.0 Transportation 188 1 187 0 180 06 Resldenttal/commercial 257 120 136 3 58 76 Industrial 238 80 157 15 56 85 Metallurgical 22 22 22 Exports 18 18 18 Stock changes 7 7 7

100 Quads . 100.0 42.5 57.5 31.1 20.2 10,9 30.1 1.7 28,4 17.2 1.0 16.2 14.5 7,1 5.1 2.0 Transportation 222 04 218 0 212 06 0 Resldentlal/commercial 336 21 1 125 5 38 72 10 Industrial 369 210 159 31 34 84 10 Metallurgical 27 27 27 Exports 43 43 43 Stock changes 3 3 3

125 Quads .‘...... 125,0 53.8 71.2 37.8 26,4 11.4 40.4 2.2 38.2 19,1 1.5 17.6 18.6 9.1 5.1 4.0 Transportation 281 04 277 0 270 07 0 Resldentlal/commerc [al 444 294 150 5 46 80 20 lndustrial 449 240 209 34 66 89 20 Metallurgical 28 28 28 Exports 44 44 44 Stock changes 4 4 4

150 Quads . 150.0 67.8 62.2 41.3 28.9 12.4 48.4 4.0 44.4 26.4 3.0 7.1 5.1 2.0 Transportation 315 06 309 0 300 0 Resldent!al/commercial 542 350 192 05 64 10 Industrial 564 322 242 40 80 10 Metallurgical 30 30 30 Exports 45 45 45 Stock changes 4 7 4 i . All values in columns labeled electricr are for the heat produced at the powerplant. The values for hydroelectric power under solar and others represent the heat that would have heen required at a typical thermal generating stattion to produce the same electrical power “ Derived from Bureau of Mines Department of the Interior press release of Mar. 14, 1977.

in a significant increase in the availability of Interpretation imported oil, and a vigorous expansion in electric power generation. These steps are required An infinite variety of scenarios can be drawn by the assumed increase in the consumption of to meet any given demand scenario. The actu- petroleum in the transportation sector and by al mix wit I depend upon relative prices, fuel a greater demand for electric power. I n provid- availability, and the other characteristics Iisted ing for the increased electric power, coal- and above. Federal policy will have a considerable nuclear-generated power are assumed to share influence on the relative level of each fuel as equally in the expansion, and geothermal ener- welI as on the level of demand. Much has been gy is starting to become significant. Both the said here of the importance of the availability industrial and residential/commercial sectors of oil and gas, but little about their actual are turning to the direct use of solar energy. availability. A detailed analysis of the subject is beyond the scope of this study, but the val- Under this scenario, coal does not surpass ues here are consistent with other recent oil as the leading fuel, largely because of in- studies. The higher estimates could be r-net creased imports. only with a substantial fraction of imported oil. If for political reasons it is necessary to strictly limit imports, other fuels could prob- 150-Quad Scenario ably not be expanded much beyond the levels of the 150-Quad scenario to meet the deficit. In addition to the increased availability of Nuclear energy has in the past been projected oiI and gas, nuclear power grows at a more op- for much higher levels than the highest in table timistic rate. The economic advantages of 2 (500 plants of 1,000 MWe). Only about these fuels limit the growth of coal to little 200,000 MWe have been ordered so far, and more than that of the 125-Quad case, and actu- many of these projects are inactive. I n order to ally makes solar energy less attractive than for exceed 500,000 MWe by 2000, all these plants slower growth scenarios. wiII have to be completed and more than 30 or- 40 ● The Direct Use of Coa/ dered each year throughout the 1980’s. This is over regulatory delays, expensive redesigns about the maximum rate of orders ever and and retrofits, public opposition, and perhaps might be accommodated by the industry, but eventually, fuel shortages unless unproven utilities are showing no signs of resuming uranium reserves are discovered or the breeder ordering at such a level. A utility ordering a reactor is commercialized. Hence the levels reactor now faces considerable uncertainty assumed here are unlikely to be exceeded.

PROJECTIONS OF COAL PRODUCTION AND USE

The scenarios of the previous section all cur, this analysis assumes it would come at the show coal to be the fuel of greatest total expense of electric generation or oil imports. growth, This growth can occur in a variety of The former is unlikely to occasion any signifi- ways and places. The primary distinction in use cant change in the impacts discussed in this is between electricity generation and direct report. The latter possibility is accounted for heat applications. At present, about 70 percent by a slight increase in the coal production of the coal mined in the United States is levels of the previous section. burned for electricity, and the bulk of coal’s As discussed in the previous section, coal as growth will be in that sector. Direct use by in- a fuel presents a set of characteristics that dustry is the only other large-scale use con- potential users will compare to alternative sidered here. The historical distribution by fuels; The balance, and hence the eventual end-use sector is shown in figure 1. The virtual level of coal consumption may be shifted by disappearance of the transportation and retail changes in several factors in addition to (essentially the same as residential/commer- growth in demand for electricity and industrial cial) markets is apparent, as is the growing processes that can use coal or coal-derived dominance of the utility sector. Also included electricity. These factors, which include tech- in figure 1 are the projections to meet the nological improvements and regulatory restric- scenarios of the previous sections. Table 3 tions, are discussed in detail in chapter IV. This summarizes the coal consumption of the three section analyzes the demand of the users con- scenarios. sistent with the scenarios, and the patterns of Coal-based synthetic fuels are another fre- supply needed to meet the demand. quently mentioned possibility. Projections of several million barrels per day equivalent by 2000 have been made, but these are becoming Electric Power Generation increasingly improbable. In order to build up the industry to meet these levels, a major com- Util ties currently produce about 44 percent mitment would have to be made— soon. Coal of the r electricity with coal. The major alter- is an economically rational source of energy native for the rest of this century is nuclear when electricity is desired, but for Iiquid or power. Most new utility demand for coal will gaseous fuels, as long as natural sources are be from new powerplants, as conversion of ex- available at one-third to one-half the cost of isting plants to coal will be quite difficult and synthetics, there is little incentive for any inexpensive. dividual user to turn to the latter. A future OTA report will address the fundamental ques- The status of coal-fired electric power tions raised by the previous sentence: the logic capacity in megawatts as of September 1978 is of electricity vs. synthetics when natural fuels as follows: are Iimited, what these Iimits are, and the rate at which a synthetic fuels industry can be de- Planned or under veloped when needed. To the extent that any Existing construction Total coal-based synthetic fuel production does oc- 220,583 152,521 373,104 Ch. I/—Energy and the Ro/e of Coa/ 41

Figure 1.—Combustion of Coal and Lignite by End” Use Sector 1,700

1,600 Resident ial/commercial General industry and other 1,500 Electric power utilities

1,400

1,300 Actual ~

1,200

1,100

600

500

400 Utilities

300

200

100

I I I I I 1947 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000

SOURCES Annual Report to Congress, Energy Information Adminlstration, Department of Energy, vol. Ill, 1977, and the Off Ice of Technology Assessment 42 . The Direct Use of Coa/

Table 3.—Coal Consumption Projections (millions of tons)

Total Total Resldentlal/ domestic Potential Addltlons Scenario production Utilltles Industry commercial combustion synfuels Nonenergy Exports to stocks 1975 ...... 655 403 62 12 477 0 83 67 32 1985 A.. . 955 675 90 15 780 0 95 70 10 B. 1050 725 120 15 860 0 95 80 15 c 1145 775 150 15 940 0 100 90 15

2000 A 1505 965 150 25 1140 65 100 185 15 B 1845 1275 160 25 1460 70 105 190 20 c 2110 1410 200 25 1635 145 110 200 20 —

Because of lengthening construction sched- If major deferrals result from a continuation of ules, it is unlikely that any plants not included the very low growth of the past few years, utili- in these figures would be operating by 1985; ty demand may be as much as 100 million tons the above total of 373,104 MW is thus an upper lower. limit for 1985 capacity estimates. Beyond 1985, projections are highly uncertain. A growth rate of 5 percent from 295,000 If recent history is a guide, some of the units MWe in 1985 for the remainder of the century planned but not yet under construction will be would result in about 450,000 MWe of coal- dropped, and some construction schedules will fired powerplants by 2000. A growth rate slip. Some older units will also be retired, nearer historical levels would lead to 600,000 though probably only a few thousand mega- MWe. These would lead to coal demands of watts worth over the next decade. Other old 1,400 million and 2,000 million tons annually. units will be downgraded from baseload to in- (Increases in coal are not proportional to intermittent operation. This procedure was more creases in capacity, because the shift to lower pronounced in the past because new plant effi- heat value Western coal requires more tons for ciencies were rising, making the newer plants the same electrical output. ) Utility forecasts cheaper to operate, but this trend has leveled are changing rapidly, mostly towards lower off since the early 1960’s. I n fact, plants with estimates. Historical growth patterns appear to scrubbers are less efficient and more expensive be unlikely to continue, as pointed out in the to operate. Utilities may favor the use of older previous sections. The year 2000 coal-fired plants when they do not need all their capaci- electric generation of tables 2 and 3 is ty, a factor that will tend to make attainment equivalent to about 330,000 to 450,000 MWe. of clean air standards more difficult than ex- The exact level will depend primarily on the pected. level of demand for electricity and the com- The National Electric Reliability Council is petitiveness of nuclear power; it is therefore predicting 309,476 MWe capacity (of units quite sensitive to policy decisions affecting nu- greater than 25 MWe) by 1985, consuming 824 clear power and the economics of coal. million tons of coal. The above concerns indicate this is an optimistic schedule. If all Decentralized Electric Power plants with prevention of significant deteriora- Generation: An Alternative Approach? tion permits are completed on schedule, and if 3,000 MWe are retired, there will be 301,000 The projections have implicitly assumed MWe, but a more conservative estimate might that the utility industry would continue the be 295,000 MWe. This would correspond to trend toward larger (600 to 1,200 MWe) gener- coal consumption of perhaps 775 million tons. ating plants. Existing generating plants in 44 This is obviously still a huge jump over the States average less than 100 MWe each, but 1977 utility use of 475 million tons (estimated). only three States have any planned faciIities at Ch. I/—Energy and the Role of Coal ● 43 that low level, and planned additions in 20 reliability. It should be noted, however, that States average greater than 500 MWe. Every most utiIities are part of large grids. The entire State that has planned capacity additions (only grid shares the spinning reserve, so the excess Vermont and the District of Columbia have capacity for each utility is not large. none) will significantly increase the average capacity per plant This trend for generating The present high interest rates throw the units may be leveling off, but stations, which economies of scale into question, Interest on can include several units, are clearly still get- capital costs is one of the larger items in the ting larger as sites become scarcer Economics final bill for a large plant that may take 6 or of power plant construction and operation more years to construct. Small plants may take have been the primary cause of the growth in one-third to one-half the time to construct, size. The physical size of the plant, and the thus providing a much faster return on their materials and labor to construct it, increase share of the capital. This time factor is also a less than proportionally with its size. Oper- great advantage to utilities as they plan in this ating costs (excluding fuel) are only slightly era of uncertainty in load forecasting. Another higher for a 500 MWe plant than for a 50 MWe economic advantage is that the smaller size plant. makes possible the factory fabrication and shipment of components that now must be Considerable interest has recently been ex- field fabricated, Factory labor is often cheaper pressed in some quarters in small, dispersed and more productive than construction labor, plants. (“Small” is relative: a 50 MWe plant Community impacts during construction will would serve an average community of 20,000 clearly be less severe for smaller plants. Re- people. ) This interest has been prompted part- mote siting of large plants needin more than ly by the downtime maintenance experience g 1,000 construction workers can provoke seri- with large coal-fired powerplants and partly by ous strains in the nearby smalI communities the environmental and social impacts of large that must support them temporarily. Construc- plants and the resulting issues of public action of small plants near bigger cities would be ceptability. Appendix I I of volume I I discusses relatively inconspicuous to the community in- the issue in detail, Smaller plants can in theory f restructure. be placed closer to the communities they serve because their siting criteria are so much more One of the major arguments advanced in modest. This dispersal would substantially re- favor of decentralized power systems is en- duce the need for long-distance, high-voltage hancement of local control, particularly if the transmission, though the distribution system would remain the same. Such a siting policy plants are owned by a local government or a cooperative. This argument is very difficult to also raises the possibility of using the waste heat from the plants (about 60 percent of the analyze. Until recently, few consumers were concerned with the other end of their power- total heat of combustion) for district heating Iine as long as the power was there when they or industrial processes. The latter in particular, flipped the switch, and their bills weren’t too usualIy called cogeneration, has been es- high. Obviously many persons feel the latter poused as a major element in energy conserva- criterion is not now being met, but it is question policy. There are no technical barriers to tionable whether decentralization or local either district heating or industrial cogenera- control would provide much relief. The advan- tion. Both have been in operation for many tages would be more subjective: a sense of in- years. The major impediments are economics volvement and control over factors affecting and a variety of institutional problems. one’s Iife. It is as easy to name examples show- In order to assure continuity of supply, a ing indifference to involvement (e. g., the dif- spinning reserve (virtually instantly available) ficulty of getting neighborhood committees to equivalent to the biggest single unit online do much) as it is to list advantages. Further ex- must be maintained. The smaller all the units ploration of this issue is beyond the scope of are, the easier it is to assure the same degree of this report. There would probably not be a great deal of This largely qualitative discussion is ambigu- difference in total environmental impacts be- ous. The economic and environmental trade- tween a centralized and decentralized system offs are uncertain, and the social impacts de- of the same capacity. Total emissions could be pend on values and expectations. Thus neither about the same, and though they would be approach appears to have an overwhelming more dispersed for the small-scale system they advantage — a striking observation, as the would probably also directly affect more peo- trend has been so strong to centralization. The ple. Lower stack heights could lead to a differ- economies of scale discussed above are not ent mix of local and long-range transport pollu- the whole cause of the trend. Regulatory con- tants, as discussed in chapter V. Insofar as any straints are another factor as suggested by the system includes district heating or cogenera- controversial Avech-Johnson5 effect: tion, thermal pollution and the combustion of Utilities subject to a constraint on their rate of other fuels would be substantially reduced. return have incentives to expand the size of Small plants and dispersed siting have their their rate base to unjustifiable levels. disadvantages, of course. Construction clearly Thus while large central stations are clearly in requires more materials and possibly more the utilities’ best interest they are not necessar- labor for the same output, Environmental con- ily in society ’s. Reversal of the trend may re- trol measures are often easier and cheaper to quire drastic changes in utility operations and implement in large plants. Flue-gas desulfur- ownership, and in regulatory practices. Never- ization, for example, may prove prohibitively theless, the subject seems worthy of more de- expensive for small units. Hence even if decen- tailed analysis. Particular attention should be tralization proves advantageous otherwise, directed to the States with utility systems most full realization may have to await commercial- resembling the decentralized concept. Michi- ization of developments such as fluidized-bed gan, Nebraska, Wisconsin, and lowa, for exam- combustion or highly cleaned coal, which are ple, have many small generating utilities and discussed in the next chapter. It is also likely facilities and access to coal. that public heath impacts of dispersed facilities would be greater even for the same efficiency of control, simply because such plants Industrial Use of Coal would be in more densely populated regions. The outlook for coal use by industry is quite Fuel delivery and waste removal can be ma- different from that for utilities. Industry jor drawbacks to dispersed units. Unit trains burned 60 million tons in 1976, representing have cut transportation costs for big plants to only about 10 percent of all energy purchased about half that of conventional trains, but by industry. Both figures have been dropping these and slurry lines would not be practical steadily for 30 years, and there appears to be for small plants. Insofar as the plants are no major effort on industry’s part to reverse located in more densely populated areas, the trend. These factors have left industry as transport would be more obtrusive, especially the sector of greatest opportunity for policy if trucks are used. actions for conversion from oil and gas to coal. A recent report by the Congressional Budget Some of the problems and expenses facing a Office’ extensively analyzed the use of fuel by utility trying to get a plant constructed and manufacturers and the prospects for increas- online are not markedly different for a small ing their use of coal. This report found that plant. Hence the total effort for several small coal use could be raised by about 90 million plants will be greater than for one large plant. Operating costs have already been mentioned. Licensing would be another. Opposition to par- ‘H. Avech and L. Johnson, “Behavior of the Firm Under ticular sites may not be much less intense, and Regulatory Constraint,” American Economic Review, 211 (December 1962), pp. 1059-69. if a close-in site is selected, opposition could “’Replacing Oil and Natural Gas With Coal: Prospects be much more intense than for a remote site. in the Manufacturing Industries, ” Congress of the United This factor is further discussed in chapter IV. States, Congressional Budget Office, August 1978, Ch. 11—Energy and the Role of Coal ● 45 tons above present levels by 1985 under vari- mind. The cement industry uses several million ous tax policies. tons of coal annually for direct heat and could expand this relative to other fuels. The glass Industry uses most of its energy for process and metals industries may also find coal use steam, electric power generation, and direct 7 advantageous. The 1962 Census of Manufac- heat applications. Most of these functions 8 tures by the Bureau of Census reported that could in principle be provided by coal, but the chemical, paper, and food industries were conversion of existing oil- and gas-fired facil- also major users of coal, with most industrial ities to coal wilI be quite difficult. There is Iit- use in the East North Central, Middle Atlantc, tle experience with large coal-fired furnaces and South Atlantic regions. for direct heat rather than steam generation, so most applications will be for steam-raising Coal use by industry will almost certainly boilers. Boilers or furnaces not designed to reverse its long-term decline because of the burn coal must be essentially replaced to ac- fuel cost advantage and policy initiatives. commodate coal, and entirely new storage and Hence a low estimate for 1985 for industrial handling equipment must be added. Coal reuse of steam coal is 90 million tons. On the quires twice the storage volume for the same higher side, perhaps 150 million tons might be heat content as oil, and the handling equip- feasible. By 2000, industrial coal will have ment is larger and more expensive. Ash remov- risen even without further policies to encour- al equipment and disposal must also be in- age it. A minimum figure for energy use might cluded. PolIution control equipment is gener- be 150 million tons. An upper limit is almost ally necessary, even when not required for oil arbitrary as the outcome is sensitive to so or gas. If industry is to be held to emission Iimi- many factors, but for the purposes of this re- tations similar to those being promulgated for port 200 million tons is used. Oil and gas will utilities, only the very largest facilities will be be the preferred alternatives as long as they able to consider coal. New technologies such are available at competitive prices. Solar as fluidized-bed combustion or synthetic fuels energy couId prove uniquely advantageous for would be necessary to meet both coal use and industry if the costs (including reliable backup) environmental goals. Strong financial incen- prove competitive, as it could be used to avoid tives above the fuel cost savings must be con- both fuel and emission restrictions. sidered if it is desired to force these conversions. New facilities are more favorable tar- Residential and Commercial gets. Energy consumption by industry, how- Use of Coal ever, is expected to grow much more slowly than consumption by utilities. Hence industry Coal has nearly disappeared as a fuel for cannot adopt coal as a major fuel without homes and commercial facilities over the last wide-seaIe replacement of existing units. three decades. In 1948 coal provided 50 percent of the energy used in this sector, but this Guiding industry toward coal will be diffi- has declined to less than 2 percent. ’ The rea- cult but not impossible. Small powerplants and sons are obvious: for the smalI user in particu- process steam generators are used throughout lar, coal required dirty and noisy truck deliv- industry. Coal boilers are now available to eries, messy storage in the house, and daily cover a wide range of needs. These units can be installed much faster than utility power- ‘Frank H. Boon, “Industrial Consumers May Loom plants. Some of the small units (up to about 1 Very Large In Coal’s Future, ” Coa/ Age, February 1976 ton of coal burned per hour or equivalent to 8Richard L Gordon, reprinted in Coal In the U.S. Energy about 2 MWe) can be manufactured and deliv- Market, Lexington Books, 1978 ered as a package. Thus if the economics and ‘E N Cart, Jr , M, M Farmer, C E Johnlg, M Lleber- the less tangible factors, such as reliability of man, and F M, Spooner, “Evaluation of the Feasiblllty for Widespread Introduction of Coal Into the Residential supply, prove favorable, industrial coal use and Commercial Sector, ” Government Research Labora- could rise rapidly. Industrial process heaters tories of EXXON Research and Engineering Company for must be designed with a specific purpose in the Council on Envlronmental Quallty, April 1977 46 ● The Direct Use of Coa/ stoking and ash removal, and it left the air economical to use coal in either conventional laden with smoke and fumes. Most Americans boilers or fIuidized-bed combustion units. turned to oil and gas, and the coal retail mar- Given the marginal economic advantages, ket (essentially the same as residential and the choice of coal as a heating fuel for the commercial use) nearly followed the transpor- residential/commercial sector is not likely to tation market into oblivion as shown in figure be based on economic or financial calculation 1. Recently, however, concerns over the price alone. Convenience and reliability of supply and availability of oil and gas have sparked a wiII probably be of major concern. The pro- flurry of inquiries, though not yet substantial jected scenarios envision residential/commer- orders, to manufacturers of coal-fired equip- cial use of coal to double from 12 million tons ment. Although a return to coal might at first in 1975 to 25 million in the year 2000, a growth appear unlikely, the scenario warrants exami- that is virtually immaterial to the national en- nation because of the large energy consump- ergy picture, but perhaps environmentalIy sig- tion of the residential and commercial sectors nificant in some regions. (21 percent of the U.S. energy budget). Appen- dix I I I analyzes this potential in greater detail. Distribution of Coal Combustion The retail market now is about 12 million and Production tons per year, including anthracite. Most of this is consumed in the Appalachian coal-pro- The national levels of consumption shown in ducing States, plus New York, Illinois, and table 3 will not be uniform across the country. , Michigan. There is no national or even regional Most coal will be burned within a few hundred market structure for coal or furnaces. Dealers miles of the coal fields, as it is now. The region- purchase coal from the mines (usually small al distribution of use is shown in figure 2 and ones) and have it delivered by train or truck. As listed in table 4. Production by State is shown the purchases are usually made on a one-time in table 5. Even more than for the national basis (spot market) in small quantities, and de- levels, these projections are not estimates but livery is made without the economies of scale indications. The actual distribution wilI de- utiIities enjoy, the retaiI price of coal is star- pend on relative changes in regional cost of tlingly high, perhaps $80 to $100 per ton. These production and transportation, success in con- prices are probably enough in themselves to trolling emissions of high-sulfur coal, custom- preclude a resurgence of coal use, but they ers’ perceptions of the reliability of delivered could drop if the retail market develops into a supply, and other unpredictable factors. Policy more stable operation, Many mines sell coal decisions affecting these factors can produce by the pickup truck load at about $30 per ton, inter regional shifts of several hundred million and retail markets in the mining areas carry it tons annually by 2000. For instance, the trend at $40 to $45 per ton, but this will benefit only towards Western coal is expected here to mod- those living near coalfields. erate after 1985 because of the full scrubbing regardless of sulfur content required by the Although improvements in equipment, such Clean Air Act Amendments of 1977 (discussed as automatic stokers, and improvements in in chapter IV, pages 167-1 75). combustion technology could increase resi- The manpower required to produce this coal dential use of coal, the scenarios used here do (assuming no change in mine productivity) is not anticipate much growth. Coal-fired district shown in table 6. heating plants (such as the U.S. Capitol Power Plant) may be the only way that coal could experience a resurgence in the residential mar- Conclusions ket, as such large plants make stringent environmental controls practical and relieve the The coal projections discussed here appear end-use consumer of the inconvenience. Large to be achievable under the present Iegal/regu- commercial customers may, however, find it Iatory and economic climate. If actual use Ch. I/—Energy and the Role of Coal ● 47

Figure 2.—Coal Combustion Distribution

t 1

1976 1985 2000 1976 1985 2000 High L OW High LOW High Low High Low

1976 1985 2000 1976 1985 2000

~;.$s EAST 1976 1985 2c00 SOUTH r SWTH /4TLANTlC CENTRALt \ High Low High Low

I 48 . The Direct Use of Coal

Table 4.—Powerplant and Industry Coal Combustion (million/tons)

6 1985 High High Low Low High High Region” Utility Industry utility industry utility industry Utllity industrv New England 0.8 o 3 2 o Middle Atlantlc. 45 10.85 64 2: 58 15 South Atlantic 83.3 10.85 124 25 106 16 East South Central 84.7 6.33 101 15 88 10 West South Central 12.7 1.61 112 15 98 6 Pacific ., 4 .4 11 5 10 3 Mountain ~ 39 3 10 66 6 14 West North Central. 52 3 ~ 12 66 6 16 45 161 28 234 57 159 35 East North Central 145 24.4 185 — Total. 4465 80.64 775 150 675 90 1410 200 965 150

‘New England Maine, New Hampshire, Vermont, Massachusetts, Connecticut, Rhode Island Mountain. New Mexico, Arizona, Utah, Colorado, Nevada, Idaho, Montana. Wyoming Middle Atlantic New York, Pennsylvania, New Jersey Pactflc- California, Oregon, Washington South Atlantlc Maryland. Delaware. West Virginia, Virginia, North Carolina, South Carolina, Georgia, Florida West North Central. North Dakota, South Dakota, Minnesota, lowa, Nebraska, Kansas, Missouri East South Central -Kentucky, Tennessee, Mississippi Alabama East North Central- Wisconsin, Illinois, Indiana, Michigan, Ohio West South Central Arkansas, Louisiana, Oklahoma, Texas

Table 5.—Coal Production Projections (million of tons per year)

Surtace Uncle Total - “ .—— ——— ! ~ High

10 15 14 — 1 — 40 49 34 2 3 2 46 30 40 12 38 45 15 20 70 80 3 7 5 : 3: 25 35 74 43 :: 110 130 175 205 I 132 355 680

7 5 10 3 10 24 39 55 62 165 27 21 32 25 57 28 28 35 41 77 5 5 2 3 4 6 91 95 95 135 54 120 135 175 215 315

11 13 6 11 — — 11 13 8 11 6 30 45 64 4 25 39 45 70 94 29 55 65 130 200 — 5 55 60 135 210 11 38 50 120 — 3$ 43 77 125 12 37 47 :; 135 — : 17 43 54 85 140 — — . 10 10 6 10 9 39 5 5 6 9 15 — 1 45 198 220 260 310 — 5 141 415 495 700 OQ5 13 80 110 154

- 417 ‘ 620 745 925 315 272 250 — 689 . I ---- i — a 1978 Keystone Coal Industry Manual p 666 (estimated) bibid. pp. 674-685 data adjusted to eliminate present production capacity

does not rise to these levels, it is more likely to If it is deemed necessary to achieve projec- be from lack of demand rather than restricted tions higher than these because of disappoint- supply, but several factors could induce the ing oil and gas discoveries or inadequate latter situation, as discussed in chapter IV. De- growth by nuclear and other energy sources, mand for coal could remain below these levels attention may have to be directed to loosening either because energy demand has been suc- environmental and other restrictions or accel- cessfuIly curtailed or other fuels prove unex- erating development of technologies that bet- pectedly bountiful. Neither situation calls for ter accommodate them. Coal’s growth rate remedial action, though attention could still may also need acceleration beyond that dic- be directed to reducing the negative impacts tated by the immediate market conditions, of coal (see chapters V and Vi). possibly because of an unexpected sharp drop Ch. //—Energy and the Role of Coal ● 49 in oil or gas availability. Then greater efforts of following chapter. Detailed analyses of the im- coercion or incentives would be required, placations, such as emission quantification, possibly coupled with a streamlining of the have not been made, as the results would not process of getting mines into production. vary greatly from published analyses.

These scenarios are used as guidelines in the

Table 6.—Coal Mine Employment Forecasts —.. —— ———- — Surface Under ground Total I —- — — 2000 1 5 2000 1985 2000 State Low High Low High High Low High Low High Low High —..—. —.. . iow- I Appalachia Alabama 3,290 4,080 2,720 4,080 9,430 11,320 16,970 25,150 12,700 15,400 19,690 29.230 Georgia — 240 — — — — — — 240 — — Kentucky 6,725 7,470 7,470 9160 20,010 23,210 34,010 46010 26,740 30,680 41480 55,170 Maryland 575 770 380 575 475 950 950 1,420 1,050 1,720 1,330 1,995 Ohio 3,210 4,010 4,810 6,420 9,990 11,100 17,7611 27,750 13,200 15110 22,570 34,170 Pennsylvania 6,070 6,6&3 3,040 4,050 22,090 25,960 44,180 55,230 28,160 32.640 47,220 59,280 Tennessee 940 1,180 710 940 1,380 1,840 1,640 2,300 2,320 3,020 2,550 3,240 Virglnla 1,480 1,910 1 060 t 700 11,090 12,670 13,200 21,110 12,575 14,580 14,260 22,810 West Vlrglnla 5,630 6,120 42,480 47,990 88,950 103,160 46,890 53,620 75,070 111,730 4,410 8,570 — Total Applachia- 26,680 31,970 26,310 35.495 “ 116,945 --135,040 197,8&” 282,130 143,630 167,010 - 224,170 317,625

Midwest ---1 Missouri 590 790 990 1.970 — — — 590 790 990 1,970 Illinois 3,980 5,170 6,720 9,470 12,440 16,910 23,920 35,090 18,400 22,080 30,640 44,560 Indiana 3,510 4,490 2,950 4,490 — — 2,820 7,080 3,510 4,490 5,770 11,550 Kentucky (west) 2,960 3,380 3,950 4,930 6,280 7,850 10,360 13,180 9.240 11,230 14,310 18,110 Oklahoma 845 1,410 560 850 1,010 2,020 2,020 3,030 1,855 3,430 2,580 3,880 Total Midwest - 11870 15,240 15,170 21,710 19,730 26,780 39,120 t 58,360 31595 42020 54,290 80,070 west Arizona 660 780 480 660 — — — — 660 780 480 660 Colorado 1,920 2,740 4,110 5.850 7,840 8,720 10,900 13,070 9,760 11,460 15,010 18,920 Montana 1,800 2,130 4,260 6,550 — — 2,270 4,540 1,800 2,130 6,530 11,090 New Mexico 3,090 4,070 6,100 9,760 490 970 2,430 3,090 4560 7,070 12,190 North Dakota 1775 2,250 3,840 6480 910 1,360 1,360 1,820 2,685 3,610 5,200 8,300 Texas 2,340 2,940 4,630 7,630 — — — — 2,340 2,940 4,630 7,630 Utah 1,670 1,670 1,330 1,670 9,520 10,830 12,800 16080 11,190 12,500 14,130 17,750 Washington 7641 910 1,360 2270 — — 860 1,720 760 910 2.220 3,990 Wyoming 1210 1,350 1,660 1,910 420 1,260 2,110 4,210 1,625 2610 3710 6,120 Total West 15,200 42,780 18,690 43870 41500 - 18,840 27710 22,660 31,270 , 33,900 58,980 86,650 Chapter II COA TECHNO OGY AND TECHNIQUES Chapter lll.– COAL TECHNOLOGY AND TECHNIQUES

Page Page

Patterns of Use ● * * * * * * * . * . * . . ****.*.,. 53 Flue-Gas DesulfurizationI-Industrial. 98 Eastern Deep Mined Coal Burned at an Nitrogen Oxide Control. . . . ‘ ...... , . . 98 East Coast Plant ...... 54 Future Technologies...... 100 Eastern Strip-Mined Coal Burned at a Coal Preparation...... 100 Mine-Mouth Plant...... 55 Mechanical Coal Cleaning ...... 100 Western Strip-Mined Coal Burned at a Advanced Cleaning Processes...... 100 Midwestern Plant ...... 55 Solvent-~Refined Coal ...... 101 Coal Resources ...... * * * * . ******.** 55 Low-Btu Gas and Combind Cycles .. ..101 Types of Coal ...... 57 Fluidized-Bed Combustion ...... 102 Coal Formations ...... 58 Magnetohydrodynamics...... 104 Coal Distribution ...... 58 Fuel Cells ...... 104 Eastern Regions...... 60 Western Regions...... 64

Mining and Preparation . ● * * * * * ******.** 64 Surface Mining ...... 64 TABLES Underground Mining...... 69 Coal Preparation...... 73 Page

Capital Costs...... 77 7< Examples of Coal/Lignite Deliveries at Transportation and Transmission ...... 77 U. S. Powerplants During 1977...... 55 Railroads ...... 78 8. Coal Ranks and Typical Characteristics 57 Waterways ...... 78 9 Geometric Mean of 36 Trace-Elements Highways ...... 81 in 601 Coal Samples From Four Major Slurry Pipelines ...... 81 Coal-Producing Regions ...... 60 Electric Transmission ...... 83 10. Recoverable Reserves as of January 1, Transportation Patterns and Cost...... 84 1976 ...... 63 Combustion Technology and Methodology . 87 11. Mechanically Cleaned Bituminous Coal Utility Boiler Furnaces ...... 88 and Lignite ...... 76 Pulverized Coal-Fired Boiler Furnace . 88 12. Origin and Destination of Coal Characteristics of Pulverized Coal Deliveries to Electric Utilities in 1976. . 85 Furnaces ., ...... 89 Supercritical Boilers ...... 89 Slagging and Fouling...... 90 FIGURES Cyclone Furnaces ...... 91 Industrial Boiler Furnaces...... 91 Page Pulverized Coal-Fired Industrial 3. Coal System Components...... 54 Boiler Furnaces ...... 92 4. U. S. Coal Resources and Reserves. . . . . 56 Spreader Stokers...... 92 5. Regional Recoverable Reserves That Traveling-Grate Stokers ...... 92 Burn With Emissions Equal or Less Than Underfeed Stokers ...... 92 Indicated...... 59 Vibrating-Grate Stokers ...... 93 6. Coalfields of the Conterminous Air Pollution Control Technology ...... 93 United States ...... 61 Particulate Control , ...... 93 7. incline No. l, Herrin Bed Illinois . . . . 62 Cyclone Collectors ...... 93 8. Strip Mining Method...... 66 Electrostatic Precipitators ...... 94 9. Typical Contour Stripping Plus Wet Scrubbers...... 95 Auger Method ...... 69 Fabric Filter Baghouses...... 95 10. Underground Mining...... 72 Sulfur Oxide Control...... 95 11. Longwail Mining System ...... 75 Flue-Gas Desulfurization -Utilities . . 95 12. Coal Distribution by Transportation Input Requirements ...... 96 Mode and End Use, January-September cost...... 97 1977 ...... 86 Alternative FGD Processes ...... 98 13. Lime-Limestone Scrubbing System . . . . 97 Chapter Ill COAL TECHNOLOGY AND TECHNIQUES

This chapter describes the various conditions and technologies that exist in the coal system from resources in the ground through use and disposal of wastes. The section below provides an overview and summary. Subsequent sections expand on the various elements of the system.

PATTERNS OF USE

Coal is burned to produce heat, which in The major factors influencing the design of turn is used to generate steam for process heat combustion facilities are the size of the unit, or the production of electricity. Alternatively the type of coal to be burned, and the environ- the heat may be used directly in industrial mental standards it must meet. Thus it is dif- process systems or space heating. Coal also ficult and sometimes impossible to switch to a can be used to effect chemical reactions as in different coal. Also the technology of the util- the reduction of iron ore or the production of ity sector is often inappropriate for the indus- lime, or indirectly as a source for synthetic trial or commercial installation. gaseous or liquid fuels, but such uses are not Because of the many interrelated factors in- considered in this report. volving coal, geographic conditions, and tech- Although the direct use of coal in the utility, nologies, control equipment and methods industrial, commercial, and residential sectors often must be “fine-tuned” to individual cir- is commercially feasible using current technol- cumstances. Reclamation techniques must be ogy, other factors may limit its use. The total adjusted to topography, climate, and future energy system — from resources in the ground, desired land use and social values. Control of through extraction, transportation, and end sulfur oxide (SOx emissions from the burning use— must be examined to identify constraints of coal can be achieved by removing sulfur on and impacts of its use. Figure 3 illustrates before, during, or after combustion. The most the variety of conditions and technological op- effective and economical design for a particu- tions that must be considered in the direct use lar case depends on such matters as the mode of coal. of operation of the combustion unit, the sulfur concentration in the coal, the availability of Coal is an abundant, widely distributed re- quality absorbents, etc. Similarly, the efficien- source in the United States. It is variable in cy of particulate control technology can be af- composition, moisture, sulfur, ash, and trace fected by changes in the sulfur content of the element content. Because of geological and coal or the physical and chemical composition geographic differences, mining and transporta- of the ash. tion methods vary. In Appalachia, most coal is New technologies for extracting, transport- mined underground with a variety of mecha- ing, nized equipment. Most Midwestern and West- “cleaning, ” upgrading, and burning coal are continuously emerging, as are environmen- ern coal is surface-mined, using gigantic tal controls for every phase. shovels or draglines to remove the overburden and expose the seam. Railroads are the domi- To illustrate the combinations that exist in nant transportation means. I n the East and the overall coal-energy system, three hypothet- Midwest, barges are important supplements. ical examples are depicted for the utility sec- Alternatively, the coal may be converted to tor as end-user. Each user is an electric power- electricity at the minesite and the energy trans- plant of 800 MW operating 70 percent of the ported to market by wire. time.

53 54 ● The Direct Use of Coa/

Figure 3.—Coal System Components t

Surface Area Contour Auger

“This system undergoing research and development in the U.S.

● “Can be considered an alternate to coal transportation in getting the energy to the final point of use.

SOURCE: Office of Technology Assessment

Eastern Deep-Mined Coal Burned at Next, the coal is loaded onto railroad hop- an East Coast Plant per cars in a unit train. The train consists of 100 cars and makes three 250-miIe round trips each The plant requires about 1,85 million tons of week between the preparation site and the coal per year with a heat content of 13,500 powerplant. Transportation adds about $5 to Btu/lb. Any one of the five largest West Virgin- $8 per ton to the price. At the powerplant, a 60- ia underground mines could currently be the to 90-day supply is normally stored to assure a single source. Such a supply requires mining at continuous feed to the boilers during any the rate of about 275 acres per year if the seam short-term supply interruption. Three-fourths is 8 feet thick. After the coal is brought to the of a pound of coal is burned to produce a kilo- surface it is crushed, screened, washed, and watthour of electricity. Ten percent of the coal dried at a preparation plant near the minesite. is ash. I n the combustion step about 20 to 40 About 700 persons are employed for extraction percent of the ash settles and is removed from and preparation. The price of the coal leaving the bottom of the furnace. The lighter residual the preparation plant is $30/ton. ash is entrained in the flue gases and carried Ch, Ill—Coal Technology and Techniques ● 55 out as “fly ash, ” more than 99 percent of it is larger to accommodate the greater volume which is coIIected in particulate control equip- of coal with high moisture and ash content. ment. In some plants, a portion of the ash is The ash is returned to the mine. The higher used for cement and the remainder disposed as capital cost of the powerplant is offset by the sol id waste, The plant is 20 miles from the lower operating cost of the fuel – $20/ton. main electric load center. A transmission line of 66,000 volts is used to deliver the power to Western Strip-Mined Coal Burned at a the distribution network, where the voltage is appropriately reduced for ultimate use in the Midwestern Plant industrial, commercial, and residential sectors. This coal has only 8,500 Btu/lb, so 3 million tons/yr are required. A 30-foot seam is exploited by 90 miners working in two shifts. The Eastern Strip-Mined Coal Burned at a overburden is 125 feet. Mining and reclama- Mine-Mouth Plant tion proceed at the rate of 50 acres/yr. The extracted coal is crushed and screened at the This coal has a lower heat content (11,300 mine and delivered to the powerplant daily by Btu/lb) than that in the previous example, so a 100-car unit train. As the 1 ,000-miIe trip re- 2.2 million tons are needed annually. It is pro- quires 50 hours each way, excluding loading duced at a mine by simultaneously exploitin g and unloading time, six trains are continuously three superimposed seams. The top seam is 9 in service and spare equipment is provided for feet thick and lies under 100 feet of overbur- maintenance periods. den. The second and third seams are 4 and 6 feet thick and lie below intervening layers of These examples, although hypothetical, are 10 feet of shale. Eighty-five acres of coal are similar to actual cases. Table 7 lists quantita- removed yearly. A total of 250 miners are em- tive values in some actual cases. The diversity ployed in two operating shifts. The coal is of suppliers, customers, types of coal, means crushed, screened, and transported 15 miles by of delivery, and contracts revealed in the table truck to the powerplant, Although the power- illustrates the variabiIity in a coal-based ener- plant is similar to that in the previous example, gy system.

Table 7.— Examples of Coal/Lignite Deliveries at U.S. Powerplants During 1977

Wt Wt Wt Coal Con- Con- Deliv. Cap Btu/b sulf. ash moist tram veyor Barge tract price c Plant and unit no State MW Stripa Deep a lb % % % miles feet males yrs $ ton Origin, State, and mines

Walsh, #1 Tex. 528 1.75 -- 8,250 030 50 320 1,451 — 25 1669 Wyoming, Amax, Gillette Monticello, #l-2. Tex. 1,150 292 -- 6300 070 143 350 11 – 25 4 30dd Texas, Winfield Chesterfield, #5-6 Va. 1,000 1 25 22 12500 1 20 100 120 450 — 25 3700 E Kentucky, St Paul av Kincaid, #l-2 Ill. 1,212 — 2.80 10500 370 90 16,8 – 1 130 — 34 1950 Illinois Peabody #10 WiII County, #l-4 Ill, 1,093 250 – 9,600 0.46 45 232 1,246 – 175 20 2370 Mont & Wyo Decker & Big Horn Powerton, #5-6. Ill. 1 700 1 70 1 70 10,550 368 11 8 137 410 – — 4 1300 Illinois Monterey (Deep) Captain (Strip) Chalk Point, #l-2 Md. 660 41 13 12,995 1 71 122 63 330 — 25 2800 Centr. W Penn some Md Bruce Mansfield, #1 Pa. 825 – 292 11,500 310 150 100 – 80 25 2300 Ohio, Quarto, Wheeling a In millions of tons b AS received by utility c Estimated average price duuring 1977 d The $430 per ton quoted does not include transportation over the utility's 11-mile self-operated rail system.

COAL RESOURCES

Coal deposits already identified in the more than 500 years. It is estimated that other United States contain enough energy to supply deposits, as yet unidentified, are equivalent in the Nation’s entire present energy demand for magnitude. By comparison, the known re- 56 ● The Direct Use of Coa/ serves of domestic crude oil would last less The estimates of recoverable reserves in than 20 years at the same rate of depletion. figure 4 are for deposits no deeper than 1,000 The amount of coal that can be extracted is feet and at least 28 inches thick if they are to less than the quantity residing underground. be mined underground, or with depth-to-seam Some deposits are too small or inaccessible to thickness ratios of 10 or less for surface mines. warrant the financial investment required to These limits are set for reasons of mining eco- bring a mine into operation. others underlie nomics. Large quantities of coal exist in other- surfaces that cannot be disturbed. Finally, all wise minable deposits that do not meet these the coal in any particular deposit cannot be ex- qualifications, but little incentive now exists to tracted by even the best mining technology mine them because others are less expensive to and equipment because of safety or economic mine. Until the energy expended for recovery considerations. exceeds the recoverable energy, no intrinsic reason exists why these less attractive deposits These concepts are illustrated in figure 4 cannot eventually be exploited after more fa- and defined as follows: vorable seams are exhausted. Average depths of coal mines in Europe exceed 1,000 feet. One ● Coal Resources are the total coal deposits regardless of whether they can be mined or recovered. Some but not all of the resources are known. There is no assurance Figure 4.- U.S. Coal Resources and Reserves that the unknown quantities actually exist, This estimate is based on the geologi- Billion cal similarity of potential fields to known tons 4,000 coal-bearing areas. ● Coal Reserves are deposits assumed to be commercially minable by virtue of their seam thickness and accessibility. The magnitude of reserves can be estimated with considerably more confidence than 3,000 that of resources. ● Recoverable Reserves are the estimated tonnage of coal that can be produced with existing mining technology. Reserves that cannot be mined for legal, political, social, or other reasons are not included. 2,000 The recoverable reserves represent less than 50 years of the Nation’s present total energy consumption, and this figure is subject to downward revision if more stringent regulations are enacted. Upward revision will result if the estimated resources can be identified, or if new techniques increase the recoverable fraction. Coal may never be required to supply energy at such a high consumption rate (75 Quads of energy imply about 3.75 billion tons/ yr), although it did supply almost 80 percent of a much smaller demand in 1910. It can, however, substitute for a large share of the decline in the production rate of oil and gas. Unlike oil SOURCE ‘Paul Averitt Coal Resources of the United States Jan 1, 1974 Geological Survey Bulletin 1412 and gas, coal can be a major source of energy “ “ Based on 57 percent recoverability in underground mines and 80 percent in through the 21st century. surface mines Ch. Ill—Coal Technology and Techniques . 57 mine in the U.S.S.R. is reported to operate characteristics (tendency to fuse when heated), deeper than 2,500 feet. Even in the United as do higher ranks of coal generally. The States, one Colorado coal mine is at a 3,000- lowest rank coals, subbituminous and lignite, foot depth and an Alabama coal mine at 1,900 are nonagglomerating. In general, moisture feet. Several Appalachian seams of less than and volatile content decreases and fixed car- 28 inches are mined underground. Exploitation bon increases with increased rank. of these reserves presently uncounted as re- Boilers and furnaces can be designed to coverable could substantially extend the use- burn almost any coal, but may not be readily ful lifetime of coal. adaptable to other coals even of the same types. The characteristics that affect equip- Types of Coal ment design are the heating value, ash melting characteristics, hardness of both the coal and Coal is divided into five classes: anthracite, its mineral matter (for grinding), and mineral bituminous, subbituminous, lignite, and peat. composition, which affects corrosion and foul- Peat is the earliest stage in the formation of ing tendencies. Coal beneficiation can im- coal. Heat and pressure force the moisture and prove undesirable characteristics and reduce hydrocarbon from the peat until progressively the differences among coal types. higher ranks of coal are formed. Thus, anthracite contains the lowest percentage of mois- The sulfur content of coal became increas- ture and the highest percentage of carbon. The ingly important when limits were imposed by chemical and physical properties of the other the Clean Air Act of 1970 on emissions from types lie between anthracite and peat. The combustion. New or modified powerplants composition, heat content, and locale of typi- starting operation between 1974 and 1978 are cal ranks of coal are shown in table 8. High- limited to emissions of 1.2 Ibs sulfur dioxide volatile bituminous coals have agglomerating (SO,)/million Btu of input. (More stringent

Table 8.—Coal Ranks and Typical Characteristics

Coal rank Coal analysis, bed moisture basis Class Group State County M VM FC A S Btu

1. Anthracitic ...... 1. Meta-anthracite Pa. Schuylkill 4,5 1.7 84.1 9.7 0.77 12,745 2. Anthracite Pa, Lackawanna 2,5 6.2 79.4 11.9 0.60 12,925 3. Semianthracite Va. Montgomery 2.0 10.6 67.2 20.2 0.62 11,925 Il. Bituminous ...... 1. Low-volatile bituminous W.Va McDowell 1.0 16,6 77.3 5.1 0.74 14,715 coal Pa. Cambria 1,3 17,5 70.9 10,3 1.68 13,800 2. Medium-volatile bituminous Pa. Somerset 1.5 20.8 67.5 10.2 1.68 13,720 coal Pa. Indiana 1.5 23.4 64.9 10.2 2.20 13,800 3. High-volatile A bituminous Pa. Westmoreland 1.5 30.7 56,6 11.2 1.82 13,325 coal Ky. Pike 2.5 36,7 57.5 3.3 0.70 14,480 Ohio Belmont 3.6 40.0 47.3 9.1 4.00 12,850 4. High-volatile B bituminous Ill. Williamson 5.8 36.2 46.3 11.7 2,70 11,910 coal Utah Emery 5.2 38,2 50.2 6.4 0.90 12,600 5. High-volatile C bitummous Ill. Vermilion 122 38,8 40.0 9.0 3.20 11,340 coal

Ill. Subbduminous ...... 1. Subbitummous A coal Mont. Musselshell 14.1 32.2 46.7 7.0 0.43 11,140 2. Subbituminous B coal Wyo. Sheridan 25.0 30,5 40,8 3.7 0.30 9,345 3. Subbituminous C coal Wyo. Campbell 31.0 31.4 32.8 4.8 0.55 8,320

IV. Lignitic ...... 1. Lignite A N.D. Mercer 37.0 26.6 32.2 4.2 0.40 7,255 2. Lignite B

Data on coal (bed moisture basis)

M equilibrium moisture, %. VM volatile matter

FC fixed carbon, %. A ash %. S sulfur % Btu = Btu/lb, high heating value Calculations by Parr formulas Adapted from Babcock and WIICOX, Steam, Its Generation and Use, p 5-11 58 ● The Direct Use of Coa/ regulations forthcoming from the Clean Air 3,000 feet of the surface. A few in the Rocky Amendments of 1977 will eliminate the use of Mountain region were canted very steeply with low-sulfur coal as the sole means of compli- the upheaval of the mountains during their for- ance for new powerplants. ) Maximum sulfur in mation. Some reach depths of 30,000 feet. coal to meet this emission standard without Coalbeds exhibit the structural vagaries of other controls is approximately 0.6 percent for geological changes that have occurred since coal with a heating value of 10,000 Btu/lb. For their inception. An example of what can be ex- each 1,000 Btu/lb higher or lower, the allow- pected in the structure of a bed is shown in able sulfur content is changed about 0.06 per- figure 7. Note that the coal is not uniform in cent (i. e., the sulfur Iimit for coal with 12,000 thickness in the roof or floor condition — nor Btu/lb would be about 0.72 percent). Some even continuous. These variations present a powerplants will be limited to more stringent changing pattern of mine problems and even limits, as described in chapter IV. Other users, limit the amount of reserves that can be safely such as industrial facilities, may be subject to and economically recovered, Other beds, how- different standards. The availability of coal by ever, are startlingly level and geometrically region as a function of SO emissions is shown X uniform for miles in every direction. I n the Ap- in figure 5. palachian region, an area of ancient eroded A large number of other substances have mountains, outcrops can often be found cir- been identified in coal. Many elements were cumscribing adjacent mountains. Some beds drawn up from the soil into the vegetation that are split into several layers with intervening formed coal. Later streams and ocean poured rock layers. Beds quite unrelated geologically in over the rotting beds of vegetation carrying can be stacked atop each other. in mud, sand, and other minerals. Thus, coal The most desirable commercial beds are can contain varying degrees of many elements. those that are thick, uniform, and very exten- Typical elements in the mineral matter of coal sive. The Pittsburgh bed is minable over an are shown in table 9. The quantities listed are area of 6,000 square miles in Maryland, West averages based on many samples. The number Virginia, Pennsylvania, and Ohio with a thick- of samples is indicated at the heading of each ness of up to 22 feet. The edges thin out over a column. As with sulfur content, elemental much broader area. This bed presents a strik- composition varies widely, not only among ing continuity over this vast region and has samples from different beds but also among yielded more than 20 percent of the U.S. coal those from the same mine. All of these ele- mined to date. Other Eastern beds also cover ments are found elsewhere in the environment, several thousand square miles with coal 2 to 10 but are known to be damaging to the environ- feet thick. Midwestern beds can be even ment or to human health at certain concentra- thicker and broader. Herrin (No. 6) in Illinois, tions and mode of entry into organisms. The Indiana, and western Kentucky covers 15,000 potential for the damage, if any, cannot be square miles with a thickness of up to 14 feet. reliably predicted because the mineral matter The largest bed in the United States is the of most coals has not yet been fully analyzed, Wyodak in the Powder River Basin of Wyo- and the pathways of these trace elements ming and Montana. The average thickness is 50 through the biosphere after combustion are to 100 feet and 150 feet has been observed. generally not known. The possible effect of . trace elements in the environment is discussed in chapter V. Coal Distribution*

Coal Formations Coal deposits are dispersed over much of the country. The major coal provinces are Coal generally occurs in major structural ‘Geological Survey Bulletin, 1412. basins as shown in figure 6. The actual coal- ‘This section is drawn largely from “Coal Mining, ” by beds are within these basins. Most beds are the National Research Council, National Academy of broad and thin with most of the coal within Science, 1978. Ch. Ill—Coal Technology and Techniques 59

Figure 5.— Regional Recoverable Reserves That Burn With Emissions Equal or Less Than Indicated

1,000,000 r I

100,000

10,000

1,000 0.6 0.8 1.0 1.2 1.4 1.6 1.8 2.0 2.2 2.4 2.6 2.8 3.0 v 10 Sulfur oxide emissions (Ibs per million Btu) 60 ● The Direct Use of Coai

Table 9.—Geometric Mean (Expected Values) of 36 Trace. Elements in 601 Coal Samples From Four Major Coal-Producing Regions, based on sequential ppm (parts per million) values recorded from Eastern, Appalachian coals

Average East Interior West Texas (601) Element (331) + (194) + (93) i- (34) = samples

200 72 34 51 89.2 70 30 300 150 137.7 70 30 100 150 112.5 60 58 37 91 61.5 30 10 15 50 26.2 B ...... 20 50 70 100 60 v ...... 20 20 7 30 19.2 Li ...... 18.8 7 4.3 14 11 Cu ...... 16 16.3 7.4 20 14.9 Crr ...... 15 10 3 15 10.7 15 18 2 15 12.5 12.8 58 12.8 28 27.9 11 12 2 5 7.5 10.9 19 4.3 2.8 9.2 7 2 3 7 4,7 7 7 3 15 8 5 7 1.5 5 4.6 3.5 2.8 .5 5.8 3.1 3 .7 3 2 2.2 3 3 1.5 5 3.1 2.8 1.6 2.4 3 2.4 2 1.5 .3 2 1.4 2 2 1.5 .7 1.5 1.3 .77 .59 1.6 1.1 1.2 1.4 1.1 4.2 2 1 2.3 .45 1.6 1.3 1 1.4 .7 2.4 1.4 .8 .8 .4 .7 .7 .7 .7 .3 1.5 .8 .3 .12 .2 .2 .2 .14 .1 .06 .13 .1 .13 .11 .028 .15 .1 .093 .5 .92 .6 .5 .074 .04 .037 .11 .1 .052 .063 .245 .17 .1 .025 .026 .1 .009

shown in figure 6. About 13 percent of the en- reserves in each State are large enough that tire country has coal beneath the surface. production could be increased substantially West Virginia and Illinois are about two-thirds even though several States (Virginia, Tennes- underlain, while North Dakota and Wyoming see, Alabama, and Kansas) have depleted more are more than 40 percent. The deposits vary than 40 percent of their original reserves. widely in size and quality, as described in the previous sections. It is useful to separate the Eastern Regions recoverable reserves by their likely means of extraction, as the impacts of strip mining are Appalachian Region: Coal production in the quite different from those of underground min- Appalachian region may be characterized as ing. Table 10 lists the recoverable reserves and being in the advanced stages of maturity (i.e., 1976 production by mining method for each having annually supplied 60 percent or more State in units of tons and heat content The of total national production since coal mining Ch. Ill—Coal Technology and Techniques ● 61

(n 5

. Y-

x u c (% 62 The Direct Use of Coa/

Figure 7.— Incline No. 1, Herrin (No. 6) Bed in Illinois

r Danville (No. 7) Coal Pleistocene glacial drift

began in the United States). The coal is ob- from 20 to 25 percent of total national produc- tained from a large number of mines of widely tion for many years. varying sizes and from a large number of coalbeds, many of which occur in areas of steep The greatest portion of the total remaining terrain. recoverable reserves for underground mining occurs in beds underlying already mined-out The remaining recoverable underground re- seams. Very large quantities remain, especially serves are large, but substantial portions may in Illinois. remain unmined because they occur in uneconomical seams. Surface mine reserves are Surface mine production has remained es- probably insufficient to support even present sentially constant for a number of years. As production rates for more than a decade. The surface topography is generally favorable for coal is generally the highest grades of bitumi- large-scale surface mining, it is likely that this nous, but it often has a high sulfur content. method wilI be further pursued (although at reduced annual rates from individual mines) in Eastern Interior Region: Coal production in thinner beds as reserves in the principal beds the eastern interior region involves a small become exhausted. number of individual mines with relatively high annual production rates. Indiana, western Prospects are favorable for substantial ex- Kentucky, and Illinois have annually supplied pansion of production from underground Ch. Ill—Coal Technology and Techniques 63

mines, Surface mines should be able to main- nificant. The coalbeds are persistent but thin tain their present rate for many years, The coal throughout the region, except in Iowa and the tends to have a slightly lower heat content southern portion of Oklahoma, where some - than Appalachian coal, and the sulfur content beds are of moderate thickness. Were it not for can be quite high. local markets, it seems doubtful that much coal would be mined in this region. Some coal occurring under difficult mining conditions in Western Interior Region: underground pro- the southern portions of Oklahoma and Arkan- duction has entirely ceased in Arkansas, Kan- sas is of metallurgical and foundry grade and is sas, and Oklahoma and has been very limited being mined and shipped out of the region. for manv years in Iowa. While surface production has remained approximately constant in Production in this region is unlikely to in- recent years, the amount produced is not sig- crease significantly in the near future

Table 10.—Recoverable Reserves as of January 1, 1976

Under- 1976 production ground Surface Un- heat heat derground Surface Under- content content minable minable ground Surface quadrillion quadrillion million million million million State Btu Btu Total tons tons Total tons tons Total

Ohio ...... 180 07 287 7,500 4,900 12,400 16.2 29.3 45.5 Pennsylvania ...... 418 28 446 16,700 1,200 17,900 43,8 39.9 83.7 Kentucky E ...... 136 84 220 5,200 3,600 8,800 41.5 48.0 89.5 Virginia ...... 53 17 70 2,000 700 2,700 24.0 12.8 36.8 W. Virginia ...... 516 00 616 19,100 4,100 23,200 88.4 20.5 108,9 Maryland ...... 14 3 17 500 100 600 0.2 2.5 2,7 Alabama ...... 27 26 53 1,000 1,100 2,100 7.4 14.2 21.6 Tennessee ...... 9 6 15 400 300 700 4.1 4,7 8.8

Total W. Interior 62 95 157 2,600 4,500 7,100 0.3 9.5 9.8 Montana ...... 898 794 1,692 40,400 39,700 80,100 26.1 26.1 N. Dakota ...... — 118 118 — 8,100 8,100 — 11,1 11.1 Wyoming 421 404 825 18,000 19,000 37,000 0.6 30.3 30.9 S. Dakota ...... — 4 4 — 300 300 — — — Colorado ...... 159 61 220 7,100 3,000 10,100 3.4 6.1 9.5 Utah . . . 91 5 ~r20 3,600 200 3,800 7.9 — 7.9 Arizona ...... — 5 5 — 300 300 — 10.2 10.2 N. Mexico ...... 29 42 71 1,200 2,000 3,200 0.9 8.9 9.8 Texas 52 52 — 2,500 2,500 — 14.2 14.2 Washington ...... — — 600 400 1,000 3.9 3.9 Alaska ...... — — 3,100 600 3!700 0.7 0.7

Total West 1,598 1,485 3,083 74,000 76,100 150,100 12.8 106.9 119.7 GRAND TOTAL ...... 3,931 2,307 6,238 169,000 113,900 282,900 292.6 367.3 659.9

SOURCE Based on Bureau of Mines data 64 ● The Direct Use of Coa/

Western Regions sidered dubious), and North Dakota and Texas (where the lignite beds are considered unsuit- Surface Minable Regions: The Western States able for underground mining), the Western contain the most recoverable surface-minable States of Colorado, Utah, Montana, and Wyo- reserves (75 billion tons) and are virtually un- ming contain more than 69 billion tons of re- touched (except for a few large active opera- coverable underground reserves. Although im- tions). The beds generally are thicker than beds portant portions of the coalfields of Utah, Col- being surface-mined elsewhere in the country orado, and Wyoming have undergone substan- (excluding Pennsylvania anthracite). In Wash- ington and Arizona, surface-minable reserves tial depletion, many relatively unmined areas remain. Some of these may be comparatively are essentially those remaining in the surface difficult to mine because of the degree of dip mines now active in each State; in South Dako- or the excessive thickness of overlying cover, ta and Utah, surface-minable reserves are rela- but in many areas mining conditions are favor- tively small, and in Colorado, surface-minable able. reserves are largely confined to the two northwestern counties. Significant increases in underground pro- The sparsity of surface mining in these duction in Utah and Colorado can be expected States has been due to their remoteness from in the next few years. Similar interest in the un- large markets. In anticipation of future need, derground reserves in Wyoming and Montana intensive prospecting and acquisition by lease may also develop, although underground re- or purchase was initiated about 10 years ago, covery of as much as 50 percent of the thicker and many large individual mines already are beds may be difficult with present technology, operating or have been planned. Contracts for which is generally limited to bed thicknesses large annual shipments from some of these not exceeding 15 feet. If or when additional unit areas to existing or contemplated new production becomes necessary, there is no rea- powerplants have been negotiated, while other son why underground production could not be units have been set aside for prospective gasi- conducted simultaneously or subsequent to fication or liquefaction plants. Plans for new surfacemining. or connecting transportation facilities have been completed or are being developed. Most Western coal is subbituminous or lig- Underground Reserves: Excluding Washing- nite. It has a substantially lower heat content ton, New Mexico, and Alaska (where signifi- and a higher moisture content than Eastern cant recovery of underground reserves is con- coal. The sulfur fraction is typicalIy low.

MINING AND PREPARATION

A wide variety of mining techniques exist to tors that suggest a particular methodology, exploit the different types of coal seams de- and the resuIting impacts. scribed in chapter 11, The two general methods, surface (i. e., strip) and underground, are used under quite different geological conditions, Surface Mining and a number of mining techniques are utilized. The ultimate choice of method and spe- Surface mining involves exposure of the cific technique depends on a number of fac- seam by removal of the overlying soil and tors such as geological conditions, safety, pro- rocks (overburden), The four basic methods are ductivity rate, skills available in the labor area, open-pit, contour, and auger mining. Un- force, economics, etc. This section presents a til about 1965 surface mining of coal was not brief description of the technologies, the fac- considered feasible unless the overburden-to- Ch. Ill—Coal Technology and Techniques ● 65 seam thickness ratio was 10:1 or less. Thus, to practiced where deposits outcrop from rolling justify removing 50 feet of overburden, the hills or mountains, particularly in Appalachia. coal seam would have to be 5 or more feet This method consists of removing the overbur- thick. Since 1965, this ratio has been increasing den above the bed by starting at the outcrop and, depending on the nature and structure of and proceeding along the contour of the bed in the overburden, coal within 150 feet of the sur- the hillside. After the deposit is exposed and face may now be economically recoverable, removed by this first cut, additional cuts are even when the overburden-to-seam thickness made into the hill until the ratio of overburden ratio is as much as 30:1.3 to product brings the operation to a halt. A variant on this technique is mountaintop removal, Area mining, the major strip-mining method when the seam Iies sufficiently near the top. used on Midwestern and some Western coal lands, involves the development of large open Contour mining creates a shelf, or “bench,” pits in a series of long narrow strips (usually on the hillside. The highwall borders it on the about 100 feet wide by a mile or more in inside, the downs lope on the other side. Before length). It is the preferred method in flat ter- the enactment of the Surface Mining Control rain where the coal seam is parallel to the sur- and Reclamation Act of 1977, or prior State re- face, as it is for many Western coals. Before quirements, the overburden, or spoil material, mining begins, access roads and maintenance sometimes caused severe environmental prob- and personnel facilities must be constructed. lems. Unless controlled or stabilized, this spoil This phase may require 5 years and about 200 material can cause severe erosion, landslides, workers. If all other components (preparation and silting of streams. Contour mining is illus- plant, transportation, and customer facility) trated in figure 9. are in place, the process can be compressed to The mining equipment used in contour min- as little as 1 year with a much greater demand ing is generally smaller than that used for area for manpower. The actual mining starts with mining and consists of bulldozers, shovels, the cutting of a trench across one end of the front-end loaders and trucks, all of a scale to strip, using bulldozers or a dragline. Top soil is fit on a relatively narrow ledge. reserved for reclamation, and the remaining overburden is placed in a spoil bank. Blasting Auger mining is employed in hilly terrain is often needed to fracture the overburden and where the slope above the coal is too steep or coal. A loading shovel lifts the coal into large high to allow normal contour mining. The usu- trucks, which take it to the crusher. The al procedure is to contour mine as far into the scraper or dragline is moved to the next posi- hill as practical, then auger mine further. Huge tion and opens a new trench, transferring the drills, with cutting heads up to 7 feet, are driv- overburden to the mined-out trench. This cycle en horizontally up to 200 feet into the coal is repeated to the Iimit of the mine boundaries. seam. Reclamation is accomplished by smoothing The types of equipment used in surface min- the spoil, covering with top soil, and revegetat- ing are shown in figures 8 and 9, These items of ing. Figure 8 illustrates the procedure. equipment (except auger) are used to achieve Open-pit mining is somewhat similar except similar basic steps in each surface mining that it involves the preparation of a larger method, The steps and equipment used are: area, perhaps 1,000 by 2,000 feet wide. The 1. Topsoil removal using bulldozers and overburden is moved around in the pit by truck loaders. Trucks convey it to a stockpile. and shovel to uncover the coal seams. This 2. Overburden removal, using blasting to technique is used primarily for the very thick loosen it if it is rock or shale, and scoop- Western seams. ing it out with bulldozers, stripping Contour strip mining is most commonly shovels, bucketwheel excavators, or draglines. Walking draglines are used in some

‘Energy A Alternatives (University of OkIahoma, May} contour mines, but their main use is in 1975), pp. 1-21 area mines. They have buckets up to 200

44- [$12 ( I) - - I - ,, 66 The Direct Use of Coa/

Figure 8.–Strip Mining Method

cubic yards and boom lengths of 180 to The trucks are usually used only to take 375 feet. Stripping shovels can be used in the coal to a nearby processing facility. any type of surface mine. Bucket wheel After crushing, and sometimes cleaning, excavators can be used with stripping the coal is stored at the tipple awaiting shovels when the overburden is soft. From transport to market. 1 to 40 tons of overburden must be moved 5. BackfiIling the overburden is generallv for every ton of coal mined. done simultaneously with removing it 3. Coal fracturing is usually done by blast- from a fresh area. It is graded and coming, though some types can be scooped up pacted with bulldozers. directly. 4. Coal loading and hauling, using mine 6. Topsoil is returned and spread. shovels or front-end loaders and trucks. 7. The area is revegetated. Ch. I/l—Coal Technology and Techniques 67

Photo credit OTA

Western surface mining. Dragline (background) exposes coal seam while front-end loaders (foreground) dump it into trucks for haulage to rail spur or powerplant 68 ● The Direct Use of Coa/ b

is self-revealing

Stripper shovel, eastern Ohio Ch. Ill—Coal Technology and Techniques 69

Figure 9.—Typical Contour Stripping Plus Auger Method

Underground Mining As with surface mines, the first step is the construction of access roads and necessary Underground mining is considerably more aboveground facilities. The next step is to con- complex than surface mining. Rather than struct a portal —the passageway to the seam. simply scraping away the overburden and The selection of location and type of portal trucking away the coal, underground miners (generally shaft or slope) depends on the par- must work with the thick overburden above ticular site. The mining plan must consider them, connected to the outside world by shafts costs of access and construction, personnel and passageways sometimes thousands of feet transit, and coal haulage among other factors. long. Problems nonexistent or unimportant on From the portal, parallel entries are driven into the surface loom large underground: roof sup- the coal to provide corridors for haulage, ven- port, ventilation, lighting, drainage, methane tilation, power, etc. Cross-corridors then reach liberation, equipment access, and coal convey- to the sides of the mine, leaving pillars in a ance, among others, must be dealt with. checkerboard pattern to support the roof. The Contour strip mining in Martin County, Ky. Photo credit OTA

deeper the mine, the bigger the pillars must be anized undercutting, drilling, and loading. Un- relative to the mined-out areas I n some cases, dercutting is accomplished by huge chain saws less than 50 percent can be removed. In such protruding from the bottom of self-propelled cases it may be desirable to mine the pillars as vehicles. These cut a slot about 6 inches high, the equipment retreats back towards the main perhaps 10 feet deep, into the coal and then corridors. The roof must then be supported by across the face, perhaps 20 feet. This machine other means or alIowed to collapse. moves to the next face while the drilling machine takes its place. The coal drill is a self-pro- Equipment used in underground mining pelled vehicle with a long auger attached to a ranges from relatively simple up to highly movable boom. It drills holes above and as automated and productive machinery. The deep as the cut. One hole is required for a face oldest method, still in occasional use in very area 3 to 4 feet high and 4 to 5 feet wide. The small mines, is primarily hand labor. The coal presence of rock in the coal may mandate is undercut at the bottom of the face, and more holes. Blasting (called shooting) is done blasting holes are drilled into the face above. with chemical explosives or compressed gas. Explosives shear the coal loose by forcing it The latter is considered safer, but it is slower down into the cut. It is then hand loaded into because only one hole can be shot at a time. shuttle cars. This method has been almost en- The coal is loaded by a machine that slides it tirely replaced by conventional mining: mech- onto a conveyor belt and dumps it into a shut- Ch. 111—Coa/ Technology and Techniques ● 71

Photo credit OTA Shoveling loose coal at Pittston’s Buffalo Mining Co., operation on Buffalo Creek, W. Va., 1975 tle car. These cars take the coal either to a trol dust. In addition, time must be spent mov- change point, where it is transferred to a con- ing equipment, changing bits, hooking up elec- veyor belt or mine car, or directly out of the tric power, and performing maintenance. A m inc. Roof bolting also is an integral part of typical conventional mining sequence is the operation in order to maintain structural shown in figure 10. integrity of the roof. A bolting machine drills holes in the roof and inserts anchor bolts, Continuous miners were developed to com- which firmly attach the roof to stronger overly- bine the operations of conventional mining, ing layers of rock through expansion shells or thereby further increasing productivity. Many resin. Bolts are generally required on a 4- by 4- different types of continuous miners are avail- foot array. This is one of the most dangerous able, but al I operate on the same basic princi- activities in the mine. AlI these operations pro- ple. A rotating head digs into the coal and duce a large amount of dust and liberate meth- dislodges it while arms scoop it up onto a con- ane trapped in the coal. Exposed areas are veyor belt for loading. Thus, the multiple rock-dusted to prevent coal dust explosions. I n cyclic transfers of machines from face to face all seams, frequent methane testing is required in conventional mining are greatly reduced. at the face. Continuous monitoring is required Most continuous miners still must withdraw to under some conditions. Some machines must allow roof bolting and ventilating duct exten- be hooked to a water supply for a spray to con- sion. The continuous mining method is ill us- 72 • The Direct Use of Coal

Figure 10.—Underground Mining

Conventional mining I Overburden I

Drilling Trackless Cutter

I Overburden I I -... ~,. ~ -- ~ r· ~ -.. 'I ~.. , ... ~ r ... "If ,- ,.. '7"~- ~.. ~ ...... - .,," . ~ ... ~......

Biasting Coal iemOval

, I

Plan view (continuous and conventional showing coal support pillars) • Ch. III--Coa/ Technology and Techniques ● 73

extracted by this process. Figure 11 shows the major elements. A variant of the IongwalI technique is known as the shortwall. It is conceptu- ally similar, but the shorter side of the rec- tangle to be mined is attacked. This rarely exceeds 200 feet. Ventilation is a major problem in modern mines because the highly productive equipment produces high levels of dust and methane. Dust is reduced by water sprays at the working face. (Further discussion about the impact of dust can be found in chapter Vi.) Meth- ane must be diluted with air to less-than-flammable limits to avoid the possibility of underground explosions. In a few mines methane is drained from the coal seam before mining. The operation recovers methane (natural gas) for use as fuel and reduces the danger of mine explosions. The legal ownership of the gas recovered before mining is not clear, as mineral rights to the coal do not necessarily convey rights to the gas or the gas may emanate from undeterminable regions beyond the ownership boundary. Generally the methane content of the coal increases at greater depths because the methane has less opportunity to diffuse to the surface over geologic time. Thus, as the shallower seams are depleted and the deeper Photo credit OTA mines are developed, the safety problem will End of shift in 30” coal at Cedar Coal Co., worsen and the recovery opportunities in- Logan County, W. Va. crease. It has been estimated that 200 cubic feet of methane are released for every ton of trated in the lower portion of figure 10. The continuous miner’s useful activity is limited to coal mined. Hence the potential contribution 20 to 30 percent of the time. Haulage of coal to our gas supply is not trivial if the legal ques- away from the face is a major constraint on tions can be resolved. ’ operations. Longwall mining is a significantly different Coal Preparation approach than both conventional and continu- Coal preparation modifies the mined coal to ous mining work in the room and pillar system help meet the customers’ needs in terms of described above. Longwall mining has been size, moisture, mineral concentration, and used in Europe for many years and is now gain- heat content. A preparation plant of some sort ing popularity in the United States. Corridors is an integral part of most large mines and may 300 to 600 feet apart are driven into the coal often serve a number of mines. I n some cases, and interconnected. The Iongwall of the inter- particularly in the West, the coal is only connection is then mined in slices. The roof is crushed. About half the raw coal in the Nation held up by steel jacks while the cutter makes a is cleaned to reduce impurities such as mineral pass across the face. The roof jacks are advanced with the shearer to make a new pass. The roof collapses in the mined-out area be- 4“Degasification of Coal Beds–A Commercial Source hind the jacks. Practically all the coal can be of Pipeline Gas, ” AGA Monthly, January 1974. —

. , . .~

.', ...... ~ .. . #-. J.

. ~, ~.' ' .. ..: ... , - ... •.. .

gw m 9 C d m m d o k B 0 h mph 0 h d g m h p o m h m w m Ad d g d d mp h h d d d h d d p h d h d h g h h p p m q pm d m p p g p m h C h g mm p m d 8 h m m 90 p b m p d d m w h g e- p d m d h p d h w R P P mp m 9 m Ch. Ill—Coal Technology and Techniques ● 75

Figure 11 .—Longwall Mining System

Elevation view

Overburden

/ Mining Conveyor machine

Plan view

. Conveyor Mining Tunnel Supports. 1 machine

Slumped overburden

A L Air Main tunnel 76 ● The Direct Use of Coa/

lion tons, or 41,2 percent of total production of due to the mining of lower quality coal. This raw coal was cleaned at a pIant. This resulted rise also coincided with a decrease in the total in a net production of 267 miIIion tons of proc- amount of coal being cleaned. Utilities began essed coal and 107 million tons of refuse. The finding cleaning less worthwhile, in part refuse fraction has been increasing, as shown because of the growth in mine-mouth plants, in table 11. Two prominent phases of increase which reap no transportation benefits from the are notable. The first, which lasted until about reduced weight of clean coal. Also, much of 1962, was mostly due to increased mining the increased production has come from the automation that reduced selectivity of mining West, where most coal produced is not appro- coal between mineral partings at the face. The priate for cleaning. A typical cleaning plant in- second, which is still in evidence, seems to be cludes the following steps:

Table 11 .—Mechanically Cleaned Bituminous Coal and Lignitea (thousand short tons)

Total raw Percent Refuse coal Cleaned of total resulting Percent moved to Cleaned by Total production in refuse cleaning by wet pneumatic Total produc- mechanically cleaning of raw Year plants methods methods cleaned tion cleaned process coal

1940 ...... 115,692 87,290 14,980 102,270 460,771 22.2 13,422 11.6 1945 ...... 172,899 130,470 17,416 147,886 577,617 25.6 25,013 14.5 1950 ...... 238,391 183,170 15,529 198,699 516,311 38.5 39,692 16.6 1955 ...... 335,458 252,420 20,295 272,715 464,633 58.7 62,743 18.7 1956 ...... 359,378 268,054 24,311 292,365 500,874 58.4 67,013 18.6 1957 ...... 376,546 279,259 24,768 304,027 492,704 61.7 72,519 19.2 1958 ...... 320,898 240,153 18,882 259,035 410,446 63.1 61,863 19.3 1959 ...... 337,138 251,538 18,249 269,787 412,028 65.5 67,351 20.0 1960 ...... 337,686 255,030 18,139 273,169 415,512 65.7 65,517 19.4 1961 ...... 328,200 247,020 17,691 264,711 402,977 65.7 63,489 19.4 1962 ...... 339,408 252,929 18,704 271,633 422,149 64.3 67,775 20.0 1963 ...... 362,141 269,527 19,935 289,462 458,928 63,1 72,679 20.0 1964 ...... 388,134 288,803 21,400 310,203 486,998 63.7 77,931 20.1 1965 ...... 419,046 306,872 25,384 332,256 512,088 64.9 86,790 20.1 1966 ...... 435,040 316,421 24,205 340,626 533,881 63.8 94,414 21.7 1967 ...... 448,024 328,135 21,268 349,402 552,626 63.2 98,624 22.0 1968 ...... 438,030 324,123 16,804 304,923 545,245 62.5 97,107 22.2 1969 ...... 435,356 315,596 19,163 334,761 560,505 59.7 100,593 23.1 1970 ...... 426,606 305,594 17,855 323,452 602,936 53.6 103,159 24.2 1971 ...... 361,168 256,892 14,506 271,401 552,192 49.1 89,766 24.9 1972 ...... 398,678 281,119 11,710 292,829 595,387 49.2 105,850 26.5 1973 ...... 397,646 278,413 10,505 288,918 591,737 48.8 108,728 27.3 1974 ...... 363,334 257,592 7,557 265,150 603,406 43.9 98,184 27.0 1975 ...... 374,094 260,289 6,704 266,993 648,438 41.2 107,101 28.6 aU.S. Bureau of Mines Yearbook, various years

l. Comminution (crushing) to liberate impur- top and the heavy refuse to the bottom. ities and provide a product of appropriate The two products can then be collected size. separately. Dense-medium processes, the 2. Sizing (to ensure uniformity of size) with next most popular, effect a sharper sepa- screens or fluid classification. ration. The coal is immersed in a heavy 3. Cleaning to remove impurities. Jigging is fluid in which the coal floats and the the technique most used. A bed of raw refuse sinks. The dense-medium cyclone is coal is stratified in water by pulsations a variant that uses centrifugal force to that move the light particles (coal) to the assist the separation. Other techniques Ch. Ill—Coal Technology and Techniques ● 77

are concentrating tables, froth flotation above, the modern practice is to recycle the and pneumatic methods. These are dewater. Completely closed loops are coming scribed in appendix I I of volume II. into practice. Leaching from the refuse piles is 4. Dewatering and drying reduce shipping prevented by compaction and layering. weight and problems of handling and combustion. Dewatering, the mechanical separation of water, is done with screens, filters, and centrifuges of various types. Capital Costs Drying uses heat to remove water. It is relatively expensive and can cause air Before a mine can be opened, a consid- pollution problems, which explains why erable amount of capital must be committed, the practice has been declining. and the operator must be sure of obtaining the 5. Water clarification is the process of re- appropriate manpower, material, and equip- moving enough suspended coal from the ment. New mines are quite expensive to open. water that the water can be recycled. This Costs vary significantly from site to site. A is usually done in settling tanks assisted 1976 estimate gave the following results in dol- by fIocculents. lars per annual ton capacity. ’ The coal preparation plant may itself be- Illinois come a significant source of pollution even AppaIachia Basin Western though it serves to reduce pollution where the Surface 47 50 18 coal is burned. Refuse piles contain sufficient Underground. 66 48 48 coal to smoulder, causing noxious emissions, These figures are sharply higher than earlier but this can be prevented by proper manage- estimates, largely because of hyperinflation in ment, Pneumatic cleaning methods and ther- the heavy equipment market. Thus a new 2- mal dryers are sources of particulate matter, million ton/yr surface mine in Illinois would and both are being phased out or equipped cost $100 million. As described in chapter 11, with baghouses. The wash water has the poten- this mine would just meet the demand of one tial of releasing large quantities of impurities large electric utility unit. In 1976 it would have similar to acid mine drainage. As mentioned been the 46th largest mine in the country.

TRANSPORTATION AND TRANSMISSION

Once mined and processed, coal is trans- The following description of rail, water, and ported to another site for combustion. Trucks truck transport has been excerpted from a ma- and belt conveyors serve nearby “mine- jor section on coal in a comprehensive discus- mouth” facilities. Highways, railroads, water- sion of current energy transportation systems ways, and slurry pipelines are the transporta- and movements issued recently by the Con- tion mode for longer distances. Energy from gressional Research Service. b This report and mine-mouth powerplants can be transmitted its accompanying maps are commended to the by high-voltage transmission cable. The cost of transportation is a major determinant of the ‘George W Land, “Capital Requirements tor New availability of specific mines or combustion Mine Development, ” Third Conference on Mine Produc- facility sites. Further, the revenues earned tIvlty, Pennsylvania State University, April 1976 from transporting coal will be very important ‘National Energy Transportation, vol. I and accompa- to the transportation industry. This section de- nying maps, prepared for Senate Committees on Energy and Natural Resources and on Commerce, Science, and scribes methods of long-distance transporta- Transportation (Washington, D C Congressional Re- tion of the coal and transmission of electric search Service, 1977), maps prepared by U S Geological power. Survey, Committee Print, Publlcatlon 95-15 78 ● The Direct Use of Coa/ reader. Additional material on unit trains and load by rotating. Some loading and unloading coal slurry pipelines is taken from a previous facilities can handle thousands of tons per OTA report. ’ hour. As a coal trade journal reported: “A typical requirement today would be to load three trains per day, each consisting of 100 cars of Railroads 100 tons net loading each; provide one and About two-thirds of the coal produced in the one-half train loads of storage on hand at the United States is transported in railroad cars. start of each loading and provide a loading Coal is moved by rail almost entirely in open- rate of 4,000 tons/hr. ”9 topped hopper cars or gondola cars, which can Track conditions dictate the types of equip- be unloaded by turning the car completely ment and the loads that can be hauled. No gen- over, by opening ports, or more rarely, by un- eral compilation of conditions is available loading from the top. The cars are generally because they vary substantially with mainte- loaded from the top at mine sidings or coal- nance, weather conditions, and other factors, Ioading installations central to a number of but it is generally accepted that younger track, mines. Coal from the mines is I if ted into silos track in the West, and track operated by the or onto storage piIes, travels by gravity or con- more solvent railroads tend to be in better con- veyer, and then moves through a chute into the dition; older track, track in the Northeast, and car. track owned by railroads that are in financial The average hopper car carries about 75 trouble tend to be in worse shape. tons of coal. Older cars average 55 tons, and A particular type of rail service for ,major the newer ones move 100 tons at capacity. The shippers of coal and other bulk commodities is complete cycle of loading, hauling to the un- provided by unit trains. This type of train, de- loading point, unloading, and returning for signed to take advantage of economies of another cargo averages 13 days for each car. scale, generally carries a single commodity in Although this is a shorter turnaround time than dedicated service between two points in suffi- is experienced for any other type of bulk move cient volume to achieve cost savings. The cars ment, inactivity is still a major factor in the are designed for automated loading and un- 8 economics of coal movement by railroad. loading, and the train is operated by proce- The size of hopper cars that can be accommo- dures that minimize switching and time-con- dated depends on roadbed conditions and the suming delays in freight yards. weight the track can tolerate. Western coal unit trains tend to use 100-ton hopper cars; A typical coal unit train consists of six 3,000- Eastern shipments often require the older 55- horsepower locomotives and 100 hopper cars ton hoppers. with carrying capacities of 100 tons each. Roughly two such trains per week are therefore Unloading facilities for hopper cars, Iike required to deliver 1 million tons of coal per loading facilities, are large-scale, permanent year depending on the results involved. Speeds installations. They may take the form of tres- vary considerably depending on track condi- tles running over storage piles, into which coal tions, but 20 to 50 miles per hour is a common is dumped from the bottom of moving cars, or range. they may be rotary dumpers, which tip the entire car over, spilling its contents. Cars with swivel couplings need not be uncoupled to un- Waterways The “hardware” of the shipment of coal by 7 Technology Assessment of Coal Slurry Pipelines, A barge or other water carrier includes the tugs, (Washington, D. C. Office of Technology Assessment, 1978) ‘Railroad Freight Cars Requirement for Transporting “’From Mines to Market by Rail The Indispensable Energy, 1974-85, prepared for the Federal Energy Admin- Transport Mode, ” Coal Age, v. 7, pp. 102-112 at p 103. istration under contract by Peat, Marwick, Mitchell, and McGraw-Hill Publications Provides a good technical de- Co Table of turnaround times at p. 11-11 scription of unit train loading and unloading, Ch. ///—Coal Technology and Techniques ● 79

Photo credit OTA Coal tipple on Cabin Creek, W. Va.

or self-propelled vessels, which push the by 35 feet) open barge cost $70,000 in 1968 and “tow,” composed of as many as 36 barges, usu- probably costs more than $125,000 today; the 0 ally of 1,500-ton capacity, from a loading towboats cost many times more. II dock to an unloading dock. A great variety of The loading facilities used for barges resem- sizes, shapes, drafts, and power capability ble some rail loading facilities. They generally characterizes the towboat fleet. entail a conveyor belt carrying coal from a Modern steel barges are of numerous de- stockpile to a movable chute, which can dump signs to handle differing commodities. Their the coal into waiting barges along a pier. Un- bows and sterns are usually formed to fit into a loading facilities are much different, however: neat tow that presents an unbroken, low-fric- barges must be unloaded without the aid of tion surface to the water. A jumbo-sized (195 ‘‘ Transportation of Mineral Commodities on the Inland “)Natiortal Transportation Trend\ and Cholces (Wash- Waterways of the South Central States, Bureau of Mines ington, D C U S Department of Transportation), p 256, information circular 8431 (Washington, D C U S De- 258 partment of the Interior, 1968), p 13. gravity, usually by a crane equipped with a carry 62,000 tons of coal. They will be self-un- clam shell bucket. The unloaded coal is gener- loading, using long conveyor belts traversing ally moved by belt conveyors to storage yards. the length of the ships. 3 The average lake car- One modern unloader consists of two revolv- rier has about 20,000-ton capacity. ing scoops, which can clean out a barge in The inland waterways themselves have been three passes. The cost of such facilities is in constructed and maintained by the Federal the millions of dollars. Government, with the “exception of the New On the Great Lakes, oceans, and coastal York State Barge Canal. Since the first appro- tidewaters, single self-propelled bulk cargo priation to the U.S. Army Corps of Engineers carriers are used. Three Great Lakes vessels be for this purpose in 1824, billions of dollars ing built to carry Western coal to a Detroit util- have been spent to make possible the large- ity plant wilI be 1,000 feet long and will each scale commercial traffic now using these internal waterways. In general, the improvement of 12“Using Waterways to Ship Coal No Cheaper Way a waterway to make it navigable involves When Destination is Right,” Coal Age, vol. 79, No, 7, July deepening and widening the channel by dredg- 1974. Description of unloading plant for J M, Stuart Gen- erating Station on Ohio River, pp. 122-123 131 bid,, pp. 126-127, Ch. III--Coal Technology and Techniques ● 81 ing and constructing dams and locks. Erosion control along sections of the riverbank and operation of the dams and locks are also part of the Federal role. There were 255 navigation locks and dams being operated by the Corps of Engineers as of June 1, 1976 The size of the locks available on the river systems is the primary Iimiting factor on river traffic. They are sized to accommodate an expected volume of traffic that generally tapers off toward the source of the river system. Thus in the region of the headwaters fewer tows can be managed; this makes it less economical to operate the carriers and less cost-beneficial to maintain the waterway or justify improvements.

Highways

The fastest growing means of coal transportation is by truck. As opposed to the average haul of 300 miles by railroad, and 480 miles by barge, the average highway shipment of coal is only 50 to 75 miIes.

The public highway trucks carry a total of 15 to 25 tons each. The standard diesel tractor is used to pull one and sometimes two trailers, depending on weight limitations, Much coal movement to nearby powerplants takes place on private roads using vehicles too large for Photo credit OTA public highways; some of these vehicles can Coal-truck traffic, Kentucky carry up to 150 tons of coal. The trucks may fuel, for storage or for transloading to be loaded from a fixed chute, but are more mode. often loaded by shovels or front-end loaders another transportation directly at the side of the coal seam in a sur- Problems involve condemnation rights to cer- face mine. Most trucks are dumpers. Truck tain property, inter-basin transfer of water, and shipments are sometimes used in connection the discharge or use of the separated (and con- with deep-mine operations, but most often are taiminated) water. connected with strip-mine operations. Coal is assembled from a mine or group of mines at a single point where mixing, cleaning, Slurry Pipelines or other beneficiation may take place, and where the slurry is prepared. Preparation Transport by this mode involves three major begins with impact crushing, followed by the stages: addition of water and further grinding to a 1. grinding the coal and mixing it with a liq- maximum particle size of one-eighth of an u id (generally water) to form the SIurry; inch. More water is then added to form a’ mix- 2. transmission through the pipeline; and ture that is about 50 percent dry coal by 3. dewatering the coal for use as a boiler weight, and the resulting slurry is stored in a tank equipped with mechanical agitators to prevent settling Water is not necessarily the “Ibid , p 81 only slurry medium, and oil — as well as meth-

+ 1- 2 - - ‘1 anol derived from the coal itself — has been this type of settling, the operating pipeline at proposed. Black Mesa, Ariz., has ponds into which the pipeline can be emptied in the event of a break The slurry from the agitated-storage tanks is or other interruption. introduced into a buried steel pipe and propelled by pumps located at intervals of 50 to At the downstream end of the pipeline, the 150 miles, depending upon terrain, pipe size, slurry is again introduced into agitated tank and other design considerations. The slurry storage, from which it is fed into a dewatering travels at about 6 ft/sec. Ideally, the flow is facility. Dewatering is accomplished by natu- maintained at a rate that minimizes power re- ral settling, vacuum filtration, or by centrifuge, quirements while maintaining the coal in sus- and the finely ground coal still suspended in pension. Once started, the flow must continue the water can be separated by chemical floc- uninterrupted or the coal will gradually settle culation. Additional thermal drying is general- and possibly plug the pipe. Considerable tech- ly required before use. The reclaimed water nical controversy exists over the likelihood of can be used in an electric-generating station’s plugging and the ability to restart the pipeline cooling system to condense steam — or it couId after given periods of downtime. To prevent theoreticalIy be recycled in a return pipeline.

Schematic of Slurry Pipellne System

Powerplant

so Barges Ch. I//—Coal Technology and Techniques 83

A potential economic advantage of this creased by a factor of more than 2.5 since technology is that the volume of coal that can 1950. Technical and environmental problems be transported increases approximately as the complicate development of transmission sys- square of the pipeline diameter (which means tems beyond 765 kV. that a 2-foot diameter Iine can carry four times High-voltage direct current (DC) systems for the amount of coal as a l-foot diameter line), long-distance power transmission are becom- while construction, power, and other operating ing increasingly competitive relative to high- costs increase more slowly. If throughput vol- voltage AC. Although only one is operating in umes are high enough to take advantage of the United States (on the west coast), other na- this economy of scale, and if the pipeline is tions have more experience. The principal dis- long enough to recover the cost of gathering, advantage of DC transmission is the difficulty preparing, dewatering, and delivering the coal in varying the voltage levels as is done with AC at the termini, the pipeline can compete with systems and transformers. Consequently, it is unit trains. necessary to convert the voltage from AC to DC and back again at each end of the DC line. Electric Transmission This conversion process adds considerably to the cost of a DC system. Until now, this has The principal means of transmitting large greatly limited its use, but new developments blocks of electric power is by high-voltage promise to facilitate the process. The great ad- alternating current (AC) transmission. Electri- vantage of DC is that the Iine is capable of car- cal transmission will become more important rying considerably more power, about 1.5 to 2 as the number of mine-mouth plants increases. times more, than an AC system of the same Electricity is usually generated at voltages of voltage. In addition to the increased energy 12,000 to 22,000 volts(12 to 22 kV). However, it density, DC lines produce less radio interfer- is not economical to transmit electric energy ence and the corona loss is considerably at these generated voltages because the high smaller than equivalent capacity AC Iines. current levels lead to excessive resistive losses Research is currently underway to increase in the transmission system. The attainment of the energy and economic efficiency of high- higher and higher transmission voltages con- voltage electric transmission and to develop tinues to be a major goal. An AC transmission underground systems, gas-insulated lines, and system requires, therefore, transformers to low-resistance (superconducting lines). Sys- step up the voltage from the generator and to tems from 1,100 to 2,300 kV are being tested. step it down where it feeds into the distribu- The principal technical problems are the de- tion system at the load. In addition, there are velopment of adequate insulators and the towers, conductors, and devices to protect the ability to protect against surge voltages. Other system in the event of short circuits and power uncertainties are the possible environmental surges. The conductors are designed to mini- effects of very high electric fields. mize effects of high electric fields that occur Underground transmission exists in this because of the high voltages. These effects, country to only a very limited extent. The prin- which include corona formation and radio and cipal roadblock is cost, owing to the need for television interference, increase energy loss cable insulation and the difficulty of installing and may create disturbances for the popu- and cooling cables underground. There is con- lation near the powerline. tinuing interest in high-voltage underground As of 1976, there were about 360,000 miles transmission, however, because of the techni- of high-voltage (69 kV or higher) transmission cal, environmental, and social problems of ex- lines in the United States. These are the candi- panding overhead networks. The utility indus- date voltages for long-distance, mine-mouth try is conducting R&D to lower costs and im- plant transmission lines. Currently the highest prove performance, but the introduction of un- operating transmission voltage in the United derground high-voltage transmission as a cost- States is 765 kV. The upper voltage has in- competitive technology is many years away. 84 ● The Direct Use of Coa/

Photo credit: Texas Power & L/ght Southwestern Electric Power Company, Shreveport, La.; Weish Power plant, East Texas; units #1 and #2

Gas-insulated and low-resistance lines similar- Two coal slurry pipelines have been con- ly are undergoing long-term development pro- structed in this country; one is in operation, grams. carrying 4,8 million tons per year 273 miles from northeastern Arizona to southern Ne- Transportation Patterns and Cost vada. (The other closed after the competing railroad introduced unit train service and Coal is seldom mined where the energy is lowered its rates.) needed, so transportation is an important element of coal use. Table 12 indicates, by State of origin and destination, the tonnages trans- Unit trains and slurry pipelines are clearly ported in 1976 to electric utilities, which con- appropriate only for very large users of coal. sume about three-quarters of all domestic Smaller users generally rely on less regular steam coal. It also shows that the average ton deliveries by train or truck, sometimes through moved 368 miles in the Nation. Figure.12 shows an intermediary retailer. Similarly, a small that railroads carry most of this coal, and this mine operator could not fill a unit train, but share is increasing. must load a few cars at a time and depend on Ch. ///—Coal Technology and Techniques 85

Table 12.—Origin and Destination of Coal Deliveries to Electric Utilities in 1976 (in thousand tons)

Northern Southern Destination Appalachla i Appalachta l Midwest

— 18,0941 — — — — 6,528,6 234,9 — —. . 7,088,9 765 — — — 4,324,6 1,553.4 — — 13.4387 1,163.9 — 10 1,778,7 21,784.4 11,217,9 1327 5,086.8 21.989,1 3,270.7 — 838 3,070.5 3,553.2 — — 2,259.9 1,172.5 44 22,271.4 3.0366 — 770 29 — — 12,019,3 7,144,4 434,3 1,710 8.6 148.1 1,4364 8,911.5 — 1,0565 520.3 — — 534 19,043 979.1 — — — 2,316 — — 12.5 1,839,6 — — 820.5 753.2 — 4,174 — 1,8948 637.9 — — — — — — 8,0197 — 5.253.7 484.4 — — — 2,908,6 16,678,6 1 — — — — — 6,884.9 38,436.9 8,5102 166 — 9,758,6 — — — — 598.8 37,2255 186,4 — — — 3.7 5.491 — — —. — 27.0 — 2,459.7 481 19,549 1,002.3 — — . — 18,867 903.9 — — — 1.869 6656 4,643.3 — — — — — — 3,600 23,307 4,8133 — — — 6953 1,984.4 5,0793 — 3,389.9 — — — 8,459,4 —.————. ——.—

the railroads to fit them into their schedules. respectively,’ b and slurry pipelines can cost Transportation is thus a major factor in the less than rail under some specific conditions. high price charged by retailers, as discussed in These figures do not include an element of chapter Il. public subsidy for barges and trucks in the form of Government highway and waterway Of the average cost of coal delivered by rail, expenditures. transportation represents about 20 percent.’5 Rough approximate costs of barge, rail and F U eI is required for transportation, amount- truck transport are O.4-, l-, and 5-cents/ton-mile ing on the average to 540 to 680 Btu/net-ton- mile for barge, 536 to 791l Btu for rail, and “.US. Coal Development– Promises, Uncertainties (Washington, DC U.S. General Accounting Office, 1977), p 55 “lbld 86 . The Direct Use of Coal

Figure 12.—Coal Distribution by Transportation Mode and End Use, January-September 1977 (Million short tons)

Transportation Consumer Tramway, conveyor, and private railroad 0 54 (11 /0) Electric utilities 37, (77”/, )

1 52 (11 0/0)

All rail 257 (53°/0)

194 (40°/0)

81 (16°/0)

49 (1 00/0)

36 (7°/0) 26 (5 0/0) ● 2

● 2 27 (6°/0) ● 4 14 (3°/0)

“ Less than 1 percent aIncludes shipments partly transported by other modes. excludes oversea exports. bIncludes retail

SOURCE Department of Energy, Bituminous Coal and Lignite Distribution, January .Septernber 1977, Feb 6.1978

2,518 to 2,800 Btu for highway shipment. 7 Unit rently require diesel fuel from petroleum. A trains are somewhat more efficient than rail ton of 8,500 Btu/lb coal hauled 1,000 miles at generally, and slurry pipelines, although more 600 Btu/net-ton-mile requires the equivalent of energy intensive than unit trains, consume 3½ percent of its energy value, usually in electricity derived from a variety of fuels, in- diesel fuel. Hence, importation of low-sulfur eluding coal, while the other three modes cur- coal can use more energy than flue-gas desulfurization applied to local high-sulfur coals. “Congressional Research Service, 1977, op cit., p 85 (See the section on Air-Pollution Control Tech- Ch. Ill—Coal Technology and Techniques ● 87 nology of this chapter for a further discussion coal transportation. Typical costs of transmis- on fIue-gas desuIfurization. ) sion as a function of voltage are: Construction Cost per The regional pattern of production and dis- cost per k Wh tribution is also sensitive to transportation mile Capacity (500 miles) a costs, One study’ simulated the purchasing 345 kv $213,000 750 MW O 43 cent behavior of the electric utility industry under 500 kv 267,000 1,500 MW O 29 cent two hypothetical scenarios, In one, the future 765 kv 400,000 3,000 MW O 23 cent cost (in constant dollars) of mining coal was DC lines are less expensive than AC for the assumed to increase by 25 percent whiIe trans- same capacity because the lower voltage al- portation cost declined in the same propor- lows smaller rights-of-way, towers, and con- tion. The other case embodied the reverse ductors. As previously stated, however, DC ter- assumption, that transportation increased by minals are more expensive because of the con- 25 percent while mining declined by the same version equipment. Hence DC is considered relative amount. The second case resulted in a only for long lines (at least several hundred predicted production level of Appalachian miles). New technology, such as very high-volt- coal in the year 2000 that was twice that age AC or DC or new types of DC terminals, predicted by the first case. Western coal ex- may change the equation. Underground trans- hibited the reverse behavior, amounting to mission will be several times as expensive as twice the production in the first case as in the overhead. DC may enjoy a relative advantage second. The pattern was also sensitive to other if underground transmission is required. considerations, Iike the extent to which power- As for comparison with other modes, a re plants constructed after 1983 with mandatory flue-gas desulfurization would be used only cent OTA study on coal slurry pipelines esti- for peakloads. Traditionally, electric compa- mated costs of transporting coal by both rail and pipeline for four different routes in the nies use their lowest cost pIants for baseload United States. The cost estimates ranged from and successively add higher cost units for peak demand. In this way they provide customers $7 to $8/ton for distances of 500 miles. Assum- ing an energy content of 20 milIion Btu/ton and with lowest cost energy. If new plants with scrubbers become more costly than old plants a heat rate of 9,000 Btu/kWh for the power- using low-sulfur Western coal, the pattern of plant at the end of the pipe-rail line, energy coal origin and distribution may be expected delivery cost is about 3.0 to 3.5 mills/kWh. to adjust accordingly, Costs vary considerably but in general, electric transmission is competitive with rail or pipe- One of the factors affecting the economies line for distances of up to 500 to 600 miles. Be of powerplant siting is the cost of delivering yond that point, rail and slurry costs increase the power to the load center. If a number of at a slower rate than electric transmission suitable sites are available between the mine costs. Federal policies can have a substantial and the load center, the utility may choose re- effect on relative pricing advantages through mote siting, with power transmission replacing differing tax advantages and subsidies.

COMBUSTION TECHNOLOGY AND METHODOLOGY

Three major factors influence the way coal The latter units are responsible for such a is burned. The first is the size of the facility to small fraction of coal burned that they are not be constructed, with utilities usually building described here. A full description is included in the biggest, industry substantially smaller, and appendix I I I of volume 11. The second factor is the residential/commercial sector the smallest. the set of environmental standards the facility is required to meet, The rapidIy changing regu- 1aTeknekron, Inc , Projections of Utility Coa/ Move- latory climate is radically changing coal use ment Patterns: 1980-2000, OTA, 1977 patterns and forcing the development of new 88 ● The Direct Use of Coal technologies Finally, the characteristics of the the boiler. The water is returned by “down- coaI to be burned control some design param- comers” to the bottom of the boiler, where it is eters as discussed earlier in the section on Coal distributed by “headers” to the lower end of Resou rces. the furnace wall tubes to pass once more through the heated zone of the furnace,

Utility Boiler Furnaces Steam, separated from the unevaporated Uti ity boiler furnaces generally have a dewater, flows through superheater tubes of low- sign f ring rate greater than 250 million Btu/hr, alloy steel located at the furnace outlet. These equivalent to about 10 tons of bituminous coal banks of tubes may be heated partly by radia- per hour. The largest utility units burn as much tion from the pulverized-coal flame, but usual- as 500 tons of coal each hour at fulI load. In- ly mostly by convection from the hot furnace dustrial boilers usually range downward from gases, now cooled to about 2,0000 F. This the smaller utility units, from 20 tons to about raises (superheats) the temperature of the 3 tons of coal per hour. Large coal-fired utility steam to about 1,0000 F as it leaves the boiler powerplants are much the same in principle to- for the steam turbine. After expanding in part day as they were in the 1920’s when pulverized in the turbine and converting some of its heat coal was first used to generate steam. Today’s energy into shaft horsepower, the partially boiler furnaces are much larger, produce cooled steam may be returned to the boiler steam at much higher temperatures and pres- where it passes through another bank of boiler sures than half a century ago, and are more ef- tubes that reheat the steam. The steam at vari- ficient in converting the energy in coal into ous stages of the turbine is bled in part to aux- steam. But the concept of grinding the coal to iIiary equipment to heat water or to power ap- very small size and blowing it with air into paratus and finally to the condenser, which large furnace cavities, where the cloud of coal reduces the final pressure at the exit of the tur- dust burns much like a fuel gas, is still the way bine to below atmospheric pressure. The con- most coal is burned today. densed water is pumped back through a series of heaters and an economizer— a bank of Pulverized Coal-Fired Boiler Furnace boiler tubes located downstream of the superheater and reheater. Here some of the heat in The principles of this most widely used the flue gas that otherwise might be wasted steam generator are relatively simple. Raw raises the temperature of the boiIer feed water, crushed coal is fed continuously into pulveriz- which passes once more into the boiIerdrum. ers, where the coal is dried and ground so that at Ieast 70 percent wiII pass a 200-mesh sieve to form a combustible cloud of coal. Air, Flue gas leaving the economizer still con- heated by the spent products of combustion tains appreciable heat energy, which is recov- before they enter the stack, is blown through ered in part by passing it through an air heater, the pulverizers, drying the coal and conveying generally a massive array of mild-steel sheets it to the burners in the boiler furnace. At the arranged in bundles or “baskets, ” which rotate burners, additional heated air is mixed with the successively between ducts carrying the flue airborne coal stream to provide a SIight excess gas to the stack and air to the furnace. Tubular of oxygen to ensure complete combustion. The heat exchanges have been widely used as air coal burns in a long, luminous flame in the heaters, but rotating platetype regenerative huge furnace cavity at temperatures in the heaters described above are common. In either flame of at least 2,7000 F. Heat energy from type, metal heated by the flue gas passes the this flame is transferred largely by radiation to heat to the incoming air, which usually is the relatively cool furnace walls. The heat is raised to temperatures between 3000 and 6000 transferred to water, which boils to generate F. Because the overall efficiency of a steam- steam. The steam is separated from the un- generating unit as a whole will increase about evaporated water in a steam drum at the top of 2.5 percent by raising this air temperature by Ch. III—Coal Technology and Techniques ● 89

1000 F, it is obvious that the highest practical ly half the total heat released when the coal is temperature is sought. burned is picked up by furnace wall tubes.

Flue gas leaving the air heater contains par- Other furnace configurations call for all the ticles of fly ash. Electrostatic precipitators, burners to be arranged on one wall, firing hori- under ideal conditions, can capture 99.9 per- zontally into the furnace, or on opposite walls cent of this fly ash. The flue gases consist of to provide opposed firing. Many such varia- carbon dioxide, nitrogen, oxygen, and lesser tions are used to control the admission of air amounts of nitrogen oxides, sulfur oxides, car- and coal to the furnace, to develop good tur- bon monoxide, and hydrocarbons. Flue-gas de- bulence for complete combustion, to mini- sulfurization systems, mostly based on scrub- mize problems with slagging and fouling of bing the flue gas with chemically active solu- furnace walIs and heat-receiving surfaces by tions or with slurries of lime or limestone, are the ash in the coal, to utilize each square toot being heavily promoted for controlling SOX of furnace walls as effectively as possible as emissions. heat-receiving surfaces, and to permit control of superheated temperature within the narrow Work now underway on alternative energy range demanded by the steam turbine. sources and fuel systems will not be sufficiently advanced in the next 10 years to have a ma- The largest pulverized-coal-fired boiler, jor impact on electric power generation meth- which was contracted in 1976, is rated at 1,281 ods using fossil fuels or their derivatives; the MW, It will provide nearly 10 million Ibs use of pulverized coal-fired boiler furnaces steam/’hr at a pressure of 3,845 Ibs/in2 and at a may be expected to dominate the fuel-burning temperature of 1,0100 F with reheat to 1,0000 public-utility field during that time. F. The surface area of the furnace walls is 146,000 ftz, with 192,000 ftz in the superheater, Characteristics of Pulverized Coal Furnaces 255,000 ftz in the reheater, 494,000 ft2 in the economizer, and over a miIIion ft2 of surface in Furnaces for burning pulverized coal can be the air preheater.20 very large. Configuration varies among the four major boiler manufacturers, but basically Supercritical Boilers a furnace is a huge, hollow, rectangular box made up of vertical water-filled mild-steel A development of considerable importance tubes welded into panels to constitute the fur- in recent years has been the design of utility nace walIs. For one typical boiIer furnace pro- boilers to operate above the critical pressure viding steam to an 800-MW turbine generator, of 3,208 lbs/in2. Above this pressure, water the height of this cavity is 160 feet, the width behaves as a single-phase fluid, and there is no 45 feet, and the depth 90 feet. A vertical water- distinction between liquid and steam, as there walI panel divides the furnace into two halves, is at lower pressures. In supercritical boilers, each with a cross-section of 45 by 45 feet, Pul- water from the economizer enters the boiler verized coal is blown tangentially into each and is heated as it passes first through the wall half of this split furnace at the corners by four tubes and then through the superheater, with- arrays of burners, aimed near the center of the out any change in phase, as by “boiling” for furnace to produce a rotating vortex flame pat- subcritical boilers. There is no steam drum in a tern with a vertical axis. In some furnaces, the supercritical boiler. Supercritical boilers are burners can be tilted upward or downward to also known as “once through” boilers, because adjust the location of the flame and to control feed water is pumped into one end of the steam temperature. At full load, essentially the boiler and “steam” exits from the other, The entire bottom half of the furnace is filled with outlet steam temperatures depends only on flame, with the upper portion providing time the rate at which feed water is supplied to the to complete the combustion reactions. Rough- boiler and the amount of heat picked up in the

19 “Steam It's Generation and Use (Babcock & Wilcox, 201976 Annual Plant Design Report, ” Power, Novem- 1972), p. 13-4 ber 1976, p S-4. 90 The Direct Use of Coa/ furnace. Control of water quality is critical in of ash on superheater and reheater tube banks; supercritical boilers, for without a steam drum and 3) corrosion. boiler, water that has accumulated impurities Some of the mineral forms in coal melt in entering with the feed water cannot be “blown the pulverized-coal flame, where the tempera- down” occasionally. ture may reach 3,0000 F. These tiny molten Supercritical units generally are large. In droplets pick up other mineral forms by colli- 1972, contracts were let for six such boilers, sion in the highly turbulent zone just beyond the smallest rated at 520 MW. In 1973, there the flame, forming larger drops of molten were four supercritical boilers sold; in 1974, “slag.” Some of these reach the wall tubes of seven; in 1975, six; in 1976, nine, and in 1977, the furnace and, by some mechanism still not three. ” There is an apparent trend downward, fully understood, adhere to that metal surface, with 30 percent of the new boilers listed being even though the metal is cooler than about supercritical in 1971, 17 percent in 1976, and 9 8000 F. Gradual buildup of these slag droplets percent in 1977. Such trends generally develop eventually forms a solid layer of slag. Because as the utilities find by experience that reliabil- coal-ash slag does not conduct heat readily, ity, operating problems, maintenance, startup, this layer of slag decreases the amount of heat or economic factors influence their choice of reaching the wall tube, and hence lowers the equipment. There does not appear to be any quantity of steam produced at this point. Peri- one reason for this falling off of interest in odicalIy, as the load changes, and there is a dif- supercritical boilers, although material limita- ferential expansion between the wall tubes and tions are a major factor. the slag layer, huge sheets of slag may peel off the walls. But to control slag more effectively, Slagging and Fouling “wall blowers” are provided that use high- velocity jets of air or of steam, and occasional- Probably the single greatest problem in the ly streams of water, to dislodge the slag and operation of coal-fired boiler furnaces is the leave clean furnace walls. Occasionally, slag accumulation of coal ash on boiler surfaces. accumulations may get so large that manual All coal contains noncombustible inorganic cleaning is required, or large pieces of slag that mineral matter. Some of it was an integral part have fallen to the bottom of the furnace can- of the original vegetation that accumulated to not be removed without breaking them by form coal seams; however, most of the mineral hand. A furnace outage is then necessary, a matter associated with coal accumulated as costly step that is avoided as far as possible. sediment from mineral-laden water that perco- lated through the coal deposits over eons of Fouling occurs when very small particles of time. The chemical composition of the mineral ash are carried to the bundles of tubing mak- matter varies widely and there are no “typical” ing up the superheaters and reheaters. These concentrations. About 95 percent of all the fly ash particles collect on the tube surface, noncombustible material in coal is made up of not only insulating the metal so that not kaolinite (A120, . 2Si0, .2 H, O), pyrites (FeS2), enough heat is transferred to raise the steam and calcite (CaCOJ).22 Many variations occur, temperature to design levels, but also ac- particularly in the clay minerals; probably a cumulating so much that it plugs the normal hundred different minerals have been identi- gas passages. “Soot blowers” are provided to fied in coal. remove such ash deposits periodically, but some coal ash may form dense adherent layers This mineral matter causes three main prob- very difficult to remove except by manual lems when burned in larger boiler furnaces: 1) cleaning. buildup of ash on furnace wall tubes; 2) accumulation of small, sticky, molten particles The third problem is corrosion of the wall tubes beneath a layer of slag or deposits. This

21 has been a serious problem in the past and re- "Annual Plant Design Survey s,” Power, 1972-77 23 William T Reid, “External Corrosion and Deposits. mains a potential threat to uninterrupted Boilers and Gas Turbines” (EIsevier, N Y , 1971), p 52 boiler operation. Ch. Ill—Coal Technology and Techniques ● 91

Cyclone Furnaces Industrial Boiler Furnaces

An innovation in boiler design in the late Industrial boilers are generally rated by 1930’s was the “cyclone” furnace, a water- horsepower or steam output, ranging from cooled, slightly tilted horizontal cylinder with about 10,000 Ibs steam/hr to as much as 1 mil- combustion air blown in tangentially to pro- lion Ibs steam/hr. The largest industrial boiler vide a high level of turbulence to burn the cen- contracted in 1977 will generate 840,000 Ibs trally admitted crushed coal. Because of the steam/hr, burning oil and gas. The largest coal- high combustion intensity, temperature ex- burning industrial boiler ordered in 1977 is ceeds 3,1000 F and the ash in the coal forms a rated at 550,000 Ibs steam/hr, with bark as a liquid slag covering the inside of the cylinder supplementary fuel. 23 and dripping from the lower end. Larger particles of the crushed coal are caught by this slag layer and burn as these pieces of coal are con- Based on earlier data24 for the various sizes tacted by the rapidly rotating tangential air of industrial boilers fired with coal, traveling- stream. grate, and underfeed stokers are most popular in smalIer units, accounting for about 41 percent of the steam generated in boilers with out- Advantages of the cyclone furnace are the put less than 20,000 Ibs steam/hr, and about 29 capture of a major part of the ash in the coal percent of the boilers rated under 100,000 as molten slag, the use of crushed rather than lbs/hr. Spreader stokers dominate the midsize more costly pulverized coal, and the smaller industrial field, accounting for roughly half of furnace required for a given steam output. the steam generated in coal-fired boilers rated With cyclone furnaces, 70 to 80 percent of the at 200,000 lbs/hr and smaller. Pulverized coal ash is converted to slag, thereby greatly de- boilers dominate the largest industrial field, creasing the fly ash in the secondary furnace, providing 78 percent of the steam generated in compared with 20 percent ash recovery in a units larger than 200,000 lbs/hr, dry-bottom, pulverized-coal-f i red furnace. Crushed coal is simpler to handle and is appreciably cheaper than pulverized coal. And be- Natural gas and fuel oil have been the pre- cause of the very high combustion intensity in ferred fuel for industrial boilers in smaller the cyclone, the associated secondary furnace sizes, in part because the cost and space re- serving as a heat-recovery system for several quirements of such plants is much lower than cyclone furnaces can be significantly smaller for coal firing. With the present unsettled fuel than a conventional furnace of the same out- supply situation, more companies may be will- put. ing to invest the greater costs for solid-fuel boilers to take advantage of a more secure source of energy. Shortcomings of the cyclone revolve mainly around ash characteristics of the coal; the Many industrial boilers are shop-assembled; viscosity of the molten slag must allow flow on fabricated under conditions favoring low-cost a horizontal surface. Because of the very high production methods. The largest size is dic- temperatures in the combustor, NO formation X tated by shipping limitations. Such shop-as- is appreciable and difficult to control. Hence, sembled boiIers are completely assembled and in recent years, cyclones have not been pop- enclosed in a steel casing, eliminating even the ular. But the growing demand for low-sulfur need for applying insulation or housing in the Western coal, often containing coal ash that forms such fluid slag at moderate furnace tem- 23 perature as to cause serious problems with “1977 Annual Plant Design Survey, ” Power, Novem- ber 1977, p 5-12 slagging in dry-bottom furnaces, could bring 24 ’’Evaluatlon of National Boiler Inventory, ” Environ- cyclone and other slag-tap furnaces back into mentaI Protection Agency TechnicaI Series, E PA-600/ the market. 2-75-067, October 1975

0 92 ● The Direct Use of Coa/ field. Although generally fired with fuel oil or the end. Adjustment of the distribution assures natural gas, similar packaged units can be de that the coal falling on the grate is properly signed with grates and stokers to be fired with positioned to burn out completely by the time coal. A coal-fired packaged boiIer was de- the coal reaches the ash-discharge position. signed and built in the 1950’s, but only a few Some spreader stokers use stationary sec- units were installed because the growing avail- tioned grates that are dumped section by sec- ability then of low-cost natural gas and the tion into the ashpit as ash accumulates. lesser attention by a fireman needed with gas Roughly half the coal burns in suspension, firing proved to be more economical. With a so there may be problems with emission of fly change in fuel availability and costs, packaged ash and unburned carbon with spreader stok- boilers fired with coal may see greater use. ers. To minimize loss of boiler efficiency from unburned carbon, fly ash collected in hoppers Pulverized Coal-Fired Industrial Boiler is reinfected into the furnace. Erosion of boiler Furnaces tubes may be troublesome. Industrial boilers fired with pulverized coal are basically similar to utiIity units except that Traveling-Grate Stokers the industrial boilers are smaller, steam output These consist of a horizontal moving grid of is less, and steam pressure seldom exceeds iron links connected to form an endless belt 1,500 lbs/in2. Because of costs for auxiliaries driven by sprockets to move a fixed bed of such as pulverizers, the lowest practical steam coal through a furnace. Coal is fed at one end output for pulverized coal-firin is about g to a depth of 4 to 6 inches, ignites as it enters 200,000 lbs/hr. The same problems with slag- the hot furnace by radiation from a furnace ging and fouling occur in large industrial arch and by recirculation of burning particles boilers as in utility steam generators, and the of coal from farther in the furnace, burns as it plant is more sophisticated and difficult to moves from the inlet, and eventually is operate than other industrial furnaces. dumped as ash into the ashpit at the end of the grate. The speed of the grate is adjusted to en- Spreader Stokers sure complete combustion, and air is admitted These stokers are very popular for steam de- through the grate in zoned sections to control mand below that supplied by pulverized coal. combustion. A spreader stoker can burn a variety of coals, it Traveling-grate stokers can burn a wide responds rapidly to load changes, and it is more economical in larger sizes than other variety of fuels, ranging from coal to garbage. kinds of stokers. They are not well suited to coals that cake strongly. The concept of the spreader stoker dates back to 1822, as a way of feeding coal to a Underfeed Stokers grate without opening the furnace door.25 The Whereas in traveling-grate stokers the coal same principle is used today. A mechanical and the combustion air move in opposite di- distributing device, either an assembly of rections (countercurrent flow), in underfeed rotating paddles or a series of air jets arranged stokers the coal and the air move together in at the end of the furnace, throws crushed coal the same direction into the combustion zone. into the combustion zone of the furnace. The Coal is forced upward through a conical retort smaller particles of coal burn in suspension topped with nozzles through which the air is while the heavier ones fall onto a moving blown. This establishes the zone where ignition grate, where they burn with air supplied up- occurs, the burning coal then moving onto sta- ward through the grate. The grate moves slow- tionary perforated grates, where combustion is ly so that the ash from the coal is discharged at completed. 26 Temperatures are high and the coal ash fuses into lumps., Unlike traveling- 25 Combustion Engineering (New York Combustion Englneerlng, Inc , 1966), p 18-2 “Ibid , p 18-8. I Ch. III---Coal Technology and Techniques ● 93 grate stokers, strongly caking coals are han- bars, or flexing grates successively, to move died readily in underfeed stokers. coal into a sloping fuel bed. As with traveling- grate stokers, air moves upward through the Single-retort underfeed stokers are used in grates, so this is a special case of overfeed small boilers, generally under about 30,000 Ibs burning. The same principle is used in grates steam/hr. For greater output, multiple-retort for burning municipal refuse. Vibrating-grate stokers have been built at ratings up to 500,000 stokers appear to be more popular in Europe Ibs steam/hr. These operate on the same princi- than in the United States, possibly because our ple of concurrent movement of coal and air strongly caking bituminous coals are more but with many engineering changes to accom- troublesome than the lower rank coals over- modate the large fuel beds. seas. Vibrating-Grate Stokers These stokers depend upon oscillating grate

AIR POLLUTION CONTROL TECHNOLOGY

There are currently six “criteria” air pol- focuses on control technology for their remov- lutants–pollutants for which National Ambi- al from flue gas. ent Air Quality Standards (N AAQS) have been promulgated: sulfur oxides (SOx, nitrogen oxides (NO X), particulate, carbon monoxide Particulate Control (CO), hydrocarbons, and photochemical oxi- Stationary combustion sources burning coal dants. Emissions of the first three can be re- produce bottom ash, cinders, and slag, which duced in the direct combustion of coal by are removed from the furnace itself, and fly three methods. One is to remove containinants ash, which is entrained in the flue gas. before combustion, the second is capture them during combustion, and the final is to remove Four types of systems are capable of remov- them from the flue gases after combustion. ing particulate from flue gas: mechanical or The effectiveness and cost of removing any cyclone collectors, electrostatic precipitators, one is in part dependent on the method and se- wet scrubbers, and fabric filter baghouses. quence of removal of the others. Because of the wide variation in the composition and Cyclone Collectors makeup of the containinants in coal and be- Mechanical or cyclone collectors work on cause boilers are designed especially for the fuel being fired, no universal method can be the principle of gravitational, centrifugal, or prescribed that would be best for al I new or ex- inertial forces to separate the particles from isting plants. the gas. One type consists of an enlarged chamber, which slows the gases and allows the The level of emissions of CO and hydrocar- particles to settle. Another form is cylindrical bons in direct coal combustion is a result of with a tangential entrance that causes the the completeness of combustion, regardless of gases to swirl rapidly. The particles, heavier the coal quality. Oxidants are not directly pro- than the gases, migrate by centrifugal force to duced by combustion but are the reaction the walls of the vessel and drop to the bottom. projects of hydrocarbons and NOx in the at- The clean gases exit at the top. mosphere. Lowering the emissions of the first three These units are simple, relatively mainte- criteria pollutants by precombustion cleanup nance free, reliable, low in pressure loss, and by new combustion technologies is de- relatively low in both capital and operating scribed later in this chapter. The next section cost, and independent of operating tempera- 94 . The Direct Use o/ Coa/ ture. They are particularly effective in remov- ticulate collection efficiency by the use of lowing large particles and can handle high dust sulfur fuels. For example, the Capitol Power loadings. However, their performance is sensi- Plant in Washington, D. C., was originally de- tive to variable dust loading and gas velocity. signed to burn 3 percent sulfur coal. Because of recent air pollution regulations the plant The efficiency of well-designed units ranges now burns 1 percent sulfur coal. This reduction from 80 to 90 percent, depending upon particle in sulfur resulted in a change in the electrical size. Because of their low cost but inadequate properties of the particulate produced, which effectiveness to reduce small particles, they dropped electrostatic precipitator perform- are sometimes used as first-stage cleaners in ance from 99 percent to about 76 percent. conjunction with other devices that are more efficient and expensive. Their use may lower High-sulfur coal has been the standard fuel the size and cost of the follow-on unit. for the power industry. To comply with S0x emission regulations the industry is using Electrostatic Precipitators greater quantities of low-sulfur coal. The ash EIectrostatic precipitators are widely used in from low-sulfur coal is usually of high resist- large stationary combustion sources to remove ivity; with coal of a sulfur content of less than particulate from flue gas. Gas containing par- 1 percent, the naturally formed sulfur trioxide ticulate is passed horizontally between a (S0,) is seldom sufficient to reduce resistivity 0 number of high-voltage discharge electrodes of the fIy ash to a level (about 5 x 10’ ohm-cm) and electrically grounded collecting plates. that permits the electrostatic precipitator to Dust particles are charged by the ions from the function normally. discharge electrode and migrate to the There are several methods of overcoming grounded collection plate, where they adhere these difficulties. Existing facilities can add to and agglomerate. As they do so, some become the size of their precipitators (provided they heavy enough to fall into the collection hop- have the space, which is not always the case) pers. Other dust particles are moved down- to compensate for the increased resistivity, or ward by mechanical rapping of the collection chemically change the resistivity of the par- plates. The particles are then drawn from the ticles by “flue gas conditioning, ” described hoppers and sent to a central particulate col- below. New facilities have these and other op- lection area. After passing the multiple system tions available. Since resistivity varies inverse- of electrodes, the clean gas exits the unit. ly with temperature, one option is to collect Electrostatic precipitators are capable of the particles in a hotter environment. Precipi- collection efficiencies greater than 99.5 per- tators are normally placed on the cool, exhaust cent, and in some cases remove more than 99.9 side of the air preheater (the heat exchanger percent of the dust from the flue gases. Pres- that transfers heat from the flue gas to the air sure drop through electrostatic precipitators is being drawn into the boiler to allow combus- very low, resulting in low operating cost. Cap- tion), where average temperatures are 2500 to ital costs for large utility boilers burning 3000 F. “Hot side” precipitators collect partic- medium- to high-sulfur coal are on the order of ulate matter on the intake side of the preheat- $25/kW. er, where the gases are at 500 to 7000 F and the resistivity of the particles is in the same range Electrostatic precipitators are sensitive to as that of higher sulfur coals at “cold side” changes in the properties of the particles and temperatures. For the Navajo Power Station in the flue gas. The changes can significantly af- Arizona, use of hot-side precipitators with low- fect their collection efficiencies; therefore, sulfur coal caused turnkey capital costs for their design must compensate for normal vari- meeting the particulate New Source Perform- ations in fuel composition and flue-gas tem- ance Standards (NSPS) to rise from $25/kW— perature. the cost of a “cold side” precipitator used with Electrostatic precipitators designed for high- medium- to high-sulfur coal — to about sulfur fuels are adversely affected in their par- $45/kW; the cost of simply using a larger pre Ch. //l—Coal Technology and Techniques 95

cipitator would have been about $50/kW. 27 Wet Scrubbers Other options would have been to use control Wet scrubbers utilize water or other liquids technologies such as wet scrubbers or bag- to “rain out” the particles in the flue gas. Many houses that depend on the physical rather than variations of the wet scrubber exist, each with the electrical properties of the fly ash. specific advantages. Although successful in- Flue-gas conditioning may be an attractive stalIations on large powerplants exist, the eco- option for existing plants because it minimizes nomics are not favorable except for low-sulfur the additional machinery that must be added coals, and most utilities appear to prefer the to a facility. Flue-gas conditioning processes more traditional precipitators. Turnkey costs are in the range of $50/kW. 30 Operating energy inject artificially produced SOJ or some other substance into the flue gas ahead of the pre- costs become quite high if fine particulate cipitator. The “conditioner” becomes attached removal is required. to the particles in the flue gas, reduces the particles’ resistivity and thereby restores collec- Fabric Filter Bag houses tion efficiency without increasing the size of Baghouses contain fabric bags suspended existing precipitators or the need for installing vertically. The particulate-laden gas passes oversized new ones. One manufacturer claims through the fabric and the dust is filtered out. that the incremental cost of using fIue-gas con- Removal efficiency is usually in excess of 99.9 ditioning to meet particulate emission limita- percent. Removal efficiency of fine particu- tions when using low-sulfur coal is approx- Iates can be greater than with other devices, imately one-tenth that of alternatives. 28 Inex- although the small size needed to achieve high pensive (about 3 cents/ton of coal burned) SO, efficiency of these particulate increases pres- injection systems have been installed in at sure drop and operating costs. Although bag- Ieast 60 powerplants and are reported to be houses have a long history of use outside the working reliably, 29 utility industry, their general use on boilers has Designers of new powerplants generally been slowed by problems of fabric clogging have not used flue-gas conditioning as a solu- and chemical damage, poor high-temperature tion to resistivity problems; they have used operation, and high maintenance costs, in ad- hot-side precipitators or larger cold-side pre- dition to their expensive high-pressure drop. cipitators. Conditioners are apparently consid- Because bag replacement represents a major ered as “last resort” solutions if the precipi- maintenance cost, the recent development of tators fail to meet emission requirements. The high-temperature bags made of teflon-coated Environmental Protection Agency (EPA) has fiberglass has made baghouses more attractive tested the effects of various conditioning to utilities. More than 50 baghouse systems agents and has found some evidence that con- have now been installed or ordered at coal- ditioning can add some pollutants to the flue fired powerplants. The next few years of expe- gas while improving the particulate removal rience with several large new facilities are Iike- efficiency; for example, in some instances a Iy to be critical to their future.

significant percentage of S03 injected into the gas was emitted. However, the effect does not Sulfur Oxide Control occur in every system and perhaps may be eliminated by better design. Flue-Gas Desulfurization futilities

The removal of SOX from stack gases is termed flue-gas desulfurization (FGD) and uses 27 Personal Communication with Les Sparks, U.S. E Envi- devices commonly referred to as scrubbers. ronmental Protection Agency, Research Triangle Park, The function of the scrubber is to bring the S0x NC 28 laden flue gases into contact with a liquid that Flue Gas Conditioning for Electrostatic Precipitators (Santa Anna, Calif. WAHLCO, Inc.) 29 William E Archer, “ Fly Ash Conditioning Update," 30Personal communication with Les Sparks, U S Envi- Power Engineering, vol. 81, No 6, June 1977, pp 76-78 ronmental Protection Agency 96 “ The Direct Use of Coa/

will selectively react with the SOX. FGD proc- The 1977 Clean Air Act Amendments passed esses are generalIy characterized by the chemi- by Congress have considerably changed the cal absorbent that is utilized, such as lime, situation for new plants; a percentage reduc- limestone, magnesium oxide, double alkali, tion in SO, emission will be required that ef- sodium carbonate, alkali flyash, and ammonia. fectively rules out use of low-sulfur coal as a The processes are further characterized as sole means of compliance for new boilers. 1 n throwaway or regenerative. In the throwaway view of this, it seems likely that all new boilers processes, the absorbent and the S0x react to for which construction is started after early form a product of iittle or no market value; it is 1978 will require FGD. The new capacity to be disposed of as a sludge or solid. By contrast, installed in the 1980-2000 period is expected to the regenerative processes recover the absorb- be on the order of 200,000 MW (although there ent in a separate unit for reuse in the scrubber is considerable uncertainty about this projec- and generally produce a product with market tion). value (such as elemental sulfur or sulfuric acid). However, if the product has Iittle or no Input Requirements market value, it must be discarded as in the throwaway processes. FGD systems require considerable amounts of raw materials, energy, water, and manpow- FGD is used mainly by the utility industry. er. If the effect of the 1977 amendments is to Although there are a number of non-utility greatly expand FGD use, then these require- FGD installations, their percentage of the total ments could have an impact on other sectors power generating capacity is not significant. In of the economy. the U.S. utility industry, the technology is predominantly used on coal-fired boilers, whereas 1. Raw Materials. Although projections are its use on oil-fired units is prevalent in Japan. difficult, there is some indication that limestone consumption (either as is or Lime-1imestone scrubbing, a throwaway calcined to produce I i me) could approach process, is presently the dominant technology 100 million tons/yr by 2000. The limestone for flue gas desulfurization in the United industry should have no trouble in supply- States. A basic flowsheet for lime-limestone ing the required amount of material, scrubbing is shown in figure 13. The absorbent, assuming (as available evidence indicates) lime or limestone, is introduced into the reac- that the lower grades of limestone are action tank along with scrubber effluent slurry ceptable. and clear liquor recycle from the dewatering 2 Water. FCD systems require from 0.5 to section. The mixture, after holding in the tank 1.5 tons of water/ton of coal burned. By for a few minutes to allow reactions to take the year 2000, this could amount to as place, is pumped to the top of the scrubber much as 1 billion tons, or sIightly more and sprayed down into the gas. A bleed slurry than 700,000 acre-feet/yr. In the west, FGD stream is tapped off from the scrubber effluent water use must be considered a significant and dewatered to give the product sludge. addition to total water demand. Some 11,500 MW of coal-fired utility boiler 3. Energy. FGD systems require energy both capacity have been fitted with FGD, as com- as electrical power to drive equipment pared to roughly 200,000 MW that possibly and as thermal energy to (when necessary) could be so equipped. Another 17,700 MW are reheat the flue gases that have been under construction and 27,200 MW are cooled in the scrubber and have lost some planned, giving a total of 56,400 MW sched- of their buoyancy. The former ranges uled to be in operation by 1985, by which time from 1.0 to 2.5 percent of the boiler there will be about 300,000 MW of coal-fired capacity (depending on the FGD process). capacity that could use FGD (assuming exist- Reheat energy requirement is also vari- ing units are retrofitted). Thus about 15 per- able, depending on the degree of reheat cent of the coal-fired capacity now operating attempted. A recent EPA study indicates or under construction will have FGD. that total FGD energy requirements would Ch. Ill—Coal Technology and Techniques ● 97

Figure 13.— Lime. Limestone Scrubbing System

Stack n

ne ID fan r Boiler

m Precipitator

%3 m

SOURCE OTA. based on EPA data

increase U.S. power consumption over a cost noncontrol situation by 0.7 percent in Although other impacts may be minor or un- 1987 and 1.0 percent in 1997, certain, it is clear that the capital and operat- 4. Manpower. The operating manpower re- ing costs of FGD systems will have a substan- quired in the year 2000 may be on the tial impact. The systems are expensive to build order of 10,000 workers, which does not and operate, and overall cost will be a signifi- seem significant. The main problem is in- cant percentage of power production costs. ability of vendors and manufacturers to keep pace with scrubber demand. The Many site-specific factors affect FGD cost, consensus is that designers and fabrica- and “average” costs must not be assumed to tors probably will not produce any bottle- apply to a particular plant. For new systems, necks but that without special measures the capital cost will “typically” be in the $80 to there may not be enough skilled workers $120/kW range in 1975 dollars, with an annual- (welders, electricians, boilermakers, and ized operating cost (capital charges plus oper- others) to keep construction projects on ating and maintenance) of 4 to 7.5 mills/kWh. schedule. This applies particularly to in- In extreme cases the cost may be 10 mills/kWh dustrialized areas that already have a or greater. Assuming an average of $l00)/kW shortage of ski I led labor. for capital cost, the 200,000 MW projected to 98 ● The Direct Use of Coal

come online between 1985 and 2000 would re- operational units are double-alkali systems. quire a capital outlay of $20 billion (based on Eleven additional double-alkali units are “current dollars”). If a cost of 5.5 mills/kWh is scheduled to start within the year. assumed, boiler system operating costs would The sodium-based units produce a liquid be increased by about $6 billion/yr. These waste containing dissolved sodium com- estimates, which are rough at best, indicate pounds, which are either sent to a pond for that a powerplant’s installation of FGD may evaporation, or treated and disposed into a add 14 percent to investment cost and 18 per- municipal sewer. The double-alkali and the cent to annualized operating cost if the alter- lime-limestone systems produce a dewatered native is no attempt at control of SO emis- Z calcium sulfite/sulfate material claimed to be sions. Site-specific conditions couId vary these suitable for landfill; however, leaching may costs over a wide range. Back-fitting cost stilI be a problem. would be even higher. Operating availability of the industrial sys- Alternative FGD Processes tems is reported to be greater than for FGD systems on utility boilers. However, the prob- Although conventionaI Iime-1imestone lems that occur are similar to those associated scrubbing is now preferred, better FGD proc- with prototype FGD systems on utility boilers. esses might be developed and could have They include corrosion, erosion, poorly sized some impact on inputs and costs. The alterna- equipment due to lack of operating experi- tive nearest to commercial adoption appears ence, and poor pH and gas flow control. to be double-alkali scrubbing, which gains a major advantage by reducing the scaling ex- Capital costs range from $25 to $115/kW. perienced with limestone. Capital costs are reported as lower than for utility installations because capital costs for One other recovery process, sodium scrub- pretreatment and disposal are not generally in- bing-thermal stripping (Wellman-Lord), has cluded in industrial systems. Although none been tested on a large scale. Current installa- has been reported to date, operating costs tions use natural gas as a reducing agent, but should be higher. the industry is testing coal as an alternative agent. Disposal of sodium sulfate will be a problem. Several other recovery methods have Nitrogen Oxide Control promise but have not been developed far enough to have much significance at the pres- Nitrogen oxides (NOx are formed during the ent time. combustion of fuels. The nitrogen originates from the nitrogen content of the fuel as well as the nitrogen in the combustion air. Factors in Flue-Gas Desulfurization — Industrial the formation of NOx are flame temperature, Flue-gas desulfurization was first applied to amount of excess air in the flame, and the industrial boilers in the United States at the length of time the combustion gases are main- General Motors plant in St. Louis, Mo. Two sys- tained at the elevated temperature and subse- tems were installed on coal-fired boilers in quently quencheched. An increase in flame tem- 1972. At the close of 1977, 35 systems had been perature and excess air favors an increase in or were being constructed at 15 industrial sites. the formation of NOX. A rapid cooling of NOX Twenty-four systems were operational, with by relatively cool boiler tubes tends to stabi- the remaining scheduled to begin operation lize the NO, that was formed. Typical NOx within a year. Of the 24, 18 were retrofitted to concentration in the flue gas is 500 to 1,000 existing boilers and the remaining 6 were in- parts per million (ppm) for coal, 200 to 500 stalled on new boilers. ppm for oil, and 120 to 200 ppm for natural gas. Thirteen of the operational systems use sodium hydroxide or sodium carbonate to absorb Currently, the common practice for lowering

S02. One uses Iimelimestone. The other 10 NO, emissions is to modify the design and/or Ch. I/l—Coal Technology and Techniques ● 99 operating conditions of combustion equip- ever, tulI demonstration probably cannot be ment. achieved before the mid-l 1980’s.

Some new furnaces have been designed for This technology is of particular interest be- two-stage combustion. I n the initial combus- cause, if proved successful, it will offer an effi- tion stage, combustion is partially completed cient control of NOX for low cost on new plants with less air than is needed for complete burn- (the new burners may not be more costly than ing. I n the second stage downstream the re- current designs), and allow a moderate cost maining fuel is burned completely, with sec- retrofit to existing plants if this is considered ondary air injected through strategically desirable. located ports. The technique has been successfully tried on a few coal-fired boilers as well as Desulfurization of fuels may provide a con- applied to oil- and gas-fired units. comitant, although small, reduction in the nitrogen content of the fuel. The lower nitrogen The location and spacing of burners in- content of the fuel can also reduce NOX forma- fluence NOx formation. Tighter spacing has a tion during combustion. tendency toward greater NOX formation, probably due to higher temperatures. Burners lo- Research and development (R&D) on the cated in the corners of furnaces produce tan- control of NOX emission by stack-gas cleaning gential flames with a somewhat lower flame is currently being conducted. Unfortunately, temperature. Tangential corner-fired boilers none of the processes is commercially available for coal-fired units. may produce about half the NOX that is generated in either a front wall-fired or an opposing- A number of dry processes are being devel- fired furnace. oped. I n one, ammonia is injected at 1,4000 to Modification of operating conditions has 1,8000 F, which causes the conversion of 40 to 60 percent of the NOx to nitrogen and water In also proven effective in reducing NOX formation. The common techniques consist of lower- other processes various solids are utilized to ing excess combustion air, recircuIating the effect NO removal, The more prominent solids flue gas, and injecting steam or water into the consist of copper oxide sorbent, base metal firebox. Reducing the excess air reduces the catalysts, and activated carbon, In Japan the quantity of atmospheric nitrogen available for capital costs of the dry processes range from

NOX formation. Flue-gas recirculation and $60 to $100/kW and have a removal efficiency steam or water injection reduce flame tem- between 40 and 70 percent. To date these proc- perature, which is an important factor in de- esses have been developed for oil-fired units, and problems caused by catalyst poisoning creasing NOk production. Combinations of these strategies have succeeded in lowering could be expected in their application to coal- NO, emissions from large utility boilers by 40 fired plants. to 50 percent. A number of wet processes for the simul- A promising technology for reducing NOx taneous removal of S0x and NOx are being de- emissions is a IOW-NOX burner currently under veloped. One process utiIizes magnesium ox- development by E PA. Single-burner tests using ide as an absorbent. other processes rely on low-sulfur - coal have yielded an 85-percent oxidants such as chlorine dioxide, ozone, and ‘ reduction in Nox emissions There appears to potassium permanganate to oxidize NO to be a good chance that similar reductions can NOx for easier absorption. Capital costs are be achieved with a multiple-burner system (all said to be in the range of $60 to $90/kW in large boilers have multiple burners) How- Japan. 100 ● The Direct Use of Coa/

FUTURE TECHNOLOGIES

With coal the dominant fossil fuel for elec- on coal cleaning and desulfurization is pro- trical generation, a great many R&D efforts are vided in appendix IV of volume 11. being aimed at future ways of burning solid fuels more effectively, and of substituting coal Mechanical Coal Cleaning for fuel oil and natural gas in applications where these clean flu id fuels have been widely Mechanical cleaning processes are based on used. Improvements in the “quality” of mined differences in specific gravity or surface char- coal are being made, new combustion schemes acteristics of the materials being separated. are being evaluated, direct energy-conversion They can be designed to remove a large frac- systems based on coal are being investigated, tion of the pyritic sulfur, generally the major and serious attention is being given to com- part of the sulfur in high-sulfur coals. Pyritic bined cycles based on coal as the energy sulfur occurs as discrete particles. It is much source. These new technologies have much to heavier than coal, with a specific gravity of offer, but some of the problems will elude the 5.0, compared to coal’s 1.4. Hence when raw best efforts of fuel technologists for many coal is immersed in a dense medium, the coal years. Nevertheless, if coal is to become a floats and the pyrites sink. This process is now more attractive fuel under stringent environ- used to remove shale and rocks, etc. (specific mental regulations, new technologies are re- gravities from 2 to 5) but pyrite is more dis- quired, especially for the smaller industrial persed and finer crushing of the coal than is users. now generally practiced is required to free it for removal.

Coal Preparation Two facilities for fine coal sulfur reduction are about to begin commercial operation. The Upgrading mined coal to improve coal’s use- Homer City Coal Preparation Plant in Pennsyl- fulness or to minimize environmental prob- vania uses dense-medium cyclones to produce lems is an old art. At one time, coal beneficia- a primary coal stream of less than 0.6 percent tion began at the face in the coal mine, where sulfur and an intermediate sulfur coal stream the miner had some control over what he to be used in areas outside of critical air loaded into his mine car. But today’s high- basins. The other plant, near Barnesboro, Pa., speed mining machines cannot distinguish be- uses a two-stage froth flotation process to re- tween coal and the rock partings within coal duce pyritic sulfur by up to 90 percent. Both seams. All goes to the surface. Handpicking plants are described in more detail in appendix rock from coal moving on a belt or a shaking IV of volume II. Neither of these processes, nor table constituted coal preparation at one time. some other mechanical and chemical cleaning Today, coal cleaning methods based on gravity processes intended for pyritic sulfur, affect the separation of the lighter coal particles from organic sulfur. Hence, they will not be usable the heavier rocks and pyrites is becoming more without other control measures by utilities in important as the cost of coal increases in the new plants. They may be of considerable inter- marketplace and environmental restrictions est in smaller or existing facilities that have are imposed on emissions from coal-burning less stringent sulfur removal requirements. The installations. Ordinary coal cleaning to remove applicability of these processes will be deter- ash and rocks, etc., wherein sulfur removal is mined by their cost and the environmental incidental, is described in the section on Min- regulations. To date, no reliable cost figures ing and Preparation. Advanced washing, which are available. can in some cases remove a substantial amount of sulfur, is considered here. More Advanced Cleaning Processes sophisticated chemical beneficiation methods also are being developed. Further information Several physical and/or chemical treatments Ch. Ill—Coat Technology and Techniques ● 101 have been proposed for improved pyritic sul- preciable part of the sulfur, filtering the hot fur removal. These are: solution to remove the insoluble coal-ash minerals, and then driving off the solvent and re- 1. High-gradient magnetic separation covering the demineralized, low-sulfur prod- (HGMS)-separation of pyrite by exploit- uct. Two pilot plants have been running since ing its magnetic properties, 1973, a 6-ton-per-day unit at Wilsonville, Ala., 2. Magnex process— a “pretreatment” proc- and a 50-ton-per-day plant at Tacoma, Wash. ess allowing better magnetic separation. Together they have investigated the response 3. Meyers process — a chemical leaching of of a wide variety of coals to SRC processing, pyrite from the coal. and have produced sufficient product for 4. Otisca process–washing with a heavy liq- burning tests. Commercial-scale burning tests u id rather than a water suspension. were made at Georgia Power. General conclu- 5. Chemical comminution — a “pretreat- sions drawn from these combustion tests indi- ment” process that chemically breaks cate that SRC is a premium fuel in regard to down the coal to smaller sizes. heat value, ash, and sulfur content. Commer- -1-1 These processes will be quite expensive. cial-size SRC plants have been proposed. Their future role is unclear because they will Sustained operation for periods as long as 75 not remove much more sulfur than the ad- days has been achieved at Wilsonville, with vanced mechanical cleaning methods. Appen- some 3,700 hours of operating time in its first dix IV of volume II evaluates them in greater J1 year. In an early stage, Kentucky and an llli- detail. no is coal were treated with 90 to 95 percent re- Processes that attack organic sulfur in addi- covery. The raw coals contained 8.9 to 11.1 tion to pyritic sulfur include: percent ash and 3.1 percent sulfur. The SRC product averaged 0.16 percent ash and 0.96 1. Ledgemont oxygen leaching process —dis- percent sulfur. The designs for a demonstra- solution of pyrites and some organic tion of a commercial-size module have been sulfur using a process simulating the pro- proposed by the private sector in conjunction duction of acid mine water. with DOE. 2. Bureau of Mines/DOE oxidative desulfurization process — a higher temperature, air instead of oxygen variation of the ledge- Low-Btu Gas and Combined Cycles mont process. Coal can be gasified to produce a low-Btu 3 Battelle hydrothermal process— leaching gas. Since the gas cannot economically be of pyrites and organic sulfur under high stored or shipped more than a few miles before pressure. combustion, it is effectively a form of direct 4, KVB process–gaseous reaction of the sul- combustion of coal. The gas is cleaned before fur with nitric oxide. burning so that no emission controls are re- These processes are claimed to remove sub- quired at the combustion facility. Low-Btu gas stantially all of the pyritic and 25 to 70 percent can be burned directly in a boiler to produce of the organic sulfur. All are still in the labora- steam for industrial use or for the production tory stage, so cost data are only conjectural. At of electricity in a conventional steam turbine. present, costs seem to be many times those Alternatively the gas generator can be inte- associated with physical coal cleaning. grated with a combined cycle plant. The first option of direct firing of existing Solvent-Refined Coal boilers with clean, low-, or intermediate-Btu gas is higher in overall capital and operating Solvent-refined coal (SRC) involves dissolv- ing crushed coal in a suitable solvent at moder- l ‘’’ Status Report of Wllsonville Solvent Refined Coal ately high temperature and pressure, treating Pilot Plant, ” EPR/ Interim Report 7234, May 1975, 40 pp the solution with hydrogen to remove an ap- plus app. 102 ● The Direct Use of Coal cost than conventional coal firing with stack eration. Its basic principle involves the feeding gas cleanup, as indicated in recent studies by of crushed coal for combustion into a bed of the Tennessee Valley Authority (TVA) for the inert ash mixed with limestone or dolomite. Electric Power Research Institute (EPRI). In ad- The bed is fluidized (held in suspension) by in- dition, the option will probably be uneconomi- jection of air through the bottom of the bed at cal for many industrial plants. Nevertheless, a controlled rate great enough to cause the gas producers may be practical for the produc- bed to be agitated much like a boiling fluid. tion of chemicals or other industrial uses. The coal burns within the bed, and the SOX formed during combustion react with the lime The second option is more attractive for power generation. With this system crushed coal, water, and compressed air are fed to a gasifier. The hot gases that are produced pass through a purification system to remove chemical contaminants and particulate matter. The clean gases power a gas turbine engine that produces electricity and compressed air for the gasifier. The turbine exhaust gases travel through a waste heat boiler driving a steam electric generator before being exhausted to the atmosphere.

Although the state of the art of turbine de sign will allow efficient combined cycle operation, gas temperature to the turbine must be as high as possible to obtain further efficiency gains. Turbine research at up to 3,0000 F gas temperature is being conducted, but the temperature of the commercially available metal blades is limited by metallurgical problems to 1,0000 F. Blade temperature is kept low by elaborate schemes to circulate cooling water or air through the rotating blades. Research is underway on blades that will withstand higher temperatures and on improved cooling means. Photo credit Department of Energy Prospects for improved efficiency are good. This small-scale model of the coal. fired, fluidized bed, gas turbine system is used to study the behavior of the fuel The low-Btu gasifier integrated with a com- mixture of coal and limestone in the production bined-cycle turbine system has been identified of electrical power as promising from the standpoint of cost of electricity, overall efficiency, and limitation of stone or dolomite to form a dry calcium sul- emissions. New combined cycle plants fueled fate. To maintain high combustion efficiency, by low-Btu gas may be 10 percent more effi- high heat transfer rates, and efficient capture cient in converting fossil fuel to electricity of SOX, the bed temperatures are maintained than are the most efficient conventional pow- between 1,5000 and 1,8000 F. Production of erplants. NOX is minimized because of the low excess air environment of the combustion zone and the low generating temperature of the fluidized Fluidized-Bed Combustion bed compared to conventional combustion, where the temperature may be in excess of Fluidized-bed combustion (FBC) is an impor- 3,0000 F. In addition, in some combustion tant technological alternative for industrial ap- processes burning certain coals, the ash melts plications and perhaps coal-based power gen- during combustion to form molten slag and Ch. ///—Coa/ Technology and Techniques ● 103 clinkers, which foul the boiler tubes and the A major concern with atmospheric FBC re- furnace walls. At the temperature of the flu- lates to adequate removal of fine particulate idized bed more of the ash remains solid, tend- matter prior to releasing the fIue gas to the ating toward unimpeded, uniform operation. mosphere. The agitation of the ash and lime Banks of boiler tubes are in contact with the stone in the bed results in their breakdown into fluidized bed. The rate of combustion and pro- fine particles that readily entrain in the high- duction of heat in the bed is rapidly trans- velocity flue gases. Attention is focused on the ferred to and through the tubes to produce effectiveness of cyclones, electrostatic precip- steam whiIe the bed is maintained at a con- itation, and fabric fiIters for particulate remov- stant temperature. As bed temperatures must al. The ash entrained in the flue gases may be remain in a narrow range during operation, low high in unburned carbon. The disposal of such load is difficult. Consequently, the first com- material wouId result in lower combustion effi- mercial units are expected to consist of a series ciency and perhaps disposal problems. To pre- of relatively small cells, only some of which vent this loss of potential fuel, atmospheric would operate during periods of low load. FBC units may employ a carbon burnup cell. By passing the entrained particles through this The advantages visualized for FBC include: cell, which operates at a higher temperature ● the flexibility to burn a wide range of rank and with greater excess air than the primary and quality of coaIs, FBC cells, the residual carbon is consumed. Considerable concern regarding corrosion and ● a higher heat transfer rate than in conven- erosion of the submerged tubes also exists. tional boilers, which reduces the requirements for boiler tube surface and furnace R&D work is being conducted with atmos- size and also lowers capital costs, pheric FBC in the United States and abroad. In ● an increased energy conversion efficiency the United States a 30-MW atmospheric FBC through the ability to operate without the pilot plant began operations in 1976 at a utility power requirements needed for a scrub- site in West Virginia. Atmospheric FBC is also ber, about to be demonstrated for the production of process heat and steam in a number of in- ● reduced emissions of SO and NO , X X dustrial configurations. ● a solid waste more readily amenable and acceptable to disposal than that from a In the pressurized variation of FBC, the com- wet-scrubber applied to conventional bustion occurs in conditions similar to those in boilers, and the atmospheric version except that the furnace is maintained at 4 to 16 atmospheres of ● the potential for operation at an elevated pressure, The elevated pressure compresses pressure sufficient to use with a combined the flue gases, resulting in a dramatic reduc- gas-turbine/steam-turbine cycle for gener- tion of furnace size from that of a comparably ating electricity at higher efficiency. rated atmospheric FBC. Although the develop- FBC may make particular sense for small comment of pressurized FBC is less advanced than mercial and industrial facilities if emission that of atmospheric, it has a number of poten- standards for smaller sources are relatively tial advantages: the efficiency of combustion stringent. and the capture of S0x are higher; less absorbent (limestone or dolomite) is required for the The fluidized bed can be adapted to a vari- same sulfur capture; the furnace is smaller for ety of modes to produce heat and power. Two the same coal throughput, and NOX emissions variations are prominent— atmospheric and are expected to be lower. Its primary advan- pressurized operation. The atmospheric FBC tage, however, is in the potential for improved can be used for generating electricity or for plant efficiency by means of combined-cycle process or space heating. The pressurized FBC operation. With no major advances in gas tur- is slated for use with a combined cycle system bine technology, an increase in efficiency of 5 of gas and steam turbines. percent is possible for power generation. 104 ● The Direct Use of Coa/

With the integration of the pressurized FBC tures in the combustor, most of the constitu- with combined-cycle operation, the problem ents in ash are vaporized. As the gas cools in of particulate removal becomes critical, as the passing through the system, the ash condenses. hot pressurized flue gases are expanded The electrodes and the walls of the MHD chan- through a gas turbine to recover a portion of nel must be cooled, thus coal-ash slag can ac- their energy. The solids suspended in the flue cumulate on those surfaces, even at the near- gases are particularly corrosive and erosive of sonic velocity of the gas stream. This slag layer gas turbine blades. More efficient particulate affects the way electrical current flows removal systems capable of operating at high through the gas stream from one electrode to temperatures need to be demonstrated to over- the other, hence the characteristics of the coal come this obstacle to higher efficiency by the ash are important. 32 pressurized FBC system. It is unlikely that MHD will be widely used Development of combined-cycle FBC sys- in this century, for the remaining technological tems is underway. A 13-MW combined-cycle problems are formidable. Progress is being pilot plant is being built to begin operation in made, however, and MHD could become an 1980 at Woodridge, N.J. The International important adjunct to new coal-fired power sta- Energy Agency (1EA) is constructing a test facil- tions. ity at Grimethorpe with joint participation of the United Kingdom, the Federal Republic of Fuel Cells Germany, and the United States. Initial operations are expected in early 1979. The program In principle, a fuel cell consists of two elec- is expected to span 7 years including construc- trodes immersed in a conducting electrolyte. tion, and commercial utility application is not One electrode, the anode, is flooded with hy- anticipated until about 1995. drogen, which reacts with ions in the elec- Although the fluidized-bed principle has trolyte, typically a solution of potassium hy- many attractive advantages, it is still an imma- droxide, to release electrons. These electrons ture technology that must demonstrate a com- flow through an external circuit–the electri- petitive position with the pulverized coal-fired cal load —to the cathode, flooded with oxy- boiler. The fluidized bed may require addition- gen, where the electrons react with the elec- al process steps and have new problems not trolyte to form the ions that can react with common with today’s conventional utility boil- hydrogen. Hence the fuel cell is simply a bat- ers. tery, consuming chemical reactants and producing electricity. Unlike ordinary primary batteries, however, fuel cells continue to pro- Magnetohydrodynamics (MHD) duce electrical energy as long as hydrogen and oxygen are supplied to their electrodes. The interest in MHD stems mainly from high The voltage of a single fuel cell is low, expected thermal efficiency for an entire sys- typically 0.8 V under load, but the power out- tem including a conventional steam cycle. In 2 put can be high, as much as 100 W/ft of elec- MHD generators, a stream of very hot gas trode area. The thermal efficiency of hydrogen (roughly 5,0000 F), flows through a magnetic and oxygen fuel cells is excellent, well over 90 field at high velocity. Because the gas at high percent at room temperature and at low load. temperatures is an electrical conductor, an With some fuels, the thermal efficiency is electrical current is produced through elec- greater than 100 percent, showing that a fuel trodes mounted in the sides of the gas duct. A cell can produce additional electrical energy natural gas-fired MHD generator has been from the heat absorbed from its surroundings. tested in the U. S. S. R., and coal-fired systems Efficiency of power production remains high are still under development.

Coal-fired MHD poses special problems be- ‘z’’ In-Channel Observations on Coal Slag,” EPRI Con- cause of the ash in coal. At the high tempera- tract 468-1 (Stanford University, 1976). Ch. ///—Coa/ Technology and Techniques . 105 for widely varying loads, which is a very desir- Another advantage of fuel cells is that, able characteristic above some moderate size, unit costs remain about the same as the size of the installation changes. This means that fuel cell “substa- Although hydrogen is ideal for fuel cells, tions” serving a small group of consumers, say carbon-based fuels, such as distillate and natu- 50 to 100 residences, or a typical industrial ral gas, as welI as producer gas from coal, or plant, could substitute for central-station pow- other fuel gases containing carbon and hydro- erplants and their extensive electrical distribu- gen, are more readily attainable. I n such sys- tion networks. The fuel cell substations would tems, an alkaline electrolyte, as in hydrogen get their energy as hydrogen, pipelined from a fuel cells, is not suitable, and a CO2-rejecting coal gasification plant located in a remote electrolyte is needed. Phosphoric acid has area. The fuel-cell electrical-generating plant been used as an electrolyte in fuel cells at would emit no pollutants, probably could be about 4000 F, but a mixture of molten car- operated with no direct supervision, and might bonate salts, at temperatures up to about also serve its nearby customers with hot water 1,4000 F, allows the direct electrochemical ox- from its waste-heat recovery system. A poten- idation even of natural gas; tial problem is the necessity to supply extreme Iy clean fuel. The technology does not now ex- Fuel cells can serve in a reverse fashion as an ist to economically clean low-Btu gas from eiectrolyzer to produce hydrogen from off- coal to sufficient purity. Hydrogen would be peak power, to store the hydrogen until a peak easier to use. The problems now are mainly of demand develops, and then to convert that hy- an engineering nature, utilizing available data drogen back into electricity, A shortcoming is on fuel cells to design, construct, and operate that fuel cells produce DC, not AC, requiring a fuel-cell installation able to hold its own an inverter to match 60-cycle powerlines. That economically and reliably with other energy- technology exists today. conversion systems based on coal. Chapter IV FACTORS AFFECTING COAL PRODUCTION AND USE Chapter IV.— FACTORS AFFECTING COAL PRODUCTION AND USE

TABLES

13.

14.

15.

16.

17.

18.

19. 20. 21.

FIGURES

14.

15.

16. 17.

18.

Sulfur Dioxide...... 163 Chapter IV FACTORS AFFECTING COAL PRODUCTION AND USE

Chapter I I shows a range of projections for coal use. Actual growth will depend on the decisions of users and producers. The major factors affecting these decisions are the cost, convenience, and availability of coaI relative to competing fuels.

Unlike oil and gas, coal will not be subject to absolute resource constraints or the resulting scarcity-induced price increases over the next few decades. But the availability of coaI depends on much more than its presence in the ground. The legal right to mine a specific reserve must be established through ownership or leasing arrangements, A mining company must decide whether it can sell its product profitably for the life of the mine. A number of studies and extensive planning must be carried out, and a host of permits secured to comply with various reguIatory processes. Arrangements must be made for adequate capital, equipment, and labor. Once mining starts, recent laws and reguIations (e. g., the Surface Mine Con- trol and Reclamation Act (SMCRA) and the Coal Mine Health and Safety Act (CM HSA)) affect methods and costs. Labor-managernent conflicts can Iimit coal availability and color customers’ perceptions of future reliability. Transportation of coal is a problem in the East and will demand attention in the West,

On the demand side, the Clean Air Act makes coal combustion more complicated and costly and presents new problems of waste disposa1. SmaIIer users may have difficuIty i n physicalIy accommodating the necessary equipment or obtaining regular coal supplies, Con- verting current oi1- and gas-f i red equipment to coal wiII be especialIy difficult. Public opposition to particular sites for surface mines or coal-burning facilities may cause substantial delays or force expensive plant modifications. Other regulatory requirements do not impose constraints on local combustion as severe as those of the Clean Air Act, but their cumuIative impact will also make combustion more complicated and costly.

The factors Iisted above increase either the cost or the difficulty of producing and using coal. (The environmental, health, and social benefits from these restrictions are discussed in chapters V and VI. ) But powerful incentives are at work, on the other hand, for users to turn to coal. Given favorable market conditions, many of the potential constraints on coal may never materialize. Others, such as Government regulation, are not directly subject to market pressures and may slow the growth in coal demand, especialIy in very high-growth scenarios. This chapter analyzes the factors that affect the components of the coal system outlined in chapter I I I Analysis provides a framework for policy discussion of the problems of increasing coal output and consumption and for determining the effect on coal development of measures designed to ameliorate its negative impacts.

COAL AVAILABILITY

Coal is plentiful enough on a national basis reserves are owned by the Federal Government to meet even rapidly growing demand. As de- and can be mined only under Federal lease. scribed in chapter 11, a massive increase of Much of the remaining Western coal is owned Western coal production is underway because by States or Indian tribes. As more than half of of its low production cost and low-sulfur char- all domestic coal reserves are found in the acteristic. Unlike Eastern reserves, however, West, Federal leasing policy is an important which are almost all privately owned and more factor in determining long-run coal availabili- accessible, about 65 percent of all Western ty. Federal leasing law is analyzed in chapter 109 110 The Direct Use of Coa/

VI 1. This section discusses the eftect of current percent of Western coal production in 1977. leasing policy on Western coal production. Coal production on Indian lands doubled between 1973 and 1977 to almost 23 miiIion tons. The Interior Department’s Bureau of Land Management (BLM)–the agency responsible Because coal Ieases are often not contig- for administering Federal leases–reports that uous, some operators have found it difficult to about 5 percent of federalIy owned coal re- assemble the 20 to 30 years’ worth of reserves sources has been competitively leased. This needed for a mine large enough to be econom- now represents 17,3 bill ion tons of known coal ical. The moratorium and the NRDC suit have reserves. ’ About 9 billion tons is subject to created uncertainty among operators, who existing applications for preference-right may defer opening a new mine until they can (noncompetitive) leases, obtained when a pros- lease Federal coal adjacent to their current pector demonstrates that commercial quan- holdings. Some operating mines must also tities of coal have been found in an area know soon whether they will be allowed to previously not known to have any. move into adjacent areas or should plan to close down when present leases are exhausted. Since 1971 a Federal leasing moratorium has Regardless of what the Carter administration been imposed and the amount of Ieased re- chooses to do about leasing, prolonged uncer- serves has remained relatively constant (only tainty is a constraint on rapid Western coal ex- 30,460 additional acres leased). Short-term (3- pansion. A continuation of the moratorium year) leasing criteria were developed to allow past 1980 will affect coal development if de- current coal producers to obtain mining rights mand approaches current forecasts. In any on adjacent Federal lands, but a successful suit case, if leasing were to be resumed, regional by the National Resources Defense Council environmental impact statements would have (NRDC) resulted in the criteria for short-term to be prepared before mining could begin, a leases being Iimited to those required to main- process that may take more than a year. Addi- tain an existing operation or to meet existing tional delay in the form of court challenges to contracts. The moratorium was imposed be- renewed Ieasing can also be expected. Despite cause most leaseholders were not mining their these constraints, sufficient Western coal has leases. This gave rise to the charge that Federal been leased to meet anticipated increases in coal reserves were being held primarily for demand through the 1980’s. However, current- speculative purposes. I n the mid-1 970’s, coal ly leased reserves would not be adequate to production from leased reserves stepped up support expected coal production levels in the considerably as rising coal prices and increas- 1990’s. The long Ieadtime required to put a ing demand made Western coal economical mine into operation requires a resumption of and attractive. Western coal production has leasing in the early 1980’s to meet these levels. more than tripled since 1971. About 166 milIion tons were mined there in 1977. One re- There is littIe chance that a significant cent study reports that total output from the number of new leases will be offered before 67 active Federal coal leases in 1977 was 52.4 the 1980’s, according to the best available in- mill ion tons, a 241-percent increase since formation. ’ The terms of any future leasing are 1973. ’ Those leases represented about 14 per- unresolved. If leasing is reinstituted, the new cent of the total of all Federal leases. Federal criteria may limit the amount of coal avail- coal lands under lease contributed about 31 able. If the administration chooses to initiate a leasing policy soon, this coal would probably ‘An Analysis of Existing Federal Coa/ Leases be commercially available after 1985. (Washington, D C U.S Department of the Interior, Bureau of Land Management, 1976), p 6 ‘Reserve Data System Report No. 2A (U.S. Department of the Interior, Geological Survey, Dec 31, 1976). ‘James Cannon, Mine Control: Western Coal Leasing “’Completion of Interior’s Coal Leasing Program Tar- and Development (New York, N Y.: CounciI on Economic geted for Mid-1980,” U S Department of the Interior Priorities, 1978), p 7 News Release, Oct. 25, 1977, Ch. IV—Factors Affecting Coal Product/on and Use ● 111

INDUSTRY PROFILE

Coal is mined by companies ranging from panies. Sixteen years ago, all major coal com- major corporations to one-family operations. panies were independent except for those few The future of the coal industry depends in owned by industrials. large part on how these companies react to The terms “commercial” and “captive” changing conditions. This section describes arose in an earlier time when companies could these companies and how they market their be differentiated by their markets and whether coal. The competitive situation in the industry their product competed freely. “Commercial” is examined. FinalIy, the mechanisms for set- is a term that no longer means quite what it did ting prices for coal are analyzed. in the 1930’s and 1940’s. Then, a commercial operator sold to a variety of customers and Ownership and Markets often in several markets. As the utility market ascended after 1950, big operators negotiated The coal industry has evolved from a large long-term contracts with major utilities, a number of small- and medium-sized independ- trend that is stilI increasing. I n 1976, 86 percent ent companies to a smalI number of very large of all coal shipped to utilities was under long- companies (most of whom are subsidiaries) term contract. Sometimes these contracts span and a large number of smalI independents 20 years or more and, in effect, turn “commer- Most major, noncaptive producers are now cial” coal into dedicated or “capt[ve” coal, as owned by energy companies or conglomerates. the coal no longer competes in an open mar- Of the top 15 coal producers in 1977, as shown ket. Such coal is in market competition only in table 13, only two were independent. Five when the buyer is evaluating bids. were captives of steel companies or utiIities, three were subsidiaries of conglomerates, and Most modern coal-supply agreements con- five were owned by integrated energy com- tain price-escalation provisions that allow up-

Table 13.—Top 15 Coal Producers and Parent Companies, 1977

1977 Coal company Tonnage Statusa Controlling company

Peabody Group .,...... 65,425,088 c

47,994,000 e 28,127,161 c 16,749,859 e 14,309,049 i 13,959,000 s 12,600,000 e

11,988,906 u 10,609,970 s 10,298,630 c 10,223,000 u 9,773,700 u 9,720,447 e 8,905,203 I 8,202,640 e

Total ...... 278,886,654 112 ● The Direct Use of Coa/ ward price adjustments to offset the seller’s 1975 to 1985, reaching 145.1 million tons per cost of infIation, overhead, new labor agree- year, about 18.8 percent of the projected 770 ments, and taxes. Some contracts have “mar- mill ion tons of coal to be consumed by the ket reopener” provisions, which allow either electric utilities in 1985.”5 DOE estimated that party to reopen the contract’s negotiated price utilIties control led 11.6 biIIion tons of re- when the market price for substantially similar coverable coal reserves as of December 31, coal sold from relevant market areas rises or 1975. falls. Typically, a coal supply agreement will A utility reaps many advantages from min- contain a force majeure cIause, which excuses ing its own coal, Supply is made more depend- either party from meeting its obligations when able. Protection is gained against noncost- unforeseen or uncontrolIable events — such as related price increases. Tax shelters are avail- labor disputes, equipment breakdowns, faults able, Leverage can be exercised in negotiations in the coal seam, or new laws — frustrate per- with independent coal suppliers, Prices may be formance. Most long-term contracts run full adjusted to achieve the “potential for greater term with various price adjustments along the return on equity than afforded by regulated way. utiIity operations.”6 Coal is also sold in a “spot” market. Unlike term contracts, spot sales are totally the The economic implications of this “vertical creature of short-term, supply and demand integration’ in the coal industry are disputed forces, Most spot-market suppliers are smaller and have not been studied adequately, Util- companies operating small mines, though ities argue that vertical integration allows some big mines sell excess production this them to effect supply reliabiIity and cost con- way. Many spot sellers enter the market when trol — both to the benefit of the consumer, In prices rise. Between 1973 and 1978, the num- return, critics say that utilities sometimes hold ber of mines increased 33 percent from 4,650 back their captive production in order to just- to almost 6,200 as the average price per ton ify rate increases. A second charge is that util- rose 140 percent from $8,53 to $20.50. Spot ities have little incentive to keep down produc- prices rose faster and went higher than con- tion costs in their captive mines as long as they tract coal because of the perceived fuel short- can be passed through to electricity con- age created by the 1973 OPEC embargo and sumers. Consumer advocates say some utilities other factors, Because many long-term con- pay more for their own coal than do utiIities tracts have reopener clauses pegged to spot without captive production, Utility profits are prices, industrywide coal prices can be pushed increased through this inflationary process, it up by very short-term or unique price pressures is said. Further analysis is beyond the scope of in the spot market. Although reopener clauses this report, are supposed to work both ways, recent exper- Horizontal integration, the ownership of ience suggests that contract prices flow up coal companies by companies that produce more readily than down. other forms of energy, has received more at- Captive producers historically were orga- tention than vertical integration. In 1963 Gulf nized as wholly owned subsidiaries of steel- Oil took over Pittsburg & Midway Coal Co., be- maker, auto manufacturers, or utilities to ginning what became substantial energy-com- assure the parent company of a steady supply pany (oil and gas producers) investment in of a certain kind of coal. UsualIy, most cap- coal-producing companies and reserves. The tive-produced coal was (and is) sold to the Congressional Research Service reported that parent company, In 1973, utilities mined about 77 percent of all coal producers mining more 8.9 percent of their total burn; in 1977, 14.5 percent. Many of the giant new strip mines in the West are utility captives. The Federal Power Commission (now absorbed into the De- partment of Energy (DOE)) estimated “captive” (utility) coal production will triple from Ch. /V—Factors Affecting Coal Production and Use 113 than 3 million tons annually were controlled by noncoal companies. 7

Heated debate over the significance of energy-company ownership of coal producers and reserves was sparked by the unprecedented increase in coal prices, which accelerated after the 1973 OPEC oil embargo. Has horizontal integration of energy production affected coal supply, price, profits, investment, competitiveness, and markets? Did oil- owned coal suppliers, for example, raise their coal prices after the embargo to keep high- priced oil competitive with coal in the Atlantic coast market? Does oil and gas ownership of coal reserves mean anything for the future? Conclusive answers to such questions cannot be offered because the data are unavailable. Some of the needed information may be considered proprietary by coal subsidiaries and parent corporations. It is often difficult to isolate the variable of oiI/gas ownership as being the only cause of coal production and price patterns, as many other factors are also at work. However, the general scope of horizontal ownership can be sketched,

Coal production by oil and gas company subsidiaries totaled 166.6 million tons in 1976 (table 14), or 25 percent of national production. Of this, about 125 million tons was steam coal, As much as 35 percent of noncaptive steam coal is currently mined by oil- and gas- owned coal producers.

Energy-company production is expected to increase its share of the total in the years ahead. All horizontalIy integrated producers plan to increase production. In addition, a number of other major energy companies, such as Sun Oil Co,, Kerr-McGee, ARCO, Shell Oil Co., Natural Gas Co., and Mobil Oil, a are in the process of opening large surface mines in the West.

Horizontally integrated energy companies account for about 40 percent of all planned 114 ● The Direct Use of Coa/

Table 14.—Oil and Gas Ownership of Coal Producers (In millions of tons produced, 1976) 1976 Coal company Parent company production

Continental Oil 55.9 Standard Oil of Californiaa 23.1 Ashland Oil-Hunt Oil 18.0 Occidental Petroleum 17.6 SOHIO 9.7 Eastern Gas & Fuel 8.0 Gulf Oil 7.9 Houston Natural Gas 5.2 Diamond Shamrock 5.2 MAPCO 3.9 Quaker State 3.6 EXXON 2.8 Panhandle Eastern 2.1 Coastal States 1.0 Belco .9 l.~"". oIl~~h 1""\:1 IVI\,;\..IUIiUlA I VII .5 Tesoro .4 TaSCa .4 International Mining and Petroleum .3 Husky Oil .1

166.6

Total 1976 production 678.7 Energy share 25%

1976 Noncaptive Production 569.7 Energy share 29%

aAMAX Coal is a wholly owned subsidary of AMAX Inc .. 20.6 percent of whose stock is owned by Standard Oil of California. Standard has attempted to extend its control over AMAX Inc .. but has encountered resistance. Spokesman for AMAX coal points out that it is not a subsidary of Standard Oil. TwentY'percent ownership. however, does convey the possibility of considerable influence though not outright control. OTA acknowledges that there IS a good deal of uncertainty and sensitivity regarding the ownership of AMAX Coal, and include it in this table with the above caveat.

SOURCE: Keystone Coai industry Manuai, 1978; Wiiiiam T Siick isenlor vice president 01 EXXON) additionai materiai submitted to the Subcommittee on Antitrust and Monopoly of the Committee on the Judiciary, U.S. Senate, The Energy Industry Competition and Development Act 0/1977, S. 1927, Part 1. 95th Cong., 1st. sess., August 2, 4, p. 251: and National Coal Association, Implications of Investments in the Coal Industry by Firms from Other Energy Industries, September 1977.

Table 15.-New Steam·CoalaCapacity of Horizontally Integrated Energy Companiesb by 1986 (In millions of tons)

State lonnage State Tonnage

Alabama illinois ARCO ...... 2.4 AMAX ...... , ...... , ...... 11.4 Arch Minerals ...... 2.0 Colorado Consol ...... 2.4 Con sol ., ...... 1.0 Monterey (EXXON) ...... 3.6 I=rnniro I=norn\J fl-lnllc;,tnn N~h Ir~1 ~~c;,\ Old Ben ...... , ...... 4.0 _.,',...,.- "'-1'_'!:1] \' IV_V"""" I.",,"UI\AI '-"'''''''''''''' ...... 2.4 Zapata/Getty Oil ...... 2.0 Shell ...... 1.8 Zeigler ...... 5.7

Total ...... 5.4 Total 30.9 Ch. IV—Factors Affecting Coal Production and Use . 115

Table 15.— New Steam-Coal’ Capacity of Horizontally Integrated Energy Companies by 1986 (In millions of tons) (Continued)

State Tonnage State Tonnage

17,6

5.6 2

7.6

45.0 7.2 30.0 24.0 5.0 5.0 30.0 8.0 19,0 14.0 4.0

191.2

335.75

SOURCE 1978 Keystone Coal /ndustry Marrua/ 116 ● The Direct Use of Coa/

acquIsition; Arch Minerals is a case in point. and construct the Trans-Alaska Pipeline, ac The significance of the ownership variable is cording to one analysis. 12 unclear given this mixed record of gain and Recent-entry oil companies - those that loss. I ndependents, steel-owned captives, and have taken over small producers or acquired conglomerate-owned producers also showed large Western reserves - have invested their output declines. AMAX, Arch Minerals, and the own capital in their coal subsidiary. The reason utiiity-owned captives- Pacific Power and is obvious: insufficient coal-generated capital Light, American Electric Power, and Western was available to finance development. How Energy- increased tonnage steadily. No clear lesson can be drawn from these data because ever, consistent or persuasive evidence that oil c.apital is expanding established coal produc ot.her factors - strikes, whether a company tion beyond what might normally be expected mined underground or surface, quality of cannot be found. While the capital expendi :,)UjJt:1r .. ..,.,.,. .. .,;r;~VDIVII, ... t:yUljJlllt:lIl,.,...... ;..,.~,.,. ... f. mainlenance,. f. marr

: 1 Implications of Investment in the Coal Industry by 1977, pp. 348-349. FIrms From Other Energy Industries (National Coal : llmplications of Investments in the Coal Industry by Association, September 1977), p. 19. FIrms from Other Energy Industries, p. 28. Ch, /V—Factors Affecting Coa/ ProductIon and Use . 117

Patterns of reserve ownership may shape the future structure of the coal industry, especially if Federal leasing does not resume soon. Re- serve ownership affects major market factors: supply, price, and the ability of potential coal producers to enter the field, Six of the top ten reserve holders are wholly or partially owned by energy companies: Continental Oil, EXXON, El Paso Natural Gas, Standard Oil of Califor- nia, occidental Petroleum, and Mobil. Energy- company representatives argue that coal reserves are widely dispersed, that the share of total reserves controlled by oil companies is not substantial, 4 that large reserve holdings are necessary for long-range development plans, and, finally, that supply, price, and competition have not been adversely affected by energy-company ownership. As the Federal Government still controls most reserves, industry spokesmen say any potential anticom- petitive situations can be controlled by Federal policy.

The research has not been done that would confirm or deny the actual market implications of coal-reserve control by horizontally integrated energy companies. The major charge against energy companies has been that by speculating and waiting higher coal prices, they did not develop their Western reserves in the late 1960’s and early 1970’s. Had Western coal been readily available in these years, prices might not have increased. It is worth noting that the major purchasers and Ieasers of coal reserves in the last decade have been energy companies. Conglomerates do not have significant holdings. As energy companies add to their reserves, it may be increasingly difficult for new entrants to acquire enough long- term reserves to justify the high start-up costs of mining. Smaller companies may not be able to compete with bigger companies because of their capital constraints.

It is worth noting that the major purchasers and Ieasers of coal reserves in the last decade have been energy companies. Other conglomerates do not have significant holdings. 118 ● The Direct Use of Coal

Kentucky coal does not sell in the Northeast. Further, high-grade metallurgical coals do not generally compete against steam coals. Cap- tive coal, moreover, does not generally compete against noncaptive coal. ” Similarly, 1 977’s 54 million tons of export coal – most of which was metallurgical — does not compete domestically, except when foreign demand slumps. A true assessment of concentration in the coal industry must disaggregate production data and look at concentration in much more precisely defined markets. DOE estimated that the top four noncaptive suppliers will provide about 47 percent of new noncaptive, electric utility supply now under contract in 1985.20 The top eight noncaptive producers will supply about 71 percent of this tonnage. Production from the new key coal States, Wyoming and Montana, will be more concentrated: 70 percent for the top four and 92 percent for the top eight.21 The long-term contracts discussed above also bear on competition. 1 n effect, these contracts reduce both the real amount of coal available in the marketplace and the number (and needs) of customers. The Federal Trade Commission noted: In manufacturing industries, production concentration is also an indicator of the present supply alternatives open to potential buyers, If a firm produces 10,000 units of output per year, it can be assumed that up to 10,000 units are available to any qualified buyer. This is not the case in the coal industry, Due to the prevalence of long-term contracts, the annual production of a coal company may not be a valid measure of the quantity of coal available to potential buyers from that producer. 22 These contracts account for about 86-percent of coal’s utility sales. With some exceptions, once a contract of this sort is concluded Ch. IV—Factors Affecting Coal Product/on and Use ● 119 coal producers, like much of American bus- the Nation’s biggest coal producer and fourth iness, use “outside” boards of directors to largest reserve holder. ) Seven of the 20 capital guide corporate policy. Directors are often suppliers were among the company’s top 20 chosen because their expertise or primary affil- stock holders .29 Continental’s biggest stock- iation will help a company do business prof- holder, Newmont Mining Company (3.29 per- itably. Many mining companies and manufac- cent) is also the principal stockholder in turers include representatives of major finan- Peabody Coal (27.5 percent). Capital suppliers cial institutions on their boards Major stock- with whom Continental shares a director are holders—which may include families, finan- major stockholders in other leading coal pro- cial institutions, and other corporations — are ducers and reserve holders.30 also represented. Direct interlocks — where one It is fair to ask a simple question at this individual serves as a director of at least two point: What do these interlocks mean? The corporations — are common between a coal fairest answer is equally simple: We are not producer and a capital supplier. One coal pro- certain. The research needed to confirm or ducer may be indirectly interlocked with deny the significance of this ownership net- others when a director of each sits on the work has not been done. Although the poten- board of a third corporation. Indirect in- tial for antitrust abuse exists where corpora- terlocks among coal producers, coal con- tions with common interests are interlocked, sumers (utilities and industrials, especially), no coal industry case study has been done to and capital suppliers are common. It is also determine whether this potential for abuse has common to find representatives of major fi- been used. Similarly, the implications of coal’s nancial institutions sitting on the boards of stock holding distribution have not been competing coal producers. studied. Distribution of voting rights differs from corporation to corporation. I n those cases where a single family does not dominate a company, bank trust departments, insurance companies, and mutual funds often own the biggest blocks of stock.2G Where stockownership is dispersed, holdings below 5 percent can constitute corporate control in some intances. If a single company — a bank, for example— owns substantial voting rights in several coal producers, some analysts argue that the potential for anti- competitive behavior is present.

Consolidation Coal –the Nation’s second largest coal producer– is fairly typical of the ownership patterns among energy-owned coal producers Consol is a subsidiary of Continen- tal Oil. Continental’s board was tied to 12 coal- reserve holders or coal producers, 9 coal consumers, and 20 capital suppliers through at least one indirect director interlock as of 1976.28 Continental shared a director with Bankers Trust of New York, Continental Il- Iinois, and Equitable Life Assurance, (Equi- table is a major stockholder in Peabody Coal, ——.

120 ● The Direct Use of Coa/

resources necessary to meet production goals. dented level of profitability in the mid-197C)’s However, if the realized rate of return does not was due less to rising production than to the meet investor expectations, capital is likely to’ price increases that followed the OPEC em- flow into noncoal investments. Energy com- bargo and to a temporary surge in worldwide panies and conglomerates can choose between demand for met coal. alternative investments whereas a nondiversi- fied coal company cannot. It is possible that A precise picture of the financial status of leading coal producers might attempt to en- the industry is difficult to develop because courage price increases and maximize their much of the necessary data has not been avail- rates of return by regulating supply. Deregula- able to the public. Parent companies have not tion of—and higher prices for—oil and gas been required to separate financial data for should lead to higher coal prices, although the their coal subsidiaries in their reports to the increases may not be identically proportional. Securities and Exchange Commission, A check Higher prices should encourage coal invest- of the financial data for the Pittston Corp. ment and enable operators to spend more on (primarily a West Virginia-based metallurgical health and safety, environmental protection, coal producer) and North American Coal (an and community improvement. eastern producer of met and steam coals) adds case-study data to the gross statistics noted The interaction among price, production above (see table 17). Despite declining produc- costs, profit, and capital investment is central tivity and slipping production, both companies to expanding coal supply. The relationship recorded increased net income after 1973. Net among these factors changed dramatically in income per employee increased in both cases, the 1970’s. All rose substantially over pre1970 suggesting that income productivity and labor levels, but production did not rise propor- productivity do not necessarily coincide. Be- tionately and productivity fell. The price per tween 1970 and 1977, Pittston’s net income per ton quadrupled between 1968 and 1975 while employee rose 252 percent and North Amer- labor costs doubled in that period. ” The unit ican’s gained 73 percent (current dollars). Con- labor cost share dropped from 58.5 percent in solidation Coal, the second biggest coal pro- 1950 to 20,3 percent of per ton value in 1974. It ducer and a subsidiary of Continental Oil, probably amounts to 25 to 30 percent of value showed coal revenues being five times greater today due to increases in wages and benefits in 1977 than in 1970, although revenues for

and the leveling off of the coal price rise. Ris- 1975 through 1977 were relatively un- ing prices helped boost industry profits. Coal’s changed. 35 return on net worth exceeded 11 percent only once in the 1950-73 period, but it approached Return on investment and profits slacked in 30 percent in 1974 following the OPEC embar- 1978 because of the coal strike and demand go. ” From 1971 through 1974, net coal income softness for certain coals. For most companies, of 24 leading coal producers rose 298 percent this should prove to be a temporary phenome- from $128.4 million to $639.5 million, most of non. which came in 1973-74. Coal’s unprece- Ch. 1 V— Factors Affecting Coal Production and Use “ 121

Table 17.—North American Coai and Pittston Corporations Profitability and Productivity

1970 1971 1972 1973 1974 1975 1976

LABOR PROFILE 122 The Direct Use of Coal never do. Many are highly skilled; others underground mines. The perspective of all aren’t. Their work environments range from UMWA presidents has been that of the deep air-conditioned, bucket-seated dragline cabs miner. This experience has shaped coal’s col- to 20-inch coal seams where the machine oper- Iective bargaining from the beginning. ator lies nearly on his back most of the day. Important differences are found between Most coal labor– about 160,000 persons— be- the two groups. Accident frequency, for exam- long to the United Mine Workers of America ple, is significantly lower for surface miners, (UMWA), which sets many of the wage and although some kinds of surface mines are less benefit standards for the entire industry. Sev- safe than some deep mines. Surface miners are eral thousand belong to the Progressive Mine generally older, work more days annually, Workers (PMW), Southern Labor Union (SLU), strike less, and are paid more than their under- Operating Engineers, and other unions. More ground counterparts. The average age of most than 40,000 probably belong to no union at all, UMWA deep miners was 35 in 1976 compared either from choice or lack of opportunity. with 41 for most UMWA surface miners. 37 I n

Photo credit: Douglas Yarrow Last shift comes out at Eccles #5 before the 1977 contract strike Ch /V—Factors Affecting Coal ProductIon and Use ● 123

“Jean M Brett and Stephen B Goldberg, Wildcat Strikes In the Bituminous Coal Mining /ndustry A Pre/im- inarv Report (Northwestern U nlverslty, 1978), p 23 “Data suppl led by BCOA 40 Don R Richardson Associates, A Survey of W’est V{rginla Coal Miners, 1977, p 26 “OTA made these estimates based on data supplied by BCOA and MSHA 124 The Direct Use of Coal

Figure 14.— Distribution of Employees by Annual Earnings at Deep and Surface Mines

Number of employees 35,000

30,000

25,000

20,000

15,000

10,000

Earnings

Deep Mines

1976

1975

Surface Mines

● ● ● ● ● ● 1976

— 1975

SOURCE Income data supplled by the Bltumlnous Coal Operators’ Assoclatlon, 1978 Ch. I V— Factors Affecting Coal ProductIon and Use 125

Figure 15. —Distribution of UMWA Employees by Age—All Mines’ 1974-76

Number of employees 25,000

20.000

15,000

10,000

5,000

0 Age

few cases of moving eastern miners and mine Non-UMWA miners are located principally management to the West have not been very in southern Appalachia (southwest Virginia, successfuI. east Kentucky, and east Tennessee) and west of the Mississippi Few demographic or attitu- The fourth and perhaps most significant dis- dinal data exist about them. Often they make tinction is unionization Those who have not as much money as — or more than — UMWA spent time in the UMWA coal fields have a miners. This relatively recent phenomenon was hard time understanding the intensity of the made possible by the higher profitability of miners’ feeling for UMWA. Whether they are mining after the OPEC embargo. Most non- disgusted or delighted with its performance, UMWA mines are relatively new, They do not they tee] it is theirs, built by them to serve their carry pension obligations to older miners and interests As harsh as its internal critics are, retirees that UMWA-organized companies most believe that unionization is the only carry Few of their workers have even retired, thing standing between them and the coal and many of the smalIer, non-organized com- company. ” panies have small pension obligations, if any. 126 The Direct Use of Coa/

In big, non-UMWA mines health insurance the coal industry over the last decade. In these plans and other benefits are comparable to years, surface production moved ahead of un- UMWA standards. In a few western surface derground production. The locus of national mines, the benefits are more comprehensive, coal output moved westward, Oil companies What many nonunion miners lack contractual- took over major coal producers, and most of ly are job protections, a grievance procedure, their effort centered on developing western and some safety rights (including the right to surface mines. The proportion of coal workers elect a safety committee and the right of the who are UMWA members dropped from be- individual to withdraw from danger). Non- tween 75 to 80 percent in the late 1960’s to UMWA miners also lack a national voice. The around 65 to 70 percent today .44 UMWA ton- UMWA, whatever its tailings, speaks for the nage, however, has fallen to about 50 percent Nation’s coal miners in Washington, D. C., Non- of the total production owing to the increase UMWA miners are not represented, although in nonunion, surface-mined coal. they benefit from legislation or regulatory in- Still, the heart of the coal industry is in the itiatives UMWA is able to push through. East. And it is there that one must go to explain The extent of unionization varies in the labor-management instability and the atti- West. The majority of mines in the Carbon and tudes that cause it. The 1960’s allowed man- Emery Counties area of Utah is organized by agement to become complacent about its UMWA. On the other hand, only the captive labor needs. Mechanization and layoffs meant Wyodak Mine associated with the Wyodak a large pool of experienced miners. Wildcat Power Plant in Campbell County, Wyo., is strikes were infrequent because of the labor organized (International Brotherhood of Elec- surplus and organizational policy. Coal pro- trical Workers (1BEW)). North Dakota mines ducers had few incentives to provide better are organized by several unions. Consolidation working conditions. Their ranks were not hos- Coal and North American Coal have UMWA pitable to policy innovators. An illusion set in contracts. Mines of the Knife River Coal Min- that all was well. It deprived management and ing Company are organized by the PMW. The labor of a vital spirit that both need for con- Operating Engineers, the predominant union in tinued health. Industry found that its lower Colorado, does not represent mines in North management consisted of men too old, too Dakota. The captive Baukol-Noonan Mine is timid, or simply too set in their ways to be- organized by the IBEW. The UMWA is a major come good leaders. But as long as coal de- force in parts of the West. It is the dominant mand stagnated and prices were more or less union i n Utah underground mines. I t repre- constant, the industry’s stabiIity was not upset. sents mines on the Navajo Reservation. It has lost some of its power to other unions. Only 2,000 to 3,000 surface miners are UMWA- organized in the West. Most Western States have right-to-work laws that limit unionization.

These demographic and social indicators reflect major structural changes that occurred in Ch. III--Facfors Affecting Coa/ Production and Use . 127

COLLECTIVE BARGAINING: A STORMY HISTORY

Labor relations in the U.S coal industry have Iated to the cost-cutting pressures of competi- been characterized by suspicion, acrimony, tion amid demand stagnation. Periodically, violence, and, occasional I y, cooperation. coal strikes erupted and dragged on for Throughout this century the unwillingness of months or even years. Strikes of national con- miners to accept the conditions of their work sequence occurred in 1902, the early 1920’s, has led to chronic unauthorized work stop- the late-l 940’s, and the mid-1 970’s. Often they pages, turmoil, and prolonged contract strikes. occurred when demand was strong. When de- The number, duration, and cost of wildcat mand surged and high prices encouraged strikes have increased since 1970.45 The ab- marginal operators to begin mining, the mar- sence of equitable and stable labor-manage- ket was quickly oversupplied and a slump soon ment relationships has hampered coal produc- followed Miners felt it opportune to press tion and supply reliabillty. Coal miners’ in- their demands during these booms, and when come, benefits, and health care systems, have demand slacked, they struck to maintain their been cut back. On the other hand, many min- gains. Understanding the boom-bust cycle as ers say wiIdcat strikes are often the only way to they did, operators resisted labor’s demands force an employer to deal quickly– and pre- during both the short booms and the long sumably favorably— with one of the miners’ busts. concerns. The roots of today’s conflict Iie deep Apart from market factors, a second source in the past. But it is simplistic to believe that of labor-management strife originates from the current practices do not contribute. Many of attitudes and conditions resulting from the the sources of discontent are deeply em- nature of the mine workplace and the work bedded in coal economics and management process, The work environment of under- policies These may not change easily. Finally, ground coal mining is unique. Danger is inher- even though U.S. energy policy counts heavily ent, although control I able. Work has been on coal, the advisabiIity of Federal interven- made easier by mechanization, but the work- tion in the industry’s labor-management rela- place has not been made more pleasant. tions is not clear Modern coal miners end their shifts wet, dirty, often chilled, with mine dust embedded in Collective bargaining and labor relations every pore. Often they work on their knees; generally have been shaped by the economics standing or kneeling in cold, oily water for and structure of the industry. How miners were hours at a time; listening to the “working” of treated by operators was often determined by the mountain above them. A roof that looks how operators treated each other and how safe may double-cross them in a second. Wari- coal was treated in the marketplace. Free en- ness and caution are essential. terprise has never produced stable labor relations in coal. Competition, rather than Unlike assembly-line work, mining requires st rengthening industry stability, tended to workers — as individuals and as part of an in- destroy it. Chronic labor unrest has been re- terdependent team — to control much of their own work. Miners must constantly adapt their work to ever-changing environmental conditions. The mining process requires a good deal of individual judgment and peer-coordination. The pace of work is determined to a great extent by the miner’s minute-by-minute evacua- tion of physical conditions and machinery. Be- cause so much of mining is a matter of judgment, miners and section supervisors often disagree. Disputes stem from the pace of work; who is to do what; what needs — or doesn’t 128 ● The Direct Use of Coa/

need —to be done; what precautions must be of the workplace. When work conflict arose, it taken; and what kind of work miners can legit- quickly enveloped the camp’s entire social sys- imately be asked to do. Miners and foremen tem. Mining was not only a job, it was a way of develop routines of interaction that are both life for workers and their families. Although adversarial and cooperative. Both take pride in the coal-camp system was dismantled a gen- “running” a lot of coal during their shifts. But eration ago (when mechanization cut employ- this shared goal is often subverted when man- ment and spendable income to the bone, thus agement asserts authority in ways that miners making the closed system unprofitable), many perceive to be arbitrary or as violating their job of the facilities are used today, and the rights. UMWA miners have developed elabo- psychology of the system remains. rate work rules and codifications of their rights Finally, industrial conflict plagues coal to protect themselves from perceived manage- because of the past. Coal camps were ex- ment transgressions. If one of the commonly periential hothouses; each perceived wrong, understood rules is breached, miners close each dispute became part of the community’s ranks and resist. history. The bitterness could never dissipate. Workplace-generated attitudes lend them- Children of miners absorbed — and continue to selves to constant confrontations. First, miners absorb — the attitudes of their parents. There is are proud of doing useful and dangerous work. no quick remedy for this historical sensitivity; Pride is Iinked to self-confidence; both are it must be accepted. combined with a certain trucuIence against be- The history that follows is necessary to un- ing told how to do their work. Second, the derstand present day labor-management rela- danger of the workplace readies miners for tur- tionships and how they will or will not be af- bulent conflict outside of it. Third, the work fected by Federal policy. process trains miners to work collectively. This interdependence carries over to conflicts with management. A wrong done to one miner is in- The Early History terpreted as a threat to all. Shared dangers and interdependent work produce group cohesion Unlike other basic industrial activities, coal when the group is faced with a common threat. production did not grow steadily over the first It creates a “them and us” attitude. It enables 70 years of this century. The industry’s capaci- miners to stick together through prolonged ty to produce did not change significantly strikes. after 1918. As recently as 1974, the operators produced only slightly more than they had in The social environment of the coalfields is a 1918 and less than in 1947. Demand stagnation third factor contributing to the volatility of forced the industry to be acutely cost-con- labor-management relations. The basic form of scious. This often translated into protracted social organization in coal’s early years was opposition to unionization and continued the company town. In these communities, pressure to reduce labor costs. Both policies mine operators owned or controlled every- occasioned many strikes and much bitterness thing— housing, medical care, schools, the in the 1920’s and 1930’s. A high level of market law, churches, and commerce. Until the 1930’s competition among hundreds of suppliers in- and 1940’s, miners were often forced as a con- tensified the cost-cutting pressures within the dition of their employment to accept wages in industry. Because demand fluctuated but did scrip instead of U.S. currency and to buy only not grow, operators were less concerned about at the company store. The miner’s perception mining more coal and more concerned about of work victimization was compounded by this continued lowering of their labor costs to same perception in a company-controlled maintain competitiveness. The implications community. The work routine regulated coal- for harmonious labor relations are apparent. camp existence. Mine operators established the quality of community life. Social equality Coal’s industrial relations changed in the among mining families reflected the equality 1930’s and 1%0’s, until that period, the majori- , Ch. /V—Factors Affecting Coa/ ProductIon and Use 129

limited situation in 1949-50 threatened both sides with a devastating circle of oversupply, wage cuts, and layoffs — the very pattern that had brought them close to ruin 20 years before. The self-interest of each led to considering ways of saving the other,

Cooperation: 1950-72

Operators’ Association

established unquestioned by this time. His political expelled or neutralized in and file had lost its right to ratify contracts. The union’s internal organization was under Lewis’ persona I direction. Lewis and Love recognized that the demand- 130 ● The Direct Use of Coa/

other, he hoped that BCOA members could vantages of the machine and the improved 48 sew up the blossoming utility market, the key techniques. to coal’s future. Both objectives depended on the ability of BCOA companies to increase Mechanization was so I inked in Lewis’ thinking productivity and cut labor costs to maintain to higher wages and benefits that he simply their competitiveness with oil and gas and shrugged off unemployment and other social eliminate low-priced coal suppliers. costs as the price of industrial rationalization. With the UMWA supporting mechanization, Love and Lewis saw mechanization as the big BCOA operators were able to cut their la- way to increase productivity and reduce labor bor costs, secure long-term contracts, and costs. I n underground mining, mechanization maintain their profitability. Much of the new meant eliminating hand loading. Machines machinery was financed by using the contracts could produce three times as much coal with themselves as collateral, UMWA also loaned 10 workers as 86 workers in a hand loading sec- money directly to a number of companies to tion. Mechanization also meant more surface finance capital investment. mining, which was more efficient than even underground centinuous miners. Surface- UMWA itself began reevaluating Lewis’ mined production increased from 24 percent policy on mechanization in 1973: of total output in 1950 to about 60 percent in A question which has persisted throughout 1977. Industrywide productivity almost tripled UMWA history is how closely related are the between 1950 and 1969. However, coal-mine welfare of the miner and of the coal industry. employment fell 70 percent between 1950 and The coal operators have always argued that 1969, from 415,482 to 124,532. what’s good for Consolidation Coal Co. is good for every mine worker, and that miners should therefore refrain from asking for too big a The crucial factor in mechanizing coal was John L. Lewis. If he had chosen to delay it, the share of the profits, During most of his career, John L. Lewis knew better. When he argued for industry would have suffered. But Lewis cham- creation of the Welfare Fund, when he argued pioned mechanization, and had done so at for better safety laws, when he argued for least since the 1925 publication of his only price controls during wartime wage controls, book, where he wrote: he repeated his confidence that the coal in- The policy of the United Mine Workers of dustry had the wealth to meet the human America will inevitably bring about the utmost needs of those who supported it, employment of machinery of which coal But in the 1950’s he went against that long- mining is physically capable. time judgment. Faced with mechanization of the mines, Lewis, in his own words, ‘decided Fair wages and American standards of Iiving it’s better to have a half a million men working are inextricably bound up with the progressive in the industry at good wages, high standards substitutions of mechanical for human power. of Iiving, than it is to have a mill ion men work- It is no accident that fair wages and machinery ing in the industry in poverty and degradation, ’ will walk hand in hand.47 It was a firm decision, and mechanization Lewis reiterated his views on mechanization with its drastic reduction of the work force in the early 1950’s: was carried out. Unfortunately, no provision was made for the hundreds of thousands of We decided that question [the UMWA’S men who were put out of work. There were no position on mechanization] long years ago benefits, no retraining programs, no new indus- . . in return for encouraging modernization, try brought in. A great many miners were the utilization of machinery and power in the forced to take their families to northern cities mines and modern techniques, the union . . . insists on a clear participation in the ad-

“Justin McCarthy, A Brief History of the United Mine “John Lewis, The Miners’ Fight for American Standards, Workers of America (Washington, DC. United Mine (Indianapolis, Ind,. Bell Publishing Co., 1925) pp 108-109, Workers of America, 1952), pp. 7-8. Ch. IV—Factors Affecting Coal Production and Use • 131

like Detroit and Chicago, where most did not needs, but that risked increasing the pressure fit in and did not want to.49 on BCOA members who were being battered Lewis exacted a price from BCOA for sup- by low prices and demand stagnation porting mechanization. Hourly wages were UMWA finally raised such criticisms of the increased — a I be it modestly–for working Fund in 1973: miners in each round of bargaining after 1950, The major concession Lewis received was the The history of the [bituminous] Funds since Many per- establishment of the UMWA Welfare and Re- their early days is a mixed one. sons have been paid, but many men were cut tirement Fund, which provided pensions and out by arbitrary and unfair rules while the hard near-comprehensive, first-dolIar medical cov- coal [anthracite] pension dropped to $30 per erage for UMWA members and their families. month. Medical services were provided for The Fund was started in 1946, when Lewis per- miners and their families, but were taken away suaded Interior Secretary JuIius Krug (who was from disabled miners and widows. For almost administering the Nation’s mines after they 20 years the royalty stayed at 40 cents, while had been seized) of its merit. A modest ton- up to $90 million of the soft coal Fund’s nage royalty was levied, But the operators money was kept in non-interest-bearing check- fought the plan and its funding formula for the ing accounts at the union-owned National next 5 years. Love committed the big operators Bank of Washington .’” to support the Fund in 1950, A tonnage royalty The scope of the Fund’s work grew increasingly was fixed, and it did not rise between 1952 and constricted over the years. Under the 1978 con- 1971. Although the Fund was supposed to be tract, medical insurance for working miners distinct from UMWA, Love gave Lewis de facto was switched to private carriers, leaving the control of the three-person board of trustees Fund to administer health benefits and pen- when he accepted Josephine Roche, a long- sions only for retired miners. time Lewis confidante, to serve as the neutral As labor costs were lowered in the 1950’s trustee. The Fund did much good work in coal- and 1960’s, the industry also externalized pro- field health care in the 1950’s and 1960’s. duction costs. Social costs and externalized Clinics were organized. A chain of hospitals costs were rarely assessed in these years. Rec- was built. Preventive services were en- lamation standards for surface mines, for ex- couraged. Controls over cost and quality of ample, were not enacted until the late-1960’s. health services were established. But the finan- Dust controls were not required in under- cial resources of the Fund were always dependent on the level of production of the BCOA ground mines until 1970, when coal workers’ companies that paid the royalties. When de- pneumonconiosis (CWP) was recognized as a mand fell in the late 1950’s and early 1960’s, disabling occupational disease by Federal legislation. Federal safety standards were the Fund — living on an unchanged tonnage royalty —was caught short. It had to sell its minimal. Industry was not expected to bear the hospitals and withdraw medical benefits from public costs of the unemployment produced by mechanization. Systematic air pollution thousands of miners who had been “mech - controls had yet to be enacted; coal suppliers anized ” out of their jobs. When the Fund’s records began to show startling increases in sold relatively “dirty” coal to utilities. Finally, coal field communities generally imposed respiratory disease among its beneficiaries in small tax burdens on local mine operators and the 1960’s, Roche and Boyle refused to de- coal-reserve owners, fearing that even the mand dust controls or an industrywide dust standard. Lewis and Boyle might have nego- slightest additional economic pressure would make local employers uncompetitive. When tiated a higher tonnage payment to cover Fund demand picked up in the late 1960’s and early 1970’s, the industry was coincidentally ex- 49 The Year of the Rank and File: Officers’ Report to the pected to begin paying many of these social United Mine Workers of America 46th Constitutional costs through compliance with environmental Convention, United Mine Workers of America, 1973, p, 68 50 The Year of the Rank and File, p. 67. 132 • The Direct Use of Coal

regulations and health and safety standards. antitrust suits against UMWA and BCOA in the The deficit of community services that had ac- 1960’s. Two succeeded in winning conspiracy cumulated during the depressed 1950’s and verdicts. I n Tennessee Consolidated Coal Com- 1960’s handicapped fast growth in the 1970’s, pany, the Supreme Court said the “union and when coal towns struggled to meet the needs large coal operators, through their National of hundreds of new miners. Wage Agreement and its Protective Wage Clause, conspired in violation of the Sherman The Love-Lewis contract of 1950 sought not Antitrust Act to drive small operators out of only to stabilize labor but to impose order on business.”52 Two months later, the Court af- coal suppliers. Surplus miners increased costs firmed a $7.2 million triple damages judgment of production while surplus operators drove awarded to South-East Coal Company against down prices. Both were seen as problems to be UMWA and Consol. The Court agreed with solved. Lewis shared the BCOA’S attitude South-East Coal that the two had engaged in a toward the marginal independent suppliers, of “conspiracy . . designed to force South-East whom he said in 1950: and other small coal producers in eastern Ken- The smaller coal operators are just a drag on tucky out of the bituminous coal business.”53 the industry The constant tendency in this South-East’s brief charged that the BCOA “was country is going to be for the concentration of formed specifically to eliminate smaller production into fewer and fewer units operators.” 54 more obsolete units will fall by the board and 5 go out of production. I The partnership did little to benefit the union’s rank and file. Mechanization threw Lewis used UMWA resources to further the several hundred thousand miners out of work competition-limiting ends of his partnership and cut many off from medical and pension with BCOA. His organizing drives in the 1950’s benefits. The annual income of those miners focused on the small companies exclusively. It who continued working in the 1950’s and appears that the real purpose of the union’s 1960’s did not keep pace with workers in com- campaign of dynamite and sabotage was less parable industries such as steel and motor to organize these companies than to eliminate vehicles. Increasing productivity did not lower them. While battling the non-BCOA operators, the frequency of mine fatalities among under- Lewis signed “sweetheart” contracts with a ground and surface miners. Injury frequency number of BCOA members. These secret did not improve between 1950 and 1970. Un- agreements allowed the favored operator to derground mechanization greatly increased pay less than union-scale wages or suspend noise and dust levels. Unregulated dust condi- royalty payments to the UMWA’s Welfare and tions produced black lung disease in thou- Retirement Fund. Coal companies often had sands of miners by the end of the 1960’s. Final- difficulty finding money to finance mech- ly, the partnership seems to have required the anization. Lewis solved this problem for cer- political disenfranchisement of UMWA’s rank tain BCOA companies by lending them $17 and file. The terms and consequences of the million from the UMWA-owned National Bank partnership probably could not have borne the of Washington and the Fund. scrutiny of democratic unionism. The UMWA The small operators fought back against the under Arnold Miller reviewed this touchy sub- UMWA-BCOA squeeze. The 1950 contract es- ject in this manner: tablished a single industrywide wage scale Under W. A.’’ Tony” Boyle, who followed (thus advantaging the most efficient com- John L. Lewis and Thomas Kennedy, the panies), which was an economic handicap to small suppliers. Other contractual provisions devised over the years had the same intent and “Tennessee Consolidated Coal Company, 72 L R R M. effect. Small operators brought a number of 2312,1970 5 JSOU th.Eas t Coa / Company v Conso/ida tion Coal COm- pany, 75 L.R R.M 2336, 1970. “ Lewis quoted In Thomas Bethell, Conspiracy in Coal, “’’UMW and Coal Company Sued, ” Coal Age, June (Huntington, W Va Appalachian Press, 1971), p. 17 1966, 1) 52. Ch. IV—Factors Affecting Coal Production and Use ● 133

UMWA leadership grew more and more out-of- one other thing. It created forces within the touch. Boyle maintained the clamp on dissent workplace and labor force that led eventually and the close coIlaboration with industry of to the dismantling of the alliance itself. The in- the late Lewis years, but in the three contracts stability that has characterized the coal indus- he negotiated he simply could not deliver as try in the 1970’s is part of the process of ending Lewis had done. 5% the Lewis-Love partnership. But the ordinary coal miner had no way of knowing about union loans to operators, sweetheart contracts, and other sleights-of- The Rebellion: 1969-77 hand. He could see that Lewis ran the union The rebellion of UMWA miners over the autocratically, but so great was his trust in terms of the alliance was front-page news in John L. that demands for rank-and-file contract 1969. Beginning with health and safety, the ratification or local election of district officers revolt soon expanded to union reform, Fund never elicited much support. policies and collective bargaining. Two The 1950-70 period is often recalled as an events — the West Virginia black lung strike era of “labor peace” and “labor stability “ (1969) and the 78-victim Farmington mine True, there were no contract strikes against the disaster–propelled coal health nd safety BCOA between 19.50 and 1971 (and compara- problems directly into the public con- tively few wildcat strikes), but the peace ap- sciousness. I n the process, the structure of pears to have benefited BCOA and UMWA at labor-management relations began to be the expense of small operators and many coal u nvei led. miners. For non- BCOA companies, market un- Coal workers’ pneumonoconiosis is a pro- certainties and cost pressures —which elim- gressive, incurable and, in its last stages, fatal inated 4,779 mines between 1950 and 1973 — disease caused by prolonged exposure to coal- and UMWA organizing campaigns, can hardly mine dust. (See chapter Vi. ) Although medical be remembered as a golden age. For many authorities in England had recognized CWP as m i ners, “labor stability” meant unemploy- occupationally related in 1942, most American ment, dust, disease, and fear. doctors refused to agree. The UMWA did not But the UMWA-BCOA partnership did ac- demand or fund extensive research into the complish what it set out to do. Mechanization disease in the 1950’s, even though the new con- and “labor peace” boosted productivity and tinuous miners were increasing dust. The Fund helped BCOA companies to ride out the hard did, however, try— unsuccessfully — to per- times. Competition was stabilized by elim- suade the American medical establishment inating marginal suppliers and through long- that CWP was a distinctive disease of the term contracts. It was also regulated by a trade. Expensive dust-control programs and deliberate, coordinated merger movement that company-paid compensation for respiratory began in 1954 among the major companies. disability would have undercut efforts to lower When the dust settled, each of the biggest production costs. By the late 1960’s, res- companies had combined with another major piratory disease among working and retired producer. With both labor and operators sta- miners was widespread, Slowly, miners began bilized, big producers were able to increase to I ink their disabiIity to the dust they “ate” on profits despite a 20-year price freeze and stag- the job. For years, coalfield doctors had told nant demand. In 1955, for example, Consolida- them that coal dust was not harmful, and some tion Coal and Eastern Associated reported net even said it prevented tuberculosis. West Vir- profits of $12 million and $2 million, respec- ginia was especially ripe for a black lung pro- tively. Profits rose to $20 million and $4 test as 80 percent of its production came from m i I I ion, respective y, in 1960, and to $33 underground mines and almost one-third of million and $8 mill ion in 1965, The alliance did the Nation’s miners worked there.

Compensation legislation was passed there 55 The Year of the Rank and F//e, p 70 in February 1969 after a month-long wildcat 734 ● The Direct Use of Coal

strike that idled 42,000 miners, some of whom later, he, his wife, and daughter were

marched on the West Virginia Capitol carrying assassinated by gunmen hired by Boyle and coffins. The final version did not incorporate paid from union funds. Because of “flagrant many of the innovative provisions of the ori- and gross” violations of Federal law, the 1969 ginal bill, which the Black Lung Association election was overturned by a Federal judge (BLA), an ad hoc group of miners and their and a rerun scheduled for 1972. allies, had supported. During the 1969 Campaign, Federal health The West Virginia protest pointed up and safety legislation was being hammered out UMWA’s apparent lack of concern for occupa- in Congress. A reasonably strong bill emerged tional health. The BLA became one base in the from the year-long debate. It toughened safety political movement by rank-and-file miners standards, gave the Interior Department broad over health and safety conditions, To the BLA regulatory and enforcement powers, set dust were added hundreds of disabled and retired standards, and provided compensation for workers and their widows who objected to re- black lung victims. The UMWA opposed the strictive Fund policies that denied them health strongest legislative measures, as did the and pension benefits. operators. Mine safety was thrust into the national UMWA safety activists and union reformers arena when a Consolidation Coal Co. mine at were bolstered by rank-a rid-fiIe disenchant- Farmington, W. Va., blew up in November ment over the contracts Boyle signed in 1968 1968, killing 78. UMWA president Tony Boyle and 1971. Boyle touted the 1971 agreement as appeared at the mine and said: “As long as we the $50-a-day package. But the $50 came only mine coal, there is always this inherent dan- in the last year of the 3-year agreement and ap- ger but Cononsolidation Coal was one of plied only to a small number of miners, Boyle the best companies to work with as far as had finally broken the 20-year freeze on the cooperation and safety are concerned. ” John $0.40-tonnage royalty (raised to $0.80), but Roberts, Consol’s public relations director, most of the new revenue went to cover the cost of the pension increase he had contrived agreed: “This is something we have to live with. ” during the 1969 campaign. Other benefits changed little. Others did not share their fatalism. The disaster prompted Joseph Yablonski, a UMWA As the dissidents escalated their campaign official, to challenge Boyle for the presidency. against Boyle, some came to understand the Strong mine-safety legislation was introduced prerequisites of labor peace that Lewis had in Congress that addressed the safety and worked out with Love. Some began to see health problems dramatized by Farmington Boyle’s “corruption” more as an exaggerated and the black lung uprising. The UMWA’s com- consequence of the union-industry partnership placency toward the disaster had discredited than as a character flaw. This perspective is Boyle and mobilized the reformers. reflected in the writings of UMWA officials and staff following Boyle’s ouster. The Yablonski campaign merged the rebellion over health and safety with growing The reformers organized themselves into the dissatisfaction over the absence of union Miners for Democracy (MFD) in 1972 and nom- democracy. Yablonski urged improved health inated Arnold Miller for president. Miller, a and safety, democratization, a merit system, disabled miner from Cabin Creek, W. Va,, had mandatory age-65 retirement for officers, a worked with the BLA and other reform ele- better grievance procedure, a higher Fund ments since 1969. He leaned heavily on the ad- royalty, and an end to nepotism, The demand vice and skills of a dozen or so young, Iiberal for union democracy was a reaction to Lewis nonminers to organize the MFD campaign. The and Boyle’s authoritarianism, which had be- MFD slate defeated the Boyle-led incumbents come a prerequisite for maintaining the alli- handily in December 1972. The reform move- ance, Yablonski lost the election, 80,577 to ment effected many changes in Miller’s first 5- 46,073, on December 9, 1969, Three weeks year term of office. Union programs in safety, Ch. IV—Factors Affecting Coal Production and Use ● 135 political action, internal communications, lob- were frustrated by what they saw as failures of bying, and research were begun or strength- the UMWA leaderhip to fulfill its early prom- ened. New leadership was placed in the Fund. ises despite the gains of the 1974 contract. District elections were democratized. The rank Operators and miners clashed over control of and fiIe obtained the right to approve or disap- the workplace when companies failed to ad- prove negotiated contracts. Organizing—the just to the new demands of their employees. lifeblood of any union–was stepped up. Ma- The conflict over mine health and safety jor wage and benefit gains were secured in the shifted from the hearing rooms of Washington 1974 contract. Yet the 1973-77 period was also to the individual mine face as UMWA and one of tremendous rank-and-file unrest. Strikes local mine safety committees pushed for and absenteeism increased, As the old part- greater protection. nership between UMWA and BCOA dissolved, Management’s struggle with its employees “labor peace” was replaced by “labor instabili- has been fought over many issues during these ty. ” Miners began demanding the right to years. Absenteeism and disputes over the strike (which they had in the late-l940’s and grievance procedure, compulsory overtime, which Lewis conceded in 1950), Some of the and job rights repeatedIy disrupted coal pro- discontent was focused on Miller’s handling of duction. Miners saw management as trying to UMWA. It came from UMWA liberals who take away job protections that they had won thought he was not moving fast enough in through the 1974 contract, Federal law, and many areas and from conservatives or Boyle local custom. Management saw UMWA job stalwarts who disliked the changes he was rights as an impediment to steady output, making. Strikes and intra-UMWA turmoil Operators believe Federal health and safety escalated after the 1974 contact, regulations and UMWA work rules enabled 1974-78: An Overview of miners to encroach on traditional management Labor-Management Relations prerogatives. This, coupled with what they perceive to be increasing Federal regulatory The factors discussed above explain the “harassment,” impedes profitable mining, the predisposition of miners and mine manage- industry says. ment to lock in what Lewis once called “a deadly embrace. ” But the political and work- The expectations raised by union democracy place struggles that came to the Appalachian were applied by miners to their communities coal fields in the mid-1 970’s were qualitatively as well. High hourly wages were hard to recon- and quantitatively different from the Lewis-led ciIe with the frequently dismal quality of com- contract strikes of the 1930’s and 1940’s. The munity life in the coal fields. Why, miners growing rebelliousness of UMWA miners cul- asked, did the roads have to be so bad? Why minated in the 3½-month-long contract strike wasn’t there decent housing? Why no water in the winter of 1977-78. The roots of this con- and sewer hookups? Why the poor schools? frontation went back to the MFD victory in Why were the politicians unable or unwilling December 1972. Freed from what the MFD re- to change this situation? The sense of depriva- formers called “the tragedy and corruption of tion miners felt in their communities was car- 56 the Boyle years,” miners found the change in ried into the pits, where it emerged as hair- union leadership stirred their long suppressed triggered combativeness over working condi- yearnings for more say not only over UMWA tions. affairs but also over their working conditions and communities. Democratizing the UMWA Wildcat strike activity was relatively con- also politicized hundreds of miners and led stant between 1969 and 1974, accounting for them to believe that they could make other more than 550,000 worker-days-idle annually. social changes. But, unauthorized work stoppages and lost time jumped dramatically in 1975-77. Part of But neither UMWA nor the workplace lived the increase is attributable simply to the fact up to these new expectations. Many miners that the work force increased 84 percent be- 56 ~~e ~ear of the /?Eink and F//e, P 71 tween 1969 and 1977. A second explanation is 136 ● The Direct Use of Coal that miners were less afraid to assert them- 7. Many of the problems of the grievance selves now that demand seemed to be expand- procedure, which may contribute to ing, labor was in demand, and wages were ris- strikes, can be reduced if management ing. A third explanation looks to the broad and the union resolve more of their range of unmet rising expectations miners de- disputes at the minesite, rather than veloped in the course of union reform, safety through recourse to arbitration. legislation, and political and social changes in the coal fields. Finally, when other channels of Wildcat strike activity dropped in 1978. But communication with mine management and it is premature to conclude that coalfield politicians seem to miners to be unproductive, peace will reign. The effects of the 4-month strikes are used as a way for one, often-un- contract strike that ended in March left represented group to get its message across. UMWA miners in debt and anxious to work. Thousands have been working on-again, off- A recent study” of wildcat strikes in Ap- again because of poor market conditions and a palachian coal mines found–among other 10-week strike by railroad workers on the N&W things — the following: line. Absenteeism declines when the mines are 1. Some companies had no strikes in 1976; working short weeks, and rises when 6-day others had as many as 17 strikes per mine. weeks and lots of overtime are the rule. Fur- Even within the same company, some ther, miners can’t strike if they are not work- mines have many more strikes than ing. A truer indication of the mood of the work others. force should develop in 1979 and beyond. It 2. In a sample of four underground mines, it would be an error to believe that steady was found that miners at low-strike mines growth in demand for coal will necessarily consistently reported better relations with lead ro good labor-management relations. their section foreman than did miners at Growth may, in fact, lead to more militant high-strike operations. demands and less concern for cooperating 3. Miners at high-strike mines believed it was with management. necessary for them to strike to get management to talk with them. Many miners believed striking would help resolve disputes in their favor. Miners at high- 1974 UMWA Contract strike mines reported that management was generally uncooperative with the The 1974 BCOA-UMWA negotiations took union and unwilling to settle a dispute place in new historical circumstances. The when the union had a good case. reform UMWA rejected partnership with 4 Ninety percent of the miners believed that BCOA. Demand was growing. Profits had risen one reason for wildcat strikes was the ex- for 4 straight years as a result of price in- cessive delay in the grievance procedure. creases and the 1973 OPEC embargo. Net coal Arbitrators were distrusted. income rose from $128.4 million to $639.5 5. Local union officials do not lead strikes. million — a 398-percent increase — for 24 major . They are led by rank-and-file miners. companies, the Bureau of Mines reported. District presidents do not appear to have Many major coal companies had been ab- the political strength to take any meas- sorbed by energy companies or conglomerates, ures against wiIdcat strikes. whose greater resources raised UMWA nego- 6. The findings suggest that wildcat strikes tiating goals. The union came to the 1974 are related to management practices in bargaining table with two basic purposes: 1) to dealing with employee matters. make up ground lost over the previous 20 years, and 2) to work out new terms for future labor-management relations. BCOA conceded an unprecedented wage “Jeanne M Brett and Stephen B. Goldberg, p 23 ff. and benefit package in 1974. Wages were in- Ch. IV— Factors Affectlng Coal Production and Use ● 137 creased more than ever before, A cost-of-1iving mist i c production projections, inflatlon, lack escalator and paid sick leave were granted for of adequate cost controls, the inability of the the first time. Miners were given the right to UMWA to organize new mines, wildcat strikes, withdraw individuaIIy from conditions any one and unexpectedly high growth in the benefici- of them judged to be an “imminent danger. ” ary population — al I forced the Funds to re- Paid vacation days were increased significant- trench. Either benefits to miners or payments ly, but a two-track pension plan was intro- to health providers had to be cut The Funds duced. Current retirees received a $75 to $100 chose to cut benefits by instituting deduc- monthly raise to $225 to $250, depending on tibles, which ended the tradition of first-dollar whether they received Fed era I black Iung com- coverage established in 1950. Miners had to pensation. But the pensions of miners who repay up to $500 per famiIy for medical services. tired after 1975 were calculated according to a The Funds also ended negotiated retainers sIiding-scale formula based on age at retire- with about 50 coalfield clinics i n favor of fee- ment and years of employment Their average for-service reimbursement This had the effect pension was $425 a month UMWA negotiators of forcing the clinics to cut services Miners believed this was the first step in phasing in a throughout the East stopped work for 10 weeks benefits-accord ing-to-service principle they to protest these cutbacks. BCOA refused to thought fairer than the flat payment. Newly refinance the Funds because it felt that wildcat retired miners Iiked their higher benefit levels, strikes had caused the cash crisis.59 but much bitterness arose among the 80,000 BCOA also came to 1974 collective bargain- pensioners locked into the lower, flat rate. ing with a new strategy. The old union-manage- BCOA agreed to continue providing first- ment partnership that had glued the big oper- dollar medical coverage for working and ators together since 1950 was discarded. The retired miners and their dependents. Health Lewis-Love alliance might be dead, but the op- care and pensions had been administered by a erators hoped major wage and benefit conces- single UMWA Welfare and Retirement Fund sions wouId buy labor stabiIity. until 1974, when it was divided into four The BCOA strategy did not work. The separately funded but jointly administered UMWA leadership was not strengthened by the trusts. The two “1950” plans provided health BCOA’S concessions in the 1974 contract. In care and pensions to miners who had retired fact, the plan backfired. If anything, the im- before 1976 and were financed by a tonnage- provements secured by the union raised the ex- based royalty. The 1974 plans were funded on pectations of the membership more than ever. a tonnage and hours-worked basis. They pro- The contract was ratified by 44,754 to 34,741. vided benefits to working miners and new The two-tier pension plan created animosity retirees, Inasmuch as benefits were “tied into and bitterness. The new grievance procedure production-related financing formulas, no did not settle workplace disputes expeditious- benefits were guaranteed. In the event that ly. Thousands of cases were appealed to ar- future production did not meet the income bitrators. Many cases were not decided for estimates used by the 1974 contract nego- more than a year. Unauthorized work stop- tiators, the Funds would be unable to meet pages continued to increase in 1975 and 1976 their obligations. despite contract gains. The number of days This happened in the spring of 1977. Al- lost in wildcat strikes in 1975 and 1976 more though the 1974 contract had increased Funds’ than doubled the 1972-73 experience. Many income 62 percent in 2 years, revenues were miners felt the 1974 contract should have still not adequate to continue services to the given them the right to strike over unsettled more than 800,000 beneficiaries. 5“ Overly opti- “Although wildcat strikes contributed to the cash short- 5H’’Report of the Hedlth and Retirement Committee, ” age, a story in the Wall Street journal (Dec. 3, 1977) cor- Proceedings of the 47tfI Consecutive Constitutlona/ Con- rectly pointed out that production lost to such strikes vention of the United ~Mine Workers of America, Sept 23- amounted to only 3 percent of projected Income, and Oct 2, 1976, (United Mine Workers of America) pp 348 was not the prlnclpal cause ot the Funds’ financial ff troubles 138 • The Direct Use of Coal

grievances, a right that Federal court decisions 5. the employer’s right to schedule produc- had eliminated in the early 1970’s. Rather than tion or processing work on Sundays; solidify Miller’s standing with the UMWA, the 6. the employer’s right to change shift start- 1974 contract divided him from part of his con- ing times at his discretion; stituency. Miller’s efforts to discipline wildcat 7. reduction to 45 days of the 90-day protec- strikers further alienated some of his member- tion period for new employees (w-ho are ship. Some observers see the 1977-78 coal not allowed to operate face machines or strike as an extension of the rank-and-file work beyond sight and sound of an ex- dissatisfaction that had been building within perienced employee), and the UMWA and against the operators since 8 increased restrictions on the mine safety 1974. UMWA spokesmen, on the other hand, committee. 61 interpret the turbulence of the 1974-78 period BCOA also insisted on restructuring more as an acting out of newly discovered UMWA’s health and pension system. BCOA de- strength unleashed by the reform victory than manded that the 1974 health trust (for working as a refIection on MilIer’s leadership. miners) be replaced by private medical insurance arranged through individual operators. 1977-78 Negotiations UMWA was to lose its influence over coalfield medical care by this change. BCOA also in- BCOA was most concerned in the 1977 nego- sisted that coinsurance be made permanent. tiations over reasserting management author- Coinsurance would save BCOA members $70 ity over labor at the minesite and curbing wild- million to $75 million annually. Fund expend- cat strikes, absenteeism, and certain work itures would go down as well. BCOA would not rules. Related to this was the matter of produc- consider equalizing pension levels or signifi- tivity, which had fallen steadily since 1969. cantly increasing benefits. The union did not BCOA negotiators abandoned their 1974 hope demand pension equalization even though the that Miller could be transformed into an instru- 1976 UMWA Convention resolved that the ment of labor pacification akin to John L. union’s “Bargaining Council . . give high Lewis. From that reluctant conclusion, the priority in the next national contract negotia- operators were tions to equalizing pensions.”62 ., grasping for something in 1977-78 Finally, the operators did not like the idea negotiations. We realized the UMWA interna- that miners felt UMWA was providing their tional had lost control of their people. We pensions and medical services. Employee were grasping for ways to put stabilization 60 loyalty was not created by carrying a “UMWA into a contract. health card” or receiving a “UMWA pension” BCOA hoped to effect “labor stability” each month. Operators saw no advantage to — a phrase the industry coined — by winning them in the Funds’ subsidizing several dozen these specific demands in 1977: clinics that everyone casually referred to as 1. the unarbitrable right of the employer to “the miners’ clinics.” By switching to a strict discharge an employee for alleged strik- fee-for-service system based on operator-ar- i ng; ranged insurance, BCOA hoped to save money 2. cash penalties against employees for and build employee identification. unexcused absences and striking; It is not easy to discern Miller’s 1977 3. the employer’s unarbitrable right to ter- negotiating goals and strategy. Certainly, minate a new employee during his first 30 UMWA negotiators believed they were in a days of employment; 4. the employer’s right to set up production ‘]’’ Memorandum of Summary of Major Improvements incentives; and Changes Contained in the Settlement Between the United Mine Workers of American and the Bituminous Coal Operator’s Association, ” Feb 6, 1978. ‘“Allen Pack, “President of Cannelton Discusses Coal ‘2 Proceedings of the UMWA 47th Constitutional Con- Issues, ” Charleston Gazette, Apr 12,1978, p 1 C vention, pp 357-358. Ch. IV—Factors Affecting Coal Production and Use ● 139 weaker position than in 1974. Miller entered 5. a 1-cent-per-hour increase for every 0.2 in- bargaining after narrowly winning re-election crease in the Consumer Price Index; in June 1977 with 40 percent of those voting in 6. no maximum (cap) to the Cost of Living a three-way race. UMWA lacked a research de- Adjustment; partment and was not well prepared for bar- 7 seniority based on length of service alone gaining. Perhaps the union’s biggest dis- (rather than on the company-determined advantage was coal’s market situation. ability to perform the work and seniority); Utilities had doubled their normal stockpiles. and Demand for Appalachian metallurgical coal 8. modifications of the grievance pro- was weak. Prices for both steam and met coals cedure. 63 were generally static and, in some cases, fall- Health and safety was another priority. The ing. BCOA operators and customers could ab- delegates called for: sorb a long strike, particuIarly as the long-term effects were appraised as outweighing the 1. a full-time, company-paid health and safe- short-term losses. ty committeeman at each mine; 2. a minimum of one UMWA miner trained According to newspaper accounts at the as an emergency medical technician on time, Miller had two principal goals: winning every operating section on every shift at the right to strike at the local level and restor- each mine; ing first-dollar-coverage health benefits. The 3. automatic, continuous dust sampling; UMWA won neither, ultimately. Wildcat 4. a UMWA miner employed as a full-time strikes had bedeviled Miller for 3 years, so dust weighman “with the authority to en- skeptics and others surmised that he planned force dust standards; to trade the right-to-strike for softening of the 5. strengthened language concerning the BCOA’S “labor stability” package. The right-to- shutdown powers of the mine safety com- strike was not included in any of the three ne- mittee; gotiated agreements. Miller sought the restora- 6. no arbitration of safety committee deci- tion of health benefits to precutback levels s ions; and their full guarantee over the course of the 7. tougher language protecting the right of contract. Apparently, high priority was not the individual miner to withdraw from given to opposing deductibles, private insur- hazardous conditions; ance plans, and clinic cutbacks. 8. a 90-day training period for new miners, and a 30-day time Iimit on arbitrators’ By contrast, the bargaining priorities out- decisions on safety and health disputes. lined by the more than 2,000 delegates to the UMWA convention in 1976 were clear and ag- None of these was included in any of the ten- gressive. Most of all, they did not want to lose tative agreements. Obviously, the union’s ne- any of the ground gained in 1974. That meant gotiators were not expected to win this entire no “labor stability” package, no deductibles, shopping Iist of convention-endorsed objec- and no reduction in benefits. The right to strike tives. But the scope and quality of the changes had mixed support among the membership. envisaged by the rank-and-file delegates sug- The convention strongly endorsed it for use in gested they expected a feisty, offensive pos- “local issues threatening the safety, health, ture from their negotiators in the 1977 talks. working conditions, job security, and other Perhaps the UMWA team lived up to this senti- fundamental contract rights. ” Convention del- ment in private discussions with the BCOA, but egates also endorsed: miners found the contracts presented to them in February and early March 1978, did not 1. rank-and-file participation in the nego- measure up. tiating process; 2. across-the-board wage increases; 3. abolition of compuIsory overtime; “See “Collective Bargaining Committee Report, ” Pro- 4. more personal and sick leave days; ceedings of the 47th Consecutive Convention. 140 ● The Direct Use of Coal

UMWA miners were off the job for 109 days gram might collapse. (Benefits had been sus- in the winter of 1977-78. Two months after pended at the outset of the strike. ) their contract expired on December 6, 1977, Third, miners were increasingly vocal in ex- the union’s 39-member bargaining council re- pressing their lack of confidence in their own jected the first tentative agreement Miller and negotiators. Summarized, their argument BCOA had worked out. A month later, miners seemed to be: “We can stop the operators rejected a second draft, 2-1. As this occurred, from taking away what we won before, but we newspapers were filled with administration can’t make our negotiators get what we want. ” predictions of impending power shortages and This belief led to a sense of fatalism about strike-caused unempIoyment of up to 3½ what could be accomplished by continued million workers. No power shortages occurred, striking. and only one State— Indiana — seriously enforced mandatory power cutbacks. The Bu- Fourth, the ratification process itself reau of Labor Statistics in the Labor Depart- weighed in favor of getting a settlement sooner ment was reporting to the White House only rather than later. Miners understood that ratifi- 25,500 strike-related layoffs at the height of cation involved at least 10 days. Rejection of the strike. ” Still, the administration sought the third contract would mean more delay and received a temporary back-to-work order before negotiations resumed, and then further under Taft-Hartley procedures invoked on delay before new terms were agreed on. March 6. The prospect of increased Federal in- All of these factors affected the ratification tervention in their affairs brought the two sides vote. It is important to understand that in together, and they hammered together a third casting his ballot a miner was not necessarily agreement. By that time, the Federal judge taking the final step in a rational process of who had issued the temporary Taft-Hartley assessing the objective advantages and disad- order refused to extend it on the grounds that vantages of the contract he had been asked to the administration had never proved the ex- consider. istence of a national emergency. On March 24, 56 percent of those miners voting accepted the What explains the protracted inability of the contract. The third contract softened some of negotiators to agree to a contract that the the BCOA’S demands embodied in the earlier miners would accept? One answer lies in the drafts. But it fell short of rank-and-file objec- ability of each side to endure a long shutdown tives in many areas. Why did miners accept it? and the expectation that by doing so the final offer could be a net improvement over any First, many were beginning to suffer eco- earlier terms. A second is BCOA’S demand for nomic hardship. The union had no national unprecedented changes in the status quo. The strike fund, and the lengthy wildcat strikes of magnitude of these changes, together with the 1977 had cut into miners’ savings just months barely disguised threat to resort to company- before expiration of the 1974 contract. By mid- by-company bargaining, was perceived by March there was an inverse relationship be- miners as an all-out attack on their way of life, tween a miner’s militance and the number of its culture, and its protections, Third, the mouths he or she had to feed. The contract perceived cleavage between Miller and his represented income. membership encouraged BCOA to demand Second, there was widespread distress about drastic contract revisions. Had the union side health and pension benefits. As the strike wore been united, the operators might have compro- on, fears increased that the entire pension promised sooner. Fourth, had BCOA not insisted on “labor stability” penalties, it is arguable that miners might have accepted BCOA’s other “The administration’s spurious estimates of unemploy- demands more quickly as part of a package. ment and power shortages were examined by the General However, miners felt the BCOA’s stability Accounting Office in a report to Cong John Dingell, entitled, “improved Energy Contingency Planning is demands were a reassertion of the operator’s Needed to Manage Future Energy Shortages More Effec- wish to do as they pleased with their employ- tively, ” Oct 10, 1978 ees, The stalemate came to focus on the Ch. IV—Factors Affecting Coal Production and Use . 141

Photo credit: Douglas Yarrow UMWA coal miners protesting changes in medical benefits in Washington, D. C., during a month-long wildcat strike that shutdown most Appalachian production, 1977 shared perception that “rights” were at stake: as the 1974 agreement in many respects, par- the employee’s right to job protection, safety, ticuIarly with respect to heaIth benefits. and security; and the operator’s right to manage his business according to his best judgment. When each side perceives that its rights The 1978 Contract Terms are challenged, wars of attrition are common. Fifth, it appears that because of poor market Discipline conditions, metallurgical coal producers and The harsh language of the first two drafts some other eastern operators were not terribly concerning management’s right to fine and dis- hurt by a long strike. Had there been no strike, cipline wildcat strikers was deleted. I n its hundreds of mines would have shut down or place, however, is a memorandum of underlaid off workers because of excessive utility standing that continues decisions made by the stockpiles, static prices, and soft markets. Arbitration Review Board (AR B). The ARB de- BCOA was not pleased with the final ver- cision decided in October 1977, gives em- sion, although it had won major changes in the ployers the right to discharge or selectively 1974 contract. Miners saw the final product as discipline employees who advocate, promote, less punitive than earlier drafts but not as good or participate in a wildcat strike. ARB 108 is 142 • The Direct Use Of Coal less punitive than the proposed “labor stabili- the best explanation, again, is simply that ty” provisions as employees can appeal miners can’t strike if they don’t work. Almost grievances through arbitration. 20,000 Appalachian miners were laid off in the No significant work stoppages have oc- summer of 1978 because of soft metallurgical- curred since the 1978 contract went into ef- coal markets, productivity-boosting plans, and fect. Some mines report less absenteeism. Are the strike against the N&W railroad. About half these short-term phenomena, or are they that number were working irregularly in the trends that are likely to continue and if so, to winter of 1978-79. On the other side, many of what extent are they traceable to the provi- BCOA’s larger members appear to have made sions of the new contract? a special effort to resolve grievances as promptly as possible. Some claim that because The second question is the easier. The recent of the new clause, more grievances are being decrease in work stoppages and absenteeism resolved in the miner’s favor. I n any case, ex- probably cannot be credited solely to the new perience with the 1978 contract is insufficient contract because, with one exception, no new to permit drawing many meaningful conclu- terms bear directly on this issue. The sole ex- sions about whether it will lead to a sustained ception occurs in the article governing settle- reduction in the number and frequency of ment of disputes — the grievance procedure. A wildcat strikes and absenteeism. small but significant change was written into the first step. A section foremen now has the In the long run, wildcat strikes and ab- authority to settle a complaint at the minesite senteeism are unlikely to be brought under within 24 hours. His decision no longer sets any lasting control until the union’s internal situa- precedents in the handling of other grievances. tion stabilizes and the industry adopts a more Formerly, mine management delayed con- generally enlightened attitude toward labor ceding a point in one matter for fear that it relations. It is too soon to know whether either would be binding for the duration of the con- wilI occur. tract. Although individual miners seem to be getting grievances settled faster than before, Productivity Incentive Plans redundant disputes over the same points may be occurring. A spot check of different The UMWA had traditionally opposed plans to increase production by offerin districts in June 1978 produced no definitive g cash information about dispute frequency but did bonuses for tonnage over a stated quota. The confirm that foremen had more latitude on union argued against bonus plans on two grievance handling. The officers of the union’s grounds. First, if bonus plans succeeded in largest and most strike-prone district (District significantly increasing a worker’s real spend- 17 in southern West Virginia) reported then a able income, the union would find negotiation very sharp drop in the number of grievances increasingly difficult for substantial across- being referred to union representatives. The the-board wage gains. The union feared that layoffs and short weeks that idled thousands wages would be shifted from an hourly basis to of miners in Appalachia in the past year prob- piece rates, which is considered regressive. ably discourage grievances being filed and Second, UMWA argued that bonus systems en- wildcat strikes from happening. If demand courage risky short-cuts, lack of proper equip- perks up in these areas, grievances may rise ment maintenance, and speed up— all leading proportionately. to more accidents and disease. BCOA made incentive systems a central demand in its Whether the reduction in wildcat strikes is a negotiating. The post-1 969 decline in produc- short-term phenomenon is a much more diffi- tivity might be turned around, the operators cult question. Miners are still recovering from thought, if cash bonus plans were adopted. a strike that lasted much longer than expected. UMWA agreed to this change. They have been concerned with retiring large debts and replacing whatever savings they had The new contract language provides for a built up. Like other Americans, they have also majority vote (among those miners voting) been troubled by continuing inflation. Perhaps before an operator can adopt a bonus plan. Ch. IV—Factors Affecting Coal Production and Use ● 143

Once accepted, it cannot be rescinded by the Health Care employees. Each plan would provide monetary The most dramatic change in the 1974 con- incentives for production or productivity in- tract involved the refinancing and control of creases. (The contract language does not spec- UMWA’s health plan. Under the 1978 agree- ify what the cash bonus is pegged to). One of ment, all working miners and recent retirees the conditions of the plan is that it “does not shifted to company-specific, private insurance lessen safety standards as established by ap- plans. A Funds medical plan will exist for plicable law and regulations. ” Some operators pre-1976 retirees only. Coinsurance— up to and some miners may not interpret safety $200 per year per family–was instituted. All “standards” as being the same as safety per- services, including those provided by the clin- formance (that is, fatality and injury rates and ics, wiII be reimbursed on a fee-for-service numbers). I t is possible that accident frequen- basis. Health benefits are supposedly guaran- cy could rise, but so long as management teed, but uncertainty remains in some areas standards or number of injuries did not about what these guarantees mean in practice. change, the bonus system would not be The imposition of deductibles for working voided. Nothing is included about health miners and retirees ends first-dollar coverage, standards or experience. The cash bonus which had been the rule since 1950. Because system will be popular with many miners, but they apply only to physician care and medica- its adverse impact on workplace health and tion, some health analysts believe miners will safety may be significant. be discouraged from buying preventive physi- Operators have adopted two different ap- cian care. The experience of other medical sys- proaches to increasing productivity in recent tems—the Stanford University Group Health months. Consolidation Coal has won accept- plan and the Saskatchewan plan — suggests ance at four mines of plans that tie the level of that the introduction of coinsurance reduces the cash bonus to increased tonnage and num- demand for physician services. ” The entire ber of injuries. It is too early to tell if this ap- health-benefits package is now seen by many

proach will raise output without compromising miners as having been seriously compromised. safety. Some union officials are worried that They were widely dissatisfied with the ad- both miners and operators will fail to report in- ministration of the Funds, and the current sit- juries in order to preserve the cash bonuses. A uation is commonly perceived as substantially second approach taken by another operator worse. Strikes over the insurance reimburse- seeks to raise productivity by eliminating near- ment issue have been narrowly averted several ly 2,100 jobs, representing about one-sixth of times over the last year. The dismantling of the its work force in West Virginia. A company Funds is also an emotional issue that is unlike- spokesman said that reduction was not ly to dissipate during the term of the 1978 prompted by poor market conditions; rather agreement. For management and union leader- “ it’s strictly to improve productivity. ” This ship alike, it will remain a difficult problem. company hopes to maintain the same level of Strikes over coalfield health care are likely. output after the layoffs, thus increasing pro- ductility. ” Occupational Health and Safety Aggregate productivity statistics over the None of UMWA’s occupational health and next 2 to 3 years will tell relatively little about safety demands survived the bargaining. The the effects, if any, of the new incentive clause. 1974 language continues in force, At each Meaningful evaluation will require close mon- UMWA mine, a health and safety committee is

itorin g of individual mines where incentive elected (generally three miners), Committee plans are put into effect to determine relation- members are entitled to special training. They ships between these plans and changes in pro- have the right to close sections of the mine ductivity, accident frequency, and dust levels, “Anne A Scltovsky and Nelda McCall, “CoInsurance and Demand for Physician Services. Four Years Later, ” ‘5Coa/ /ndustry News, Sept 18, 1978 Socla/ Secur~ty f?u//efln, May 1977 144 ● The Direct Use of Coal

when they find conditions of “imminent dan- proving workplace relations. The significance ger,” If their employer challenges their judg- of the changes that have taken place in the in- ment, Federal or State inspectors may be dustry’s work force over the past decade are called in to settle the question, or the issue difficult to exaggerate. The industry Iaid off 70 may be taken through arbitration. The commit- percent of its work force between 1950 and

tee’s action can be reversed only after the fact. 1970, then turned around and began hiring This provision, stronger than most labor agree- again in record numbers when demand picked ments, dates back to 1946, when John L. Lewis up Today, most miners are in their 20’s and won it when the mines were under Federal con- 30’s The supervisory work force is also over- trol. If an arbitrator upholds an employer’s ac- whelmingly young. In some mines, informal cusation that a committee member acted “ar- alliances between young foremen and young bitrarily and capriciously, ” the miner may be miners have reportedly occurred in response to removed from the committee but cannot be perceived intransigence by upper manage- fired or otherwise disciplined for his official ment. Low-level supervisory skills are no longer actions. sufficient, Most industry spokesmen acknowledge the shortage of experienced mine These provisions contrast starkly with those foremen who are able to maintain good rap- generalIy in effect at non-UMWA mines, where port with hourly employees. Some companies the safety committee, if one exists at all, is are trying to upgrade supervisory skills; others often reluctant to enforce standards for fear of hope to get by with what they have. The likely jeopardizing its members’ jobs. safety and production payoffs of more capable foremen cannot be understated. Workplace Relations The 1978 contract provides for employer-de- The basic issues that created friction under veloped orientation programs of not less than previous agreements were not resolved and 4 days for inexperienced miners and not less can be expected to cause difficulties in the than 1 day for experienced workers. The con- future. tract specifies that each program should em- For example, management retains the right phasize health and safety. The trainee period — during which a new miner cannot op- to operate mines 6 days a week (a BCOA proposal to permit operation 7 days a week erate mobile equipment or work beyond sight failed). The compulsory sixth shift is a primary and sound of another miner — was cut from 90 source of discontent among miners at opera- to 45 days. tions where the 6-day week is scheduled. Com- pulsory shift rotation is another source of Education and training for miners can take widespread discontent. Wildcat strikes have many forms. A sample list of priority objec- erupted over it. Some miners believe manage- tives might include: ment routinely awards preferred jobs on the ● basis of favoritism, and that the contract Machine-specific training beyond basic language does not protect a miner’s right to be requirements of State and Federal law. ● awarded a job on the basis of seniority and Training in dispute settlement directed at ability to perform the work. Some of these con- both supervisors and members of the flicts might be resolved if each side were will- UMWA Mine Committee. ● ing to meet and work out a compromise. It is Training for the Health and Safety Com- still too early to telI whether this will happen mittee to familiarize them with occupa- u rider the 1978 agreement. tional health and safety hazards and Government regulations. ● Interchangeable skills for work crews Education and Training within the mine. The benefits from such Education and training have been foreign training are obvious. Safe working habits concepts in the coal industry through much of are encouraged. The impact of absentee- its history. Both are inextricably tied to im- ism is blunted when a miner can step into Ch. IV—Factors Affecting Coal Production and Use . 145

the job of an absent worker without ex- cific bargaining will create more problems posing himself and other crew members to than it promises to solve. They point out that hazards arising from unfamiliarity with a this kind of bargaining historically has de- machine or work procedure. Recent Fed- stablized this industry. The signing of a eral regulations on miner training are a number of agreements (each of which em- step in this direction, but critics argue that bodies a different set of wages and benefits) they are inadequate in many respects. would create strike conditions because of the differences. It is improbable that miners at one Wages mine wiII work very long for less than miners at an adjacent mine. It is also likely that miners Most miners approved the wage package. who strike when their contract expires will Unadjusted standard wage rates rose from “picket out” other mines in order to increase 1977’s $55.68 per day for the top-paid miner to economic pressure on their employer. This $74.32 per day in the first year. The lowest paid chain reaction could go on indefinitely as stag- underground miner went from $50.38 to $64.78 gered expiration dates are reached. It is debat- per day in the first year. The gap between lowable whether decentralization would produce est- and highest-paid miners is $8.64 per day, as a net reduction in time lost to strikes. Had the it was in the previous contract. 31A -month strike actually imperiled the coun- The 1974 agreement initiated a capped cost- try, solid ground would have been established of-living escalator pegged to increases in the for a radical restructuring of the UMWA-BCOA Consumer Price Index. In the final adjustment structure. But as a national emergency never period (November 1977), the maximum infla- existed — and is even less likely to in the tion adjustment was $0.98 per hour. The new future– it does not appear to be imperative to contract includes no inflation adjustment change the status quo. mechanism in the first year, and a $0.30 maximum per hour raise in the second and third Community Development years. Although the 3-year, hourly wage increase amounts to about 30 percent, the in- Community development problems are be- crease in real income is likely to be closer to 3 yond the scope of the collective bargaining percent after inflation, deductibles, and higher process, but they must be addressed more ef- tax payments are taken into account. fectively over the term of the 1978 agreement or the basic unrest that has characterized coal- Union-Industry Relations field life will not abate. The most significant In the last round of negotiations, some coal difference in strike activity in the 1970’s from operators were encouraged by the Carter ad- earlier periods was that the former sometimes ministration to break from the BCOA bargain- was triggered by nonworkplace social and eco- ing structure and conclude contracts with nomic conditions, such as a gasoline rationing UMWA miners on a company or geographical plan in West Virginia, controversial school basis. Proponents of this innovation argue that textbooks, unsafe coal-waste impoundments, decentralization would reduce the impact of Federal court decisions, pending Federal black contract strikes because no common contrac- lung legislation, and cutbacks in health bene- tual expiration date would exist. Some also be- fits. Before the 1970’s, strikes were rarely lieve that the more profitable companies caused by matters other than those arising could buy “labor stability” through compara- over working conditions or contract terms. Re- tively “fat” packages, leaving less-profitable cent field studies suggest that inadequate, companies to settle as best they can. Many unstable living conditions contribute to ab- newer companies — as welI as some miners — senteeism, wildcat strikes, and lower produc- feel the pension obligations of older BCOA tivity. The President’s Commission on Coal, companies limit the size of wage gains that which began its investigation in September can be negotiated. The other side of the 1978, is exploring the relationship between liv- debate argues that regional or company-spe- ing conditions and work relations, as well as 146 ● The Direct Use of Coal

possible strategies for improving the quality of health rights, and benefits for retired miners. If . coal field life. UMWA succeeds in upgrading its western surface-mine agreements to prevailing non- Non-UMWA Labor UMWA standards, it will probably have better organizing success among western surface Roughly 30 percent of 1977’s 230,000 coal miners as nonwage issues take on increasing workers did not belong to UMWA. Some be- importance. long to other unions, such as the International Operating Engineers or PMU. The rest belong Conclusion to company-approved associations or to no labor organization at all. In the East, most non- The 1977-78 shutdown was one episode in a UMWA labor is found in small, mostly non- long-running coalfield drama; it was not the union mines in eastern Kentucky, Virginia, and final act. Labor peace is not unreasonable for a Tennessee. PMU is based in Illinois. In the coal operator to expect, but it is unlikely to be West, miners generally are either unorganized achieved by the approach adopted by BCOA or non-UMWA. With a few exceptions, UMWA in the recent talks. Too much bitter history and mines there are underground operations. too many contemporary conflicts exist to Still, UMWA exerts a good deal of indirect enable threats and penalties to promote influence over non-UMWA operations. In the stability, let alone peace. Any long-term ap- 1977-78 strike, much non-UMWA production in proach requires recognition that many of the the East was shut down, too. Wages and ben- problems have become embedded in the efits in non-UMWA mines are often pegged to American system of coal mining— its produc- UMWA rates. Non-UMWA operators will often tion process, work relations, work environ- offer higher wages than the UMWA scale in ment, communities, and culture. Changing the order to keep UMWA from organizing its consequences of this system — absenteeism, miners, Three UMWA contract provisions ap- strikes, distrust, arbitrariness — means chang- pear most objectionable to non-UMWA oping the components of the system that produce erators: job security protections, safety and confIict.

REGULATORY RESTRICTIONS ON MINING

Federally mandated permits and operating Federal regulations. Permits are required under methods have become significant factors for SMCRA, the Clean Water Act, and the Re- the mining industry. The principal require- source Conservation and Recovery Act (RCRA). ments arise under the Surface Mining Control SMCRA mandates State permit systems in ac- and Reclamation Act (SMCRA), the Mine Safe- cordance with Federal guidelines that include ty and Health Act, and the Clean Water Act. comprehensive performance standards for sur- These are discussed in detail in chapter VII. face mining operations and for the surface ef- This section addresses the ways these regula- fects of underground mining. These standards tions affect mine operators as well as their are intended to prevent adverse environmental potential to affect the supply of coal. The ma- impacts such as ground and surface water con- jor areas of concern are the increased Ieadtime tamination, degradation of land quality, and required to open a new mine, increased capital subsidence. Mine operators must demonstrate, and operating expenses, the designation of cer- as a prerequisite to obtaining a mining permit, tain areas as unsuitable for mining, and a sense that the land can be restored to a postmining of “harassment” within the industry. land use equal to or greater than the premining A longer Ieadtime for opening new mines use. The Clean Water Act and RCRA also man- could result from the need for additional plan- date State permit systems in accordance with ning, design work, and permits to comply with Federal guidelines. Under the Clean Water Act, Ch. /V—Factors Affectlng Coal Production and Use ● 147

Federal effluent limitations designed to tial customers, but smaller companies could achieve national water quality goals apply to lose their historic ease of access into the all active mining areas (surface and deep) in- market because the planning and permitting cluding secondary recovery facilities and prep- costs would be incurred so far in advance of a aration plants. Solid waste disposal standards return. The flexibility of coal supplies also under RCRA are designed to control open could be reduced greatly because only those dumping; substantial constraints could be im- mines that are welI into the planning stage posed on the disposal of mine wastes if they couId be considered viable suppliers. were declared to be hazardous. Additional Increased capital and operating expenses design restrictions may be imposed by the re- for surface mines would result primarily from quirements of the Mine Safety and Health Act. reclamation and other environmental protec- In addition, the planning stage for leases in- tion requirements For underground mines volving federalIy owned coal or for mines on both environmental and occupational health Federal lands may include the preparation of and safety requirements increase production an environmental impact statement under the costs. Before passage of SMCRA, surface mine National Environmental Policy Act (NE PA) or reclamation costs averaged $3,000 to $5,000 the Federal leasing program. per acre. Depending on seam thickness, this Before the implementation of these en- cost translates to a range of about $0.20 to vironmental and health and safety regulations, $1.00 per ton. Industry estimates of the in- a mine could be opened in Iittle more time creased costs attributable to SMCRA vary than that required to conduct geologic sur- widely, depending on the characteristics of the veys, assemble the tract, order equipment, and site. prepare the site, This process typically might Any cost increases probably will not limit have required 5 years. However, permitting the industry’s ability to supply coal, but they and review and other mandated planning have will make coal more expensive and could force added significantly to this Ieadtime. Coal small, capital-short companies out of business. operators now estimate that the opening of In addition, coal operators could have difficul- some new mines couId require 8 to 16 years ty obtaining reclamation bonds for areas that from initial exploration to full production, are difficult to reclaim because of the strin- depending on the characteristics of the mine gent, detailed SMCRA requirements for these site and the resources of the mining company sites. Federal programs are available to help (see figure 16). However, if many of the re- small companies meet these increased costs, quired activities proceed simultaneously, and but it is unclear whether they will be adequate. if full compliance with applicable legislation is A third concern raised by regulatory restric- achieved at the outset, the Ieadtime shouId not tions is the designation of areas as unsuitable be increased substantially. for mining. Except for valid existing rights, However, if greatly increased Ieadtimes SMCRA prohibits surface mining on Federal become the norm, they could constrain coal lands valuable for recreation or other purposes supplies for the high-growth scenario by the (such as national parks, wildlife refuges, wil- late 1980’s, when a rapidly expanding coal in- derness areas, wild and scenic rivers) and on dustry would need new mines not yet in the much of the national forest lands. I n addition, planning stage. Supplies should be more than SMCRA requires the States to institute plan- adequate for all scenarios until then. In addi- ning processes for designating areas unsuitable tion, substantial delays in the opening of new for all or certain types of surface mining. These mines could alter the structure of the industry. include areas where reclamation wouId not be Because utilities will not contract for coal not technologically or economically feasible; needed for many years, coal mine planning where mining wouId be incompatible with ex- would have to begin without an identified isting land use plans; where it would adversely market. Larger mining companies can maintain affect important historic, cuItural, scientific, fully permitted nonoperating mines for poten- and aesthetic values; where it would result in Figure 16. —Permitting Network for Surface Mines + .-i

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ar 46 Mo. Ch. IV—Factors Affecting Coal Product/on and Use • 149 substantial loss or reduction in long-range pro- groups. Similarly, SMCRA inspectors may be ductivity of water supplies or food or fiber perceived by mine operators as allied with the products; or where it would endanger Iife or “environmentalists ” and vice versa. On the property in areas subject to flooding or un- other hand, all three groups — mine operators, stable geology. Until these State planning miners, and environmentalists — may feel that processes have been established, it is not clear the inspectors are incompetent and do not pro- to what extent they could Iimit coal supplies. tect any interests adequately. The final factor related to Government regu- An additional source of hostility within the lations is the sense of “harassment” en- industry is the automatic citation provision of gendered within the industry by Federal reg- the Mine Safety and Health Act, which re- ulation of what historically had been the in- quires an inspector to cite every violation re- dustry’s prerogatives. This hostility can result gardless of its severity or its potential for im- from the concerns discussed above (delays in mediate correction. Automatic citations and mine openings, increased costs) or from inter- civil penalties are intended to deter noncom- ference in mining practices by Federal inspec- pliance. However, as with frequent inspectors, and it can occur among mine operators as tions, they may be perceived as harassment by welI as between operators and miners or the operators who feel they are making a good- public. Mine operators may perceive frequent faith effort to comply with regulations. On the inspections as harassment, especially if the other hand, miners claim, that Federal inspec- operators feel that they are making a rea- tors do not always issue the automatic cita- sonable effort to comply with the regulations tions because their experience tells them that or that the reguIations are counterproductive. the specific circumstances do not warrant it. For example, mine health and safety inspectors Probably most inspectors use judgment in issu- may be seen by management as allied with ing citations; some are too lenient, others are labor or by labor as cohorts of management, too literal. resulting in increased tension between these

PRODUCTIVITY

Productivity is a measure of the efficiency productivity, it should be able to lower its proof an industrial process. It expresses a relation- duction costs, better compensate its labor, sell ship between a unit of output and the effort more cheaply, and show a better return on in- that goes into it. In coal mining, productivity is vestment. Although it is often imperative for expressed as tonnage mined per worker per an individual company to raise its productivity shift. each year, that imperative may be much less strong for the industry as a whole. Where sup- Production is not the same as productivity. ply (and capacity to produce) exceeds demand Production refers to total output or tonnage; it as it does in the coal industry, higher produc- says nothing about the efficiency of a coal tivity leading to more output may hurt coal mine or industry. The two concepts are related. suppliers who already have more coal than Coal production can rise through increasing they can sell. productivity; that is, by more efficiently using labor, capital, management, technology, and Mining productivity–output per worker raw resources. But output will also increase shift—expresses efficiency in terms of labor without any improvement in productivity productivity. Coal (labor) productivity is cal- when more units of production are employed. culated by dividing total tonnage mined by the Increasingly productive companies usually re- number of employees. This formula can be flect an ever more efficient use of economic misleading. Actually, productivity reflects the resources. When a company is able to raise its efficiency of how many factors work together — -.. .

750 ● The Direct Use of Coal to produce a ton of coal. When coal mining quently, productivity declined. Underground was a labor-intensive industry and labor costs productivity fell from 15.6 tons per worker accounted for as much as 70 percent of total shift in 1969 to 8.7 tons in 1977. Surface mining production costs, this way of measuring effi- productivity dropped from 35.7 tons to about ciency made sense. Then, each miner was paid 26 tons. Production rose from about 560 on a piecework basis — so many cents per ton miIion tons in 1969 to about 688 milIion tons mined — and mining systems required many in 1977, a 23-percent gain. But employment in- workers, Iittle capital, and simple tools. Today, creased 84 percent from 125,000 in 1969 to coal mining— both surface and underground almost 230,000 in 1977. systems— is capital intensive, and productivity Industrywide productivity data must be rises or falls according to how many variables used with caution because of numerous incon- interact, labor being only one. A more useful sistencies and uncertainties in the numerator indicator of mining productivity today might (tonnage) and denominator (workers) of the be derived by measuring capital efficiency (in productivity formula. constant dollars), mining system efficiency, individual machine efficiency, or total-factor ef - Tonnage, for example, is reported different- ficiency. ly by different companies—and even within the same company. Productivity is affected by The decline in coal productivity since 1969 whether operators report tonnage “as sold” or has received much attention. That decline has “as mined. ” The latter represents raw coal as it been dramatized because it reversed a steeply comes directly from the mine face. The former rising productivity curve that had character- represents both raw coal (sold as is) and ized the industry since 1950. I n that year, pro- cleaned coal. Productivity falls in proportion ductivity was calculated at 6.77 tons per to the amount of cleaned coal reported be- worker shift compared with 19.9 tons in 1969. cause wastage (which has been increasing— Productivity almost tripled over that 20-year see chapter 11) is subtracted from “as mined” period. But annual production never matched output. Because tonnage data include dif- the 1950-51 level until the late-l 960’s. Rising ferent definitions of output, productivity productivity did not result in increased pro- statistics may not be measuring efficiency in duction. (In fact, more bituminous and anthra- the same way. cite coal was mined in 1920— 655.5 million tons—at a productivity level of 4 tons per The data also do not distinguish between worker shift than was mined in 1975 —654.6 steam and metallurgical coals. Met coal and miIIion tons — at 13‘A tons per worker shift. ) steam coal prices were about the same in the Productivity improvement in the 1950’s and 1960’s, but met prices have been roughly dou- 1960’s did, however, allow the biggest coal ble steam prices in the 1970’s. High prices enabled inefficient met coal mines to operate companies to survive a protracted demand profitably. The effect of high met prices has slump. The spectacular rise of coal productivi- been to lower industrywide productivity. ty in these years was the result of mechanization of underground mining, increased surface Another data weakness involves the concept mining, the absence of environmental controls of tonnage itself. Coals differ in quality, and on surface mining, and inadequate mine safety tonnage simply measures weight. If, for exam- standards. Productivity improved statistically ple, the numerator in the productivity formula because 70 percent fewer miners were working were Btu instead of tonnage, underground and in 1969 as were in 1950 while production in- eastern productivity would rise relative to sur- creased slightly. As the numerator (tonnage) re- face mine and western productivity. mained relatively constant in these two decades, the denominator (workers) dropped” The raw data may also be misleading be- steadily, resulting in ever higher productivity. cause coal companies count their workers differently. Some count only hourly employees; In the 1970’s, production went up, but em- others include office workers. Obviously, the ployment rose at an even faster rate. Conse- larger the denominator (workers), the lower the Ch. IV—Factors Affecting Coal Production and Use ● 151

productivity rate. Another weakness involves A second crucial distinction needs to be the definition of a working shift. Actual shift drawn between new mines and old mines. The times range from 7‘A hours to as much as 12 productivity of new underground mines aver- hours, Generally, surface miners work more aged about 18 tons per shift compared with 11 overtime than underground miners. The typ- tons for existing deep mines in 1974.67 Similar- ical surface shift may be longer than the ly, new strip mines averaged about 70 tons per average underground shift. in this fashion, worker shift — and in some Western operations long-shift mines would show higher productivi- approached 150 tons— compared with about ty than short-shift operations, other things be- 36 tons for existing surface mines.68 lndus- ing equal. This wouId tend to show surface- trywide productivity will increase as new mine productivity higher and underground pro- mines replace old mines. ductivity lower on an aggregate basis, To be analytically useful, productivity data perhaps the single most serious flaw in the must compare Iike things — mining systems, data is that they often grossly combine the per- machines, geologic conditions, etc. Mine-by- formance of vastly different mining systems. mine data that include all the variables in- Coal mines range from huge investments pro- volved in productivity are needed. The ab- ducing 10 to 15 million tons annually to tiny sence of such data impedes sound policy mak- “dogholes” punched into a hillside, producing ing. 1,000 tons or less. Shovel size runs from 130 The productivity decline since 1969 must be yd’ down to a No. 4 hand shovel. Coal is seen in Iight of these data problems; the moved by 650 hp jumbo trucks as well as one unique factors causing the productivity in- pony-power railcars. The industry is made up crease between 1950 and 1970, and the equally of very different parts, and in analyzing pro- unique factors causing the uneven gains in ton- ductivity the differences may be more relevant nage and employment since 1970. than the simiIarities. The most obvious distinction is between sur- The rise in productivity in the 1950-69 period face and underground mining. Surface mines was the result of a combination of conditions are roughly three times as productive as deep that are unlikely to be repeated. Significant ad- mines. The productivity advantage of surface vances in underground and surface mining mining is inherent in its extraction technology technology maintained output levels while and geologic conditions, As more and more sharply reducing labor needs, (Indeed, the surface-mined production comes from the tre- labor cost per ton of coal dropped from 58.5 mendously efficient open-pit mines in the percent of value in 1950 to 38.3 percent in West, surface mining productivity should rise 1969. ’9 Further, the environmental and safety and to a lesser extent, industrywide productiv- costs of mining were not well regulated by ity as well. Although OTA estimates that the State or Federal law, Productivity rose but at a 60/40 ratio of strip to deep production is not social cost. The combination of shrinking de- likely to change over the next 20 years, indus- mand for labor and the cooperative arrange- trywide productivity would rise considerably if ments between UMWA and BCOA kept strike this ratio does increase (as it has since 1950). activity to a minimum. Finally, poor market conditions in the 1950’s and 1960’s weeded out Even within similar mining systems, varia- several thousand small, inefficient mines, thus tions in productivity occur according to seam boosting industrywide productivity, Unem- thickness and accessibility, mining techniques, ployment, black lung, environmental damage, and equipment size, among other factors. Un- and accidents were the hidden costs of rising derground productivity rates range from 31A product ivity. tons from a thin-seam in southern West Vir- ginia to 30 tons or more in a thick-seam. Sim- “Coa/ TasL Force Report for Project /ndependence(U S ilarly, surface productivity ranges from about Department of the Interior, November 1974), p 29 20 tons in east Kentucky to 100 tons or more in ’“1 bld Wyoming, “Joe Baker, “Coal Mine Labor Productivity, ” p 8 152 • The Direct Use of Coal

What happened after 1969 to reduce pro- is taken from the ground, much of it is not ductivity? The explanation for the decline can- counted in productivity calcuIations. For a not be pinned to a single cause. A number of number of reasons, deep-mined coal is more demographic, economic, and regulatory devel- often and more thoroughly cleaned than sur- opments contributed. face-mined coal, which further lowers deep- mine productivity. Productivity at individual First, innovations in mining technology mines may be substantially affected by this topped out both in reducing labor and in factor. For example, one underground mine expanding output. Continuous-miner technol- OTA visited was routinely discarding 56 per- ogy has not changed significantly since 1969 cent of material taken from the mine in order and, by that year, almost 96 percent of under- to fulfill coal-quality specifications in its sup- ground output was mechanically loaded. The ply contract. Productivity at this mine was onIy productivity enhancing change in about 3 1/2 tons per worker shift. I f its produc- underground mining has been the introduction 70 tion had not had to be cleaned, productivity of Iongwall systems, which mined about 4 would have doubled. Throughout the 1970’s, percent of all underground coal in 1977. the percentage of refuse-to-raw coal has Although surface mining expanded its share of inched upward. This reflects either dirtier raw national production, its technology has not coal or stricter customer specifications, and changed significantly in scale or concept. possibly both. Assuming that the Environmen- Second, as coal prices rose to unprec- tal Protection Agency (E PA) finally promul- edented levels, hundreds of small, inefficient gates a 0.2-lb/85-percent sulfur removal limita- mines opened, adding many employees but rel- tion, the amount of coal cleaned is likely to in- atively little tonnage to the industry’s ag- crease as the utility market expands. Also, as gregate.71 Inflated coal prices enabled these the more marginal seams are mined, the mines to operate profitably despite their rel- amount of waste extracted in mining may in- ative inefficiency. Conditions and policies that crease. Both factors retard productivity gains, encourage marginal mining wilI lower aggre- Fourth, the labor force has changed dramat- gate productivity. As long as coal prices re- ically since 1969. Both miners and supervisors mained constant in the 1950’s and 1960’s, pro- are young, often inexperienced and inefficient. ductivity rose steadily, But when prices rose Almost half of the experienced 1969 work sharply in the 1970’s, productivity fell. force retired in the 1970’s and 65 percent of to- Third, clean air legislation and relatively day’s work force has been hired in the 1970’s. steady metallurgical demand in the 1970’s The industry has had trouble transferring the meant coal had to be cleaned, sometimes practical wisdom of its older miners to this cleaner than before 1969. More than 100 new generation. Absenteeism has also reduced mill ion tons of waste (the equivalent of 15 per- productivity. Few hard data exist on the actual cent of 1977’s total output) was cleaned from extent of absenteeism or its root causes. One run-of-the-mine output. Although this material way of offsetting absenteeism is to train miners to have interchangeable skills so that each can do every job on the crew. But few 70 Longwalls can mine more coal with fewer miners, but coal companies do this. Nor do many com- they are expensive and workable only in certain geologic panies employ “utility” workers as the auto- conditions. About two-thirds of the 77 units operatin in g makers do, whose job it is to substitute for 1977 were In metallurgical mines, where high product price justified high capital investment. absentee workers. The industry may be able to “The biggest single employment category In 1975 was improve productivity by adopting such miners [n underground and surface mines producing few- changes if permitted by union work rules. er than 25,000 tons annual Iy 46,695 miners in these Finally, an estimated 5,000 miners were hired mines (about 24 percent of all miners) produced only after 1974, when the new UMWA contract re- 141 million tons (about 2 percent of all output) Calcu- lated from, /njury Experience in Coa/ Mining, 1975, in- quired helpers on underground face equip- formational Report, 1077 (Department of Labor, Mining ment. Helpers safen the operation of mobile Safety and Health Administration, 1978), p 77. equipment by moving high-voltage trailing Ch. I V—Factors Affecting Coal Production and Use ● 153 cables out of the way, watching roof and rib than 30 percent of time lost from wildcat conditions, helping the machine operator strikes in 1977. maneuver, and being around in case of trou- Sixth, the 1970’s saw extensive legislative ble. Helpers also receive training in machine and administrative regulation of the coal in- operation from experienced miners during dustry. States began to require surface their apprenticeship, which allows them — operators to reclaim land and control land- after 120 training days — to operate equipment slides and water runoff. This forced the in- when the regular operator is not present. The dustry to hire more workers and buy new addition of 5,000 helper jobs lowered produc- equipment. This added effort was “social [y tivity statistics. But the industry may recoup productive” from a national and public per- these statistical losses in the future by having a spective but lowered the economic productivi- pool of trained machine operators ready to ty of the individual operator and the industry. step in at a moment’s notice. Although the pro- Neither the Federal Office of Surface Mining ductivity decline has its qualitative side (such nor industry associations could supply data on as inexperience or anti-company attitude), the the percentage of the Nation’s 64,000 surface simple quantitative aspect— more miners— is miners that were engaged in reclamation work, its real cause. A major regulatory initiative that affected Fifth, disabling injuries lower productivity to underground mining was the 1969 Coal Mine the extent they disrupt production teams and Health and Safety Act. Federal health and require extra personnel. Disabling injuries have safety standards forced operators to devote risen since 1969. I n that year, 8,358 under- more personnel and equipment time to ventila- ground injuries and 967 surface injuries were tion, rockdusting, methane and dust monitor- recorded. I n 1977, underground disabling in- ing, roof control, maintenance, and retrofitting juries had risen 40 percent to 11,724 and sur- machinery with safety features. Safer oper- face injuries had gone up 132 percent to 2,246 ating procedures require equipment to be (see Workplace Safety, table 35). The amount moved in and out of the working place more of lost time from disabling injuries is substan- frequently than before. Had these practices tial. Average severity of an injury refers to the not been adopted, it is reasonable to suppose average number of calendar days lost by an in- that coal’s safety record would have been sub- jured worker. I n 1977, underground miners ex- stantially worse. Some new personnel were perienced 146 permanent partial injuries cost- needed to handle the employee-training and ing an average of 297 lost days and 11,575 tem- administrative aspects of the Act. Other gov- porary total injuries with an average cost of 73 ernmental regulations required new safety and work days.72 Surface miners experienced 66 environmental personnel. Office workers — permanent partial injuries with an average loss professional and clerical –were needed to ob- of 529 days each and 2,211 temporary total injuries with an average loss of 58 days each. 73 Calculated In the fol Iowlng manner Multlply number Together, underground and surface injuries of lnjur[es by the average number of days lost to get tota I resulted in the loss of 1,051,489 calendar days number of lost days To f Ind the number of lost work in 1977, which meant 751,079 lost production days, subtract two-sevenths of the total number of lost days. That represents 3,391 lost worker years. ” days (representing weekend time) from the total number of lost days Divide this sum by the average number ot In one form or another, an equivalent amount working days each year– 22o (underground), 230 of labor had to be hired to substitute for these (surf ace)–to get the number of work-year equivalents injured workers to maintain production. This lost to dlsabllng injuries. For underground mlnlng, this represented extra personnel and extra dolIar formula finds 888,337 lost calendar days reduces to costs to mine operators, as well as reduced 634,539 lost work days, or 2,884 lost worker vears For productivity. To put 3,391 lost worker years in surface mlnlng, there were 163, 152 lo\t calendar days or 116,.539 lost work d~ys, the equ Iva lent of 507 lost worker a comparative perspective, it represents more years Adding underground and surface lo~t worker years gives a total of 3,391 lost worker yedrs from m Ine Inju rles ‘iData supplled by MS HA’S Data Analys[s Center, I n 1977 Data for worker$ I n m I ne construct Ion, prepa ra- January 1979 Excludes permanent total injuries tion plants, etc are not Included 154 ● The Direct Use of Coal

tain permits, develop plans and administer old, smaller mines will close. Finally, it is likely them at the minesite. In 1969, for example, that many operators will try to improve their operators reported 2,640 office workers of all training programs and labor relations, which kinds at minesites; that figure rose to 7,037 in should help raise productivity. 1977, an increase of 167 percent. Presumably, However, increasing productivity may be a all of these management employees do nec- mixed blessing. Strategies to enhance produc- essary work. But they lower a mine’s productivity directly affect the health and safety of tivity when they are included as workers in the coal workers and the quality of community Iife productivity equation. It has not been possible in the coalfields. Production can be boosted to determine how many officeworkers are rou- through one of four productivity-enhancing tinely counted in productivity calculations, strategies, each of which carries a different set but anecdotal evidence suggests the number is of workplace and social consequences. substantial. These strategies are: Other factors may contribute to declining productivity. Operators may have trouble get- 1. Use fewer workers to mine more coal. ting capital. Delays in replacing mining equip- 2. Speed the pace of work so that each ment may reduce output. Underground haul- miner produces more tonnage. age technology has not kept pace with cutting 3. Invest capital in more efficient equipment technology. These systems often break down. to enable each worker to produce more. In older mines haulage and ground-control 4. Make the work process more efficient by problems tend to be more troublesome. Trans- redesigning jobs, improving morale and portation problems from mine to market slow motivation or improving coordination in down production when logjams develop. Prim- the production cycle. itive coal field social conditions and public ser- The first two approaches can have substan- vice deficiencies have been cited in several re- tial health, safety, and social costs, depending studies as to high cent contributing on how the work force is expected to maintain absenteeism and hostile labor-management production levels. If labor-saving equipment is relations, which lower productivity. purchased, health and safety may be improved because fewer workers will be exposed to dan- What of the Future? gerous conditions. However, if the remaining employees are simply expected to work faster The decline in coal mine productivity has or spend less time taking safety precautions, probably bottomed out. Gradual improvement accident frequency or health conditions may over the next decade should occur if many of worsen. One major West Virginia operator re- today’s trends continue. Some of these trends cently announced the layoff of 2,100 workers are mentioned here. Western surface mining to improve productivity. This operator who will account for an increasing share of total hopes to maintain output with fewer workers production. Its productivity ranges from 50 to consistently shows extremely high disabling- 150 tons per worker shift. Many of the person- injury rates, and the safety and heaIth conse- nel needed to handle the requirements of quences of this change may be substantial. In- Federal environmental and safety regulations efficient sections of these mines may close are already hired. Major legislative initiatives down entirely, or “nonproductive” jobs related in both areas requiring many more salaried or to mine housekeeping, rock dusting, and ven- hourly employees are not likely. The big hiring tilation work may be eliminated. surge of young workers has already taken place. They are likely to spend the next 20 Speedup strategies (#2) may involve heavy years or so in mining as highly skilled, ex- safety and health costs. Recently, a number of perienced employees. Marginal, inefficient mines have adopted cash bonus systems mines will probably close if coal prices whereby a miner can receive extra income if a stabilize and big companies expand. New big tonnage quota is exceeded. One union official mines with high productivity rates will open; in the United Kingdom, where a similar plan Ch. /V—Factors Affecting Coal Production and Use • 155 was begun in 1977, reported a 50-percent in- tional energy policy. Increasing coal produc- crease in fatalities at mines that switched to tion is related to— but is not necessarily the the incentive plans. The American experience same as — raising productivity, Each objective with these plans is too recent to assess. Some entails a different set of economic and social U.S. plans tie the cash bonus to both safety implications. Price, for example, affects pro- (defined as disabling injuries) and productivity. ductivity and production differently. High coal Clearly, this is a commendable approach. But prices lower industrywide productivity but the plans may encourage miners and manage- raise production; low prices do the reverse. ment to undercount i n juries i n order to pre- Federal policy has yet to specify the desired serve the bonus payoff Even plans that tie pro- blend of production and productivity. Private duction to safety ignore possible health costs. policy, if the 1978 UMWA-BCOA contract is If miners work faster at producing coal, they any indication, appears to have shifted toward may take less time to maintain workplace con- productivity enhancement as a way of increas- ditions that protect their health. As there is no ing production. Before decisions are made that way to measure a worker’s immediate respone commit Federal policy to either direction, ma- to increased dust or noise, bonus plans may be jor research is needed into the relationships encouraging workers to buy short-term extra among productivity, safety and market condi- dollars in return for their long-term health. tions on a mine-by-mine basis, together with a re-evaluation of productivity measurements Investing capital for greater productivity (# themselves. Most Federal research personnel 3) can take two forms. First, a mine operator do not feel that a radical technological break- may upgrade his mining system by replacing through— something like in-situ combustion existing machines with newer, more efficient for power generation or a surface-controlled, models. The costs and benefits of this invest- automated underground mining system — are ment — in productivity, health and safety— are in the offing. If it were, Federal and local of- generally well-known. A second form of pro- ficials would face the social dislocation of ductivity investment is the purchasing of a new thousands of unemployed miners and possibly product that has recently been commercial- the economic devastation of hundreds of coal ized. The productivity advantages of new tech- mining communities akin to that of the 1950’s nology are usually more easily estimated than and 1960’s. The state of coal mining technol- any possible health and safety costs. Congress ogy is such that production can double or tri- stated clearly that one of the purposes of the ple without any major technological innova- 1969 Act was “ . . to prevent newly created tions. Specific aspects of the mining cycle can hazards resulting from new technology in coal benefit from technological innovation, but mining. ” The industry is aware that new tech- viewed as a whole, no compelling or urgent nology sometimes may increase productivity need exists to commercialize new technologies at the expense of safety. Joseph Brennan, presi- to meet anticipated production goals, dent of BCOA, noted that “any new mining technology developed to aid in boosting productivity should also incorporate safety as one Restructuring the production process and of its key features.”74 It is likely that the safest better training and education (#4) may offer productivity strategy would be one that re- the most promise for productivity improve- moved the most workers from the workplace, ment over the next decade. Little research and but the unemployment implications of this ap- experimentation has been done on better ways proach would be immense. of organizing work and managing production crews. Similarly, little attention has been given Although rising productivity brings eco- to determining the most effective safety and nomic benefits to management and labor, job training and education programs. Both effi- greater production is the primary goal of a na- ciency and safety are Iikely to increase in relation to the relevance of their training and the 74’’Productivlty and the BCOA, ” Coal Age, july 1975, p involvement miners feel they have in its prac- 97 tical application. 156 ● The Direct Use of Coal

WATER AVAILABILITY

Water is an essential resource for almost all ● removal of water-using natural vegeta- phases of energy development. The avail- tion. 75 ability of sufficient water to meet energy None of these alternatives is applied univer- needs is more than a function of the presence sally; some have potentially undesirable side of large quantities of water; it depends on the effects. Crop switching depends on available political acceptability of using the physically markets and proper farming conditions. Re- available supply, the economic competition moving marginal lands from production can from other users, the legal system controlling lead to unemployment and other social prob- water rights, environmental factors, and other lems. Natural vegetation (“phreatophyte”) i nfIuences. removal can harm wildlife habitat and erode Irrigated agriculture is the major consump- affected lands. tive water use in the United States. Most agri- A major policy problem is that incentives to cultural water is consumed west of the Missis- conserve agricultural water have been so low sippi. Improved irrigation efficiency can re- that minimal research and analysis have been duce consumptive use of water, with a portion done to illuminate the tradeoffs among alter- of this savings made available to the energy native water use policies. This lack of knowl- sector in the West. The SoiI Conservation Serv- edge, coupled with extreme resistance to any ice (SCS) estimates that in a dry year 195 mil- change in water policy, has hampered intel- lion acre-feet of water is diverted for irrigation, ligent reform of water management practices of which 103 m i II ion acre-feet of depletion is for agriculture. charged to irrigated agriculture. Of this, 78 million acre-feet (76 percent) is consumptively Meanwhile, without management reform to used by the growing crop and the remaining 24 make water more readily available, the energy miIIion acre-feet is lost to “incidental” causes. industry can afford to pay far more for water than a farmer can. In the Western States, some SCS estimates that, by the year 2000, 8-mil- owners are selling their agricultural land and lion acre-feet of the water that is presently its associated water rights for coal mining and “lost” each year can be salvaged by improving energy development. If this process of convert- irrigation efficiency. (A bonus of improved ef- ing agricultural land and water resources to ficiency would be a 48-million acre-feet reduc- the energy sector continues and accelerates, it tion in withdrawals and a similar reduction in may become an important political issue in the return flows, yielding a substantial improve- West. It seems improbable that State government in water quality. ) Depending on its loca- ments will allow wholesale replacement of tion, part of this water could become available agriculture by energy. It is clear, however, that to energy developers. However, agriculture the heavy subsidies paid to marginal farmers pays such a low price for water ($I5 to $40/- by selling them water at a small fraction of ac- acre-foot) that little incentive exists for its effi- tual costs is a very expensive policy. cient use. One possible compromise would be to es- Besides improving irrigation efficiency, a tablish a partnership between farmers and the number of other agriculture water conserva- energy sector with the cooperation of the State tion alternatives exist, including: governments. The energy sector could finance water conservation measures and use the ● crops witching (from water-intensive water that is saved. Although cost estimates crops, such as alfalfa, to less intensive are unavailable, the cost seems likely to be crops such as wheat, oats, and barley); considerably less than other alternatives being ● improvement of cuItivation procedures; ● removing marginal lands from produc- ‘5 S Plotkin, et al., “Water and Energy In the Western tion; and Coal Lands, ” Water Resources 13u//etin, February 1979 Ch. IV—Factors Affecting Coal ProductIon and Use . 157 considered, such as the diversion of water to two interpretations of the source of the from the Oahe reservoir in South Dakota to right. One line of reasoning argues that, with Gillette, Wyo., at an estimated cost of $700 to regard to Indian reservations created by treaty $900/per acre-foot, or the changing of technol- (or executive orders), water rights were re- ogy in electric power from wet-cooling to dry- tained by the Indians at the time of the treaty. cooling systems at an estimated minimum Moreover, the document is silent on the ques- equivalent cost of $900 per acre foot.76 tion because the Indians did not intend to transfer the water rights. The alternative view Inter-basin transfers are often hampered by holds that the water rights were in fact trans- legal and institutional complaints that have ferred, but that the Federal Government, under emotional overtones. Congress has the power its own powers, “reserved” an amount of water either to prohibit or require an interstate inter- from proximate streams to support an agricul- basin water transfer. As part of the Colorado tural existence for the Indians. In Arizona v. River Basin Project Act (Public Law 90-537, California, the U.S. Supreme Court approved also known as the Central Arizona Project Act), water allocations to various Colorado River Congress in 1968 declared a 10-year morato- Basin Indian reservations. Water quantities rium on studies on the importation of water demanded and ultimately adjudicated for ln- into the Colorado River Basin. Many questions dian reservations remain to be determined, remain unsettled on this issue. Water rights re- Whatever the amounts, the water will come off main unadjudicated for many river basins in the top of the available water in the Colorado the West—particularly in the Northwest; the River Basin, reducing the amounts remaining total allocation of water within many basins to the States for allocation to agricultural, remains unknown, and conflicts have not been energy development, municipal, recreational, settled for many multiple uses. Questions re- and other uses. main unresolved on the amount of water required for instream purposes; regional goals Ground water currently supplies about 20 have not yet been backed by local goals and percent of all freshwater used in the United policies on land use, economic growth, and States. The estimated storage capacity of aqui- population growth, making uncertain the pre- fers (underground reservoirs) is nearly 20 times diction of water requirements. the combined volume of all of the Nation’s rivers, ponds, and other surface water. Ground Indian tribes are increasingly exercising their water serves about 80 percent of municipal water rights in the West. The present confusion water systems and supplies 95 percent of rural over Indian water rights may be detrimental to needs; in all, it serves 50 percent of the Na- the planning of water and related land re- tion’s population. Irrigation accounts for more sources in general, and to energy development than half of ground water use. In many parts of in the West in particular. The key to Indian the country ground water mining (pumping water rights is a 1908 U.S. Supreme Court case water from an aquifer faster than the water in that produced what is widely known as the the aquifer is replenished) is occurring. The “Winters Doctrine. ” The case involved a dis- tendency to use saline water for energy devel- pute between Indians of the Fort Belknap Res- opment may add to the overall problem of soil ervation and non-Indian appropriators over subsidence, salt water intrusion, and the lower- waters of the MiIk River, a nonnavigable Mon- ing of the water table in many aquifers. In tana waterway. The Court held that, although many States, ground water law, Iike riparian it was not explicitly mentioned in the 1888 surface water law, is inadequate to allocate documents creating the Fort Belknap Reserva- the resource among competing users and is tion, there existed an implied reservation of unresponsive to the problem of excessive use. rights to the use of waters that originate on, The first defect results from vagueness of the traverse, or border on the Indian land, with a rule of allocation (“reasonable use”) and the priority dating from the time the treaty created second from failure of the legal system to per- the reservation. The Court’s language has led ceive that the ground water is often a com- “1 bld mon-pool resource for which there is Iittle in- 158 • The Direct Use of Coal centive to save an exhaustible supply for use percent reduction in withdrawal, but a 20- tomorrow. Any user who seeks to save it is sub- percent increase in the amount consumed. ject to having his savings captured by another The production of energy and the extraction pumper from the same aquifer. of fuels from which energy is produced constituted 27 percent of the total U.S. water In virgin or undepleted conditions it is es- withdrawals and 3 percent of total consump- timated that the average annual surface runoff tion in 1975. By 2000, mining and energy pro- or yield of the stream systems of the 11 West- duction (excluding synthetic fuels) will con- ern States totaled 427 mill ion acre-feet, institute 27 percent of the U.S. withdrawals and cluding 50 miIlion acre-feet of inflow from 10 percent of total consumption. Canada. Today, owing to the cumulative activities of man, this virgin water supply has been The geographic and temporal distribution of depleted by 83 million acre-feet of consump- the Nation’s surface waters is so variable as to tive water use annually, leaving 344 million pose substantial problems for energy develop- acre-feet or about 81 percent of the virgin ment where billion dollar localities depend on yield still unconsumed. Within this western a continuous supply of water. Rainfall varies region are large areas such as the Upper Rio widely from region to region, from season to Grande and the Gila River Basins, where the season, and from year to year. Similar varia- total annual surface water supply, for all prac- tions occur in runoff and streamflows. For ex- tical purposes, is completely consumed. In the ample, within a normal year, the ratio of max- Colorado River Basin this condition will be imum flow to minimum flow may be 500 to 1 reached when the Central Arizona project is or greater. Year to year variations in the aver- completed. The Missouri River and its tribu- age flow also are substantial. Even in areas of taries in Montana and northern Wyoming ap- high precipitation and runoff, a series of dry pear to have sufficient unused water supplies years may occur, resulting in serious drought to meet needs for the foreseeable future. The problems such as those in the Northwest from Platte River tributaries in Wyoming, and par- 1961 to 1966 and in the Pacific Northwest in ticularly in Colorado, are approaching the 1976 and 1977. saturation point in water use. The United States appears to have enough Present and projected water demands for water available to supply its most urgent 1985 and 2000 indicate, on one hand, severe needs, but there are numerous legal, institu- regional water shortages and problems, and on tional, and political constraints on its use, and many areas may have severe water shortages the other hand adequate water availability to unless concrete physical measures — restraints meet energy needs on a nationwide basis. Ac- on development, water conservation require- cording to the 1975 National Assessment of the ments, construction of additional storage, U.S. Water Resources Council, the Nation’s etc. — are taken. Some critical elements of freshwater withdrawals in 1975 from ground legal/institutional change include: and surface water sources for all purposes average about 404 miIIion acre-feet/year ● resolving the problems of Indian water (mafy). Of this amount, 125 mafy were con- rights; sumed through evaporation or incorporation ● making the price of water commensurate into products, and the remainder was returned with its cost whiIe recognizing the non- to surface water sources for possible reuse in price value to a locale of alternative types downstream locations. By 2000, total with- of development; and drawals are projected to be about 348 mafy, ● developing a cooperative, instead of com- with about 151 mafy being consumed — a 14- petitive, relationship between energy and agricuIture. Ch. IV—Factors Affecting Coal Production and Use • 159 CAPITAL AVAILABILITY

The costs of coal production and conversion lated in the industry structure will have an un- facilities have increased rapidly because of hy- predictable effect in this area. Utilities may perinflation in the equipment market and the have more difficulty raising capital for a varie- addition-of environmental protection controls. ty of reasons, which this report has not studied Coupled with the rapid growth expected, much in detail, but most analysts feel the problems more capital wilI be needed. The constraints will not be insurmountable. If necessary, a and uncertainties discussed in other sections number of different incentives could be con- wilI make financing more difficult by increas- sidered to make all the necessary financing ing overalI production costs. Nevertheless, if available. These could include tax incentives, demand for coal actually develops, financing loan guarantees, guaranteed purchase prices the new mines probably will not raise insur- for products, investment tax credits, and a mountable problems. As discussed previously more uniform application of regulatory policy. in the Industry Profile section, changes legis-

EQUIPMENT

Most studies of the potential availability of Little information is available on the condi- mining equipment to meet expanded coal de- tion of existing mining capacity and how much mands have concluded that equipment can be upgrading will be required to meet new under- supplied as needed. The one exception is the ground production targets. There are few long Ieadtime for delivery on large draglines mining equipment suppliers and most are used to strip mine Western coal. However, small; a sudden increase in demand for new these conclusions were based on the expecta- equipment would strain their ability to supply tion that much of the expansion of production the industry’s needs and they may have dif- would come from Western coals. If there is a ficulty raising the capital to expand their pro- shift toward more production from Eastern un- duction to meet the new demand. derground mines, the dragline delays may not be serious but deliveries of underground equipment could be delayed.

TRANSPORTATION

On a national scale, coal development prob- bottlenecks that do develop will tend to alter ably will not be constrained by the availability the pattern of mining, shipment, and consump- of transportation for the period under study. tion. Routes and mode choices will be adjusted Minor capacity expansions will be required by to alleviate capacity limitations, for example, 1985, and more significant ones will be needed and mining and power generation will tend to thereafter. However, transportation facilities be expanded only where transportation service can be planned and constructed within the is adequate. same amount of time as powerplants or large At the local level, however, availability of mines, so that with adequate investment and the means of transporting coal, or the electric planning, improvements wilI take place as power derived from it, will be significant. The needed, following limiting factors may serve to inhibit Rather than reduce the total level of na- coal growth in specific regions. tional coal production and use, transportation 160 ● The Direct Use of Coal

Rail also will affect regional production and market patterns and will tend to divert traffic to Some northeastern and Midwestern rail- raiIroads. roads are characterized by poor financial performance and deteriorated track conditions. Slurry Pipelines Without either public or private investment in right-of-way improvements, particularly in Ap- Slurry pipelines become an alternative to palachia, growth in mining in this region may railroads only where rights-of-way and water . . be inhibited, truck use increased, and mlne- rights can be acquired. Slurry pipeline enter- mouth power generation expanded. prises do not enjoy the power of eminent domain in many States, and opposition by rail- Western coal-producing areas are served by roads and other landowners can impede devel- railroads in somewhat better financial condi- opment of this type of facility. Also western tion, but there rail lines must be extended to coal-producing States are characterized by serve new mines. scarcity of water, which may not be made available by local authorities for slurry Highway pipelines.

Investment in Appalachian coal roads has High-Voltage Transmission also not kept up with increases in truck traffic. Installation of long-distance transmission Deteriorated roads, like deteriorated rail lines, lines generally requires Federal approval, may eventually inhibit coal production in af- which provides an opportunity for opponents fected localities. to intervene, particularly on environmental grounds. Siting powerplants to take strategic Waterway advantage of this means of transporting power may also be difficult, particularly in western Barge transportation is ultimately limited by coal-producing areas. Regulations to prevent the capacity of channels and locks, which are significant deterioration of pristine air quality constructed and maintained by the Army under the Clean Air Act and local opposition Corps of Engineers. Major extensions and im- to water use and other environmental impacts provements to the waterway system are au- serve to inhibit mine-mouth power generation, thorized by Congress; failure to undertake for which long-distance transmission generally projects as capacity limitations are reached is suited.

REGULATORY RESTRICTIONS ON COMBUSTION

Federal agencies indirectly regulate the discussed in chapter VIl. This section ad- siting of large new coal combustion facilites dresses the constraints imposed by these and directly regulate the construction and regulations on coal users; the next section operation of these facilities as well as the discusses the options available for operating disposal of combustion wastes. The principal within those constraints. constraints are imposed by the Clean Air Act; additional considerations include the Clean Facility Siting Water Act, the National Environmental Policy Act (N EPA), the Resource Conservation and Facility siting is affected primarily by the Recovery Act (RCRA), the Endangered Species Clean Air Act; other considerations may arise Act, and regulations governing the use of under the Clean Water Act, NE PA, the En- Federal lands and of navigable waters. The dangered Species Act, and regulations related legal framework of most of these provisions is to the use of Federal lands. Ch. IV—Factors Affecting Coal Production and Use . 161

The Clean Air Act is structured around Na- Nonattainment programs will impose severe tional Ambient Air Quality Standards (NAAQS) constraints not only on increased coal use but (see table 18), which are implemented through on all growth in these areas. As mentioned a variety of regulatory programs designed to above, most of the AQCRS have not attained Iimit emissions of airborne polIutants from sta- the primary particulate standards, while 15 tionary and mobile sources. Programs ap- percent have not met the S02 standards. Wher- plicable to stationary sources primarily use ever a new source would exacerbate an exist- control technology requirements and numer- ing NAAQS violation, the permit applicant ical emission limitations to regulate polIution must apply the lowest achievable emission from new and existing facilities, from facilities rate (LAER) and must secure from existing located in clean and dirty air areas, and from sources in the area emission reductions that facilities located near scenic areas such as na- more than offset the emissions from the pro- tional parks. posed facility. The cost of meeting these two Table 18.—National Ambient Air Quality Standards requirements is high, and securing the offsetting emission reductions is difficult. Conse- Averaging Primary Secondary quently, new sources are more likely to be Pollutant time standard standard located in rural areas where the NAAQS have ParticuIate matter Annual (geo- 75 ug/m3 60 uglm3 been achieved. In addition, major modifica- metric mean) tions to existing sources in nonattainment 3 24-hour 260 ug/m 150 ug/mJ areas probably would be rejected in favor of Sulfur 3-hour — — dioxide . . . Annual (arith- 80 ug/m3 — new sources in clean air areas. metic mean) “ 24-hour 365 ug/m3 — However, the Clean Air Act also includes 3-hour — 1,300 ug/m3 Nitrogen comprehensive provisions to prevent the sig- 3 dioxide . . Annual (arith- 100 ug/m 100 ~g/m3 nificant deterioration (P SD) of air quality in metic mean) 24-hour — — areas where the air is cleaner than the NAAQS — — 3-hour -. require, The PSD increments for Class I areas (usually parks or monuments, or wilderness As of 1977, 116 of 247 air quality control areas) allow the lowest increase in ambient regions (AQCRS) reported violations of the concentrations over the baseline, and thus the primary annual particulate standard while 108 fewest new stationary sources, while the Class reported violations of the 24-hour standard. I I I increments allow the greatest increase (see Similarly, 12 AQCRs reported violations of the table 19). In no event may a new source lo- primary annual SO standard while 37 reported 2 cated in a clean air area cause the concentra- violations of the 24-hour standard. These tion of any pollutant to exceed either the na- regions are designated nonattainment areas tional primary or secondary ambient air quali- for these pollutants, as shown in figures 17 and ty standard, whichever concentration is lower. 18. Many of the AQCRS that are shown as At present the PSD regulations apply only to nonattainment areas may only have localized emissions of particulate matter and SO . violations with the remainder of the AQCR in 2 Regulations for NO , hydrocarbons, photo- compliance. The States are responsible for 2 chemical oxidants, and carbon monoxide are developing control strategies for areas show- to be promulgated by August 1979. ing violations that wilI provide for the attainment of the primary NAAQS as expeditiously To obtain a permit to locate a new source in as practicable, but not later than December an area subject to the PSD regulations, the ap- 31, 1982, The State strategy must require signif- plicant must demonstrate that the source will icant annual incremental emission reductions meet all applicable emission limitations under from existing stationary sources in areas that the State implementation plan (SIP) as well as show violations, as welI as permits for the con- performance standards for new sources and struction and operation of new or modified emission standards for hazardous pollutants, sources that would exacerbate existing NAAQS and that the source will apply the best violations. available control technology (BACT). BACT is Figure 17.—AQCRs Status of Compliance With Ambient Air Quality Standards for Suspended Particulate

❑ Areas with violations

. .**. Areas with inadequate data. Status unknown

SOURCE U S Enwronmental ProtectIon Agency 1976a

determined on a case-by-case basis, taking into electric generating units of more than 250 account energy, environmental, and economic million Btu/hr heat input and coal-cleaning impacts and other costs. In addition, the appli- plants with thermal dryers) with uncontrolled cant must demonstrate, based on air quality emissions of 100 tons per year, or to any source monitoring data and modeling techniques, with uncontrolled emissions of 250 tons per that allowable emissions from the source will year. Previous regulations applied only to not cause or contribute to air pollution in sources in 19 specified categories. However, violation of the NAAQS or PSD increments. under the new regulations, only those sources The permit applicant also must provide an with controlled emissions of 50 tons/yr or analysis of the source’s air-quality-related im- greater or that would affect a Class I area or an pacts on visibility, soils, vegetation, and an- area where the increment is known to be vio- ticipated induced industrial, commercial, and lated, will be subject to full PSD review. residential growth. Sources with controlled emissions of less than 50 tons per year need only demonstrate that Under the 1977 Clean Air Act amendments, they will meet all applicable emission limita- PSD provisions apply to a source in any of 28 tions. Each SIP must include a program to categories (including fossil-fuel-fired steam assess periodically whether emissions from Ch. IV—Factors Affecting Coal Production and Use ● 163

Figure 18.—AQCRS Status of Compliance With Ambient Air Quality Standards for Sulfur Dioxide

❑ ,. Areas (n compliance

9 0 . , * n) ‘a’ Areas with violations

% ❑ Areas with Inadequate data ..- . +- Status unknown

SOURCE U S Enwronmental ProtectIon Agency. 1976a

these small, exempt sources, and from any than the allowable increment. Second, where other sources that may be unreviewed because there are several sources that are exempt from of their date of construction, are endangering the PSD requirements because of their size or PSD increments. date of construction, these exempt and unreviewed sources may capture the available in- Because the 1977 PSD provisions apply to a crements and foreclose siting for larger new wider range of sources, they are expected to in- facilities, as mentioned above, States are re- crease the costs of facility siting significantly. quired to assess periodically the emissions EPA estimates that 1,600 sources of all types from these exempt and unreviewed sources. will be subject to the permit requirements each year (as compared to 164 per year under Finally, provisions in the Clean Air Act de- the previous regulations). In addition, there are signed to protect visibility in areas primarily two situations in which facility siting probably important for scenic values, such as national will be constrained, First, PSD permits will not parks, are expected to affect the siting of coal- be available for large new sources in areas fired facilities. EPA’s regulations, to be pro- where the difference between the baseline muIgated not later than August 1979, are to re- concentration and the NAAQS already is less quire SIP revisions in order to achieve visibility 164 • The Direct Use of Coal

Table 19.—Ambient Air Increments around the quality of water necessary for a variety of uses, including public water sup- Maximum plies, propagation of fish and wildlife, recrea- allowable increase tional, agricultural, industrial and other pur- Pollutant (~9mY poses, and navigation. New facilities must obtain a permit under the National Pollution Dis- Class I Particulate matter . charge Elimination System (NPDES). The per- Annual geometric mean ...... 5 mit incorporates all applicable effluent limita- 24-hr maximum ...... 10 tions and water quality standards promulgated Sulfur dioxide under the Clean Water Act, and an applicant Annual arithmetic mean ...... 2 must demonstrate that these limitations and 24-hr maximum ...... =...... 5 3-hr maximum .~.-.-~.-..-..-ti. 25 standards will be met. In addition, if the plans for a combustion facility require any structure Classll to be built in navigable waters (such as a cool- Particulate matter ing-water intake structure or barge unloading Annual geometric mean ...... 19 24-hr maximum ~~.fi.fi.fi.fiti.ti.~ti-=ti.. 37 facility), a permit must be obtained from the Army Corps of Engineers. Corps regulations Sulfur dioxide Annual Arithmetic mean ...... 20 stipulate that no such permit may be issued un- 24-hr maximum ...... 91 til the applicant demonstrates that all other 512 3-hr maximum titi.-.--ti.-~ti--.tifiti..ti.. necessary Federal, State, and local permits, Class Ill certifications, or other authorizations have Particulate matter been obtained. Finally, if the coal combustion Annual geometric mean ...... 37 unit or any of its support facilities (such as 24-hr maximum ...... 75 transmission lines) are to be located on Federal Sulfur dioxide land, a permit must be obtained from the agen- Annual arithmetic mean ...... 40 24-hr maximum ~.~.~.-.f~.---~-.-titi-.~- 182 cy having jurisdiction over that land. 3-hr maximum ..fi..ti..-~.~tititifitifi 700 Most federally issued permits for coal combustion facilities will trigger the environmental improvement by retrofitting plants in existence impact statement (E IS) requirements of NE PA. for less than 15 years as well as by adopting a Although the E IS is prepared by the agency is- long-term strategy for progress toward a na- suing the permit, it is based on analyses sub- tional visibility goal. Proposed fossil-fuel-fired mitted by the applicant, and the length of time powerplants with a design capacity of more required to prepare the E IS depends on the than 750 MW must demonstrate that they will quality and completeness of those analyses. In not cause or contribute to the significant im- addition, before issuing a permit an agency pairment of visibility in any of the specified must obtain a certification from the Secretary areas. However, until the visibility regulations of the Interior that the faciIity wilI not jeopard- have been promulgated, it is not possible to ize the continued existence of an endangered determine their impact on the costs of, or site species. Under the FWCA, when a federally selection for, coal-fired facilities. permitted project would result in the modification of any water body (for example, reduction Additional, less significant constraints on of water flow through consumption by cooling siting are imposed by the permit requirements towers), the permitting agency must consult of the Clean Water Act, the Army Corps of En- with the Fish and Wildlife Service and with the gineers, and agencies having jurisdiction over State agency having supervisory authority over Federal Iands, as well as by the general require- fish and wildlife prior to issuing the permit. Is- ments of NEPA, the National Historic Preserva- suance of the permit may be enjoined until tion Act(NHPA) the Fish and Wildlife Coordi- consultation and coordination has occurred, nation Act (FWCA), and the Endangered Spe- and serious consideration must be given to cies Act. The Clean Water Act is structured recommendations for mitigation of impacts to Ch. IV—Factors Affecting Coal Production and Use • 165 fish and wildlife. Finally, regulations promul- not related to air quality). That is, New Source gated under the NHPA require all permitting Performance Standards (NSPS) must be met agencies to determine whether there are his- through the use of a technological method of toric, archeological, architectural, or cultural control, such as a scrubber or precombustion resources affected by the proposed action that treatment of the fuel, rather than through al- are listed in the National Register of Historic ternative fuels such as oil or Iow-suIfur coal. Places or are eligible for listing. If any of these resources may be affected, the permitting The principal coal combustion facilities for agency must obtain comments from the Advis- which NSPS have been promulgated include ory Council on Historic Preservation. I n most steam electric-generating plants of more than cases, however, historic and other sites must 250 million Btu/hr heat input, large industrial only be studied, not necessarily preserved. boilers, and coal preparation pIants (including any facility that prepares coal by breaking, Of all these requirements, the Clean Air Act crushing, screening, wet or dry cleaning, and/or wiII have the most far-reaching consequences thermal drying). The standards for these in terms of the number of sites foreclosed to sources are shown in table 20. EPA plans to an- coal combustion facilities. However, the cu- nounce new standards for large industrial mulative effect of all provisions, each with ex- boilers in 1980. tensive interagency and public participation requirements, will be to lengthen significantly Each SIP must include a procedure for the time necessary for site approval. When nu- preconstruction review of new sources to en- merous State and local permits and other re- sure that NSPS will be met. In addition, quirements are added in, this Ieadtime can be- sources that undergo a modification that will come costly. increase the kind or amount of polIutants emitted must undergo a similar NSPS review. How- ever, the provisions relating to source mod- Combustion ifications do not apply to facilities subject to a coal conversion order under the National As with siting, the Clean Air Act imposes the Energy Act. most significant constraints on increased coal Although NSPS restrictions will eventually combustion. other limitations include the apply to most boilers that could emit at least Clean Water Act and the RCRA. The Clean Air 100 tons of a pollutant per year, it will be Act affects coal combustion through standards several years before these regulations are proof performance for new sources and through mulgated. Meanwhile, smalI boilers are reg- the provisions related to nonattainment areas ulated only by State and local authorities and and the prevention of significant deterioration. do not require a Federal permit. A utility could Standards of performance for new or sub- be concerned that a number of small units stantially modified facilities establish al low- could start up between the time of a power- able emission limitations for those facilities plant’s permit application and the time of per- and require the achievement of a percentage mit award and make it impossible for the plant reduction in emissions from those that would to operate without violating air quality restric- have resulted from the use of untreated fuels. tions. For example, six 250-million Btu/hr Under the 1977 amendments to the Clean Air boilers, each burning 50,000 tons of 3 percent Act, these standards must reflect the degree of sulfur coal (without control) can release the emission limitation and the percentage reduc- same amount of S02 as a large powerplant tion achievable through application of the best burning 2 million tons of the same coal with technological system of continuous emission 85-percent control. Because small coal plants reduction that has been demonstrated ade- can be ordered as package units with short quately (taking into consideration the cost of delivery schedules, this scenario may be achieving the reduction and any health and en- plausible. The Clean Air Act requires the States vironmental impacts and energy requirements to monitor small sources to prevent them from 166 • The Direct Use of Coal

Table 20.—New Source Performance Standards

Pollutant Particulate matter Sulfur dioxide Nitrogen dioxide Emission Emission Emission Emission Emission Emission Source limitation reduction limitation reduction limitation reduction

Coal-fired steam 0.03 lb/10 6 Btu 99 percent 1.2 lb /106 Btu 85 percent 0.60 lb /106 Btu 65 percent generator and 20- percent opacity Coal Preparation: Thermal dryer gases 0.031 gr/dscf and 20- percent opacity Pneumatic coal- 0.018 gr/dscf cleaning equipment and 10- gases percent opacity Other 20-percent opacity

“using up” available air quality increments, final NSPS regulations. Under most circum- but State enforcement programs may, in some stances, the proposed full-control requirement cases, have difficulty complying with these re- would achieve the greatest reduction in SO2 quirements. emissions, but would increase the amount of EPA’s proposed regulations under the 1977 scrubber sludge from approximately 12 miIIion NSPS provisions have become controversial. metric tons dry basis under the previous NSPS The principal issue is whether a plant burning to around 55 million tons in 1985. A full- low-sulfur coal should be required to achieve control requirement would promote the use of the same percentage reduction in potential locally available, higher sulfur coals, especial- SO, emissions as one burning higher sulfur ly in the Midwest, and discourage the use of coal. E PA’s proposed regulations for steam more expensive low-sulfur coals. Partial scrub- electric-generating units set forth a full or bing would reduce flue-gas desulfurization uniform control requirement regardless of the (FGD) costs and permit the bypassing of a por- sulfur content of the fuel, but with a 3-day-per- tion of the flue gas and thus alleviate the need month exemption from the percentage reduc- for plume reheat and associated energy costs. tion to accommodate high-sulfur Midwestern Full scrubbing would delay the construction of coals. Alternative proposals considered by new plants causing existing coal- and oil-fired EPA include a sliding-scale standard under plants to be utilized more than they would which the required percentage reduction de- have been without the proposed standards, cIines proportional to the sulfur content of the thus causing an increase in emissions from ex- coal, and monthly, rather than daily, averaging isting plants in the short-term future that of the percentage reduction requirement. In would partially offset reductions achieved by addition, the General Accounting Office new plants. (GAO) has recommended that EPA continue to The provisions of the Clean Air Act related allow supplementary controls until mandated to nonattainment areas and the prevention of studies of SO , sulfates, and fine particulates 2 significant deterioration (as described above) are completed in Iate 1980.77 also affect emissions from existing facilities. A variety of considerations will affect the The offset policy included in the requirements “Sixteen Air and Water Pollution Issues Facing the Na- for nonattainment areas and the availability of tion (Washington, DC.: General Accounting Office, U.S PSD increments will put pressure on existing Comptroller General, October 1978), sources to install costly polIution control tech- Ch. /V—Factors Affecting Coal Production and Use ● 167 nology. I n addition, each SIP must include a Finally, the Federal Government regulates control strategy for existing sources in order to disposal of combustion byproducts–ash and achieve and maintain the national standards. scrubber sludge— under RCRA. The Act establishes guidelines for the identification, trans- The Clean Water Act imposes effluent lim- portation, and disposal of hazardous and non- itations on quantities, rates, and concentra- hazardous solid wastes. The extent to which tions of chemical, physical, biological, and RCRA will constrain increased coal combus- other constituents that are discharged from tion is unclear until all final regulations have coal combustion facilities. Limitations have been promulgated. However, a preliminary in- been established for total suspended solids, oil dustry analysis indicates that both ash and and grease, copper, iron, hydrogen-ion concen- sludge meet at least one criterion for the tration (p H), free available chlorine, and “hazardous” designation. 78 If either were materials used for corrosion inhibition in- listed as hazardous it would have to be dis- cluding zinc, chromium, and phosphorus. posed of in accordance with a State plan, and These limitations are implemented primarily the generator of the waste would be subject to through NPDES. As mentioned above, a facil- extensive record keeping provisions. If both ash ity may be issued an NPDES permit for a dis- and sludge were listed as hazardous, RCRA charge on the condition that it will meet al I ap- could prohibit the use of sludge ponds, in- plicable water quality requirements. However, crease the cost of waste disposal by as much as these Iimitations are not as difficuIt to achieve 84 percent, and foreclose the sale and/or use of as the air quality standard, and the necessary the wastes either directly or by making them controls do not add significantly to the cost of noncompetitive with raw materials. a coal combustion facility.

COMPLYING WITH THE CLEAN AIR ACT

The three major strategies for complying opment. The environmental costs and benefits with the provisions of the Clean A i r Act are ap- of applying it are discussed in chapter V. propriate siting, pollution controls, and new combustion technologies. The range of pollu- The FGD Controversy tion controls and combustion technologies avaiIable to minimize emissions from coal con- The recent history of FGD has been one of version are summarized in table 21. substantial disagreement between EPA and the utility industry over reliability, secondary ef- Theoretically, complying with Federal emis- fects, and costs and benefits of scrubbers. sion restrictions should not be a problem. EPA Most, though not all, of the operating FGD sys- is supposed to set the restrictions for new tems have experienced rather severe operating plants on the basis of demonstrated BACT. difficulties such as scaling of calcium sulfate BACT for control of particulate and NO, on scrubber surfaces, corrosion of operating emissions is relatively noncontroversial, al- parts, erosion of stack liners, and acid fallout though more stringent control measures could around the powerplants. Lime/limestone sys- be enacted in the future. SO emission control, X tems, the technologies that have been ordered however, is a matter of acrimonious dispute. by most powerplants, produce large quantities The proposed NSPS for S0 requires all new x of calcium sulfite sludge that, unless specially coal-fired powerplants begun after September treated, has poor structural strength (and thus 1978 to use continuous technological controls, does not provide a stable foundation) and rep- For the immediate future, this is in essence a resents a potential water pollution problem. requirement for FGD. This technology is de- FinalIy, the forced installation of FGD wilI cost scribed in chapter I I 1. The controversy sur- 78 The Impact o! RCRA (Public Law 94-580) on Utility rounding its technological adequacy is ana- Solid Wastes (E Iectrlc Power Research Institute, E PRI lyzed here along with alternatives under devel- FP-878, TPS 78-779, August 1978) 168 ● The Direct Use of Coal

Table 21 .—Applicability and Status of Pollution Control Technologies

Applicability Pollutant reduction Residential Pollutants and efficiency and control technology (%) Utility Industrial commercial cost

so2 Mechanical beneficiation ...... 20-40 Current Current Current Low Low-sulfur coal ...... Varies Current Current Current Variesa Flue-gas desulfurization (FGD) ...... 85-95 Current Current (large Not suitable for High installations) small boilers. Fluid bed combustion (FBC) ...... 80-90 1985’ Very near term or Not evaluated Low to current moderate Chemical coal cleaning ...... 40-60 Post-1 980 Post-1 980 Post-1 980 Moderate to high Solvent-refined coal ...... 70-90 Post-1 980 Post-1 980 Post-1 980 Moderate to high Coal gasification Low BTU ...... 90–95 Post-1 980 Post-1 980 (larger Probably not Moderate to (preferable for units) or industrial applicable high new units) parks. except in commercial centers High BTU ...... 90-95 Post-1 980 Post-1 980 (highly Post-1 980 High to very applicable) (highly high applicable) Coal liquefaction ...... 90-95 Post-1 985 Post-1 985 Post-1 985 High Coal-oil slurry ...... varies 1980 1980 Probably not Low applicable Magnetohydrodynamics (MHD) ...... 90 Post 1990 Nonapplicable Not applicable FGD combined with mechanical beneficiation ...... 85–95 Current Current (large Not suitable for Moderate to installations) small boilers high

NOX Combustion modification ...... 20-80 Current for Current Partially Low some units applicable Flue-gas denitrification ...... 60-95 Post-1985 Post-1985 Not suitable for High small boilers

Particulate inertial devices .-.~~=~-ti~-fi.-.-~~fi~fi.. 90 Current Current Low Electrostatic precipitators ...... 99 Current Current Moderate to high Fabric filters (bag houses) ...... 99 Current Current Moderate to high Scrubbers -.-....=.=..~.-.fi.....fi . .. Current Current a when western low-suff~r coal is used at thesource, the costlslow bTvA(spresenfly plann[ngfora FBC powerplantwhtch Is expected tocome Onlmeln 1985 c Strictly speaking this IS not a sulfur oxide control technology, but rather a technology to utdue coal m boders designed foroti wfih mmlmal changes m boflerdeslgn If a hlghor medium sulfur coal IS used, then the S02em@lons WIH be higher than Ifod alone were burned billions of dollars over what would have been a serious ecological problem in the Northeast. required under the old NSPS, as well as several Finally, EPA claims that the issue of sludge percentage points in lost electrical conversion disposal is more of an enforcement and cost efficiency. Industry will acknowledge no sig- problem than a technological one; that tech- nificant benefits from such an investment. On niques for stabilizing the sludge have been the other hand, EPA can point to smoothly run- demonstrated; and that the volume, although ning FGD units in Japan as well as a steady im- extremely large in absolute terms, is not dis- provement in scrubber reliability in this coun- proportional to the volume of fly ash that the try as counterweights to the industry’s reliabili- industry has been handling for many years. En- ty arguments. In addition, EPA can point to the vironmentalists who either support EPA’s posi- role of S02 as a precursor of acid rain, which is tion or who want stricter standards, point to Ch. IV—Factors Affecting Coal Production and Use ● 169 the possibility, strongly disputed by the in- isting boilers, although this situation should dustry and by many in the health community, change within the next few years with the con-

that further controls on SO2 will lower mortali- struction of new plants, which must comply ty rates (see Health Effects, chapter V). with the percentage removal requirements stipulated by the 1977 Clean Air Act amend- The level of controversy over these issues ments. has become so intense that it was felt necessary to add a discussion of the technological Although EPA and the utility industry would arguments over the problems of FGD. The agree that most of the existing scrubber

health and ecological effects of SOx are dis- systems have encountered operational prob- cussed in chapter V, as are the mechanics of lems, their viewpoints then diverge widely. disposal and the potential environmental prob- What follows is a simplified, abbreviated sum- lems associated with the sludge. The various mary of the major EPA and industry arguments FGD systems are described in chapter I I 1. about scrubbers. Note, however, that the utility industry is hardly a monolithic structure, FGD Status and thus the summary “industry argument” shouId be interpreted accordingly. Some seg- The first FGD instalIation was made i n ments of the industry have found scrubbers to England in the 1930’s (the Battersea A power- be the best alternative for their plants and are plant, a 228-MW unit using alkaline Thames trying to make them work well, River water as the scrubbing medium). In 1968 the Union EIectric Meremac Unit became the The Industry Viewpoint first U.S. commercial installation, using dry limestone injection in the boiler followed by As electric power demand grows, constraints wet scrubbing Between 1968 and 1972, five on capacity growth will demand high levels of utilities had installed this type of system, but reliability for individual units. The industry al I encountered operating difficulties in the contends that scrubbers are unreliable and form of plugging of boiler tubes, low removal their use endangers the system reliability of efficiency, and interference with particulate the powerplants they serve. They take the view colIection efficiency This technology is no that virtually every scrubber that has been in- longer sold, and the five original systems are stalled on a major unit in the United States has either shut down or being converted to other had severe operating difficulties and major systems. This record, along with operational shutdowns. I n many cases, these shutdowns difficulties with newer scrubber systems, has wouId have forced reductions in boiIer capaci- created the basis for years of arguments and ty except for the utility’s ability to bypass the controversy between EPA and the utility in- scrubber, New EPA regulations, if approved, dustry. wilI eliminate these bypasses. EPA points to a few smoothly operating scrubber systems, but As of March 1978 there were 34 operating the industry counters that in every case these FGD systems, totaling 11,508 MW, 42 systems systems have unique properties that avoid under construction (17,741 MW), and plans for problems that most plants have to face. In installation of 56 other units (27,230 MW), Of some cases, this “smooth” operation is due to the systems installed since 1968, EPA counts 15 almost continuous maintenance, such as night- (all “demonstration units”) as having been ter- ly cleaning of the unit, which the industry does minated. 79 With only a few exceptions, utilities not feel is practical or reasonable for the have chosen direct scrubbing with lime or average plant. limestone as the scrubbing medium, Most of the new systems have been retrofitted to ex- Case studies of individual plants illuminate these problems (for more detailed descriptions 7“’Summary of the Opera blllty of FGD Technology” of actual operating experience at a number of (Washington, D C U S Fnvlronmental Protection Agen- plants from an industry perspective, see ap- cy, Office of Energy, Mlneral$, and Industry, Sept 14, pendix V of volume I l). For instance, the South- 1977) west plant (Springfield City UtiIities), with 200 170 • The Direct Use of Coal

MW of scrubber capacity, started up in April ciency can be achieved, the problem of 1977. Operation has been poor; only one of the achieving high levels without incurring ex- two scrubbers has been kept in service. The cessive costs becomes very complicated operating scrubber is only 60-percent reliable, for the high removal levels that may be re- with problems such as: (1) mist eliminator plug- quired by EPA. The major complicating ging, (2) corrosion of dampers, (3) failure of the factors include the wide variety of scrub- lining materials in the scrubber duct work and ber types and selection of type and stack, and (4) damage to nozzles and pumps amount of absorbent. from foreign material in the Iimestone. Wet-dry interface deposition: Drops or Another problem is that, due to a lack of slugs of slurry become detached, splash reheating for the cooled gas coming from the back into the gas stream, and stick to sur- scrubber, acid fallout around the plant has oc- faces. curred. Another plant, the 830-MW Mansfield Plugging and scaling of mist eliminators. powerplant (Penn Power), ran well for its first Gas reheat: The requirement to reheat the year of operation because of the ability to cut scrubber gas to increase its buoyancy re- boilers back and thus maintain the scrubbers, quires several percent of the total plant but it was reduced to half capacity after output. failure of the stack liner, a problem that has Corrosion/erosion: Especially due to the occurred elsewhere. Operation of this plant chloride concentrations in the scrubber has been said to be simplified because its liquids. Failure of the stack lining is a ponded wastes are being discharged to the common problem, as are plugging, ero- river rather than recycled. This has been said sion and corrosion of the reheater. to reduce scaling problems because the con- In short, industry feels that a commitment to centration of dissolved solids in the scrubber FGD is premature because the technology circuit is kept low. creates problems that are substantially more As noted above, some of the better exper- severe than those utilities have historically had iences with scrubbers are felt by the industry to face, the units require maintenance and to be unique and inapplicable to general ex- system debugging of a kind and intensity the perience. For example, Paddy’s Run (Louisville industry has heretofore been spared, and the Gas & Electric) has received special attention reliability of the units is seen as unacceptably because it operates reliably and is quite effec- low or unproven. tive in SO2 removal. However, critics point to a Beyond technological problems, however, number of factors that raise questions about the industry has severe economic problems the validity of extrapolating the Paddy’s Run with scrubbers. They are the most capital-in- design to larger installations (the units are only tensive controls it has ever been asked to in- 35 MW each). The operation is said to be stall — in an industry that is currently under- atypical because the plant has a low load fac- going capital shortages. The industry is being tor. Moreover, unlike other installations, the asked to increase its power costs by as much as unusually low-chloride content of the coal re- 15 to 20 percent even when no ambient air duces problems associated with chloride build- quality standards or PSD increments are being up in the scrubber. Finally, the lime employed threatened. Moreover, where control of exist- by the system is a byproduct that is not ing plants is required, the industry is almost generally available and appears to have forced by the nature of its regulatory system to unique properties that provide better opera- prefer increases in fuel costs (i.e., switching to tion than standard Iime. low-sulfur coal) to installing capital-intensive equipment. While general rate increases usual- Some of the major scrubber problems iden- ly involve a lengthy hearing procedure, fuel ad- tified by the industry are: justment clauses in many States allow the util-

. Achievement of high SO2 removal effi- ities to recoup immediately the cost of a fuel

ciency: Although high SO2 removal effi- switch. Ch. IV—Factors Affecting Coal Production and Use ● 171

The EPA Viewpoint the United States, In fact, some of the systems were designed and installed by U.S. EPA justifies its very strong support for FGD systems despite the severe operating problems vendors. E PA can point to the Japanese experience as one where basically the by the following points: same physical problem existed, but where ● The industry, in its description of a completely dissimilar industry attitude “problems,” is said to ignore the pro- (one of commitment to scrubber success), gressive improvements both in debugging recognit ion of the need for careful existing scrubbers and designing new maintenance and chemical expertise in ones. EPA concludes that the perform- operation, and a conservative attitude ance of utility FCD systems has consist- towards design, materials, and contractor ently improved over the last 5 years, that accountability led to an extremely suc- many of the problems described in the lit- cessfuI scrubber-based control system. erature either are essentialIy solved or are ● Utility industry shortcomings (EPA con- more in the nature of startup problems re- tends) are a major cause of FGD prob- quiring differing degrees of “fine-tuning” lems: at each instalIation. Features of the newer – Utilities’ tendency to select the lowest systems (improved mist eliminators and bid regardless of vendor experience or reheaters, a trend toward open scrubber system design. types, high scrubber liquid to gas ratios, — Inexperience in dealing with complex improved materials) and newer systems chemical processes, and unwillingness (double alkali, magnesium oxide) should or inability to hire trained operating prevent many of the operational problems and maintenance personnel. of the past. EPA asks that the viability of ● EPA notes that FGD units can build in re- its FGD requirements be judged on the dundancy, allowing a more intensive basis of what designers can achieve today maintenance program and compensating and in the future, rather than on the basis for any unexpected failures. This trans- of units that were designed several years lates a reliability problem into an ago and that were often improperly economic one. operated and maintained. ● The Japanese experience with FGD is fre- Although EPA is concerned about the sub- quently cited as an indication that FGD in stantial economic impact of scrubber require- this country could achieve far higher reli- ments, E PA’s viewpoint is different from that ability if more optimum designs and more of the industry. EPA is much more likely to intensive maintenance programs were consider the public at large rather than utility utilized, Japan has five exemplary coal- shareholders as its major “cons tituents,” and fired facilities operating at greater than thus will not automatically prefer a strategy 90-percent removal efficiencies and 95- that will raise operating costs over capital percent operabilities. All are greater than costs as the industry does. Second, EPA must 150 MW in size, and four burn 2 to 2.5 per- respond to the wording of the 1977 Clean Air cent sulfur coal. A recent interagency re- Act amendments, which stipulates the use of port on these scrubbers80 notes their ex- technological controls for power production. tremely high operability (degree to which the scrubber is used when the boiIer is op- Interpretation erating) and performance, while also con- The substantial improvements in operating cluding that their operating conditions are experience of scrubbers in the United States, not at all dissimilar to those applicable in the availability of new designs and new and improved systems, and the excellent operabili- ‘OM A Maxwell, et al , Sulfur Oxides Control Technology in )apan, report prepared for Henry M ty of the scrubbing systems on Japanese coal- jackson, Chairman, Senate Committee on Energy and fired powerplants represent substantial evi- Natural Resources, ) une 1978 dence that FGD is both a perfectible technol- 172 ● The Direct Use of Coal

ogy and one that U.S. powerplants can install control efficiency to 75-percent removal is al- with reasonable confidence that high levels of lowed for a maximum of 3 days per month. Al- reliability can be obtained. though all of the existing Japanese coal-fired plants meet these requirements, recently de- The experience at the La Cygne (Kansas City signed U.S plants have not been required to Power & Light) powerplant illustrates the im- meet them and have not met them. It would be provement that has occurred with experience naive to expect that the problems associated in scrubber systems. The scrubber, which is with scrubbers will evaporate even when (and designed to remove 80 percent of the SO, and if) U.S. powerplants are asked to satisfy the most of the particulate matter from a very EPA standards. U.S. coal characteristics, utility “dirty” coal (5 percent sulfur, 30 percent ash), operating practices, and plant conditions vary was installed in June 1973 and initially ex- enough to ensure that each scrubber will re- perienced a very low 31-percent reliability. quire carefully tuned design and operation to This reliability has been gradually increased attain satisfactory performance. U.S. utility over the past several years with experience in operators must emphasize conservative de- proper operation and the appropriate mate- sign, extremely carefuI and constant mainte- rials to use in critical components. The current nance, use of trained operating and mainte- reliability is 92 to 93 percent, and the manager nance personnel, and pressure on FGD ven- of the plant sees no reason why this level dors– just as the Japanese and the successful should not be maintained or improved in the a U.S. operators have. To the extent that utilities future. ’ This experience also is being applied do not take these requirements seriously, they to scrubbers now being designed. The signif- invite scrubber breakdowns and consequent icance of this experience is that many of the loss of system reliability. At the same time, problems described by the industry are impor- EPA should share the responsibility for ensur- tant only in a historical context, or in the con- ing scrubber success by acting in a watchdog text of understanding the problems that can capacity over vendor design and installation develop if utmost care is not taken in equip- and utility operations. EPA must take an ex- ment design and maintenance. tremely vigorous position in disseminating its The Japanese experience, as EPA claims, ap- substantial experience; at a minimum, it pears to indicate that the major FGD problems should sponsor a series of courses or seminars are avoidable. Although many in the utility infor utility personnel who are responsible for dustry continue to challenge the applicability ordering FGD systems, to assist them in select- of this experience to the U.S. situation, the ing systems appropriate to their needs. evidence indicates that the two most visible In conclusion, existing evidence points to criticisms — that the Japanese success has been FGD as a viable technology, albeit one with re- with oil-fired plants, and that their scrubbers maining problems. I n most situations, scrub- run in an open loop mode that is inapplicable bers should be able to obtain sufficiently high to U.S. utilities— are, respectively, no longer levels of both control efficiency and reliability true and incorrect. Although the highest sulfur to satisfy EPA and utility requirements. Some coal used in the Japanese facilities is only the doubt remains about satisfying EPA require- equivalent of a 3 percent sulfur Midwest or ments for very high-sulfur coals, and both DOE Eastern coal, the La Cygne experience indi- and the Utility Air Regulatory Group (UARG) cates that the problems of scrubbing very high- have expressed concerns about the need for suIfur coal are not insurmountable. scrubber bypass capability for plants using

The EPA proposal for an NSPS for S0x con- these coals. trol of utility boilers asks for an 85-percent Given the technological viability of FGD, reduction in SO2 emissions determined on a 24- hour daily basis for most coals. A reduction in there remains the critical question of its costs. Present estimates range from $80 to $120/kW ‘ l Personal communication with Mr Cliff McDaniel, out of a total plant cost of about $800/kW. Dec 4,1978 Some utilities report higher FGD capital costs Ch. IV—Factors Affecting Coal Production and Use • 173 wilI be necessary to achieve adequate reliabili- sufficient sulfur removal to affect FGD designs ty, DOE and EPA estimate the cost of the EPA significantly. If 30 percent is removed in clean- NSPS proposal by 1990 to be on the order of ing, FGD stilI has to remove 80 percent to meet $22 billion over and above the cost of the an 85-percent standard. However, despite its previous standard. The accuracy of these and failure to reduce significantly FGD removal re- other estimates is very much in doubt, given quirements, coal cleaning does allow a signifi- the rapidly changing state of the art of scrub- cant reduction in limestone and sludge han- ber design, the substantial degree of uncertain- dling requirements and an improved operating ty as to the degree of scrubber module redun- environment for the scrubber. FGD units are dancy that will be needed to maintain the re- sensitive to the variability of the sulfur in raw quired reliability, the uncertainty as to how coal and the presence of other contaminants risk-averse the utilities wilI be in their scrubber that may be partially removed by cleaning. For purchases and operating programs, and the ex- some new plants, this combination of front- tent to which systems other than Iime/lime- and tail-end cleaning can be economically ad- stone are used Nevertheless, the order of vantageous. EPA82 has shown that, under some magnitude of the estimate is certainly correct, limited conditions, physically cleaning the and it demonstrates how much is at stake in coal before scrubbing lowers the total cost of the current argument over NSPS. Both DOE SOX control. and UARG have proposed alternative stand- Current FGD technology may be inappropri- ards that would reduce costs substantialIy with ate for control of smalIer, intermittently op- smalI increases in emissions, However, none of erated industrial boilers. Unit capital costs rise the actors in the regulatory process appears to sharply with decreasing size, and if a boiler is have analyzed the probable air quality effects used only 20 percent of the time, capital costs of any of these alternatives. The existing alone make FGD prohibitively expensive. The analyses are based on gross emissions, which emissions standards for industrial boilers have are an inadequate measure of benefit. E PA, in not been promulgated yet. If they are similar turn, has satisfied the requirements of section to utility limitations, only the largest industrial I I I of the Clean Air Act by analyzing the units will be able to comply; until new coal “nonair quality health and environmental im- combustion technologies are developed, pact” of the proposed standard, but it has not smaller units simply will not burn coal. If these attempted an analysis of the actual en- facilities and the even smaller residential/ vironmental benefits of the SO reductions it X commercial-size equipment are to burn coal proposes to achieve. Thus, neither DOE nor cleanly in the short term, it will be possible EPA has evaluated the relative costs and only by feeding them “clean” coal and accept- benefits of the alternative NSPS options. This ing a higher level of pollution per ton than raises some interesting questions about the from utilities. adequacy and policy orientation of the environmental research programs sponsored by The list of options should lengthen con- these agencies, as well as their attitude toward siderably in the future. Fluidized bed combus- the need to attempt to balance costs and tion (FBC) is an efficient method of burning benefits. coal while simultaneously controlling SOx emissions. FBC furnaces can be smaller than Other SO Control Options conventional ones; this should lower capital X costs. The residue of ash and sulfur compound In the immediate future the only significant is dry, simplifying disposal. FBC currently is developed to the stage that some industrial- variant to the use of FGD as the total S0x control mechanism will be the use of physical size units are offered commercially. Utility- desulfurization in conjunction with the scrub- size units stiII pose substantial design prob- ber. Any sulfur removed in cleaning counts 82Coal Cleaning With Scrubbing for Sulfur Control toward the continuous removal required by (Washington, D C : U S Environmental Protection Agen- the Clean Air Act. Very few coals can undergo Cy, August 1977), E PA-600/9-77-017 174 • The Direct Use of Coal

Iems and may never offer any cost advantages The costs for U.S. construction and operation over FGD. Although the technology is ex- of this process, as well as most of the other pected to be able to meet all new emission lim- “clean” coal processes, are the major uncer- itations, the performance has not been demon- tainty. Thus, none of the processes is expected strated on a large scale. If FGD is required as to begin making much impact until the late- an add-on to FBC, as could theoretically hap- 1980’s. Chemical cleaning of coal is the only pen, there would be little incentive to under- one of the “clean” coal processes that would take FBC. The initial (and possibly sole) ap- require other control technologies in tandem plication would appear to be in industrial since none of these methods removes suffi- units. If the units now on order work out as ex- cient sulfur to comply with new NSPS. This pected (and the British experience indicates deficiency could limit its use. they will) a very rapid expansion could follow.

Low-Btu gasification is an intriguing near- NOX Strategies term development concept for utilities and in- The control techniques now in use in the dustry. A combined-cycle facility should prove more efficient than powerplants now in use, United States predominately involve combus- and the economics look attractive. Industry tion modifications. These techniques appear adequate to meet present standards without should find gasification more convenient than excessive economic penalty. Development of direct coal use. IOW-NOX burners is underway, and if suc-

Solvent-refined coal, chemical coal clean- cessful, could reduce NOX emissions still fur- ing, coal gasification (both low- and high-Btu), ther (to 85-percent control) at little cost. and coal liquefaction are processes to produce The “clean” fuel technologies remove var- coal-related fuels that are clean enough to meet emission limitations on combustion with- ious degrees of nitrogen along with the sulfur. out the addition of FGD. “Clean” fuels assure Coal gasification and liquefaction achieve that emissions limitations always are being almost complete removal. Chemical cleaning met as long as the boiler is operating, regard- and solvent-refined coal are less effective in less of load level. Those utilities that are least nitrogen removal as currently operated. favored in the capital market are relieved of FBC produces lower NOx emissions than the capital costs burden of limiting emissions. pulverized coal combustion because of its Instead, the capital burden would be on a coal- lower operating temperature and larger coal refining industry that, Iike the oil-refining in- size. The first factor reduces atmospheric dustry, can operate at constant load factor nitrogen reactions and the latter controls fuel over the Iife of the equipment. Utilities are bound nitrogen. This may prove to be a major constrained to follow the load demands of attraction of the technology. their customers, and therefore have less flexibility even when output is reduced, which in- Flue gas denitrification processes are in creases unit cost for pollution control. “Clean- various stages of development— mostly in ing” of fuel, therefore, is in some ways more at- Japan– and are designed for oil-fired units. tractive than FGD — but the economics still are Their commercial availability is not expected questionable. “Clean” fuels also are appli- for coal-fired units in the United States until cable over a wider range of boiler sizes than after 1985. These processes are considerably FGD. They provide greater flexibility in siting more expensive than combustion modifica- coal-fired units. Existing units are more likely tions. to be adaptable to “clean” fuels than to FGD. Particulate All the processes are currently under development except the Fischer Tropsch coal liq- EIectrostatic precipitators (ESPS) are the ma- uefaction technology, which has been in con- jor particulate control technology for large in- tinuous operation in the Union of South Africa. dustrial and utility boilers. They are likely to Ch. IV—Factors Affecting Coal Production and Use • 175 remain the technology of choice for utilities Control System/Fuel Compatibility burning high- and medium-sulfur coal unless a stringent standard for fine particuIates is pro- Coal-burning facilities must be designed as mulgated. Such a standard is an eventual pos- integrated systems. Thus, change in one part sibility because fine particuIates are suspected can affect others, and the switch of an existing of playing a role in health and ecosystem plant to lower sulfur coal can cause a large damage that is disproportionate to their loss to the efficiency of ESP’s. This particular weight fraction of the aerosol complex. problem can be alleviated by use of flue-gas conditioning, but other changes in control may Baghouses have recently been installed on a call for some extensive modifications. Existing few utility units, They can be efficient collec- facilities might find a conversion to baghouses tors of fine particulate (ESPs are not) and they from ESPs virtually impossible because of the do not suffer performance degradations when increased space and pressure drop require- low-sulfur coal is used, as do ESPs. Industry ment. has extensive successful experience with baghouses, but this experience is not fully appli- New plants must consider the effect of the cable to utility requirements. Thus a testing technology selected for control of each pollut- period is necessary, but there is no reason to ant on all the other controls. Thus the use of believe that baghouses cannot be applied suc- low-sulfur coal may force the use of hot side cessfuIIy to utiIity boiIers. precipitators at double the cost of a cold side ESP with high-sulfur coal.

PUBLIC CONCERN

Expressions of public concern about energy lines, and coal transportation systems. Opposi- development are relatively recent. Until the tion at first was limited to environmental mid-l 960’s, active and organized opposition to groups, but recently such diverse groups as energy projects arose primarily among proper- agriculture, labor, Indians, and local govern- ty owners over mining or combustion methods ments are acting to protect their interests when that created nuisance-like conditions. In re- they perceive them to be threatened. In the cent years, however, the increasing knowledge past, this opposition has been constructive about the effects of energy development, as because it has focused national attention on welI as the growing distrust of large institu- the problems and has resulted in remedial tions of all kinds and the general concern for legislation. For example, mine workers’ pro- environmental quality and for future genera- tests about occupational hazards resulted in tions, has led to increasing opposition to mine health and safety legislation and black energy-related projects, This opposition is not lung benefits; public protests about the en- unique in American history; in many ways it vironmental degradation from strip mining echoes late-19th century populist revolts brought the Surface Mining Control and Recla- against the railroads and other large industries. mation Act (SMCRA). However, even when I n general, individuals appear to be increasing- concerns have been addressed by legislation, ly unwilling to suffer personal and environ- opposition to coal development can continue. mental risks, especially when they feel those For example, many Appalachians continue to risks have been forced on them with few or no oppose increased strip mining as well as counterbalancing benefits, mining not covered by SMCRA.

I n order to devise more effective ways of ad- Initially, opposition to energy development dressing public concerns about coal growth, focused on nuclear power and surface mining, better ways must be devised to involve af- but in recent years the trend has been spread- fected parties in the decisionmaking process. ing to coal-fired powerplants, transmission Federal, State, and local agencies that regulate 176 ● The Direct Use of Coal energy development already have included in trostatic field make the farmers feeI their their regulations extensive interagency consul- families are being used as guinea pigs. tation and public participation procedures to Much of the conflict surrounding the line ensure that all parties to development are stems from the planning process by which the identified and their interests heard. Most route was selected. The line was routed under energy, natural resource, and environmental the 1973 Minnesota powerplant and powerline legislation provides for citizens’ suits to ensure siting legislation, which authorizes the State that the purposes of the legislation are at- Environmental Quality Council (EQC) to deter- tained. In many situations these mechanisms mine routes based on recommendations from have adequately addressed public concerns utiIities and citizens. The Iegislation precluded about coal development. I n others, however, the use of parks and wildlife areas or highway the parties have found that they lack the and raiIroad rights-of-way, thus forcing the Iine resources to articulate or substantiate their onto farmland. Alternatives such as smaller concerns in public hearings or that their decentralized powerplants built near the load recourse lies with the legislature rather than center (rather than at the mine mouth) or un- the courts. In these cases, delaying tactics and derground transmission lines were not con- civil disobedience have continued long after sidered. The cooperatives misinformed EQC the conventional mechanisms for resolving about the line’s point of entry into Minnesota, disputes have been exhausted. limiting EQC’s obligation to consider alternative corridors that might have crossed less This section examines several cases in which productive, less populated lands. public concerns have not been addressed adequately and discusses some alternate ap- Minnesota officials feel they have a siting proaches to resolving energy development dis- process that protects individual rights and the putes. It should be noted that these cases were environment whiIe assuring timely and respon- chosen because they do not fit the stereotype sible energy development. The farmers were of zealous environmentalists blocking devel- included in extensive public hearings during opment to protect scenic areas far from their the siting process, and their Iawsuits have been homes. Rather, these examples reflect disputes heard throughout the State court system. The that emerged spontaneously among people Governor and church officials tried (separate- concerned about their day-to-day quality of ly) to negotiate settlements between the farm- life and their long-term economic well-being. ers and the cooperatives through mediation. The farmers received compensation for their One of the most dramatic examples of the easements, and the siting legislation has been failure of traditional citizen involvement amended to protect farmland in future route mechanisms to resolve public concerns about selections. Yet the farmers continued to op- coal-related development is the confict over a pose the line, often using civil disobedience transmission line in Minnesota and North tactics such as standing in front of surveyors’ Dakota. The 470-mile, 400-kV direct current transits. Although they are pleased that farm- transmission line being constructed by two land will be protected in future routings, that rural electric cooperatives (United Power protection will not prevent this Iine from cross- Association and Cooperative Power Associa- ing their land. In addition, they object to the tion) will be the largest of its kind in the coun- use of heavy-handed tactics and mis-informa- try. Any high-voltage line on farmland will tion by the rural electric cooperatives to force modify field work and irrigation patterns, Iimit acceptance of plans for energy development. future land use, disrupt drainage patterns and To the energy industry such continued re- sometimes reduce the value of the land. The sistance seems not only irrational but selfish line’s extra-high, direct-current voltage may in- and irresponsible, given the role of northern volve health and environmental problems not Great Plains coal in the administration’s previously encountered. Uncertainties about energy plan. Thus, where an extensive public the potential health effects of the line’s elec- participation process was intended to produce Ch. /V—Factors Affecting Coal Production and Use ● 777 consensus, instead the participants have and plant construction workers often are not emerged from the process even more firmly en- included in community activities because they trenched in their individual and opposing posi- are perceived as transients. Those who will tions. profit are in favor of the rapid growth; lower- income groups that will not share significantly A second example of public concerns that in the community’s increased wealth are op- have not been alleviated through the tradi- posed. Long-term residents and local govern- tional mechanisms is the conflict over the ment officials, who are aware of the historic community impacts of Western coal develop- cycle of booms and busts in the history of the ment. Concern about these impacts has risen in West, are skeptical of rapid temporary growth western towns such as Craig, Co I.; Rock Spring, but do not know how to control it. Coal devel- Gillette, and Wheat land, Wyo.; Colstrip, opers, who could contribute to planned, order- Mont ; Farmington, N. Mex.; Moab, Utah; and ly growth, tend to feel that the solution must Page, Ariz, The rapid development occurring come from government. in these areas creates confIicts among long- term residents, newcomers, coal operators, Although the impacts of rapid development and utilities, primarily over changes in quality of Western energy resources and the resulting of life as well as the nature of the growth and patterns of conflict have received widespread the responsibility for its adverse impacts. Long- publicity, little has been done to resolve them term residents feel that their sense of commu- beyond conducting studies and holding public nity and continuity has been lost; coal miners hearings. Rather, the early planning processes

# .: j , . ‘ “ , , .:

Photo credit: EpA-Llocumerlca John and Bud Redding with a chunk of the sub-bituminous coal that underlies their land and some 25,000 square miles of Montana and Wyoming

44- I(I2 [) - 7 I - ,? 178 • The Direct Use of Coal

in more recently developed areas continue to none of these has been entirely successful. repeat patterns that already have proved in- Public relations campaigns present only one adequate, such as minimal company support side of a conflict and do not contribute to its (sometimes in the form of company towns that resolution. Although public meetings and hear- provide housing but little more), ineffective or ings are designed to present all sides of an misdirected government assistance, and a lack issue, those opposing development generally of local money. Little effort has been directed lack the resources to debate energy companies toward determining the region’s long-term effectively. Studies can be designed to explore comparative advantages (as opposed to rel- al I facets of development, yet they cannot ana- atively temporary, “boom and bust” growth) or lyze changes in quality of life adequately, and toward accumulating resource tax monies that they quickly become outdated. Lawsuits are could be used to promote long-term improve- costly and time-consuming and often merely ment. Unless means of adequately addressing serve to demonstrate to the parties that their these concerns are found, active and orga- relief actually rests with the legislature. Yet nized opposition could develop in small seeking new or amended legislation also can western towns slated for coal development. be time consuming and usually only affords relief in future conflicts. And while lawsuits or Opposition to Western coal development al- new legislation are being considered, uncer- ready has arisen among ranchers and farmers, tainties delay investments and increase eco- who also are concerned about their quality of nomic risks. life and sense of continuity. Many ranchers are working land that has been in their families for Although each of these mechanisms may, to three and four generations. They are proud to some extent, reach a result that favors what know that they were not pushed aside or may be termed a common good or the majori- bought out by a corporation. They also resent ty view, present-day society increasingly seeks the extra taxes that have been imposed on to protect the rights of minorities and increas- their land and their cattle to pay for coal ingly questions the definition of “common” development in neighboring boomtowns. In good. Yet an issue or conflict does not lend addition, ranchers are concerned about the itself to a simple resolution that simultaneous- uncertainties associated with reclaiming arid ly pleases both the majority and all minorities, and semiarid western land, and especially and no other traditional mechanisms are able about potential disturbances to hydrologic to respond when the minority continues to systems vital to agriculture. Yet the ranchers rebel. This is especially true when the conflict are unable to counter effectively the influence arises over ethical questions such as whether a exerted by large energy companies. Again, lit- large corporation should be allowed to exploit tle has been done to resolve these conflicts energy resources for profit without paying beyond energy companies offering more and local costs, as well as over questions related to more money to buy out ranchers, ranchers national long-term priorities, such as energy expending large amounts of time and money to versus agriculture. educate themselves about environmental and However, some of the traditional mech- energy issues and to prepare for court battles, anisms are amenable to modifications that and local government continuing to increase could eliminate or mitigate some future dis- cattle and property taxes rather than coal putes. For example, in the case of the Min- severance taxes. nesota powerline, if farmers had been given an In these and other instances of public op- opportunity for public participation in the position to coal and related energy develop- planning stages of the development–rather ment, the most common mechanisms for at- than at the permitting stage, when the coope- tempting to resolve disputes have been public ratives already had a vested interest in a par- relations campaigns, public meetings and hear- ticular route— the conflict might have been i rigs, studies, lawsuits, and legislation. resolved. Similarly, in the case of the commu- However, as is seen in the above examples, nity impacts from Western coal development, Ch. IV—Factors Affecting Coal Production and Use ● 179 tax revenues could be used to ensure that the was formed to help -settle environmental dis- affected States and localities receive an ade- putes at the national level. In the energy area, quate share of the benefits of development to the National Coal Policy project was intended promote long-term economic improvement. to produce agreements on how coal can be mined and burned without unacceptable exter- New methods for preventing or resolving nalities. In a series of meetings, leading conser- conflicts must be devised. Two recent cases vationists and executives from coal-mining that show promise are greater local control and coal-consuming industries agreed in prin- over the manner in which development occurs, ciple but not necessarily in practice on a vari- as typified by the Navajo experience, and ety of public concerns. For example, industry mediation, such as the compromises nego- accepted the principle that environmentally tiated during the National Coal Policy project. sensitive areas should be closed to mining; the The Navajo Nation owns an estimated 20 environmentalists agreed to back off from percent of U.S. strippable coal reserves. The their insistence that surface miners always Black Mesa coal mining complex, one of the must level off high walls. The environmental- largest in the world, is located on Navajo-Hopi ists also agreed that their standard delaying lands, as are major existing and planned coal- tactics in powerplant siting and licensing pro- fired powerplants. Yet Navajo per capita in- cedures are counterproductive and concurred come remains at about one-third of the U.S. in a recommendation for one-step licensing. In- average, their unemployment rate is about 40 dustry representatives agreed that the public percent, and they are becoming increasingly should be notified in advance of license appli- concerned about the air quality and other en- cations and assented to the principle that vironmental effects of coal use. The Navajos qualified public interest groups participating have indicated that in the future they will de- in mine and powerplant hearings should re- mand more favorable leasing arrangements as ceive public financial support. The two sides well as needed social and environmental ben- also agreed in principle that powerplants efits such as jobs, management training, and should be sited near the area where the bulk of pollution controls as prerequisites to energy the power would be sold, rather than at the development on tribal lands. They already mine mouth or in a remote rural area. Some of have won the right to impose a possessor in- these and other agreements may require new terest tax equivalent to a property tax on or amended legislation, but many could be im- powerplants and other energy development, as plemented privately. welI as a business activities tax. They also are attempting to institute an emissions charge The National Coal Policy project has been system in order to resolve their concerns about criticized because it did not include some of the air quality effects of coal combustion. In the parties at interest and because the par- effect, the Navajos are ensuring their participants failed to agree on all the issues. ticipation early in the planning stages of However, its example of conciliatory behavior energy development as well as ensuring that provides a model for speedier and wiser revenue wilI be available for needed social and alleviation of public concerns about energy economic benefits. development. This and other models for constructive public participation in both short- An even more promising mechanism is medi- and long-term energy planning must become ation of public concerns outside the courts, more common. Yet it must be recognized that legislatures, and bureaucracies in which devel- some public concerns about coal and related opers and parties-at-interest negotiate a com- development reflect basic value conflicts promise. For example, a group based at the rather than objections to specific projects. University of Washington has successfully me- Where these value conflicts exist, some people diated a controversy over the route and size of wi I I continue to believe their rights are not pro- a major freeway. Recently a foundation-sup- tected. Thus, in some instances, even when ported nonprofit corporation called RESOLVE energy companies make every effort to an- 180 ● The Direct Use of Coal

ticipate and address legitimate concerns and considered, opposition in the form of lawsuits to demonstrate that all alternatives have been and civiI disobedience will continue.

CONCLUSIONS

Many of the factors affecting coal produc- scenarios outlined in chapter II suggest, supply tion discussed in this chapter may limit the constraints may become significant. If these pace of coal expansion in the future. Some constraints do materialize, they are likely to be manifest themselves as temporary imped- found among the factors analyzed in this iments to production — e.g., strikes and siting chapter. disputes–while others have become ground rules within which the industry must work. A No insurmountable supply constraints now number of these factors enable coal to be pro- exist. However, Federal leasing will have to duced, but become constraints in certain cir- resume in the 1980’s for Western coal produc- cumstances. For example, coal cannot be tion to meet expected demand in the 1990’s. mined without labor, but prolonged strikes by Coal transportation systems need upgrading miners can disrupt coal supplies. Rail transport and expansion, as is being planned. Existing carries the bulk of the Nation’s coal each year, data are insufficient to determine whether in- but bottlenecks and car shortages slow down dustry structure has been or will be a con- the tonnage carried from mine to market. straint on production. I n recent years, poor labor-management relations have cut into coal The most important constraint on coal pro- production. However, as more and more coal duction has been lack of demand; it is likely to is mined in the West and from non-UMWA op- continue to be the most important for at least erations, this factor should become less impor- the next decade despite the rapid growth in de- tant nationally. Even during the 3 IA-month mand projected in chapter II. The Clean Air UMWA-BCOA strike in the winter of 1977-78, Act has been said to be a major constraint on few power shortages occurred and only 25,500 meeting national goals for coal development, workers were laid off at the height of the shut- in part because of the requisite emission con- down. Further, wildcat strikes slacked off in trol equipment. This report does not concur. 1978. Labor-management relations may either The now mandatory SO controls on new coal- X be improving or each side may be regrouping. fired powerplants obviously increase the costs of burning coal, but the evidence indicates The highest growth scenario would require that the new standards can be met. This almost all supply and demand factors to work evidence, it must be noted, is based on a out well. No new complex environmental con- relatively few plants operating for only a few trol strategies could be accommodated in all years. Hence some utilities may experience dif- probability. All the major resources required ficulties with their control equipment, espe- for production and use would have to be avail- cially if they have not made the necessary able. This situation is plausible, but it probably commitment of capital and manpower. will not occur without additional Federal Despite the burden of regulations, labor- policy actions that promote the use of coal. management unrest, transportation breakdowns, and other constraints, most operators report they can mine as much coal as they can sell.83 If coal demand grows faster than the

8JSee testimony of Stonie Barker, Jr., E B. Leisenring, Jr., and Robert H, Quenon (coal operators) before the President’s Commission on Coal, Oct 20,1978 Chapter V ENVIRONMENTAL IMPACTS Chapter V.- ENVIRONMENTAL IMPACTS

introduction ...... 183 TABLES Air Pollution Impacts ● *********8*.***** 186 Page Pollutant Emissions...... 186 22. Energy Demand Projection Used to Coal Activities Other Than Develop DOE’s’’National Environ- Combustion...... 186 mental Forecast No.1” ...... 186 Combustion ...... 187 23. Environmental Control Assumptions Sensitivity of Emission Estimates to Used to Develop DOE’s’’National Assumptions...... 195 Environmental Forecast No. 1“...... 186 Chemical and Physical Transformation 24. Gases Emitted From Burning Coal and Removal...... 196 Mine Refuse Banks in 1968 ...... ,187 AtmosphericTransport...... 198 25. Distribution of Trace Elements in Coal Health Effects...... 202 Combustion Residues ...... 194 Introduction...... 202 26. Reactions in the Atmosphere ., .,..,.197 Evaluating Health Effects...... 202 27. Some Gaseous and Particulate Effects of Specific Combustion Substances From Coal Combustion. ...205 Pollutants ...... 204 28. Nitrogen Dioxide: Levels and Effects ..209

Effects of Air Pollution on Death 29. Ozone(O3) Levels and Effects ...... 210 Rates ...... 233 30. Health Effects of Sulfur Dioxide ...... 212 Quantitative Assessments of Health 31. Health Effects of Sulfates...... 214 Damage From Future Pollution 32. Annual Projected Mortality From Coal Levels ...... 216 Combustion...... 218 Research Needs...... 21$ 33. Biological Concentration Factors for Conclusions...... 219 Selected Trace Elements in Aquatic Ecological Effects...... 220 and Terrestrial Environments ...... 227 Sulfur Oxides ...... 220 34. Acid Drainage in Mines...... 234 Nitrogen Oxides ...... 222 35. Water Requirements for Coal System Acid Rain ...... 222 Activities...... 237 Visibility Reduction ...... 225 36. Land Affected by Coal Utilization ..,.246 Particulates and Associated Trace Elements ...... 225 FIGURES Carbon Dioxide...... 226 Effects of Materials ...... 230 Page Regulations...... 230 19. Environmental Disturbances From lmpacts to Water Systems ...... 232 Coal-Related Activities...... 184 Sources, Effects, and Control of Water 20. Jurisdiction of Federal Control Pollution ...... 232 Legislation ...... 185

Coal Mining and Cleaning...... 232 21. SO2 Emission Contours—Emission Transportation ...... 237 Densities in g/m2 /year ...... 189 Coal Combustion ...... 237 22. Yearly Average Sulfate Concentrations)- Wastes From Coal Combustion...... 240 ug/m3 ...... 190

Regulations...... 244 23. Nationwide Ambient NO3 Impacts to the Land 246 Levels ug/m3 ...... ,191 Sources, Effects and Control of Land 24. National NOx Emission Densities, . . Impacts...... 246 g/m 2/year...... 192., Surface Mines...... 246 25. Flow Diagram of Sulfur Transmossion ..- Underground Mines ...... 249 Through the Atmosphere ...... 198 Regional Factors...... 250 26. Annual Concentrations of Sulfate for a Mines Wastes ...... 251 1990 25.7 Quads Coal-Use Scenario 217 Transportation and Transmission ....251 27. Regional lmpact of Acid Rainfall .. 223- Coal Combustion ...... 252 28. Heat Radiation Emitted to ..

Regulations...... 252- Space by C02 ...... f .;,. .227. Chapter V ENVIRONMENTAL IMPACTS

INTRODUCTION

Memories of the era when coal dominated the U.S. energy supply are blackened by visions of soot-laden cities, discolored streams, and scarred landscapes. Since the heyday of coal, Americans have become not only “spoiled” by the cleaner fossil fuels —oil and natural gas — but also more protective of their natural environment. They want to breathe clean air and drink pure water, and they insist that, after its resources have been removed, the land remain capable of supporting both natural ecologies and a thriving agricultural economy. Thus, if coal is to return to prominence in U.S. energy plans, its comeback must be staged under environmentally sound methods of extraction, cleaning, transportation, and combustion.

The “residuals ’’-unintended products that ness or mortality from air pollution. The ef- may affect the environment — from each oper- fects also vary in their temporal and regional ation involved in handling coal are illustrated extent— from the short-term creation of dust in figure 19. The avenues of disturbances to at a local minesite to the possible long-term the environment are abundant, and the intensi- global alteration of climate by carbon dioxide ty of even the minor disturbances will be mag- (CO,). The environmental effects of coal also nified by the large quantities of coal forecast differ from region to region, not only because by most current energy projections. The most of the unequal concentrations of coal extrac- vociferous objections to coal use have tion and combustion activities but also be- stemmed from concerns about the pollutants cause of the difference in geologic, demo- released to the air during combustion and the graphic, topographic, and climatic factors. variety of damages to land and water that re- Thus, for example, surface mining may be sult from mining. Most of these impacts are more benign in the lignite fields of Texas than now addressed by Federal legislation, as in- on the steep slopes of Kentucky. As another ex- dicated in figure 20. In general the legislation ample, the most significant impact of a coal- establishes either ambient air, land, and water fired powerplant in New England might be to quality standards, or minimum pollution con- worsen the urban air breathed by millions, trol performance standards that can be while that of a utility in Utah might be to achieved economically and effectively by the degrade the quality and visibility of the clean best state-of-the-art technology. In response to air that is a major resource in that region. the passage of this large body of environmental legislation, public attention is shifting to Figure 19 emphasizes that each environmen- questions of whether the new laws and tech- tal impact may be envisioned as primarily af- nology are adequate, whether they are effec- fecting one of the three media–air, land, and tively enforced, and whether they are them- water. This viewpoint is adopted as the organi- selves the cause of environmental problems— zational structure for this chapter, although it such as the pollution of one environmental should not obscure the very extensive interac- medium by the wastes collected to protect tions among the three media. Each of the next another. three sections examines the impacts of coal use on one of the three media, describes the Figure 19 summarizes only the byproducts resulting effects on health or ecosystems, and of coal-related activities and not the resulting assesses the ability of relevant legislation and effect on public health or on the ecosystem at control technology to mitigate these effects. large. These effects may vary in their severity — from the annoyance and property damage This chapter draws selectively on analysis of of blasting to a possible tragic increase in ill- future energy impacts available in the liter-

183 184 ● The Direct Use of Coal

Figure 19.– Environmental Disturbances From Coal= Related Activities

Polycyclic Polycyclic organic material Trace elements Radionuclides organic material Polycyclic AIR organic material I Sulfur Patiicles\ CO~ compounds t Sulfur Particles CO compounds Thermal Dust 4 / discharge Fumes from fires t Fumes from fires + nf t Coal dust II Exhaust Topsoil I Mine Waste I Plant waste +

t Erosion Flood danger

Waste disposal Industry problem LAND Barge

Slurry pipeline

Land use Home Changes and disruption, ecological displacement

ature — and especially on the 1978 National En- which assumes medium economic growth, vironmental Forecast No. 1 (NEF #l)’ —to illus- medium energy supply expansion, and con- trate the level of residuals that would be gener- stant (corrected for inflation) world oil prices. ated by future increases in coal development. The scenario assumes an electricity growth of The forecast uses a “business as usual” scenar- 4.8 percent per year, with total energy demand io developed by the Department of Energy’s growing from 70.6 quadrillion Btu (Quads) in (DOE) Energy Information Administration, 1975 to 94.6 Quads in 1985 and 108.5 Quads in 1990 (see table 22 for a more complete break- ‘1978 National Environmental Forecast No. 1, Division down of the projections). Coal use is assumed of Environmental Impacts, U.S. Department of Energy, to double by 1990 to 25.4 Quads, from 12.8 September 1978 (draft). Quads in 1975. Table 23 presents the environ- Ch. V—Environmental Impacts ● 185 mental control assumptions used to predict Iutants. This projection is similar to scenario B future emissions of the three principal air pol- in chapter II.

Figure 20.—Jurisdiction of Federal Control Legislation

AIR ,/ ,/ ./ ,/ ./ ,/ ,/./~~~~ ,/

I I ~ / I Train / I I / / " 1 ,I / LAND , I / I 786 ● The Direct Llse of Coal

Table 22.—Energy Demand Projection Used to Table 23.—Environmental Control Assumptions Develop DOE’S “National Environmental Forecast Used to Develop DOE’S ’’National Environmental No. 1“ Forecast No.1” (quadrillion Btu per year) Revised NSPS 1975 1985 1990 Industrial Industrial boilers Domestic Consumption boilers 25MWe under Oil ...... 32.8 43.9 48.5 Pollutant Electric Utilities or greater 25 MWe Natural gas ...... 20.0 19.1 19.3 Coal ...... 12.8 21.2 25.4 TSP Revised NSPS Nuclear ...... 1.8 6.2 10.3 Revised NSPS Revised .05 lbs/MM Btu Hydro & geothermal ...... 3.2 4.2 5.0 .05 lbs/MM Btu NSPS .05 lbs/MM Btu so, Revised NSPS Revised NSPS Revised (scrubber (scrubber NSPS 1.5

efficiency 89 efficiency 89 Ibs S02/MM percent) percent) Btu NO, NSPS (.7 lbs/ NSPS (,7 lbs/ None MM Btu) MM Btu) Schedule: For Schedule: For Schedule: revised NSPS, revised NSPS, For revised all new utilities all new boilers NSPS, all on line in 1984 on line in 1981 new boilers and after. and after. on line in 1981 and after.

AIR POLLUTION IMPACTS

Pollutant Emissions greater intensity in arid climates. Other sources of particulate are the construction ac- Coal Activities Other Than Combustion tivities at each stage of the fuel cycle, the transportation of coal in open hopper cars or Most concern about air emissions from the on barges, the storage of coal or coal wastes in coal fuel cycle centers on coal combustion, piles, and coal processing and cleaning. All the emissions of which can affect natural particulate emissions that include either coal ecosystems as well as human health and wel- dust or ash contain quantities of trace ele- fare over a broad region. The other portions of ments and radionuclides that may exacerbate the fuel cycle also have important impacts on the health and environmental impact of these man and nature, although these impacts tend emissions. to be confined to a more local area. Mining impacts involve primarily the fugitive dust from Additional releases can result from uncon- surface and underground mines. After combus- trolled fires at mines or within mine piles. Such tion, the dry disposal of ash or waste from flue- fires, not uncommon, may smolder for years. gas treatment produces particulate loadings In January 1973, a survey counted 59 uncon- that can be, on the site, in excess of Federal trolled fires in abandoned mines in Appalachia standards. 2 This dust problem is naturally of and 185 uncontrolled fires in unmined coal seams in the West.3 Another survey by the ‘Report of the Committee on Health and Environmerita/ Effects of Increased Coal Utilization (“Rail Report”), F. R., ‘Underground Coal Mining: An Assessment of Technol- vol. 43, no. 10, Jan. 16, 1978; “App. on Coal Ash and FGD ogy, EIectrical Power Research Institute, AF-219, July Sludges, ” U.S. Environmental Protection Agency, 1976, Ch. V—Environmental Impacts . 187

Bureau of Mines in 1968 registered 292 fires in culation to the combustible material, mini- coal refuse banks, principally in Appalachia.4 mize the concentration of combustible materi- Because such fires burn under oxygen-defi- al, and promote cooling. For abandoned mines cient conditions, they generate a somewhat these techniques may not always be possible different spectrum of air pollutants than coal- to apply. The best means of prevention is to fired boilers. Table 24 presents a crude remove the excess combustible material and estimate of the emissions of carbon monoxide seal holes where feasible. The Surface Mining (CO), hydrocarbons, sulfur oxides (S0x), Control and Reclamation Act of 1977 requires nitrogen oxides (NOx, and fine particulate that combustible materials exposed, used, or due to such fires. Other releases include produced in underground mining (including ex- hydrogen sulfide and ammonia. It is reason- posed coal seams) be treated, if necessary, and able to speculate that a significant portion of covered. The Act also requires that all open- the hydrocarbon emissions couId be polycyclic ings to the surface be capped, sealed, or organic matter, which is particularly danger- backfilled when no longer needed for mining. ous; however, appropriate data are not avail- Presumably, enforcement of these provisions able. will substantially decrease the incidence of new-mine fires. Table 24.—Gases Emitted From Burning Coal Mine Refuse Banks in 1968 Combustion Percent of total The air pollutants released in large quan- Emissions — nationwide 10’ tons emissions tities by combustion units include the oxides of sulfur, nitrogen, and carbon, as well as par- Carbon monoxide...... 1.2 1.2 Sulfur oxides...... 0.6 1.8 ticles of ash that become entrained in the hot Hydrocarbons...... 0.2 0.6 flue gases. Smaller quantities of trace in- 0.2 1.0 Nitrogen oxides ...... organic elements, radionuclides, and hydrocar- Fine particulate...... 0.4 1.4 SOURCE Natlonwlde Inventory of Alr Pollutant Emlsslons. 1968, National Alr bons are also emitted; these are often ad- Pollution Control Administration, AP-73, August 1970 sorbed on the surface of the ash particles. Once emitted to the atmosphere, most of these Development of controls for these air emis- substances may be transformed by a variety of sions has not received the attention given to chemical reactions, and all will be transported air emissions from combustion. Dust from min- and deposited under a variety of different ing operations is not always completely con- meteorological conditions. The polIutants may trolled, and may be a serious occupational react with other polIutants from the same or health problem. Coal dust from trains can be different source or with natural atmospheric avoided by covering the hopper cars if spon- components. The nature and extent of result- taneous combustion of the coal can be ing human health hazards and environmental avoided. The dust from waste disposal sites damage depend on the types and rates of reac- can be kept to a minimum by wetting agents tions in conjunction with the atmospheric and its impact reduced by a buffer zone transport and deposition, as well as the nature around the site. Dust from coal hauling usually of the “receptor” —the ecosystem and/or is controlled by watering the roadbeds. Un- human population. This discussion examines fortunately, most of these controls are not re- the emissions of each coal stack component. quired by Federal regulations, and State and The following sections discuss the transport local requirements vary widely and often are and transformation of each component. not strictly enforced. Understanding of these factors is crucial to The general techniques for prevention of predicting and mitigating the health or envi- mine or refuse piIe fires are to reduce air cir- ronmental impacts of coal combustion.

4Coal Refuse fires, An Environmental Hazard (Washing- Sulfur oxides receive more attention than any ton, D. C.: U.S. Department of the Interior, Bureau of other emission from the combustion of coal, Mines, 1971) I.C 8515 primarily because of the large quantity of 188 ● The Direct Use of Coal

emissions, the diversity of and controversy sur- years should more than balance the addition rounding the potential impacts (human health of new sources. NEF #l computes the follow-

effects, acid rain, crop damage, etc.), and the ing total SOX emissions for its moderate coal

great expense involved in SOX controls. use scenario: Coal combustion is a major source of man- 1975 ....., ...... 29.9 million tons caused sulfur emissions, and all of these 1985 ...... 28.8 million tons sources may now exceed the emission of sulfur 1990 ...... 30.6 million tons compounds from natural processes world- After full compliance has been achieved, SOX 5 wide. Estimates of the fraction of man-caused emissions will begin to creep upwards. Coal sulfur emissions range from about one-third to burning– and especially that from the electric b about two-thirds. In industrialized parts of the utility industry— plays a major part of this United States the man-caused emissions may trend. Electric utilities and industrial boilers be at least an order of magnitude greater than burning coal are projected to remain at their 7 natural emissions. present 70 percent of the total emissions Coal burning contributes more than half of through 1990. Existing coal-fired powerplants man-caused sulfur emissions and 80 percent of had 1975 emissions of 18.7 million tons; these the sulfur emitted from stationary fossil fuel will decline to about 15 million tons if full combustion. All stationary combustion compliance is achieved, then drop only as ex- sources together release 70 percent of man- isting plants are decommissioned. Utilities caused sulfur, with industrial processes run- commissioned after 1975 would have a maxi- ning a distant second.8 mum (no control) emission of 15 million tons by 1990 under moderate growth conditions;

The regional sulfur dioxide (SO2 “emissions given the strong controls listed in table 23, ac- densities” (emissions per unit area) shown in tual net emissions will be about 3 million tons. figure 21 exhibit a wide geographic variation. This imbalance between old and new source The peaks in emission density do not necessari- emissions is a critical point, because it illus- ly correspond to peaks in ambient sulfate con- trates the need to consider existing sources in centrations shown in figure 22, because of devising a national S0x control strategy. Pro- complex transport phenomena that may carry posed New Source Performance Standards pollutants far from their source. (NSPS) for steam electric utility boilers will cost tens of billions of dollars over the next Total emissions of S0x may be expected to few decades but will reduce total emissions decline slightly in the next decade if current less than 10 percent under emissions produced State implementation plans (SIPs) for air pollu- under the current standards (as projected by tion control are strictly enforced, because the the Environmental Protection Agency (EPA) effect of existing sources coming into compli- and DOE in a joint, ongoing analysis). Mean- ance with local regulations in the next few while, the major sources of S02 emissions for 5R. B. Husar, et al., “Report on the International Sym- the next several decades—coal-fired power- posium on Sulfur in the Atmosphere,” Third National plants already in existence— are allowed to Conference on the Interagency Energy/Environment R&D operate with far less control —and sometimes Program, 1978, p. 77. none. ‘E. Robinson and R. C. Robbins, “Gaseous Sulfur Pol- lutants From Urban and Natural Sources,” J. Air Pollut. Industrial coal combustion also plays an im- Assn. 20, 1970; Kellog, et al., 1972, “The Sulfur Cycle,” portant role in SO emissions. Because indus- Science, 175; and J. P. Friend, “The Global Sulfur Cycle” X in Chemistry of the Lower Atmosphere, S. 1. Rapeol (ed.) trial use of coal is expected to grow substan- (New York: Plenum Press, 1973). tially in the next few decades, the NSPS will af- ‘R. B. Husar, personal communication. fect a higher percentage of the total emissions ‘Preliminary Emissions Assessment of Conventional than is the case with powerplants. Existing in- Stationary Combustion Sources: Volume II-Final Report, dustrial plants emit about 2 million tons of GCA Corporation, GCA/Technology Division, EPA-600 2- 76-046b, U.S. Environmental Protection Agency, March SOx/year . By 1990, new plants will emit about 1976. half this amount if maximum control is as- Ch. V—Environmental Impacts ● 189

Figure 21 .—S02 Emission Contours—Emission Densities in g/m2/year

0.3

\ I /

SOURCE Report on the International Symposium on Sulfates in the Atmosphere, in EPA-600/9-78-022, Energy/Environment Ill, U.S. Environmental Protection Agency, Offfice of Research & Development, October 1978. sumed. However, final emission standards for marily of nitric oxide (NO), nitrogen dioxide industrial sources have not been established. (NO2), and small amounts of nitrous oxides.

More than two-thirds of the S0x emissions About 95 percent of the NO, of manmade occur in the industrialized Middle and South origin is emitted from fossil fuel combustion. Atlantic States and in the Midwest, both in The direct product is primarily NO, which is 1975 and 1990, although emissions will decline readily converted in the atmosphere to the in the Middle Atlantic and Midwest if existing more toxic NO2 and corrosive nitric acid sources comply with local standards according (HN03). to schedule. Substantial emission increases should occur in the Southwest and Northwest The amount of NO produced is determined as coal begins to replace natural gas as the partly by the composition of the fuel itself. dominant fuel. Coal has considerable fuel-bound nitrogen, and most of the NO produced by a normal Nitrogen oxides from coal combustion are boiler is created by the reaction of this nitro- associated with some plant damage, possible gen with the oxygen in the combustion air. NO health effects, acid rain, and production of is also produced by the high-temperature reac- deleterious secondary pollutants. Unlike the tion between the oxygen and nitrogen in air; sulfur compounds, however, man-caused this reaction is the sole NO source from the sources produce only 10 percent of total NOX combustion of nitrogen-free fuels (such as emissions (50 million tons per year compared natural gas). Coal’s high nitrogen content ex- to 500 million tons per year from natural plains the major NOX control strategy for coal sources). NOX in the atmosphere consist pri- boilers, which is to burn the coal initially in a 190 ● The Direct Use of Coal

Figure 22.— Yearly Average Sulfate Concentrations, µg/m3

SOURCE : Report on the International Symposium on Sulfates in the Atmosphere. in EPA-600/9-78-022, Energy/Environment Ill, U.S. Environmental Protection Agency, Office of Research & Development, October 1978. fuel-rich condition that promotes reduction of levels and composition is related to the quan-

NO to nitrogen gas (N2), and then to allow tities emitted, the availability of ultraviolet complete combustion after the fuel-bound light to affect chemical transformation, me- nitrogen has been depleted. teorological conditions, and the presence of other contaminants in the atmosphere. Combustion of coal accounts for 24 percent Because of the very large amounts of NOx of all NO produced by man, and about 49 per- X emitted by stationary and mobile sources, ur- cent of NO from stationary fossil fuel com- X ban areas tend to have the highest NO levels. bustion. Mobile and stationary sources con- X Figure 24 shows the ambient N0 concentra- tribute about equally to the NOx national emis- 3 tions on a nationwide basis, averaged by State. sions. Although manmade sources are only 10 percent of all NOx sources globally, they can Levels of NOX are subject to temporal as result in high local concentrations. Thus, well as spatial variation, because of the com- although the natural background for NO is X plex relationship of NO and NO2 to light inten- 3 about 8µg/m , the national standard is sities as welI as to the variation in time of emis- 3 1 OOµg/m , on an annual average, and short- sion levels from industrial and automotive term local concentrations can be much higher. sources (strong time-of-day variations have Figure 23 shows the 1973 national emissions been observed and some evidence exists for densities for NO .9 Spatial variability of NOx X seasonal variations). ‘National Emissions Report 1973: National Emissions Data System (NDES) of the Aerometric and Emissions Although NOx emissions from automobiles Reporting Systems (A EROS) (Washington, D C.: U.S. Envi- are supposed to decline in the next few dec- ronmental Protection Agency, 1976), E PA-450/2-76-O07. ades, the lack of effective controls on station- Ch. V—Environmental Impacts ● 191

3 Figure 23.— Nationwide Ambient NO3 Levels, µ9/m

2 \

. . . . .

SOURCE: “Air Quality Data for Non-Metalllc Inorganic LOSS 1971-1974 from the National Air Surveillance Networks,” Gerald G. Akland, EPA-600/4-77-003, Research Triangle Park, NC

ary sources wilI lead to a substantial increase (fIy ash) or by release of gases that are “precur- in total emissions. N E F #1 projects national sors” to the formation of secondary particles. emissions to increase by 21 percent by 1990, Secondary particulate include sulfates, ni- from 19,4 million to 23.5 million tons, reflect- trates, and particulate hydrocarbons. ing both increased energy production and a shift from gas to coal (coal combustion pro- Although particulate emissions from fuel duces more NOx than natural gas combustion; combustion sources are generally well con- although the ratio varies, it is about 3:1 for trolled, the most common control mechanisms powerplants). Coal combustion by electric util- are less efficient in controlIing fine partic- ities and industrial boilers will play an increas- ulate (those less than 3 µm in diameter). Thus, ing role in these emissions. In 1975, these proportionately more particles in this size range escape capture and are emitted. In addi- sources produced 4.6 million tons of NOX, or 24 percent of total emissions; with a moderate tion to this direct emission, most secondary growth in coal use they will produce 8.7 mil- particles (particles formed by chemical trans- lion tons or 37 percent of the total by 1990. The formation of gaseous pollutants) are also in shift in emissions away from automobiles and this size range. toward powerplants and industry should be ac- Fine particulate have a greater impact on companied by an increase in NO concentra- X visibility and are more Iikely than coarse par- tions in rural areas and possibly a slight decrease in urban areas. ticulate to become lodged deep in the lungs and to travel great distances. I n addition, Coal combustion produces particulate directly emitted fine particulate have a larger either by direct emission of primary particles surface area than an equal weight of larger 192 The Direct Use of Coal

2 Figure 24.—National NOX Emission Densities, g/m /year

SOURCE : “National Emissions Report 1973,” National Emissions Data System of the Aerometric and Emissions Reporting System, EPA-450/2-76-007, Research Triangle Park, NC

particles and thus tend to adsorb on their sur- made particulate and 90 percent of those faces a disproportionate share of the toxic ele- from stationary fossil fuel combustion sources. ments in the flue gas. All stationary combustion sources account for 36 percent of U.S. emissions, the second larg- Present regulations and measurement tech- est source after industrial processes, which niques are based on total concentrations of constitute 49 percent (NE F ##1 ). particles, which may have little relevance to their chemical or biological behavior. In rec- Because compliance with all SIPs is far from ognition of this, EPA has recommended setting complete today, total particulate emissions a standard for particulate matter of less than may decline quite significantly despite con- 15 µm, and examination of the effects of par- tinued economic growth if compliance is ticles smaller than 2 pm. Information gathered achieved according to schedule. NEF #1 pro- by this examination may provide the basis for a jects a decrease in the total emissions from new “ inhalable particulate matter” standard. 10 14.5 million tons in 1975 to 8.2 million tons in Natural sources of particulate far outweigh 1985, with a rise (to 9.1 million tons in 1990) manmade sources but are difficult to measure. thereafter that is characteristic of the assump- Coal combustion yields 33 percent of the man- tion that future controls on both existing and new emission sources will not change. Clearly, at some point controls on particulate and ‘“’’Health Effects Considerations for Establishing a Standard for Inhaled Particulate Matter, ” EPA-HERL, in- other pollutants will have to become stricter if ternal publication, January 1978 continued growth without unacceptable en- Ch. V—Environmental impacts ● 193

vironmental degradation is to occur. Also, times as great as those from utility boilers none of these projections is likely to hold for more than 500 MW, while POM concentrations fine particulate, where emissions could in- were several thousand times as great (but still crease sharply unless control strategies shift to less than 1 percent of the total hydrocarbon devices that are more efficient in collecting emissions). 2 Recent EPA-sponsored tests on a particles in this size range. 10-MW industrial boiler, on the other hand, in- The role of utilities and industrial boilers dicated that POM emissions were either zero will shrink from its present one-third contribu- or below the limits of detection of the 3 tion of total national emissions to one-fourth available equipment. There are now 12 mil- by 1990 despite the substantial shift to coal. lion tons of coal burned each year in the The major portion of these particulate is con- residential/commercial sector, presumably in tributed by coal combustion. small boilers and furnaces in populated areas. The potential of these units, and additional These trends differ substantially by region. units in the future, to generate quantities of Slight increases in particulate emissions are ex- the more toxic hydrocarbons is uncertain but a pected in New England and the Southwest, source of concern. while substantial decreases should occur in those regions that now have many noncomply- Coal combustion plays only a minor role in ing sources —the Middle Atlantic and Midwest. total hydrocarbon emission and will continue to do so in the future. In 1975, coal-fired utility Hydrocarbons from coal combustion may be and industrial boilers emitted about 70,000 divided into two main groupings, correspond- tons of hydrocarbons, only one-half of 1 per- ing to the way they are emitted. First, there is a cent of national emissions. By 1990 these volatile fraction composed mostly of low mo- boilers may double their hydrocarbon emis- lecular weight species that are emitted as sions and increase their share of the total to 1.4 vapors. Second, there is a fraction of higher percent. During this time, strict automotive molecular weight species that are emitted as controls should (if the standards are suc- fine particulate or are preferentially adsorbed cessfulIy enforced) cause a sharp decline in na- on the surfaces of fine particulate. Although tional emissions from about 14 million tons in EPA has recently increased its efforts to char- 1975 to 10 million in 1990. A notable exception acterize these emissions, little reliable in- to this sharp decline will occur in those areas formation exists on their composition. Avail- slated for new petroleum and organic chem- able data indicate that for moderate to large icals development. Thus, hydrocarbon emis- boilers (greater than about 25 MW), the vola- sions in Louisiana will increase somewhat in tile fraction (measured as methane) and partic- the next decade, while emissions in Texas and ulate fraction (measured as benzene soluble Delaware, sites of expected new refineries, will organics) are emitted in amounts of the order remain relatively stable. of only a few milIigrams per cubic meter in the flue gas. Emissions of polycyclic organic mat- Inorganic trace elements and radionuclides are ter (POM), species of which are known carcin- emitted during coal combustion in particulate ogens, are emitted in quantities considerably form or as vapors that can condense or be ad- smaller. The available data indicate, however, sorbed on the particulate in the flue gas as it that both the total hydrocarbons and the pro- cools. These elements can be divided into portion of POM to the total may increase three classes: substantially as boiler or furnace size de- 1. those that are not volatilized and thus are creases. For example, hydrocarbon concentra- either left in the slag and bottom ash or tions in the flue gas of boilers less than 1 MW become entrained in the flue gas as partic- in capacity were found to be more than 60 ulates, ‘‘N. Dean Smith, Organic Emmissions from Conven- ‘ ‘Ibid tional Stationary Combustion Sources (Research Triangle “Personal communication with Wade Ponder, U S En- Park, N C , U S Environmental Protection Agency, vironmental Protect Ion Agency, Research Triangle Park, August 1977) N C. 194 ● The Direct Use of Coal

2. those that are volatilized and are ab- “ranks,” lignite has the highest concentrations sorbed on the fly ash as the flue gas cools, of both radionuclides. This is unfortunate and because lignite is the lowest rank coal and re- 3. those that are volatilized and remain in quires the most tonnage to generate a unit vapor form (see table 25). amount of electricity. Substantial variation Those elements that volatilize and become ad- also exists between different coal deposits of sorbed are (as are the volatile hydrocarbons) equivalent rank in the same region; some Wyo- preferentially concentrated on smaller par- ming and New Mexico coals are so high in ura- ticles because, as noted above, fine par- nium (up to 6,200 ppm) that the coal is essen- ticulate offer greater surface area than an tially uranium ore. equal weight of larger particles for condensation and adsorption to occur. This presents a Total emissions of most trace elements are serious problem in controlling trace element expected to decline between 1975 and 1990, (and hydrocarbon) emissions, as conventional mainly because of increased particulate con- particulate control equipment grows pro- trols. The importance of such controls is dem- gressively less efficient as particle size onstrated by an examination of arsenic emis- decreases. sions; electric powerplants produce more than half of the gross (uncontrolled) national emis- Table 25.—Distribution of Trace Elements in Coal sions but less than one-sixth of the total actual- Combustion Residues ly emitted (NEF #1), owing to the high particulate control levels in powerplants.

NEF ##l projects future trace metal emission increases only in arsenic, cadmium, fluorine, and selenium (however, it is not clear that these projections account for increases in fine- particulate emissions); of the four, utilities and industrial combustion are the major source only of selenium. Selenium emissions are projected to increase from 1,270 tons in 1975 to 2,900 tons in 1990, nearly all from coal combustion. Although coal combustion is a substantial source of other trace elements, and its emissions are unlikely to decline much in view of the future growth of coal, controls on other sources — such as smelters —wiII drive down total emissions.

Concentrations of both trace elements and Carbon dioxide extracted during photosyn- radionuclides vary considerably among differ- thesis many millions of years ago is returned to ent coals. For instance, thorium concentra- the atmosphere by combustion of fossil fuels. tions are quite high in Pennsylvania anthracite Although CO, is naturally recycled through ab- and low in interior bituminous coal (4.7 versus sorption by plants and by the oceans, the rap- 1.6 parts per million (ppm), mean concentra- idly growing worldwide consumption of fossil tions) while uranium varies from a high (mean) fuels could lead to increased concentrations of concentration of 2.4 ppm in Gulf lignite to a CO, in the atmosphere. In fact, measurements low of 0.7 ppm in northern Great Plains in Hawaii have shown approximately a 5-per- 4 coals. Looking at different coal qualities or cent increase in COZ levels since 1958. Fossil fuel combustion facilities may be the largest 14R, I van Hook, “Appendix on Trace Elements and Ra- manmade source of this emission with coal dionuclides, Oak Ridge National Laboratory, Rail Report. yielding 11 percent more CO, than oil and 67 Ch. V—Environmental Impacts ● 195 percent more than natural gas for the same to 2000, 1,900 million tons demand by energy value. 5 By projecting worldwide uses 2000) are compared for the year 2000. of fossil fuels and by modeling CO exchange 16 Z Utility Emissions, Millions of Tons/Year processes between the atmosphere and the Mod- oceans and the biosphere, a number of studies erate High have developed estimates of atmospheric CO, SO, 140 171 (assuming 90-percent control levels over the next several centuries. Most for new plants) show peak levels in the 21st and 22nd centuries 156 207 (assuming 80-percent control). from two to eight times higher than today. NO, 95 175 However, these estimates and their projected Higher growth rates will have a maximum effects are subject to considerable uncertain- effect on those pollutants that are not ef- ty. (See C02 under Ecological Effects.-) ficiently controlled by available equip-

ment. Thus, (NOx and fine-particulate Sensitivity of Emission Estimates emissions are of particular concern in a to Assumptions high-growth situation. ● Predictions of emissions are sensitive to Environmental controls. -Most forecasts ex- assumptions about rates of growth, energy amine different versions of soon-to-be-en- technologies used, environmental controls in- acted New Source Performance Standards stalled, quality of fuels burned, and other fac- (NSPS) for steam-electric powerplants but tors. Changes in the following assumptions are assume constant control levels after en- especially important: actment. This is unlikely, as EPA must periodically review these standards. The ● State Implementation Plan compliance. - very high levels of control achieved in Virtually all forecasts of future emissions Japan for scrubbers imply that future SO, assume full compliance by 1985 with ex- emission standards may become more isting State standards. There is substantial stringent, thus lowering national SOZ pressure in many States to revise emission emissions below expected levels. Other standards upwards, especialIy for power- control variations that would affect emis- plants. The Mitchell and Kammer plants sions levels are: in West Virginia recently won adjustments —“Ful/ scrubbing” versus “sliding scale. ”

in their SOX emissions reduction require- Although national utility S02 emissions ments, and the requirements for several are not significantly different (in 1990, large plants, including Cliftie Creek in ln- 19.6 million tons versus 20.2 million diana and Labadie near St. Louis, Me., are tons) for the EPA proposal (for a under review. Also, assumptions of com- uniform percentage removal require- pliance for other sources—especially for ment) and the DOE proposal (to allow automobiles — may be too optimistic. utilities using low-sulfur coal to apply ● Growth rate.–The growth rates of elec- only partial scrubbing), SOZ emissions tricity and coal demand are critical fac- would be significantly higher in West- tors in determining emissions, yet are ern clean air areas under the DOE pro- highly uncertain. As an example of the ef- posal. fect of varying growth rates, emissions — NOx controls. Since NOZ emissions are from a “moderate growth” scenario (5.8- expected to increase substantially from percent electricity demand growth for expanded coal use, pressure for further 1975-85, 3.4-percent growth for 1986 to controls is likely to increase. The prob- 2000, 1 billion tons of utility coal demand ability of such additional control de- by 2000) and a “high growth” scenario (5.8 pends primarily on the success of EPA’s percent for 1975-85, 5,5 percent for 1986 “Review of New Source Performance Standards for 15Analysis of the Proposed National Energy Plan (Wash- Coal-Fired Utility Boilers, vol 1 (Washington, D C.: U.S. ington, D C : U.S. Congress, Office of Technology Assess- Environmental Protection Agency, August 1978), ment, 1977), p 161. E PA-60017-78- 155A. 196 ● The Direct Use of Coal

NO, control program. A particularly soil, waterbodies, forests, farms, residen- promising control technology appears tial developments, and all other areas of

to be a IoW -NOX burner that has the Earth’s surface. achieved 85-percent emission reduc- ● On a large spatial scale, pollutants in the tions on a single full-size burner in the atmosphere are not well mixed. Conse- laboratory. Preliminary indications are quently, many air pollution problems are that there may be little or no cost penal- localized over cities and large metropoli- ty for using these burners in a new facil- tan regions. Further, climatological phe- ity. However, it is unlikely that suffi- nomena (such as inversions), topographic cient full-size demonstrations can be features (such as the Los Angeles Basin completed and an NSPS promulgated and the Appalachian Chain), and devel- before the mid-1980’s. opment patterns (such as the concentra- — Particulate standards. Electrostatic pre- tion of powerplants along the Ohio River) cipitators (ESPs) are less effective at can influence what pollutants are present, capturing fine particulate than are in what quantities, and what types of reac- baghouses (fabric filters) but are gener- tions are taking place. ally less expensive and can achieve re- ● The nature of the atmospheric chemical quired emission reductions except reactions is exceedingly complex and, at when used with low-sulfur coals. Thus, present, incompletely understood. Impor-

the effect of S02 standards on low-sul- tant factors that determine the rate at fur coal use will also affect particulate which the reactions occur are: control choices and, consequently, fine- — The form of the reactants (gases or aero- particulate emissions. sols). It is clear that certain future conditions – The presence of catalysts (metals, light, could lead to levels of emissions substantially and other reactants). Some of these greater than those projected. For example, a may be present in the same emission as greater than expected level of coal develop- the reacting substance, or may come ment coupled with a significant relaxation of from other emission sources (including SIP control requirements could lead to signifi- natural sources); some may exist only at cant increases in emissions of SOX and fine certain times of the day or in certain particulate. NOX emissions would be signifi- seasons. cantly increased if energy demand increased at – The concentration of reactants and type a more rapid rate than projected. of reaction. Doubling or halving the amount of a particular pollutant pres- Chemical and Physical ent in the atmosphere will not necessarily double or halve the rate of forma- Transformation and Removal tion of reaction products; reactions often are nonlinear with respect to con- As soon as each of the pollutants considered centrations. This same nonlinearity ap- here is released to the atmosphere, it is free to plies to the eventual atmospheric con- participate in a complex series of chemical centration of the reaction products; and/or physical processes that alter its form thus, reductions in “precursor” pollut- and location. Before the specifics of atmos- ants could, depending on the circum- pheric chemistry are addressed, the following stance, produce proportionately greater general relationships and conditions should be or lesser reductions in ambient concen- understood: trations of the secondary pollutants. . Individual pollutants in the atmosphere ● Considerable uncertainty exists as to are not static. That is, they react with which chemical reactions predominate other polIutants to give more or less harm- under various atmospheric conditions. ful products, they decay, and they are ulti- This uncertainty results in severe difficul- mately deposited to varying degrees on ties in predicting the effects of new con- Ch. V—Environmental Impacts . 197

trol strategies on concentrations of sec- deposition. Dry deposition (particles settling ondary polIutants. out or coIIiding with surfaces) occurs continually, and is more important close to the Reactions involving S0x have been the most SO source. Wet deposition (scrubbing of the intensely studied to date. The predominant set X atmosphere by precipitation) is sporadic and of reactions involves the conversion of SO to Z may be more important in regions remote from some form of sulfate. The reactions believed the source. The relative importance of the two to be of major importance are summarized in mechanisms depends on the climate and the table 26. The importance of understanding the form of the sulfur pollutant. However, from mechanism of production is quite obvious observed data in temperate climates, wet and from the table. For example, indirect photo- dry removal of all S0x is believed to be of oxidation requires free radicals often present 7 roughly equal importance. The relative im- in a polluted atmosphere, and indicates that portance of each deposition mechanism is dif- conversion to sulfates may then proceed more ferent for each sulfur species, however; wet rapidly in urban centers, especially in daylight deposition is 10 times more important for or summer conditions. As another example, the sulfates than for SO . Thus, keeping track of fourth reaction requires ammonia to convert Z precipitation is crucial in considering long- suIfuric acid to a sulfate salt. This buffering ac- range transport of sulfates. tion could be important where acid rain was an important problem; in such circumstances, The mean residence time in the atmosphere controlIing atmospheric ammonia couId be unfor SO, is about 1 day. For sulfates it is 3 to 5 desirable.

Removal of sulfur pollutants from the atmosphere takes place by gaseous, dry, and wet 17R. B Husar, et al., see note 5

Table 26.—Reactions in the Atmosphere

Catalyst/special Reaction type Reaction conditions Comments

Heterogeneous catalytic Liquid water; metal ions oxidation

Water droplets

Water droplets 198 The Direct Use of Coal days and for particulate S, about 2 to 3 days. are particularly important. These result in At a speed of 500 km/day, which is typical in various complex organic nitrogen species, in- the Midwest, half the particles or molecules cluding peroxyacyl nitrate (PAN) and perox- would travel over 500 km, 1,500 to 2,500 km, ybenzoyl nitrate (PBN). PAN and PBN are ex- and 1,000 to 1,500 km respectively. 8 I n tremely damaging to plants and irritating to temperate climates, 20 to 50 percent of SOZ is animal tissues. converted to the sulfate ion before removal. Gaseous, wet, and dry deposition are the Overall rates of conversion ordinarily range sinks for atmospheric NO , with the first two of from about 1 to 4 percent per hour during the X roughly equal importance and the dry deposi- day and less than 0.5 percent per hour at night tion somewhat less important. for an average daily rate of 1 to 2 percent per hour during the summer. ’9 This gives a sum- The chemistry of formation of polycyclic mertime S02 half-life of from about 11/2 to 3 hydrocarbons is both complex and incomplete- days, Figure 25 shows, in schematic form, ly understood. This subject requires more re- sulfur removal mechanisms and the relative search, especially with respect to formation of contribution of wet and dry deposition. benzo(a)pyrene and other species of POM from advanced coal technologies. The transformation of NO from coal combustion is less well understood than that of S0x Although a variety of reactions involving Atmospheric Transport

NOX are known, no reaction rates for actual atmospheric conditions can yet be assigned to Superimposed on the chemical interactions them. Important inorganic reactions involve just discussed are the largely physical transformations between the oxides NO and mechanisms that govern not only the degree and duration of the mixing among pollutants NO2 formation of N2 0 5 and reaction with but also the direction and distance to which water to form HNO3. Organic reactions of NOX the reaction products are transported. These physical factors may be divided roughly into mechanisms that primariIy affect shorter range ‘81bid. transport and those that determine the extent 191 bid, of long-range transport.

Figure 25.— Flow Diagram of Sulfur Transmission Through the Atmosphere. Over Half of the SO2 is Removed or Transformed to Sulfate During the First Day of Its Atmospheric Residence

S04 Aerosol

SOURCE: Report on the International Symposium on Sulfates in the Atmosphere, in EPA-600/9-78-022, Energy/Environment Ill, U.S. Environmental Protection Agency, Office of Research & Development, October 1978 Ch. V—Environmental Impacts ● 199

The short-range geometry of the plume is ants travel. Before 1973 there was little docu- critical to both short- and long-range transport. mented evidence to suggest that air polIutants Under some conditions, the plume spreads were transported in significant quantities to quickly to the ground level (“fumigation”) and regions remote from their origin. high concentrations of primary pollutants may Numerous studies since then have confirm- result. Under other conditions, the plume re- ed that this phenomenon does indeed occur. mains isolated in a narrow vertical layer that disperses little and travels far (“fanning”), car- One such example is the plume of the rying high levels of secondary products far Labadie Power Plant, outside of St. Louis, Me., from the source. A variety of other possibilities which has been extensively tracked by the falls between these two. Each type of plume EPA’s Project MI STT. This plume has been behavior is associated with different atmos- followed for more than 180 miles, and at that pheric conditions. distance its width was not much greater than 15 miles. Other examples include the Electric An important factor in the short-term disper- Power Research Institute’s (EPRI) SURE pro- sion of pollutants is the vertical temperature gram’s observations that sulfate episodes in variation with altitude. I n daylight hours of in- West Virginia occurred only when the air mass tense sunlight, air that is heated by the warm over the area had first traveled over high- surface continually rises, causing the atmos- emission regions; satellite tracking of “hazy phere to be unstable and well mixed. These blobs,” masses of polluted air that have been conditions promote the local deposition of observed over the Midwestern and Eastern pollutants, especially when persistent surface United States, lasting for more than a week; winds are Iight. Under the conditions of a tem- and observations and analyses of acid rain in perature inversion (warmer temperatures at Europe, where Scandinavian rivers and lakes higher altitudes)–whether it is caused by have apparently been degraded by long-range nighttime cooling of the surface faster than transport of NO and S0x from the United the air or by a cold air mass sliding under a X Kingdom and other Western European coun- warm air mass—the air layers are stable and tries .20 do not mix. At these times, effIuents from moderate stack heights may be trapped below the One of the four factors important in long- inversion, while those from tall stacks may range transport is the blend of local factors, become embedded in the layers above, and discussed above, that determine dispersal of hence subject to longer range transport. Night- pollutants from a given source. Local condi- time conditions often lead to fanning plumes tions promoting long-range transport are tall that remain in a narrow region and may be stacks, nighttime or cloudy conditions, and transported especially rapidly by a nighttime relative constancy of wind speed and direction jet stream. with altitude. Other local factors determine the extent of, A second factor is the persistence of surface vertical mixing of a plume. One is the wind tur- winds, These have been studied in great detail bulence caused by rough terrain, surface ob- at many stations in recent years. It has been stacles, or variation of wind speed with alti- found that many regions are characterized by tude. Another is the local wind pattern, such as surface winds that persist for 6 hours or more the urban-rural wind or the land-sea breeze. If in a given direction (or, to be more accurate, the local wind system becomes a temporary within a narrow anguIar sector). They help de- closed loop, pollutants can be sloshed back termine the dominant direction(s) of transport. and forth with no real dispersal, and produc- A third factor is the type of winds prevailing tion of secondary products can further deteri- at the altitude typical of plant stack heights. orate the air quality until the cycle is broken. These, too, are characterized by dominant di- Once the plume type has been determined rections that often may differ only slightly by short-range transport mechanisms, several 20 Altshuller, et al, “Appendix on Transport and Fate, ” long-range factors govern the way the pollut- Rail Report. 200 ● The Direct Use of Coal

Photo credit: EPA —Documerica

Conditions leading to long-range transport of a plume from a coal-fired powerplant: persistent winds, and a stable atmosphere

from that of the persistent surface winds. Thus, These conditions can create large regional the two often couple positively to carry pollut- areas of stagnation. ants still longer distances from their point of generation. Several research organizations are developing long-range transport models and are cur- These last two factors can contribute to the rently using such models primarily in an ex- additive effect of pollutants from several perimental mode. Models in current use have sources. Because the winds tend to blow more not undergone extensive peer review and thus frequently in some directions than others, any are not Iikely to be immediately acceptable for emission sources Iined up in the same direction regulatory purposes. This situation could will contribute to intensification of pollution change drastically within a short time— per- concentrations. For example, powerplants haps a year– and conceivably lead to greater clustered along the Ohio River are also in line regulatory attention to long-range transport with prevailing winds blowing to the northeast; problems. occurrence of these winds has been correlated with high pollutant concentrations in Pennsyl- Although long-range transport models are vania and other States to the northeast. still not fully verified, regions of the United A final factor is the large-scale meteorologi- States can be surveyed for some of the key fac- cal conditions resulting from the relative tors in long-range transport mentioned above. movements of low- and high-pressure systems. Data compiled by Teknekron for EPA on re- —

Ch. V—Environmental Impacts ● 201

gional air quality and aerometric parameters areas with a large number of current and pro- yield the following brief survey .2’ jected urban and utility emissions sources. In addition, the prevailing winds tend to be from One potential air quality problem lies in the the south and may entrain elevated levels of West, especially in the northern Great Plains sulfates from smelters in the Southwestern and southeastern Utah, an area slated for con- United States. siderable future powerplant development. Many areas nearby currently are designated as The gulf coast is expected to increase its Class I (i.e., areas where air quality is to be utilization of coal, partly in response to the strictly protected, with very Iittle development growing development of lignite fields. These allowed), and many of these lie in the direction fields lie primarily in eastern Texas and are of extremely persistent winds coming from alined approximately parallel to the prevailing wind direction (from southwest to northeast). If powerplants develop along the same line, in- 21An Integrated Assessment of EIectrlc Utlllty Energy tensification of concentrations may result. Systems Briefing Material s,” prepared for EPA/NASA Meeting on Cooperative Program on Synoptic Regional The region that has been the most heavily Air Pollution Problems, Sept 11-12, 1978, by Teknekron studied for air pollution transport is the Ohio Inc , Berkeley, CaIif , and Waltham, Mass/pt 2, Aero- metric Data Compilation and Analyses for Regional Sul- River Basin. This region not only contains a fate Modeling large cluster of coal-fired powerplants but also 202 ● The Direct Use of Coal

exemplifies some of the meteorological fac- tribution of air pollution and the large number tors that contribute to long-range transport. Ex- of different polIutants usualIy present. tremely persistent winds in the Basin lead to Increased coal combustion will eventually intensification of pollution levels from a string increase the ambient concentrations of SO , of sources. Prevailing winds in the Upper Basin X NO , fine particulate, and other pollutants, as blow predominantly east and north, carrying X discussed in the previous section. The popula- polluted air as far east as Pennsylvania and tion exposed to the increased concentrations beyond, while winds in the Lower Basin carry will be large because pollutants travel long pollutants north into Canada. distances and, due to prevailing wind patterns, Several regions in the Eastern United States will be concentrated along the heavily popu- have been found to be susceptible to pro- lated Eastern seaboard. The present regulatory longed atmospheric stagnation. Many of those structure fails to address this problem directly. cases are centered over a line from southern If present and projected levels of ambient West Virginia to Georgia. Although emissions pollutant concentrations are shown to cause are generalIy low along this region, they are ex- severe chronic effects, the implications for pected to grow. coal use and the degree of control to which it is likely to be subjected wilI be profound. Health Effects** Evaluating Health Effects

Introduction The determination of the potential of a sub- It is known that very high levels of air pollu- stance for causing adverse health effects can tion cause illness and death. Present ambient be accomplished by combining the results of: air standards are well below these levels, and it 1 ) short-term tests, 2) animal bioassays, 3) is unlikely that episodes of high concentra- chamber exposures to human beings, and 4) tions of “criteria pollutants” similar to the epidemiologic studies on human populations. notorious catastrophes that occurred in Short-term tests expose tissue, cellular, and Donora, Pa., in 1948 and London in 1952 will microbial cultures to controlled levels of pol- be repeated in this country. However, occa- lution to measure toxic effects, such as cellu- sional episodes of adverse meteorological con- lar or bacterial death, or mutagenic changes ditions such as those that occurred in the refIecting alterations in genetic structure. Northeast during November 1966 could lead to high (and possibly dangerous) levels of current- Animal bioassays are used to measure acute ly unregulated pollutants. Also, elimination of and certain chronic effects. Tests for acute tox- acute, high-concentration episodes does not icity may measure the dose that causes death preclude the possibility of chronic damage and or impairment of target organs such as the life shortening as a result of exposure to low lungs, kidneys, liver, reproductive system, etc. levels of pollution. The existence of these Chronic effects might include gradual impair- types of effects is quite difficult to establish ment of target organs (e. g., chronic bronchitis because the damages may take the form of through long-term insult to the lungs), terato- common illnesses (e. g., bronchitis, asthma, genic effects, or carcinogenesis. cancer) that are known to have other causes Exposure studies using human beings are re- and would not necessarily be attributed to air stricted, for ethical and legal reasons, to pollution. The effects, if any occur, would also (usually) short durations and exposure levels tend to be masked by the very widespread dis- no greater than might be expected in the normal working or outdoor environment. Further, 2 ‘ This section summarizes a detailed and extensively “health effects” induced by controlled human referenced report on health effects to be published exposures are limited to those responses that separately as an appendix to this report. Full referencing of source material was considered impractical for this are known to be reversible, such as increased summary carboxy-hemoglobin levels in the blood or Ch. V—Environmental Impacts ● 203 changes in airway resistance. Controlled All of these methods of assessing health ef- studies of the short-term effects of air pollu- fects are necessary to establish the damage tant exposures to human beings provide a vital potential of a substance. Animal tests are in- link between toxicologic animal studies and sufficient by themselves because a biological large population epidemiologic studies. effect in any living system cannot always be applied to a biological effect in others. Although the cellular or subcellular effect may be similar, the clinical effect may be quite different. The chamber tests can show human sensitivity to the substance, but it is impossible to infer from studies exposing 5 to 20 subjects to low levels of the substance for relatively short times what the chronic morbidity or mortality effects on the entire population may be, Finally, epidemiologic studies can establish statistical associations between a substance and damage to human beings, but they cannot prove cause and effect; the short-term and animal tests, by establishing the existence of Photo credit: EPA — Documerica damage mechanisms, and the chamber tests, Tests on mice are used to measure acute and chronic by demonstrating human sensitivity, provide health effects credibiIity to the cause-and-effect argument, The epidemiologic studies have proven to be a weak link in the analytical chain needed to establish air pollution standards that will guard against chronic health effects. The studies that have attempted to examine the effects of low levels of pollution on the health of the general population have run into several problems: heterogeneous populations with different thresholds to particular toxic substances and different socioeconomic characteristics; very poor measurements of pollution lev- Photo credit. EPA —Documenca els — in most cases, the limited number of Clinical studies on humans are limited to pollution monitoring sites and the failure to in- levels that result in treatable health problems corporate levels of pollution indoors lead to poor determination of the pollution Epidemiologic studies are statistical examina- levels that the population is actually ex- tions of illness and death rates, air pollution posed to; levels, and other variables–studies that seek outright failure to measure some poten- to discover whether there is a direct correla- tially important pollutants (such as fine tion between a suspect air pollutant and ad- particulate); verse health effects. As such, they extend be- lack of data on variables (such as smoking yond the function of short-term tests and ani- habits) that are important determinants of mal bioassays that are used to identify the health; mechanism of damage and the dose response wide variations of pollution levels with function of the substance under study, and at- time, raising the question whether any tempt to quantify those effects in human observed health effects are caused by the beings. mean levels or the occasional peaks; and 204 ● The Direct Use of Coai

● presence of multiple pollutants that might divided into fine (usually defined as less than 2 act in combination. or 3 pm in diameter) and large particulate. This differentiation is important because: Some of these problems are discussed in more detail later in the context of epidemiologic 1. Fine particulate are not explicitly regu- studies of sulfate damage to human health. lated and are not as efficiently controlled by existing technologies as the large par- Effects of Specific Combustion Pollutants ticles. 2. The most significant route of exposure to Coal combustion releases a mixture of gases air pollutants is through inhalation. Fine and particles into the atmosphere. These in- particulate can pass through the filtering clude sulfur compounds, nitrogen compounds, mechanisms of the upper respiratory tract fly-ash particulate, CO, CO2, hydrocarbon and penetrate deeply into the lungs. Sev- vapors and particulate, radionuclides, and eral studies using zinc ammonium sulfate many trace metals. These emissions may lead and sulfuric acid aerosols have demon- to the formation of secondary pollutants, in- strated that small particles result in cluding photo-oxidants and particulate. greater functional and structural changes Human beings are exposed to a complicated in the lungs than result from larger par- mixture that may act additively, competitively, ticles of the same substance. or synergistically. However, clinical studies 3. Toxic substances, either gases or recon- have seldom examined more than two pollut- densed metal vapors, can be transported ants in combination. Even epidemiologic into lung tissues by inhaled fine particles. studies, in which the populations are exposed A unit mass of fine particulate has a to the entire gas-aerosol mixture, rarely at- greater total surface area than the same tempt to sort the effects of more than two of mass of large particulate, hence can the pollutants of the mix. This adds to the transport more toxic material on its sur- uncertainty of predicting health effects from face. future coal use. Thus, although there is not much explicit The following discussion summarizes the evidence defining their impacts on health, health effects of specific pollutants from com- fine-particulate emissions are a primary con- bustion. Table 27 presents the acute and cern in considering the impacts of expanded chronic effects of specific gases, elements, and coal combustion. particulate compounds that are emitted from coal combustion. Little is known about the ac- Both chemically inert and active aerosols tual magnitude of the effects attributable to have been shown to alter the mechanical increased coal use. The ambient concentra- behavior of the lungs, The principal response tions of radionuclides, organic compounds, of different aerosols as measured by animal and various trace metals due to increased coal and human control led studies is to increase air combustion are projected to be very low. How- flow resistance in the lungs, This indicates that ever, these polIutants are stilI a concern be- lung airways are in some way altered. Several cause of multiple exposures from other physical mechanisms are known to cause this sources. Health effects from these pollutants symptom: reflex constriction of the trachea are Iikely to appear first in the population and bronchi, excessive secretions of mucus, working in coal conversion or related technol- edema, and local enzyme stimulation causing ogies because exposures wilI be higher. smooth muscle constriction. In general the deeper that relatively insoluble particles are Total suspended particulate (TSP) are com- deposited in the lungs, the longer the time re- posed of many different substances. The ambi- quired for their clearance, Some particles, ent aerosol (suspension of solid and liquid par- such as asbestos fibers, penetrate the lung lin- ticles in air) includes trace metals, radionu- ing and lodge in the interstitial space or are clides, and organic compounds, as well as sil- carried by the lymphatic and circulatory sys- ica and other minerals. TSP can be roughly ens to other body sites. In these cases, the Ch. V—Environmental Impacts ● 205 manifest health effects may not be respiratory, the lung (the importance of the transport of but rather carcinogenic or systemic. The toxic dissolved gases makes it very difficult to con- elements contained in insoluble aerosols may sider the health effects of specific chemical uItimately affect extrapuImonary tissue irre- compounds or particulate in general without spective of where they enter the body. considering gas-aerosol interactions). A number of coal-related aerosols have been studied Besides changing airway resistance or caus- in animals and human beings. These include ing systemic changes, aerosols can cause harm several sulfates, chemically inert dusts, metal by altering lung clearance, transporting dis- oxides, and fly ash. Surprisingly, the effects of solved gases that may damage lung tissue, and nitrate aerosols have not been reported. affecting the compliance (tissue elasticity) of

Table 27.—Some Gaseous and Particulate Substances From Coal Combustiona

Toxicity Sources of Environmental Substanceb Acute Chronic Pollution standards Comments

Pulmonary irritation, chronic obstructive and restrictive lung disease.

Sulfates Increased Respiratory disease respiratory and increased disease; mortality breathing suspected. difficulty in asthmatics.

Organic matter Unknown for Long-term is poten- many com- tially carcinogenic pounds. and mutagenic. Specific toxicity for others. 206 ● The Direct Use of Coal

Table 27.—Some Gaseous and Particulate Substances From Coal Combustiona–Continued

Toxicity Sources of Environmental Substanceb Acute Chronic Pollution standards Comments

Arsenic (oxide forms) Effects large to Carcinogen, and Weathering; mining, 0.05 mg/1 small teratogenic and smelting; coal drinking depending on cumulative combustion; water. form and poison. pesticides; route of detergents. exposure; rarely seen. Beryllium Short-term Long-term systemic Industrial; combustion 0.01 pg/m3 poison at high poison at low of coal, rocket fuels. hazardous air concentra- concentrations; pollutant tions, carcinogenic in especially experimental toxic by in- animals halation. Cadmium Very toxic at Possible Weathering; mining 0.010 mg/1 Chronic cadmium high carcinogen, and smeiting, drinking water poisoning resulting in concentra- cumulative especially of zinc; 40 ~g/1/day illness and death tions; to poison; iron and steel proposed has occurred in animals associated with industry; coal effluent Japan, where and aquatic hypertension, combustion; urban standard cadmium mobilized life. Toxic by cardiovascular runoff; phosphate (withdrawn) by mining all routes of disease, kidney fertilizers. contaminated daily exposures. damage diet. Margin of safety—measured levels of cadmium in renal cortex compared to threshold for renal dysfunction-is low: . . 4 to 12.5. Chromium No chromium now 0.05 mg/i mined in U.S. drinking water Emissions from industrial processes, including electroplating, tanning, dyes; coal combustion.

Mercury Methyl mercury Weathering; volcanoes; Environmental pollution and mercury mining and smelting; leading to fumes very industrial; contamination of fish toxic; other pharmaceuticals; and shell fish caused forms of coal combustion; illness and death in variable sewage sludge; Japan; toxicity urban runoff; contamination of fish fungicides. in U.S. has caused closure of waters to commercial fishing.

Selenium Soluble Probable Natural; mining and interacts with other compounds carcinogen; also smelting; industrial metals, increasing or are highly essential for life. process; coal decreasing toxicity. toxic combustion. Ch. V—Environmental Impacts ● 207

Table 27.-Some Gaseous and Particulate Substances From Coal Combustiona —Continued

Toxicity Sources of Environmental Substanceb Acute Chrome Pollution standards Comments Gases Sulfur dioxide Increased Increased Sulfur contained in respiratory respiratory fossil fuels, smelters, impairment— disease and volcanoes morbidity and decreased mortality-in respiratory combination function with with parlculates. particulate. Nitrogen dioxide Increase Changes suspected Nitrogen fixation in respiratory in lung function; high temperature infections emphysema. combustion, and from nitrogen contained in fossil fuels: coal, oil, gasoline combustion. Carbon monoxide Behavior Increase risk of Incomplete combustion changes, coronary heart of fossil fuels: coal, nausea, disease-arterial oil, gas, gasoline drowsiness, sclerosis combustion. headaches, suspected coma, death Ozone Increased Unknown Photochemical respiratory reactions involving infection, eye hydrocarbons, irritation, nitrogen oxide and headaches, other compounds in chest pain, lower atmosphere; impaired reaction of atomic pulmonary oxygen and oxygen function in upper atmosphere. Aromatic hydrocarbons Fatigue, Irritation, A broad class of weakness, Ieukopenia and compounds naturally skin anemia. Certain evolved from organic paresthesia compounds are material, and from (> 100 ppm) mutagens and the evaporation and carcinogens. combustion of fossil fuels and other organic industrial chemicals.

a This table is provided merely to indicate some of the substances which are potential environmental hazards along with some Information on each regarding toxicity, sources, standards, etc. It IS not to be interpreted as definitive.

b The substance listed is not necessarily the form in which it becomes a potential environmental threat in some cases the oxide or some metabolite, rather than the substance Itself, IS the culprit

Controlled exposures to sulfates represent of health effects literature concluded that the vast majority of aerosol-health effects ex- “research on the toxicity of aerosols has not in- posure studies. Overall, the aerosol studies frequently led to an overinterpretation of report “health effects” at levels many times technically weak or insufficient data. ”23 Some higher than common urban levels. There is studies suggest that particulate pollution, evidence that chronic exposures below these 23Airborne Particles, National Academy of Sciences, levels adversely affect health by increasing National Research Council (Baltimore University Park respiratory disease (although a recent review Press, 1978) 208 The Direct Use of Coal

much of which is sulfur compounds, can initiate the development and progression of bronchitis and emphysema. Ambient particulate pollution has been associated with the development of lung cancer; the benzo(a)pyrene component of soot has been advanced as the causal factor. Although benzo(a)pyrene is a known carcinogenic material, it may be serving as a surrogate for a class of hazardous organic compounds found in urban aerosol samples. Polycyclic organic matter (POM) is a fractional constituent of particulate matter emitted during coal combustion. POM emissions appear to vary inversely with combustion efficiency. There is a factor of approximately 10,000 difference between POM emission factors (emissions per pound of coal) for hand- stoked coal stoves and large new utility coal boilers. 24 Therefore, the major health risk of POM is not from the large sources but with the older, less efficient utility and industrial boilers near populated areas. Depending on dispersion characteristics, POM from these coal sources may add to POM concentrations from other sources such as refuse burning, coke production, and motor vehicles. Also, any substantial increase in residential and other small-source coal combustion could aggravate problems with POM emissions.

Nitrogen dioxide health effects are normally associated with exposures close to the pollu-

tion source, because N02 is reactive and takes part in complex reactions within the atmosphere that produce ozone, PAN, and other complex organic nitrogen species. The Clean Air Act Amendments of 1977 require EPA to promulgate a short-term N02 standard (not more than a 3-hour averaging time) by 1980. An extensive review of N02 is reported in the EPA Office of Research and Development’s draft document “Health Ef- fects for Short-Term Exposures to Nitrogen Dioxide,” March 1978. Although this draft document does not contain a synthesis, it does contain extensive review with some critical interpretations and serves as a draft criteria document. EPA has requested public comment

24N, Dean Smith, see note 11 Ch. V—Environmental Impacts ● 209

Table 28.—Nitrogen Dioxide: Levels and Effects

Comments Concentrations Reported Effects (exposure time)

EPA lowest

400 .2

SOURCE Health Effects Appendix

Although there is extensive literature on ex- ozone have been reported in the range of 200 periments relating health effects of ozone and to 400 pg/m3 (0.1 to 0.2 ppm). Decreased run- other oxidants, assessment of a safe standard ning performance has been associated with is difficult. The problems parallel similar diffi- similar ozone levels. More severe symptoms of culties with interpreting health effects from chest discomfort and coughing have been re- other pollutants. First, questions are raised by ported in healthy young adults at measured the specificity and accuracy of ambient moni- ozone levels of about 725 µg/m3 (0.36 ppm) toring used in epidemiological studies. Sec- and at 490 µg/m3 (0.25 ppm) in hypersensitive ond, there are uncertainties in extrapolating individuals, Levels high enough to cause these from cell and organ studies, as well as from more severe symptoms occur in Washington, whole animal studies, to estimates of human D. C., Houston, Tex., Philadelphia, Pa., and Los damage. Finally, field studies measure only the Angeles, Cal if., with some regularity. ozone component of total oxidant levels but are actually observing the effects of all ox- Japanese investigators have observed that idants. The evidence is consistent that nose, the frequencies of several symptoms in school throat, and eye irritation occurs in the range of chiIdren, including sore throat, headache, 200 to 294 pg/m3 (0.1 to 0.15 ppm) of measured cough, and dyspnea, are higher on days when ozone. Breathing difficulties in exercising maximum hourly oxidant concentrations adults and chest pain in children exposed to equaled or exceeded 0.15 ppm than on days

44-102 [) - -i~ - 15 210 ● The Direct Use of Coa/

Table 29.-Ozone (OJ: Levels and Effects ——

1200 1100 1000 — .5 4

800 — .4 -i

700

600 — .3 -i

500

400 — .2 i 300

200

100 0

SOURCE: Health Effects Appendix. when corresponding concentrations were be- can studies. The consistent difference between low 0.10 ppm.25 in Japanese studies, the num- Japanese and American findings raises several ber of individuals experiencing symptoms has questions, including whether the components generally been more strongly associated with of oxidant pollution in Japan are different ozone concentrations than with total oxidant from those in Los Angeles, or indeed, from concentrations. The Japanese studies also sug- those in any U.S. location. It is possible, for in- gest that people with allergic tendencies are stance, that oxidants in Japan are accompa-

more susceptible to short-term photochemical nied by higher SOX levels than in the United oxidant exposure than are other segments of States. In any case, the Japanese results the population. underscore the point that epidemiological results gathered in one area can be generalized Japanese studies have generally shown oxi- to other areas only with the greatest caution. dant- or ozone-associated effects at lower oxi- The Japanese results also demonstrate the dant or ozone concentration than have Ameri- need to gather comprehensive data in U.S. 25 J. Kagawa and T. Toyama, “Photochemical Air Pollu- locations other than Los Angeles. tion: Its Affects on Respiratory Function of Elementary Schoolchildren, ” Archives of Environmental Health, 30: Because the discrepancy among these re- 117-122,1975. suits is along national lines, it is of particular Ch. V—Environmental Impacts 211 interest to note the results of a study on nine As yet, no convincing association has been new arrivals to the Los Angeles area.2G They shown between short-term oxidant exposures showed substantial decreases in pulmonary and rates of mortality due to any cause. Al- function for ozone exposures of 800 µg/m3 for though a positive association has been ob- 2 hours, whereas six local residents did not served in one study, a re-analysis appears to show measurable effects. In a further study,27 negate this conclusion. Interpretation of mor- four southern Californians and four Canadians tality studies has been hampered by limita- were exposed to 700 µg/m3 for 2 hours with tions in statistical methodology. It has not light intermittent exercise. The Canadians ex- been possible to fully separate the effects on hibited discernible decreases in lung function, mortality of oxidants, other polIutants, and but the Californians did not. Thus, either a meteorologic factors, most notably tempera- possible adaptation or a “selective migration” ture. effect is inferred. (“Selective migration” occurs when people moving into or out of an Sulfur dioxide.–Although there have been area show a sensitivity to a pollutant that is many studies of SOZ, there is little evidence of markedly different from the average). Any acute adverse effects at ambient levels (usual- adaptation would indicate an altered lung sur- ly below 0.4 ppm). The gas is soluble and face due to air pollution, which is an effect removed almost entirely by the upper airways. that should arouse considerable concern. This At levels much higher than the ambient stan- observation is consistent with the observation dard of 0.14 ppm for 24 hours, controlled ex- that at low ozone levels smokers are generally posure studies have demonstrated increased less reactive than nonsmokers. An alteration in airways resistance in subjects. These and other the lung would also be consistent with deacti- reversible effects occurred at 1 ppm (2- to 3- vated surface cells in the bronchi, which may hour exposures) and higher. Long-term animal lead to long-term respiratory problems. exposures in the range of 340 to 15,000 pg/m3 In his comprehensive review of health ef- (0.1 3 to 5.72 ppm) show no functional or struc- fects from exposure to low levels of air pollu- tural lung damage. All long-term exposure studies on human beings have involved a tion, Ferris concludes: simultaneous exposure to the gas-aerosol mix- Because of the highly reactive character of ture. However, it would appear on the basis of 0 3, prudence dictates that we should abide by a lack of cumulative functional or structural the present standard until more valid data impairment of the lungs from high-SO animal have been collected. Chamber studies will be z exposures that SO alone at ambient levels is useful to define acute or short-term effects but Z not hazardous for human beings. The observed cannot identify subtle long-term effects. For effects are shown in table 30. these we shall have to turn to epidemiologic studies which have many confounding variables. To date there is no evidence that health Sulfur dioxide and particulates.-Exposure to

effects result from chronic exposure to levels S02 virtually always occurs in the presence of of oxidants that currently occur in Los particulate and other gases. Generally, there Angeles, but careful studies to confirm this is a heightened response from the dual expo- have yet to be done. ” sure that is not observed from single exposures. A popular explanation of this synergism is that the aerosol acts as a carrier for the S0 26 J. D.Hackney, et al , “Studies in Adaptation to Am- 2 bient Oxident Air Pollution: Effects of Ozone Exposures (which would otherwise be screened by the in Los Angeles Residents vs New Arrival s,” in En- lung’s defenses), thereby delivering a higher vironmental Health Perspectives, 18: 141-146, 1976. fraction of the gas to the deep recesses of the 27). D Hackney, et al., “Effects of Ozone Exposure in lungs. An alternative explanation is that chemi- Canadians and Southern Californians, ” Archives of En- cal reactions can occur between the gas and vironmental Health, 32: 110-116, 1977. 28 B. G. Ferris, Jr., “Health Effects of Exposure to Low particle, forming new compounds (such as sul- Levels of Regulated Air Pollutants, A Critical Review, ” ). furic acid) that are more toxic. Both expla- Air Poll. Control Assoc., 28:482 (1978). nations are supported by laboratory animal . 272 ● The Direct Use of Coal

Table W.—Health Effects of Sulfur Dioxide

SOURCE: Health Effects Appendix.

studies using combined exposure of SO2 and Quality Standards (NAAQS) by coal combus- various particles. tion may be damaging to human health.

Sulfate particulates. -Over the past decade

emissions of SOZ have remained fairly stable, but their distribution has changed substantial-

ly. Urban SOZ levels have decreased considerably as powerplants and other sources have either moved away or come into emissions compliance. At the same time, however, sulfate levels in most cities have not declined. This can be attributed to the formation of

sulfate from the SOZ emitted by new rural sources, and its long-range transport to the urban areas. Sulfate particulate can travel more Gas-aerosol interactions have been docu- than 1,000 km, with atmospheric residence mented in the laboratory and observed in time of between 2 and 4 days. The available population studies at levels slightly higher data indicate that large regional reductions in

than the present standards. Given that these total SOZ emissions would be required to re- potentially harmful reactions are quite com- duce sulfates. Thus, current policies designed plex, perhaps impossible to understand com- to reduce ambient pollutant concentrations , pletely, violations of National Ambient Air are not fully successful because they inade- Ch. V—Environmental impacts 213 quately deal with long-distance transport of Laboratory studies provide mixed evidence pollutants across jurisdictional and inter- on the adverse health effects of sulfates on national boundaries. both human beings and experimental animals. Airway resistance has been measured in ani- Review of the available human experiments mals at sulfate levels higher than those ex- and epidemiologic studies indicates that high perienced in ambient exposures. Impaired lung levels of some sulfates irritate eyes and the clearance in animals has been reported in the respiratory tract, decrease lung function, ag- upper range of ambient exposures. Some gravate emphysema, asthma, and chronic human studies show effects at levels below 100 bronchitis, and may increase mortality. µg/m3 for short-term exposures. However, these Research seems to indicate that sulfates observations are not confirmed in other function independently of SO, in producing studies. Table 31 summarizes the data avail- health and ecological effects. Sulfates exist as able over the range of ambient exposures. several chemical species. Sulfuric acid mist In summary, animal and human respiratory and several species of sulfate particles have studies indicate health effects for sulfates by been demonstrated to be more toxic than SO , 2 themselves and in combination with other as measured by flow resistance in pulmonary gaseous pollutants at levels higher than cur- airways in animals, while at least two sulfate rent ambient exposure. Further, these studies species appear less toxic than the S0 gas. It 2 distinguish among sulfate compounds. Ammo- has also been demonstrated that for a given nium sulfate, the principle constituent of air- concentration of a sulfate compound, toxicity borne sulfates, is less hazardous than other increases with decreasing particle size. Atmos- sulfate compounds. Sulfuric acid aerosol, also pheric sampling has repeatedly shown that detected in urban atmospheres, is the most more than half of the mass concentration of hazardous. At times, urban and rural sulfate sulfate is found in the aerosol fraction of par- levels are almost exclusively comprised of ticles less than 1.0 µm in diameter. sulfuric acid. The most extensive epidemiological study of

S02 and sulfate is the Community Health and Effects of Air Pollution on Death Rates Environmental Surveillance System (CHESS) study conducted by EPA.29 As a consequence Several epidemiologic studies of mortality of many valid criticisms, it is generalIy felt that (death) rates have shown an association be- insufficient information exists in the CHESS re- tween sulfate and TSP levels and community sults to propose a standard for sulfate.30 Upon mortality rates. Most of these studies are re-analysis, the CHESS results do not substan- “cross-sectional;” that is, they examined differ- tiate the original conclusions that ambient sul- ences in mortality, air pollution, and other fate levels are associated with respiratory variables among geographical areas over one symptoms in asthmatic adults and acute lower time period. Increased levels of mortality are respiratory illness in children. However, other observed at or near air pollution levels that CHESS results are not inconsistent with other prevail in urban regions of the United States. findings and represent a large body of epidemi- Although different studies show a consider- ological data. 31 able range of pollution/death rate associations, the majority of these studies derived coefficients of air pollution-induced mortality (deaths per unit population exposed per unit of 29 Health Consequences of Sulfur Oxides: A Report pollutant concentration, or annual number of From CHESS, 1970-71 (Washington D. C.: U.S. Environ- deaths that would be expected to occur if mental Protection Agency, May 1974), E PA-650/l-74-004. 100,000 persons were exposed to an average of 30 B. G. Ferris, Jr., see note 23. 1 µg/m3 of pollution) that indicate that several 31 “R. S. Chapman, discussion in: “Health Effects of Ex- tens of thousands of premature deaths annual- posure to Low Levels of Regulated Air PolIutants: Discus- sion Papers, ” Journal of the Air Pollution Control Associa- ly are associated with current pollution levels. tion, vol 28, no 9, September 1978, pp. 887-889 Owing in part to limitations in the pollutant 214 ● The Direct Use of Coal

Table 31.—Health Effects of Sulfates

Cone. (µglm -) Health Effects 500

100

measurements (several important pollutants the independent variable being measured. were unmeasured), it is impossible to deter- It is likely that the error introduced by mine from these studies whether sulfates and using central station data as measures of suspended particulate are the true causes of population exposure would make it less the statistically observed deaths, or whether likely that the analyst would find a posi- they serve as a measure of some other pollut- tive association between air pollution and ant or combination of pollutants. In the mortality. Thus, this is not a logical argu- absence of a plausible alternative hypotheses, ment against a positive finding. however, any other causative pollutants ap- 2 The single monitoring station is typically pear likely to have been the products of the located in the center of the urban area, same (fossil fuel combustion) sources that pro- which often coincides with the areas of duced the sulfates and TSP. highest pollution exposure. This biases results. These studies have been widely criticized in Discussion: The bias produced by loca- the health community for deficiencies similar tion of monitors in areas of relatively high to those described earlier on pages 202 to 204, pollution may be either positive or nega- and their results have been rejected by many. tive, depending upon the relative gradi- Statements of the more frequent arguments ents of exposure among the cities under against the studies and discussions of the argu- consideration. ments’ validity are presented below: 3 It is unlikely that current air pollution ex- 1. These studies typically use data from a posure is an adequate exposure param- single monitoring station to represent the eter. Past exposure or cumulative history exposure to the residents of a metropol- of exposure is undoubtedly more relevant. itan region. Measurements taken at a Discussion: It can be demonstrated that single point are a poor measure of the regardless of whether air pollution levels mean exposure of the population. are increasing or decreasing, it is possible Discussion: The effect of using poor that this bias could operate in either direc- data is, if the error is random, to bias tion. To the extent that present exposures downward the estimated coefficient of are less than perfectly colinear with past Ch. V—Environmental Impacts ● 215

exposures, there will be a tendency to un- in relation to air pollution exposure. In derestimate the true magnitude of the most of this work, air pollution exposure relationship. Also, efforts to include meas- appears to have a stronger effect on men ures of cumulative exposure have gener- than women. Combining this with the ally failed to increase the explanatory knowledge that historically men in the power of air pollution mortality models. United States smoke more heavily (and 4 The studies have been confounded by the more men smoke) than women, two hy- similarity of patterns of certain critical potheses become possible: socioeconomic variables with patterns of i. smoking is confounding the associ- air pollution. Whereas the researchers ation; believe that they are seeing the relation- ii. smokers have more respiratory dis- ship of death rates to pollution, they are eases, and thus are more susceptible actually seeing the relationship of death to air polIution. rates to occupation and other factors that Because of a lack of data on community happen to be somewhat colinear with pol- smoking habits, cross-sectional studies lution in the United States. If these vari- can do little to resolve these two hypoth- ables were taken into account, the pollu- eses. However, it is important to note that tion/mortality association would disap- a very high correlation between air pollu- pear. tion and the smoking habits of entire ur- Discussion: Confounding is possible in ban populations would be required to ac- any epidemiologic study. This can influ- count for the mortality differences now ence results in two ways: either an impor- attributed to air pollution. It is unlikely tant variable is not included or two or that this is true. more seemingly independent variables are b. Occupational exposure. It is argued really measures of the same thing. In sta- that the regional differences in heavy tistical studies on mortality and air pollu- manufacturing and other industrial activ- tion, smoking and occupation are fre- ities vary simiIarly to the air polIution con- quently cited as confounding variables centrations and that the differences in left out of regression analyses. The effect mortality reflect the hazards of working of confounding would be the production rather than breathing outdoor air. of seemingly valid but spurious associa- When occupational variables such as tion. For confounding to occur, the vari- the percentage of the work force em- able must be a cause of disease, and must ployed in each of the following categor- be highly correlated with the variable of ies — agriculture, construction, manufac- interest, air polIution. turing, transportation, trade, finance, edu- a. Smoking. It is certainly reasonable to cation, white collar, and public admin- argue that smoking may be confounding istration —are added to regressions, the the results. Data on the smoking habits of amount of mortality associated with air metropolitan populations are virtually pollution is reduced. This indicates that nonexistent. It is generally accepted that adequate accounting for the occupational smoking can induce lung cancer, induce variable could reduce the effect attrib- and/or exacerbate bronchitis and emphy- uted to air pollution. Lave and Seskin32 sema, and reduce life expectancy. There- suggest an alternative interpretation. fore, if there were substantial differences They argue that occupational variables in the amount of smoking across metro- are surrogates for unmeasured air pollu- politan areas–differences that varied tants that affect the general population. If similarly to air pollution — then smoking differences in occupation patterns are may be the real cause of mortality now at- correlated with air pollution levels, this tributed to air pollution. There is mixed

evidence on this issue. Several investiga- 32 L. B. Lave and E. T. Seskin, Air Pollution and Human tors have independently examined the Health, John Hopkins U. Press, Baltimore and London, mortality experience of men and women 1977 216 ● The Direct Use of Coal

represents a limitation of the air pollution mortality associated with fossil-fuel-derived mortality associations derived from cross- air pollution. 33 The Atmospheric Sciences Divi- sectional studies. Currently available data sion has applied a long-distance trajectory do not permit resolution of this issue. model to predict the ground-level concentrations of a number of pollutants emitted from c. Differential/ migration. Occasionally coal combustion. The model is capable of in- it is argued that people have been moving corporating alternative siting and emission out of the heavily polluted Northeast and patterns to show the air quality implications of East Central United States to the less various scenarios. The modeling effort: polluted Southeast, South, Mountain 1 projects pollutant emission from 1,088 States, and West. It is well established coal-fired sources (71 1 industrial point that those who move tend to be relatively sources and 377 utility point sources) young and healthy. Thus it is possible that using 1985 and 1990 emissions projec- selective outmigration from the polluted tions, and assuming 80-percent SO con- areas might result in a spurious associa- X trol for existing sources and 85-percent tion between air pollution and mortality. SO control for new sources; Lave and Seskin have approached this 2 computes the resulting ground-level air problem by splitting their data base into quality concentrations with a model areas of “high” and “low” migration and which accounts for long-range transport performing independent analyses on these and chemical conversion (i. e., SO and two groups. The coefficients of air-pollu- Z S0x concentrations are calculated by the tion-induced mortality derived from the BNL model); and low-migration data set were about half as 3. ca l c u I ates the annual population large as those from the high-migration weighted sulfate exposure with 32 x 32 km data. Differential migration may be par- grids for the entire country. tially confounding the results, but a positive association remains for air pollution. Figure 26 displays the calculated sulfate annual concentrations for the 1990, 25.7 Quads These arguments are the most important of coal-use scenario. The pattern reflects very many criticisms of cross-sectional studies of high sulfate concentrations in the Northeast air-pollution-induced mortality. Others are with peak levels in the region of eastern Ohio, considered in volume 11, appendix IX. Although western Pennsylvania, and West Virginia. After the findings and interpretations of these cross- obtaining population sulfate exposure, BNL sectional studies are still being debated, a applied to them a mortality coefficient of 3.25 positive relationship between air pollution and deaths per year for every 100,000 people ex- mortality cannot be rejected. posed to a 1 µg/m3 annual averaged sulfate level. This coefficient is a “most likely” coeffi- Quantitative Assessments of Health Damage From Future Pollution Levels cient of mortality derived from BNL’s examination of the available cross-sectional mortality The coefficients of air-pollution-induced studies and their data bases. In the BNL work mortality derived from the studies discussed the mortality coefficient is expressed in a prob- above can be used to project the deaths that ability function that ranges from no health ef- might result from future coal development. In fects (actually a negative coefficient) to four conducting such a projection, the analyst must times this “most likely value. ” In this way the develop a “scenario” that describes the development, compute its air quality effects, ‘ ] For example, see L. D. Hamilton, “Alternative and overlay those effects on the population. Sources and Health, ” in CRC forum on Energy, ed. The Biomedical and Environmental Assess- Robert. T, Budnitz, by CRC Press, Cleveland, 1977 and M. G. Morgan, et al, “A Probabilistic Methodology for ment and the Atmospheric Sciences Divisions Estimating Air Pollution Health Effects from Coal-Fired of Brookhaven National Laboratory (BNL) have Power Plants, ” in Energy Systems and Policy, vol. 2, No. 3, developed a methodology for quantifying the Crane Russak & Co., Inc., 1978 Ch. V—Environmental Impacts ● 217

Figure 26.— Annual Concentrations of Sulfate for a 199025.7 Quads Coal-Use Scenario (Brookhaven National Laboratory, 1978)

BNL excess mortality, as shown in table 32, is the current air pollution mortality estimates. approximately the 50th percentile. That is, This increase is approximately 0.4 percent of there is a 50-percent chance that the actual ex- the annual total U.S. mortality. pected mortality is greater than the estimates The credibility of estimates of this type has presented, based on the BNL probability func- been severely challenged by many in the tion for the mortality coefficient. health community. As noted above, there is The implications of the estimates shown in widespread skepticism that any air pollutants table 32 are startling. First, they imply that at current levels of concentration are killing coal emissions are responsible for approx- people in large numbers, Furthermore, even imately 2.5 percent (48,000 deaths) of the total the supporters of the air pollution/mortality annual mortality in this country. The second associations used in the analysis generally implication is that an increase in coal use agree that sulfates may not be the “guilty” could raise the air-pollution-caused annual pollutant. Other problems with the analysis in- mortality by approximately 7,000 in 1990. In clude potential inaccuracies in the sulfate pro- comparison to the more than doubling in coal jections and the use of a simple linear model use, the projected annual air pollution mortali- for health effects. However, this work is the ty would increase by less than 20 percent over first comprehensive attempt to formulate a 218 ● The Direct Use of Coal

Table 32.-Annual Projected Mortality From Coal Combustion

Year Quads of coal use Expected mortality 1975...... 11.3 48,120

1985...... 22.5 49,543

1990...... 25.7 55,835

NOTE: Proportional Mortality Model—3.25 deaths/y r/100,000 populations/(1 µg/m3—annual average for sulfate). SOURCE: Based on population exposures from: Meyers, R. E., Cedarwall, R. T., Kleinman, L. l., Schwartz, S. E., and McCoy M., “Constraints on coal utilization with respect to alr pollution production and transport over long dtstances: summary,” Oct. 2, 1978 (draft report), Brookhaven National Laboratory.

quantitative methodology for assessing air 3. Insufficient epidemiologic evidence exists pollution health effects. Even if the damage to relate mortality and/or morbidity to coefficient is not accepted, the model can ambient levels of air polIution. identify population exposures to sulfates and related pollutants and can identify the rela- Significant improvement in the ability to quan- tionships between regions of high exposures tify the effects of coal combustion is con- and regions with multiple pollution sources; tingent upon continued development in ex- this information can be used to evaluate the posure assessment, health effects research, relative effects of alternative siting patterns. and quantitative applications.

Research Needs Exposure.-Comprehensive pollutant moni- DOE, EPA, the National Institutes of Health toring is fundamental to epidemiologic (NIH), and other agencies support air pollution studies. Present monitoring assesses outdoor health effects research in areas of bioscreening concentrations of relatively few pollutants. for hazardous substances, cellular toxicology, Particulate, for instance, are determined on a animal toxicology, human exposure studies, weight basis only and are not differentiated by and risk analyses. This research is funded size or chemical composition. Encouragingly, through the Federal Interagency Energy En- EPA is conducting a nationwide fine-partic- vironmental Research and Development Pro- ulate monitoring program. The relationship of gram, as well as the basic contract and grant outdoor air pollution to indoor exposures and, programs of various agencies. Health effects in fact, the total integrated dose of pollutants research programs related to fossil fuels are re- to the individual are not understood. ln- viewed in volume 11, appendix IX. tegrated exposure assessments that measure the human body burden from multiple ex- Quantification of mortality and morbidity posures to pollutants are urgently needed. from fossil fuel air pollutants is currently Moreover, to facilitate epidemiologic work, limited because: the exposure of entire urban populations must be better characterized by implementation of 1. Population exposures to pollutants are more “dense” monitoring networks, including poorly defined. personal monitors. 2. The mechanisms of biological injury induced by specific pollutants are not ade- Damages.-The specific mechanisms causing quately understood. biological injury from many atmospheric pol- Ch. V—Environmental Impacts ● 219

Iutants are unknown. Knowledge of these tion exposure to coal-related air pollution in- mechanisms will provide a firmer scientific creases. Such studies must receive long-term basis for epidemiologic investigation of funding commitment to comprehensively ex- specific health damages and pollutants and, amine multiple health indicators whiIe proper- consequently, a foundation for effective ly assessing pollutant exposures. pollutant-specific control strategies.

Until direct information from controlled tox- Ideally, understanding of the biochemical icologic and epidemiologic studies is avail- and metabolic fate of pollutants is desired. able, quantitative assessments of health im- However, the precise fate of pollutants is often pacts from fossil fuel combustion must rely on impossible to determine. When this is the case, cross-sectionaI statistical studies. These research must be focused on understanding studies can be improved by a more accurate the grosser, aggregate effects of pollutant in- measurement of socioeconomic variables. For sults. For example, pollutant effects may mani- example, as noted above, differences in region- fest themselves as increased susceptibility to al smoking habits have not been adequately infect ion, or as inhibition of lung-clearing accounted for. This deficiency could be cor- mechanisms. In pursuit of a better understand- rected if social, economic, and geographic ing of these effects, new techniques and tradi- smoking patterns were assessed as part of the tional research for assessing defense mecha- National Census. nism inhibition should be expanded. New techniques are currently being developed for non- invasive methods for mapping particulate dep- In order to resolve the question of whether osition and particle retention in the lungs. long-term health effects are caused by peak ex- These techniques would permit rapid survey- posure or are the cumulative effect of mean ing of pollutant loadings in human lungs; they exposures, studies should be undertaken of the may allow the detection of health effects in effects of periodic exposures to sulfate, ni- human populations before the onset of clinical trate, ozone, and fine particulate. Summer- symptoms. time “episodes,” where these and other pollutants are elevated for hours to days over large areas of the Northeast, have been documented As the result of suggestive evidence on in ongoing field monitoring studies. Selected synergistic interactions of multiple pollutants, populations must be closely monitored for res- additional studies examining the combined ef- piratory and other physiological changes be- fects of two or more pollutants should be fore, during, and after such episodes. begun. Few clinical studies of this type have been done. Federal health organizations as well as EPRI have recently recognized this Conclusions fact. A few animal and human studies of multiple pollutant exposures have started; however, The discussions in this section and in appen- more such studies should be encouraged. In dix IX indicate that there are grounds for addition, there have been too few controlled speculation (for example, our knowledge of exposure studies on subjects under stress. the ability of fine particulate to penetrate Stress may be induced by exercise or with deeply into the lungs) and some positive but medication. Stress-pollutant studies are impor- not conclusive statistical evidence that current tant in determining biomedical effects in sen- and expected future concentrations of coal- sitive individuals. related polIutants may be dangerous to human health. A significant segment of the health community considers the statistical evidence Epidemiology .-Epidemiologic studies will be to be meaningless. Several of the objections necessary for monitoring possible changes in they raise are valid but do not appear to justify morbidity and mortality as the total popula- rejection of the evidence. 220 The Direct Use of Coal

Policy makers are faced with a difficult tradeoff. More stringent regulation of air pollution can involve very large costs and can even incur new environmental damages. For example, an insistence on full scrubbing will cost several tens of billions of dollars by 1990 and create a substantial disposal requirement for millions of tons of scrubber sludge. On the other hand, a failure to control incurs the risk that significant health damages may occur. The tradeoff is complicated by the current inability to definitely associate the (statistically observed) health effects with one specific pollutant; although sulfates have been implicated by most of the statistical analyses, they may be an indicator for another pollutant or mixture of polIutants. Uncertainty in environmental policymaking is inevitable. However, the level of uncertainty and the stakes in coal policy are very high. There is thus a high premium on reducing the uncertainty by improving predictions of future coal-related health effects. The research needs identified above (increased monitoring, improvement in the capability to conduct cross- sectional and time series statistical studies, and expanded investigations of the mechanisms of pollution-caused biological injury) are critical elements in this process.

Ecological Effects

Sulfur Oxides

As emphasized in the discussion of pollutant transformation and transport, SOZ may retain its chemical identity or may convert in the atmosphere to sulfuric acid or to a variety of sulfate salts. Within about 40 km of a coal- fired powerplant, the form of sulfur most likely to be deposited is S02. To place experimental evidence in proper perspective, one must compare levels at which damage is observed both to levels mandated by the current air quality standards and to those actualIy prevaiIing near and far from powerplants. The secondary

NAAQS SOZ standard is 0.5 ppm (3-hour average) and the primary standards are 0.14 ppm (24-hour average) and 0.03 ppm (annual average). In the United States as a whole in 1975, Ch. V—Environmental Impacts . 221

Although ambient levels near powerplants physical appearance of produce can also be in- usualIy are below the current secondary stand- jured by the combined impact of different air ards, much higher values can occur during pollutants. As a result, the marketability of plume touchdowns. The S02 levels during a vegetables and ornamental may be reduced. touchdown, as well as the frequency of Damage to animals occurs at far higher touchdowns, strongly depends on local factors doses of SO, than those levels at which plants surrounding a given powerplant. Measure- are affected. Rather than being affected di- ments of concentrations during these episodes rectly by S0 , animals may be more seriously are scarce, although measurements 3.6 miles 2 endangered by its indirect effect; sulfur com- from an Indiana powerplant showed nearly 100 pounds can destroy or alter their natural episodes per year of l-hour SO concentrations Z habitat. 42 above 100 pg/m 3 (.037 ppm) in the direction of 39 Better documentation exists persistent winds. S02 is transformed in the atmosphere to for the actual damage done by plume touch- various forms of sulfate that are damaging to downs, or fumigations, from coal-fired power- plantlife. Plants are directly injured when ex- plants and industrialized sources. These fumi- cessive sulfates accumulate in their tissues. gations have caused acute foliage burning to The rate at which this occurs varies according commercial soy beans,40 ponderosa and lodge- to the plant species and according to the pole pine forests, Douglas fir forests, ” and to amount of sulfur already available in the soil other plants. (some possibly stemming from chemical fertilization). The California Air Resources Board Damage caused by mixtures of pollutants has reported growth and yield reductions from have been shown in the field and in chamber sulfate accumulation in cotton, oats, rye, studies over a wide range of environmental tomatoes, barley, and in forests in New Hamp- conditions, including variations in soil type, shire. Other studies have shown damage to temperature, light, and humidity. Combined spruce needles from sulfate accumulation effects appear to take place through several over periods of time as brief as 10 to 100 days. mechanisms. The most common seems to be that the combination of pollutants reduces the Some sulfates, notably ammonium sulfate, plant’s threshold of injury; frequently the ef- can act as plant fertilizers. Nevertheless, even fect of the more toxic of two pollutants is apparently beneficial sulfate compounds may enhanced. be deposited at times not conducive to good farming practices, and the deposition of such A wide variety of field, vegetable, fruit, nut, sulfates may interfere with the individual farm- forage, and forest crops have been shown to be er’s schedule of chemical fertilization. sensitive to SOZ —even at levels below the

Federal secondary standard – in mixtures with As discussed previously, the emission of SOX common pollutants (ozone, nitrous oxides, from all sources may be relatively stable in the hydrofluoric acid, and peroxyacetyl nitrate). next 10 years (at moderate coal use growth Such pollutant mixtures disrupt critical pIant rates), although emissions may begin to grow functions, including growth, yield, root/shoot again unless controls are placed on older ratios, photosynthesis, and respiration. The powerplants. DOE projections show that the emissions in the eastern portion of the United States will generally decline during this period. This is fortunate because that is where the

brunt of SOX impact is now borne. However, some impacts –for example, the acidifying effects of acid rain – may be somewhat cumulative and thus could become more intense unless changes in control strategies are forth-

4ZN. R. Glass, cd., “Appendix on Ecological Effects, ” U.S. Environmental Protection Agency, p 6, Rail Report. 222 ● The Direct Use of Coal

coming. An intensification of SOX controls on lead to an increase in concentrations of ozone existing combustion sources is the only prac- and peroxyacyl nitrates. However, the degree tical alternative available, as the proposed of increase is complicated by a certain degree

NSPS is near the present limits of control of quenching of oxidants by NOX and by an ex- technology and increased requirements on pected decline in hydrocarbon emissions, new plant facilities would have only minor ef- which are also oxidant precursors and may be fects in this period. the limiting component for oxidant production. Nitrogen Oxides Any increase in oxidants appears particular- The direct action of man-caused NOX on the ly worrisome when it is recognized that ele- ecosystem is difficult to analyze because vated ozone concentrations caused by long- nitrogen is an element essential to all biologi- range transport of pollutants from urban areas cal systems and because natural sources of have become a severe regional problem NOx (especially anaerobic bacterial action and throughout the United States. “Repeated epi- chemical decomposition of nitrate) account sodes during 4 to 6 months of the year . . . 43 for more than 90 percent of global levels. The cause obvious foliage injury, impaired photo limited evidence suggests that NO, is more tox- synthesis, and growth reductions of sensitive ic than NO and that the most susceptible re- species populations, in both agricultural and ceptors in the terrestrial ecosystem are the forest ecosystems.’’” Oxidants have caused higher plants, among them oats, barley, tobac- well-documented damage to agricultural co, apples, and lettuce. Still, the threshold for crops, forests, and native vegetation in south- almost all observed effects on ecosystems is ern California as well as widespread damage to well above the NOX levels in most U.S. cities. crops in the East, and have become a new NOx is not nearly as obviously damaging to stress on ecosystems in the Southwest. Al- vegetation as either SOX or photochemical oxi- though animals do not appear to be sensitive dants at similar levels of concentration. Also, to existing levels of oxidants, they are affected very high NOZ concentrations are required to by the loss of cover and food accompanying produce morbidity or mortality in most ani- such levels. mals, 44

NOX, like SOX, has the potential for synergis- However, there are some poorly understood tic effects. It may facilitate the creation of areas of ecosystem effects that may be a cause nitrosamines, which are known carcinogens, for concern. For example, soils absorb NO and and it also seems to have more adverse effects

NOZ quite readily and change them to nitrate, when present together with SOX. decreasing soil pH and possibly affecting the micro-organisms in the soil. The effects of Finally, the most serious effect of NOX may

be its involvement with SOX in the formation of chronic low-level or intermittent NOZ exposures on vegetation also deserve attention. acid rain, which is discussed separately below.

The role of NOX in the formation of photo- Acid Rain chemical oxidants is of greater concern than NO, by itself, for oxidants are the most damag- Both NOX and SOX are implicated in the oc- ing air pollutants affecting agriculture and currence of acid rainfall at many locations forestry in the United States.45 NO, is the one around the world. “Normal” precipitation is primary “criteria pollutant” (pollutant regu- expected to have a pH of about 5.7, based on lated by a NAAQS under the Clean Air Act) theoretical calculations that postulate an 47 that is likely to increase significantly in the equilibrium with CO2. Precipitation samples from various points in the United States in- next few decades. The 21-percent increase in dicate that in large portions of the Eastern NO, projected for 1990 by DOE (NEF #l) may “I bid,, p. 10. “Ibid. “I bid., p. 13. “J. N. Galloway, C. E. Likens, and E. S. Edgerton, ‘s Ibid., p. 19. Science, 194, p. 722,1976. Ch. V—Environmental Impacts 223

United States, the pH falls between 3 and 548 One effect of acid precipitation is to lower (see figure 27). In northwestern Europe, where the pH of bodies of water into which it falls. If acid rain has been more intensely studied, a the pH dips below 5.0, fish such as trout or network of monitoring stations yields evidence salmon may perish, for they are very sensitive that the pH of the precipitation has dropped to pH. Fish kills have in fact been reported in over the past 20 years.4g It has been widely areas such as New York’s Adirondack Moun- stated that the region of acid precipitation in tains, where 51 percent of the lakes now have a the United States is extending westward and pH below 5.0, and where 90 percent of these southwestward. 50 The data available are support no fish populations.5’ A valuable rec- strongly suggestive of this statement, but are reational trout industry has thus been endan- neither systematic nor extensive enough to be gered. In Norway the losses to the salmon fish- considered conclusive. EPA and the Forest eries attributed to acid rain are estimated in Service are currently establishing networks of the tens of millions of dollars.52 Other aquatic monitoring stations that will provide better effects include reduction in algal communi- data in the future.

Figure 27.–Regional Impact of Acid Rainfall

San F

pH greater than 5.5 New Orleans- pi-i between 50 and 5.5

pH between 4,0 and 5.0

\ pH less than 4.0 ...... 224 The Direct Use of Coal

ties, growth of thick mats of benthic moss, and contrast, in the Western United States, where hindrance of nutrient recycling. indications are that rainfall may be growing more acidic and may continue to do so, the ef- The evidence for damage to terrestrial vege- fects may never become serious because the tation is somewhat more elusive. An associ- soils and lakes are so alkaline. More studies ation has been postulated between acid pre- must be initiated to identify sensitive regions cipitation and the decline in forest growth with low buffering capacity and to understand observed in both the Northeastern United the processes that affect the buffering capaci- States and in southern Sweden, where growth ty of soils, such as acidification by natural declined between 2 and 7 percent from 1950 to 5 processes and by chemical fertilization. 1965. ’ The ecosystem is unfortunately too complex for the cause to be laid so unequivo- Any increase in soil acidity may alter the calIy at the door of just one of many environ- delicate balance of soil calcium, magnesium, mental stresses. Nevertheless, numerous ex- and potassium to aluminum. Essential nutri- perimental studies have shown that acid rain ents, including nitrogen, potassium, and phos- can harm terrestrial systems in several ways: it phorus, can form compounds that are not use- may “damage foliage; accelerate cuticular ful to plants, or they may be leached from the erosion; alter responses to associated patho- soil altogether. The living organisms of the soil gens, symbionts, and saprophytes; affect the are very sensitive to pH changes in their envi- germination of conifer and hardwood seeds ronment, and these include not only important and the establishment of seedlings; affect the lower plant forms such as algae, lichens, and availability of nitrogen in the soil; decrease fungal associates of higher plants, but also the soil respiration; and increase leaching of nutri- nitrogen-fixing bacteria, which are essential if ent ions from the soil. ”54 Acid rains have been airborne nitrogen is to be made available for strongly implicated in causing extensive dam- use as a nutrient by plants. Current high nutri- age to Christmas tree farms in West Virginia ent erosion rates from soils subjected to acid downwind of the Kyger Creek coal-fired precipitation of 4.0 pH or less in remote for- powerplant in Ohio. The disease afflicting the ested areas of the Adirondack Mountains57 and trees has been duplicated in at Ieast two inde- elsewhere are evidence that forest soils in the pendent laboratory studies using sulfuric acid Northeastern United States are becoming mists. In other studies, several important food acidic at an accelerated rate. crops and trees were adversely affected by Fossil-fueled powerplants may be major simulated acid rain and mist. It has also been contributors to the occurrence of acid rain shown that increasing acidity of rain signifi- through their generation of NOX and SOX. Re- cantly increases the uptake of cadmium and searchers in Scandinavia attribute its acid rain other toxic substances by plants that may sub- to the long-range transport of sulfates from the sequently be included in human and animal heavily industrialized areas of northern Europe diet. 55 and England. Data from New York and New The effects of acid precipitation depend England indicate that about 60 to 70 percent largely on the buffering capacity of the region of the acidity in precipitation there is caused on which the rain falls. The damage may be by sulfuric acid, with the contribution from 58 quite dramatic in Scandinavia, for example, nitric acid becoming increasingly important. because 80 percent of the forest land in Swe- Because the background of air pollutants from den is acid podzolic soil and thousands of its stationary and mobile sources varies with lo- lakes are underlaid with granitic bedrock.5’ By cale, these figures may not universally represent the composition of acid rain.

“Ibid , p I105 “C W. Cronan, R C. Reynolds, Jr,, and G, E Lang, “L S Dochinger, see note 49 “Forest Floor Leaching: Contributions From Mineral, ’ 5 1 Shen-Miller, M B Hunter, and J Miller, “Simu- Organic, and Carbonic Acids in New Hampshire Subal- lated Acid Rain on Growth and Cadmium Uptake in Soy- plne Forests, ” Science, vol. 200 (1978), pp 309-11. beans, ” Plant Physiology, vol 57 (1976), p 50 58 G. D Likens, “AC id Precipitation, ” Chemical and “L S Dochinger, T A Seliga, p 1104 Engineering News 22,1976. Ch. V—Environmental Impacts ● 225

Future increases in energy development, and called, have been tracked over periods in coal use, may seriously aggravate acid rain longer than a week as they moved over problems through two mechanisms. First, al- large portions of the United States. These though tall-stack emissions of SOZ will not in- “blobs” are correlated closely with sulfate crease rapidly if best available controls are ap- level s.” plied, serious increases in NO, emissions will ● Visibility substantially increased during be inevitable if Federal emission standards– which require only about 50-percent control — are continued. As noted earlier, success of

EPA’s IOW-NOX burner will be a primary determinant of this required control level. Second, there is a possibility that the fraction of sulfates and nitrates that are in the strong acid form – currently thought to be about one quarter– may rise because of exhaustion of the neutralizing capacity of the atmosphere. If exhaustion occurs, a l-percent increase in emissions would subsequently lead to a 4-percent increase in acid rain. 59 Very little is known about the atmosphere’s neutralization capacity. Finally, as some of the impact of acid rain may be cumulative, even a stable level of acidity may lead to an increase in acid rain damages.

Visibility Reduction

S0x emissions from coal combustion have been strongly implicated as a major factor in the occurrence of visibiIity reductions throughout the United States. The evidence consists of the following.

● Sulfate particles formed as the result of

the atmospheric transformation of SOZ emissions tend to be in the size range of fine particles that are most effective in scattering light and hence in producing haze. ● Field studies by EPA indicate that power-

plant S02 emissions are converted to sulfates at significant rates. ● Sulfates account for about half of the particles in the “maximum light scattering” size range in industrial regions.60 ● Visibility reductions and sulfate concentrations have been strongly correlated; for example, large-scale polIuted air masses characterized by decreased visibility, or “hazy blobs, ” as they are sometimes

59’’Appendlx on Transport and Fate, ” Rail Report. ‘“’’ Appendix on Ecological Effects, ” Rail Report

44-102 0 - ;rl - 15 226 ● The Direct Use of Coal caused almost exclusively by fine particulate ticular problem in aquatic ecosystems (see and the associated trace elements and hydro- table 33). Another source of concern is the ex- carbons that are preferentially adsorbed on tent to which trace element impacts are cumu- their surfaces. Although total particulate load- lative; logic argues that many will be cumula- ings will be substantially reduced in the future tive, although the ambient levels caused by as the result of strict controls on new plants coal combustion are not likely to be high in and progress in obtaining conformance with most instances. Although the uncertainty sur- State regulations from existing pIants, emis- rounding these effects is very great, concentra- sions of fine particulate are unlikely to tions of polycyclic aromatic hydrocarbons that decline unless controls that are effective on have been demonstrated to be damaging to fine particulate (such as baghouses) are retro- fish have been observed in Norwegian rain- fitted on older plants as well as being installed water.68 However, the potential for significant on new ones. impacts on either terrestrial or aquatic ecosystems is clearly a very speculative area that re- Fine-particulate effects on ecosystems may quires considerably more evidence before firm be more of a regional than a local problem. conclusions can be drawn. Glass” notes that more than 95 percent of the particulate emissions from a large powerplant with an ESP travel beyond a 20 km radius, and Carbon Dioxide most studies of trace element contamination near powerplants have shown few significant COZ concentrations measured at Mauna effects. 65 Loa, Hawaii, and elsewhere have increased at a rate that appears to be tied to fossil fuel com- Soils are the principal repository for fine bustion. b’ The combustion of coal yields 11 particulate, and there is some concern that percent more CO, than oil and 67 percent the heavy metals contained within or on the more than natural gas. 70 The confluence of surface of the particles could eventually alter these two facts has led to concern about the the normal soil processes associated with role that increased coal development might nutrient recycling and with soil micro-orga- play in altering the Earth’s climate. nisms. Plants are also an important sink for fine particulate, which are captured by the CO2 is relatively transparent to short-wave fine hairs on plant surfaces. Plants are general- radiation (sunlight), but absorbs long-wave (in- ly not considered to be endangered by such frared or heat) radiation. Thus, atmospheric bb pollution; Van Hook notes that “there is no CO2 admits incoming sunlight that warms the reason to expect acute effects on plants . . . Earth, but absorbs a portion of the infrared the potential chronic toxicity is relatively low heat radiation coming from the surface of the except in local areas already enriched with a warmed Earth and re-radiates part of it back to particular element. ” However, more subtle ef- the surface. The heat is “trapped” in the at- fects, such as reduction in photosynthesis due mosphere in the same way that heat is trapped to reduced light or interference with stomatal inside a greenhouse, or an automobile with its function, and foliar lesions have been at- windows closed; hence the “greenhouse ef- tributed to fIy ash. b’ feet. ” (See figure 28). Although no effects on global temperatures have yet been measured, Both inorganic trace elements and trace most scientists believe that a continued in- hydrocarbons present a potential danger to crease in COZ levels must eventually affect the animals in water and on land. Biomagnifica- Earth’s temperature. tion, whereby trace materials can be concentrated as they move up the food chain, is a par-

“Ibid. “’’Appendix on Ecological Effects, ” Rall Report “C. Marland, and R. M. Rotty, “The Question Mark ‘s’’ Appendix on Trace EIements,” Rail Report. Over Coal; Pollution, Politics and CO, ” Futures, February “Ibid. 1978, “’’Appendix on Ecological Effects,” Rall Report. ‘“Analysis of the Proposed National Energy Plan, 1977. Ch. V—Environmental Impacts ● 227

Table 33.—Biological Concentration Factors for Selected Trace Elements in Aquatic and Terrestrial Environments

Biological Concentration Factor” As Cd Hg Pb Zn

a concentration in organism to concentration in substrate.

SOURCE Van Hook, R 1, ‘Transport and transformation pathways of hazardous chemicals from solid waste disposal," Environ. Health Perspectives (in repress)

Figure 28.— Heat Radiation Emitted to Space by CO2

SOURCE: Mitchell J. Murray, Jr., “Carbon Dioxide and Future Climate,’’ EDS, March, 1977 cited in Norwine, J., “A Question Climate,” Environment, Vol. 19, N0. 8, November 1977. 228 ● The Direct Use of Coai

The legitimacy of environmental concern Accepting even the lower value still leaves over the climatic influence of coal production an enormous gap in the existing models of car- hinges on the answers to two critical questions: bon balance; it is not known where all this excess carbon is going. However, if Woodwell is ● How wiII future atmospheric C0 concen- 2 correct that the biosphere is a C0 source trations be affected by fossil fuel combus- 2 rather than a “sink, ” this means that an un- tion and other activities such as forest known mechanism, capable of removing and clearing? storing atmospheric C0 at a substantial rate, ● What effect wilI increased C0 in the at- 2 2 must exist and might be available to remove mosphere have on global climate? excess C02 from fossil fuel combustion if the Considerable uncertainty clouds both ques- shrinkage of the forests could be halted t ions. Uncertainty also is added by a lack of full

C02 Concentrations.–There is general agree- understanding of the various known mecha-

ment about the amounts of carbon currently nisms involved in oceanic uptake of COZ. For

being released as C02 through fossil fuel com- instance, carbonate ions in the surface layers bustion (about 5 billion kilograms per year) of the ocean react with and remove atmos-

and the increase in the amount of carbon in pheric C02. As the pressure of C02 increases the atmosphere (about 2.3 billion kilograms and the carbonate ions are used up faster than per year) .7’ Until recently, scientists thought they can be replaced by mixing, the ocean’s

they could readily explain where the remaining absorption of COZ from the atmosphere could

2.7 billion kilograms per year went; a max- slow and the atmospheric COZ buildup could imum of about 2.5 billion kilograms per year accelerate. On the other hand, increased acid- was thought to be absorbed by the oceans, and ity of surface waters caused by greater dis-

the remainder by the biota-forests, grasslands, solved C02 concentrations could increase the etc. A number of researchers have now chal- dissolution of calcium carbonate and thus in- lenged this view based on evidence that the crease the supply of carbonate ions. The extent largest and most intensive pool of carbon in of these potential changes presently is the biosphere— the forests (both the trees unknown. Uncertainty also is caused by the themselves and their humus floors)— are lack of understanding of the effects of in-

shrinking significantly in area because of wood creased C02 on ecosystems and the corres- harvesting and clearing for agriculture and ponding effect on their photosynthetic produc- other development. This is especially true of tion and carbon storage capacities. the tropical rain forests such as those in the Any changes in these factors would alter the Amazon Basin, which are said72 to play the ma- capacity of the biosphere to act as a sink — or jor role in carbon storage in the biosphere. source — of atmospheric CO . Thus, a net carbon release rather than a net ab- Z sorption now is theorized. Woodwell 73 esti- Despite these uncertainties, however, prob- mates this release from the biosphere to be ably few scientists would disagree with the about 8 billion kilograms, although he esti- statement that continued reliance on fossil mates the range due to uncertainty to be 2 bil- fuels, in the absence of drastic measures to lion to 18 billion kilograms per year. Other re- change worldwide development patterns that searchers have developed lower estimates, are radically altering the biosphere, will result ranging from about one-tenth to one-third of in substantially increased levels of COZ in the the fossil fuel contribution. 74 atmosphere. Kellogg’s75 estimate of a 400-ppm

C02 concentration by 2000 and a doubling of “G. M. Woodwell, “The Carbon Dioxide Question,” that level by 2040 (if fossil energy trends con- Scientific American, January 1978, vol 238, No 1. tinue) should be taken quite seriously. “lb Id. “Ibid “R A. Kerr, “Carbon Dioxide and Climate: Carbon “W. W Kellogg, “Global Influence of Mankind on the Budget Still Unbalanced, ” Science, vol. 197, pp. Climate,” in Climate Change, J. Gibbin, cd,, Cambridge 1352-1353, Sept 30,1977. University Press, 1978. Ch. V—Environmental Impacts ● 229

Climatic Effects. -Even if precise forecasts of reflection of incoming solar energy and, future atmospheric C02 concentrations were consequently, a cooling effect. possible, the effects of these concentrations ● Changes in cloud cover: the increasing on the climate and on man would be uncertain level of fine particulate (which act as owing to several confounding factors. One fac- condensation nuclei), the increasing areas tor is that the climate, with or without man’s of irrigation projects, the expanded use of influence, may be changing as part of a natural cooling towers, and any warming trend cycle. Scientists disagree as to the nature of (leading to increased evaporation rates) these changes. Secondly, the “anthropogenic ” would al I tend to increase the cloud cover (man-caused) effect on global temperatures in- of the Earth and increase its reflectance. cludes several effects aside from the “green- This provides a “negative feedback” to house effect. ” Their role complicates the cal- compensate for the greenhouse effect, cuIation of the temperature effect of man’s ac- ● Thermal pollution of the atmosphere: by tivities. Finally, the translation of more precise the year 2050, the total heat added to the knowledge of the “greenhouse effect” and the Earth’s atmosphere by energy production other temperature-changing factors into a wilI approach 10’ 9 Btu per year, which is global climatic effect is a modeling problem on the order of one-half of 1 percent of that requires considerably more knowledge the solar energy reaching the Earth’s sur- and sophistication than is currently available. face. A 1- percent increase in this energy It is the distribution of temperature and other “flux” would generate about a 10 F in- effects, rather than the global average tem- crease in global temperatures. perature effect, that is critical to under- A reliable computation of the climatic standing the changes that will occur in actual Iiving conditions.

There are three major schools of thought on the nature of future climatic cycles. ‘b The first is that the recent climatic record is not sufficient to allow accurate forecasts of future climate. The second is that the Earth is due for a short period of cooling followed in the early 21st century by mild warming, and that man’s activities will not affect these trends. The third and most widely accepted is that global warming will occur sometime in the next century or so as a result of man’s activities, and that any manifestation of natural climatic cycles will eventually be overwhelmed by this induced warming. In addition to the “greenhouse effect, ” the other man-created effects that may affect global temperatures” include:

● Change in reflectance of the Earth: continued injection of particles into the upper atmosphere will lead to increased 230 ● The Direct Use of Coal

community generalIy agrees that the probabili- from powerplants or coal combustion sources) ty of significant global warming and other is $2.2 billion per year. The relative contribu- climatic changes is sufficiently high to warrant tions of the four major pollutant components

exceptional attention in form of expanded re- are: SOX— 41 percent, particulates —27 per-

search and monitoring, and caution in weigh- cent, ozone —26 percent, and NOX—6 per- ing any decisions that might tend to tie us ir- cent. 80 revocably to a fossil-based energy economy. There are five major causes of damage: It must be stressed that the “scenarios” ● abrasion by high-velocity and/or sharp- postulated by the more pessimistic researchers edged particles, would involve massive disruption of the world ● direct chemical attack, economy and well-being. A 20 to 30 C change ● indirect chemical attack —where the pol- in mean world temperatures could lead to lutant becomes harmful only after a trans- melting of the polar icecaps sufficient to cause formation when in contact with the mate- flooding of coastal regions. Another critical ef- rial, fect would be significant shifts in the viability ● electrochemical corrosion —where pollu- of the world’s food-producing areas owing to tion increases conductivity of thin surface massive shifts in rainfall distribution. 1 n the films of moisture and helps to destroy pro- long run, such shifts might not lead to a net tective films on material surfaces, and decrease in potential worldwide productivity. ● discoloration by particulate. However, the transient effects would be severe. Given appropriate climatic conditions, Each mechanism depends on a variety of inde- overalI agricuItural viability depends upon ex- pendent variables, including moisture, tem- isting land use, ownership patterns, transporta- perature, sunlight, etc. If estimates of future tion, water, and other resource availability, pollution levels are a guide, one might expect etc. These factors represent a massive physical that acid rain and ozone damage caused by and societal infrastructure that would have to powerplant NO, emissions will rise in the be virtually torn down and rebuilt to make a future, that SOX-caused damage will not under- successful transition to a warmer climate. go radical changes if best available control Problems with such a transition process could technology (scrubbers) is enforced, that partic- mean food shortages and social and economic ulate soiIing damage should decrease with sub- disruption on a massive role. stantial decreases in particulate emissions as all new powerplants control to better than 99- Effects on Materials percent efficiency and existing particulate emitters comply with State and local control Although human health and ecological ef- requirements, and that chemical damage due fects are the most serious problems associated to particulate might increase because of in- with air pollution from the coal fuel cycle, creases in emissions of fine particulate. damage to nonliving materials from this pollution is substantial today and may remain a po- tent policy issue because of memories of Regulations coal’s past. The soiling problem commonly Air pollution from coal combustion is regu- associated with coal combustion has been all but eliminated by extensive controls on par- lated under the Clean Air Act, which sets am- ticulate emissions and the phasing out of most bient air quality standards and establishes of the small coal-fired furnaces. However, limits on the emissions from a variety of problems that remain include the deterioration sources in order to achieve and maintain those standards. The legal framework of the Clean of building materials and works of art, fading of dyes, weathering of textiles, and corrosion Air Act is discussed in chapter VI 1; this section of metals. 80T E Waddell, “The Economic Damages of Alr Pollu- A 1970 estimate of total damage to materi- tion, ” U S Environmental Protection Agency, als from air polIutants (not limited to emissions E PA-600/5-74-012, May 1974 Ch. V—Environmental Impacts ● 231

summarizes the way the Act seeks to regulate and requires large new sources to use the best the health and ecological effects of the pollu- available control technology. Finally, the Act tants. requires the retrofitting of polIution control National Ambient Air Quality Standards technology on existing large sources near areas (NAAQS) have been promulgated under the primarily important for scenic values (such as Clean Air Act for six pollutants: S0x partic- national parks) in order to protect visibiIity. There are problems associated with imple- ulate matter, NOZ, photochemical oxidants, hydrocarbons, and CO. There are two types of mentation of the Clean Air Act to protect pub- NAAQS: primary standards are those needed lic health and welfare. As of mid-1976, 178 of to protect public health, allowing an adequate the 313 air quality control regions (AQCRS) or margin of safety. The secondary standards are State portions thereof had not attained the pri- intended to protect the public welfare from mary particulate standard, while 46 had not

pollution damage to soil, plants, animals, achieved the primary S02 standard. Most con- materials, and other factors not directly ventional stationary sources (such as coal-fired related to human health. The NAAQS are powerplants) in these nonattainment areas are based on air quality criteria that reflect the either in compliance with the standards or are latest scientific knowledge useful in indicating on compliance schedules. The particulate vio- the kind and extent of identifiable effects of a lations tend to arise because of fugitive emis- pollutant on public health or welfare. These sions, fugitive dust, and fine particulate, alI of criteria must include information about vari- which are more clifficuIt to monitor and con- able factors, such as atmospheric conditions trol, and which are not now explicitly regu- that may alter the effects of a pollutant, and lated under the Clean Air Act. about interactive effects among polIutants. No deadlines have been set for attainment The Clean Air Act is implemented at the of the more stringent secondary standards. State level through a variety of regulatory pro- Rather, the States are given a reasonable time grams designed to achieve and maintain the to achieve the secondary standards, where NAAQS. First, State Implementation Plans “reasonable time” depends on the degree of (SIPS) must include control strategies designed emission reduction needed to attain the stand- to reduce the contribution of existing sources ards and on the social, economic, and techno- to airborne pollutant loadings, generally logical problems involved in implementing a through the application of reasonably avail- control strategy adequate to achieve and able control methods. Second, the Act estab- maintain the standard. Thus the secondary lishes performance standards for large new standards are not being enforced, and soil, sources that mandate the use of the best tech- plants, animals, materials, and other environ- nological system of continuous emission re- mental factors are unprotected to the extent duction as well as a percentage reduction in they require greater protection then that af- emissions over those from the uncontrolled forded by the primary standard. combustion of untreated fuel. Third, in those The air quality criteria on which the NAAQS areas where air quality now exceeds the are based were published in 1969-71 and re- NAAQS (nonattainment areas), new sources flect the scientific knowledge current at that must meet the lowest achievable emission rate time about the effects of the various pollu- (LAER) by applying stringent technological tants. However, in 1969-71 the phenomena of controls and must secure emission reductions pollutant transformations and long-range from existing sources in the area that will more pollutant transport had not been documented. than offset the emissions from the proposed Consequently, the Clean Air Act and the regu- facility. Fourth, in order to prevent significant latory programs that implement the Act gener- deterioration of air quality in areas where the alIy treat S02 and particulate matter as static air currently is cleaner than the national stand- pollutants that do not convert. The transfor- ards, the Clean Air Act specifies maximum al- mation products, such as sulfates and acid lowable increases in pollutant concentrations precipitation, are not regulated. In addition, as well as ceilings for ambient concentrations, current EPA regulations limit the applicability 232 ● The Direct Use of Coal of air quality modeling techniques to a down- review the NAAQS and the criteria on which wind distance of not more than 50 km from the they are based, and revise them if necessary by source (because of EPA’s judgment that the 1980 and every 5 years thereafter. Thus more models are not reliable beyond this distance). recent evidence on health effects and on pollu- Although the 1977 amendments to the Clean tant transformations and transport should be Air Act include procedures for the prevention reflected within a couple of years in the stand- and abatement of interstate air polIution prob- ards and in the programs that implement them. lems attributable to particular sources, longer Second, the amendments require the States to range transport that may contribute to air revise their implementation plans by 1979 in quality problems farther than 50 km downwind order to provide for achievement of the pri- currently is unregulated. mary standards by 1982. However, this requirement may be largely moot if the standards are The 1977 amendments to the Clean Air Act made more stringent in 1980, and it does not include two provisions designed to remedy address the problem of implementing the sec- these problems. First, they require EPA to ondary standards.

IMPACTS TO WATER SYSTEMS

The impurities in coal that are released to Sources, Effects, and the air and land in all stages of the fuel cycle Control of Water Pollution may wend their way eventualIy into the waterways. Thus water may become the ultimate re- Coal Mining and Cleaning pository for many of the byproducts of coal activities. The water system can transport Surface Water Impacts. -In mining, huge these impurities both geographically—from slices are made into the earth, and layers once the local source to distant sites—and blologi- deeply buried are brought to the surface to be cally —from micro-organisms on up the food deposited, often only temporarily. In surface chain, often in ever-increasing concentration. mining, the top layers of overburden are placed in “spoil banks” until time for reclama- The uses for which our water systems are tion. In underground mining, the waste materi- needed include — roughly in order of increas- al is heaped at the surface, and the mine walls ing demand for water purity — navigation, rec- often remain exposed when the mine is aban- reation, irrigation, industrial processing, water- doned. At the preparation plant, where impuri- ing of stock and wildlife, maintenance of aqua- ties are removed from the coal, still more tic life, and drinking water supply. A lowering waste piles are generated. As long as these of water quality may affect these uses and once-buried materials remain exposed and un- consequently the health, economy, or quality stabilized, they are subject to runoff and ero- of Iife within a community. sion, and become the source of chemical and physical alteration of local streams. These im- The various activities of the coal fuel cycle pacts are addressed by a variety of State laws affect not only water quality but also water and, as discussed later, by Federal water pollu- quantity and hydrology. For example, mining tion and surface mining laws. can cause stream flows to change and water tables to decline, and in some instances may Within the coal production waste piles are affect the intensity of floods. Of particular many soluble components that dissolve as rain concern is the potential alteration of the water percolates through them. A conse- ground water system. quence is an elevation of total dissolved so/ids Ch. V—Environmental Impacts ● 233

(TDS) within the local watershed. TDS is a pa- (Indiana, Illinois, Western Kentucky )–where rameter of water quality that very generalIy in- the coal seams are rich in pyrite (iron disul- dicates the presence of soluble ions such as (in fide), The mining process exposes the pyrite to the case of coal waste runoff) sulfates, cal- water and air, causing a reaction that forms cium, carbonates, and bicarbonates (hardness). sulfuric acid and iron. The lowered pH also Elevated concentrations of these ions make tends to dissolve heavy metal compounds, water largely unpotable by altering its taste adding metal ions (aluminum, manganese, but otherwise have only minor human health zinc, nickel, etc. ) to the acidic drainage water. effects. TDS and hardness can also degrade the use of water for agricultural and industrial Acid drainage is a problem with active and uses. Regions that will absorb substantial TDS inactive mines, and with both surface and as a result of expanded coal mining are the underground mines. Recent data are not readi- Middle Atlantic (sulfate and fluoride from ly available, but in the 1960’s underground underground mining), and the Midwest and mining accounted for fully three quarters of North Central (sulfate from strip mining). the problem (see table 34). About 10,000 miles Acid mine drainage is a particularly severe of streams and rivers, principally in Appalach- byproduct of mining in those regions –Appa- ia, have been degraded by acid drainage. The Iachia and parts of the interior mining region effects are most severe in Pennsylvania and

Photo credit. EPA —Documerlca Acid mine drainage from abandoned underground mines and other sources still affects thousands of miles of streams in Appalachia 234 The Direct Use of Coal

West Virginia, while less severe in southern Ap- charge by controlling water flow in the mine, palachia. ” or treating the discharge by neutralizing the acid (or by using reverse osmosis or ion ex- Table 34.—Acid Drainage in Mines change techniques, at much higher costs). Although neutralization treatment can in- Acidity Source 1,000 lb/day Percent crease hardness and dissolved sol ids content, it is the commonly used method for controlling 614 9 acid mine drainage from active surface and 1,712 53 28 01 underground mines and is considered an effec- 361 11 tive control. Surface mines also must utilize 60 02 drainage control and special mining tech- 238 07 245 07 niques to properly control acid drainage. 100 3,258 The only major problem facing successful alncludes sources where underground could not be separated from surface control of acid damage from active surface mines is enforcement, which has been a long- The environmental effects of acid mine standing problem with the smaller mines. This drainage are severe. The acid and heavy situation is essentially duplicated with the con- metals are directly toxic to aquatic life, and trol of inactive surface mines: available recla- render the water unfit for domestic and indus- mation techniques can control acid drainage trial use. Zinc and nickel, often present in from most inactive mines, but enforcement ef- substantial quantities, are known carcino- forts on small mines must be strengthened to gens.82 Other carcinogenic trace elements are ensure adequate control. Also, a small percen- present in smaller concentrations but may tage of mining situations still defy acid control have additive effects. attempts. For instance, a few mines in West Virginia have been found to produce acid Many of the metals found in acid mine seepage from horizontal water movement drainage can become concentrated as they through buried spoils. However, strict enforce- move up the food chain. Adsorption of these ment by the new Office of Surface Mining and metals can occur on the surfaces of small sus- continued development of control techniques pended solids and sediments; thus, the largest for the remaining problem situations should reservoir of trace contaminants resides in the ensure an acceptable degree of control. bottom sediment and is available to the rest of the ecosystem according to a complex web of Unfortunately, available controls for inac- factors. An additional ecosystem impact is the tive underground mines are not likely to be as smothering of stream bottom-dwelling orga- successful. When an underground mine is be- nisms by precipitated iron salts. ing closed, the techniques for stopping acid drainage are: The acid content of the mine drainage also causes substantial material damage by eating ● sealing the mine to prevent air infiltration; away metal structures and destroying con- ● filling the mine with water; crete. ● preventing water infiltration by grading, sealing, aquifer control, etc.; A variety of measures exists to control acid ● backfilling the mine; and mine drainage from active and inactive sur- ● removing mine pillars and allowing the face and underground mines. All involve pre- mine to collapse. venting the formation of acid by controlling oxygen flow to the pyrites, preventing a dis- Although these techniques can be effective in some circumstances, success in preventing a continuing significant flow of water has been intermittent; the technology available to control acid drainage from most inactive underground mines must be considered inadequate. Ch. V—Environmental Impacts ● 235

An alternate approach to controlling drain ing organics used in the processing, as well as age in new mines, both during active oper runoff from waste piles. The latter is similar in ations and after abandonment, is to mine content but smaller in amount than the acid "down dip" - i.e., in mining a sloping seam, to drainage from mines. Techniques are available mine the coal from the top of the seam on to control these pollution sources. Federal down-rather than the usual "up dip." In this standards for coal preparation plants require type of mining, water will accumulate at the zero discharge of pollution, which should "working face" during operations and must be eliminate impacts from at least the larger pumped out. In a mine examined during an plants. Enforcement of these standards on the EPA study 8J acid levels in the drainage were ex smaller plants has been uneven in the past, and tremely low. After deactivation, the mine can future performance clearly depends on State be flooded, shutting off oxidation of the and EPA regional office resources. pyrites, without the need for a watertight seal. The disturbances of land by mining results in The extent to which this technique is appli physical as well as chemical pollution of cable has not been adequately demonstrated, streams. Erosion of unstabilized waste piles or but it is a promising approach to permanent of denuded land produces large quantities of acid drainage control. suspended solids and subsequent heavy silta As the shallower deep-minable coal reserves tion of local streams. Erosion is greatest from become depleted, underground mining will be surface mines in areas with rugged terrain and gin to shift to seams deep enough to be below rainy climates, such as southern Appalachia. the water table. Many of these mines can be Research in Kentucky indicates that sediment flooded without the use of a watertight seal, yields from lands strip-mined for coal can be allowing the seams to be shut off from air and as much as 1,000 times that of undisturbed for preventing acid drainage problems after the ests.84 I n more level and dry regions such as the mines are closed. Based on this expectation, Midwest or West, the problem is less serious. and on the expectation that reclamation of Sudden violent storms that occur in parts of abandoned mines (under provisions of the new the West, however, may wash large amounts of surface mining legislation) will proceed as silt into local waterways. planned, projections of acid drainage to the One effect of the siltation is to alter the year 2000 show a declining trend. character of stream bottoms. It may, for exam D ~ ~ ; ~ ~,.. • .,;...... 11/ .... I ; ~ '" ,.. ~ ; I,.. ,.. •• ~...... ,...... ~ \ AI ~,.. .. 1'C:bIVID VVllll OI"OIIlIC: :>VII:>, :>ULII 0:> lIlC: YYC::>l, ple, interfere with the spawning of fish eggs. do not have problems of acid mine drainage Siltation also causes material damage by short but may have a problem with increased salinity ening the life of reservoirs and increasing the caused by dissolution of soluble ions such as need for channel dredging. sulfates and chlorides. The impact depends on Coal mines are never the major cause of sus the elevation of TOS levels (for example, a 10- pended solids pollution on a regional basis, to 20-percent increase has little effect on but they have severe local impacts. At present, aquatic biota) and on the uses to which the mining causes significant consequences in the water is put. The impact of salinity in the Middle Atlantic (30,000 tons/yr, mostly under northern Great Plains, where water is used for ground mining) and Midwest (17,500 tons/yr, irrigating largely salt-resistant crops, may be mostly surface mining) regions and lesser im less severe than in the Colorado River Basin, pacts in the South Atlantic and North-Central where water is needed for more salt-sensitive regions. I mplementation of controls on both plants. In times of low water levels in the surface and underground mining will sharply streams, TDS concentrations may rise. reduce sediment loadings in most areas, and Thp rhpmir;ll nolilltion r;lll,p,-f hv rO;l1 nrpn- , .. ~ ~ .. ~ .... ~~, ,....~ .. ~~'~ .. ~~~~~~ ~ 1 ~~~, ,....'~,.... mining-caused suspended solids should de- aration inclUdes treatment water, often bear- 84( R. Collier, R. J Pickering, and J. S. Musser, "Hydro 8JJohn W Mentz and Jamison B. Warg, "Up-Dip Ver logic Influence of Strip Mining," U.S Geological Survey sus Down-Dip Mining," EPA-670/2-75-047, June 1957. professional paper 427-(, 1970. 236 ● The Direct Use of Coal cline significantly in the future. For example, from treatment of acid mine drainage. More loadings in the Middle Atlantic are projected water also may be demanded for irrigation of to decrease to one-third of 1975 levels by 1990. revegetated surface mines, especially in the One notable exception to this trend may occur West where reclamation is more difficult. The in the North-Central region, where sediment quantities of water are comparatively small loadings may increase sharply by 1990 unless (see table 35) but may nevertheless become a better controls are devised and implemented. public concern in arid regions where competition for water is becoming critical. However, Flooding potential is affected by several fac- the potential for water conservation in the tors related to surface mining: West is great enough to offset any potential . permeability of land surface, regional shortages if the legal and political bar- . vegetation cover of surface, and riers to conservation can be dealt with (see ● carrying capacity of streams. chapter IV, Water Availability).

The mining and reclamation process may act Ground Water Impacts. -Mining is likely to to increase surface permeability and thus have significant effects on ground water as allow the ground to soak up more water in a well as surface waters. Mining operations can given period than the premined surface could. both contaminate ground water and cause se- The loss of vegetative cover that acted as a vere physical dislocations of aquifers, water retention mechanism will tend to coun- teract this effect. In addition, increased ero- A primary mechanism of ground water con- sion and consequent siltation lead to de- tamination is the seepage of acid mine drain- creased carrying capacity of streams and age into aquifers via joints and fractures in the greater flooding potential. Studies of the ef- rock or via direct interception of the aquifer. fect of surface mining on flooding potential Inadvertent connection of two aquifers also thus have tended to conflict, with one study of can lead to contamination; this is more of a strip-mined watersheds in Kentucky showing problem in the West, where deep saline aqui- increased flooding potential and studies in ln- fers abound. Coal spoil banks also can be the diana indicating the reverse.85 An examination source of this contamination through leaching of these factors leads to the tentative conclu- and penetration of the soil. Investigations of sion that flooding potential may be decreased ground water contamination typically have by area mines, while contour mines may cause shown high local effects but extremely vari- increased flooding. Indeed, several studies able effects some distance from the m inc. now appear to support the association of surface mines with flooding in steep terrain. More Direct interception of aquifers and other studies, of surface mine hydrology, soil me- physical disturbances can substantially affect chanics, revegetation techniques, and the posi- the quantity of ground water as well as its tive impacts of methods to stabilize benches quality. Where a mine is located below the are needed to settle this issue. However, the water table, seepage of water into a mine pit only practical control of this problem in some can lower the water table and dry up wells in flood-prone areas may be a limit on surface the vicinity. (Thus, the trend towards deeper mining. mines, identified as providing a benefit in reducing acid drainage, can cause additional A final group of impacts is the alteration of ground water problems.) Blasting may rupture the hydrology of local water systems. Surface the impermeable strata below an aquifer and streams often are diverted around mines to cause water to seep to a lower level, or may in- lessen the degree of siltation or acid or alka- advertently connect two aquifers. The process line drainage. Some surface water may have to of mining and reclamation will change the per- be impounded for entrapment of silt or sludge meability of the overlying soil, altering the rate of ground water recharge, and affecting flood- * s’’ Appendix on Reclamation, ” Coal Extraction Land Reclamation Group, ” Argonne National Laboratory, Rail ing potentials (as discussed in the preceding Report. section). Ch, V—Environmental Impacts ● 237

Table 35.-Water Requirements for Coal System Activities

Peak water requirements associated with Water consumed by population increases’ energy facility Peak Acre-ft Gallonsl/106 Construction Operation Coal activity Size per year Btu in product (acre-ft yr) (acre/ft/yr)

Surface mine ...... 12 MMtpy 3,400 4 71 323 Underground mine ...... — 0 0 275 1490 Power generation ...... 3,000 MWe 29,000 54 (thermal) 853 260 157 (electric) Lurgi gasification ...... 250 MMscfd 6,700 28 1570 350 Synthane gasification ...... 250 MMscfd 9,100 38 1570 350 Synthol liquefaction ...... I00,000Bbl 17,500 28 1750 1800 day Slurry pipeline -...-..=...... 25MMmtpy 18,400 14 Not Not considered considered

aAssumes 150 gallons per capita per day, multiplier of 2 to account for added service personnel during construction, and a multiplier of 3.5 to account for families and service personnel during operation. SOURCE White et al., ’’Energy from the West’’, EPA-6OO/7-77.O72a, July 1977

Transportation that percentage of the energy originally present in the coal (about 60 percent in a modern Coal energy transportation systems—trucks, utility) that is not converted to electricity. This railroads, coal slurry pipelines, barges, and thermal energy is transferred to an adjacent transmission lines– can directly or indirectly river, lake, or cooling pond and to the local at- affect water quality. New clearing of rights-of- mosphere, in proportions depending on the way and construction of facilities will increase cooling system. The thermal pollution problem sediment loadings. Where herbicides are used is not unique to coal-fired utilities but is shared for clearing and maintenance, excess applica- to the same degree with oil and gas plants and tion can lead to both surface and ground water to a greater degree by nuclear plants (which contamination. Both coal slurry pipelines and currently are less efficient than fossil-f uel-f i red barge transportation on canals “consume” plants and thus produce more waste heat). water, the former by exporting water (approximately 500 acre-feet per mill ion tons of coal) The large quantity of heat that emanates out of arid regions, the latter by exposing more from a coal-fired utility boiler is bound to af- water surface to evaporation. fect at least the local environment. If heat is released in an open cooling cycle (that is, Transmission generally has insignificant water is withdrawn from a source such as a direct effects on water quality. The major in- river, lake, or ocean, circulated within the direct effect is associated with powerplant plant’s heat exchanger, and released at higher siting. A mine-mouth plant with long-distance temperature, usually to the original source), transmission lines may be sited in an arid many properties of the receiving waters are region, where the impact on water availability altered by the resulting temperature rise. is greater than if the coal were shipped to Changes occur in such properties as salinity, another site with abundant water. vapor pressure, etc.; the amount of dissolved oxygen in the water will decrease owing to Coal Combustion lowered volubility and re-aeration rates, while TDS will increase because of the increased Coal combustion releases thermal as well as volubility of many compounds with increasing chemical effluents into water systems. The temperature. These changes in turn alter the waste heat from a coal-fired boiler represents life functions of organisms within the water. 238 ● The Direct Use of Coal

Higher temperatures also may elevate meta- available, would still consume a large amount bolic rates of organisms, thus influencing ox- of water (50 to 60 percent of evaporative tower ygen demand, total energy needs, foraging consumption) because of the evaporative cool- ability, reproduction, migration, and suscepti- ing that takes place in the river or other body bility to disease. Heated effluents accelerate of water into which the heated water is dis- the consumption of dissolved oxygen by orga- charged. This fact has not always been consid- nisms; when coupled with lower oxygen levels ered by critics of the current requirements for as a result of the physical mechanisms noted closed-cycle systems. above, oxygen content can become critically The environmental effect of massive con- low within the thermal plumes. sumption of water by powerplant cooling sys- In addition to the thermal effect, physical tems is twofold: impacts are caused by small organisms or even ● The amount of water available to dilute fish eggs and larva being drawn through the downstream discharges is reduced, and cooling system of the plant. This entrainment water quality is thus degraded. This effect may damage these organisms and affect not is especially evident in the Colorado only their own lifespans but those of large fish River, where massive water consumption that feed on them. (by agriculture, in this case) coupled with These impacts can be mitigated by careful substantial pollution loadings have ele- siting of powerplants and construction of cool- vated salt concentrations in the River to ing intakes and outflows. However, complete the point where desalinization plants are control can be obtained only with cooling sys- required to keep water quality within tems that emit heat into the atmosphere or standards. into a small artificial body of water. These are ● In critical watersheds, the physical quanti- called “closed-cycle” cooling systems. ty of water remaining in the streams may Current Federal regulations require that, fall below that needed to support the wa- with certain exceptions, closed-cycle cooling ter ecosystem. The recognition that this systems be used in large, steam electric-gener- “instream use” of water is a “beneficial ating plants built after 1970 and certain use” within the legal system established smaller units built after 1974. Thus, closed- for allocating water rights is a recent one, cycle systems will be essentially standard and thus protection of water ecosystems equipment on new powerplants, and open- from destruction by sheer lack of water is cycle (“once through”) systems will be used a recent development. only in the Iimited cases where exemptions can The concentrating effect of evaporation in- be obtained (see chapter VII, section on Pres- creases the levels of mineral salts in the circu- ent Federal Coal Policy). lating water of an evaporative cooling system. The two major water impacts of closed-cy- This water must be continually bled from the cle, or evaporative, cooling systems stem from system and replaced with freshwater to main- water consumption and “blowdown” disposal. tain system operation. This bleed water, which Although water consumption by evaporative is extremely high in salt concentration, is cooling towers and cooling ponds depends on called “blowdown. ” Although the majority of many site-specific and design factors, in the “pollution” in the blowdown water is the general the evaporative systems associated same mix of salts as in the water source (with a with powerplants are the largest water con- small concentration of biocides to keep the sumers in the coal fuel cycle (see table 35). tower clear of fungae and algae, and some Their widespread use causes the issue of water dust scrubbed out of the air), this water can be use for energy to be a major concern nation- damaging locally because of the high salt con- wide, and especially in the arid Southwest (see centration levels, or when the water enters Water Availability, chapter IV). However, the ground water or surface water other than the use of relatively water-’ ’conserving” once- source. In some cases, the local effects of the through (open-cycle) cooling, in those areas biocides may be more damaging than those of where a sufficient volume of water would be the high salt concentration. Ch. V—Environmental Impacts ● 239

Photo credit: EPA — Documerlca The enormous quantity of water that must be evaporated to cool a large generating facility is graphically illustrated by these cooling tower “plumes”, which overshadow the plume from the plant’s stacks

Uncertainty about the precise level of con- The dissolved solids loading that electric trols that will be required is considerable. Pres- utiIities impose on the Nation’s waterways as a ent EPA effluent guidelines forbid the dis- result of blowdown (from both the cooling sys- charge of biocides but allow the discharge of tem and the boiler) is extremely large. Utilities the salts originally present in the intake water. produced nearly 6 million tons, or nearly 28 However, if the cooling process uses a signifi- percent of the total national dissolved solids cant portion of the water source, the blow- discharge in 1975 and may increase this to 10 down could violate water quality standards by milIion tons by 1990. The share of this burden substantially increasing the overall salt con- contributed by coal-fired utilities was nearly 4 centration; in these cases, some level of treat- million tons in 1975 and will be around 6.6 ment will be required. Also effluent standards million tons in 1990 with moderate coal for new powerplants in some parts of the West growth. Increases in utility coal burning play require totally closed-cycle operations, with important roles in the projected substantial blowdown being concentrated and either dis- growth in TDS by 1990 both nationally and in charged to evaporation ponds or else undergo- several regions: South Atlantic, Midwest, ing further treatment and disposal as a sludge. North-Central, and Central. Disposal problems are similar to those associated with disposal of fIy ash and fIue-gas The large water requirements associated desulfurization (FGD) sludge, except that trace with operation of a coal-fired powerplant can elements should not be a problem. be reduced substantially by the use of air- 240 ● The Direct Use of Coal

cooled or “dry” cooling systems, either by and that of sludge may be 19 million tons themselves or in combination with evaporative assuming moderate coal growth. These wastes systems. In the combination or “wet/dry” represent approximately half of the Nation’s system, the air-cooled tower may fulfill the total noncombustible solid waste and in- total cooling requirements of the powerplant dustrial sludges, respectively. By 1990, the in winter and be supplemented by the wet quantities of coal combustion waste requiring tower when weather conditions lower the cool- disposal may grow to 90 million tons of ash ing capacity of the ambient air. Using either and slag, and 35 million tons of scrubber system, the cost of building and operating the sludge (NE F #1). powerplant increases substantially because of The major ash-producing areas are the Mid- the large capital cost of the cooling systems, dle and South Atlantic and Midwestern States. lessened efficiency of the pIant due to a lower By the end of the century, the Southwest is ex- cooling capability, and the increased capital pected to join these regions as a major ash pro- cost of turbines designed to operate in a higher ducer. With the exception of New England and pressure environment. In a strictly economic the Northwest, the rest of the country should tradeoff, a decision to use these systems would also experience substantial increases in ash be correct if the cost of water began to ap- production in the near future. Although sludge proach $700 to $1 ,000/acre-foot. In few cir- production is relatively minor now, by the end cumstances would this tradeoff be made to- of the century the South Atlantic and Midwest- day, but these systems still might be utilized ern States should be major sludge producers, where water is unavailable for physical or poli- with the New York/New Jersey, Middle Atlan- tical reasons. tic, Southwest, and Central regions being ma- 8G In addition to the environmental impacts jor contributors. associated with their cooling systems, power- The potential disruption of water quality by plants generate additional water pollutants in these ash and FGD wastes depends largely on the form of a blowdown from the boiler and their chemical and physical structure. The ash acid drainage from coal storage piles. How- is an alkaline material consisting primarily of ever, these pollutant sources are relatively insoluble inorganic elements (most of which minor compared to their counterparts from the are enriched in concentration compared to cooling and extraction portion, respectively, of their natural abundance), as well as elevated the fuel cycle levels of radionuclides. Up to 10 percent of the ash consists of water soluble species, principal- Wastes From Coal Combustion ly calcium, magnesium, potassium, sulfate, Under current and future combustion con- and chloride. The presence of these materials trol technologies, coal impurities are removed creates a strong potential for leaching of ash from the air– onIy to reappear in solid or slur- components into surface and ground waters ried form. An air pollution problem is thereby unless the ash is carefulIy disposed. a’ transformed into a waste disposal problem. The sludge from FGD systems varies with the The concentrations of undesirable constitu- scrubber design and operation but in general ents within the wastes demand strict attention consists primarily of calcium sulfite or calcium to disposal methods to prevent contamination sulfate with some carbonates, inert elements, of surface or ground waters. and insoluble ions.88 Calcium sulfite hemihy- The wastes generated by coal combustion drate (the major species in the lime/limestone facilities are the fly ash from particulate con- scrubbers) consists of small, thin crystals that trol devices: the bottom ash and slag from the settle very slowly, making the sludge difficult boilers, and the sludge from FGD systems. In to dewater and contributing to its physical in- the future these wastes may include spent sor- stability. bent from fluidized-bed combustion (FBC) ‘b’’ Appendix on Ash and Sludge, ” Rail Report. units. By 1985, the quantities of ash and slag “Ibid , p. 11, requiring disposal may total 80 million tons, 881 bid., p. 13 Ch, V—Environmental Impacts ● 241

Photo credit: EPA — Documer/ca FGD sludge pond–Commonwealth Edison’s Will County powerplant

The concentration of trace elements in FGD ash transport water to receiving streams. Some sludge is much smaller than that in fly ash; of the solids and trace metals that are not in those that are present tend to be elements that solution in the alkaline ash medium may dis- escaped the ESP in gaseous form or that came solve as the pH is lowered in the receiving from the sorbent used. Often fly ash and FGD stream. If the ash transport water pH exceeds sludge are combined for disposal, and the mix- 9, it may have to be treated with sulfuric acid, ture may be referred to as flue-gas cleaning causing the formation of a precipitate (floe) (FCC) wastes. The ash helps increase the solids that can affect the receiving stream. content of the sludge but also contributes a In addition to direct discharge to surface substantial load of trace elements to the mix- waters, ponded wastes may leach to ground ture. water. In the case of sludge, the leaching Whether these undesirable elements in FCC comes both from the fluid (liquor) initially wastes enter surface or ground water depends present and from the dissolution of sludge on the disposal method used. The disposal solids once the fluid is gone, The major soluble methods traditionalIy used for ash and current- species in most FCC (combined) wastes are ly being considered for FGD are impound- chlorides and sulfates (primarily in calcium, ments (ponds), landfill, and utilization, in sodium, and magnesium salts). 89 These species decreasing order of common use for ash. Open-cycle ponds allow direct discharge of “Ibid , p 11 —.

242 The Direct Use of Coal have been found in high levels in FCC leach- ment, landfill, and utilization. Considerable ex- ates and would increase the TDS of ground perience exists with the disposal of ash by all and surface waters if leaching or surface of these methods. Pending has been the most discharges occurred. In addition, trace ele- common because it is the easiest and cheapest ments present in the ash may be leached out method; ash is sluiced to a lagoon near the and added to the potential groundwater con- plant, and the water is either returned or dis- tainination. charged. The imminent restrictions on ash transport water discharge and the declining The characteristics of FCC discharges that availability of land near powerplants may dis- are most important from an environmental im- courage future use of ponds (at least open- pact standpoint are the: cycle ponds) for ash disposal. ● presence of small particles, Ponds are less satisfactory for disposal of • high trace element concentrations, and FGD sludge (either alone or mixed with ash) ● reducing capacity of sulfite-rich sludge.90 than they are for ash. The use of a pond for Trace element contamination of surface and sludge disposal represents a long-term commit- ground water can lead to ingestion by aquatic ment of the land; pending of untreated sludge organisms and contamination of soils (and, in (and perhaps even some treated sludge) does turn, crops). Iron oxide floe and the FCC sludge not result in the degree of settling that would itself can coat the bottom of streams and dis- be required for future development on the site. rupt bottom communities. The oxygen demand The problems of leaching associated with of sulfite-rich sludge can cause serious stresses pending of wastes mandate attention to possi- on aquatic Iife by depleting oxygen supplies. ble lining of the pond, selection of a pond site These and other impacts, coupled with the with highly impermeable soil, and treatment of very substantial increases expected in FCC the sludge itself to reduce its porosity and waste generation, focus attention on the im- permeability. In addition, continual removal portance of appropriate specification of re- of the surface layer of water that develops in quired controls for waste disposal. the pond from rainwater or other runoff is Virtually all of the above pollution impacts necessary. of waste disposal are controllable with avail- These problems with pending appear to be able techniques, as discussed below, and both turning more plant operators in the direction surface discharge and leaching to ground of landfill for FCC wastes,9’ despite its higher water fall under existing regulations (discussed cost. For landfill purposes the ash is collected in the following section). Although leaching of dry and the sludge is dewatered and/or treated salts and trace elements into ground water to improve its structural properties. In this generally is considered a major problem with form the wastes are more easily transportable FCC disposal, the actual impact is extremely than the wet sludge, allowing the landfill site dependent on site-specific factors. In some to be further from the powerplant, perhaps in a cases, it could be quite small because of the less valuable location. However, the cost of attenuation of pollutants as they pass through transporting the dried and treated sludge is soil layers. Unfortunately, gaps in our knowl- high, and onsite disposal will be favored where edge of the pollutants present, the attenuative it is possible. Land impacts are decreased with nature of different soils, and the actual physi- landfill because of the smaller area and shorter cal characteristics of ground water systems retention time required before the land can be complicate the specification of potential envi- developed. As a tradeoff, the air pollution ronmental effects. from fugitive dust (especially for a dry ash As noted previously, the options for coal landfill in an arid climate) is greater during combustion waste disposal include impound-

“J. Jones, “Disposal of Power Plan:t Wastes, ” presented at the Third National Interagency Energy/Envirorr- 9[)1 bid mental R&D Conference, Washington, D.C, June 1978 Ch. V—Environmental Impacts ● 243 transport and disposal. This effect is highly whether the economics and institutional links local and may be mitigated by use of a wetting between mine and plant are favorable enough agent or by a buffer zone around the site. on a large scale to promote widespread use of this disposal method. Before sludge may be used for landfill it must undergo some physical or chemical treat- Another disposal method for FCC wastes is ment to improve its structural stability and to dump them in the ocean. The idea is appeal- reduce its volume, permeability, and porosity. ing for northeastern utilities that are close to One method is to alter the operation of the the coast but have little space to store wastes. scrubber itself to force the oxidation of sulfite The concept is further encouraged by the fact to gypsum. Alternatively, one might exploit the that the major chemical constituents in FCC finding that some modes of scrubber operation wastes are already in relatively high concentra- seem to produce forms of calcium sulfite that tions in seawater. Promising forms of disposal are easier to dewater. 92 are concentration of treated FCC wastes in bricklike form or dispersion of treated or The FGC wastes may be dewatered by sever- sulfate-rich FCC wastes in either deep ocean or al physical techniques such as vacuum filtra- on the Outer Continental Shelf .94 The envi- tion, centrifugation, or gravity settling in order ronmental impacts of ocean disposal are being to increase the percentage of solids (65 to 70 investigated by EPA. percent is desirable). Adding ash to the sludge also increases the solids content and lends The utilization of wastes is more appealing structural strength. from a resource conservation standpoint than is disposal, but it is not always as economicalIy Several commercial chemical sludge treat- attractive. About 20 percent of all ash is now ment processes have been developed and are used for some purpose, and the National Ash being used by coal-fired plants. Field tests of Association is actively pursuing new uses for chemically treated wastes demonstrate signifi- ash. The most promising use is in the manufac- cant structural improvement and a reduction ture of portland cement. Approximately one- in permeability, as well as a reduction in the third of the 1980 fly ash production could be concentration of dissolved solids in the leach- used for this single application .95 Other uses ate and a decrease in the actual volume of are as a light aggregate for construction, as a leachate. ” An additional benefit of sludge filler for asphalt, as an abrasive, and as a soil treatment is the improvement in handling additive. In addition, extraction of valuable characteristics, which allows better sludge minerals from the ash may be economically placement and thus additional control of feasible. leaching. The potential uses for sludge are not as Another disposal method for FCC wastes is numerous. In Japan, scrubbers are operated so burial with the mine wastes. This technique is as to produce gypsum, which is then used for felt to be too expensive for underground mines wallboard and portland cement. However, the but may be feasible for surface mines. The economics are not favorable enough for FCC concept is made more appealing by the coal wastes to penetrate the market in this coun- transportation link that connects a mine with a try.96 plant. Alternatively, the plant may be a mine- mouth plant with close ties, both geographical- An alternative to sludge disposal is to avoid ly and economically, to the mine. The mine sludge generation altogether. Several “regener- may welcome the wastes as additional fill to able” systems have been developed for FGD. restore the original land contour and, in the These typically produce elemental su!fur or East, as alkaline material to help neutralize sulfuric acid. Some wastes are emitted as a some of the acid wastes. It is not known “J. Jones, “Disposal of Flue-Gas Cleaning Waste, ” Chemical Engineering, Feb. 15, 1977 92lbld , p 12 “Jones, R&D Cont., p 1 ‘]’’ Appendix on Ash and Sludge, ” Rail Report “Ibid , p 2 244 ● The Direct Use of Coal bleed stream, but the volume is far less than being severe underestimates of the costs that wastes from nonregenerable systems. Sulfur is wilI have to be borne under RCRA. unfortunately not a scarce element but may These costs must be balanced against the become valuable when present sources are protection of ground waters and reduction in depleted. Iand use impacts provided by the increased Only general statements can be made about controls. An unfortunate side effect of a haz- the waste disposal problems associated with ardous designation for ash might be the elimi- the spent sorbent from FBC, because no large- nation of the ash byproduct market, but this is scale demonstration yet exists. The amount of clearly dependent upon the precise nature of sorbent waste generated will depend on the EPA’s regulatory stance, chemical balance needed to assure adequate removal of sulfur in the coal, but indications Regulations now are that the volume will be greater than that of sludge for a plant of comparable size Impacts to water systems are regulated burning the same coal. By contrast with under the Clean Water Act, the Surface Mining SIudge, however, the sorbent has a much Control and Reclamation Act (SMCRA), and higher solids content and greater structural RCRA. These are discussed in detail in chapter stability. Among the possible uses being in- VII and summarized below. vestigated is as an agricultural fertilizer. The Clean Water Act sets effluent limita- A key to the actual waste disposal alterna- tions for chemical and physical discharges tive selected will be the application of the Re- from steam electric-generating plants, coal source Conservation and Recovery Act (RCRA) preparation plants, and coal mines. For gener- described in the following section. Designation ating units, limitations have been established of sludge as a “hazardous” material under for discharges of: total suspended solids and RCRA will result in extensive use of liners, oil and grease from low-volume waste sources, chemical fixation, and landfill disposal of ash transport water, metal-cleaning wastes, scrubber sludge. DOE has estimated that such and boiler blowdown; copper and iron from a designation could increase sludge disposal metal-cleaning wastes and boiler blowdown; costs by about 20 percent over costs incurred free available chlorine from once-through by a “nonhazardous” designation” to a total cooling water and cooling tower blowdown; of about $600 million per year by 1990. Similar- and materials added for corrosion inhibition, ly, designation of ash as hazardous material is including zinc, chromium, and phosphorus, estimated to yield a 30-percent increase over from cooling tower blowdown. In addition, dis- the costs incurred with a nonhazardous desig- charges of total suspended SO I ids from materi- nation, to a total of about $1 billion by 1990 al storage and construction runoff are regu- for utilities. As even a nonhazardous designa- lated. tion will require an upgrading from present practice, the total cost of disposal for sludge For coal mines and coal preparation plants, and ash is estimated to increase up to 45 per- limitations have been established for dis- cent over present practice for a nonhazardous charges of iron and total suspended solids designation, and up to 84 percent if both are from acidic and alkaline mine drainage, and designated hazardous. The incremental cost of for manganese from alkaline drainage. In addi- waste disposal on electric generation was tion, the pH of all discharges from generating estimated to range from 1.22 to 2.01 mils/kWh units, mines, and preparation plants must be in under RCRA; in comparison, continuation of the range of 6.0 to 9.0. current practice would cost approximately 1 The Clean Water Act also limits thermal dis- mil/kWh (NEF#l). All of these cost estimates charges from steam electric-generating plants. have been challenged by the utility industry as Standards of performance for new units provide that there shall be no discharge of heat “National Environmental Forecast No 1. from the main condensers; existing units (with Ch. V—Environmental Impacts ● 245 some exceptions) must meet this limit by 1981. sealing acid-forming and toxic-forming materi- In addition, the Act requires that the location, als, selectively placing waste materials in design, construction, and capacity of cooling backfill areas, achieving rapid revegetation water intake structures reflect the best tech- and, where necessary, maintaining water treat- nology available for minimizing adverse envi- ment facilities. In addition, all surface drain- ronmental impacts such as impingement and age from disturbed areas must be passed entrainment of organisms. through at least one sedimentation pond.

Effluent sources must obtain a permit under Additional requirements for underground the National Pollutant Discharge Elimination mines include designing mines to prevent grav- System (NPDES), which includes all applicable ity drainage of acid waters and sealing and effluent limitations. Variances are available controlling subsidence. Similar provisions ap- only for sources that can demonstrate that fac- ply to support facilities such as coal loading tors related to the equipment or facilities in- and storage facilities, roads and other volved, the process applied, or nonwater quali- transportation faciIities, and mine buildings. ty impacts (such as economic factors) are fun- SMCRA also requires mine operators to damentally different from the factors consid- minimize hydrologic disturbances. Overland ered by EPA in establishing the effluent limita- flows and stream channels may be diverted tions. when necessary to comply with other perform- For the most part, the effluent limitations ance standards in the Act and when the diver- established under the Clean Water Act are in- sion meets specified engineering standards. In tended to achieve a water quality goal that addition, mine reclamation must restore the provides for the protection and propagation of premining capability of the area to transmit fish, shellfish, and wildlife and for recreation water to the ground water system. The mine in and on the water by 1983. Stricter I imita- operator also must replace water supplies used tions designed to eliminate all pollutant dis- for domestic, agricultural, industrial, or other charges will not be enforced until at least the uses when they become contaminated, dimin- late 1980’s. ished, or interrupted as a result of mining activity. No Federal regulations deal with water consumption by coal combustion facilities. Water In order to obtain a mining permit, the mine rights traditionally have been regulated by the operator must demonstrate that these require- States, and the means of allocation vary wide- ments will be met and that they will be ade- ly by region. The 1977 amendments to the quate to comply with all applicable Federal Clean Water Act reaffirmed this system by and State water quality standards and effluent stating that the Act in no way impairs the au- limitations. thority of each State to allocate quantities of water within its jurisdiction. However, the Act The disposal of combustion byproducts is does require that water resource management regulated under the Clean Water Act and be considered in State water quality planning. RCRA. Where the wastes are discharged to receiving waters, they come under the Clean SMCRA sets performance standards for sur- Water Act; an example, as discussed above, is face mines and for the surface operations of ash transport water. Land disposal of the underground mines that are designed to pre- wastes is regulated under RCRA, which seeks vent acid and other toxic drainage as well as to control open dumping of wastes under a runoff containing suspended sol ids, and to pre- system of State plans and permits for waste vent disruptions in local water supplies. Man- disposal. The Act distinguishes hazardous and dated practices to control surface mine- nonhazardous wastes and places more strin- related water pollution include stabilizing gent restrictions on the former. If either ash or disturbed areas, diverting runoff, regulating scrubber sludge is determined to be hazard- the channel velocity of water, lining drainage ous, the disposal options for these substances channels, mulching, selectively placing and are constrained. For example, sludge ponds 246 ● The Direct Use of Coa/ would have to be constructed in a manner that be prohibited in wetlands or floodplains would prevent any leaching to the ground (where most large combustion facilities such water. Similarly, burial of wastes or their use in as powerplants are located), adding substantial landfills or in roadbeds would be prohibited transportation costs to the waste disposal where there is any possibility of leaching. In costs. addition, disposal of hazardous wastes would

IMPACTS TO THE LAND

The impacts from air pollution provide an face mining in the northern Great Plains and, interesting contrast to the direct impacts to the to a lesser extent, in the Southwest. Surface land caused by the use of coal. The air emis- production in the Midwest fluctuates widely in sions from the coal fuel cycle stem primarily the long term with varying assumptions, al- from coal combustion. Many of the impacts though it is unlikely to increase much by 1985. are subtle or are masked by other factors; As shown in table 36, Western surface min- others take a long time to become manifest. ing disturbs considerably less land per ton of By contrast, the land impacts of the use of coal extracted than do Eastern and Central sur- coal stem primarily from the mining and waste face mining. This occurs because many West- disposal portions of the fuel cycle. These im- ern coal seams are over 50 feet thick, allowing pacts are more site specific and often cause extraction of more tons per mined acre. acute and drastic alterations of a local area. The most obvious land impact of a surface The land impacts of mine activities are more mine, while it remains active, is the complete likely to damage plantlife, animals, or human removal of the land from its normal uses. The beings by mechanical harm (such as that resulting from removal of habitat or from landslides and floods) than by chemically induced Table 36.—Land Affected by Coal Utilization damage. Some land disruptions, such as blast- Acres over ing damage, may be short term. Others, such 30-year as subsidence, may Iinger for many years. Facility period

A variety of impacts to other media result in- Mining: 10T5 Btu’s per yeara directly from perturbation of the Iand by coal Western strip ...... 4... 15,000-96,000 Central strip ...... 216,000 extraction and waste disposal. These include Central room and pillaP ...... 525,000 air pollution from coal mine fires and fugitive Eastern contour ...... 470,000 dust or water pollution from waste pile runoff. Eastern room and pillarb ...... 560,000 Gob and refuse disposalc ...... 15,000 Although the specific details are treated in the sections concerned with the air and water Combustion/Conversion: c Input of 10’5 Btu’s/ media, the interaction of the three media year shouId not be forgotten. Powerplants ...... 13,600 Lurgi gasification ...... 6,500 Synthoil liquefaction ...... 6,300 Sources, Effects, and Control of Land Impacts

Surface Mines

Although estimated future coal production levels, and therefore land use impacts, vary considerably with assumptions about environmental policy and economic conditions, most SOURCE: Calculated from White et al , “Energy from the West”, EPA—60017-77. studies show a very substantial increase in sur- 072a, July 1977. Ch. V—Environmental Impacts ● 247 surface covering, which may have been agri- hydrological impacts that would affect the cultural crops, range land, forests, or desert, is agricultural productivity of the valley floors. replaced by the sights of excavation and the As discussed below, SMCRA strictly regulates sounds of blasting. Wildlife, deprived of food mining on alluvial valley floors, but interpreta- and cover, must migrate if possible to other tion and enforcement of the law’s provisions is areas. The unsightliness may degrade both critical to the actual degree of protection af- property and scenic values, impacting a dis- forded these lands. tance beyond the mine equal to the extent of Another type of land where surface mining the vista. Thus the surface mining of one might threaten the resumption of a vital func- mountain can alter the recreational quality of tion is the agricultural farmland of the Mid- a large geographical area. west. Before passage of SMCRA, new strip min- Once the coal resource has been extracted ing would have encroached on prime agricul- from a given area, the land generally can be tural lands. For example, in 1976, about 75 per- recontoured and revegetated so that it can cent of the surface mine permits issued in 11- support former uses. There is sufficient recla- Iinois were for lands classified as prime agri- mation experience with most of the coal-pro- cuItural lands by the Soil Conservation Serv- ducing areas to suggest that successful recla- ice. The main concern surrounding agricul- mation will occur with the appropriate com- tural lands is that the ecology of the soil sys- mitment of resources. Doubts about the suc- tem is too little understood for the success of cess of reclamation procedures, however, have reclamation to be guaranteed. Only recently been fostered by the poor attention given to have researchers begun to treat soil as an reclamation in the past. Some 420,000 acres of ecosystem rather than as a mineral. 00 It is not mine lands are unreclaimed. Although more known whether the soil productivity deteri- stringent reguIations and keener public aware- orates as the soil layers are removed, sepa- ness should produce a better record in the rated, piled, and stored. future, the past can serve as a reminder of the Some concern also centers on stands of importance of constant monitoring. Doubts hardwood timber in southern Appalachia that about reclamation also stem from lack of ex- require decades or even centuries of natural perience in reclaiming some of the more eco- forest succession to become re-established. logically fragile regions to be mined in the The Ponderosa pine forests in the West also future. In particular, experience with revege- are believed to be quite difficuIt to re- tating strip mines in the arid or semiarid establish. A final concern is that some areas regions of the West is not extensive. A key (southern Appalachia in particular) have such issue here is whether apparently successful steep slopes that reclamation is unfeasible. reclamation efforts may degrade over time, es- The rapid erosion of soil prevents successful pecialIy in the face of periodic droughts. rooting of vegetation. The concern over reclamation centers on Surface mine reclamation usually proceeds lands that play a unique vital role in a region, in parallel with excavation; the overburden and many of these critical lands are protected and topsoil from the active area are placed in by the 1977 SMCRA. Among these are the allu- the area of the previous cut. The overburden is vial valleys, which often form the backbone of backfilled, graded, and compacted. The top- the ranching and farming economy in semi- soil is removed and replaced as a separate arid regions. Even though only 3 percent of the layer. The land is then replanted with some coal leases in an eight-State area of the West species of vegetation. underlie such valleys, the shallow overburden there makes these lands most attractive for Besides merely replacing topsoil and over- mining. ” Some fear that even strip mining in burden separately, these materials must be

the lands adjacent to alluvial valleys, where 10 “Department of Mines and Minerals, “1976 Annual percent of the strippable coal exists, may have Report – Surface Mine Land Conservation and Reclama- tion, ” Springfield, III , 1976 1 9“’Appendix on Reclamation, ” Rall Report, p 27 100’’Appendix on Reclamation, ” Rail Report, p 35 replaced properly: toxic or acid-producing quire proof in the form of scientifically valid layers in the overburden must be identified experiments. and covered by sufficient depth of acceptable The provision to return land to its approx- material to prevent containinants from enter- imate original contour will help minimize any ing the aquatic environment; layers must be permanent disruption by surface mining in ordered to prevent fine topsoil particles from most locations. However, universal applica- being swallowed by coarse particles. Finally, a tion of this requirement may be inappropriate. thick layer of subsoil must underlie the topsoil. I n the steep terrain of Appalachia, reclamation All plans for soil layer replacement must be of slopes greater than 300 may be hindered if based on thorough analysis of the overburden the land must be returned to its original slope, in the area. as the long, uninterrupted slopes will promote In prime agricultural lands, the permanent erosion. (The law does, however, allow the use provisions of SMCRA require the segregation of terracing and other erosion control meas- of topsoiI horizons so that the root zone can ures to alleviate this problem. ) In other areas, be reestablished. Before a permit is granted for local governments and residents might prefer a new surface mine in such areas, the operator alternative configurations to allow new uses must demonstrate that the original soil produc- (or enhance old uses) of the land. For instance, tivity will be restored. Some operators current- land contour shaping can be used to trap water ly mining prime farmlands contend that they and allow growth of important wildlife cover have indeed done this, but the regulations rein portions of the arid West. Ch. V—Environmental Impacts ● 249

Underground Mines Atlantic regions, where underground mines could affect up to a few percent of the total Although less conspicuous than surface land in those regions. 102 mines, deep mines nevertheless can have severe impacts on the land. Aside from their im- The amount of land potentially disturbed by pacts on hydrology, underground mines have a underground mines is greater than that for sur- potential for subsidence. This problem occurs face mines of the same production capacity, when the support of the mine roof either shifts as illustrated in table 36. This table compares or CO I lapses. While subsidence can occur dur- the land affected by 30 years of various types ing the active operation of a mine, it is more of coal activity that produce or consume 1 likely to be delayed for many years as the mine Quad of energy. This comparison between the pillars slowly erode and collapse. The altered effects of surface and deep mines must be ground slopes can damage roads, water and made cautiously. Surface mining disturbs all gas lines, and buildings. The subsidence may the land, but for a limited time. For deep further change natural drainage patterns and mines, one can cite only the maximum amount river flows, intercept aquifers and existing of land that could be disturbed, with the ac- springs, or create new springs and seeps. tual acreage, duration, and degree of disruption subject to greater uncertainty. The extent, severity, and timing of the subsidence are complex functions of soil composi- Subsidence problems can be addressed by tion, overburden thickness, and mining meth- both preventive and corrective measures. The od, to name only a few relevant factors. The common preventive measure for subsidence is difficulty in predicting and preventing sub- to leave a considerable portion of the coal sidence complicates land use planning greatly. itself — sometimes as much as half — in place Just the potential for subsidence may reduce as a roof support. the land available for construction of homes Another strategy is to allow subsidence to and businesses. Even farming of the land may occur but in a controlled manner. In this be discouraged by possible future unevenness scheme, called longwall mining (see chapter of the surface. I II) each section of the mine is collapsed after Unfortunately, reliable surveys of sub- all the coal is extracted. This allows surface sidence do not exist, although a sizeable per- subsidence to occur sooner than with room cent of the 8 milIion acres undermined to date and pillar mining, and the subsidence also oc- have experienced some degree of subsidence, curs more evenly with major disruptions only and more of this acreage may yet subside in at the perimeter of the mined area. Thus, years to come. Future subsidence impacts will future plans for the land may be made with depend heavily on the success of preplanning greater certainty. Longwall mining is used ex- and control measures, and upon the degree to tensively in Europe, but there has been less ex- which underground mines will contribute to perience in the United States. the future U.S. coal supply. A Bureau of Mines One of the few corrective measures that can report estimates that a potential 1.5 million be applied to existing mines is to backfill them acres would be affected by subsidence by 101 with mine waste or other materials (including 2000. A study of the environmental impact FGD sludge). At first glance this suggestion of the National Energy Plan assumed that 35 seems to solve the waste disposal and subsi- percent of coal production would come from dence problems at the same time. More exten- underground mines by 2000. The study pre- sive studies, however, reveal that this method dicted that, in that year, underground mines is quite expensive, involves considerable would account for three-fifths of the land hazard to workers and may release contami- disturbance by total coal production. Most of the impact would be in the Middle and South ‘[’2 Annual Environmental Analysis Report, Vo/ume I Technical Summary (Washington D C U S Energy ‘“’’’ Appendix on Acid Mine Drainage and Subsi- Research and Development Administration, Office Of dence,” Rail Report, p 37. Environment and Safety, September 1977) 250 ● The Direct Use of Coal nants into the ground water. I n addition, some are subject to residential or agricultural devel- mine wastes and untreated sludge lack the opment. A considerable fraction of the subsi- structural strength to provide the needed sup- dence problem in Pennsylvania has resulted port for the mine roof. An additional tech- from the underground mines in the urban areas nique that is quite feasible for some of the of the anthracite region. shallower mines is “daylighting;” it involves surface mining to obtain the remaining coal The problems of surface mining are more se- and reclaiming the entire area. This technique vere in southern Appalachia because of steep is a cure for acid mine drainage as well as sub- slopes and heavy rainfalls. The stands of hard- sidence in abandoned mines. wood forests require much longer times to re- establish than do the softwood forests of the Regional Factors northern region. The regional variation of the extent of land disturbed is largely a function of the thickness Surface mining in the Illinois Basin will be of the predominant coal seams. Western coal, limited in those portions that are designated as although low in heating value (and thus at a prime farmland, as discussed earlier. In other certain disadvantage when comparing impacts regions, reclamation is facilitated by relatively on a unit energy basis), affects strikingly less flat topography and favorable rainfall. The im- acreage than either Eastern or Central coal pact of subsidence from underground mining because of the extreme thickness of the coal in this region is relatively unknown, but sub- seams (seams greater than 50 feet in thickness sidence may pose serious problems for agricul- are not uncommon). On the other hand, many tural lands. Appalachian seams are only a few feet thick and thus require the disturbance of consider- Over the next several decades, surface min- ably greater acreage to extract the same coal ing is expected to dominate coal extraction in energy. In fact, virtually all of the effects of the northern Great Plains. The key problem in mining vary greatly with geographical factors, reclamation will be the scarce water supply so it is instructive to give an overview of the and rainfall, coupled with the lack of ex- pertinent characteristics of each general pro- perience with reclamation in this region. The vi rice. alluvial valleys in these regions are protected by the SMCRA, as discussed earlier. The major coal-producing area in the East – Appalachia —can be divided into two regions, Surface mining also will be the dominant based on differing concerns over mining. In mining method in the gulf coast, where lignite northern Appalachia, stretching upwards from reserves are concentrated in Texas. Except in the northern coalfields of West Virginia, the the areas south of the Colorado River, rainfall topography is not rugged, and the soils contain appears adequate and potential land impacts substantial acid-forming materials. The region minimal. is densely settled, and the land is dotted with small farms and forested primarily with soft- In the Rocky Mountains, most mines in west- woods. By comparison, southern Appalachia ern Wyoming, western Colorado, and Utah will has more steep, rugged terrain and smaller be underground. The low population density concentrations of acid-forming strata. The and infrequent farms should minimize eco- population is less dense and the forests are nomic damage from subsidence. By contrast, mainly hardwoods. the subbituminous coal deposits in New Mex- These characteristics make the impacts of ico and Arizona will most likely be surface acid drainage more severe in the northern re- mined. The limited rainfall could hamper gion and necessitate careful attention to prop- reclamation efforts, but some mines have been er management of toxic spoil banks there. In successfully revegetated when irrigated. addition, the subsidence problem is of greater Therefore, the surface mine impact there is impact in northern Appalachia, for more lands uncertain. Ch. V—Environmental Impacts ● 251

Mine Wastes during a heavy rainstorm and flooded the valley below, causing more than 125 deaths and Both surface and underground mines gener- millions of dollars in property damage. A 1974 ate large quantities of wastes that impact both study of dams in the East, only 40 percent com- water and land. The waste is of three types: pleted, found 30 similar water impoundments 1. the solid waste from underground mines, that were classified as imminent flood hazards which commonly is called “gob” and cor- and 176 additional structures that were classi- responds in composition to the over- fied as potential flood hazards ‘“3 burden removed in surface mining; A major concern about coal gob and refuse 2. the refuse from coal washing and prepara- piles — especially in the eastern regions — is tion, which consists of coal waste and their content of acid-producing materials. Ex- other impurities; and posure of these layers to air and water causes 3. the sludge resulting from treatment of the leaching of coal impurities into surface acid mine drainage. and ground waters. Erosion of these wastes The total amount of solid waste generated also contributes sediment and dissolved sol ids by coal mines in 1975 was estimated to be to local waterways, as was discussed in the sec- almost 50 milIion tons. tion on water impacts. Although the percentage of coal that is washed has decreased from about 65 to 41 per- Transportation and Transmission cent between 1965 and 1975, the fraction of coal that is discarded has increased from The key factors determining the land re- about 20 percent to around 29 percent. One quirements for the various coal energy trans- reason for the larger quantity of waste from portation modes are the right-of-way require- coal cleaning is the greater use of automated ments, disturbances outside the right-of-way, equipment that digs less selectively than the the directness of the route, barriers created, hand-mining methods of the past. A second other uses of the right-of-way, and other uses reason is that most coal is now being extracted of the mode. Transmission and waterways gen- from seams that are less rich and hence con- erally require the widest paths, typically about tain more impurities. More than 3 billion tons 200 feet. Waterways may also produce flood- of waste Iie in 3,000 to 5,000 refuse banks in ing for a much wider distance, or require exten- Eastern coalfields. sive areas for disposing of dredged material, Slurry pipelines may disturb large areas during One of the most obvious impacts of these construction. Rails, waterways, and highways unsightly wastes is the degradation of local may act as barriers to people or wildlife. These property values and destruction of esthetics. three modes can be useful for other purposes, The land used for waste disposal, unless re- while slurry and transmission lines are dedi- claimed, is no longer available for other uses. Furthermore, the gob, refuse, and sludge cre- cated to one product. The rights-of-way of the latter, as well as those of waterways, however, ate dangers of many kinds if effective disposal may have multiple uses such as pathways or techniques are not applied to them. First, the farming, which may provide a Iand benefit. In refuse piles contain flammable material that the case of very high-voltage transmission makes them susceptible to spontaneous com- lines, multiple use may be compromised be- bustion. They are also vulnerable to landslides cause of the possibility of electrical effects. and erosion because they usually are com- The existence of these effects remains a con- prised of mixed, poorly graded, and uncom- troversial issue. pacted material. These wastes have been used to construct dams near the minesite for impoundment of water or slurry, a use to which they are poorly suited. The danger of this prac- ‘“’ The National Strip Mine Study– Vol. 1, Summary Re- tice was dramatized in 1971 when such an im- port, (U S Department of the Army, Corp of Engineers, poundment, in Buffalo Creek, W. Va., broke Washington, D.C. 1974) 252 ● The Direct Use of Coal

Coal Combustion opment for a considerable period. The choice of disposal technique, if not dictated by RCRA, AS noted earlier, both the ash and the scrub- should depend largely on the value of land, Of ber sludge produced by utility and industrial the major sludge-producing regions, the more boilers represent a very sizable disposal prob- densely populated ones–the Midwestern, lem. With particulate collectors on most large New York/New Jersey, and MiddIe Atlantic coal-fired boilers, 92 percent of all fly ash gen- regions — might be expected to lean heavily erated in the United States is now collected. toward landfill disposal. As the major prob- This collection efficiency should increase with lems associated with obtaining suitable land time because Federal standards now require disposal sites may fall on industrial coal users greater than 99-percent collection for moder- rather than on utilities — because the industrial ate and large boilers. Also, provisions for re- plants may be expected to locate closer to ur- quiring technological controls for SOx will ban centers– industrial users may also be ex- yield increasingly large amounts of scrubber pected to lean more heavily toward landfills. sludge requiring disposal. As noted in the pre- However, other factors, such as the impor- vious section, the total solid waste— fly ash, tance and vulnerability of ground water and bottom ash, and slag–generated in 1985 is the State and local regulatory climate, should projected to be approximately 80 million tons play a major role in disposal decisions. per year, while scrubber sludge is expected to be about 19 million tons assuming moderate coal growth. ’04 Although this weight of sludge is only about one-quarter of that projected for Regulations ash wastes, the two materials may necessitate comparable storage volumes because of the The land impacts of coal production and use high water content of the sludge. For example, are regulated primarily under SMCRA and the sludge produced in 1 year by a “typical” RCRA, which are directed at mining and waste 1,000-MW powerplant (3.5 percent sulfur, 90 disposal practices that tend to cause land im- percent SO2 removal, 12 percent ash, 6,400 pacts. In addition, a variety of provisions cover hrs/yr, 20 percent excess lime, 50 percent oxi- the potential land impacts of transportation dation, 0.88 lb coal/kWh) requires 630 acre-feet and transmission. These laws are summarized of pond volume if it is 40-percent solids and below and discussed in detail in chapter VI 1. 270 acre-feet if the sludge is dewatered to 70- The primary purposes of SMCRA are: percent solids. The ash produced in 1 year would occupy about 140 acre-feet. Over a 30- ● to ensure that surface coal mining opera- year lifetime, the plant would require about tions are conducted in a manner that pro- 600 acres for waste disposal (assuming the ash tects the environment, and dewatered sludge are mixed and placed in ● to ensure that adequate procedures are a 20 feet thick storage area). By the year 2000 undertaken to reclaim surface areas as or so, the cumulative storage area devoted to contemporaneously as possible with min- these wastes could approach 100,000 acres, or ing operations, and welI over 100 square miles (based on the same ● to strike a balance between protection of assumptions). the environment and agricultural produc- Although the land use requirements for tivity and the Nation’s need for coal as an sludge disposal are similar to those for ash essential source of energy. disposal, the actual land impact attributed to the sludge could be considerably greater than i o accomplish these ends, SMCRA man- that of the ash if pending remains a predomi- dates State permit systems in accordance with nant sludge storage mechanism; in that case, Federal guidelines that include comprehensive the land utilized will be unavailable for devel- performance standards for surface mining operations and for the control of surface ef- ‘(’’National Environmental Forecast No. 1. fects of underground mining. Ch. V—Environmental Impacts ● 253

For surface mining, the environmental per- that which existed prior to mining. In addition, formance standards regulate the removal, stor- the surface soil horizon must be replaced in a age, and redistribution of topsoil; siting, ero- manner that prevents excessive compaction sion control, drainage, and restoration of coal and reduction of permeability and that pro- haul roads; protection of water quality and the tects against wind and water erosion. Finally, hydrologic balance; waste disposal; backfill- the operator must apply nutrients and soil ing, grading, and revegetation, and postmining amendments as needed to establish quick land uses. This section discusses those provi- vegetative growth. sions of SMCRA that relate to areas of special concern, such as alluvial valleys and prime Protection of timber stands under SMCRA is farmland. The overall legal framework of the not as rigorous as that afforded to alluvial Act is discussed in chapter VI 1. valley floors and prime farmland. In general, mine operators must establish a diverse, effec- Minimum performance and reclamation tive, and permanent vegetative cover of spe- standards for alluvial valley floors in the arid cies that are native to the area or that support and semiarid areas in the Western United the approved postmining land use. Introduced States are intended to preserve existing or species may be substituted only if they are of potential agricultural uses and productivity. equal or superior utility for the postmining An applicant for a mining permit in these areas land use and if they meet the requirements of must demonstrate that the operations will pre- State or Federal laws. Specific provisions for serve the essential hydrologic functions of an forest land in the Eastern United States, as alIuvial valIey floor by maintaining the geo- measured 5 years after planting, require an logic, hydrologic, and biologic characteristics average of 600 trees of commercial species of that support those functions. These require- at least 3 years of age per acre. I n the Western ments apply both to disturbed and adjacent United States, where shelter belts, wildlife undisturbed areas. I n addition, surface mining habitat, or commercial or other forest land is and reclamation operations may not interrupt, the approved postmining land use, the oper- discontinue, or preclude farming on alluvial ator must conduct a premining and postmining valley floors unless the premining land use is inventory of vegetation. The density and num- undeveloped rangeland or the area affected is ber per unit area of trees and shrubs on the small and production is negligible. The mine restored land must be equal to or greater than operator must conduct environmental moni- 90 percent of the premining density and num- toring to ensure that these requirements are ber. The success of the reforestation, in terms met; where the monitoring shows they are be- of species, diversity, distribution, seasonal ing violated, mining must cease until approved variety, vigor, and regenerative capacity of the remedial measures are taken. However, mines vegetation, is evaluated on the basis of the that were permitted or in production before results that reasonably could be expected from August 1977 are exempt from these SMCRA re- the approved reclamation plan. quirements.

SMCRA also includes regulations designed Finally, reguIations promulgated under to minimize the effects of surface mining on SMCRA provide special environmental per- prime farmland so that the land will have formance standards for operations on steep equal productivity after mining and is not lost slopes. Spoil and waste materials may not be as a resource. Each soil horizon used in recon- placed on the downslope; the highwall must be struction of the soil must be removed before completely covered with compacted soil and drilling, blasting, or mining in a manner that graded to the original contour; land above the prevents mixing or contaminating the soil hori- highwall may not be disturbed; woody materi- zon with undesirable material. When replaced als may not be buried in the backfill area, and and reconstructed, the soil material must be at unlined or unprotected drainage channels may least 48 inches deep and must create a final not be constructed on backfiiIs unless they are root zone of comparable depth and quality to stable and not subject to erosion. 254 The Direct Use of Coal

Photo credit: Union Pacific COAL MINING.—This was a coal mine pit 3 years ago. Arch Mineral, operator of the Medicine Bow Coal Mine in Wyoming, follows rigorous reclamation, regrading worked over areas into gentle contours and reseeding with native grasses Ch. V—Environmental Impacts . 255

105D Willard, et al “Land Use Changes Resulting from Strip Mining in the Ohio River Basin Energy Study Region” (Draft Report, unpublished) October 1978 Chapter VI WORKPLACE AND COMMUNITY IMPLICATIONS

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INTRODUCTION

This chapter discusses the occupational and social implications of increased coal production and use. It seeks to identify likely problem areas and enable policymakers to assess the need for remedial action. The trends in mine health and safety performance are traced and estimated future costs of increased coal production are presented. The socioeconomic impacts of more coal development differ in the East and West. Separate sections are devoted to the current experience in each region, and likely patterns of development are described.

WORKPLACE HEALTH AND SAFETY

Health after 1969 have lowered the amounts of respirable dust that miners now breathe on the job. Background But other hazards were overshadowed in the Coal mines are inherently unhealthy places debate over CWP. This section discusses CWP to work. Mortality studies of mineworkers who and the programs to control the respirable dust were employed in the 1940’s, 1950’s, and 1960’s that causes it, as well as other relevant health suggest that they died more often than others hazards. from respiratory diseases (influenza, emphy- The costs of occupational illness from coal sema, asthma, and tuberculosis), stomach and mining have been immense. More than 420,000 lung cancer, and hypertension. I Pneumoconi- coal workers “. . . who are totally disabled due osis and bronchitis were underlying causes of to pneumocniosis . . .“2 or their widows were death in a significant number of fatalities at- awarded Federal black lung compensation be- tributed to nonmalignant respiratory diseases. tween January 1,1970, and December 31, 1977. Since 1969, Federal officials, mine operators, That number of beneficiaries equals the total and coal workers have sought to minimize ex- number of coal workers employed industry- posure to coal mine dusts and noise, and they wide in 1950. Occupational health officials at have succeeded to a degree. If current dust the United Mine Workers of America (UMWA) standards are met on a daily basis, coal work- estimate that 4,000 Federal black lung bene- ers’ pneumoconiosis (CWP) should disable far ficiaries have died from black lung disease fewer workers 20 years hence than today. each year since 1969. other work-related ill- Many occupational diseases require two or nesses– hearing loss, bronchitis, and breathing three decades to become manifest. Because difficuIties– are impossible to estimate. about half of the total coal work force is under Occupational illness usually affects older or 34 years of age, the actual results of today’s retired workers, leaving them financially and dust-control efforts will not be known until the psychologically strapped. For every worker 1990’s and beyond. Efforts focused on CWP disabled by CWP, two or three family members are also affected. Stress is created. Work schedules must be readjusted. Family income

‘Public Law 91-173, Federal Coal Mine Health and Safety Act of 1969, title IV, pt. A.

259 260 ● The Direct Use of Coa/ is reduced. Bills from doctors and hospitals magnified many times for the deep miner. In rise. an underground mine the dangers of dust, fumes, noise, and other contaminants are in- Discussions of occupational disease often tensified by close quarters and artificial ven- dwell on numbers, percentages, and sanitized tilation. Surface miners, too, face health haz- scientific terminology. To the victim, black ards. The outdoor work environment of these lung can bean overwhelming fact of life: heavy equipment operators, truck drivers, sup- At work you [coal miners] are covered with ply workers, welders, electricians, and mechan- dust. It’s in your hair, your clothes, and your ics exposes them to dusts, heat and cold, diesel skin. The rims of your eyes are coated with it. and welding fumes, whole-body vibration, It gets between your teeth and you swallow it. noise, and stress. Because the underground en- You suck so much of it in your lungs that until vironment is so clearly more hazardous, com- you die you never stop spitting up coal dust. paratively little research has focused on sur- Some of you cough so hard that you wonder if face miners. you have a lung left. Slowly you notice you are getting short of breath when you walk up a Table 37.— Eight”Year Summary of Black Lung hill. On the job, you stop more often to catch Compensation your breath. Finally, just walking across the (Jan. 1, 1970-Dec. 31, 1977) room at home is an effort because it makes you so short of breath. J The cost of mineworker occupational illness Claims filed: Social Security ...... 586,400 are also borne by the public and, to a lesser Labor ...... 124,200 extent, by the coal industry. Black lung com- Total ...... 710,600 pensation has been administered by the Social Claims approved: Security Administration and, since July 1973, Social Security ...... 415,200 by the Department of Labor. Table 37 summa- Labor ...... 5,744 rizes the 8-year dollar cost of this program. Of Total ...... 420,944 the $5.569 billion paid to miners and their sur- Claims denied: vivors from 1970 through 1977, the Federal Social Security ...... 171,200 Labor ...... 68,062 Government paid $5.567 million, or almost 100 Total ...... 239,262 percent. An operator-paid tonnage tax was enacted by Congress in 1977 to provide for Total federally paid benefits: Social Security ...... $5,513,712,000 future benefits. Compensation is from funds Labor ...... 54,000,000 contributed by the “last responsible operator. ” Total ...... $5,567,712,000 Labor Department spokesmen say coal companies contest many — if not most — determina- tions of their responsibility to pay. If the current trend continues, most new black lung claims may be paid from Federal resources. Recent legislation allows coal companies to deduct their contributions to the black lung trust fund from their Federal taxes. The deduc- tion cannot exceed 38 percent of the company’s payroll, which means, in practice, that many operators will be able to write off their Preventive measures in the workplace are black lung contribution. the most effective approach to controlling occupational disease. Prevention of all work-re- Some health risks of mining are common to lated diseases requires a holistic approach to underground and surface miners, but they are analyzing hazards and controlling them, This approach recognizes that disability results from cumulative, total exposure. Unfortunate- ly, most occupational disease research and Ch. VI— Workplace and Community Implications ● 261 prevention programs dwell on the effects of rock drilling, respirable coal dust when quartz single hazards. The cumulative and synergistic is present, and noise. Compensation for black impacts of workplace hazards — that is, the lung was started. The 1969 Act failed to ad- way human beings experience them — have not dress other potentially significant hazards been well researched. such as diesel emissions, heat, “nonrespirable ” coal mine dust, and harmful fumes. As single factors, some of these may have little effect, but coupled with known hazards from respirable dust and noise, their total health consequences may be substantial. Enforcement of the standards since 1970 has been marked by litigation, technical problems, unsympathetic Federal administrators, and insufficient funds. ’

MSHA’S task is made more difficult by the lack of data on the health effects of coal mining. MSHA requires operators to report all occupational illnesses. The agency distributes form 6-347, listing seven categories of report- able occupational illness: occupational skin diseases, dust diseases of the lungs, respiratory diseases (toxic agents), poisoning, disorders (physical agents), disorders (repeated trauma), and all other occupational illnesses.5 When a computer printout was sought from MSHA on disease experience for the 1972-76 period, data were available for only two categories — occupational skin diseases and all other occupational illnesses. MSHA statisticians said the other data were not available because the operators do not report them — and that even the available data were probably not very ac- Photo credit: Douglas Yarrow Jan Chapin, a nurse with the Cabin Creek Medical Center, curate. Without this information, policy- examines miner at minesite on Cabin Creek, W. Va., 1977 makers are blocked from evaluating current prevention strategies.

The Federal Role

Congressional concern for coal miners’ health–as distinguished from safety– is relatively recent. The 1969 Coal Act established the Mining Enforcement and Safety Adminis- tration (MESA) to develop health standards and enforcement procedures. When the agency was shifted from the Interior to the Labor Department in the spring of 1978, it was re- named the Mine Safety and Health Administra- tion (MSHA), seemingly promising a new emphasis on workplace health.

The 1969 Act regulated four health hazards — respirable coal mine dust, dust from 262 ● The Direct Use of Coa/

Mortality is clear that both sizes can impair lung func- Disease recognition and prevention are ham- tion when inhaled in quantity over time. The pered by the time required for many occupa- larger particles are probably linked to bron- tionally linked diseases to appear. The most re- chitis among coal miners. Although these particles are generally not retained in the lung, cent mortality study surveyed more than 23,000 UMWA miners—of whom 7,628 had continuous exposure to them during the normal work year produces a more or less con- died – between 1959 and 1971. Rockette found stant irritation of the upper respiratory tract. coal miners died more often than the U.S. male population from respiratory disease (pneumo- Breathlessness has also been found to be sig- coniosis, influenza, emphysema, asthma, and tuberculosis), accidents, hypertension, and stomach and lung cancer, b

Rockette’s data may be used cautiously to correlate coal mine employment with excess mortality from certain diseases. It is clear that death from accidents, pneumoconiosis, and nonmalignant respiratory ailments are associated with coal mining. Hypertension may be. Lung and stomach cancer may or may not be. It is conceivable that the combination of coal dust, trace-element exposure, noxious fumes and gases, and other irritants (including cigarette smoking and tobacco chewing) are related to excessive cancer among coal miners. 7

Dust—The Greatest Hazard

All mine dusts–of which coal dust is the most prominent — are classified as either respirable or nonrespirable according to the size of the dust particles. It is generally accepted that only the smallest particles (smaller than 5 pg in size) are respirable. They alone are retained in the alveoli —the gas-exchanging sacs of the lungs — and cause pneumoconiosis. Gen- erally, the larger particles (nonrespirable dust) do not penetrate the alveoli and are not thought to cause CWP. Photo credit: Douglas Yarrow While the distinction between respirable Black lung victim using vaporizer at the Cabin Creek and nonrespirable dust is scientifically valid, it Medical Center, Cabin Creek, W. Va., 1977

nificant among miners who do not show X-ray evidence of CWP. All researchers believe that breathlessness is related to chronic, nonspeci- fic, obstructive bronchopulmonary disease. Some investigators, in addition to CWP and bronchopulmonary disease, have found a third, as yet unidentified disease process, that reduces the ability of the lungs to exchange Ch. VI— workplace and Community Implications ● 263 gases. ’ Black lung disease has come to represent a broad definition of occupational respiratory disabilities in miners, of which CWP is one major component. The 1969 Act regulated respirable dust exposure but did not Iimit exposure to nonrespirable dust. Respirable dust, which is invisible to the unaided eye, accounts for less than 1 percent of the dust in a mine workplace. It is not clear how much nonrespirable dust is retained in the lungs when the Federal standard for respirable dust –2 mg/m3 of air — is being met. Because compensable black lung is associated with other factors in addition to respirable coal mine dusts, prevention programs aimed exclusively at that hazard are likely to reduce CWP but may not reduce black lung disability proportionately.

Coal Workers’ Pneumoconiosis

The 1969 Act defined CWP as a “chronic dust disease of the lung arising out of employment in an underground coal mine. ”9 It is caused by the inhalation and retention of respirable coal mine dust in the lower lungs. After a dozen years or so of exposure, a noticeable dose-response relationship may appear. CWP is classified by X-ray diagnosis into levels of ascending severity, from simple to complicated. If dust exposure continues, simple CWP can progress into more advanced stages. Miners with advanced CWP (characterized as progressive massive fibrosis) are usually totally disabled. Miners breathing high dust concentrations may be disabled after only a few years of exposure. Some miners seem more vulnerable than others, and this variability has yet to be explained. Cigarette smoking contributes to lung impairment among miners as in the population generally. Considerable controversy exists over the role smoking plays in miners’ lung impairment compared to occupational factors. 264 ● The Direct Use of Coal

The second round of this study in 1973-75 CWP prevalence in the future. Thus, each of found CWP prevalence to be about 11.5 per- the three scenarios forecasts steadily lower cent. J Of miners X-rayed in both rounds, prevalence rates. However, even if prevalence about 6 percent showed disease progression. declines, more workers will be exposed. As- Some controversy exists over the reliability of suming 230,000 coal miners will be working in these findings, however. Critics say the results 1985, the number of likely CWP cases ranges should be considered with several caveats. from almost 13,700 to almost 18,800. Assuming First, different X-ray classification schemes about 411,000 miners will be employed in were used in each round and side-by-side X-ray 2000, CWP cases might range from 10,600 to readings using one system were not performed. about 18,000. Second, although X-ray diagnosis is the ac- Both the optimistic and pessimistic cases cepted (and only) method for diagnosing CWP, probably err on the side of optimism because it is not foolproof. The quality of X-rays is they assume more or less full compliance with directly linked to the conditions in which they the 2-mg dust standard on a daily basis. If are taken. Critics say that differences in condi- every mine strictly complies with this standard tions were not weighed in the final evaluation. between 1975 and 2000, the prevalence rate Third, only 40 to 50 percent of the miners X- may be 3-percent underground and l-percent rayed in the first round were X-rayed again in surface in that year. The current standard will the second round. This has led some to argue not eliminate CWP, but it is likely to cut signifi- that the second-round data reflect CWP preva- cantly the probability of its occurrence. lence for a “survivor population and the slightly lower prevalence rate between round 1 and Along with CWP, coal miners will continue round 2 reflects the “healthy worker” effect, to experience other black lung diseases — that is, workers who are not healthy are forced bronchitis, severe dyspnea (shortness of out of the labor force leaving only healthy breath), and airways obstruction. Much of this workers to be surveyed for CWP. The 50 to 60 illness will be work-related and some of it will percent of round 1 miners who were not X- be caused or worsened by cigarette smoking. rayed in round 2 may consequently have a con- For every case of CWP, about three cases of siderably higher prevalence of CWP than those bronchitis, one case of dyspnea, and two cases miners who continued working and were X- of airways obstruction may be found. These rayed in both rounds. ” (Many of the first-round cases are not exclusive, and are often found in CWP cases may not have been examined be- combination. cause they no longer worked in the mines or refused to be examined because they feared job NIOSH calculated the health effects of in- discrimination if they had a “bad” X-ray.) Final- creased coal production using current preva- ly, dust exposures cannot always be correlated lence rates and higher estimates of the future to X-ray results with a great deal of confidence, work force. NIOSH estimated there were making it difficult to say anything conclusive 19,400 cases of CWP in 1975, rising to about about the safeness of the Federal 2-mg dust 28,500 in 1985, and 45,500 in 2000 (table 39). standard using these data. Cases of chronic bronchitis, dyspnea, and airways obstruction are estimated to increase Rough estimates of CWP prevalence for proportionately. Both OTA and NOSH esti- 1976, 1985, and 2000 appear in table 38. Actual mates deal only with the illniess found an-tong prevalence of CWP in the future will differ working miners. Retired and disabled workers from these projections according to the actual do not appear in these estimates. This group, numbers of miners employed and actual preva- which will be eligible for black lung compensa- lence rate. These estimates assume the existing tion, is likely to be large. Federal dust standard will significantly reduce Questions relevant to congressional policy 13 Status of Mandated Programs, Receiving Center, Na- include: 1 ) Are these estimated health costs of tional Institute for Occupational Safety and Health, unpublished reports, end of second round of examinations, increased coal production unacceptably high? 1975 2) If so, what can be done to reduce these Ch. VI—Workplace and Community Implications ● 265

Table 38.— Estimates of CWP Among Working Miners, 1976,1985, and 2000 Prevalence Rates Optimlstlc Pesslmistlc Underground Surfacea Underground Surfacea

Table 39.—Projected Health Effects of lncreased Coal Production

Millions of Cases of”b Cases of’b Cases of’b tons produced Number of Cases’ chronic severe airways Year (quads) employees of CWP bronchitis dyspnea obstruction

1975 estimates Underground ...... 279 ( 7,3) 139,500 18,100 41,800 11,200 41,800 Strip auger ...... 332 ( 7.9) 52,500 1,300 15,700 4,200 10,000

1985 estimates

2000 estimates Underground ...... 630 (15.7) 315,000 40,900 94,400 25,300 94,400 Strip auger ...... 1,170 (29.2) 185,000 4,600 66,300 14,800 35,200 266 ● The Direct Use of Coa/

costs? 3) Who should bear the costs of reduc- Congress based the 2-mg standard on British ing dust levels? 4) How may tradeoffs be deter- research done in the 1960’s. More than 4,000 mined between miners’ health and dollars British miners were studied over a 10-year peri- spent on prevention? od. The study’s methodology— how its data were collected and how they were used — may raise questions as to the soundness of its final Enforcement of Federal Dust Standard conclusions. 5 Dust exposure of each miner was not monitored daily. Rather, a stratified The current dust-control program has four random-sampling procedure was used, which components: 1) the federally established 2- took 50 to 250 samples annually at each of 20 3 mg/m dust standard, 2) dust suppression ef- mines. The dust sampler used in the study is no forts in the mine, 3) monitoring dust levels in longer used. The exposure data were converted the work environment, and 4) enforcement from particles to weight, but the conversion strategies for compliance with the Federal factors were developed experimentally rather standard. The Federal dust standard refers only than from in-mine measurement. Average 8- to respirable coal mine dust. hour exposures for each job at the face were calculated from the stratified random sam- The Federal Government plays an important pling. Calculating a mean from a set of aver- role in each of these components. Ventilation ages twice removes statistical results from standards are federally established. Federally reality. Probability curves were then con- sponsored research has helped develop water structed that related 10-year mean exposures sprays and other dust-control techniques. to X-ray evidence of CWP. The probability Operators must have Federal approval of their curves suggest the current standard is reason- dust-control plans. Monitoring the work envi- ably safe (at 2 mg, 1 to 3 of every 100 miners ronment is now a joint Federal and industry re- would show X-ray evidence of CWP after 35 sponsibility. Mine operators are required to years exposure)<” However, if the data collec- submit dust samples to MSHA several times a tion and statistical manipulations were not year. These samples are weighed and the oper- totally sound, then the curves are flawed. The ator is told several weeks later whether the safeness of the 2-mg standard has never been sample complied on the day it was taken. If confirmed by a long-term epidemiological the sample exceeds the standard, the operator study. A recent British update of the 1969 re must redo it until it complies. MSHA inspec- suits showed that in 10 mines the “earlier pre- tors take their own samples two or three times dictions underestimated 35-year working-life a year. If the operator is out of compliance, he risks [the probability of developing simple will be issued a notice of violation and may be pneumoconiosis] by 1 to 2 percentage prob- assessed a civil penalty. The average assessed ability units.’” 7 Researchers could not explain penalty was between $150 and $175 for a respirable dust violation in 1978, and the average amount collected was about $120.

The adequacy of the current 2-mg/m3 respirable dust standard is one key assumption that will determine the prevalence of respiratory disease among coal miners in the future. Al- though the U.S. standard is probably the strict- est in the world, its inherent safeness is not entirely certain. When the 2-mg standard was mandated in the 1969 Coal Act, Congress assumed that full and comprehensive compliance would effect foolproof prevention, based on the best evidence available at the time. That evidence deserves renewed scrutiny. Ch. VI— Workplace and Community Implications . 267 why CWP risks were five to six times higher use of this responsibility has been reported, in- than average at one mine, where the mean concluding deliberate falsification of sample re- centration of airborne dust to which the miners sults. Miners express little faith in a sampling were exposed was 2.9 mg/m3, compared with system managed by their employers—whose another mine, where the CWP risks were about interest, they claim, is not served by submitting one-ninth the average but the mean dust con- noncompliance samples to MS HA. Fourth, a centration was 4.4 mg/m3. A 1979 draft of a lag of 2 to 6 weeks often occurs before the NIOSH report, “Criteria for a Recommended operator is apprised of the results of his sam- Standard . . . Chest Roentgenographic Surveil- ple. By that time, the work environment has lance of Surface Coal Miners,” on X-ray moni- changed considerably, for better or worse. toring of surface miners said the “current U.S. Behavioral factors influence the representa- permissible exposure limit for coal mine dust tiveness of the samples. Miners don’t like to 3 of 2 mg/m does not assure a zero risk for the wear the samplers because they are noisy, awk- development of either simple or complicated ward, and heavy. Both the company and the pneumoconios is.” The draft said the current miner have incentives to take “good” samples standard is “. . . insufficient to eliminate the (by tampering with the sampler or leaving it in development of CWP in a small portion of a nondusty place). If a noncompliance sample American coal miners . . . .“ The risk of is submitted to MS HA, the individual miner developing more advanced stages of simple must take 10 more samples, which is consid- pneumoconiosis approaches zero at an aver- ered a nuisance. The miner may not wear his age coal mine dust exposure concentration of sampler to minimize his inconvenience or pos- 3 1 mg/m and below, NIOSH reported. Since the sibly to appease an anxious supervisor. Man- average dust sample submitted to MSHA in agement may try to distort the sampling, too. 1978 indicates that concentration levels of In one case, two company technicians at a 3 slightly over 1 mg/m are being achieved, Con- mine of a major operator were found guilty— gress may wish to consider lowering the stand- and then innocent—of deliberately falsifying ard to attain zero CWP risk. I n light of the large samples once miners had turned them in at the numbers of young miners joining the coal end of their shift. The samplers themselves are labor force in the 1970’s, prudence suggests far from perfect. MSHA stopped the use of the that new research confirm or change the 2-mg most common sampler in 1976 because it standard as soon as possible. gained weight artificially. In the past, samplers Assuming, for the moment, that 2 mg is low were also found to lose weight for no apparent enough to prevent CWP, it is apparent that reason. dust control depends on reliable monitoring of The General Accounting Office (GAO) the work environment. MSHA says that more found: than 90 percent of the operator-submitted . . . many weaknesses in the dust-sampling samples of mine sections have been in compli- program which affected the accuracy and va- ance since 1973. This seemingly encouraging lidity of the results and made it virtually im- record leads to the conclusion that CWP possible to determine how many mine sections should be almost eliminated in the future. Yet were in compliance with statutorily estab- the sampling system is so burdened by uncer- lished dust standards. tainty and flaws that such a conclusion may GAO said factors that affected sample accu- prove to be unwarranted. racy were: sampling practices used by oper- The dust-monitoring process has been criti- ators and miners, dust-sampling equipment, cized on a number of grounds. First, the sampl- weight loss of sampling cassettes, and weighing is performed only on perhaps 2 percent of ing of cassettes by MESA and cassette manu- the days worked each year. Second, the sam- facturers. plers used to monitor the dust are not always ‘‘Improvements Still Needed In Coal Mine Dlust-Sampl- Ing Program and PenaIty Assessments and Collections reliable. Third, control of the sampling pro- (Washington, D C U S Congress, General Accounting gram at each mine is exercised by the operator Off Ice, Dec 31, 1975), p I. rather than the miners or MS HA. Serious mis- 191 bid , p 15 268 ● The Direct Use of Coal

A National Bureau of Standards (NBS) study found: when the miners and mine operators perform” and supervise the sampling and when the weighings are made in the normal manner . . . the uncertainty [of accurate, actual measurements of dust concentrations] is estimated to be as large as 31 percent .. .20 No followup study on the accuracy of the sampling program has been done since the GAO and NBS reports were released in Decem- ber 1975. Both investigations noted that MSHA and NIOSH officials have made efforts to improve. A recent study of underground mines in east Kentucky found that: Both the interviews and the Federal dust records suggest that many dust samples are being collected incorrectly. In some instances, extra dust has been added; but in substantially more cases, the samples are too low. One explanation for the inaccurate sampling, of course, lies in the fact that the mineowners control sampling in their own mines. Since the penalty for exceeding Federal standards may be to close the mine, coal operators have a strong incentive to err in the direction of samples showing less than the actual dust levels. The 1969 law attempts to circumvent this possibility by requiring that all samples be collected by actual miners on the assumption that, since their own health is at stake, coal miners will have a vested interest in insuring the accuracy of samples taken at their workplace. For various reasons, however, that assumption has proven wrong. 21 Sharp found 27 percent of the 680 face and high-risk samples he studied were at the 0.1 and 0.2 mg levels, which are generally considered to be impossibly low. (That level represents dust levels in fresh, intake air. ) About 23 percent of equipment operator’s samples were also found to be inaccurate (low). Operator attitude toward the sampling program has an important effect on sampling accuracy, Sharp concluded. “An Evaluation of the Accuracy of the Coal Mine Dust- Sampling Program Administered by the Department of the Interior, a Final Report to the Senate Committee on Labor and Public Welfare (Washington, D.C. : Department of Commerce, National Bureau of Standards, 1975), p. iii “Gerald Sharp, “Dust Monitoring and Control in the Underground Coal Mines of Eastern Kentucky, ” masters thesis, University of Kentucky, November 1968, p 4. Ch. VI— Workplace and Community Implications ● 269 gers an automatic power cutoff when dust Table 40 provides information on seven levels are too high. Such a system is being trace-element concentrations in various coals. developed but is several years away from com- The permissible levels of workplace air con- mercialization, the Bureau of Mines says. taminants as developed by the Occupational Longwall mining, in particular, needs more ef- Safety and Health Administration (OSHA) are fective dust control s.” also included in the table. The median concentration levels of these seven elements in un- Other Mine Dusts cleaned coal almost uniformly exceed OSHA’S standards. Research has not determined how The 2-mg dust limit covers all respirable coal much of each element is actually liberated in mine dust, not only coal dust. Coal mine dusts the mining process or, further, how much of contain a wide range of noncoal constituents, that is inhaled by miners. One sample of West including silica and hazardous substances Virginia miners found their lungs to contain an such as benzenes, phenols, and naptha lenes. excess of beryllium, cobalt, copper, and other 24 Shultz, et al., found 13 polynuclear aromatic minerals, but was unable to determine the sig- hydrocarbons in the respirable mine dusts they 26 A autopsy study nificance of these excesses. n studied. Polynu clear aromatic hydrocarbons found miners’ lungs contain higher than nor- are listed among NIOSH’S suspected carcino- mal concentrations of aluminum, barium, gens. *5 Arsenic beryllium, cadmium, fIuorine, boron, chromium, germanium, iron, lead, mag- lead, mercury, ‘and selenium are all found in nesium, manganese, nickel, silver, tin, titani- coal and alI appear on the Environmental Pro- um, and vanadium — al I common coal constit- tection Agency’s (EPA) list of hazardous ele- 2 uents. 7 ments. At even one part per million, a mine producing 1 million tons of coal generates 1 Little research has been done on the health ton of each element annually. As coal is cut effects of trace-element dust or trace-element from the face, some of each element will be compounds generated in coal extraction. liberated as dust or gas in the workplace. Trace elements may have a role in producing black lung disability, either alone or synergistically. They may also play a role in the excess lung and stomach cancer found in miners.

Harmful Fumes and Gases

Hazardous fumes and gases are often produced in underground mines under both normal and abnormal conditions. Common gases include nitrogen and its oxides, carbon dioxide

(C02), methane and other hydrocarbons, sulfur

dioxide (S02), and hydrogen sulfide. If ventila- 270 ● The Direct Use of Coa/

Table 40.—Median Trace Element Concentrations by Coal Type (parts per million dry weight, uncleaned basis)

Type of coal Asb Be Cd F Pb Hg Se (OSHA permissible level)” (0.4) (1.6) (.2) (.2) (.2) (.1) (.2)

23.00 2.40 0.45 83.50 9.00 0.22 3.40 25.00 1.80 0.20 50.00 9.00 0.12 3.00 31.00 1.80 NA 103.00 9.00 0.17 NA 26.50 2.50 2.90 75.00 11.00 0.13 2.00 26.50 1.10 11.00 92.50 4.00 0.19 2.90

NA 1.50 0.40 65.00 7.00 0.07 0.80 NA 1.10 1.10 NA NA 3.15 neg. 1.00 0.90 NA 131.00 7.50 0.05 1.60 2.00 0.04 NA 130.00 7.50 0.05 1.85 7.69 0.38 NA NA NA 3.08 NA

tion is maintained at required levels, these occupational noise has these actual, or possi- gases will be diluted and carried quickly from ble, effects: temporary or permanent loss in the workplace. Miners are often exposed to hearing sensitivity, physical and psychological noxious or poisonous fumes from fires in ma- disorders, interference with speech communi- chinery, insulated electric cables, conveyor cations or the reception of other wanted belts, lubricating oils, and various synthetic sounds, and disruption of job performance.29 materials. Friction from moving parts and elec- Excessive noise may also cause changes in car- tricalfaults are common fire sources. Close ob- diovascular, endocrine, necrologic, and other servation of equipment by miners and supervi- psychologic functions.30 sors and compliance with Federal equipment standards are well-known ways of preventing NIOSH completed the most comprehensive fires. Stil several hundred probably occur survey of hearing loss in the underground coal each year. mining industry in June 1976.3’ It found that Hartstein and Forshey28 analyzed coal mine “mining operations cause 20 to 30 percent of combustion products from brattice cloth, ven- all miners to be exposed to noise that is poten- tilation tubing, belts, insulation, resins, foams, tially hazardous to their hearing. ”32 However, and oils— products commonly found in mines. disagreement was noted as to the proportion Hazardous emissions identified were polyvinyl of miners suffering actual hearing loss as a chlorides, neoprenes, and other chemical com- consequence of exposure. Occupational hear- pounds plus hydrogen chloride, carbon monox- ing loss in the studies NIOSH surveyed ranged 33 ide (CO), SOZ, and hydrogen sulfide. When from 9 to 29 percent. “The results of this fires occur, these substances are liberated study indicate that coal miners have measur- simultaneously in large doses. Harmful syner- ably worse hearing than the national aver- gism with ambient dust may occur. No morbid- age, ” 34 NIOSH concluded. MSHA has not con- ity study has been done to assess the cumulative health impact of these substances.

Noise

Noise is a proven hazard to both underground and surface miners. NIOSH believes Ch. VI— Workplace and Community Implications 271 ducted an equivalent noise survey for surface neering of equipment and design of the work miners, although comparable data suggest process. Exposure can be reduced by providing similar hearing risk for truck operators and personal protective headgear, but this ap- earth-moving equipment drivers. Data on ac- proach is usually less reliable than engineering tive and retired miners covered by the UMWA control and may increase accidents. Machine Health and Retirement Funds in 1974 indicated modifications to achieve a lower noise stand- that the Funds male population has a preva- ard would involve retrofit expenditures and lence rate for hearing aids of 1.5 percent com- perhaps increase the cost of new equipment. pared with a l-percent rate for all U.S. males. Concern for inflationary impact and engineering considerations have discouraged Federal Operators of underground and surface safety agencies from promulgating the recom- equipment are usually exposed to high, often mended 85 d BA standard. intermittent noise levels. I n surface operations, where machinery is in continuous operation, noise is often excessive. Miners are ro- Diesels in Underground Coal Mines tated in and out of the workplace to limit ex- Diesel-powered equipment is commonly posure. The Federal noise level of 90 dBA aver- found in surface coal mines throughout the age for an 8-hour period permits higher expo- United States. However, only 200 diesel units sures for shorter periods of time. However, operate in underground coal mines. About 160 convincing evidence is not at hand to indicate of those pieces of equipment are found in the the 90 dBA level is sufficiently safe. NIOSH West; most of the others are used in east Ken- has recommended that the permissible expo- tucky. Only 10 or 12 pieces are found in mines sure level be lowered to 85 dBA; UMWA health organized by UMWA. advocates have urged a 75 dBA Iimit. Health hazards to both surface and under- Operators are required to submit noise-sam- ground coal miners from diesel emissions have pling data to MSHA. Samples are taken only not been studied definitively. I n fact, no long- once or twice a year in most cases. The results term epidemiological study of diesel exposure indicate almost total compliance with the Fed- has been done of any work group. A prelimi- eral standards. MSHA issues even fewer no- nary survey covering a 6-year period that tices of noise violations than the small number matched 772 diesel-exposed miners with an of noncompliance samples warrant. MSHA has equal number of “controls” reported that the no way of systematically checking the reliabil- diesel miners reported significantly more ity of the operator-submitted noise samples. symptoms of persistent cough, phlegm and ex- MSHA inspectors are required to sample acerbations of cough and phlegm. Their pul- noise during inspections. But the agency does monary function performance was generally not tabulate its inspectors’ measurements. poorer, but they reported fewer symptoms of Thus no way exists to compare the operators’ moderate to severe dyspnea and wheezing. 35 data with MSHA’S. NIOSH expressed concern about the health hazards of diesels underground, but has not Without reliable noise exposure data, it is yet been able to justify a recommendation that impossible to predict the extent of hearing im- diesels be prohibited. However, mine oper- pairment miners will experience in the future. ators have been cautioned not to invest heav- It is reasonably clear that a significant number ily in underground diesels pending further re- of today’s miners is exposed to and impaired search. NIOSH is currently working up a crite by noise. Noise-related accidents are not un- ria document, which surveys the Iiterature and common. Lowering the Federal noise standard to 85 dBA, for example, and instituting a reliable monitoring and enforcement system would probably minimize future hearing impairment and accidents. Noise control at the 90 dBA level or lower requires careful engi- 272 The Direct Use of Coal recommends a standard, for diesel emissions. derground coal mines. However, it is also rec- This should be issued within 2 years. ognized that safety and productivity considerations could potentially provide overall gains Diesel engines produce emissions that are in protection of the miners’ well-being. Unfor- known to be health hazards: CO, unburned hy- tunately, none of the potentially positive drocarbons, oxides of nitrogen, particulate, aspects of diesel use have been scientifically polynuclear aromatic hydrocarbons, phenols, and objectively documented at this time. Con- aldehydes, oxides of sulfur, trace metals, nitro- versely, there are valid investigations which gen compounds, smoke, and light hydrocar- clearly demonstrate that toxic substances are bons. ” introduced into underground coal mines from diesel engine exhaust such exposures With exhaust scrubbers, rigorous mainte- would not be expected to produce a healthy nance, and massive ventilation these emissions work ing environment. 37 can be minimized. However, Federal researchers point out that diesel particulate (which in- Shift Work clude carcinogens and mutagens) and oxides Several studies have linked shift work–es- of nitrogen cannot be trapped within the com- pecially rotating shifts—to a wide range of bustion process. The safeguard standard is adverse health effects. Most U.S. mines oper- 3 8,000 to 17,000 ft per minute of air per piece ate on either two or three shifts,38 and about 3 of diesel equipment. NormalIy, only 9,000 ft one-third rotate shift times every week or two, per minute is required in each section (and according to BCOA. Larger and newer mines 3 3,000 ft per minute across each working face). tend to use rotating shifts more than smaller The tremendous volumes of air required for and older mines. More than 30,000 Appalach- diesel operation probably precludes their use ian miners struck in protest for several weeks in most older mines. in 1973 over compulsory shift work. Miners’ NIOSH’S current assessment of the potential wives picketed at a number of northern West health effects of diesels underground is Virginia mines in 1978 over the family disrup- pessimistic. tion caused by rotating shifts.

Although acute or subchronic health ef- Akerstedt summarized the literature in 1975 fects” are important, chronic health effects are and found: the central issue. The principal organ likely to . . . the studies . . seem to indicate that shift be affected by diesel emission products is the workers have: lung, In addition to coal mine dust, many of ● An excess of sleep problems including the individual pollutants associated with die- short sleep time, difficulties of falling sel exhaust are known to cause chronic ad- asleep and retaining sleep, not feeling verse respiratory effects after prolonged expo- refreshed after sleep, etc. The problems sures. The introduction of carcinogenic mate- occur mainly in the nightwork period and rials into the mine environment through the often are associated with tiredness, bad use of diesel engines provides yet another in- mood, restlessness, digestive problems, sidious potential for chronic illness and death. etc. These chronic effects may take years to mani- ● An excess of minor nervous disturbance fest themselves. Thus, the real human impacts states. of introducing diesels into mines today may ● An excess of gastrointestinal disturb- not be determinable for several decades. It ances. 39 must be emphasized that currrent or proposed standards for these individual pollutants offer “Gamble, et al., Health Implicattions, p. 87. no assurance of protection when the contami- “’UMWA conventions in recent years have urged adop- nants are found in combination with other tox- tion of a 4-shift, 6-hour-per-shift pattern in order to in- ic substances . crease job opportunities and safety The fourth shift would be designated a safety and maintenance shift . . . from a health protection posture it is ob- 9 viously undesirable to use diesel engines in un- ‘ Torbojorn Akerstedt, “Shift Work and Health – inter- disciplinary Aspects, ” Shift Work and Health (Washing- ton, D.C..: DHEW, National Institute for Occupational Safety and Health), p. 180. Ch. VI— Workplace and Community Implications ● 273

Akerstedt noted that “shift workers suffer from The findings of the 1977 NIOSH study on a host of social handicaps . that can be ex- stress “. . . provided support for the argument pected to affect physchological aspects of that strain produces illness. ”43 The reported in- well-being, e.g., anxiety, tension, self-esteem, cidence of circulatory and gastrointestinal and simiIar parameters. 40 problems, nervous system disorders, urinary tract conditions, or musculoskeletal problems The most recent NIOSH study by Taste, et . . were associated with pyschological strain, al., found that workers on a rotating-shift sys- and those miners with these disorders reported tem experience significantly more accidents significantly higher strain than workers who than those working either straight-day shift or did not experience these problems.44 When a fixed-shift pattern .4’ high- and low-accident mines were compared, Several important questions about shift it was found that miners in high-accident work remain to be studied. What are the bio- mines reported more illness than those in low- logical costs of adaptation? What is the long- accident mines .45 Miners were found to experi- term cost of the “wear and tear” on the body ence higher morbidity and mortality from as a consequence of repeated attempts to ad- stress-related illnesses than expected.4b just or simply of being active at times when Negative health effects are likely to increase physiological preparedness for activity is at its where newly initiated productivity plans in- lowest? What are the long-term consequences crease job stress. Although some of the incen- of being active during those portions of the 24 tive plans tie cash bonuses to safety, none ap- hours when the resistance to noxious agents is parently tie them to illness. NIOSH concludes: lowest? Do rotating shifts contribute to absen- . . . it can be expected that there wiII be an in- teeism and labor-management antagonisms? crease in the number of health and safety problems related to behavioral factors if coal Health Effects of Job Stress production is increased.’’” Job stress is produced by a miner’s work en- Conclusions vironment. Working conditions that either make unattainable demands on the miner or This catalog of occupational health hazards do not fulfill his needs create stress. Strain is a is long and discouraging. It is difficult to pin- psychological reaction to stress—that is, a point the extent of occupational disease deviation from normal responses. Although a among working miners. MSHA’S data are in- recent NIOSH study found that miners do not complete and unreliable. Epidemiological perceive their work environments to be more studies suggest an excess of respiratory dis- stressful than the perceptions of other blue- ease, hypertension, lung and stomach cancer, -collar workers, miners experienced more and hearing impairment. But no one knows strain — irritation, anxiety, depression, and how many working miners die prematurely or physical com pa i n ts — t ha n their counter- suffer work-related illness. No one knows how 42 perts. AS measures of job stress are subjec- many retired miners eventually die of work-re- tive [workers’ perceptions of their own environ- lated diseases. No one knows the extent of psy- ment), it is less useful to ask “How stressful is chological and social stress a miner’s ilIness in- mine work?” than to ask what possible stress- flicts on him and his family. related health effects are found among miners. ‘iIbid , p 63 “Ibid “lbld , pp 124-125 “C M Pfelfer, J F Stafanski, and C B, Grether, Psy- chological job Stress and Health, Contractor Report #C DC99-74-60 (Washington, D.C. DHEW, National Insti- tute for Occupational Safety and Health, 1975 ) “Occupational Safety and Health Implications of lrl- creased Coal Utilization (Washington, D.C. DHEW, Na- tional Institute for Occupational Safety and Health, Nov 4, 1977), Iines 848-850 274 ● The Direct Use of Coal

Estimates of the future number of CWP and 5. Epidemiological study (including synergis- black lung cases vary widely depending on tic potentials) of underground coal miners assumptions about numbers of workers and exposed to diesel emissions. disease prevalence. These estimates range 6. Extent of work-related bronchitis and em- from about 14,000 cases of CWP among work- physema; causes and controls. ing miners to 28,500 in 1985; from 10,600 CWP 7. Epidemiological survey of respiratory dis- cases to 45,500 in 2000. A proportional range eases–both CWP and black lung– exists for bronchitis, severe dyspnea, and air among surface miners and preparation obstruction. Thousands of additional cases of plant workers. respiratory disability will be found among 8. Health effects of radioactive trace ele- retired workers especialIy over the next decade ments in underground coal miners. (that is, among those who spent most of their Others. – work Iives in uncontrolled dust conditions). 1. Health effects—synergistic and other- Other uncertainties must be added to this wise — of shift rotation in coal miners. list. The safeness of the 2-mg dust standard is 2. Epidemiological study of health effects of open to question. If 2 mg eventually proves to job stress. be too high, miners and compensators alike 3. Possible unique health effects of mining wiII pay a higher price for coal production. on women miners. Further, the full health effects of coal-mine dusts are not clear. Lung and stomach cancer, TO BE DONE BETTER skin disease, and gastrointestinal problems may be related to various noncoal constitu- 1. Data collection and analysis of occupa- ents. While respirable dust is a known hazard, tional disease. the degree of risk associated with nonrespira- 2. Reorganization of the respirable dust- ble dust has not been fully explored. Uncer- sampling program. tainty also exists about whether (and to what 3. Noise sampling. extent) mine health hazards work synergis- 4. Training of miners and management in tically. Do diesel emissions underground health hazard recognition and control. worsen the respiratory impact of coal mine 5. Nonrespirable dust control. 48 dusts? Do large– but short –doses of mine-fire 6. Dust control on Iongwall mining units. smoke increase respiratory disability? 7. Involvement of miners in occupational disease prevention programs such as haz- This list of unknowns and uncertainties sug- ard monitoring. gests a heavy research agenda before thou- 8. Engineering production systems and sands of new miners are hired underground. equipment with health-hazard control in Essentially, a list of research priorities can be mind. grouped according to factors that need to be 9. Training MSHA inspectors in health mat- known and ways of doing things better. ters. 10. Sampler design (both area and personal TO BE KNOWN samplers should be able to give miners Dust. – and management immediate feedback on 1. Safeness of the current 2-mg/m3 Federal dust levels). standard for respirable dust. Congress faces several obvious policy ques- 2. Need for a standard for nonrespirable tions in the area of coal mine health. First, is dust. 3. Need for a standard on trace-element and ‘*In recent hearings on MSHA’S dust-sampling proce- combustion-product exposure. dures, industry health specialists said mine operators 4. Possible relationship between mine dust have yet to succeed in bringing long-wall units into compliance, To comply with Federal standards, mine oper- both respirable and nonrespirable, coal ators are forced to rotate miners onto the mining and noncoal constituents with stomach machine for short periods to comply with the Federal 8- and lung cancer. hour standard Ch. V/— Workplace and Community Implications ● 275 the current program of Federal standards and 15,000 disabling injuries and 10,000 nondisabl- enforcement adequate? Second, are the pro- ing injuries (which did not result in an extra jected levels of miner occupational disease ac- shift lost time). The actual number of injuries ceptable? Third, if the estimated health costs has increased each year since 1975. Injury fre- of increased production are unacceptably quency in underground mines has risen after a high, what additional legislation, if any, may 2-year (1974-75) improvement. In 1977, the rate be needed to reduce workplace exposure to was 50.86 disabling injuries per milIion hours health hazards? of exposure, about what it was throughout the 1950’s and 1960’s. About 60 coal workers ex- Safety perience a disabling injury every production day. Injuries rose in the 1970’s because almost Concern for the safety of American coal 100,000 additional coal workers were hired workers” has been expressed repeatedly by since 1969 and because the underground injury labor, coal operators, and public officials over rate has not improved. If underground produc- the years. The reason is simple: mining is a tion in 1977 had accounted for the same share dangerous job. of total national output that it did in 1969 (62 percent), the industry’s overall safety record Mining is undoubtedly safer today than it would show Iittle improvement at al 1. was during the first three decades of this century. In 1926-30, for example, 11,175 miners The safety costs of producing coal are borne were kiIled on the job compared with 715 fatal- by mine operators, taxpayers, and miners and ities in 1971-75. I n 1977, 139 coal worker fatal- their families. The dollar costs alone are ities were recorded. Altogether, coal mining substantial. A recent study found that the has claimed a recorded 110,833 lives since average annual cost of each coal mine fatality 1900 and more than 1½ million disabling in- was $125,000 (in 1974 dolIars) and $4,000 for 51 Minin companies paid juries since 1930. In some respects, mining is each disabling injury. g safer today than it was 10 years ago but in about 41 percent of the total as compensation other ways — the number and rate of disabling payments, lost production, and investigative injuries, for instance– no improvement has costs. Wage losses to the injured miner and his been seen. family amounted to about 47 percent. Public agencies paid the remaining 12 percent as Congress passed five major pieces of mine compensation and investigative costs. In 1977 safety legislation in this century, each one dollars sz each fatality would have cost coming on the heels of a major mine disaster. $153,000 and each disabling injury $4,900. That Each law strengthened its predecessor. The means a cost of more than $73 million for 1969 Federal Coal Mine Health and Safety Act 15,000 coal worker injuries in 1977 and more established the current legal framework fol- than $21 million for 139 fatalities. Added to lowing a 78-victim explosion at a Consolida- these dollar costs (paid after the accident) are tion Coal mine in northern West Virginia in No- the expenditures for research, training, and vember 1968.50 The 1969 Act mandated safety equipment paid by operators, UMWA, and practices to prevent future methane explo- public agencies to prevent accidents from hap- sions. The Act has reduced disaster-caused fa- pening. The human costs of accidents— pain, talities from 158 in 1965-70 to 37 in 1971-76. mental anguish, lost opportunities, disorienta- But the 1969 Act did not address specifically tion— cannot be calculated in dollars and the problem of injury prevention. In 1977, cents. 229,000 coal workers experienced almost

“Coal worker refers to all workers in the coal Industry, includlng miners (underground and surface) and workers in preparation plants, shops, and contract construction (shaft drillers, for example) 50 Publlc Law 91-173 276 ● The Direct Use of Coal

Mine safety can be measured in different historically than surface mining (table 41). Be- ways. Most obvious is the actual number of tween 1952 and 1970, both underground and recorded fatalities and injuries. This number surface fatality rates (measured in hours of ex- depends on the number of workers in the labor posure) did not change although actual fatal- force and the accident frequency rates. Rates ities declined because the work force was re- for fatalities and injuries (both disabling and duced by 70 percent. Since 1970, both rates nondisabling) can be expressed as per million have fallen: the 1977 underground fatality rate hours of worker exposure or per million tons of is about one-third the 1970 level; the surface coal mined. Rates in exposure are more com- rate about one-half. The gap between under- mon and express accident risk from the work- ground and surface fatality rates has narrowed ers’ viewpoint. Accidents expressed in terms of as underground mining made proportionately output show directly the human costs incurred greater improvement. per unit of coal produced. Accidents are also measured in terms of severity— the average Post-1969 improvement in fatality reduction number of calendar days lost because of the is not matched by a similar trend in disabling injury. Finally, accidents are grouped accord- injuries. Underground mining has been con- ing to mining method, underground or surface. sistently more than twice as hazardous as sur- Underground mining employs more workers face mining in the frequency of disabling in- per unit of production than surface mining and juries (table 42). Underground mines injure about three times as many industrywide. more than five times as many miners as surface operations each year. Except for 1974 and Underground mining has resulted in more 1975, no improvement in underground disabl- fatalities and higher fatal frequency rates

Table 41.— Fatalities in U.S. Coal Mines, 1952-77 (hours of exposure)

Underground Surface Surface fatalities as a percentage of Year Fatalities Ratea Fatalities Ratea underground

1952 514 .97 33 .55 60/0 1953 440 .96 21 .39 5 1954 374 1.10 22 .48 6 1955 391 1.06 25 .51 6 1956 417 1.11 28 .52 7 1957 451 1.30 22 .42 5 1958 334 1.26 19 .39 6 1959 268 1.11 20 .43 7 1960 295 1.29 24 .52 8 1961 275 1.34 17 .39 6 1962 265 1.34 20 .46 8 1963 257 1.28 22 .49 9 1964 224 1.12 15 .33 7 1965 240 1.21 18 .40 8 1966 202 1.12 23 .55 11 1967 186 1.05 22 .52 12 1968 276 1.63 24 .57 9 1969 163 .95 28 .63 17 1970 220 1.20 29 .55 13 1971 149 .86 23 .39 15 1972 128 .68 20 .38 16 1973 105 .56 16 .28 15 1974 97 .51 24 .33 25 1975 111 .47 32 .33 29 1976 109 .45 23 .22 21 1977 100 .43 27 .23 27 Ch. VI— Workplace and Community Implications . 277 ing injury rates has occurred since 1952. The mining showed a 90-percent increase! I n 1977, underground disabling rate and actual number underground mining registered 46 injuries per of disabling injuries have risen each of the last miIIion tons compared with 6 injuries for sur- 3 years. Modest improvement is seen in surface face mining. injury rates since 197o, although this trend seems to have bottomed out since 1973. The Safety data measured by output and expo- actual number of surface injuries has been ris- sure are compared in table 44. Fatality and in- ing as more miners are employed, In 1977, jury rates are higher when expressed in expo- about 142,000 underground miners experi- sure than in output. Rate comparisons for 1977 enced 50 disabling injuries per miIIion hours of appear in table 45. exposure— that is, about 55 injuries every working day. I n contrast, 65,000 surface miners A central relationship in coal’s future is that experienced roughly 18 injuries per million of productivity and safety. Productivity (ton- hours of exposure, or about 10 injuries every nage mined per worker per shift) can be in- working day. creased in different ways. Each produces a Underground mining generally produces unique set of safety consequences. For exam- more severe disabling injuries than surface ple, the introduction of continuous-miner mining. I n 1977, for example, the average systems in the 1950’s raised productivity by severity of all temporary total disabling in- maintaining output and reducing the labor juries in all underground mines was 73 calen- force. This had the effect of lowering the ac- dar days per injury compared with 58 days for tual number of accidents (since fewer workers surface mines.53 Although the average disabl- were exposed) but not accident rates. ing injury idles a miner for 2 months or more, 98 percent are temporary total disabilities that A rough index relating safety and productivi- do not produce permanent impairment. Of the ty for 1967-77 appears in table 46. Safety is ex- 14,989 disabling injuries in 1977 for all coal pressed as fatalities and injuries per million production (mining, dredging, preparation, and tons of coal mined. Productivity is expressed in shopwork), only 3 permanent totally disabling two distinct ways: first, as tonnage produced injuries were recorded and 225 permanent par- per worker per shift (labor productivity), and tial disabling injuries. second, as tonnage produced per production day. By calculating and tracing the number of Measured in terms of output rather than ex- fatalities and injuries that occur every produc- posure, a somewhat different perspective on tion day, safety can be associated with produc- safety is gained When expressed in output, the tivity. productivity advantages of surface mining (more tons for less exposure) show it to be five The steady 43-percent decline in under- times safer than underground mining in fatali- ground labor productivity since 1967 is ty frequency and almost nine times safer in in- matched by a 43-percent decline in the number jury frequency in 1977 (table 43). In 1977, of underground fatalities per production day. underground mining showed 0.39 fatalities per However, underground injuries per production million tons compared with 0.07 fatalities in day increased 47 percent, from 38 in 1967 to 55 surface operations. Surface mining showed a in 1977. Surface productivity dropped 22 per- 42-percent decline in its fatality rate in 1967-77 cent in this period, but surface fatalities per compared with a 26-percent decline for under- production day rose 20 percent from 0.10 to ground mining. On the other hand, the injury 0.12, and injuries rose 134 percent from 4 to 10 rate in surface mining only registered a 10-per- (table 46). If underground and surface mines cent increase in 1967-77 while underground are compared on a productivity-safety index, it is clear that surface mining is three times more 53 Mine Safety and Health Adminlstratlon, “ln]ury Ex- productive, four times safer in fatalities, and perience at All Coal Mines in the United States, by almost six times safer in injuries per produc- General Work Location, 1977, ” table 7 tion day. 278 ● The Direct Use of Coal

Table 42.—Nonfatal Disabling Injuries in U.S. Coal Mines, 1952.77 (hours of exposure)

Underground Surface Injuries Ratea Injuries Ratea

28,353 53.26 1,698 28.11 22,622 49.38 1,604 29.48 16,360 47.98 1,342 29.01 17,699 48.10 1,140 23.14 18,342 48.88 1,318 24.31 17,076 49.23 1,339 25.72 12,743 47.94 1,150 23.86 10,868 44.90 1,054 22.64 10,520 46.09 1,125 24.45 9,909 48.19 1,052 24.44 9,700 48.88 1,027 23.50 9,744 48.62 1,099 24.25 9,692 48.35 1,116 24.75 9,705 49.09 1,178 26.12 8,766 48.78 1,043 25.00 8,417 47.57 949 22.43 7,972 46.99 1,039 24.59 8,358 48.77 967 21.84 9,531 51.79 1,346 25.67 9,756 56.40 1,564 26.54 10,375 55.32 1,305 24.84 9,206 48.80 1,208 20.94 6,689 34.95 1,229 16.83 8,687 37.13 1,714 17.74 11,390 47.09 2,071 20.04 11,724 50.86 2,246 18.91

Table 43.— Fatality and Disabling injury Rates for U.S. Coai Mines, 1967-77a (tons mined)

Underground Surface” Fatality Injury Fatality Injury Tonnageb rate’ rated Tonnage rate rate Ch. V/— Workplace and Community Implications ● 279

Table 44.—Accident Rate Comparisons for U.S. Coal Mines, 1967-77

Fatality Rates Injury Rates Underground Surface Underground Surface

Table 45.—Accident Rate Comparison, 1977 about the same throughout this period. This means that any rise in recorded injuries will Hours Tons show up dramatically as a rise in injuries per Fatality Ratea production day. Underground ...... 0.43 0.39 Surface ...... 0.23 0.07 The decline in underground productivity In]ury rate’ was matched by a decline in underground pro- Underground ...... 50.86 45.54 Surface ...... 18.91 5.53 duction per day. The 23-percent reduction in underground production per day coincided with a 43-percent decline in underground fatalities per production day. But it also coincided with a 47-percent increase in underground injuries per production day. Surface mining showed a Ill-percent increase in production per day that coincided with a 20-percent increase in fatalities per day and a 134-percent increase in injuries per day. The production- per-day (raw output) measure may be a better predictor of likely accident experience than labor productivity (efficiency of output) because of the great number of variables that affect labor productivity rates and the defini- tional problems in the concept itself (see chapter lV, Productivity).

Several ways of increasing labor productive- ty can be discussed in terms of safety. First, productivity can be increased by cutting the labor force without reducing current production. Since fewer miners are employed, the number of accidents will probably fall. But the rate of accidents—that is, the risk to the worker—may rise because of increased pro- 280 ● The Direct Use of Coa/

Table 46.—Accident and Productivity Experience, for U.S. Coal Mines, 1967.77 (tons mined)

Fatalitye Injuryf Estimated d per proper Fatality a Injury” production duction production rate rate Productivity b Employees per day day day

Underground .53 24.02 15.07 103,993 1,567,175 .83 37.64 .80 23.13 15.40 98,831 1,521,997 1.22 35.20 .47 24.04 15.61 97,395 1,520,336 .71 36.55 .65 28.07 13.76 102,379 1,408,735 .92 39.54 .54 35.09 12.03 97,740 1,175,812 .63 41.26 .44 36.06 11.91 109,396 1,302,906 .57 46.98 .37 32.20 11.66 100,843 1,175,829 .44 37.86 .37 25.34 11.31 113,169 1,279,941 .47 32.43 .40 31.18 9.54 137,060 1,307,552 .52 40.77 .39 40.53 8.50 137,316 1,167,186 .46 47,31 .39 45.54 8.58c 141,411 1,213,306 ,47 55.25

Percent change 1967–77 ...... –26% +90°A –43~o +36°10 –43% +470/o

Surface 1967 .12 4.99 35.17 24,064 846,331 .10 4.22 1968 .13 5.49 34.24 24,400 835,456 .11 4.59 1969 .14 4.79 35.71 25,323 904,284 .13 4.33 1970 .12 5.42 36.26 31,103 1,127,795 .14 6.11 1971 .09 5.91 35.88 33,344 1,196,383 .11 7.07 1972 .08 5.53 36.33 35,364 1,284,774 .10 7.10 1973 .06 4.63 36.67 30,475 1,117,518 .07 5.17 1974 .08 4.20 33.16 44,491 1,475,322 .12 6.20 1975 .10 5.28 26.69 57,562 1,536,330 .15 8.11 - 1976 .06 5.78 25.50 55,993 1,427,822 .09 8.25 1977 .07 5.53 27.34c 65,254 1,784,044 .12 9.87

Percent change 1967–77 ...... –420/o +lOO/o –22”/0 +1710/o +lll% +20% +134%

existing work force. The safety implications of these alternative approaches vary and deserve study before being embraced. To illustrate this point it is useful to work out the possible safety costs of a hypothetical case of higher productivity leading to higher production. If 1977 underground productivity (8.58 tons per worker shift) had been what it was in 1967 (15.07 tons)- production would have increased from 255 million to 449 million tons (assuming 210 production clays and 141,752 miners) Similarly, if 1977 surface pro- ductility (27.34 tons per worker shift) was the 1967 rate (35.17 tons), production would have increased from 407 million to 524 million tons Ch. V/— Workplace and Community Implications ● 281

(assuming 230 production days and 64,753 ments — prohibiting activity under an unsup- workers). Total national coal production ported roof, requiring a roof-control plan, would have increased from about 688 milIion etc. –that have helped reduce roof-fall fatal- to 973 miIIion tons, a figure in Iine with current ities. Comparatively little legislative attention national goals for 1985. Underground fatalities was paid to machinery and haulage, although would have risen from 0.48 per production day some regulations — cabs and canopies, for ex- to 0.83 per production day; annually from 100 ample– have been promulgated since 1970. As to 174.54 Underground injuries would have a percentage of the total, roof-falI fatalities risen from 55 per production day to 97, annual- have declined from a 1956-60 average of 50 ly from 11,535 to 20,370. Similarly, surface percent to a 1971-75 average of 34 percent. fatalities would have gone from 28 (actually However, haulage and machinery fatalities are 29) to 37 annually, injuries from 2,146 to 2,760. increasing as a share of total annual fatalities. This illustration, of course, is suggestive rather Such accidents are often caused by speeding than definitive. up production, taking short cuts, poor training, inadequate equipment maintenance, and not Productivity strategies that reduce the work using caution as a regular part of the produc- force or increase production may prove to tion process. Haulage and machinery are also have substantial safety costs. However, other the leading categories of surface mine fatal- ways of improving productivity— technologi- ities. cal innovation, redesign of the work process, or more efficient production systems— may Underground disabling injuries are most actually improve safety performance either by often associated with material handling, haul- making the production process safer or by age, and machinery. Surface injuries are most reducing human exposure. The particular often slips or falls (of persons), handling method of productivity enhancement will material, and machinery. Reducing injuries determine the level of safety costs. Analysis of from these causes may be more related to safety and productivity is handicapped by the altering production patterns, work routines, total lack of comparable mine-specific data and workload/work pace pressures than to new that would lend itself to deriving hard-and-fast equipment standards. 55 causal relationships between alternative On the whole, the larger the underground productivity-enhancing strategies and safety, mine, the lower its fatality rate both in terms of Such research is critically important to any na- exposure and output. Underground mines pro- tional policy aimed at greater coal production ducing more than 500,000 tons a year generally and productivity. had lower injury rates than smaller operations in 1975. Strip mines producing more than 1 Types of Accidents million tons annually had the lowest fatality Three major kinds of conditions are now and injury rates of all (with one exception). associated with underground fatalities — roof falls, haulage, and machinery. One of the major pre-1 969 causes of fatalities — mine disasters — has been sharply curtailed. The 1969 Act outlined some general roof-control require- 282 ● The Direct Use of Coal

Auger mines— none of which produced more mining found in the Midwest and West, than 250,000 tons annually— had an extremely but the difference is due more to terrain high fatality rate. The smallest underground than to equipment used in each system. and surface mines — producing less than Mining technology can be engineered 250,000 tons a year –generally had very high for safety as well as productivity. Current fatality and injury rates. Most coal produc- underground mine technology — uninsu- tion — both surface and underground — comes lated electric powerlines, opaque ventila- from mines producing 250,000 tons or more an- tion curtains, belt haulage, electric-pow- nually. Table 47 compares accident frequency ered track haulage, cable-reel shuttle cars, rates for 1975 by mine size. At every size— and conventional mining machinery— de- with one exception — strip mines were safer serve safety analysis. I n surface mining, than underground mines whether measured in comparisons between different flatland exposure or output. I n most cases, larger mines excavating methods (power shovel vs. were safer than smaller mines, both under- draglines) and mountain-stripping systems ground and strip. Smaller mines are usually the (auger vs. contour vs. mountaintop remov- most marginal economically. Their equipment al) would be instructive. is often older and they work more difficult 2. Coal price appears to be related to acci- seams. Large mines in the East are usually dent frequency. Both price and accident organized by UMWA, which has safety require- rates were relatively constant in the 1950’s ments negotiated into its contract. 56 Manage- and 1960’s. When prices rose after 1969, ment attitude in small mines may affect safety fatality rates, at least, declined. The coal as much as market economics, safety econ- industry’s two lowest years in injury fre- omies of scale, and worker participation. quency were 1974 and 1975, the same years that coal prices hit record highs. What Makes Mining Safe? Prices stabilized in 1976 and 1977, and so Certain economic and mine conditions ap- did fatality rates. But injury frequency– pear to be associated with safe mining. Three especially underground —went up. This economic variables —technology, price, and pattern implies that operators are able to Federal regulations — are discussed below. take extra steps to safen their mines when their profit margins are large and, con- 1. New extraction technology does not versely, do less when margins are necessarily lower fatality and injury fre- squeezed. quency. When continuous miners were 3 Federal mine safety regulation has three phased in underground (1950-70), the fa- components: setting standards, inspec- tality rate rose slightly and the disabling tions, and civil penalties. Each compo- injury rate remained relatively constant, nent, however, does not appear to have Longwall mining may reduce fatalities but had equal impact on safety performance. not necessarily injuries. 57 Contour strip mining used in the Appalachian moun- Both miners and operators generally tains is generally less safe than open-pit agree that most Federal regulations setting out electrical standards and minimum conditions and practices have safened mining. But many aspects of

systems. Leslie Boden, “ Coal Mine Accidents and Gov- ernment Enforcement of Safety Regulation s,” Ph D dis- sertation, Massachusetts Institute of Technology, 1977 Another found that no significant difference in injury trends among the various mining methods See, D P Schlick, R G Peluso, and K Thirumalal, “U S Coal Min- ing Accidents and Seam Thickness, ” The Aus. IMM Cen- tral Queensland Branch, Symposium on Thick Seam Min- ing by Underground Methods, September 1976 Ch, V/— Workplace and Community Implications ● 283

Table 47.—Injury Experience in Bituminous Coal Mines by Production Size, 1975 — — Per mill ion— hours of exposure — ———Per million tons of coal mined Nonfatal Nonfatal Fatal disabling injury Fatal disabling injury

.72 26.94 4.27 159.00 1.25 48.11 .92 35.17 .56 45.86 .44 36.12 .45 55.74 .36 44.38 .47 50.06 .42 44.82 .50 46.46 .46 42.64 .33 30.12 .26 23.96 ,34 32.00 .25 23.40 — .34 — — 28.68 .18 15.49 .48 37.11 .40 31.11

.58 10.10 .85 14.74 .35 15.49 .18 8.11 .38 17.42 .17 7.86 .35 15.33 .14 6.32 .64 18,46 .25 7.19 .09 22.72 .03 7.67 .42 18.55 .13 5.81 .22 22.18 .05 5.23 .19 16.22 -— .03 . 2.73 .33 17.05 ‘.1O 5.01 .42 29.89 .25 17.91 —— aDoes not Include auger mining and other miscellaneous surface mining. SOURCE Mine Safety and Health Administration Injury Experience in Coal Mining. 197, p. 77.

mining machinery have no standards set nondisabling injuries per year. 56 Another study for them. Some in the industry challenge estimated that one more Federal inspection the inherent safeness of particular stand- per mine would decrease annual fatalities by 4 ards, such as underground lighting, tem- and nonfatal injuries by 52.59 porary roof support, or cabs and canopies in thin seams. Often, a complaint It is difficult to discern the real effect of against a standard is based on the costs MSHA’S civil penalty program on safety. The of implementation rather than its intrin- average assessed penalty in 1978 was about sic worth. Since compliance is basically $180, of which about $150 was collected, ac- a matter of management policy, it is rea- cording to MS HA. Both the average assess- sonable to conclude that post-1 969 im- ment and average collection in 1978 was about provement has resulted from operators twice the level of earlier years. MSHA also has complying with standards. a “special” penalty program for serious Federal inspection is the principal minesite violations—those involving negligence, and enforcement tool. Several studies have found unwarrantable failure to comply, and viola- that safety improved with the frequency of Federal inspection. Boden’s study of 539 bituminous underground mines producing more than 100,000 tons annually indicated that in- 8 spection leads to fewer injuries. A 50-percent ‘ Boden, “Coal Mine Accidents “ 9 increase in Federal inspection rates in this sam- ‘ Louise Julian, “Output, Productivity, and Accidents and Fatalities Under the Coal Mine Health and Safety ple was predicted to lead to 11 fewer fatalities, Act, ” mimeographed (University Park, Pa The Pennsyl- 2,400 fewer disabling injuries, and 3,800 fewer vania State University, circa 1978) 284 ● The Direct Use of Coal

(steel-owned) are generally safer than noncaptive mines, but this may have as much to do with reporting practices as safe operations. b2 No clear relationship is demonstrated between safety and unionization. Large, captive underground mines (almost all of which are organized by UMWA) are safer than small, non captive underground mines (many of which are non-UMWA), but it is not clear that the unionization variable makes the difference.

Several conclusions may be drawn from the available data. First, since surface mining is demonstrably safer than underground mining, additional research and enforcement should be directed at the latter. Research is needed to determine what combination of underground mine factors— equipment, management attitude, worker role, and so forth —safen operations. Since small underground mines are generally less safe than large mines, research and enforcement should be focused there. Second, worsening underground injury experience needs to be addressed specifically. Injury-producing accidents appear to be linked to the interaction of three factors:

1. an incredibly narrow margin for error in the work environment, 2. inadequately trained workers who may not know how to— or are not permitted to–work safely, and 3. production-oriented supervisors who accelerate the normal pace of work and fail to maintain equipment properly. b3

“Theodore Barry and Associates, Industrial Engineer- ing Study of Hazards Associated With Underground Coal Mine Production, 1971 “Ibid Management skill and management policy are variables of acknowledged importance In maintaining safety, but neither has received the necessary attention One exception was the Barry study of mine accidents which found: almost every operator interviewed cited the insufficient numbers of high-quality operating supervisors, and the resultant loss of supervisory effectiveness at the working face, as one of the major problems confronting the industry today in terms of both safety and production. (p 259) too many foremen are not safety conscious (continued) Ch. VI— Workplace and Community Implications 285

Smaller mining machines that build in safety safety . . . if coal companies truly do features, pneumatic, battery-powered, chain- value safety over production, the message type, or hydraulic face-to-portal haulage sys- is apparently not reaching miners. If coal tems; packaging supplies in smaller, lighter companies do not, in fact, value safety units are al I areas where research and develop- over production, then a more fundamen- ment might reduce accidents. Behavioral fac- tal problem exists in terms of overall goals tors also require examination. Job pressure, in- and orientation of the organization. Re- sufficient training, inexperienced supervision, sults indicate that in high-accident mines, inadequate hazard-recognition education, in- problems stem from safety never having appropriate worker and management atti- been adopted as an organizational goal. tudes— all may bear more heavily on injury- ● .,. a second area that deserves considera- producing conditions than those more easily tion in the coal industry is work organiza- recognizable conditions that produce fatal- tion and job design. It has been estab- ities. Injury prevention may not be achievable lished in the literature that jobs which are by more rigorous enforcement of existing Fed- designed with an awareness of worker eral standards if, as seems to be the case, cur- needs for recognition, responsibility, and rent standards don’t come to grips with the variety tend to contribute to higher causes of mine injuries. worker satisfaction and improved work quality, including safety performance. Third, mine safety may be improved consid- ● Survey results substantiate the need for erably by changing certain psychological, training by providing empirical evidence behavioral, and organizational factors in the that good training is related to a low-acci- workplace. A recent report found significant dent record. Underground miners in low- differences in such areas between high- and accident mines indicated that their train- low-accident mines.64 Some of its major finding in dealing with hazards such as gas, ings were: dust, and noise was significantly . . . bet- ● It appears that coal companies, especially ter than the training in high-accident high-accident mines, need to formalize mines . the fact that foremen could safety as an organizational goal, and use additional training is evident from the subsequently communicate to workers fact that many foremen do not use safety both verbally and through the behavior of equipment when necessary, management the relative importance of ● I n comparing high- with low-accident mines, two disorders were significantly more prevalent in miners working in high- accident mines — high blood pressure (29 percent versus 10 percent respectively) and ‘nervous trouble’ (16 percent versus 2 percent respectively) . . . it would seem that a program designed to reduce occupational stress could have a significant impact on the safety, health, and well- being of coal mining personnel. ’s

In the past, the cause of mine safety has been driven by headline-grabbing, multivictim disasters. In the future, this driving force is not likely to exist, yet fatalities and injuries are likely to rise steadily. While management reserves the right to determine the balance between production and safety, higher numbers

’51 bld 286 ● The Direct Use of Coa/

of mine accidents may lead Congress to find it data base, but it is too early to evaluate the ef- prudent to encourage modifications in man- fectiveness of the effort. agement attitudes and priorities. A compre- Other reporting loopholes exist. For exam- hensive injury-prevent ion program would ple, persons who die from “an event at a mine” equip miners with the knowledge, skills, and but who are not at the mine when the event oc- rights to protect themselves. Because so much curs should be counted as mine fatalities. of mining is a matter of individual miners Usually, they are not. The 125 deaths that adapting to ever-changing conditions, enfran- resulted from the collapse of a coal-waste im- chising them in this manner may prove to be an poundment on Buffalo Creek, W. Va., in 1972 inexpensive and effective way of reducing ac- were not reported in MSHA fatality data. Off- cidents. site fatalities that occur from boulders and debris launched by surface-mine blasting Data Analysis would not be usually reported. When a fatality Coal mine injury and fatality data are im- from occupational illness occurs at a mine, it is perfect and incomplete. A clear bias toward usually not reported despite clear Federal reg- undercounting appears. bb The actual human ulations requiring the operator to do so. Deter- costs of coal production have been under- mining whether such a fatality was caused by stated historically. Accurate data are crucial coal mine employment is medically difficult; to wise policymaking. Valid projections of consequently, an attempt is rarely made. future human costs associated with increased MSHA data show no fatalities from occupa- coal production must be based on the most ac- tional illness reported since 1972. For these curate data obtainable. It is probably reason- reasons and others, puzzling discrepancies ex- able to assume that fatalities have been under- ist between Federal fatality data and those counted by as much as 3 to 6 percent annually recorded by State worker-compensation pro- and disabling injuries by 25 percent. Both, ad- grams. Finally, MSHA defined coal workers in mittedly, are “guesstimates. ” The Mine Safety such a way that when three of its own inspec- appendix in volume I I discusses the shortcom- tors were killed at the Scotia mine in 1976 they ings in the reporting and counting of work- were not counted as mine fatalities. place accidents. That argument is highlighted Injuries. – Until 1978, MSHA defined a here: disabling injury as “any work injury which does Fatalities.— Accidents involving employees not result in death but which either results in of independent contractors, such as mine con- any permanent impairment to the injured per- struction workers, were excluded from MSHA son or causes the injured person to lose 1 full data until last year. Perhaps as many as 20,000 day or more from work after the day of the in- workers fall into this category. UMWA sources jury. ”b7 A nondisabling injury did not result in estimated that 32 coal construction workers a lost shift after the day of the injury. The died between 1970 and the end of 1976. A rea- distinction between disabling and nondisabl- soned guess is that an average of four or five ing is important. Insurance premiums are construct ion/contractor fatalities may not linked to the former, but not the latter. Cor- have been counted each year. MSHA is now porate safety performance is measured in the trying to include contractor accidents in its same fashion. Thus, employers had incentives to show as few disabling injuries as possible. “Both the General Accounting Office and the Depart- Some mines and companies, therefore, ment of the Interior have reached this conclusion after adopted “light-duty” policies whereby an in- studying MSHA’S system Every major study of occupational injury and disease reporting supports this finding jured miner was encouraged to come to work See for example, Jerome B Gordon, Al Ian Akman, and on the day after an injury to be assigned light Michael L Brooks, Industrial Safety Statistics. A Re- Ex- work. Miners call this “bench warming” or the amination, A Critical Report Prepared for the U.S. Depart- “bandaid brigaid.” The injury was reported as ment of Labor (New York Praeger, 1971), and Nicholas Ashford, Crlsls In the Workplace (New York Quadrangle, “Department of the Interior, Bureau of Mines, title 30, 1976) pt 80 l(e)(f) Ch. VI— Workplace and Community Implications ● 287 nondisabling rather than disabling. Miners fits that were less than normal pay. But by not often agreed to Iight-duty assignments because reporting the injury as disabling, the worker they feared job reprisals. It was also far less lost any claim to future compensation. In a bother to go along with the company and col- case — such as a back injury — that may worsen Iect an uninterrupted paycheck than it was to over time, the miner could be severely penal- file for workers’ compensation and await bene- ized.

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Photo credit: Earl Dotter Disabled UMWA miner and family on strike in Harlan County, Ky., 1974 288 ● The Direct Use of Coal

Injury data may also be affected by how injuries are now being reported under the new dividual companies choose to interpret their system. Some observers argue that accidents Federal accident-reporting obligations. Interior were undercounted by as much as 60 percent Department investigations in 1975 found ex- under the old definitions. 72 The 1975 Interior tensive misclassification of accidents. b8 ln- audit found 39-percent undercounting of dis- terior found in its sample that only about 17 abling injuries. A correction factor of 25 per- percent of all injuries were ever reported to cent is used in table 48 to illustrate possible ac- MSHA’S data collection center. ’9 About 39 per- cident experience for 1967-77. Underreporting cent of disabling injuries were not reported, in- of tonnage and accidents lowers productivity, cluding: 1) finger amputated to first joint (8 distorts accident data (thereby confusing pol- lost workdays); 2) foot bruised with complica- icy analysis), understates future compensation tion (13 lost workdays); and 3) knee bruised costs, and lowers worker morale and respect and infected, fractured fingers, and cracked for Federal safety efforts. rib. About 44 percent of nondisabling injuries Safety Projections. —The safety implications were not reported. Underreporting resulted of increased coal production are critically im- from oversight, misinterpretation, and deliber- portant to Congress. The dollar costs of fatal- ate circumvention of reporting regulations. An ities ($1 53,000 each) and injuries ($4,900 each) Interior update of the 1975 survey turned up are immense. Production and productivity are similar findings. ’” In 1975 and 1976, nearly 65 reduced when accidents occur. Coal workers percent of all active mines did not report a and their families experience pain and suffer- single injury. Underreporting was most suspect ing. For these reasons and others, Congress has at larger mines and less suspect at smaller expressed sustained interest in minimizing coal ones. Interior’s “basic conclusion” was that mine accidents. Unfortunately, fatalities and MSHA’S “accident/injury data submitted by injuries will increase as more coal is mined mine operations cannot be relied on as reason- unless steps are taken to reduce accident fre- ably accurate. ” Suspect reporting was the quency. result of “corporate policy on reporting practices,” Interior said. Recent survey-research of The likely range of fatalities and injuries 30 underground mines found that “foremen in associated with higher production levels is low-accident mines were reported to turn in in- shown in table 49. These estimates assume no accurate safety reports more often than fore- change in certain variables — production pres- men in high-accident mines. ”7’ sure, productivity rates, accident reporting reliability, seam conditions, and work force and Within the last year, MSHA has tightened its management characteristics. Those variables definition of disabling injuries to reduce un- that have been considered are: number of coal derreporting. MSHA believes that the new defi- workers and production levels. nitions of disabling injury has cut underreporting by two-thirds. Some MSHA officials say un- Fatality and injury rates for 1977 were used officially that more than 80 percent of all in- to calculate the number of fatalities and injuries in 1985 and 2000. These rates may go “’’Review of Accident/Injury and Production/Man- down. If they are lowered sufficiently, they hour reporting under the Federal Coal Mine Health and will offset the increasing number of workers Safety Act of 1969 administered by the Mining Enforce- exposed to safety hazards, thereby reducing ment and Safety Administration, ” U.S. Department of estimated accident totals. However, if the the Interior, Office of Audit and Investigation, memorandum of Nov 19,1975. rates improve only modestly, the actual num- ‘glbld,, p 5. “’Opportunities to Improve the Effectiveness of Mining 72L. Thomas Galloway of the Center for Law and Social Enforcement and Safety Administration Accident/Injury Policy argued that the MESA injury rates did not reflect and Employment Production Data Information Systems up to 60 percent of al I coal mine accidents because of (Washington, D C.: U.S. Department of the Interior, Of- underreporting. See GalIoway testimony in U S Senate, fice of Audit and Investigation, 1977), pp. 6,15. Federal Mine Safety Health Amendments of 1976, hear-

7’ Westinghouse Behavioral Service Center, Psychologi- ings on S. 1302, 94th Cong , 2d sess., Mar, 24, 25, 30, and cal. . . Factors, p. 84. 31,1976, p. 920, Ch. VI— Workplace and Community Implications ● 289

Table 48.–All U.S. Coal Estimated Accident Experience, 1967.77 (hours of exposure) Unrecorded Nonfatal Nonfatal disabling Rate as disabling Estimated injuries calculated by injuries, adjusted recorded’ MSHAb additional rate d

10,115 41.84 2,529 51.82 9,639 41.12 2,410 51.13 9,917 41.76 2,479 54.70 11,552 44.40 2,888 62.32 11,916 46.89 2,979 53.70 12,329 46.08 3,082 52.53 11,220 40.41 2,805 36.58 8,545 28.79 2,136 34.28 11,107 30.17 2,777 45.51 14,389 37.55 3,486 47.82 14,989 38.37est. 3,698 45.68est.

Table 49.—Mine Worker Fatality and injury Estimates

1985b 2000 1977 Low High Low High

29 25 30 32 46 2,281 1,954 2,401 2,515 3,634

100 118 140 203 291 11,724 13,907 16,513 24,012 34,405

Other Coal workersa Fatalities ...... 10 14 17 24 34 Injuries ...... 984 1,586 1.891 2,653 3,804

139 157 187 259 371 14,989 17,447 20,805 29,180 41,843

ber of fatalities and injuries will still rise over Between 157 and 187 coal workers are likely current levels because of the Iarger number of to be killed and between 17,400 and 20,800 in- workers employed. Accident frequency rates jured in 1985. That represents a 13- to 35-per- have not improved substantially for several cent increase in fatalities over 1977 and a 17- years, and it may be that the 1969 Act will not to 39-percent increase in injuries. By 2000, be- have any additional impact on lowering them. tween 259 and 37I coal workers preestimated 290 The Direct Use of Coal

to be killed and between 29,200 and 41,800 in- Congress clearly stated its position in the 1969 jured. These estimates represent an 86- to 167- Act, which provided for the “attainment of the percent increase in fatalities over 1977 and a highest degree of safety protection for min- 95- to 180-percent increase in injuries. These ers. ” The Act recognized that “deaths and seri- calculations assume no underreporting and un- ous injuries from unsafe . conditions and dercounting. The 25-year total (1976-2000) of practices in the coal mines cause grief and suf- mine fatalities may exceed 5,000 and injuries fering to the miners and their families. ” They may exceed 500,000. also cost money and coal, Thousands of hours of production will be Conclusion lost because of injuries. Productivity will be These estimates of future fatality and injury lowered. Hundreds of millions of dollars in costs are disquieting. No one likes to measure worker compensation benefits will be paid. the cost of electricity in human life and limb. Coal workers and their allies may increase Yet it is clear that coal production two to three their resistance to management over safety times higher than current levels will greatly in- issues. Absenteeism and wildcat strikes may crease the number of fatalities and injuries erupt. Congress may again become the object unless frequency rates are cut sharply or proof intense pressure for even more stringent ductivity rises spectacularly (which would mine safety legislation. For all of these rea- mean fewer workers exposed). Neither seem sons, the effort to step up coal production and likely to materialize in the next 10 years assum- productivity ought to be accompanied by in- ing “business as usual. ” Frequency rates have creased efforts to minimize fatalities and in- not improved since the mid-l 970’s. Productivi- juries. So far, this has not occurred. ty is Iikely to rise in the future, but very slowly.

COMMUNITY IMPACTS

Introduction Mining has usually occurred in remote areas, where industrialization and other forms Coal mining shapes the social, economic, of commerce were not well-developed. Often, and political life of the communities in which coal became the only “cash crop. ” One-crop it occurs. The scope and intensity of coal’s economies–be they cotton, cocoa, or coal– local impacts differ from region to region” often mean many social and environmental depending on the nature of the precoal econ- costs are externalized. Where mining was the omy, the extent of local coal development, principal economic activity, its effect on com- and the level and regularity of demand for the munity life was greatest. Where mining was local product. Local and regional impacts were part of a diversified economy, its impact was also determined by the kinds of mining meth- less broad and less deep. ods employed, level of mechanization, size of the mines, extent of economic diversification, Appalachia has been America’s bituminous local sociopolitical structures, company own- coal bucket for a century; it is there that coal ership patterns (local or absentee), presence or has impacted most heavily. What strikes the absence of unionization, and topography. observer of coal field Appalachia is the near total absence of other primary economic en- “Coal production has been centered historically in terprise. The Iand itself was not hospitable to three regional coal fields the Appalachian fields ranging much more than subsistence farming, so min- from Pennsylvania to Alabama: the Midwestern fields in- ing quickly replaced existing socioeconomic cluding IIlinols, Indiana, west Kentucky, and portions of structures. I n Ohio, IIIinois, and western Ken- Kansas and Iowa; and the Western fields covering Col- orado, Wyoming, Montana, Utah, New Mexico, and tucky the agricultural base was sufficient to Arizona resist being supplanted. Yet even there, other Ch. V/— Workplace and Community Implications ● 291 industrial activity did not generally follow the continued the boomtown pattern. As the development of local coal resources. seams played out or demand evaporated, the jerry-built boomtowns tended to be aban- Coal operators often had to build not only doned. In contrast, Appalachians tended to mining and transportation systems, but also stay where they were despite cyclical coal de- whole towns, complete with commercial and mand. professional services, housing, roads, cultural activities, and political systems. Each com- Coal development shaped the political munity was almost totally dependent on the structures and culture that evolved in coal marketplace success of its local operator. The towns. Coal entrepreneurs had economic rea- public infrastructure in these communities— sons for developing harmonious relationships its institutions, services, and personnel —was with the local officials who administered the an adjunctive activity for the operators, whose legal apparatus, tax system, and public serv- principal concern was the profitability of their ices. In many cases, coal operators had to coal business. Company town were often a create a political system because none existed, profitmaking business for a coal company often tying the public sector directly into the even in slack times. Many times the town’s administration of the mining enterprise. As a profits were the only ones an operator could result, the political culture that took root was show for being in the coal business. I n some widely perceived by residents to be the public cases, operators saw community social invest- expression of the local coal company. ment as an unproductive and unprofitable use of scarce capital. When competition was intense and demand slack — as it was for most of In terms of social structure, in much of the the 20th century— support for community in- Eastern coalfields, coal’s method of industrial- stitutions was often the first economy oper- ization meant that communities were divided ators effected. into two basic classes: management and labor. The antagonisms produced in the mine work- The pattern of coal development in the Mid- place never dissipated in the environs of the west and West differed less in manner than company town where the workplace division scope. There, too, the company-town model was maintained socially. Miners’ grievances was used, but it was less frequent and less per- have usually been played out through on-the- vasive. More often, coal commercialization job militancy rather than in electoral politics occurred in existing towns whose Iifeblood was because miners believed their power was more agriculture, which continued alongside coal effective in the workplace. production. Coal development in the Midwest did not snuff out traditional economies and The two-class structure prevented a noncoal social systems as it did in much of Appalachia. middle class from forming. In other parts of Economic diversity enabled Midwestern com- America where an independent middle class munities to survive coal’s lean times. Finally, developed, civic reform was forced on en- because the demand for Midwestern and West- trenched political elites. Had an independent ern coals was generalIy less than for Appalach- middle class existed, it is reasonable to sup- ian coals, mining never dominated these pose that coalfield politics would have been regions as it did Appalachia. pluralized and more adaptive to change. As it was, however, civic improvement was left to Rocky Mountain coal development was the discretion of individual coal companies. even slower and less comprehensive than that Some companies made good-faith efforts to of either the Midwest or Appalachia, although supply their employees with decent housing, it impacted specific communities with equal medical attention, education, and public serv- intensity. Markets were generally limited to ices. The majority, however, could not or did steam-grade coal for railroads and industrial not spare the money and effort. Yet even activity. Mining towns and boomtowns existed where operators made a good-faith effort, they in the West prior to coal development; coal did soon their terms. 292 ● The Direct Use of Coal

For these reasons and others, public admini- Public costs are generally not evaluated by the stration in many coalfield communities to- mine developer because they are not directly day–particularly in Appalachia– is often relevant to his balance sheet. characterized by a lack of professional skills The local private sector bears a share of the and institutions. Local politics is often tied to costs of increased coal development. The pri- political machines and personalities. Corrup- vate sector in this instance consists of three tion and inefficiency are not unknown. In the parties: the operator, his employees, and local slack years of the 1950’s and 1960’s, public ad- private interests. Private costs can be divided ministration was heavily influenced by patron- into three categories: costs of production that age considerations, as the public sector often are internalized by the operator, costs of pro- replaced the private sector as the major local duction that are externalized and absorbed employer. Because the political system was so either by the workers or by local private in- much an extension of local economics, public terests, and opportunity costs. Internalized authority could do little to regulate the wide- production costs are carefully projected and spread cost externalizations of mining. regulated by mine operators and are a normal These historic patterns of underdevelop- part of doing business. Externalized costs and ment have produced in much of the Eastern opportunity costs are not readily quantifiable coalfields stunted private and public infra- but may be gauged by looking at occupational structures that cannot respond to the needs of injuries and disease (including compensation rapid coal expansion. programs), private health care utilization patterns and costs, lack of economic diversifica- Because underground mining is the most tion, shortage of local investment capital, common system in Appalachia, the communi- stress on community values and social struc- ty impacts there have been far greater in pro- ture, etc. Opportunity costs include all of the portion to output than in the West where sur- existing local business that ends as a result of face mining dominates and requires far fewer coal mining, together with all noncoal business miners per unit of output. Even though most that might have occurred had mining not hap- new coal output is scheduled to come from pened. surface mines west of the Mississippi River, five times as many miners will work in the East Coal production directly benefits its em- than in the West in 1985 (chapter 11, table 6). If ployees and their communities through wages the impact problems of increasing coal pro- and fringe benefits. The public sector also duction were to be translated into one simple benefits from production. Economic growth concept —more people— the socioeconomic helps a community prosper. Taxes may be impacts will be predictably greater in the East, levied on coal property, wages, sales, cor- and especially in central Appalachia, than in porate income, and on the product itself to the West. support public services. Presumably, a relationship can be drawn between the level of Coal mining brings benefits and costs alike private sector benefits on one hand with pub- to local communities. Both have a private and lic-sector benefits on the other. It might rea- a public side. Further, both have a dollar side sonably be expected that where the private and a nondollar side. In developing a mine, sector–both owners and employees–bene- however, the cost-benefit calculus lies entirely fits, the public also gains. with the individual entrepreneur. He establishes the scope of the project, its methods, But such a relationship has not always held and its rate of development. It is his ratio of in the Eastern coalfields throughout much of (private) dollar costs to dollar benefits that this century because of the volatility of coal determines whether a project is begun. it is on demand, the boom-bust cycle, and other the assumption of profitability (that is, bene- unique factors. In the first two decades, the fits over costs) that he ventures capital. The level of public benefits was determined by the costs in this case are those that the company coal operator who owned the community. The pays (internalizes) to produce coal at a profit. public interest was defined by the private sec- Ch. V/— Workplace and Community Implications ● 293 tor. The company-town model polarized the their mines outside of incorporated areas to private sector into “company men” and em- avoid taxation and land-use restrictions. State ployees; neither group was capable of advo- legislatures and Governors rarely chose to do cating an independent public interest. Even to- battle with politically powerful, economically day as increased spendable income from mine imperiled coal operators. These economic re- employment reflects “economic growth”, the alities and attitudes inhibited predictable and development of community services and insti- sustained development of public services in tutions lags. Growth is not synonymous with – coal communities. Long-term planning was not and may not lead to—development. Commu- undertaken. Eventually, coal field expectations nity polarization continued long after com- about public services became permanently panies liquidated company towns. For these undervalued. What people never had, they reasons, increasing private benefits have not were encouraged never to expect. Doing with- been matched by increasing public benefits. out became the norm. Public benefits from coal production have also Congress has debated an energy-impact as- been circumscribed historically by protracted sistance bill in recent sessions. Funds would be demand stagnation. Even as America’s con- provided from general Federal revenues rather sumption of energy quadrupled from 1920 to than through a national severance tax. The 1970, coal’s share dropped from about 78 per- Farmers Home Administration (Fm HA) pro- cent of the total energy market to 19 percent. 74 posed guidelines to disperse $20 million to Stagnating demand meant that coal towns coal- and uranium-impacted communities in were never able to levy reasonable taxes on March 1979. The assistance would be used for their principal local business for fear of shut- growth-management plans, housing plans, ting it down. Thus they never had the money to housing, public facilities, and services. How- provide adequate public services. Studies of ever, little of this aid will find its way to Ap- taxation patterns in coal counties find histori- palachian communities because the FmHA cal patterns of underassessment of undevel- growth requirement— 8 percent or more in oped coal property and undertaxation of that coal employment in the year following the which is assessed. States passed severance base year— is too high to qualify the well- taxes in the early 1970’s with great difficulty, settled, high-employment areas there. Con- and only when demand and prices were rising. gress may increase appropriations for this pur- Low taxation functioned as a public subsidy to pose orconsider a coal-financed contribution. local operators. Whatever the merits of the Much of this history is discouraging and pes- subsidy, it resulted in the chronic underdevel- simistic. Perhaps sustained, increasing coal de- opment of coalfield public services and institu- mand will correct these problems. If that is to tions. The public sector—especially at the happen, policy makers need a clear picture of local level –was thus forced to bear dispropor- current coal field conditions and the reasons tionately high costs while reaping dispropor- why things are as they are. The following sec- tionately few benefits from coal development tions describe these conditions in the East and through the 1960’s. On the other hand, what- West. ever public benefits that existed in these areas came from coal. To that extent, coal develop- Impacts on Eastern Communities ment was a source of both community benefit More than 90 percent of all of the coal ever and community deficit. mined in the United States has come from Similarly, local governments rarely regu- States east of the Mississippi River. Nearly 50 lated coal’s social costs. Operators often sited percent of the Nation’s remaining demonstrated coal reserves are found there. Billions “See National Coal Association, Coal Facts, of dollars of coal have been —and will be— 1974-1975, pp 58-59 In 1920, about 592 mllllon tons of mined from under the Appalachian Mountains bituminous and anthracite coal were consumed whereas and the fields of the IIlinois Basin. In 1970, only 524 mill ion tons were used domestically. Domestic consumption of bituminous coal was 509 mll- The visitor to the Central Appalachian coal- I ion tons in 1920 and 516 mllllon tons in 197o fields is struck by its contrasts. Trains of 100 294 The Direct Use of Coal

cars regularly haul hundreds of thousands of miners feel an intense pride in their profession dollars worth of coal past grimy, railside and appreciate its wages and benefits. On the shacks. Yet amid the dingy grimness of many other, many believe they and their communi- old coalfield towns, the visitor wilI sometimes ties have been victimized by the ups and come upon a bustling county seat that has downs of coal demand and the cost-conscious- been turned into a multicounty, commercial ness of their employers. center within the last 5 years. The natural North into Pennsylvania and west through beauty of the mountains contrasts starkly with Ohio, Indiana, Illinois, and Kentucky, the coal the scars and blemishes they bear from past towns change. The mountains flatten out. The mining practices. Finally, the visitor will meet visual impact of old strip mines is less severe. at least three distinct groups of people: the The towns are less cramped and seem more very poor, the middle-income working miner, prosperous. Farming coexists with mining. In and the well-to-do. the Ohio River Basin, manufacturing and other The typical Central Appalachian coalfield businesses make coal less important. Public community is small, congested, and lies along services appear to be closer to national norms. a stream or smalI river. Mountains often cir- The towns are less coal towns than towns cumscribe the town and define its growth. where coal mining occurs along with other Here and there comfortable ranch-style brick businesses. The distinction is significant. In houses appear. Most buildings are old and one, community life is totally dependent on rarely renovated, except for an occasional new the fortunes of a single industry. In the other, fast-food restaurant or quick-service grocery, a economic development is balanced and has modern brick post office, or public building, been cushioned from the consequences of The roads linking the outlying hollows to the coal’s quick booms and long busts. Finally, towns (and the towns to each other) are often miners here appear to enjoy a better quality of narrow, poorly engineered, dangerous, and community life and seem able to use their in- falling apart. Mobile homes are wedged becomes more efficiently. One sees fewer very tween mountain and highway wherever a flat poor or very affIuent. place can be found or bulldozed. Yet the Coal mining’s impact on community life visitor will also see a meticulously tended varies with conditions in the marketplace, ter- garden beside each house. Well-kept churches rain, the extent of economic diversification, and cemeteries are the rule. Evidence that this and the kind of industrial socialization each is coal country appears frequently: a tipple; a community experienced when coal was devel- portal; an old strip mine highwall or slag heap; oped. Generally, the social, political, and eco- a bumper sticker that says, “We dig coal. ” nomic effects of coal mining have been most severe where communities were totally de- Within a typical community it is common to pendent on coal, where the terrain was inhos- find severely inadequate water and sewage pitable to other activity, and where mining was systems, a low level of most public services, an the principal socializing force in community almost complete absence of public transporta- life. When these factors were less dominant, tion, a shortage of adequate housing, under- the public benefits of mining were greater. capitalized financial institutions, limited education programs, and a general feeling that the The extensive underdevelopment of much quality of community life is not what it could of the Appalachian coalfields is not difficult to be. Although coal miners make $17,000 or explain. First, demand for coal has remained more in a normal year, many find it difficult to stagnant for most of the last 55 years. This purchase quality goods and services that non- placed tremendous cost-cutting pressure on Appalachians with similar incomes take for coal companies. Economy was effected by granted. Thus coaifield residents often feel in- holding down labor costs, mechanizing, and dividually deprived and publicly disadvan- minimizing tax burdens through the exercise of taged. As a result, there is a general ambiva- political power at the local and State levels. lence about the coal industry. On one hand, Neither miners nor indigenous coal operators Ch. V/— Workplace and Community Implications ● 295

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Photo credit: Earl Dotter Coalfield housing located in the Cityview area of Logan County, W. Va. 296 ● The Direct Use 01 Coa/ got very far ahead until the 1970’s. That meant side and wages and jobs on Iabor’s. That com- coal field communities lacked investment capi- bination, lacking as it does the necessary tal, tax resources, and spendable income. premise of more output, cannot be and has not been sustained. Even as the promise of coal Second, mining companies were forced to growth beckoned, 5,000 to 10,000 miners were externalize production costs in order to sur- laid off or placed on short work weeks in re- vive. Thus strip mines and slag heaps were not cent months as metallurgical demand dropped reclaimed; coal-haul roads were abused; and because utilities chose to meet air pollu- streams were polluted. Most State and local ef- tion standards by using low-sulfur coals rather forts to internalize these costs through taxa- than through installing scrubbers or other tion and regulation were fought and generally sulfur control measures. defeated until the 1970’s. Had such efforts been successful, some marginal companies With these shifting developments, it is dif- would have gone under and others would have ficult to forecast a uniform set of socio- had a harder time. economic implications from increased Appa- lachian coal mining. Two to three dozen coun- Third, Appalachia has served America as a ties may find it extremely difficult to manage resource exporter. Coal mining did not stimu- either growth or stagnation, as neither condi- late investment in manufacturing, often lim- tion is predictable. For other coal counties, ited development of other economic activity. production will expand steadily and a range of Coal users usually did not locate their manu- growth-related social and economic issues will facturing and processing near coal mines. demand attention. As a result, Federal policy Again, a diversified economic base did not will need to be flexible and address three coal- take hold. related issues of Appalachian community development: Fourth, the biggest mining operations were usually owned by nonindigenous companies. 1. The current residual deficit in facilities Some of these companies developed adequate and services in both stagnating and ex- communities to service their mines; others did panding communities. not. Mining profits— such as they were—were 2. The problem of continued uneven coal not deposited in coalfield banks, so mining’s demand affecting particular communities financial benefits to coal towns were limited or sub-State areas. principally to wage and salary income. Conse- 3. The problems of rapid coal development. quently, the private sector in many coalfield communities has been chronically short of The capacity of any community to benefit cash. Native entrepreneurs usually engaged in from coal expansion depends to a great extent the most marginal kinds of business, mining on the seriousness of its existing underdevelop- and otherwise, because capital was so hard to ment. Where this deficit is greatest, expansion assemble. These two factors— initial inade- will produce the most problems; where it is quacies in community-building and subse- least, growth will be accommodated and the quent capital shortages— left coal towns with ability of communities to cope with associated chronically unmet needs and lacking the abili- social problems will be greatest. ty to solve their own problems.

Any analysis of the future socioeconomic Scope of Eastern Coal Expansion impacts of increasing Eastern coal production must confront the social legacy of past coal Estimates of new Eastern coal production development. The post-1973 Appalachian vary, rising or falling according to the op- “coal boom” has not been based on increased timism and assumptions of the estimator. One production. Indeed, production has falIen– survey forecast 255 miIIion tons of new capaci- particularly underground tonnage. The boom ty in 11 Eastern States by 1987, of which 197 was one of price and profit on management’s million tons would be deep-mined and 58 mil- Ch. V/— Workplace and Community Implications ● 297 lion tons surface-mined, ” This report esti- dividual counties may show net gains of mates 212 million tons of planned capacity miners. In Illinois, Indiana, and western Ken- east of the Mississippi by 1985 (chapter 11, tucky between 29,000 and 38,000 miners table 5). More significantly, no net increase in shouId be employed in 1985. As net production Eastern coal production is foreseen through increases between 1985 and 2000, mine em- 1985. ployment will probably increase proportionately. These projections assume no change in Appalachia produced 390 million tons in productivity and do not include nonminer coal 1977, (had there not been a 10-week wildcat workers, such as mine construction workers, strike that summer and a month-long shut- and those who work in preparation plants, tip- down in December, output would have been ples, and shops. around 425 mill ion tons). Appalachian production in 1985 should range from 355 million to For each new miner, it can be assumed that 415 million tons and in 2000 from 510 million five other persons– spouse, children, and sec- to 680 million tons (chapter 11, table 5). The ondary-employees —wiII be added to local three remaining Eastern States — IIlinois, ln- communities. The net population increase diana, and Kentucky (west) –produced 133 from coal production in the East is likely to million tons in 1977. Actual production should range from zero to 100,000 persons by 1985. range between 128 miIIion and 164 miiIion tons Specific counties will be most heavily affected in 1985. Substantial expansion of eastern pro- when new deep mines are put in where the ex- duction is likely to occur after 1985. From 510 isting social deficit is greatest. The most im- miIIion to 680 miIIion tons of Appalachian pro- pacted counties will probably be in southern duction and 206 million to 299 million tons West Virginia, eastern Kentucky, southwestern from IIlinois, Indiana, and western Kentucky is Pennsylvania, and some areas of the Illinois expected by 2000. Basin, These estimates suggest that the East as a Existing Conditions coal-producing region has 6 years in which to plan for higher production. However, some Social and economic conditions in Eastern communities will be heavily affected by coal- coal field counties differ widely. Compared related growth within these 6 years. Others wilI with the United States as a whole, the 50 lead- not experience any expanded production but ing coal counties in the East showed gross defi- will probably be required to absorb additional cits in income, educational attainment, and coal-related employment. housing in the 1970 census. ” Central Appa- Forecasting community impacts of increased coal production hinges on the amount of coal actually produced in the future (rather than theoretical capacity) and the proportion of new production mined by strip and deep methods. Underground mining now requires roughly 550 miners to produce 1 million tons; surface mining uses about 160 miners for the same amount at current productivity rates. Ac- cordingly, between 144,000 and 167,000 miners will be employed in Appalachia in 1985. No increase in net Appalachian mine employment is forecast for the next 6 years, although in-

“George F Nielsen, “Keystone forecasts 765 Million Tons of New Coal Capacity by 1987, ” Coal Age, February 1978, pp 113-134 The 11 States are Alabama, Georgia, II- IInols, Indiana, Kentucky, Maryland, Ohio, Pennsylvania, Tennessee, Vlrglnla, and West VIrglnla 298 ● The Direct Use of Coa/

Iachian counties had the highest deficit, Il- average in 1975. From Kentucky’s low of 66 Iinois Basin counties the next highest, and percent of the national average, with Virginia northern Appalachian counties the least when (73 percent), Ohio (79 percent), Alabama (82 compared with the other two. Measures of percent), and West Virginia (84 percent) in be- poverty have historically been higher in coal tween. counties than in most noncoal counties. The more dependent a county has been on coal, Similarly, the 50 coal counties had nearly the higher its poverty index. In the 1920’s and one-fourth more than their share of persons 1930’s, this was the result of the industry’s low- with less than a high school education. About wage policies and slumping demand. In the 59 percent of persons 25 years and older 1950’s and 1960’s, mineworker unemployment lacked a high school diploma. Northern Appa- and lack of economic diversification caused lachian coal counties had the lowest incidence poverty to increase. The 50-county coal region of poverty and the lowest percentage of those had a 43-percent greater incidence of poverty with less than a high school education. Central than the United States as a whole in 1970, Appalachian counties had the highest inci- while family poverty was 53-percent higher dence of both. than the national average. 77 The comparative- One reflection of educational quality in Ap- ly strong showing of northern Appalachian palachia is provided by comparing regional coal counties is due to their diversified econ- achievement test scores with National or State omies — especially high-wage industries such rankings (see table 50). The widest discrepan- as iron and steel, chemicals, metal products, cies between county performance and Nation- glass, transportation, and electric power. By al/State reading and math standards occur in contrast, much noncoal economic activity in Central Appalachia, principally a coalfield the IIlinois Basin is agricultural. area. There, 69 percent of those counties re- The range of social problems coinciding porting were below National/State standards with poverty places extra burdens on commu- on reading achievement in 1976-77 and 94 per- nities whose tax resources are already limited. cent were substandard on math. Students in The 1970 census data show that much of the northern and southern Appalachia performed Eastern coalfields entered the mid-1970’s better than National/State standards on “boom” with few financial resources. Despite reading, but did less well in math. the gains in mining wages, personal income in the Appalachian region was below the national Rapid population expansion from coal development will add to problems of educational quality. In Raleigh County, W. Va., for example, even though a $20-million construction 7 ’ (continued) coal miners. Many were unemployed miners, retired and program was begun in 1973, the county super- disabled miners, and widows of miners Some portion of intendent admits that “in four or five cases the coal field poor had nothing to do with the coal indus- we’ve had to put two teachers in one class- try. Although miners’ pensions have improved since 1974 and Federal black lung benefits now pump dollars into room with 50 kids. ” He anticipates “this sort of coal towns, there remains a thick slice of mining-related thing . , . will probably occur more often in the residents who Iive on modest fixed incomes They are dis- future.” In Greene County, Pa., local school of- advantaged by coal-boom inflation. They do not contrib- ficials feel that school construction should be ute as much to local tax revenues on a per capita basis as postponed until after the population expands, active miners Each coal fieid community must absorb some of costs of providing services to this group. Even as with portable classrooms used in the interim. coal growth brings income gains to working miners, a When a large number of young, married coal class of poor and lower income residents will remain. miners settles near new coal mines, local They will be economically and psychologically disadvan- school systems will face front-end financing taged by the coal-based advancement of their neighbors problems in building facilities. Educational “Calculated from County and City Data Book, 1972 (Washington, D C : U.S. Department of Commerce, quality will be adversely affected by over- Bureau of the Census, 1973), tables 1 and 2 See vol. 11, crowding, inadequate facilities, and teacher app. Xl 1. shortages. Ch. V/— Workplace and Community Implications ● 299

Table 50.—County Rankings on Achievement Tests, 1976-77 (3rd or 4th grades)

Reading Math Percent of Percent of Percent of counties at counties at Percent of Appalachian or above Percent of or above counties counties National/State counties below National/State below Geographic region Reporting standard standard standard standard

Housing is crucial to expanding coal produc- befouled creeks. A recent West Virginia State tion. Coalfield housing is of low quality com- health department study found that 70 percent pared with national norms. More than 31 per- of the water from public suppIies in the county cent of the Central Appalachian housing units was substandard. Raleigh County residents surveyed in 1970 lacked plumbing facilities; complain of tapwater the color of orange pop. 15.6 percent lacked them in the Illinois Basin; In Mingo County, W. Va., primary sewage and 8.6 percent in northern Appalachia. But treatment faciIities exist in only two communi- coalfield housing is more complicated than ties. Drinking water for Williamson, the county plumbing inadequacies, although they are a seat, comes from the Tug River, which the good index of housing quality. The most urgent county says is polluted by acid mine drainage, issue is supply. Every study of coal field hous- preparation discharges, and diesel-oil runoff ing finds the existing housing stock insuffi- from adjacent railroad yards. Williamson’s cient. It is not likely to expand fast enough to treatment plant is old and overloaded. The city house adequately additional mining-related is seeking State and Federal funds to replace it. population. The current housing deficit is the In Breathitt County, Ky., only Jackson, the product of the coal slump of the 1950-70 peri- county seat, has sewage service. The pervasive od when few units were built. It is com- lack of water and sewage facilities makes pounded today by a lack of adequate water coal field housing development costly. It is and sewage facilities, an absence of private especially difficult when State and Federal builders, a shortage of mortgage capital, an reguIations require such services. unwillingness of coal field banks to make hous- In many coal counties, most of the land is ing loans, and, most fundamentally, the un- owned by a handfuI of corporations, which are availabiIity of land on which to build. reluctant to sell, preferring to hold the land for Water and sewage systems are expensive. future development. The underlying coal They do not exist in many Appalachian coal makes the land worth considerably more than towns. In Raleigh County, W. Va., only half the sale for housing would justify, especially when population is served by public sewage facil- taxes are low. One study found that in the 14 ities, The rest use septic tanks, package plants, major coal-producing counties in West Virgin- outhouses, or the nearest stream. The head of ia, the top 25 landowners — all of whom are the local chamber of commerce says a total connected to the coal industry —owned as moratorium on new construction could be im- much as 2.1 million acres of land, or nearly 44 posed by health agencies because of sewage percent of all of the land in these counties.78 problems. One local health official says the The top 10 landowners who owned 31 percent only thing preventing a typhoid epidemic from striking some sewer less hollows is the acid Jj Davltt McAteer, Coal Mine Health and Safety The mine drainage that kills the bacteria in the Case of West Virginia (New York Praeger, 1973), p 163. 300 The Direct Use of Coa/

of the land in West Virginia, were, by rank: long distances; this, in turn, leads to absen- Pocahontas Land Corporation (a wholly owned teeism at work. subsidiary of the N&W Railroad), Consolida- A few landholders have begun to make some tion Coal, the Chessie System, Georgia-Pacific housing Iand available. The Beth-Elkhorn Corporation, Eastern Associated Coal Corpora- Corp., a subsidiary of Bethlehem Steel, is tion, Island Creek Coal Company, Bethlehem located in Jenkins, Ky. In 1976, Beth-Elkhorn Steel, Charleston National Bank, Berwind Cor- provided title in fee simple to 92 acres of land poration, and Union Carbide. Nine of the top on an abandoned strip mine bench for residen- 10 Iandowners in these 14 counties had head- tial development to contain 48 single-family, quarters outside of West Virginia. 79 This study 62-multifamily, and 33-clustered housing units. reported that the top 25 landowners had their Unfortunately, the development costs of using property assessed at about one-fifth of the 14- surface-mined land make this apparently logi- county total assessment. A second study in cal solution of limited feasibility in many West Virginia found that “two dozen out-of- places. Island Creek announced an even bigger State corporations and land companies–all housing development for southwestern Virgin- tied directly or indirectly to mineral indus- ia. Another example is the Raleigh County- tries — own a third of the State’s 12 million based Coalfield Housing Corporation (CHC), a privately held acres."80 This report found that joint industry-union effort begun in March “in almost 50 percent of West Virginia coun- 1977. CHC has 26 units under construction and ties, at least half the land is owned by out-of- 210 additional units scheduled. Land availabil- State corporate interests . . . [that often pay] as ity, financing, and lack of builders have been little as $2 per acre in annual property taxes. ” its three major obstacles. The CHC model has The most recent study found that nearly 80 not been repeated elsewhere in the coal fields. percent of the land in Mingo County, W. Va., is Recently West Virginia Governor John D. owned by major corporations, most of which Rockefeller IV initiated land condemnation were related to coal mining and natural re- proceedings against the Philadelphia-based sources.82 The Appalachian Regional Commis- Cotiga Land Co., which refused to sell land to sion has recently funded a major landowner- the State at what the Governor considered a ship survey to facilitate housing and economic reasonable price for victims of the 1977 Tug development. River flood. Given the steep terrain and the flood-prone- ness of the valleys, flat land suitable for per- Housing and land shortages force miners to manent housing is inherently limited. Moun- remodel old coal-camp houses or purchase tainside housing is possible in many areas, but mobile homes instead of permanent resi- development costs (for water, sewage, and dences. These are bunched in towns or strung roads) are high. Individual homebuilders can closely together along valley floors. Mobile rarely afford to build there. Federal programs homes may shortchange local tax coffers, as have not adequately explored using this type their owners use a full range of community of land for coalfield housing. Although the services but often pay personal rather than coal fields are rural, their population is con- real property taxes on their dwellings. Their gested along narrow creek bottoms. Without owners often complain about construction additional land, the population density of quality, rapid deterioration, fire hazards, and coalfield towns and hollows will continue to low resale value. Some of the newer and more increase or miners wilI be forced to commute expensive models address these concerns. Many residents believe that coal companies “ibid , pp 140-149 prefer to have their workers housed in mobile ‘“Tom D. Miller, “Who Owns West Virginia?, ” Hunting- homes so that they can be moved out of the ton, W Va , Huntington Hera/d-Dispatch, 1974, pp 2, 23. way when a mine needs the land. On the other a Ibid ’ hand, some coal executives believe one solu- “Study prepared by the staff of the Tug Valley Recov- ery Center and the Sandy New Era, published in the San- tion to wildcat strikes is to have miners buy dy New Era, Feb 1, 1979 quality housing that comes with a long and Ch. VI— Workplace and Community Implications ● 301

Photo credit: Douglas Yarrow Flood damage in Wyoming County, W. Va., 1977 302 The Direct Use of Coa/ heavy mortgage. If significant production is weights on interstate highways in their bound- expected from the eastern fields after 1985, aries or suffer a cutoff of Federal highway aid. land must be made available for single-family Without strict enforcement of weight limits, housing, and a housing construction industry road repair money will have little long-term must be created. value.

Coalfield underdevelopment is reflected in Coalfield health care is generally inade- the quantity and quality of other public serv- quate and extremely vulnerable to overloading ices. For example, the Appalachian Regional from rapid population growth. The Appalach- Commission funded an assessment of the im- ian Regional Commission reports that most of pact of coal movement on Appalachian high- coalfield Appalachia is underserved by physi- ways. 83 This study found that coal movement cians, dentists, nurses, and hospital beds com- by truck affected more than 14,300 miles of pared with the U.S. average. Many measures of Appalachian roadway in 1974. Of that total, community health— infant mortality, fluori- 6,880 miles of coal-haul roads were inadequate dated water, prenatal care, per capita public to meet the present volume of coal-truck traf- health expenditures, immunizations, etc. – in- fic. Between 897 and 1,103 bridges were inade- dicate that much of coalfield Appalachia falls quate. The cost of maintenance was placed at below national standards. Many of these same $66 million to $81 million annnually (1977 dol- problems were first brought to national atten- lars), bridge replacement at $59I million to tion in 1947 when the Department of the interi- $726 million, and roadway reconstruction and or published a comprehensive survey of coal- rehabilitation at $4.1 to $4.9 bilIion.84 Only a field health, under the leadership of Adminis- tiny fraction of these sums is now spent to trator Joel T. Boone.85 Much improvement has maintain, replace, and reconstruct coal-haul been recorded since the Boone report, but cur- roads. These numbers do not adequately con- rent data reveal many unmet needs. In 1950, vey the visible wreckage of the public road UMWA won an operator supported system of system in many Appalachian coal counties. medical insurance and health services pro- Some portions have simply slid down a moun- viding near comprehensive benefits to UMWA tainside. Spillage and coal dust from over- miners and their families. Hospitals and clinics loaded trucks have caused problems for were built. Preventive medicine and group motorists and landowners. Major secondary practice were encouraged. The Fund brought lines must be traveled with a sharp eye for dozens of doctors and hundreds of other axle-breaking potholes. Taxpayers pay for the health professionals into the coalfields. Today, constant upkeep on coal-haul roads while con- part of this system is floundering, and some of sumers pay repair bills for their vehicles. The the rest is uncertain. Severe health care cur- main cause of the problem — apart from the tailments have already been recorded at about initial shortcomings in construction and four dozen Funds-dependent clinics. The cut- upkeep — is the illegal overloading of coal back in clinic services resulted from the Funds trucks. Numerous studies of this phenomena ending first-dollar coverage for miners along have reached the same conclusion: coal trucks with replacing retainer payments to the clinics regularly exceed legal axle weights, offenders with fee-for-service reimbursement. The West are rarely cited, and fines are so low as to be Virginia University Department of Community no deterrent at all. State officials are reluctant Medicine found that total doctor office visits to tighten up on enforcement. Federal officials fell 31 percent since the imposition of copay- are reluctant to use Federal law—which re- ments on physician care in the five clinics quires States to enforce Federal gross and axle surveyed. The financial condition of the clinics worsened measurably. Where utilization fell, receivables rose — by as much as 190 percent in “]Research Triangle Institute, An Assessment of the Ef- fects of Coa/ Movement on the Highways in the Appa- lachian Region (Washington, D. C.: Appalachian Regional “5A Medical Survey of the Bituminous Coal Industry Commission, November 1977) (Washington, D.C : U.S Department of the Interior, Coal 841 bid , p. vi, Mine Administration, 1947). Ch. VI— Workplace and Community Implications . 303

Photo credit: Douglas Yarrow Shopping center construction, Beckley, W. Va., 1977 one clinic. Operating deficits were recorded in high hospitalization rates as being a reflection each quarter studied. Physician staffing de- of a kind of "cultural hypochondria” that clined by 42 percent from July 1977 through predisposes Appalachian miners and their September 1978. Nonphysician staff declined families to overuse medical facilities. Hospital by 25 percent. Special preventive health pro- utilization will be encouraged by the physician grams have been eliminated. Facilities and drain that began with the Funds cutbacks in equipment are not being adequately main- the summer of 1977 and by implementation of tained. Pharmacy and medical supply inven- the 1978 UMWA contract, which imposes coin- tories have plummeted .8’ surance payments on physician care but not on hospitalization. The Funds population had a higher-than- Coalfield health care issues revolve around normal hospitalization rate, which may be re- questions of availability and quality. In most lated to the shortage of ambulatory physican coal counties —with certain prominent excep- care. Some operators and physicians interpret tions—there are too few quality doctors and

8 health care extenders, facilities, and preven- ’William Kissick and American Health Management and Consulting Corp , “West Virginla Primary Care Study tion programs. Much of this shortage is due to Group Problems of Reimbursement, ” Department of the remoteness and isolation of these counties, Community Medicine, West Virglnla University, update, and the lack of certain kinds of cultural and November 1978 See also Virginia Gemmell and Jane recreational facilities for health professionals. Ray, Physician Loss in Central Appalachian Coal field Hospitals and Clinics, draft report by the Appalachian But these limitations were overcome by the Regional Commlsslon, 1978, and Charles Holland, et al , UMWA Fund in the 1950’s and do not present West Virglnla Primary Care Clinics, 1978 an overwhelming obstacle to recruitment to- 304 ● The Direct Use of Coal day. Federal and State programs designed to 1970’s turned Beckley into a boomtown. The encourage general physician care in rural areas city is trying desperately to manage a host of have had some success. But even where new housing, water, sewage, and transportation doctors with rural-practice specialization go problems. Although Raleigh has been a fair- into coal towns, communities have trouble re- sized coal producer for decades, the fact that taining them. Where significant expansion of Beckley has been turned into a center of re- the coal population occurs rapidly, currently gional commerce and finance has broadened overloaded treatment systems will function the county’s economic base. Yet prosperity even less adequately. continues to be keyed to coal. Because of The system of group-practice clinics and Beckley’s regional importance, its resources regional hospitals initiated by the UMWA Fund are greater than most coal field county seats. may still serve as a model for coalfield health Raleigh County is now, ironically, experiencing care. The Fund recruited health personnel a severe economic slump that came with slack carefully. Quality control on services was demand for local metallurgical coal. With lit- maintained on non-Fund providers. Outpatient tle noncoal industry in the county, its econom- and community outreach programs were em- ic fortunes rise and fall with demand for local phasized. The entire system was supported by coal. Little attention appears to have been an operator-paid tonnage royalty. When de- given to economic diversification during the mand was steady or rising, the system worked short-1ived boom. well. Only when demand felI steadily over a Mingo County, W. Va., has not expanded period of years, did the Fund falter. If future production, although more miners have been demand increases as most estimates predict, a hired in the last 6 years. Some new mines have coal-supported health system of this kind may opened, but others have cut back. A flood again prove to be the most practical solution. swept through Williamson, the county seat, in 1977, devastating the community. The econ- Six Case Studies omy was slow to recover. A report to President Carter in March 1978 found that: Six high-growth Eastern coal counties were examined to determine their socioeconomic It has been almost impossible to acquire land to accommodate coal mining families problems related to coal development and to whose homes were ruined in early 1977 floods assess their capacity to manage additional or who are coming in for additional coal em- mining (volume 11, appendix Xl l). Most Eastern ployment. The land not on steep slopes or on coal counties have had to cope with some flood plains is largely held by landowners un- level of mining-related population growth even willing to sell their land for housing, preferring though, in many cases, production did not in- to hold it for speculation or resource develop- crease at all. These six counties represent the ment, 87 spectrum of capabilities and problems that ex- As nearly 80 percent of Mingo County’s land is ist in the Eastern fields. owned by nonlocal, coal-owning corporations, The picture that emerges suggests that–to tight land policies present major roadlocks to various degrees — short-term coal expansion efficent growth management. Many public has already overloaded Raleigh and Mingo services — education, water, sewage, recrea- Counties, W. Va., and Breathitt County, Ky. tion, and health– are inadequate. More flood- Greene County, Pa., Tuscaloosa County, Ala., ing has occurred since 1977. The viability of and Perry County, I Il., have been less coal- the coal industry in the Tug River Basin rests dependent historically and appear to be able partly on better flood-prevention measures. to manage increased coal production with lit- Breathitt County, Ky., experienced a 109- tle disorientation. percent increase in coal production between Although coal production has not increased 1970 and 1976. Almost all of its output is sur- significantly in Raleigh County, its county seat, 87 Report to the President on Energy Impacts Assistance Beckley, has been turned into a regional (Washington, D C U S Department of Energy, Energy growth center for southern West Virginia. The Impact Assistance Steering Croup, March 1978), app. A , price rise of metallurgical coal during the mid- p3 Ch. VI—— Workplace and Community Implications ● 305 faced mined. Mining accounts for 40 percent potential. Several factors will work to facili- of all public and private employment there. tate eastern growth. First, there exists a tradi- Production is expected to increase by 50 to 75 tion and orientation among the population percent by 1986. Breathitt County was one of toward coal mining. Miners tend to be the America’s poorest counties; coal growth is children of miners. The lore of the work is welcomed by its residents. Still because of handed down from generation to generation. earlier underdevelopment, Breathitt is experi- The problems of the craft are understood by encing adverse impacts. (Because the expan- wives and families. Local schools are geared sion is in surface mining, the population im- toward mining-related training programs. pacts are expected to be less severe than if sig- Local colleges usually offer mine engineering nificant underground production were sched- degrees. A second strong point is the produc- uled.) Breathitt County lacks many services. It tion infrastructure that already exists. Despite has no hospital. Sewage treatment is found the problems of coal-haul roads and rail and only in the county seat, No public transporta- bargeline bottlenecks, a mine-to-market trans- tion system exists. The County has a compara- portation system is in place. Further, there is tively high tax rate, but its base is very small. an adequate support system consisting of Unmined coal was assessed at only $11.3 mil- equipment manufacturers, repair shops, and lion in 1976, or about $0.025 per ton of recov- supply retailers, who can respond to increased erable coal (441 miIIion tons). The State has in- mining. Local lawyers and brokers understand creased assessments in recent years, but reve- the coal business. The operators know the lay nue is unlikely to cover needed services. of the land both literally and figuratively. Coal resources are well known. The components of Greene County, Pa., is a deep-mining, coal a production system are familiar. Problems of county where almost 25,000 coal-related addi- expanded development are not new. What is tional persons are estimated to be living by not greatly in evidence is the recognition that 1996— a number equal to the county’s current the ability to expand coal production is linked population. A Westinghouse study of Greene to the ability of mining communities to benefit County projects a total population increase of 88 from that expansion. 118,300 by 1996. The county is not well prepared to handle the impacts of massive and Since the early 1970’s many eastern commu- rapid growth. nities have experienced expanding mining pop- uIations and/or increased production. The seri- In contrast, Perry County, Ill., and Tusca- ousness of community impacts varies accord- loosa County, Ala., appear generally to be able ing to the variables discussed above. Most coal to benefit from anticipated expansion, Both counties are aware that coal impacts will in- counties have diversified coal economies, with crease, but few have begun to do the necessary mining representing 1 percent of Tuscaloosa’s planning and resource accumulation that im- employment and 17 percent of Perry ’s. The pact-management requires because of the dol- rate of coal expansion and its extent are more lar costs and time involved. To be effective, modest than those in Greene or Breathitt planning must occur before coal impacts Counties, which enable growth to be managed begin. Existing Federal programs have not met more effectively. Individual communities in the planning and front-end financing needs of each county may be seriously affected by the coal-affected communities. Planning and re- opening of a mine, but this appears to be little source management push communities to cause for concern countywide. evaluate their tax systems, revenues, service- Any rendition of the historical impacts of delivery systems, and likely sources of non- mining on Appalachia obscures the benefits local assistance. As coal impacts have fallen that coal has brought and the region’s growth on coalfield governments, communities are becoming aware that local taxation systems are inadequate. First, they rarely generate sufficient income to provide adequate public services. Second, they do not adequately tax the 306 The Direct Use of Coa/

community’s main assets: undeveloped miner- costs. Strategies of this sort are likely to call al wealth and current coal production .89 I n for economic diversification in coalfield com- Mingo County, for example, coal and land munities, citizen participation, new land and companies —which own almost 80 percent of taxation policies, regulated growth, and fewer the land — had an aggregated property tax levy cost externalizations. Strategies of this sort in 1978 of $231,000 compared with $960,000 may slow the rate of coal development initial- for private residents and local businesses.90 ly, but advance the East’s ability to produce Many coal counties assessed undeveloped coal over the long term. coal at only a penny or two per ton, and tax revenues amounted to only a few dollars per acre each year. Individual counties and States Impacts on Western Communities have been reluctant to impose burdensome coal-related taxes. They feared the increased Introduction cost of local coal would disadvantage local Coal development is occurring in eight operators in the marketplace. Nevertheless, States of the northern Creat Plains, the Rocky many counties needing to raise substantial ad- Mountains, and the Southwest– North Dako- ditional revenue are now eyeing local coal ta, Montana, Wyoming, Colorado, Utah, Texas, resources. Coal companies are challenging New Mexico, and Arizona. (Limited develop- higher assessments in several counties. From a ment is also found in the State of Washington. ) national perspective, differential tax burdens Coal production in these States amounted to (from State to State) may create inefficient in- some 166 mill ion tons, or nearly 24 percent of centives for wise resource development. the Nation’s coal output in 1977. By 1985, Perhaps the most severe coal impact that some 630 million additional tons of annual communities have been unable to resolve is capacity may be available there. Currently, the issue of Iand availability and housing, Coal about 17,000 miners are employed in Western operators have generally chosen to stay out of coal mining. Between 34,000 and 42,000 miners the housing business and are reluctant to assist will work in this region in 1985. Coal mining is private developers. The private housing mar- only one cause of coal-related impacts in the ket is inadequate to build middle-income hous- West. The construction and operation of coal- ing. Most coal counties have had little experi- combustion facilities, such as coal-fired ence in public housing. Multiunit townhouses powerplants and coal-gasification plants, also or high-rise developments do not fit the hous- affect isolated communities, ing expectations of local residents. The stop- The West shares some characteristics with gap solution of mobile homes is not likely to the Appalachian coalfields, but significant dif- produce community stability and growth or to ferences stand out. Both regions export raw benefit the industry in terms of employee materials, although the variety of Western re morale and absenteeism, sources extracted is far greater. Both regions The level of current and future costs and have depended on imported capital to develop benefits partly depends on the extent of ex- their resources. As the economic return to isting underdevelopment. As plans are carried communities where minerals are extracted is out to increase Eastern coal production, com- often less than most other industrial activities, munity development strategies will be re- both areas have experienced relatively limited quired to achieve a positive ratio of benefits to growth rates. Finally, each region has evolved an identity and cohesiveness that come, in 89Some Eastern States such as West Virginia have un- part, from the collective perception of eco- dertaken a comprehensive reevaluation and assessment program that promises to bring more coal-related tax nomic dependency or subservience to the rest revenues to coal field governments. But West Virginia tax of the Nation. officials admit that the higher valuations of undeveloped coal property will not produce sufficient income to The West is not a homogeneous region geo- finance the range of needed services graphically or socially. Its coal-producing ‘“See Sandy New Era, Feb. 1,1979. areas are characterized by widely scattered Ch. VI— Workplace and Community Implications ● 307 towns, with typical populations of 5,000 per- Identification of Impacted Communities sons or fewer. The counties are much larger in With one exception, the distribution of new area than counties in the East and exhibit a production throughout the West will be rela- varied topography. Much of the area is subject tively uniform. Six States–Colorado, Mon- to Federal jurisdiction. Roughly 44 percent of tana, New Mexico, North Dakota, Texas, and the land area in the major Western coal States Utah– are each expected to add 55 million to is owned either by the U.S. Government or by 61 million tons of new annual capacity be- various Indian tribes .9’ Actual land control, tween 1977 and 1987, according to estimates owing to Federal coal-leasing policy, is even presented by Coal Age. 92 (These estimates are higher. referred to as the “Keystone Case” throughout the remainder of this discuss ion.) The excep- In contrast to the relative cultural homoge- tion is Wyoming, which Keystone estimates to neity of the Appalachian coal region, the West- be able to produce more than 270 million addi- ern fields encompass a majority white popula- tional tons annually by 1987. Campbell Coun- tion and three major cultural subgroups: ln- ty, Wyo., alone is scheduled to have an annual dians, Hispanic Americans, and members of production capacity of nearly 203 million tons the Church of Jesus Christ of Latter Day Saints per year over its 1976 level. Arizona and Wash- (Mormons). Regionwide generalizations about ington are expected to have minor increases in attitudes toward growth are risky given this capacity of 3 million and 1 million tons per cultural mosaic. For historical and cultural year, respectively. Table 51 presents a county- reasons, attitudes toward coal development by by-county breakdown of estimated additional minorities may differ from those of coal pro- western capacity by 1987, by both surface and ducers. The problems faced by Indian commu- underground mining methods, developed from nities in managing coal-related development the Keystone data. and the governing structure of the reservation system are unique. They are considered sepa- These estimates are generally considered to rately in this chapter. be optimistic. They are derived from a survey of coal producers on projected new mines and planned expansions of existing mines. Many of Water is a prized commodity in the arid West. The ability of communities and coal the proposed mines have not begun to acquire operators to obtain sufficient water will shape the necessary permits and approvals. Some ca- the extent of coal development. There is little pacity will never materialize because of unfa- or no western water that is not already al lo- vorable market conditions or unanticipated cated to existing water-rights holders, primarily problems. agricultural users. Obtaining water rights for In order to evaluate more accurately the coal development may occur smoothly likely range of impacts on western communi- through negotiated purchase. But in some ties, a low-production “case” (the OTA case) areas of high water demand, or where State was calculated by State and county. Likely policies promote conservation of the agricul- slippages in each State’s production, owing to tural sector, conflicts may develop between a slowdown in coal gasification efforts, reluc- private and public entities, In market competi- tance to resume large-scale Federal coal leas- tion for scarce water, energy developers will ing, and other factors were identified. (See almost always be able to offer higher prices volume 11, appendix Xl 1 I for complete discus- than agricultural and ranching interests. sion of statistical methodology). Total new Special protection for certain groups of water miner requirements for both production esti- consumers may be warranted in this regard. mates, along with the 1976 population estimate for each county, are presented in table 52. Public Land Statistics, 1975 (Washington, D C. U S ‘zGeorge F Nielsen, “Keystone Forecasts 765 Million Department of the Interior, Bureau of Land Manage- Tons of New Capacity by 1987, ” Coal Age, February ment, 1976) 1978, pp 113-114 308 The Direct Use of Coa/

Table 51 .–New Western Coal Production Capacity by County, 1977-86 (in millions of tons)

Keystone case OTA low-production case State and county Surface Underground Total Surface Underground Total

Arizona Navajo ...... 3.30 3.30 0.00 0.00 Colorado 12.50 12,50 2.44 2.44 0.10 0.10 0.10 0.10 0.25 1.80 2.05 0.25 1.02 1.27 1.80 1.80 1.80 1.80 3.00 3.00 0.40 0.40 3.70 3.70 0.27 0.27 0.10 0.10 0.10 0.10 3.00 3.00 3.00 3.00 3.25 3.25 0.96 0.96 8.85 8.85 3.76 3.76 6.30 1.85 8.15 6.30 1.85 8.15 1.50 1.50 1.29 1.29 4.20 4.20 1.81 1,81 3.60 4.30 7.90 3.60 2.74 6.34 0.30 0.30 0.30 0.30

30.65 29.75 60.40 17,99 14.00 31.99

Montana 35.50 35.50 14.28 14.28 13.00 13.00 5.00 5.00 1.20 1.20 0.17 0.17 0.10 0.10 0.10 0.10 8.16 8.16 4.09 4.09

62.96 62.96 18.64 18.64

New Mexico Colfax ...... 0.50 1.50 2.00 0.50 0.50 McKinley ...... 20.70 20.70 11.13 11.13 San Juan ...... 37.70 37.70 15.37 15.37

58.90 1.50 60.40 27.00 27.00

North Dakota 0.60 0.60 0.60 0.60 14.00 14.00 4.07 4.07 1.50 1.50 0.44 0.44 22.00 22.00 11.34 11.34 11.80 4.00 15.80 5.63 2.00 7,63 2.60 2.60 2.60 2.60 0.46 0.46 0.32 0.32

52.96 4.00 56.96 25.00 2.00 27.00 Texas 6.00 6.00 2.98 2.98 2.50 2.50 0.60 0.60 0.60 0.60 4.00 4.00 0.18 0.18 8.80 8.80 0.18 0.18 0.18 0.18 9.60 9.60 3.57 3.57 Ch. VI— Workplace and Community Implications ● 309

Table 51 .–New Western Coal Production Capacity by County, 1977=86 (continued) (in millions of tons)

Keystone case OTA low-production case State and county Surface Underground Total Surface Underground Total

Panoca ...... 16.00 16.00 11.98 11.98 Robertson ...... 6.00 6.00 1.98 1.98 Titus ...... 4.60 4,60 4.60 4.60

58.28 58.28 26.07 26.07 Utah 10.20 10.20 7.00 7.00 4.00 15.00 19.00 2.19 8.86 11,05 11.00 6.00 17.00 6.03 6.03 8.25 8.25 4.33 4.33 1.00 1.00 0.77 .77 16.00 39.45 55.45 8.99 19.99 29.18 Washington 1,00 1.00 2.00 2.00

Wyoming 202.50 202.50 112.73 112.73 17.10 7,90 25.00 6.80 6.80 13.00 13,00 3.43 3.43 1,00 1.00 0.78 0.78 7.60 7.60 5.69 5.69 7,00 7.00 6.04 6.04 10.25 0.95 11.20 7.89 0.95 8.84 3.00 3.00 2.63 2.63

Table 52.–Additional Manpower Requirements for Western Coal Development, 1977-86 (Keystone case and OTA low case)

Annual population growth Manpower Requirements rate, ”/0/year 1976est Keystone OTA Keystone OTA State and county pop. case Iowcase case Iowcase

Arizona Navajo ...... 61,200 184 0 0.18 0.00 Colorado 19,100 624 353 1.81 1.06 8,800 1,068 78 5.62 0.52 16,200 1,217 360 3.79 1.26 65,400 3,051 1,297 2.50 1.11 8,900 576 576 3.34 3.34 9,600 544 413 2.97 2.32 5,300 762 328 6.42 3.21 10,200 987 769 4.68 3.80 310 The Direct Use of Coa/

Table 52.–Additional Manpower Requirements for Western Coal Development, 1977-86 (continued) (Keystone case and OTA low case)

Annual population growth Manpower Requirements rate, ‘/o/year 1976 est. Keystone OTA Keystone OTA State and county pop. case low case case low case

10,600 1,804 727 7.29 3.51 2,383 661 0 10.30 0.00 2,700 333 0 5.70 0.00 9,900 538 270 2.86 1.53

3,336 997

13,300 430 383 1.79 1.61 56,000 1,478 794 1,48 0.82 67,700 1,336 545 1.13 0.47

3,244 1,722

4,200 15 15 0.21 0.21 4,800 300 87 3.24 1.04 11,800 1,100 567 4.54 2.57 6,700 1,764 874 9.94 5.95 2,400 85 85 1.95 1.95

3,264 1,628

19,800 396 197 1.14 0.58 12,100 40 40 0.20 0.20 12,200 264 12 1.23 0.06 30,600 582 1.09 0.00 19,900 634 236 1.76 0.69 16,400 926 692 2.96 2.28 14,300 396 131 1.55 0.54 18,000 304 304 0.97 0.97

3,542 1,612

19,100 3,617 2,482 7.89 5.93 7,600 5,437 3,200 18.13 13.43 3,400 2,796 399 19.49 5.48 12,400 2,855 1,498 9.06 5.60

14,705 7,579

48,900 66 132 0.08 0.16

14,500 6,237 3,459 13.61 9.29 17,200 1,410 372 4.08 1.23 9,400 858 226 4.46 1.36 10,500 473 355 2.42 1.86 21,100 371 321 1.01 0.88 31,300 522 448 0.96 0.83

9,871 5,181 47,041 23,025 — Ch. VI— Workplace and Community Implications . 31 I

The real population growth associated with The list of vulnerable counties grows slightly coal development encompasses not only the if the time frame shifts from 1977-86 to miners themselves, but their spouses and 1977-81. With Keystone’s assumptions, three children. Secondary employment is also gener- more Colorado counties— Moffat, Pitkin, and ated. An average family size of three for both Routt — are now experiencing rapid population primary and secondary workers, coupled with growth. The shorter time frame does not add an assumption of one local service job per pri- counties to the OTA estimates. mary job, yields an estimate of five additional persons per mining job. Projected annual Two other factors should be considered. growth rate in total population for each of the Mine construction workers appear 2 to 5 years affected counties is presented in table 44 earlier than the mine-operating work force. Some officials on the scene in Western States Construction crews are about the same size as say the available estimates of county popula- mine-operating crews, so actual popuIation ef- tion severely understate reality. Where this is fects are moved ahead in time but not in- true, it hinders their efforts to secure outside creased in magnitude. Second, some utilities aid based on population. It also would have have located mine-mouth powerplants near the effect of lowering estimated growth rates coal mines. Powerplant construction crews are (because the base population is higher than the from 5 to 10 times larger than operating crews. number used in these calculations). Some communities have had trouble adjusting to the short-term impacts of these crews, (e. g., Population growth that exceeds a rate of 5 Rock Springs, Colstrip, Huntington, Craig, and to 10 percent annually is considered to gener- Gillette) and if coal development continues, so ate significant socioeconomic consequences. will many of their problems. Only eight coun- Table 52 shows that 11 counties in the West ties will experience both new coal production will achieve growth rates exceeding 5 percent and operational powerplants after 1981 (table per year in the Keystone case. Four of these 53), according to these forecasts. When in- counties will have growth rates exceeding 10 dividual plant situations are investigated, percent per year over the 10-year period. (High- these eight can be pruned because of time- growth county data are in bold face. ) Under phased unit construction (which maintains a the Keystone assumptions, the Utah counties semipermanent construction work force in a of Emery and Kane, where underground mines general area) and time lags between startup are planned, are the most impacted, with and operation. Mercer County, N. Oak., and growth rates of 18 and 19 percent, respective- Emery County, Utah, have already been iden- ly. Coal development in Campbell County, tified in both cases as high-growth areas. The Wyo., yields a population growth rate of near- powerplant construction variable adds several ly 14 percent per year. (It is assumed that Texas counties to the list of impacted com- population impacts of coal development are munities. However, since all of these Texas felt only in the county in which development counties have relatively high populations occurs. When miners do not reside in the coun- (ranging from 12,000 to 30,000) and are within ty where they work, this assumption needs ad- 100 miles of Dallas or Houston, local popula- justment.) tion growth will probably be spread out and absorbed without great clifficulty. When the OTA low-production case is used, only six western counties appear to be vuIner- In sum, this analysis shows that from 6 to 11 able to rapid growth. Four of these counties — western counties will show rapid population Carbon, Emery, Kane, and Sevier– are in Utah. growth from coal development in 1977-86. The The others—Campbell and Mercer —are in population effects will stem from coal mine Wyoming and North Dakota respectively. The construction and operation rather than from OTA case removes both Colorado counties powerplant development. I n both the Keystone and the three Montana counties from the and OTA cases, four counties in Utah are iden- highly vulnerable list. tified. Mercer County, N. Dak., and Campbell 312 ● The Direct Use of Coa/

Table 53.—Western Counties With Both New Coal and benefits of Western coal production, but Production and Powerplants to Come Online After does not make generalizations about when 1981 costs equal benefits, when costs exceed bene- State County Online date fits, and when they are less.

North Dakota ...... Mercer 1981, 1984 Texas ...... Freestone 1983, 1984 Private Sector: Costs and Benefits Grimes 1982 Henderson 1982 It is possible to make very rough calcula- Morris 1980, 1982 tions of some of the private-sector, economic Robertson 1984, 1985 impacts of projected coal development. Titus 1982 Utah ...... Emery 1978, 1980, 1983, 1985 Annual coal-related wage income and benefits are the principal economic gain from West- ern coal development in local communities. County, Wyo., are also singled out in both Assuming that each new miner will earn cases. Most of these counties have small popu- $25,000 annually ($100 per day times 250 work lations, the range being between 2,383 on the days), the 34,000 to 42,000 additional miners in Crow Reservation to 19,100 in Carbon County, 1985 will earn between $850 million and $1 bil- Utah. The four Utah counties and Campbell lion per year in pretax income. To this must be County, Wyo., will experience the fastest rates added the wages paid to workers involved in of growth. Several dozen western towns are secondary coal employment. also Iikely to grow rapidly from coal development even though their respective counties do Coal development does not bring large in- not appear in the high-growth Iists. puts of local capital investment or large profit returns to coal areas, Almost all of the major Boomtown Effects mines in the West are being opened by non- How any particular community is affected local investors, usually utilities, energy com- by rapid coal development depends on the size panies, or conglomerates. Apart from costs of of the mining enterprise, mining method, size acquiring the minable coal resources, the ma- and quality of existing public and private in- jor capital expense involved in opening a new f restructures, rapidity of development, tax mine is equipment, almost all of which comes structure, and ratio of transient to permanent from nonlocal manufacturers. Once a mine is employees among other variables. The dura- operating, net income is either reinvested or tion of coal impacts is likely to run for 10 to 30 distributed as profits to stockholders. Little of years at one or another level of intensity. the mine’s economic surplus can be used by local banks or local entrepreneurs and resi- Coal impacts can be grouped according to dents. The surplus that is likely to remain in broad subject classifications (economic, politi- local communities is hard to quantify, but is cal, and social). Both public and private sec- likely to be insignificant in most cases. How- tors are affected. But it is impossible for two ever, where a mine-mouth generating plant is reasons to calculate a definitive, cost-benefit part of the coal development, the local return bottom line. First, all of the costs and benefits increases even though the profit distribution are not translatable into dollars. Second, costs pattern is not likely to change. and benefits are distributed unevenly among private-sector groups (workers, owners, and Coal development will affect existing busi- others) and public-sector interests (local com- ness sectors in western communities. Many munities, national energy needs, etc. ) There- will be able to expand their sales and profits. fore, although policy makers can become But for some it will be a mixed blessing, and aware of the implications of various coal poli- for others no blessing at all. Noncoal wage in- cies, there is no neat formula for weighing one come does not rise as quickly as miners’ wage kind of cost against another kind of benefit. rates. Local businesses will have difficulty re- The ensuing discussion talks about the costs taining current employees and recruiting new Ch. V/— Workplace and Community Implications 313 ones, Secondly, local entrepreneurs may want housing loans, as higher interest rates can be to expand their business, but local loan capital charged on personal and consumer loans. Con- may be tight. There is also the prospect of in- sequently, housing costs skyrocket. In western creased competition from new business started boomtowns the average $50,000 price of a new by local or, more likely, out-of-State entrepre- home is about 30 percent higher than the na- neurs or national chains. Some local business tional average for nonmetropolitan areas. may be wiped out. Apartment rents are nearly double the median national figure of $120 per month. With the In the past, the short-term costs of rapid housing supply inadequate and costly, new coal development to the private sector have residents are forced into mobile homes. Little been high. The experience of Rock Springs, property tax revenue is generated by these Wyo., is a dramatic example. When coal devel- units in some States because they are bought opment increased the population of Rock and owned as personal rather than real prop- Springs rapidly, its quality of life deterior- erty. State legislatures can remedy this. The ated.9J The preboom ratio of two service jobs shortage and high price of housing are also to every one primary job declined leaving local caused by the natural reluctance of local business without sufficient personnel to main- builders to risk major investment on the basis tain services. Workforce turnover was high. of promised coal expansion; the West has seen Mining and construction caused inflation, its share of booms burst. bringing financial hardships to noncoal em- The uncertainty of demand for western ployees and residents on fixed incomes. After boomtown housing is a major part of the hous- the initial disruption the ratio of local service ing supply problem. Lenders, housing devel- jobs to primary jobs tended to normalize as opers, and builders are reluctant to rely on the they did in Gillette. Coal-induced inflation fre- announced schedules for new energy projects. quently pinches the wallets of noncoal em- 94 They fear being stuck with unsold homes if ployees and fixed-income residents. High projects are delayed or canceled. The private, turnover rates among both coal and noncoal primary mortgage market is composed princi- workers is often seen. People leave the com- pally of savings and loan associations and the munity, although a net increase may be regis- secondary mortgage market is insurance com- tered in the census. Much social stress occurs. panies and other investors. These capital In the Rock Springs case, the costs of boom- lenders may be unwilling to back investments Iike coal development to many new miners that are not in low-risk categories. and noncoal local residents may have outweighed the benefits. The reluctance of local lenders is attributable partly to the funds available. Local The most significant private-sector problem financial markets in the West are unable to ac- in boomtowns is housing. UsualIy, there are commodate the demand for new mortgages in few local builders capable of undertaking rapidly growing smalI communities. Outside fi- large developments. Often local banks cannot nancing is constrained by the absence of finan- finance major housing projects. Many small cial relationships with out-of-State institutions banks are reluctant to tie up their capital in and the inability of local financial institutions “John S. Gilmore and Mary K Duff, Boom Town to accumulate large enough blocks of mort- Growth Management: Rock Springs-Green River, Wyo.- gages to sell in secondary mortgage markets. ming (Boulder Westvlew Press, 1975) These shortcomings of the mortgage market in “4 Interviews with bankers in northwestern Colorado the rural West may become a greater problem found that fixed-income residents were borrowing to meet Increased Iiving costs by using the appreciating in the future. Fm HA recently announced guide- value of their homes as CO I lateral Such short-term loans lines for providing assistance to energy-im- are rolled over each year to repay previous loans and ob- pacted areas where energy employment in- tain additional money for rising living expenses This pat- creases 8 percent or more in a year, a housing tern, the bankers predicted, will certainly end in econom- shortage exists and local and State financial ic disaster for some of those Involved Don Kash, Mike Devlne, and Allyn Borsz, Impacts on Western Coa/-Pro- resources are inadequate. Only $20 million is ducing Communities, OTA contractor report, April 1978 available under this program which applies to both coal and uranium production, processing, available mobile home. By living closer to the and transportation. mine than they would have in Gillette, the only town in Campbell County, workers will com- The potential demand for new homes is mute shorter distances. Wright will cost ARCO somewhat more certain in larger towns, such about $18 milIion. as Gillette and Farmington, where large numbers of energy executives or administrative The company-town approach is one alterna- personnel live. However, even in these larger tive to chronic housing shortages. But the cost towns the temporary nature of powerplant of building and operating such towns discour- construction and uncertainty about future ages most companies from trying it. More com- energy development result in a fear of over- mon is a catch-as-catch-can approach to hous- building. This is particularly true of towns that ing, Coal developers will offer some assistance have had previous booms collapse. to towns or to their employees, but principal Several coal developers have provided hous- responsibility is left to local authorities and in- ing for construction worker and mineworker dividuals. Several examples illustrate the families. Much of this has been planned mixed record of western towns in coping with mobile-home developments. Arco is building a housing needs. planned town (Wright, W. Va. ) primarily for employees of its Black Thunder MineWright’s In Emery County, Utah, housing is desper- single-family housing is expensive — in the ately needed. One cause of the shortage is a $50,000-and-up range— and most miners seem deficient public infrastructure, Without water to be opting for the cheaper, more readily and sewer hookups, housing of any kind can- Ch. V/—Workplace and Community Implications ● 315

not be built. Another problem has been Emery Housing on Indian reservations raises sever- County’s lack of licensed contractors. Inflated al problems that are different from those dis- costs, housing shortage, and the limited supply cussed above. A boomtown syndrome proba- of contractors has significantly changed the bly won’t occur on most reservations, although composition of the housing inventory. In 1977 the social stress created may be similar. The mobile homes were 41 percent of Emery Coun- number of new miners that will be involved in ty’s housing supply. In Huntington, where in Indian coal production will not be more than 1970 there were only two mobile homes, 375 several thousand. Most of these will be Indians were counted in 1976. The Southeastern Utah already living on reservation land if the tribes Association of Governments sees mobile succeed in making the coal companies give hir- homes as the only housing choice available to ing preference to local Indians. The housing new households. A somewhat different pattern problem on the reservations is less one of is found in Gillette, Wyo., where there were no shortage and more one of adequacy. The seri- large-scale builders or developers before the ous deficiencies in Indian housing are well- coal boom. Market uncertainties and the known –to Indians, at least. Table 54 presents possibility of environmental litigation over a snapshot summary of Indian housing qual- Federal coal leasing presented an unattractive ity— including the Navajo Reservation — where level of risk for large-scale land developers and housing needs are most severe, creditors. These initial problems have been alleviated. Many developers now see a single- I n sum, the distribution of private costs and family housing market in Gillette. The risks in- benefits of increasing Western coal production volved in large subdivisions have been largely vary. Coal workers and mineowners will obvi- absorbed by the coal companies. In some in- ously benefit from new employment opportu- stances, the companies have acted as land de- nities. Coal-related services will establish velopers; in others they have either guaranteed themselves in regional centers, and locally the sale of lots and/or houses or guaranteed owned commercial enterprise may expand. the credit of a housing subdivider. Yet single- Spendable income in local communities will family housing production has not increased increase rapidly. The material quality of life substantially. The primary barriers are the will rise for some. delays and high costs of producing new units of acceptable quality and the relationship bet- On the other hand, these private benefits are ween the cost of producing the types of dwell- not distributed evenly. Local capital liquidity ings desired by the newcomers and their abiIity is unlikely to increase significantly, apart from to pay for the desired units. ’s Many residents the savings deposited by wage earners. Local are forced to Iive in mobiIe homes, which have businessmen may not be able to expand or become the fastest-growing housing alter- modernize their services, and national chains native in Campbell County. Sixty percent of may take over their markets. Opportunity the increase in housing since 1970 has been in costs may be high in Western coal develop- mobile homes. Currently 67 percent of the ment. Ranching, farming, and tourism may be housing in the county outside the Gillette city curtailed in coal areas. Local inflation penal- 9 Iimits is mobile homes. ’ izes those on fixed incomes and those whose 951n a recent Wyoming survey, 67 percent of the re- wages are independent of the coal business. spondents preferred a single-famiIy unit and 56 percent Data are not available comparing boomtown Indicated both the willingness and ability to purchase inflation rates with national or regional rates, one, but only 45 percent had achieved the goal of owning a single-famiIy unlt (DaIe Pernula, 1977 Citizen Policy although anecdotal evidence suggests that the Survey (GlltetteCampbell County Department of PIan- former is abnormally high. Coal profits will not nlng and Development, 1977) ) generally be distributed locally. Much invest- “Keith D Moore and Carrie Loom Is, Housing Market ment will not be spent locally, either. Dynamics in Campbell County, Wyoming and the Im- pacts of the Proposed Mobi/-Consol Pronghorn Mine, a Denver Research Institute report prepared for the U S One important and relatively unexplored Geological Survey, 1977 issue is the dolIar cost of impact internaliza- 316 ● The Direct Use of Coal

Table 54.—Housing Conditions of Indians in it is on long-term utility contracts, wilI smooth Three Western Regional BIA Areas—1973 out the boom-bust cycle. However, it is likely that a considerable lag will occur in the BIA area office perceptions of local residents as they weigh Billingsa Navajo Albuquerque this boom against those of the past. Their caution is justifiable because economic diver- Total number of families ...... 6,071 23,801 8,349 sification and planning for the postcoal years Number of standard are not occurring. A long boom followed by an units ...... 3,335 3,126 3,180 even longer bust may be in store. In any case, Number of substandard units 2,269 19,242 2,841 boom growth is the least preferable path of Families doubled up 467 1,433 2,328 economic development. Slower and more Total need as steady growth is less disruptive and more bene- percent of families 45.1 86.9 61.9 New units needed . . . . 1,861 7,324 3,332 ficial to more people over a longer period of Rehabilitations time. However, because coal projects are usu- needed ...... 875 13,351 1,837 ally matters of corporate decision making, many western communities may have no choice. If this perception is shared by westerners it would not be surprising to observe a tions on the dollar cost of producing Western political backlash against current coal devel- coal. Coal companies in the West generally of- opment by citizens who see their long-term infer extremely high wages to attract labor. To terests depreciated by rapid coal develop- the degree that rapid coal expansion decreases ments. quality of life, operators may be forced either to offer increased monetary incentives to re- Public Infrastructures: Costs and Benefits tain workers or to become directly involved in The balance between public costs and bene- the costly business of providing community fits of Western coal development changes over services. 97 If coal operators absorb the capital time. In the 5 years needed for a mine to be costs of, for example, a water and sewage sys- developed, public services in small communi- tem, their product prices will rise. It is debat- ties will be strained by the rapid increase in able whether price-escalator provisions in utili- population. Demand for more and better serv- ty contracts can be invoked. If the labor force ices will usualIy exceed a community’s tax perceives coal development as the source of revenue and ability to deliver services. Where quality-of-life decline, workers may seek county or State tax revenue increases but unionization and even higher monetary re- heavily impacted towns can’t get a fair share, wards or community development clauses in the financial situation is aggravated. Antitax collective bargaining. State and local govern- feeling, expressed in Proposition 13-type movements may impose taxes on coal developers to ments, further binds local governments. finance needed services. To the degree that coal-related public costs are paid by tax reve- Coal development also strains local physical nues on Western coal, higher coal taxes may infrastructures — roads and bridges, water sup- lower company profits and raise coal prices. plies and purification plants, sewage facilities, schools, and fire and police protection. Exist- Western communities have had much expe- ing service systems are likely to be severely rience coping with the short-term stresses cre- stretched and weakened. Individual pieces of ated by booms and the long-term depressions these systems may collapse entirely. Short- left by the “busts.” From today’s perspective, term public costs may also be expressed in it appears that Western coal growth, based as terms of community destabilization, cultural strain, social disorganization, and a general 97 Richard Nehring and Benjamin Zycher, Coa/ Deve/- perception of decline in the quality of life. oprnent and Governrnent Regulation in the Northern Great Plains (Santa Monica, Cal if RAND Corp , 1976), p As the mine reaches full capacity some pub- 127 lic costs will become less serious. Tax revenue Ch. VI— Workplace and Community Implications ● 317 wiII generalIy increase; services shouId expand. a dollar-for-dollar basis and does not begin at The pace of growth will slow. The rate at which all until coal is actually sold. any given community begins to normalize de- Aside from education, public services that mand for services with its ability to deliver usually need expansion in boomtowns include them depends on a number of local factors. fire and police protection, roads, water and The most important of these are: the degree of sewage treatment, solid-waste collection and predevelopment need, tax policy, rate of disposal, health-care facilities and services, development, priorities and attitudes of the detention facilities, county and municipal coal producer, reliability of demand for local facilities, and recreation. For each new resi- coal, skilI of local officials, extent of economic dent, between $1,500 to $2,300 (1975 dollars) is diversification, and ability of State and county estimated to be required for just the capital governments to adapt their policies to meet costs of these facilities. Of this amount, the needs of localities. In some communities roughly 75 percent is devoted to water and front-end problems, such as lack of revenue, sewage treatment. A hypothetical town of may extend for years. The deficit may never be 2,500 persons with an annual municipal budget eliminated with available resources. These of $20,000 would require between $1.5 milIion problems will be solved in some communities, and $2.3 million capital investment if its popu- to be sure, but western history shows a spec- lation were to increase 40 percent (1 ,000 per- trum of success and failure concerning the sons). Clearly, the front-end costs are huge in ability of communities to assemble public comparison to local tax revenues and bonding capital and meet boomtown needs. capacity.

Western mineral development also starkly Existing transportation facilities may be sud- portrays the common “back-end” problem of denly overloaded when coal mining grows fast. resource depletion and community decay. Highways break down. Coal haulage disrupts When mines play out or market conditions small towns. Unit trains bisect communities. A force closure, local communities are “busted.” recent Colorado Department of Highways 98 When communities were tied to a single com- study, estimated that more than $250 million pany or industry in the past, back-end prob- would be required for primary and secondary lems were often disastrous. Since western highway construction by 1985. In six energy- mines have operational Iives of 20 to 60 years, impacted counties, more than four times the planning and diversified development of West- annual level of construction for primary and ern coal areas may be needed to avoid the secondary highways in all 63 counties of Col- worst public cost of earlier mineral develop- orado, is needed. It has also been estimated ment: ghost towns. that at least 30 new grade separations are required to maintain intracommunity access in Most impacted western communities are communities suddenly beset by unit trains. now struggling to cope with the front-end prob- Current funding in Colorado provides for one lems of coal development. Such communities or two new grade separations per year for all face the necessity of either expanding existing purposes. public services or building them from scratch. Boomtown problems are aggravated where In either case, a period of 2 to 5 years exists the coal project creates revenues for one juris- before those services appear. Most western diction while the social impacts of the new communities do not have adequate funds in mine occur in another. jurisdictional mis- the early stages of coal development to plan matches are one of the most intractable prob- their growth and seek Federal assistance. lems. The most common mismatch occurs Where coal-processing or electric-generating when coal mines or powerplants are located plants are being constructed, front-end finan- outside a town’s Iimits. The county collects the cial problems are magnified by the overnight tax dollars while the municipality struggles to appearance of the temporary plant-construction crew. State-administered severance-tax in- ‘ 8 Briefing to commissioners by staff of Colorado come does not return to local communities on Highway Dept 318 The Direct Use of Coa/ meet the needs of new miners. But the jurisdic- provide adequate public services following ini- tional mismatches within a county are more tial coal development. easily handled than those occurring across county or State Iines. There are no examples of The net public gain or loss from coal growth where this inequity has been addressed except also depends on how much system deficit is through usually meager State impact assist- present when development begins, the extent ance programs. of the overload, and the level of services perceived necessary to meet the perceived need. The evolving balance between public bene- Communities that are created from scratch fits and public costs depends largely on local have extremely high startup costs and may and State coal tax policies. The level and equi- need subsidies for many years. But they may ty of public revenues depend on the mix of be ultimately more successful in providing taxes imposed, the level of each tax, and the services and achieving a net gain The more efficiency of the collection system. These mat- common western pattern appears to be coal- ters often involve two or three levels of govern- growth overloads of existing systems, which ment and are always matters of political de- may already be below par. I n such cases, arith- bate. Local authorities rarely impose a cor- metic gains in population may require geo- porate income tax on local business. Property metric increases and investments in services. tax usually generates most local revenue. This (For example, a 50-percent increase in popu- burden often falls more heavily on residential lation may require a doubling of the local and agricultural property owners than on min- police budget.) The greater the existing deficit eral-resource owners. Leasers of publicly and the greater the development impacts, it is owned coal pay no property tax although they more probable that there will be a small net pay a tax on leasehold value based on produc- public gain. Conversely, the smaller the exist- tion. Some counties impose specific taxes on ing service deficit and the smalIer the develop- coal. For example, most coal counties in Illi- ment impact, the more probable that public nois have imposed a l-percent sales tax at the benefits will be greater. The level of public mine mouth; local and county taxes in Mon- services differs from town to town. A few ex- tana average about 5 percent; Wyoming coun- amples suggest the range of experience. ties average about 6.3-percent ad valorem tax based on production; counties in other West- Craig, Colo., is a typical rural community on ern States impose no coal-specific taxes. States Colorado’s western slope. Preboom services differ significantly in their coal taxation provided by the community cost $208 per cap- schemes. These Western States impose coal ita and were considered adequate by most resi- taxes: Wyoming (10.1 percent in 1978); North dents. The 1979 estimated per capita expend- Dakota (65 cents/ton with an inflation escala- iture is $344 (in constant 1973 dollars). With tor); New Mexico (38 cents/ton steam coal and coal development the water system was ex- 18 cents/ton metallurgical coal); Montana (30 panded to serve a population of 15,000 but is percent on the value of the coal at the mine almost at capacity with 11,000. The sewer sys- mouth); Colorado (30 cents/ton for deep-mined tem will be expanded to a 20,000-population coal and 60 cents/ton surface-mined coal) .99 capacity. Craig was not able to finance these Utah, South Dakota, Texas, and Oklahoma capital projects totally with local revenue. have no coal taxes. Western States also use dif- Most of the money came from Federal and ferent formulas to redistribute State-collected State sources, along with some industry contri- severance taxes to counties of origin. State and butions. The city has not yet resolved the issue local tax policies do not seem to be a criteria of how to pay for a new reservoir (estimated to for mine siting. Depending on the level of pre- cost $10 mill ion). development need in each community, future tax income may or may not be sufficient to The public infrastructure in Emery County, Utah, communities was not ready to absorb the coal-based growth that came. In some “Coal Week, Apr 17 and 24,1978 cases, services were not even adequate for the Ch. VI——— Workplace and Community Implications ● 319 existing population. Many of the small towns categories of assistance provided through Fed- in the county were not required by the State to eral programs. The local school system’s abil- prepare annual budgets. Those that did often ity to manage coal-generated enrolIment de- had budgets only l-page long. Little planning pends on the preboom use of existing facilities, or forecasting of capital expenditures oc- the rate of expansion and size of the new stu- curred. A 1978 report by the Southeastern As- dent population, and the financial ability of sociation of Utah Governments said that al- the community to provide additional facilities most every town in the county needs a new and services. municipal building. Many need to upgrade School costs are usually the largest portion their water and sewer facilities; others need of local public expenditures. Per capita ex- sanitary IandfiII operations. Every town is in penditures for education in the West are need of a fire station and new equipment, and already high. For example, the capital costs for many need a massive street improvement pro- each additional student in Gillette, Wyo., are gram. 00 projected to be approximately $2,500. An in- Gillette, Wyo., had energy-related growth in crease of 500 in the school population would the oil and gas boom of the 1960’s and the coal amount to $1.25 million more in capita I ex- development of the 1970’s. Even with this penditures. Operating expenditures are about growth, the city’s tax base has fallen further $2,000 per student, so that 500 new students and further behind the county’s, Gillette has would require an additional yearly operating not always had the capital needed to improve expenditure of $1 million. 103 its public services. I n the 1960’s GilIette’s The long-term financial demands for educa- bonds were issued piecemeal, with no provi- tion in Western coal communities are substan- sion for long-range planning of financial strat- tial. Whether this situation poses serious finan- egies. The result was poor use of the city’s ex- cial problems will be determined by how soon isting tax base in creating bonding capacity. the school-age population begins to expand For a time, this severely limited what the city rapidly. Where school-age populations do not could do. However, through the efforts of a grow until coal facilities are operating, school bond counsel and a new professional town districts may have surplus revenue. An exam- manager, these debts were largely refinanced ple of this favorable situation is found in Rose- in 1977101 bud County, Mont., where school districts are Gillette and Campbell County have been expected to enjoy substantial financial surplus fortunate in receiving assistance from industry at current tax rates. However, this is the excep- in the form of in-kind contributions such as tion. loans of equipment to clean streets or help Typically, the increase in school enrollment with digging the foundation for the hospital. from coal-related work occurs before any in- The members of the industrial subcommittee crease in ad valorem tax receipts. This may of the chamber of commerce have also con- cause operating expenditures per pupil to tributed money that has been used for studies decrease. However, most States “guarantee” and plans for long-term city projects. 102 that these expenditures wilI not falI below a set Education amount fixed by the legislature. Therefore, the operating portion of the budget is not the main Public education is usually financed by cause for concern; rather, it is capital expend- State and county governments, with special itures. For example, if additional permanent 100 Morrograph Series: Local Government (Price, Utah: classrooms are to be built or temporary ones Southeastern Association of Utah Governments and De- purchased, the existing population pays, not velopment District, 1978) the newcomers or the coal companies. These 101 From 1976 and 1977 Interviews with Mike Enzl, Mayor of Gillette and a 1977 Interview with Flip McCon- initial problems may be corrected if mines and naughey, City Manager ‘“’From 1978 Interview with Dave Bell, Director, GiI- Iette Chamber of Commerce 320 ● The Direct Use of Coal

powerplants are placed on the tax rolls and no ing less personal and more bureaucratic, hence jurisdictional mismatches are involved. less accountable. The destabilizing effects of rapid economic growth may be played out in In Moffat County, Colo., for example, school school disruptions and student stress. enrollment increased 29 percent from 1976-78. In the same period assessed property valuation Boomtown educational needs have both a increased 144 percent. While these statistics quantitative and qualitative dimension. Quan- may suggest optimism, the fact is that the titatively, the problem is finding capital and county’s schools are overcrowded. Increases in personnel to sustain and expand existing facil- enrollment have put the total student body at ities and programs. Qualitatively, the problem about 300 students over capacity. 1 n October is matching perceptions of preboom and post- 1978, a $9 million bond issue was finally boom reality with the changing nature of local passed (after having failed twice) for construc- education. The concern of the community tion of a new high school. I n addition to over- about the “quality” of their boomtime educa- crowded conditions, the school district lost 35 tion will vary according to the precise mix of teachers in the summer of 1978 for a variety of short-term adaptation mechanisms and longer reasons. A number went to work in higher pay- term expansion of services that authorities are ing coal projects. Although the positions were able to orchestrate. Both newcomers and old- filled, there were problems in attracting new timers may continue to be dissatisfied with teachers, mainly owing to the high cost of liv- their educational system for different reasons. ing in Craig. Both groups may have legitimate grievances. It may be unlikely that quantitative improve- Much of the locally perceived impact on ment in the local educational system will pro- education involves subjective judgments duce a one-for-one, stepped increase in the about what constitutes good education. community’s perception that education has “Quality” education is an intuitively mean- improved. ingful concept to most parents, but it is hard to quantify. Different communities may have dif- Health Care ferent collective perceptions as to what “it” is and whether their children are currently get- Both the public and private sectors are in- ting “it.” To the difficult question of educa- volved in health care delivery and financing, tional quality must be added the question of Coal development will enlarge the health- who pays for it. Long-time residents sometimes treatment needs of local communities in vari- object to higher property taxes and more in- ous ways: more people need more care; more debtedness to pay for the education of the people need a wider range of health care; coal children of “newcomers. ” Moreover, coal de- miners have special health needs. velopment pressures may inflame residents Health services, which are often inadequate over what is perceived as a lessening of educa- in rural communities before development tional quality. This may diminish over time as starts, are among the most difficult to main- new facilities are built. But the absence of tain in boomtowns. Medical needs typically ex- front-end monies and the high costs of perma- pand at least as rapidly as population, and nent school facilities make the process of faster when a large proportion of the new resi- resolving this problem difficult. Adaption to dents are young children. If health services are boom conditions may take the form of increas- limited, a smaller proportion of children may ing student-teacher ratios, shifting to half-day be immunized against preventable diseases. sessions and installation of temporary school Fewer screening tests may occur. Inability to trailers. This is likely to keep the issue of coal obtain early treatment may permit disease to and education alive indefinitely. Other prob- become more serious. lems may be perceived. New teachers will have to be hired, and some, at least, may have non- The health care delivery system in western local educational values and methods. The communities is limited and, by national stand- education system may be perceived as becom- ards, less than adequate. One eight-State study Ch. VI— Workplace and Community Implications ● 321

of 185 potentialIy impacted western towns public and private prevention systems in West- found that fewer than half (87) had a resident ern coal towns are haphazard and not well syn- doctor and about one-third (60) had a hospi- chronized. tal. 104 Generally, the doctor/popuIation ratio is Coal miners have special health needs stem- much lower in western towns than in the coun- ming from their occupation. Although western try overall. Like other rural areas, the West has surf ace mining is statistically safer and difficulty attracting and holding physicians. healthier overall than underground mining, Apart from the availability of physicians and surface miners stilI experience a significant health care extenders, health care norms de- level of industrial injury and disease, Respira- pend on the quality of care provided and the tory and pulmonary disease, hearing loss, and rate of use, both of which depend to a greater stress are found more frequently in miners or lesser part on the individual’s ability to pay. than in the population generally, Coal’s acci- It is easy to understand the frustration coal dent rate requires adequate emergency medi- miners and others feel when “good” health cal services at the mines and fast transpor- care is unavailable even though adequate in- tation to treatment centers. Provision of emer- surance plans cover them. gency services— including the training of Recent survey research in Sweetwater Coun- miners as emergency medical technicians — is ty, Wyo,, sheds Iight on the importance of ade- not required under Federal law or by most quate health services. Fully 82 percent of the States. Some coal operators provide such train- 157 newcomers interviewed ranked medical ing and service; others don’t. Specialists in and mental health services in their top five miners’ occupational health problems are not community priorities. Sixty percent of the sam- found in the newer, Western coal development ple said they would leave town if these serv- areas. Some practice in the older coal fields of ices were not improved. These opinions were Utah and Colorado, where UMWA and the acted on: “The labor turnover rate was running UMWA Fund established clinics after 1950. up to 150 percent as mining employees were Other health-related services are required in leaving the area because of dissatisfaction stressful boom conditions, including treatment with the quality of Iife. ” 105 and counseling for alcoholism, child abuse, IllIness-prevention systems are even less de- marital strain, juvenile delinquency, and men- veloped than treatment systems. Prevention tal health The rapid infusion of newcomers programs are provided by both the public and into welI-established communities creates private sectors. In small, rural communities, stressful situations among natives and new- public health services are minimal, where they comers alike. The smaller the community, the exist at al 1. Immunizations, water and sewage less likely that such services are available. treatment, prenatal and postnatal care, and However, high absenteeism and turnover rates nutrition education are not well developed. in Western coal towns suggest that services are Adequate systems are even less likely to be needed to treat the symptoms and conse- found on many Indian reservations. Much pre- quences of growth-related stress. ventive care depends on an individual’s awareness of its importance and his ability to pay. Absence of prevention measures often results Political Impacts in higher treatment costs, some of which are borne by public agencies. Generally, the The political impacts of Western coal development may be extensive, both from the perspective of boomtown residents and in terms 104Regional Profile: Energy-Impacted Cornmunities of the politics of further coal expansion. (Lakewood, Colo Federal Energy Administration, Socio- economic Program Data Collection Office, 1 977) Rapid population growth often generates ‘(’’John S Gllmore, et al , Analysis of Financing Prob- conflict between antigrowth and progrowth lems in Coa/ and Oil Shale Boom Towns (Denver Colo University of Denver Research Instltute and Bickert,, factions, newcomers and oldtimers, labor and Browne, Coddington & Assoc., Inc., 1976), p 72 management, environmentalists and prodevel- 322 ● The Direct Use of Coa/ opment factions, high-wage jobholders and disasters. These conditions do not exist in fixed-income or low-wage persons, transients Western coal communities. Hence, most Fed- and permanents, and coal-related business and eral impact assistance funds are unavailable to local business. These conflicts may benefit Western coal towns. local communities in the long run if they mo- Western rural county governments are large- bilize political interest constructively and cre- ly dominated by farmer/rancher interests. ate pressure for better public services. Yet County commissioners deal with few major more public services almost always involve conflict-producing issues. Those they do han- more Government regulation, which may itself dle usually concern the level and distribution become a political issue. Political cleavages of taxes and public expenditures. Because of resulting from coal development may shatter the western populist tradition and the preva- community life. In company towns, coal devel- lent skepticism of government in general, rural opers may dominate local politics, for better officials tend to be ambivalent toward land or worse. I n other places, two-party competi- use planning and zoning. Their ranching and tion may result from the introduction of new landowning constituents are strongly opposed interest groups. One-party systems may be fic- to any intervention in their control of their tionalized. Tightly run political machines may 106 property. develop. The conflict that change produces may interact with economic and social condi- In Gillette, Wyo., it was not until 1976 that tions to produce widespread community dis- the Gillette/Campbell County planning office integration and dissatisfaction. But, on the really became active when the need to handle other hand, growth can create conditions boom conditions became obvious. When plan- where political cooperation is required to meet ning and zoning codes were established, a 3- new demands. by 5-mile box was drawn around Gillette. The planning department’s control is much greater Coal-impacted western communities vary within this area than in the rest of the county. tremendously with respect to attitudes toward Outside the box, the planning commission can politics and coal development, so that regional only make recommendations to the county generalizations are especially risky. Nonethe- commissioners, who need not (and do not less, it is reasonable to assume that some com- always) follow them. 107 munities will eventually group themselves into two polarized alliances: progrowth and less Coal growth is apt to cause drastic changes growth. As the rate and scope of development in existing political structures. Whether these increase, polarization is probably more likely changes are seen as good or bad depends on to occur and be irreconcilable. But exceptions the observer’s point of view. Eventually, ranch- will be found. Some Mormons of Utah, for ex- ing interests may lose their role as the domi- ample, favor coal development without reser- nant political force in local politics. New- vation. This prodevelopment view comes from comers may share power with older residents, the desire for economic development and or they may supplant them entirely. Newcom- from a set of socioreligious values arising from ers are likely to bring with them different the Mormon experience. — ‘“’’’ Our findings reveal that a significant feature of the Although procoal factions among Indians study area is Its traditional rural abhorrence of planning and Mormons may favor procoal Federal pol- The area’s residents consistently and strongly resist the Idea of telling people what they can and cannot do icy, they may also oppose the Federal regula- with/on their land Almost 60 percent state that no one tion that often accompanies such policies. but the owner should have any say about how privately Western hostility toward Federal policy may owned resources are used. ” Community Service Pro- be intensified by the lack of applicability of gram, University of Montana, A Study of Social Impact of Federal aid to western boomtowns. Most rele- Coa/ Development in the Decker-/Birney Ash/and Area (Helena, Mont,: Montana Energy Advisory Council, Of- vant Federal programs make funds available to fice of the Lieutenant Governor, 1975), p. 20 States and local governments only to remedy ‘“’ Based on a 1978 interview with Dave Ebertz, former problems of economic stagnation or natural part-time City Manager, Gillette Ch. V/— Workplace and Community Implications ● 323 values and expectations that may be at odds In response, communities usually expand with those of the existing residents. Political their official control mechanisms to compen- change in coal communities is driven by the in- sate for the loosening of informal social con- flux of new residents. One study of southeast- trols. Police forces are enlarged. Mental health ern Montana found that newcomers and old- clinics either increase in number or add to timers tend to stay apart. For the most part, their caseloads. The emergency room of the newcomers have not been accepted into estab- hospital and social service agencies are busier lished social structures. than before.

Often, changes in boomtown political cul- Craig, Colo., provides a good example of ture will not come easily. Conflicts may occur what can happen to a community impacted by between newcomers and oldtimers. There may a large construction work force. Rapid popula- be more urban vs. rural strain, as well as an in- tion growth (a 47-percent increase between crease in industry vs. environment issues. 1973-76) coincided with an increase in negative There may be more concern over and need for social behavior, as suggested by the follow- Federal intervention as urbanization takes ing: 09 place. Unions r-nay become more of an issue Percent increase Problem area 1973-76 and possibly a political force. Substance abuse 623 It is difficult to predict whether such Family disturbance 352 Self-respected emotional changes wilI be beneficial to the community in disorder 45 the long run. Many preboom residents will not Child abuse/negiect 130 favor them. Conflict may not be viewed favor- Child behavior problems 1,000 ably by either oldtimer or newcomer. Yet as Crimes against property 222 900 assimilation and adaptation occur, conflicts Crimes against persons may be resolved. While negative social impacts are frequently reported, they represent only part of the pic- Social Impacts ture. The other part involves many examples of citizens organizing to provide social, recrea- In preboom western towns, informal social tional, and cultural activities. Many residents controls shape community social structure. 08 of coal-impacted communities speak with Doors are rarely locked because everyone pride and satisfaction of the informal initia- knows everyone else. Family violence occurs tives they have taken to improve the quality of less often. Teenage drug usage may not be a life in their communities. Mayor Enzi of Gil- serious problem because of stable and familiar lette reflects this pride. “Gillette is virtually in social norms and the community’s isolation. the process of building a new town, and there Alcoholism is considered more an individual is room for everyone’s participation. In Gil- than a community problem. This kind of social lette, the only newcomer is the spectator who structure is vulnerable in boomtowns. Some of is unwiIIing to pitch in. ” the changes that occur are not beneficial. High-growth communities often have in- The farmer/rancher interests also have am- creased crime and mental health problems. bivalent attitudes toward coal. Development juvenile delinquency grows. Divorce and fami- may make marginal farmland valuable for ly disruptions are more common. future housing sites, thus giving its owners the opportunity to sell at a great profit. The farm- ‘O ’ Sociologist William Freudenberg has concluded er/rancher who does not want to selI may work that the primary reason for stablllty in small communities IS because there IS a kind of “social buffering” at a his place part time and seek full-time employ- very localized small group/primary acquaintance level, ment in the mines. On the other hand, ranchers which provides a source of continuity for feellngs of per- 109 Includes cases reported to law enforcement, social sonal worth and social Integration Wllllam Freudenberg, services, hospital and mental health clinic in Craig The The Social Impact of Energy Boom Development on Rural number of cases was averaged from November/Decem- Communities: A Review of the Literature and Some ber 1973 and November/December 1976 Denver Re- Predictions, paper presented for the American Sociologi- search Institute, Impacts on Western Communities (OTA cal Associatlon, session 77, August 1976. contractor Report, 1978), p 63 324 The Direct Use of Coa/

and farmers may not be able to replace their and outdoorsmen are often against develop- workers who switch over to high-paying jobs. ment because they do not want to lose their Also, they may resent using good agricultural hunting, fishing, and backpacking areas to the land for mining. Fruit growers around Paonia, coal industry. Colo., were unhappy about orchards being The tourist industry shares these concerns. It taken out of production. Finally, they may be may face competition for employees and loss skeptical about different kinds of people mov- of land for recreational purposes, as well as a ing into a homogeneous community. lessening of the area’s attractiveness to tour- Utah’s policy favors energy development ists. Tourism may suffer from the increased de- almost without qualification because of the mand for temporary accommodations caused State’s desire for economic expansion. As a by transient construction workers. whole, Mormon communities share this desire, The elderly may or may not have definite but some have reservations. Rural, somewhat feelings about coal development, but they are isolated Utah towns that have high percent- usually hit hard. Some rural communities have ages of Mormons may not welcome outsiders. a relatively high proportion of retired people Newcomers are not easily integrated. Resi- living on fixed incomes. As the town booms, dents of Kane County, Utah, wanted the prices (particularly rents) are inflated, squeez- Kaiparowits powerplant built but did not want ing those with low or fixed incomes. plantworkers to live in their communities. They persuaded coal developers to plan a new The degree to which prodevelopment, go- community to house the outsiders. SlOW development, or antidevelopment attitudes exist in a given area depends on the People in places like Gillette, Wyo., which makeup of the community and the characteris- can now be classified as mid boom, see coal tics of the coal project. Articulate, politically development as inevitable. They know their active newcomers can play an important role county contains vast coal resources and that in deciding whether or how much coal devel- new mines wilI inevitably open. According to opment will take place. Mayor Enzi, the people in Gillette no longer challenge growth but have accepted it. This at- The one point that can be drawn from the titude has taken 10 years to evolve. sparse information on the social impacts of Western coal development is that instability is Some westerners see no real benefits from created. Sometimes this appears to be as much coal development. Those who have left an ur- a result of the uncertainty attending coal ban environment and have settled in beautiful, development as from any actual changes that small western communities are often against have occurred. Social change will come with development. They have chosen their new coal development, but it is doubtful that it will home, typically on Colorado’s western slope, affect western towns uniformly. Some towns because of its environment. They do not want will ultimately benefit from this change; others it changed. I n a few places on the western probably will not. slope, miners with Brooklyn accents can be found working in the mines and arguing for no more growth. Their attitudes are not contradic- Coal Development on Indian Lands tory. Their feelings are often shared by some long-time residents and their children, who are Present and Potential Production concerned about the influx of outsiders and environmental protection. They often form or It is estimated that some 100 to 200 billion ally themselves with environmental organiza- tons of recoverable coal lie beneath Indian tions on issues like air and water quality and lands in the West. There are currently 10 coal degradation of the quality of life. Sportsmen leases on 239,402 acres of Indian land. Although they are only a fraction of the total ‘‘°From a 1978 interview with Flip McConnaughey, coal under lease in the West, Indian leases City Manager, Gillete, Wyo have a special importance because of their Ch. VI— Workplace and Community Implications ● 325 size and coherence. The average Indian lease ment of the Interior. BIA advised the tribes as covers almost 24,000 acres —16 times larger to whether, to what extent, and under what than the average Federal and 25 times larger terms their coal would be developed. Tribes than the average Western State lease. Each ln- are no longer satisfied to rely on BIA for deci- dian lease is large enough to support large- sions regarding their resources. scaIemining projects, In March 1973, one tribe—the Northern Five mines now operate on Indian land. Four Cheyenne– became so dissatisfied with leases of these mines rank in the top 10 largest in the it had signed with B 1A advice, that it peti- country. They produced approximately 22.9 tioned the Secretary of the Interior to cancel million tons of coal in 1977, almost 14 percent all outstanding coal leases and permits on its of the coal mined in the West, reservation. A year later, the Secretary ruled in favor of the Northern Cheyenne and declared Three reservations— Navajo, Hopi, and the leases “technicalIy invalid. ” Crow– now host coal mines. Several others— Southern Ute, Uintah and Ouray, Fort Bert- Since this ruling, other lease-holding tribes hold, Northern Cheyenne, and Zuni — have ex- have tried to renegotiate or cancel contracts, cellent potential for coal mining. The Depart- accusing Interior of violating its trust respon- ment of the Interior Iists 25 Indian reservations sibilities to protect tribal interests. as coal owning. Estimates of surface- minable Despite the controversy surrounding these capacity on these reservations ranges from 217 contracts, many tribes see coal development million to 326 million tons per year by the mid- as an opportunity to bring badly needed reve- to late-1980’s. Actual production, however, nues to tribal governments as welI as income may be considerably less. and jobs to tribal members, Most feel, how- The extent to which Indian coal is developed ever, that they will not realize the potential wiII depend on decisions made by each tribe, benefits of coal development unless they develop the capability to manage development A key to understanding how — and under themselves. Tribes are building their own staff what conditions— coal development will take capabilities so that they can determine the place may be found in the history of coal leas- quantity and quality of their resources, ing and mining on Indian lands. The legal analyze the impacts of potential development, framework within which coal development has make informed decisions concerning their re- been conducted is shaped by the unique trust sources, and manage and regulate coal pro- relationship between the Federal Government duction activities and impacts. and tribes. The basis of the Federal-Indian relationship may be found in the treaties, congressional Coal Development Impact acts, and executive orders that began in colo- Rapid or extensive coal development often nial days. Treaties were used primarily to causes adverse social, economic, and environ- secure lands for white settlement and to main- mental impacts. This is especially true on ln- tain peace with the tribes. In return, some dian reservations. lands–a small portion of the land the tribes once owned —were reserved for Indian tribes, Most reservations are sparsely populated with guarantees of protection and certain serv- and have few towns. I n a few cases, coal min- ices from the Federal Government. ing may spawn the growth of instant towns to provide support services for new mines. Even if Among the services provided by the Federal future tribal contracts provide for Indian hir- Government is advising the tribes on the man- ing preferences, non-Indians wiII be drawn to agement of their resources. I n the past, Indian the mines as technicians and other manage- coal was developed under standard-form ment personnel. Non-Indian businessmen may leases arranged for and managed by the open stores on or near reservations. Although Bureau of Indian Affairs (B IA) in the Depart- only 5,000 to 10,000 miners are Iikely to be in- 326 The Direct Use of Coa/ volved in Indian coal development over the to many Indian leaders as a solution to their next 10 years, the ripple effect of their new- dire poverty — average per capita income is be- found income, work habits, and social rela- tween $1,000 and $1,500 annually— and unem- tions are likely to be disproportionately large ployment–40 to 70 percent depending on the on established Indian societies. reservation. However, many energy projects on the reservation have been met with bitter Coal development would also affect tribes grass-root protests. more than other rural communities because the reservations have a dearth of services and Coal development will have major socioeco- facilities, such as sewers, housing, schools, etc. nomic and cultural impacts on Indians. The Any population increase—even a small one— reservations lack public infrastructures would strain already-overburdened systems. capable of absorbing mining-related popula- Cultural differences between the tribal mem- tion. The tribes have difficulty raising revenues bers and outsiders who migrate to the area to to manage the impacts of coal development. work on the project can augment the problem. Tribal leaders interviewed agree on several conditions for coal development. First, that the In addition, coal development impacts lndi- majority of coal-related jobs be filled by lndi- ans more than other rural residents because of ans. Second, that fair market value is obtained the importance of the land to Indian tribes. For for the coal. Third, that coal development will some tribes Iand has religious significance; for enhance tribal sovereignty by recognizing trib- others, certain areas are sacred. For all of the al jurisdiction over environmental standards tribes, land is an important tie to their history and by preserving the integrity of Indian land and future. and cuIture. Tribes want to ensure that coal de- Finally, coal development will affect tribes velopment is not a one-crop economic devel- more than most small, isolated communities opment that leaves them several decades from because tribal governments have great diffi- now without any resources, with scarred lands culty generating revenues needed to offset de- and shattered cultures. Thus, tribes are ex- mands created by development. Conventional pected to demand higher coal royalties, more methods of raising revenues, such as taxation, control over the conditions of mining, and issuing bonds, obtaining private financing, or more social benefits from coal development. receiving Federal funds directly, are either not available or difficuIt for tribes. Social Impacts of Transportation

All of these impacts can serve as deterrents Much of the increase in mine-to-market coal to the development of Indian coal unless tribes traffic will probably make use of existing can effectively manage them. routes. Expanded operation, rather than new construction, involves additional safety and environmental costs to the public. Conclusion All forms of moving coal –or coal-fired Coal development on Indian reservations is electricity – have social costs. Trains interrupt likely to increase as tribes gain greater control motor vehicle traffic and contribute to ac- over their own resources. cidents at grade crossings. More than 1,900 Tribes are building up their staff capabilities persons were killed and almost 21,000 injured in railroad accidents in 1974.1 Most of these so they can determine the quality and quantity of their coal reserves, negotiate with energy accidents were at grade crossings. Perhaps, 15 companies, and regulate the companies’ oper- percent or more of all train accidents involved Truck haulage, which is ations. Tribes are looking at alternatives to the coal-hauling trains. standard form lease used in the past. Tribal ‘‘ ‘Compiled by OTA from Federal Railway Administra- coal holdings are attractive to energy compa- tion data. “*Coal represents about 20 percent of all rail traffic, nies because of their large size and the quality but for reasons such as frequency of grade crossings and of the minerals. And coal development— if routes, coal traffic probably accounts for less than 20 carefully managed by the tribe— is attractive percent of rail accidents compiled Ch. VI— Workplace and Community Implications ● 327 extensive in Appalachia, adds to highway haz- increase in volume although vehicular delay is ards and congestion. The big trucks accelerate greater. the deterioration of the roadways, especially Deaths and injuries associated with the total when weight limits are not enforced. Trucks transport component of the coal cycle were and trains are noisy. They disturb large num- calculated in a recent study. 3 For a 1,000-MW bers of people where they pass through heavily coal-fired powerplant with a 0.75 load factor, populated areas. Barge haulage is safer to the MITRE estimates 2.3 fatalities and 23.4 injuries public than either truck or rail carriers, but it occur annually. That translates nationally to adversely affects recreational boating, fishing, about 460 deaths and 4,680 injuries each year and swimming to some degree. Barge wakes from coal transport. As coal production in- may erode river shores and islands. High- creases, the scale of human costs will grow voltage transmission lines may produce harm- unless countermeasures are initiated. ful electric-field effects. The alternative to coal haulage is high-volt- Railroads now carry about 65 percent of all age electric transmission, which carries its own coal from mine to consumer. This pattern is costs. Intense electric fields surrounding these likely to continue. Aside from the needs to im- lines disturb people living along their rights-of- prove rail-haulage capability, safety and envi- way. Noise and radio interference have been ronmental costs may require attention. Two noted. problems, in particular, stand out. First, disrup- Concern has developed about health and tion to community life caused by rail traffic safety near the Iines. Tests are now underway through population centers will increase as to measure the effect of high electric fields on large mines are developed in the West for cus- plants and animals. For voltages up to 500 kV, tomers several hundred miles distant. Haulage no evidence exists to indicate health hazards, through a given point may approach the equiv- but very little is known about the long-term ef- alent of 18 hours a day in some heavily used fects of low-voltage electric fields on human areas. Rerouting may be desirable in some health. At higher voltages–say at 765 kV–ad- communities to minimize this inconvenience. verse reactions have been reported that may have been caused by the fields. As the voltages Second, grade-crossing accidents will in- increase, potential health effects may increase as haulage increases unless remedial crease. Much work is needed to determine the steps are taken. Underpasses and overpasses possible health costs of high-voltage transmis- are standard ways of eliminating rail-haulage sion lines carrying more than 765 kV. DC risks in population centers. Automatic, lighted presents fewer potential problems because it barrier gates are safety features at crossings carries an equivalent amount of AC power at that are often not found at rural crossings. lower voltages. But because the character of Because of the cost and inconvenience, rail- DC electric fields differs from AC fields, other roads are often reluctant to reconstruct their human health effects may occur. Objects near lines or add safety features, such as lights and DC lines may be charged with voltages of 20 to mechanical crossing guards. Table 55 illus- 40 kV, enough to cause annoying shock. trates four costs— noise, vehicle delay, injuries, and deaths– associated with a hypothetical 36-percent increase in coal trains per Impacts on Coal-Utilization day (measured in ton miles) between a Mon- Communities tana mine and a Wisconsin utility. At 26.6 trains per day, 53,000 persons would be exposed to excessive noise; 983 hours of vehicle delay per year would occur; and 9 fatalities and 37 injuries wouId happen at grade crossings. Yet it should be noted that the increase in noise and accidents is not proportional to the o

328 ● The Direct Use of Coal

Table 55.—impacts of Increased Coal Train Traffic Carrying an Assumed Added Volume of 13.5 Million Tons Per Year from Colstrip, Montana to the Vicinity of Becker, Wis.

Percent Present Future increase

Trains per day (average) ...... 19.6 26.6 36 Population exposed to noise levels exceeding EPA community Guidelinesa ...... 45,000 53,000 18 Vehicle hours delay per year at grade crossings ...... 602 983 63 Injuries per year at grade crossings ...... 33.1 36.6 11 Deaths per year at grade crossings ...... 8.6 9.4 9

1977 the extraction phase, i.e., on coal mine coming community services. The plant may also munities where new facilities for the prepara- contribute substantialIy to the county tax base tion and combustion of coal are located. and benefit other local taxpayers. A general knowledge of the coal industry The major potential negative impacts would suggests a number of categories of potential appear under the headings of environment, impact. These can be divided roughly into public safety, and convenience. The first cate- those that should be on balance beneficial to gory includes air and water pollution, noise, the host community and those that will be esthetic (i. e., visual) impacts, and possible con- predominantly harmful. The former consists cerns relating to the health effects of high- mainly of economic impacts. The establish- voltage transmission Iines from powerplants. ment of a coal preparation plant or power- Safety and convenience refers to concerns plant can be expected to provide employment such as coal-carrying truck or rail traffic and opportunities in the construction, operation, the potential disruption of recreational and and maintenance of the plant and in support- other community activities. Ch. VI— Workplace and Community Implications ● 329

Surprisingly, virtually no attempt has been had on that level. Almost half of the respond- made to ascertain public attitudes toward ex- ents indicated the air and water pollution isting coal powerplants. At a minimum, such levels were severe but only a smalI percentage information shouId be usefuI in developing thought the plant was largely responsible (6.4 siting strategies for future instalIations. Conse- percent for air; 4.8 percent for water), The dis- quently, OTA undertook a survey of residents parity between the level of impact and its living near three coal-fired powerplants in the perception is due in part to the fact that re- Middle Atlantic region: the Chalk Point plant spondents felt that industries located in the in Maryland, the Chesterfield plant in Virginia, same area contributed to the pollution prob- and the Bruce Mansfield plant in Pennsylvania. lem. A relatively small percentage of respond- The results of that survey indicate that the ents indicated that traffic to and from the public regards increased employment opportu- plant had a negative impact. In an effort to nities as the most significant advantage of Iiv- elicit an overalI summary judgment concerning near such a plant (table 56). Other advan- ing the local impact of such a plant, respond- tages cited by the public included the percep- ents were asked their attitude regarding con- tion that coal-generated electric power is more struction of an additional coal-fired power- economical than other sources of energy such plant in or near their community. In all three as oiI and gas. The public also perceived bene- cases, a large percentage of respondents living fits to the Nation in shifting from imported oil within 3 miles of the plants opposed the con- to domestic coal. A relatively smalI percentage struction of a new plant. I n addition, when of respondents cited tax benefits and the given a choice between coal and nuclear perception that coal-fired plants were safer powerplants, the public did not express a than nuclear. On the negative side, a large per- strong preference for either (39.3 percent pre- centage of the public (52.3 percent) cited air ferred coal; 36,8 percent preferred nuclear). In pollution as the most significant disadvantage many cases the preference for coal was attrib- associated with Iiving near a coal-fired power- uted to perceptions that nuclear powerplants plant, regardless of plant location or distance. were unsafe and fear of radioactive fallout. In Other disadvantages cited were water pollu- general, the balance of positive and negative tion, noise, adverse visual impacts, and recrea- attitudes toward coal plants correlated more tional impacts (fishing, boating, and swim- closely with the distance respondents lived ming). I n an attempt to measure the air and from the plant than with any other variable, in- water pollution impact, respondents were cluding the degree of plant compliance with asked to rate the level of pollution in their State environmental standards. communities and indicate the impact the plant

Table 56.—Survey Results — -- —— — ——— —Percentages .— Chalk— Pt.— Chester.— B.— Mansfield — .— — 3. Air pollution level 28.2 17,5 8.1 Not a problem. 37.2 34.1 24.3 Some, but does not disturb anyone. 23.8 42.7 46.8 ——— Occasionally reaches severe levels. 1.1 3.3 12,7 - Usually severe and interferes with some community activities. 9.7 2.5 8.1 Cannot rate level.

4. Plant impact on air pollution 4.8 2.0 13.8 Severe with frequent odor, dust, or damage, 29.7 18.7 34.3 . Moderate with occasional odor, dust, or damage 31.5 28.0 27.0 Sllght with little odor, dust, or damage. 34.1 51.3 24.9 No noticeable impact. 330 ● The Direct Use of Coal

Table 56.–Survey Results (continued)

Percentages—.. Chalk Pt. Chester. B. Mansfield 5. Water pollution level 8.6 33.9 8.6 Usually severe and interferes with some community activities. 33.0 27.0 25.5 — –. Occasionally reaches severe levels and sometimes interferes with community activities. 24.4 15.5 27.6 Some, but does not disturb anyone. 16.8 11.5 14.8 Not a problem. 17.2 12.1 23.4 Cannot rate level.

6a. Plant impact on water pollution 7.9 2.9 5.1 —— Severe with major changes in temperature, level, or chemicals in the water. 25.7 13.1 24.3 Moderate with some changes in temperature, level, or chemicals in the water. 29.4 31.1 27.5 Slight with minor changes in temperature, level, or chemicals in the water. 37.0 52.9 43.1 No noticeable impact.

6b. If plant has impact on water pollution, which of the following apply? 19.3 6.0 6.1 —— — Fishing is better. 35.0 21.9 33.7 ——. Fishing is not as good. 2.5 4.1 7.5 Boating and swimming are better. 41.4 23.8 31.6 Boating and swimming are not as good. 7.5 6.8 22.1 Drinking water is polluted. 13.2 18.9 10.5 — Other, please specify.

7. Plant impact on public health 0 0 .7 —.— Public health very much better. 4.1 1.5 3.0 Public health somewhat better. 79.0 84.0 61.1 No difference in public health. 15.7 13.3 29.3 Public health is somewhat worse. 1.1 1.2 5.9 — — Public health very much worse.

8. Plant impact on public safety or convenience 3.0 4.7 3.6 — Public safety or convenience very much better. 5.2 9.4 8.0 ——. Public safety or convenience somewhat better. 79.9 79.8 50.0 No difference in public safety or convenience. 10.4 5.3 29.6 Public safety or convenience somewhat worse. 1.5 .9 8.8 Public safety or convenience very much worse. 9. PIant impact on area attractiveness .7 .6 3.9 — -- Very much more attractive. 6.2 1.7 11.0 — — Somewhat more attractive. 35.4 61.2 24.9 - No difference in attractiveness. 38.0 30.1 32.4 Somewhat less attractive. 19.7 6.4 27.8 .- Very much less attractive.

10. Impact of power transmission lines on area .4 .6 1.8 Very desirable effect. 2.2 2.3 5.1 —– Somewhat desirable effect. 47.6 52.9 46.9 —--- No noticeable effect. 35.4 38.8 30.7 ——— Somewhat undesirable effect. 14.4 5.5 15.5 Very undesirable effect. 11. Plant impact on area activities 1.1 3.8 .7 ——— Plant grounds and facilities available for community use. 17.8 16.8 19.2 Plant tax payments prevent taxes on home from being higher. 14.4 11.2 30.8 — —- Noise or air pollution or water pollution discourage community activities. 61.0 63.5 42.0 No noticeable impact.

12a. Mode of transportation 56.6 64.6 0 Train. 2.9 1.7 49.4 Barge. 5.4 .3 .4 Truck. 23.3 13.6 8.2 Don’t know. Ch. VI— Workplace and Community implications ● 331

Table 56.—Survey Results (continued) — Percentages—. Chalk Pt. Chester. B. Mansfield— — 12b. Transportation impact on community 6.1 2.8 22.9 — Yes. 93.9 97.2 77.1 ---- No.

13. Favor/oppose construction of new plant 28.2 11.8 23.6 Strongly oppose. 21.1 16,7 21.6 — Somewhat oppose. 24.6 33.4 27.7 – Neither favor nor oppose. 14,6 23.0 12.7 - Somewhat favor. 11,4 15.1 13.4 Stongly favor,

14. Preference for coal or nuclear plant 34.4 46.7 38.7 -. Coal-fired. 41.1 39.0 33.9 — Nuclear, 24,4 14.3 27.4 -- Don’t know.

15. Distance from home to plant 31,4 9.3 61.9 --- Less than 3 miles. 27.1 38.5 27.9 —– Between 3 and 6 miles. 22.5 29.2 4.8 – Between 6 and 10 miles. 14,3 13.9 1.0 – --- More than 10 mtles. 4,6 9.0 4.4 -.— Don’t know. . ——— 332 ● The Direct Use of Coa/ ESTHETIC IMPACTS

Introduction for improving the landscape. Others argue, however, that the construction and operation The esthetic impacts of increased coal utili- of coal utilization facilities will have adverse zation are difficult to quantify and evaluate esthetic impacts; changing the natural charac- because procedures for measuring esthetic im- teristics of an area and its ecosystems is pacts have not been established. In part this is viewed as detrimental. Furthermore, in some a result of the subjective nature of esthetics. instances esthetic impacts can be used as a For example, Webster defines esthetics as surrogate for other concerns, such as opposi- “beauty or sensitivity to beauty. ” The response tion to government and industry, and resist- to an esthetic impact, positive or negative, is ance to outsiders. An example of this is the largely dependent on value judgments. Kaiparowits controversy where fear of esthetic Consequently, a great deal of uncertainty impacts were used as a basis to mobilize sup- exists regarding the role esthetics should play port from a broad-based national constitu- in affecting public policy. ency. Although strong local support was given to the development of the Kaiparowits plant, a Section I02(2)(B) of the National Environ- national constituency that views air polIution mental Policy Act calls for the consideration impacts on nearby pristine areas as unaccept- of esthetic impacts in decisionmaking but does able actively opposed the plant. not provide assistance in determining what The variable most often used to measure es- methods and procedures should be developed thetic impact is change. Present EISs generally to facilitate that consideration. Some atten- reflect the view that changes in the environ- tion has been given to the formulation of quan- ment are negative. In addition, esthetic im- tifiable indicators but these are still in the very pacts identified in EISs appear to be of an im- early stages of development, Table 57 illus- mediate or first-order kind; EISs do not identify trates work in this area. beneficial second-order esthetic impact associ- The most obvious problem is the fact that ated with social and economical benefits (li- esthetic impacts are perceived differently by braries, theaters, etc.). Legislation also appears different individuals and groups. Although no to embody the assumption that change is nega- one finds strip mines esthetically pleasing, tive. This is evident in the language of the there are individuals who feel that the con- prevention of significant deterioration stand- struction and operation of coal utilization ards for air quality. There does not appear to facilities will have a positive impact. For exam- be any firm basis for defining all change from ple, some feel reclamation is an opportunity the natural state to be bad, however.

Table 57.—Esthetic Judgment Categories

Esthetic judgment Equality of esthetic Air esthetics Water esthetics Landscape esthetics Biota esthetics Sound esthetics opportunity Visibility Clarity Urban dominated Population Background sound Odor Floaters Mountain dominated Variety Intermittent sound Irritants Odors Desert dominated Health Agriculture dominated Location Forest dominated Water dominated ——— SOURCE. Adapted~rom Gum, et al , 1974” 34. Ch. VI— Workplace and Community implications ● 333

Photo credft: Earl Dotter Ellsworth, Pa. Slag pile in the background

Mining probably of greater concern in the West where rainfall is Iimited Noise is another impact A major concern in the West is whether re- from mining. Although blasting noise is not claimed land can be revegetated in an area identified as a serious problem, it is an annoy- with Iimited rainfalI Although simiIar con- ance to individuals who Iive near the m inc. The cerns are expressed in the Central and Eastern most significant visual impact resulting from regions, revegetation is easier there because of underground mining is subsidence (uneven the higher levels of rainfall and thicker soil sinking of land surfaces). This impact is a sig- profiIes Because of thin coal seams, however, nificant concern in the Central and Eastern as much as 10 times more land in the East must coal regions. be stripped in order to provide the same quantity of coal as in the West. Contour mining in mountainous areas produces stiII another seri- Transportation ous esthetic impact. Often the highwalI is visible for miles. Reclamation of contour mining is Several esthetic impacts result from the costly and difficult and may appear sIightly ar- transportation of coal. Unit trains produce a tificial. But if properly reclaimed, nonmoun- noise level of about 9S decibels; these levels tainous land can be used for many purposes, may remain as high as 55 decibels within one- including agricuIture, recreation, forestry, half mile of the track. At present, noise from housing, and industrial development. Another transportation affects trackside residents and impact associated with strip mining is a reduc- as rail haulage increases with expanded pro- tion in visibility due to dust. This impact is duction, noise, and dust will become more fre- 334 The Direct Use of Coa/ quent and more serious annoyances. Highways ble for miles. In addition, coal piles surround- also contribute to noise pollution, and both ing the plant are unsightly and may produce highways and railroads may be considered un- dust. Large-scale coal utilization facilities can sightly. However, the most obvious visual significantly reduce visibility and alter the transportation impact is from transmission natural coloration of the sky. During an inver- lines. The lines are especially unsightly in sion, visibility may be reduced even more. scenic and residential areas and are visible for Gray skies associated with heavily industrial- miles. Tower design as well as proper siting ized areas may suggest what is to come if coal couId possibly reduce the impact. utilization is accelerated. Individuals living in close proximity to the facility may experience Combustion noise and odor impacts, but these do not appear to be a serious concern at this time. Visually, coal-fired electric powerplants are rarely pleasing to the eye. Often stacks are visi- Chapter Vll . PRESENT FEDERAL COAL POLICY Chapter VII- PRESENT FEDERAL COAL POLICY

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Policy Evolution ● .*** ... ,.. ,.. ... *.. m**. *.. ,.. a m...... * 337 National Environmental Policy Act ...... , ...... 338 Federal Coal Leasing ...... 339 Past Leasing Law and Practice ...... 340 Development of a New Federal Coal Leasing Policy ...... 341 Problem Areas ...... 342 Surface Mining Control and Reclamation Act of 1977...... 343 The Federal Mine Safety and Health Act of 1977...... 345 The Clean Air Act. , ...... 349 Background and History...... 349 National Ambient Air Quality Standards ...... 349 New Source Performance Standards ...... , .. .350 Nonattainment Areas...... 351 Prevention of Significant Deterioration/Visibility Protection. 352 EPA Studies and Potential New Standards ...... 353 Interface with Energy Legislation ...... , ...... 353 Implementation of the Amendments ...... 354 The Clean Water Act ...... 355 Water Quality Standards ...... 356 Effluent Limitations ...... , ...... 356 Thermal Discharges ...... 358 Permit Systems...... , ...... , ...... 359 Areawide Planning ...... ,359 Resource Conservation and Recovery Act of 1976. . ., ...... 360 Coal Conversion Authority...... ,..361 Other Federal Policy Actions ...... 363

Implementation ● .*..*...... ● 0....., , 365 Institutional Factors, ..., ., ...... , ..365 Environmental and Social Impacts...... 365 The Promotion of Coal Use ...... , ...... i ..368 Evaluation ...... , ...... 368

TABLES

Page 58. Standards for Particulate Matter, Sulfur Dioxide, and Nitrogen Dioxide ., ...... , ....350 59. Effluent Limitations: Steam Electric Power Generating Units .357 60. Effluent Limitations: Coal Mining Point Source Category ....358 61. Potential Sludgeand Ash Disposal Costs Under RCRA...... 361 Chapter Vll PRESENT FEDERAL COAL POLICY

Neither Congress nor the President has yet articulated a comprehensive and consistent policy for coal. Nevertheless, the major elements of such a policy are in place. The National Energy Act of 1978 and the earlier Energy Supply and Environmental Coordination Act of 1974 promote the use of coal to increase the Nation’s capability to use domestic energy sources. The National Environmental Policy Act, the Clean Air Act and Amendments, the Clean Water Act, the Surface Mine Control and Reclamation Act, and other Federal policy actions minimize environmental degradation resulting from, among other causes, the production and use of coal. The Mine Safety and Health Act is intended to reduce the hazards to miners, while black lung benefits compensate for past abuses. Various provisions also have been made to assist communities experiencing rapid growth as a result of coal development. Thus coal policy might be summarized briefly as: When fossil fuel is to be used, coal shall be the choice wherever practical, but it must be mined and burned in ways that minimize the negative environmental and human impacts. These goals are obviously contradictory, but they need not be mutually exclusive. Because Congress has never legislated a national coal policy, the current Federal role has evolved incrementally as part of a continuing political process where different interests – both inside and outside of Government–compete for influence. This competition involves lobbying Congress, media campaigns, gaining access to policy makers, researching issues, bargaining with the opposition, and mobilizing and targeting pressure. The consequence of this process is that Federal policy is often contradictory, frequently delayed by legal challenges, occasionally jarred by legislative initiatives, and rarely settled once and for all. This chapter explores the present structure of Federal coal policy and how it is being implemented. The next chapter analyzes policy strategies that may be considered in the future.

POLICY EVOLUTION

At the end of World War 11, coal supplied ing in a variety of Federal policies related to about half the Nation’s energy needs. By 1950, coal. Federal legislation first addressed the oc- it had been eclipsed by oil, and natural gas sur- cupational health and safety risks of coal min- passed it in 1958. Such a rapid decline in abso- ing. Subsequent Federal policy directives ad- lute as well as relative importance indicates dressed the air and water quality effects of that more was occurring than an industry suc- mining and combustion on human health and cumbing to stronger competition. Both market the environment, Recently, the disposal of prices and Federal policies discouraged the mine and combustion wastes and the reclama- use of coal relative to oil and gas. Similarly, tion of surface mines have come under Federal the negative impacts of coal were not of para- jurisdiction. However, there are many points in mount concern to the Federal Government ex- the entire pattern of coal production and use cept in so far as they contributed to the tilt where the different goals — increased produc- toward oil and gas. Federal coal on western tion, environmental protection, and maximum lands was made easily available, but little social benefit— conflict. Both Congress and development was expected to take place. the executive branch have sought to fashion policies and administrative frameworks that In the last decade, the realization of the re- can resolve these conflicts, but they often are source limitations of oil and gas has renewed frustrated by overlapping and conflicting man- interest in coal as the logical substitute, result- dates that result in inconsistent or fragmented

44-11, .! ( 1 - 7 ~ - 23 337 338 The Direct Use of Coa/

policies. For example, an adequate water sup- ● the environmental impact of the proposed ply is crucial to mining operations but the lack action, of a comprehensive Federal water policy offers ● any adverse environmental effects that little direct support to a policy of increased cannot be avoided should the proposal be coal development. implemented, ● alternatives to the proposed action, The Federal legislation that constitutes the ● the relationship between local short-term major elements of a national coal policy are uses of man’s environment and the main- analyzed below, categorized according to tenance and enhancement of long-term their goals: environmental and social impact productivity, and management, and the promotion of coal use. ● any irreversible and irretrievable commitments of resources that would be involved National Environmental Policy Act in the proposed action should it be implemen ted. The National Environmental Policy Act of In addition, the Council on Environmental 1969’ (NE PA) was intended to restructure Fed- Quality (CEQ) regulations for the preparation eral agency decision making in favor of an in- of EISs require discussions of indirect effects, terdisciplinary approach to ensure that en- such as population and growth; energy require- vironmental amenities and values would re- ments and the conservation potential of vari- ceive appropriate consideration along with the ous alternatives and mitigation measures; and traditional economic and technical factors. possible conflicts between the proposed ac- NEPA was the first major environmental legis- tion and the objectives of other Federal, relation passed by Congress and it has remained gional, State, tribal, or local policies. the most far-reaching in scope. All coal-related activities that have a signifi- In general, NE PA has a threefold purpose: to cant impact on the environment and that need declare a national policy to create and main- Federal authorization require an E IS. This in- tain conditions under which man and nature cludes coal leases on Federal lands and large can exist in productive harmony and can fulfilI coal combustion facilities. Although permits the social, economic, and other requirements issued by the Environmental Protection Agen- of present and future generations; to increase cy (EPA) under the Clean Air and Water Acts the understanding of ecological systems and are exempt from the E IS requirement, those natural resources; and to promote efforts that Acts require separate analyses of a project’s will prevent or eliminate damage to the envi- impact on the environment. ronment. As one means of achieving these purposes, NEPA requires all Federal agencies to The original CEQ regulations implementing include a detailed environmental impact state- NEPA were limited to the preparation of E1Ss ment (E I S) in every recommendation or report and did not address NE PA’s other provisions in- on proposals for legislation and other major tended to improve agency planning and deci- Federal actions significantly affecting the sionmaking. In addition, CEQ’S guidelines for quality of the human environment. The E IS re- preparing EISs were only advisory; more than quirement has been held to be applicable to a 70 different sets of agency regulations were wide variety of Federal actions, ranging from promulgated to implement the guidelines. As a the construction of a Federal building to the is- result, agency practices varied widely and the suance of a construction permit for a nuclear EIS tended to become an end in itself rather powerplant. than a means to making better decisions. The NEPA process was criticized by environmental- An E IS is required to include detailed infor- ists for its attention to procedure rather than mation about: substance, by permitters for delays it caused in project authorization, and by Government officials for the amount of paperwork it re- ’42 U. SC. 4321 et seq quired. Ch. V1l—Present Federal Coal Policy ● 339

In 1977, CEQ was given the authority to the E IS and how the responsibility for the E IS issue binding regulations to replace its advi- should be apportioned among the agencies in- sory guidelines and the various agency regula- volved. This scoping procedure is to begin as tions. The new CEQ requirements, which were early as possible in the N EPA review and must published in November 1978, are designed to be integrated with other planning. produce better agency decisions and to reduce Provisions of the regulations designed to re- delays and paperwork. 2 duce delays in project authorizations include The new CEQ regulations are intended to emphasizing interagency cooperation before comply with the original intent of NE PA that the E IS is prepared rather than submission of the E IS be an action-forcing procedure to im- adversary comments on a completed draft, es- plement the substantive requirements of the tablishing time limits for E IS preparation, and Act and thus to produce better agency deci- using categorical exclusions to define actions sionmaking. They require agencies to publish a that are exempt from the E IS requirement. In concise public record that indicates how the addition, the regulations calI for a “tiered” ap- E IS was used in making a decision, This record proach in which material common to a broad must indicate which alternative is preferable program or a related series of actions is in- on environmental grounds. If that alternative cluded in broader EISs, such as national pro- is not the one chosen, the record must identify gram or policy statements, and then summa- the essential considerations of national policy rized and incorporated by reference in suc- that were balanced in making the decision, in- cessively narrower EISs, such as regional or cluding factors not related to environmental basinwide program assessments and, ultimate- quality such as economic and technical con- ly, site-specific statements. Finally, many of siderations or legislative mandates, and must the regulations intended to reduce paperwork explain why the environmental considerations also will reduce delays, such as the scoping were outweighed by these other factors. A sec- process and the elimination of duplicate state- ond provision of the new regulations, which is ments. intended to produce better decisions, requires It is too soon to tell whether these regula- agencies to monitor projects to ensure that tions will restructure agency decision making in mitigation procedures and other conditions es- order to implement fulIy NE PA’s environmen- tablished in the EIS are implemented. Finally, tal policy goals. However, the regulations the new regulations require that a list of the should significantly reduce the resources re- people who helped prepare an EIS and their quired to comply with the Act and thus pre- professional qualifications be included in the vent N EPA from becoming a Iimiting factor in statement to encourage accuracy and profes- decisions related to coal development. sional responsibility and to ensure that an in- terdisciplinary approach was followed, Federal Coal Leasing To reduce paperwork, the regulations require agencies to reduce the length of EISs The National Energy Plan calls for expanded (CEQ suggests 150 pages as the limit for a nor- reliance on coal. Some commentators have mal E IS), prepare analytic rather than encyclo- suggested that Federal coal reserves will be a pedic statements, use plain language, follow a key factor in determining whether the Nation clear format, and reduce emphasis on back- wilI meet its energy goals. Western coal com- ground material. In addition, Federal agencies prises roughly half of the total U.S. coal can eliminate duplication by preparing EISs reserves; the Federal Government owns 65 per- jointly with State and local agencies that recent of Western coal and indirectly controls quire similar assessments. The regulations also another 20 percent. On the other hand, the institute a new “scoping” procedure for de- 1977 amendments to the Clean Air Act may ciding which issues should be emphasized in considerably reduce the advantages that have accrued to low-sulfur Western coal in the past

2 43 F R 55978 (Nov. 29, 1978) if those amendments require pollution con- 340 ● The Direct Use of Coa/

trols regardless of the sulfur content of the could be held without development at little fuel. cost and transferred at will. Leasing generally was based on a site-by-site Even if Western coal is required to meet na- response to applications, usually at the State tional energy goals, it is not clear how many level with no National policy guidance. Conse- new Federal coal leases would be needed. Six- quently, what mining did occur was hampered teen billion tons of Federal coal already are by irrational landownership patterns in the under lease and another 9 bi1Iion are subject to Western coalfields. Areas that logically should existing applications for preference-right have been mined as single units were divided leases. In addition, there are an estimated 93.4 among private owners and Federal lessees. billion tons of recoverable coal reserves on private lands in the West. Similarly, there was often a split in ownership of surface and mineral rights. In addition, data Thus it is unclear how important Federal necessary to develop a coherent National pol- coal will be to the Nation in the future or icy, such as information on the location and whether additional Federal leasing is needed. extent of coal deposits, were not available. Yet no comprehensive Federal coal leasing pol- In November 1970, the Bureau of Land Man- icy currently exists, and even if more Federal agement (BLM) released a study that summa- coal is required to meet the Nation’s energy rized the results of these abuses.4 The study goals, it probably will not be able to play a found that while the number of acres being central role until the early 1980’s. This section leased was rising, production from leased reviews the history of Federal coal leasing, ex- lands was dropping; 91 percent of all coal amines recent congressional action, and out- leases were not producing anything. BLM con- lines the major obstacles to a rational leasing cluded that “existing policies and procedures policy. with respect to the development of federally Past Leasing Law and Practice managed coal resources are inadequate to encourage their development. ” As a result of this Originally, the Federal Government sold or study, the Department of the Interior imposed gave away its coal-bearing lands. Then, under a moratorium on coal leasing while it reas- the Mineral Leasing Act of 1920,3 it became sessed its own policies. In February 1973, in- Federal policy to issue leases for prospecting terior announced that a new long-term policy and mining. Where there were known coal de- was under development and in the interim no posits, leasing tracts were awarded by com- new prospecting permits would be issued and petitive bidding. In other areas, the Depart- coal would be Ieased only where certain ment of the Interior issues 2-year prospecting “short-term” criteria were met. permits. If commercial quantities of coal were discovered during those 2 years, the permittee The short-term criteria were designed to pre- was entitled to a preference-right lease for all vent undue hardship to companies as a result or part of the land. of the moratorium. Initially, they permitted coal leasing when necessary to maintain an ex- Although the 1920 Act contained numerous isting operation or to serve as a reserve for pro- provisions designed to protect the public inter- duction in the near future. Unfortunately, est and to ensure a fair return to the Govern- these criteria were abused and received scath- ment, most leases were issued on an ad hoc ing criticism from the General Accounting Of- basis without regard to energy needs or envi- fice.5 The criteria were revised in July 1977; ronmental factors. Much of the leased land fell 2 months later they were included in an in- into the hands of a few large companies that 4 were interested only in speculation. The Fed- Holdings and Development of Federal Coal Leases, (U.S. Department of the interior, Bureau of Land Man- eral Government often charged lower royalties agement, unpublished, November 1970). than private lessors and Government leases 5Further Action Needed on Recommendtions for Im- proving the Administration of Federal Coa/-Leasing Pro- gram (Washington, D. C.: General Accounting Office, U.S. ~30 USC. 181 et seq. Comptroller General, April 1975). Ch. V/i—Present Federal Coal Policy ● 341 junction issued by a Federal court against the aging national energy resources. 7 In September entire Federal Ieasing program. b At present, 1977, a Federal court enjoined Interior from short-term leasing is permitted only when nec- taking any steps whatsover, directly or in- essary to maintain the level of production at directly, to implement the new coal leasing an existing mine or to meet existing contracts program, and ordered the Department to cor- and when the extent of the lease is not greater rect the deficiencies in the final EIS and to cir- than required to meet these conditions for 3 culate the revised statement for review and years. comment. 8 Until the new E IS is completed — which Interior indicates will be not earlier than Short-term leasing has produced little coal. mid-1 979 — no long-term Federal coal leasing Only 12 leases covering 30,459 acres have been will occur. issued since 1973. Industry is reluctant to commit itself to short-term coal leases and the Development of a New Federal Coal court’s criteria are difficuIt to meet. Leasing Policy Over the same period, the Federal Govern- In 1976, Congress passed the Federal Coal ment’s long-term leasing program has gone Leasing Amendments Act’ to address the defi- through two stages, known as EMARS I and ciencies of the Mineral Leasing Act of 1920. EMARS 11. In May 1974, the Department of the The 1976 amendments discourage speculation Interior issued a draft programmatic EIS, out- by making leases more difficult to obtain and lining its plans for a long-term leasing program, to hold cheaply. Federal leases now must be or Energy Minerals Allocation Recommenda- developed within 10 years or they terminate tion System (EMARS l), which required the automatically, they cannot be issued for less Government to set leasing targets based on na- than their fair market value, and mimum roy- tional energy needs. Under EMARS 1, leasing alties are set. In addition, all leasing must be tracts were to be nominated by the Govern- by competitive bidding with 50 percent leased ment based on land use plans. Environmental under a deferred bonus bidding system that impact assessments were to be performed on makes it easier for small companies to com- the nominated tracts and those that were suit- pete. Preference-right leases are abolished, able for leasing put up for competitive bid- and no person or corporation may hold more ding. than 100,000 acres of leases. In September 1975, after a comment period The amendments also contain various provi- on the impact statement and EMARS 1, the De- sions to encourage land use and environmental partment of the Interior issued the final pro- planning, including the creation of “logical grammatic E IS. The impact statement adopted mining units. ” In addition, one-half of all an Energy Minerals Activity Recommendation royalties must be turned over to the States to System (EMARS II) instead of the Allocation provide public services and mitigate communi- System contained in the draft statement. ty impacts. Finally, the Department of the in- Under EMARS II, industry would nominate terior is directed to conduct a comprehensive leasing tracts, indicating the type, amount, and exploratory program to determine the extent location. of Federal coal reserves.

Both the final impact statement and the In 1977, BLM promulgated regulations to im- EMARS II program were criticized severely. plement the Federal Coal Leasing Amendments The General Accounting Office noted, among Act. Because they are so recent and because other deficiencies, that the Department of the

Interior was assuming its traditional role of 7 reacting to industry proposals rather than man- Ro/e of Federa/ Coa/ Resources in Meeting Nationa/ Energy Coals Needs To Be Determined and the Leasing Process Improved (Washington, D. C.: General Account- ing Office, U.S. Comptroller General, April 1976) bNatural Resources Defense Council v, Hughes, 7 E.L..R. aNRDC v. Hughes. 20785 (D. D. C., 1977). 930 USC. 201-209. 342 ● The Direct Use of Coal new leasing has been almost nonexistent since Problem Areas 1970, the degree to which they will remedy Many of the problems that still must be re- past abuses is unclear. However, it already is solved by the Federal Coal Management Re obvious that a number of the regulations are view Policy Committee, the Department of the confusing and may have to be clarified or re- Interior, and Congress are carryovers from vised. earlier leasing policy. They include logical In his May 1977 environmental message, mining units, preference-right lease applica- President Carter directed the Secretary of the tions, the requirements of diligent develop- Interior to undertake a major review of Federal ment and continued operation, estimated coal leasing policy. In particular, the Secre- recoverable reserves, advance royalty pay- tary was directed to ensure that the Depart- ments, and the exchange of environmentally ment of the Interior could respond to reason- sensitive leased lands for other unleased able production goals while leasing only those Federal land. areas where mining is environmentally accept- A logical mining unit (LMU) is a contiguous able and is compatible with other land uses. area of coal land under the control of one Special attention is to be given to existing operator that can be developed effectively leases that are nonproducing or environmen- and mined within a defined period of time. The tally unacceptable. theory of LMU makes sense; it asserts that na- In response to this directive and to a request tional Ieasing policy should consider the by the court that enjoined EMARS II, the De- nature of the coal resource in each case and partment of the Interior created a Federal Coal then assemble the physical resources neces- Management Review Policy Committee. ’ The sary to produce the coal economically while committee has undertaken 13 management preserving environmental safeguards. How- tasks in response to the Presidential directive. ever, the regulations promulgated by BLM to implement the Federal Coal Leasing Amend- One of its first products is a paper that outlines three options for an overall approach to long- ments Act depart from this theory in two re- term leasing: industry nomination of both spects. First, under the regulations, boundaries areas and tracts for leasing, Government iden- of an LMU are set according to the legal tification of areas with industry nomination of boundaries of leases rather than according to specific tracts, and Government selection of natural formations of the coal seam. Second, both areas and tracts. 2 an LMU is required to produce a fixed amount of coal each year without regard to the individ- Until the committee’s work is complete, it is ual characteristics of each coal mining oper- unclear what direction the new Federal coal at ion. leasing policy will take, or which, if any, of these three options will be adopted. However, Technical problems also surround the formation of LMUS. The Secretary of the Interior the Secretary of the Interior has stated that the does not appear to have the authority to order new Federal policy will restrict coal Ieasing to private, State, or Indian lands to be combined those areas where the Federal Government owns the surface rights. 3 with Federal leases to form an LMU nor does the Secretary have the authority to divide existing leases into several LMUS. In addition, practical and legal problems may arise from ‘“ The President’s Environmental Program (Washington, the requirements that all lands in an LMU be D C : Council on Environmental Quality, 1977). contiguous and that the holders of existing 11Federal Coal Management Review Policy P/an (U.S. leases must consent to their inclusion in an Department of the Interior, unpublished, July 25, 1977), LMU. Finally, industry representatives have 12 Memorandum to the Secretary of the Interior From argued that the congressional mandate that all the Deputy Executive Secretary on Department/ Ap- proach for the Long-Term Coal Leasing Program: Deci- reserves in an LMU be mined within a 40-year sionmaking (unpublished, Oct. 17, 1977) period may result in inefficiencies in some cir- 13 ’220 Energy Users Report 24 (Oct. 22, 1977). cumstances. Ch. V1l—Present federal Coal Policy ● 343

Much uncertainty and controversy also sur- ferent ways at different times, As a result, in- rounds the preference-right lease applications dustry and Government estimates can vary by (PRLAs). At present, there are approximately as much as 100 percent. Moreover, the present 180 outstanding PRLAs covering an estimated regulatory scheme provides Federal leasehold- 9 billion tons of coal on 446,000 acres. The De- ers with strong incentives to underestimate partment of the Interior contends that it must their recoverable reserves. issue a PRLA when a permittee has established Finally, problems exist in the regulations that the land contains commercial quantities designed to implement those portions of the of coal. “Commercial quantities” was inter- 1976 amendments that relate to advance royal- preted as coal “of such character and quantity ty payments and exchanges of land or leasing that a prudent person would be justified in the rights. The protection afforded by advance further expenditure of his labor and means royalty provisions of the amendments appears with a reasonable prospect of success in devel- to have been diluted by the Department of the oping a valuable mine . .’”14 Some critics have Interior regulations that grant the Mining questioned the appropriateness of the prudent Supervisor blanket authority to permit ad- person test and suggested the substitution of a vance royalty payments in lieu of continued “workabiIity” or “paying quantities” concept. operation without requiring a specific finding Others have asserted that, in addition to the that such a substitution would be in the public commercial quantities test, Interior must con- interest. I n addition, Interior currently is sider environmental impacts before issuing a developing regulations that would authorize PRLA. Finally, even if all the foregoing issues the exchange of Federal land under lease or are resolved quickly, it wiII take years to proc- subject to a PRLA for future bidding rights. The ess the pending applications. It appears that a Department would prefer the broader author- minimum of 5 to 7 years will pass before any ity to exchange leases in environmentally sen- coal can be produced from PRLA tracts. sitive areas for other unleased land as well as A number of problems also exists in the regu- for future bidding rights. lations that implement the requirements for diligent development and continued operation Surface Mining Control and of leases. First, the reguIations define those re- Reclamation Act of 1977 quirements in terms of LMUS, yet old leases Many surface mining operations result in cannot be designated as LMUS without the disturbances that adversely affect commerce consent of the lessees. The Department of the and the public welfare by destroying or dimin- Interior has taken the position that it can des- ishing the utility of land for commercial, indus- ignate an old lease as an LMU when it is read- trial, residential, recreational, agricultural, and justed despite statutory language that suggests forestry purposes. Many operations have that the consent of the lessee is required. Sec- caused erosion and landslides, contributed to ond, it is not clear that the present definition floods, polluted the water, destroyed fish and of diligent development, which does not re- wildlife habitats, impaired natural beauty, quire periodic reports, will prevent lessees damaged private property, and undercut Gov- from holding land for long periods of time ernment policies and programs to conserve without substantial development. soil, water, and other natural resources. The Additional problems exist in implementing existing State regulatory programs intended to the concept of estimated recoverable reserves. deal with these impacts varied widely and often were not enforced adequately. These Many of the key terms in the coal leasing findings, and others, formed the basis for con- regulations are defined in terms of this congressional action leading to passage of the Sur- “ cept, but there is no commonly accepted defi- face Mining Control and Reclamation Act nition of “estimated recoverable reserves” and (SMCRA) of 1977. ’5 A detailed analysis is various organizations compute reserves in dif - presented in volume 11, appendix XVI 1.

“41 F R 18847 (May 7, 1976) ‘ 530 U S C 1201 et seq 344 The Direct Use of Coal

Based on the assumption that mining should detail how this use will be achieved including be a temporary activity, the Act was intended the engineering techniques and equipment to to change coal mining practices that generate be used, the cost per acre of reclamation, and severe social and environmental costs and to a detailed timetable for accomplishing rec- prohibit mining operations in areas that cannot lamation. In addition, the plan must describe be reclaimed. To accomplish these goals, the the means of compliance with applicable air Act mandates State permit programs for sur- and water quality and health and safety regu- face mines and for the surface operations of lations. underground mines and State procedures for All surface mining permits issued under the designating areas unsuitable for mining. In the Act must require that the coal mining opera- interim, or in the event of a State’s failure to tions meet all applicable environmental pro- establish an adequate program, the Federal tection performance standards. These stand- Government will retain regulatory authority. In ards govern the maximum recovery of fuel; res- addition, the Act establishes a fund for the rec- toration of the land to its original contour; use lamation of abandoned mines. of explosives; waste disposal, including the use This section discusses the permit programs of waste piles as dams or embankments; con- for surface and underground mining. Man- struction of access roads; and revegetation. dated procedures for designating areas as un- Additional, more stringent standards apply to suitable for mining are discussed in chapter IV. environmentally sensitive areas such as prime Each application for a surface coal mining farmland, steep slopes, alluvial valleys, and and reclamation permit must include detailed timber lands. information about the type and method of Permits for underground mining must also coal mining operation, engineering techniques, require the mine operator to prevent subsi- and equipment to be used; the probable hydro- dence to the extent possible, seal all openings logic consequences of the mining and reclama- to the surface, and prevent acid or other toxic tion, both on and off the minesite; any man- drainage. made features or significant archeological sites that may be affected by mining; the geo- Enforcement of SMCRA’S performance logical and physical characteristics of the coal, standards and reclamation plans will play a including a chemical analysis of potentially critical role in determining the impact of the acid- or toxic-forming strata; a soil survey of Act on coal production and environmental potential prime farmland; and the reclamation quality. As with administration of other plan. SMCRA provisions, enforcement can be delegated to States if their mining standards and The probable hydrologic consequences of reclamation requirements are at least as strin- mining and reclamation must be determined gent as the national standards. If this strategy relative to the hydrologic regime and the quan- of delegating the primary enforcement role to tity and quality of surface and ground water the States is successful, the Federal Office of systems including dissolved and suspended Surface Mining (OSM) would not require large- solids under seasonal flow conditions. Suffi- scale enforcement resources. If the strategy cient data must be collected to enable the does not succeed, the ability of OSM to en- regulatory agency to assess the probable force the Act adequately is uncertain. During cumulative impacts of all mining in the area interim enforcement of the Act by OSM, about on hydrology and water availability. 160 inspectors were responsible for ensuring The reclamation plan must describe the con- compliance at more than 3,900 surface mines dition of the land prior to mining including its and approximately 2,550 underground mines existing and potential land uses and its produc- (or approximately 1 inspector per 35 surface tivity as well as its average yield of food, fiber, and per 56 underground mines). forage, or wood products under optimum management. The plan also must specify the pro- An inadequate inspection force will result in posed postmining land use and describe in an inability to make the required number of in- Ch. V1l—Present Federal Coal Policy ● 345 spections and therefore an emphasis on “prob- specified by Congress) indicates that their final lem mines” and flagrant violations. It is doubt- regulations would result in only a 0.25-percent ful that all problem mines will be identified; increase in the cost of electricity to the aver- those mines that are not inspected as frequent- age residential customer in 1985.7 ly as required could escape strict compliance with the Act. The Federal Mine Safety and Other issues related to enforcement of Health Act of 1977 SMCRA include the availability and adequacy of performance bonds, which are intended to The hazards in mining coal and other materi- secure compliance with the Act. The amount als, and the need to provide for the health and of a bond depends on the characteristics of the safety of the Nation’s miners, have long been site, but must be sufficient to cover comple- matters of Federal law. The Federal Mine Safe- tion of the reclamation plan if the work had to ty and Health Act of 1977’s is the most recent be performed by the regulatory agency. Where expression of congressional intent to remedy reclamation is difficult and therefore expen- unsafe conditions and practices and to reduce sive, performance bonds may be difficult to the number of mining fatalities and injuries. secure. The Small Business Administration, The 1977 Act is based on the Federal Coal which guarantees bonds from private sureties Mine Health and Safety Act of 1969; it incor- in other industries, reportedly does not plan to porates many of the provisions of the 1969 Act do so for coal mine reclamation. ” I n addition, but increases the level of protection for where the adverse impacts of mining may not miners. become apparent until long after mining has The 1969 Act complemented the earlier ceased (for example, acid drainage from un- Metal Act, ’” which regulated the occupational derground mining), the period of liability may health and safety of all miners except coal be insufficient. miners, and represented a direct response to The mining industry has been highly critical the number of deaths and serious injuries from of SMCRA. The principal complaints include unsafe and unhealthy conditions and practices the complexity and detail of the regulations in coal mines. To remedy these abuses, the Act and the resulting increased costs of mining and established interim mandatory health and safe- reclamation. The industry argues that the Act ty standards and directed the Departments of and OSM’s draft regulations are too detailed the Interior and of Health, Education, and and do not permit a mine operator to tailor the Welfare to develop permanent standards; to engineering designs to site specific factors. ensure that mine operators comply with those The result, according to industry, will be sub- standards; to provide benefits for victims of stantial increases in the cost of mining and rec- black lung; and to assist the States in develop- lamation, and therefore in the cost of coal. ing and enforcing effective health and safety Many of these requirements will be made more programs. flexible in OSM’s final regulations, issued spring of 1979. However, much of the speci- Implementation and enforcement of the ficity is written into the Act itself and must be mandatory standards established under the 1969 Act resulted in dramatic decreases in the changed legislatively. Once these changes have been made, the cost increases attributable to SMCRA probably will not be substantial enough to limit either the supply of or demand for coal. For example, OSM’s cost analysis of the discretionary portions of the Act (that is, excluding the requirements that were

“’’Excessive Regulation Drowns the Industry, ” Coal Age, January 1979, pp. 11-13. 346 ● The Direct Use of Coal

number of coal mine fatalities and injuries. By enacting the Federal Mine Safety and However, a 1974 report on occupational safety Health Act of 1977, Congress combined pro- and health21 found that the incidence of work- tection of all miners under a single comprehen- related injuries and illnesses for miners still ex- sive law that adopts the best features of both ceeded the “all industry” rate by about 14 per- earlier statutes relative to health and safety. cent. Work-related deaths showed, even more Insofar as the 1977 Act’s objectives affect coal forcefully, the continuing inadequacy of mine mine productivity, the Act adopts the consen- safety and health laws and their enforcement. sus of labor and industry witnesses that a safe According to this report, about 1 of every 1,500 coal mine is also a productive mine. The resuit- mine workers was killed on the job or died ing extensions of regulatory power in coal min- from work-related injuries or illnesses in 1973. ing are more the product of technical improve- This compared with 1 of every 2,800 railroad ments in the standard-setting and enforcement workers, 1 of every 4,000 construction workers, process than substantial departures from prior and only 1 of every 12,400 for al I workers cov- law. ered by the Occupational Safety and Health The 1977 Mine Safety and Health Act Administration. adopted the provisions of the 1969 Act that In 1977 the Senate Committee on Human prescribed mandatory health and safety stand- Resources drew a number of conclusions from ards and provided black lung benefits. That its oversight of the Metal Act and the 1969 these parts of the Act were not appreciably Coal Act: altered is consistent with the legislative intent First, the Metal Act does not provide effec- that standard-setting and enforcement proce- tive protection for miners from health and dures be made uniform throughout the mining safety hazards and enforcement sanctions industry whiIe the standards themselves re- under that Act are insufficient to encourage main responsive to the characteristics of dif- compliance by operators. ferent segments of the industry. Second, enforcement of safety and health laws should be the responsibility of agencies Although much of the 1969 Coal Act re- which are generally responsible for the needs mains as it was, several important changes are of workers. expected to increase the level of safety and Third, both the Coal and the Metal Acts do health protection in the Nation’s coal mines: not provide means to react quickly enough to standard-setting and enforcement provisions newly manifested health hazards. were made more effective, admininstration Fourth, the procedures by which safety and was transferred from the Department of the In- health standards are made under both the terior to the Department of Labor, the Federal Metal and the Coal Act are much too slow and Mine Safety and Health Review Commission cumbersome for standards promulgated under those Acts to keep pace with developments in was established, mandatory health and safety a dynamic and expanding industry. training of miners was instituted, and the exer- Fifth, the assessment and collective civil cise of safety and health rights by miners was penalties under the Coal Act have resulted in given added protection and support. penalties which are much too low, and paid Past procedures for promulgating and revis- much too long after the underlying violations to effectively induce meaningful operator ing standards in both the Metal and the Coal compliance. Acts had resulted in long delays between the Sixth, enforcement sanctions under the cur- perception of needed improvements and the rent laws are insufficient to deal with chronic implementation of new or revised standards. violators. 22 Each step in the process now requires compliance within a specified period. Enforcement “Annual Report on Occupational Safety and Health procedures now also must comply with a more (Washington, D. C.: U.S. Department of Labor, Occupa- rigorous timetable. tional Health and Safety Administration, 1974). ‘zSenate Report No. 95-181, 95th Cong., 1st sess., Fed- A key element of the 1977 Act is the shift of eral Mine Safety and Health Act of 1977, p. 7. administration from the Department of the In- ‘ Ch. V1l—Present Federal Coal Policy ● 347 terior to the Department of Labor, Interior’s re- their normal rate of pay and any costs incurred sponsibility for maximizing energy resource while attending this training. If an inspector development was found to be incompatible determines that any miner has not received the with concurrent responsibilities for enforcing requisite training, then the miner must be with- mine safety and health regulations; the Labor drawn from the mine until his training is com- Department was perceived as having but one plete. Any miner so withdrawn may not be dis- purpose: the welfare of the workers. The re- criminated against by the operator and is en- sponsibilities of Interior’s Mining Enforcement titled to fulI compensation during the training. and Safety Admininstration also have been transferred to the Department of Labor, where Congress expressed its displeasure with the an Assistant Secretary for Mine Safety and Interior Department’s repeated attempts to Health will preside over the new Mine Safety restrict miners’ protection from retaliation for and Health Admininstration. engaging in safety activity by changing not only the substantive aspects of the antidis- Under the 1969 Coal Act, review of con- crimination provisions but also the procedural tested matters was an internal function of the aspects. Under the new provisions, once a Secretary of the Interior, who established a complaint is filed, the Secretary must conduct Board of Mine Operations Appeals to separate an investigation. If as a result of the investiga- prosecutorial and investigative functions from tion the Secretary believes that a violation has his adjudicatory functions. With the transfer of occurred, the Secretary must file to intervene administration to the Department of Labor, a in the proceedings and attempt to prove to the similar system was considered but ultimately Commission that a violation has occurred. If rejected. While recognizing organizational and the Secretary concludes that no violation oc- administrative drawbacks, Congress was per- curred, the miner can still prosecute a case suaded to establish a completely independent before the Commission. Even where the Secre- adjudicatory authority, the Mine Safety and tary participates in the proceedings, the miner Health Review Commission. An independent has the right to offer evidence, cross-examine commission was considered essential to pro- the respondent’s witnesses, and generally par- vide administrative adjudication that pre- ticipate as a party. In both the 1969 Act and serves due process and instills more confi- the 1977 Act, the miner is entitled to an award dence in the program. Affected miners or their of attorney’s fees if a violation of the anti- representatives have an opportunity to par- discrimination provision is proved. The 1977 ticipate in the Commission’s proceedings, and Act, in clearly setting out the procedural steps it is the intent of Congress that the Commission in an antidiscrimination proceeding and clear- develop procedures to facilitate the participa- ly delineating the role of the Secretary, has tion of parties appearing pro se or not repre- greatly strengthened the antidiscrimination sented by counsel. This attention to adjudica- provision. tive detail and purpose is better suited to serving both the interests of the parties and the One of the most valuable provisions in the underlying purposes of the Act. 1977 Act is the possibility of temporary reinstatement. Under the 1969 Act, miners often One of the historic problems in the Ameri- were severely disadvantaged if they chose to can coal industry has been the inadequate prosecute complaints, including significant training afforded coal miners. Many miners economic hardship during the 1 or 2 years it stilI go underground with Iittle or no training might take to litigate their claims. The 1977 and, until very recently, the Federal require- Act solves this problem by requiring the Secre- ments for training were weak. The 1977 Act tary to make an initial determination, after a provides for at least 40 hours of training for factual investigation of a discrimination com- new underground miners, 24 hours for new sur- plaint, as to whether the miner’s complaint is face miners, and 8 hours per year of refresher frivolous. If the Secretary determines that the training for all miners. Miners must be paid complaint is not frivolous, the Secretary must 348 ● The Direct Use of Coal petition the Commission for temporary rein- ator” is expanded to include any independent statement of the miner, and the Commission contractor performing construction services at must order reinstatement absent a showing of a mine. Thus, employees of mine construction bad faith on the part of the Secretary. This sim- contractors now are considered miners and the ple measure should go a long way in providing Secretary should be able to issue citations, practical protection for the miners who exer- notices, and orders, and the Commission cise their safety rights and are discharged as a should be able to assess civil penalties, against result. these contractors. Statistics on mine-related deaths and injuries also will be more accurate Both the 1969 and the 1977 Acts provide for because these contractors previously were not reinstatement with back pay for discharged required to comply with recordkeeping and re- miners who prevail on their discrimination porting obligations. claims. The 1977 Act also provides for interest on an award of back pay to compensate min- I n addition, some penalties have been made ers for the loss of wages during Iitigation. more harsh, the collection of fines has been facilitated by an 8-percent interest charge, and The loss of income that occurs when a miner an additional enforcement mechanism, injunc- is fired presents serious problems that back tive-type relief, has been adopted to provide a pay and interest alone may fail to remedy. flexible method of dealing with habitual or Neither the 1969 Act nor its legislative history chronic violators of the Act. explicitly provided for the award of special damages to a miner who had been discrimi- nated against for attempting to enforce safety Because the 1977 Act is modeled on its pred- rules. Not surprisingly, the Interior Department ecessor, the Mine Health and Safety Act of never exercised its discretionary authority to 1969, no substantial adaptations by the coal in- award special damages, even where clear eco- dustry appear necessary. While noncoal min- nomic damages resulted from a discriminatory ing operations previously subject to the Metal act. The legislative history of the 1977 Act re- Act may face adjustment difficulties, coal in- jects the Interior Department position and spe- dustry and labor familiarity with the prior law cifically authorizes the award of special dam- should permit a relatively smooth transition. ages. In addition to compensatory relief, the Increased operating costs may result from 1977 Act anticipates the use of affirmative re- mandatory safety and health training, but lief, such as a cease and desist order, where ap- whether the total additional costs directly propriate. associated with the legislation represent a net loss to the operators remains unclear,

The Federal Mine Safety and Health Act of 1977 is not a major departure from prior law Costs and benefits associated with safety governing the operators of the Nation’s coal and health regulations have been difficult to mines, Those most affected wilI be miners em- define accurately. If productivity can be im- ployed in other mining sectors and mine oper- proved as a result of vigorous Federal enforce- ators. The present law does represent an increment and operator compliance, all parties will mental improvement, however, in what is an benefit. If productivity remains unchanged or ongoing congressional effort to reduce mining declines, however, coal consumers can be ex- deaths and injuries to the lowest practicable pected to share the burdens of improving the levels. In addition to the major changes al- safety and health of the Nation’s miners. Not ready discussed, several smaller amendments unmindful of these costs, Congress has never- in the law can be expected to further these ob- theless declared mine safety to be an overrid- jectives. ing concern, and the several changes described can be expected to lessen the annual rate of For example, the definition of a mine “oper- mining deaths and injuries. Ch. VII—Present Federal Coal Policy ● 349

The Clean Air Act and the preservation of States rights. Those factors that were deemed to require national In drafting the Clean Air Act Amendments of uniformity in order to prevent regional subver- 23 1977, Congress was aware of the related but sion of the Act’s goals or regional economic often conflicting demands of environmental advantages included numerical standards for and energy policies. However, the amend- how clean the air must be and for emissions of ments do not always refIect a consistent uni- airborne polIutants from future sources as well fied approach to the fundamental problems in- as guidelines for air quality control plans. The volved, and the overaIl effect of the Act is dif- States were required to devise and implement ficult to assess. To the extent that coal-fired fa- plans in accordance with these guidelines for cilities have a greater potential for emitting air achieving and maintaining the specified levels pollutants than do facilities using other energy of air quality. The Act also allowed the States sources, they may require greater expenditures to set more stringent standards. This funda- for pollution control equipment under the Act mental role division continues under the 1977 or be subject to stricter siting and other pre- amendments, which were intended to remedy construction review procedures and thus may problems that had developed under the 1970 be at a competitive disadvantage. On the other Act and to strengthen some regulatory pro- hand, some provisions of the Act exempt coal- grams. burning sources from regulatory restrictions applicable to other fuels. Still other provisions National Ambient Air Quality Standards limit the growth and development of all stationary sources in certain areas. The central feature of the 1970 Clean Air Act Amendments was the requirement that EPA It is not possible to quantify the impact of promulgate National Ambient Air Quality any of these provisions on increased coal use, Standards (NAAQS). NAAQS define air quality much less to assess their combined impact. in terms of ambient concentrations of pollut- Such an analysis would require a major techni- ants. These standards represent target levels cal and economic inquiry. Rather, this section for air quality; they do not regulate emissions identifies and briefly discusses the nature of from individual sources. The amendments re- the Clean Air Act provisions that affect the use quired two sets of standards that reflected the of coal by new fossil-fuel-fired sources as well latest scientific knowledge about the effects of as the conversion from oil or gas to coal by ex- various air pollutants. Primary standards were isting sources. Some of these provisions have intended to protect public health; secondary been in effect since 1970; others are included standards were designed to protect the public in the 1977 amendments. welfare from polIution damage to soils, vegetation, animals, materials, and other environ- Background and History mental factors not related to human health. Before 1970, air pollution control essentially Pursuant to the 1970 amendments, the EPA was left to the States, with the Federal Govern- Administrator listed six pollutants as having ment providing technical and financial assist- potentially adverse effects on public health ance for planning and for R&D. The Clean Air and welfare and established primary and sec- Act Amendments of 197024 inaugurated direct ondary NAAQS for each. Standards have been Federal regulation, mandated specific State established for sulfur oxides (SOX) (measured implementation plans (SIPs), and required Fed- as sulfur dioxide (S0 )), particulate matter, ni- eral intervention in the absence of State ac- 2 trogen dioxide (N0 ), hydrocarbons, photo- tion. 2 chemical oxidants, and carbon monoxide (CO); The 1970 amendments represented a bal- standards for lead were proposed in 1978. ance between uniform national requirements Under the 1977 amendments, these standards are to be reviewed and revised if necessary every 5 years beginning in 1980. The standards

for SOX, particulate matter, and NO2,, the pri- 350 The Direct Use of Coal

mary byproducts of coal combustion, are needed to attain the standards and on the listed in table 58. social, economic, and technological problems involved in doing so. However, as of 1977, 116 Table 58.—Standards for Particulate Matter, of the 247 ACQRS reported violations of the Sulfur Dioxide, and Nitrogen Dioxide primary annual particulate standard while 108 Averaging Primary Secondary reported violations of the 24-hour standard. Pollutant time standard standard Similarly, 12 ACQRS reported violations of the

primary annual S02 standard while 37 reported violations of the 24-hour standard. zs The 1977 amendments require the States to revise their S1Ps by 1979 in order to provide for attainment of the primary standards by 1982. However, the amendments did not change the “reasonable time” requirement for achieving the secondary standards.

New Source Performance Standards The Clean Air Act Amendments of 1970 required the EPA Administrator to establish These ambient air quality standards are im- standards of performance for large new or plemented at the national level through stand- substantially modified stationary sources to ards of performance for new stationary ensure that they would not exacerbate existing sources and guidelines for State control strat- air quality problems or contribute to new ones. egies for existing sources as well as through Under the 1970 Act, New Source Performance guidelines for regulatory programs designed to Standards (NSPS) included federally deter- improve air quality in areas that have not at- mined allowable rates of emissions from 19 tained the national standards, to prevent deg- categories of sources. S1Ps were required to in- radation of air quality in areas cleaner than the clude a procedure for preconstruction review national standards, and to protect visibility in of new sources to ensure that these standards important scenic areas. were met.

The State role centers on the preparation The 1977 amendments significantly tight- and implementation of a plan, consistent with ened these requirements. In order to meet EPA guidelines, that sets out control strategies NSPS, 28 categories of sources now must apply for meeting and maintaining NAAQS in vari- the best technological system of continuous ous parts of the State (known as air quality emission reduction that has been demon- control regions (ACQRs)). States have consid- strated adequately. In addition, fossil-fuel- erable discretion in deciding what emission fired sources are subject to an enforceable limitations and other controls on individual percentage reduction in emissions that would sources to use in cleaning up their air, as long have resulted from the use of untreated fuels. as their SIPs are shown to be capable of In determining which technological systems achieving the national standards. of continuous emission reduction have been The 1970 Act required the States to attain demonstrated adequately, the EPA Administra- the primary standards as expeditiously as prac- tor is required to consider the energy require- ticable but not later than 3 years after the date ments of a technology as well as its cost and the S1P became efective. The S1Ps also were re any nonair quality health and environmental quired to specify a reasonable time at which impacts. I n calculating the percentage reduc- the secondary standards would be achieved; tion requirements, the Administrator may give “reasonable time” was defined by EPA to depend on the degree of emission reduction 2543 F,R, 8962 (Mar. 3, 1978). Ch. VII—Present Federal Coal Policy ● 351 credit for mine-mouth and other precombus- positive net air quality benefit results. LAER tion fuel-cleaning processes. NSPS have been must reflect the most stringent emission rate promulgated for fossil-fuel-fired steam gener- required by any State or the lowest rate ators and for coal preparation plants. EPA achieved in practice, if the latter is more strin- plans to announce new standards for industrial gent. In no event, however, may emissions boilers in 1980. from a source subject to LAER be allowed to exceed the applicable NSPS. As discussed in chapter IV, the NSPS provisions in the 1977 amendments have become This offset policy applies to any source controversial. If the final regulations require capable of emitting 100 tons per year of a pol- continuously operating flue-gas desulfuriza- lutant that would exacerbate an existing tion (FGD) systems, it probably will promote NAAQS violation. EPA has announced that it the use of locally available high-sulfur coals, will implement the policy through the use of especially in the Midwest, while removing the significance levels patterned after the preven- advantage that accrued to low-sulfur coal tion of significant deterioration (PSD) incre- under the previous regulations. 1 n addition, a ments (see below). A source will not be consid- continuous control requirement could delay ered to exacerbate air quality problems if its the construction of new coal-fired power- emissions are below the specified significance plants, causing a greater reliance on exisiting level. ” plants than would have occurred under the previous regulations. zb Regardless of whether Whether a source is subject to the offset the final regulations require full, partial, or a policy is determined on a case-by-case basis sliding-scale control, they will increase the pol- through air quality modeling. Thus a source lution control costs of new coal-fired plants. still could be located in an AQCR with localized violations so long as its emissions will not Nonattainment Areas exacerbate those local violations. The 1970 Clean Air Act Amendments did not After June 30, 1979, construction of new or specify the consequences of a State’s failure to modified stationary sources that would ad- attain NAAQS by the deadline While EPA reg- 27 versely affect air quality in nonattainment ulations promulgated in 1976 filled this gap to some extent, it was clear that congressional areas must be prohibited unless the applicable guidance was necessary. Consequently the SIP meets the requirements of the 1977 amend- 1977 amendments add new requirements that ments. SIP revisions must provide for attain- must be incorporated into all SIPS by July ment of the primary standards not later than 1979. 1982, and in the interim must require annual incremental emissions reductions from existing The 1977 amendments basically adopt EPA’s sources through the implementation of reason- 1976 offset policy for nonattainment areas un- ably available control measures. til July 1979. In general, this policy imposes the following conditions for the issuance of con- As with the new NSPS requirements, EPA’s struction permits for new or modified sources offset policy is controversial. It places signifi- in nonattainment areas: the source meets the cant constraints on siting in many areas be- lowest achievable emission rate (LAER), the cause the offsetting reductions are difficult to permit applicant certifies that all its other obtain and LAER is expensive to meet; siting facilities are in compliance with all applicable constraints could become even more severe if Clean Air Act control requirements, the permit SIP revisions are not accomplished in a timely applicant has secured emissions reductions manner. I n addition, most industries feel it is from existing sources that more than offset the inappropriate to place the burden of securing emissions from the proposed source, and a emission reductions on the private sector

2643 F R. 42154 (Sept 19, 1978) 2741 F R 55524 (Dee 21, 1976). *44 F.R, 3274 Jan 16, 1979). 352 The Direct Use of Coal rather than on Government. 29 Although many The PSD regulations could constrain the States are expected to adopt E PA’s offset pol- development of coal combustion facilities in icy in their SIP revisions, they are being en- two main situations: where the difference be- couraged by EPA to experiment with alterna- tween the baseline concentration and the max- tive programs for cleaning up “dirty air” areas, imum allowable increase already is lower than such as emission taxes, or banking of emission the applicable increment, and where sources reductions to allow for future growth. 30 that are exempt from PSD review (because of their size or date of construction) will use up Prevention of Significant Deterioration/ available increments. However, a 1975 Federal Visibility Protection Energy Administration (FEA)/E PA study of the effects of the then-pendin PSD legislation on The 1970 Clean Air Act Amendments merely g the electric utility industry concluded that the required EPA and the States to achieve and requirements would not significantly hamper maintain NAAQS; they did not address the siting of even the largest sources of air pollu- question of air quality in areas already cleaner tion. J2 These conclusions are summarized in than NAAQS require. In 1972 environmental appendix XVI of volume 11. In addition, the groups brought suit against EPA to prohibit the study analyzed the economic impacts of PSD Agency’s approval of S1Ps that failed to pre- requirements on the utiIity industry; it con- vent significant deteriorate ion of air quality. Re- cluded that the industry’s total capital require- lying on the Act’s stated purpose of protecting ments and annual operatin costs as well as and enhancing the Nation’s air quality, the g the costs to consumers would increase less court ordered EPA to develop a program to than 3 percent to the year 1990. prevent the degradation of air quality in clean air areas. EPA’s PSD regulations were pro- Siting considerations also could be affected mulgated and incorporated into all SIPS in by regulations intended to protect visibility in 1974, and were adopted with some changes in Class I areas (national parks and wilderness the 1977 amendments. areas subject to the lowest PSD increments) primarily valuable for scenic factors. The 1977 In general, the PSD program divides clean amendments established a national goal of air areas into three classes and specifies the preventing any future—as well as remedying maximum allowable increases in ambient con- any existing— impairment of visibility in these centrations of pollutants, or PSD increments, areas. By August 1979, EPA is required to pro- for each class. mulgate regulations to assure reasonable prog- As discussed in chapter IV, construction of a ress toward meeting the national goal, taking major emitting facility (defined to include into account the economic, energy, and envi- most large fossil-fuel-fired steam electric ronmental costs of compliance. In addition, plants and other coal-burning sources) that will States must revise their SIPs to require all exist- affect air quality in a clean air area is subject ing major stationary sources constructed in the to extensive preconstruction review and per- last 15 years to install the best available retro- mit requirements. Review of a permit applica- fit technology for controlling emissions that tion must be preceded by an analysis of the may impair visibility. A principal contributor ambient air quality at the proposed site and in to reduced visibility is fine particulate matter; areas within 50 km downwind that may be af- these particles are not captured by the current fected by emissions from the proposed facility. technology-of-choice, electrostatic precipitators. Their control may require the use of baghouses, a costly alternative. However, the Act does provide exemptions for sources that

‘2An Analysis of the Impact on the Electric Utility In- dustry of Alternative Approaches to Significant Deteriora- tion (Washington, D.C : Federal Energy Administration and Environmental ProtectIon Agency, October 1975) Ch. VII—Present Federal Coal Policy ● 353

can demonstrate that they will neither cause August 1979; background documents on the nor contribute to a significant impairment of sources, health effects, population exposures, visibility in mandatory Class I areas, or where and risks associated with the other pollutants the costs of compliance would be too high (for were available for public comment in spring example, if the source is scheduled for retire- 1978. All of these pollutants are present in ment soon). Until the final regulations are pub- trace amounts in the fly ash of coal emissions; lished, it is not possible to estimate the extent moreover they are concentrated preferentially to which visibility protection requirements will on the fine particulate matter that conven- constrain increased coal consumption. tional control technologies do not remove effectively. Baghouses entailing large costs and EPA Studies and Potential New Standards space requirements would be required to cap- I n adopting the 1977 amendments, Congress ture these materials if the standards mandated directed EPA to undertake an extensive review highly efficient removal. of existing standards and to study potential Finally, EPA currently is developing a stand- new standards. To the extent that E PA’s efforts ard for the control of sulfates, a transforma- result in tightening existing standards or in pro- tion product of S0x. Sulfates also adhere to mulgating new standards, these provisions may fine particulate and contribute to visibility impose new and potentially costly constraints impairment and acid precipitation, primarily on the use of coal. At this time, however, it is in the Northeast. A stringent sulfate standard possible only to identify the areas of potential may impose severe constraints on new coal- concern. fired sources in the Eastern United States. The amendments require EPA to review air quality criteria and NAAQS by the end of 1980, Interface With Energy Legislation and every 5 years thereafter, and to revise the The Energy Supply and Environmental Coor- criteria and standards as appropriate. Any revi- dination Act (ESECA) of 19743’ (discussed be- sion of a NAAQS for a pollutant may result in low) amended the Clean Air Act to provide for major changes in SIPs and control require- coordination between national energy and air ments applicable to sources of that pollutant. quality goals. E PA’s primary responsibilities I n addition, the amendments direct EPA to pro- under ESECA were to determine the earliest mulgate a 3-hour primary standard for NO , 2 date that a source converting to coal could unless EPA determines that there is no signifi- meet applicable air polIution control require- cant evidence that this standard is necessary. ments and, if necessary, to grant an order to A stringent short-term NO standard may re- 2 the source extending its date of compliance quire flue-gas denitrification, a technology with the Clean Air Act. The 1977 Clean Air Act that is not expected to be available until after Amendments repealed this requirement under 1985. ESECA and placed E PA’s coal conversion over- Another provision of the amendments re- sight within its general authority to grant de- quires EPA, in conjunction with the National layed compliance orders. Academy of Sciences, to complete a study of In 1978, ESECA was replaced by the Power- the health effects of fine particulate; prelimi- plant and Industrial Fuel Use Act” (see below), nary findings will be published by June 1979. which prohibits the use of oil or natural gas as The amendments also require EPA to deter- a primary energy source in new fuel-burning in- mine whether emissions of radioactive pollut- stallations and the use of natural gas in exist- ants, cadmium, arsenic, and polycyclic organic ing facilities after 1990. Temporary and perma- matter may endanger public health. If EPA nent exemptions from these prohibitions are finds that these emissions do pose a hazard to human health, then EPA must establish air “Public Law 93-319 (June 22, 1974), as amended by quality standards, NSPS, or hazardous pollut- Public Law 94-163 (Dee 22, 1975) and Public Law 95-70 ant standards for them. For radioactive pollut- (July 21, 1977) ants, EPA must make this determination by “Public Law 95-620 (Nov 9, 1978) 354 ● The Direct Use of Coal provided for facility operators who demon- such as fossil-fuel-fired powerplants monitor strate that they cannot meet the prohibition their emissions. A condition for EPA approval without violating environmental requirements of SIPs is that they include requirements for such as emissions limitations; the operator the installation of monitoring equipment and must demonstrate that he has made a good for the submission of periodic reports on the faith effort to comply with environmental re- nature and amount of emissions. In addition, quirements before he is entitled to use gas or EPA has independent authority to require a oil instead of coal. The Act specifically states source to monitor and report its emissions that it is not intended to permit any existing or when EPA determines that this information is new facility to delay or avoid compliance with required to assess compliance with the Act. applicable environmental requirements. Monitoring data are used in conjunction The 1977 Clean Air Act Amendments en- with dispersion modeling techniques in order courage increased coal use through measures to determine a source’s impact on air quality designed to prevent significant local or region- under a variety of Clean Air Act provisions. al economic disruption or unemployment. Current regulations limit the applicability of Where a source or class of sources intends to air quality models to a downwind distance of use petroleum products, natural gas, or non- not more than 50 km.35 However, recent re- local coal in order to comply with the Clean search suggests that under certain meteoro- Air Act requirements, and it is determined that logical conditions, such as after prolonged the result would be local economic disruption periods of stagnation or during extremely per- or unemployment, the President can prohibit sistent winds, air pollutants and their transfor- the source from using any fuel other than mation products may be transported over locally or regionally available coal. A source distances greater than 50 km. To the extent may be ordered to enter into long-term con- that this longer range transport of pollutants tracts of at least 10 years for supplies of local occurs and is not regulated directly, it may in- coal as well as contracts to acquire additional terfere with enforcement of measures directed pollution controls. This provision does not ex- at visibility protection and it may consume empt a source from the requirements of the PSD increments in clean air areas or contribute Act, but prevents it from relying on fuels with a to NAAQS violations in nonattainment areas sulfur content lower than that of locally avail- downwind. Thus the limits imposed on air able fuels. quality modeling may further constrain siting downwind. Implementation of the Amendments Finally, the 1977 amendments enhance This review of the 1977 amendments indi- EPA’s enforcement authority in several impor- cates that, if effectively implemented, the Act tant respects. First, EPA now has the authority may increase the costs of coal utilization and to seek civil penalties to a maximum of may impose siting constraints in both dirty and $25,000 per day of violation. Second, criminal clean air regions, primarily in the vicinity of actions now may be brought against any re- Eastern and Western coal resources. However, sponsible corporate officer. Third, and most the extent to which the environmental and important, the amendments provide for the im- health objectives of the amendments are position of noncompliance penalties that oper- achieved and, conversely, the extent to which ate in addition to the other penalty provisions. substantial constraints on increased coal use These noncompliance penalties essentially re- are created, depend on the implementation of move the economic advantages accruing to a the Act. Major implementation factors to be noncomplying source. The Act sets forth elab- considered include monitoring requirements, air quality modeling, and the level of enforcement. 3543 F.R. 26380 (June 19, 1978). See also Guideline on Air Quality Mode/s (Research Triangle Park, N. C.: U.S. The Act contains several provisions de- Environmental Protection Agency, April 1978), OAQPS signed to ensure that major stationary sources 1.2-080. Ch. VII—Present Federal Coal Policy 355 orate procedures and standards for this penal- to remedy existing pollution control problems ty provision, which, in general, requires a the Agency is unable to allocate funds to the source not in compliance as of July 1979 to anticipation of future control problems. pay a quarterly penalty equal to the money Conclusions saved during that quarter as a result of noncompliance. The Clean Air Act of 1970 failed to achieve the primary NAAQS nationwide by the target However, a variety of problems still exist in date of 1975. In 1977 Congress responded with enforcing the Clean Air Act and in air quality thorough revisions of the Act in order to management in general. Gaps may be created achieve those standards in areas that had not in the ability to enforce the Act when new reg- done so and to protect the quality of the air in ulations are challenged in court (as they al- regions that already are cleaner than NAAQS. most always are). New regulations supplant old Whether in light of continued industrial ones, yet the courts will grant a stay of en- growth the new amendments will achieve the forcement of the new ones, leaving EPA with desired air quality is uncertain. In an effort to nothing to enforce. In addition, enforcement do so, however, the amendments may impose problems may occur from a lack of communi- new constraints on stationary sources. cation among the various agencies and governments involved. Thus action taken by the De- whether the 1977 amendments will impede partment of justice, the EPA Office of General increased coal use is largely a question of eco- Counsel, or the State may undercut enforce- nomics. Within certain limits, increased costs ment actions in progress at the EPA regional resulting from clean air requirements, such as offices. Similarly, there is a general lack of in- NSPS, will not significantly affect the amount tegration within EPA for overall environmental of coal used; fuel demand has been shown to management strategies. Personnel responsible be rather unresponsive to moderate price infor developing air programs may be unaware creases. However, regulations that may delay of the implications of their actions for solid the siting of facilities, such as those for nonat- waste disposal or water pollution and vice tainment areas and for PSD, or that may sub- versa. stantially increase the cost of new facilities, could encourage greater reliance on existing General air quality management also is con- capacity in Iieu of new plants. I n addition, pro- strained by States rights in that administration visions of the Act that require stringent con- of the Clean Air Act must be turned over to the trols regardless of the sulfur content of the fuel States as soon as their SIPs meet the minimum may tend to favor production of locally avail- requirements, yet the States may not be ready able high-sulfur coals over higher priced low- or able to administer and enforce the Act ade- suIfur coal. quately. Conversely, whenever a State program falls below the minimum requirements, The Clean Water Act administration and enforcement revert to the Water pollution associated with the direct EPA regional office regardless of whether that use of coal stems from three major sources: off ice has sufficient funds or personnel. surface and deep mining operations, prepara- In addition, most of the Clean Air Act re- tion plants (including ancillary storage areas quirements are dependent on the technologi- and washing facilities], and combustion facil- cal and economic availability of control tech- ities. Effluents from these sources are regu- nology, yet the Act places most of the burden lated under the Clean Water Act36 (formerly for developing that technology on Federal known as the Federal Water Pollution Control R&D programs that are not funded adequately. Act) through ambient water quality standards, A shift in regulatory philosophy that would effluent limitations for new and existing force industry to take the initiative, such as an sources, I imitations on thermal discharges, per- emissions tax, could alleviate some of EPA’s mit programs, and areawide planning. management problems. Finally, because EPA must use its available R&D funding to attempt 3633 u S.C. 466 et seq. 356 ● The Direct Use of Coal

Water Quality Standards the normal water temperatures, flow rates, seasonal variations, existing sources of heat input, Section 101 of the Clean Water Act estab- and the dissipative capacity of the waters, and lishes two national water quality goals. The also must include a margin of safety that takes first, to be achieved by 1983, is an interim goal into account any lack of knowledge about the that provides for the protection and propaga- development of thermal water quality criteria. tion of fish, shellfish, and wildlife and for recreation in and on the water. The second national goal is the elimination of all pollutant dis- Effluent Limitations charges. The States have the primary responsi- Effluent limitations are restrictions estab- bility for achieving these goals and for plan- lished by a State or the EPA Administrator on ning the development and use of land and quantities, rates, and concentrations of chemi- water resources consistent with them. In 1977, cal, physical, biological, and other constitu- Congress recognized that significant progress ents that are discharged from point sources. Ef- toward these goals was not being made and fluent limitations may be categorized by: 1) that the discharge elimination goal probably is the sources for which they have been estab- unrealistic. Accordingly, the Clean Water Act lished, 2) whether those sources discharge di- Amendments of 1977 extended the deadline rectly into receiving waters or into a publicly for compliance with the stricter limitations owned treatment works, and 3) the degrees of under the Act by 1 to 3 years. control required for each category of sources Each State is required to develop and imple- or pollutants and the dates those controls be- ment, subject to the approval of the Adminis- come mandatory. trator of EPA, a comprehensive water quality In general, the 1977 amendments require all management plan that includes water quality categories of point sources to apply the best standards. These standards consist of the des- practicable control technology currently avail- ignated uses of the waters involved, including able (BPCTCA) not later than July 1, 1977. their use and value for public water supplies; Those point sources that discharge conven- propagation of fish and wildlife; recreational, tional pollutants (including, but not limited to, agricuItural, industrial, and other purposes; pollutants classified as biological oxygen de- and navigation. In addition, the standards in- manding, suspended sol ids, and hydrogen-ion clude water quality criteria for the waters concentration (p H)) must apply the best con- based on these uses. ventional pollution control technology In general, the water quality standards are (BCPCT) not later than July 1, 1984. Finally, all to be achieved through effluent limitations on categories of point sources must apply the best discharges from point sources (see below). avaiIable technology economically achievable However, for those waters for which the ef- (BATEA) that will result in reasonable further fluent limitations are not stringent enough to progress toward the stringent discharge elimi- implement the applicable water quality stand- nation goal if the Administrator finds that the ard, the State must establish a total maximum goal is technologically and economically daily load for the relevant pollutants. This load achievable. BATEA is required not later than 3 must be established at the level necessary to years after the date the effluent limitations for implement the applicable water quality stand- a pollutant have been established or by July 1, ards with seasonal variations and a margin of 1984, whichever is later, but in no case later safety that takes into account any lack of than July 1, 1987. In determining the control knowledge concerning the relationship be- measures and practices to be applicable to tween effluent limitations and water quality. point sources, the EPA Administrator must In addition, the State must estimate the total take into account the age of equipment and fa- maximum daily thermal load required to as- cilities involved, the process employed, the sure protection and propagation of a balanced engineering aspects of the application of vari- indigenous population of shellfish, fish, and ous types of control technologies, process wildlife. This estimate must take into account changes, and nonwater quality environmental Ch. VII—Present Federal Coal Policy ● 357

impacts (including energy requirements) as costs of achieving the limitation, including any well as the total cost of achieving the limita- economic or social dislocation in the affected tion in relation to the effluent reduction bene- communities, and the social, economic, and fits to be achieved. water quality benefits to be obtained; and 2) whether the limitation can be implemented Where pollutants are introduced into pub- with available technology or alternative con- licly owned treatment works they are subject trol strategies. to pretreatment standards to ensure that the effluent limitations applicable to the treat- The principal coal-based activities for which ment works will not be violated. I n addition, as effluent I imitations have been established are mentioned above, where the general effluent steam electric-power generation and coal min- limitations are not strict enough to contribute ing; these are summarized in tables 59 and 60. to the attainment or maintenance of the water The steam electric-power generating point quality goals for a particular stream, the EPA source category applies to all units that pro- Administrator may establish stricter standards duce electricity for distribution and sale. It is for point sources located along that stream, broken down further by the size and age of the These stricter, water quality related effluent unit. I n practice, however, neither the distinc- limitations must take into account: 1) the tions based on size and age of the facility nor tradeoff between the economic and social those based on degree of control required

Table 59.—Effluent Limitations: Steam Electric Power Generating Units Technology Measurement Source category requirement Type of discharge Pollutant Limitation time Generating unitb and small BPCTCA All except once-through pH 6.0-9.0 – At all times – unitc subcategories: and BATEA cooling water; existing and newd sources; all PCBS No discharge At all times old unite subcategory low-volume waste sources; TSS 100 mg/1 Maximum/day 358 ● The Direct Use of Coal

Table 60.—Effluent Limitations: Coal Mining Point Source Category

(BPCTCA or BATEA) is meaningful. As can be generating units and NSPS for generating units seen in table 59, except for pollutants from and for small units. corrosion-inhibiting materials, the effluent limitations are the same across the board. The Existing generating units are required to coal mining point source category applies to eliminate the discharge of heat from the main all active mining areas (surface and deep) in- condensers by July 1, 1981, through the appli- cluding secondary recovery facilities and prep- cation of BAT EA. Exceptions to this general aration plants but excluding surface mines in limitation include: which grading has been completed and recla- ● Blowdown from recirculated cooling mation work has begun. The limitations are water systems, provided the temperature broken down into those applicable to acid of the discharge does not exceed the low- drainage and to alkaline drainage. est temperature of recirculating cooling The EPA Administrator may modify any of water prior to the addition of the makeup the limitations for a point source if the owner water. (Systems technologically incapable of the source demonstrates that the modified of meeting this exception are exempt pro- requirement will represent the maximum use vided they begin construction prior to July of technology within his economic capability 1,1981 .); ● and will result in reasonable further progress Blowdown (overflow) from a cooling pond toward the discharge elimination goal.37 The under construction or in operation prior 1977 amendments provide that such a modifi- to July 1, 1981, and used to cool water cation is mandatory if the owner also demon- before it is recirculated to the main con- strates-that it will not interfere with attainment densers; ● of a water quality standard or the 1983 water Where sufficient land for mechanical quality goal, and it will not result in additional draft evaporative cooling towers is not requirements on any other point source. As available (on property owned before mentioned above, this provision reflects con- March 4, 1974) and where no alternate re- gressional doubt about the reasonableness and circulating cooling system is practicable; ● practicability of the 1985 discharge elimina- Where the total dissolved solids concen- tion goal. tration in blowdown exceeds 30,000 mg/1 and land not owned by the owner of the Thermal Discharges source is located within 150 m in the pre Limits on thermal discharges from steam vailing downwind direction of every prac- electric-generating plants are included in the ticable location for mechanical draft effIuent I imitations for those sources. These in- cooling towers and no alternate recircu- clude the BATEA requirements for existing lating system is practicable; and ● Where the cooling tower plume would, in the opinion of the Federal Aviation Ad- ministration, cause a substantial hazard to commercial aviation in the vicinity of a Ch. VII—Present Federal Coal Policy 359

major commercial airport and no alter- Federal licensing or permitting agency must nate recirculating cooling water system is condition the permit to ensure that all water practicable. 38 quality requirements will be met. In addition, when Federal regulations require only a con- In addition, the effective date of the retrofit re- struction permit, the certifying State must be quirement may be extended for from 1 to 2 given an opportunity to review the manner in years where reliability would be jeopardized which the facility will be operated in order to by timely compliance. ensure that water quality requirements will not The New Source Performance Standards for be violated. If the State finds that the oper- generating units and small units provide that ation of the facility will result in violations, the there shall be no discharge of heat from the Federal agency may suspend the license or per- main condensers except in the case of blow- mit. down from recirculated cooling water systems or from cooling ponds where the temperature NPDES is designed to ensure the orderly and of the blowdown does not exceed the lowest timely achievement of water quality goals temperature of recirculated cooling water without sacrificing economic or energy prior to the addition of the makeup water. In growth. Under NPDES, a facility may be issued addition, the Act requires that the location, a permit for a discharge on the condition that design, construction, and capacity of cooling the discharge will meet all applicable water water intake structures reflect the best tech- quality requirements. NPDES permits are is- nology available for minimizing adverse envi- sued under State programs approved by EPA, ronmental impacts (e. g., impingement and en- or, where a State program has not been ap- trainment). proved, by the EPA Administrator. The permits are for fixed terms not to exceed 5 years and Where these limitations on thermal dis- can be terminated or modified for violations. charges are deemed to be more stringent than Compliance with the conditions under which necessary for the protection and propagation an NPDES permit is issued is deemed compli- of a balanced, indigenous population of shell- ance with the effluent limitations and water fish, fish, and wildlife, the EPA Administrator quality standards promulgated under the may modify the thermal discharge limits for a Clean Water Act. source. In addition, sources upon which modifications are begun after 1972 and which, as modified, meet all applicable effluent limita- Areawide Planning tions, are exempt from more stringent limita- Section 208 of the Clean Water Act encour- tions for a period of 10 years following com- ages areawide land and water management pletion of the modifications. planning for regions with substantial water quality problems because of urban-industrial Permit Systems concentrations or other factors. The features Effluent limitations and water quality stand- of section 208 plans that could affect coal de- ards are implemented through State certifica- velopment include programs: tion programs and through the National Pollut- ant Discharge EIimination System (NPDES). 1. to regulate the location, modification, and construction of facilities that may An applicant for a Federal license or permit result in a discharge; to conduct any activity, including the con- 2. to control mine-related sources of pollu- struction or operation of facilities, that may tion including new, current, and aban- result in a discharge into navigable waters, doned surface and deep mine runoff; must obtain State certification that the dis- 3. to control construction activity-related charge will not violate any effluent I imitations, sources of pollution; and water quality standards, or NSPS. Where the 4. to control the disposal of residual waste discharge will affect more than one State, the material and of pollutants on land or in 38 ld. subsurface excavations. 360 ● The Direct Use of Coal

Section 208 programs were intended to pro- the characteristics of hazardous wastes, taking vide the long-range planning basis for the im- into account toxicity, persistence, and degra- plementation of other Clean Water Act pro- dability in nature, potential for accumulation grams. However, the other programs addressed in tissue, and related factors such as flamma- immediate pollution problems and received bility, corrosiveness, and other hazardous funding priority over section 208. Consequent- characteristics; and 2) based on these charac- ly, implementation of areawide land and water teristics, list particular hazardous wastes that management planning has been slow; to date will be regulated. only 9 of 216 plans have received final approval. For reasons primarily related to local The generator of a substance that is listed as politics, when the section 208 plans are im- a hazardous waste is responsible for its dis- plemented they are not expected to affect the posal in accordance with the applicable State siting of new coal combustion facilities signifi- plan. In addition, generators of hazardous cant y. wastes are subject to extensive recordkeeping provisions that require them to identify the Resource Conservation and quantities of wastes generated, the constitu- Recovery Act of 1976 ents of the wastes that are significant in quantity or in potential harm to human health or Prior to passage of the Resource Conserva- the environment, and the eventual disposition tion and Recovery Act (RCRA) of 1976,3’ the of the wastes. Finally, the generator must fur- Federal Government faced a policy vacuum in nish information on the general chemical com- regard to the control of solid wastes from coal- position of hazardous wastes to anyone trans- producing and coal-consuming facilities. Be- porting, storing, treating, or disposing the cause there were no major Federal programs wastes. related to the land disposal of solid wastes, disposal practices could not even be regulated The Act also imposes Government-wide re- indirectly through the requirements of NE PA. sponsibilities that affect coal production and Yet scrubbers eventually will produce large use. It requires Federal agencies to conform to quantities of sludge, and coal mines are EPA solid waste management guidelines if notorious for their waste piles. their activities, such as leasing or permitting, embrace production or disposal of solid In general, RCRA seeks to control open wastes, particularly hazardous solid wastes. dumping under a system of State plans and The impact of this provision is unclear until permits for solid waste disposal. All forms of the Act’s implementation by EPA is under- solid waste are covered, both hazardous and stood more fulIy within Federal agencies. How- nonhazardous, with more stringent regulations ever, it can be expected to involve operating for the former. In neither case, however, are agencies such as the Tennessee Valley Author- there prohibitions on waste disposal. ity and permitting agencies such as the Depart- The implementation of this Act by EPA ments of the interior and Agriculture, which could have far-reaching consequences for the grant mining leases and approve powerplants handling of solid wastes from coal production on Federal land. and use. For example, section 1004(5) of the The overaIl effect of RCRA probably will be Act defines “hazardous wastes” to include to increase the cost of waste disposal; the Act those which, because of their quantity, con- also could increase the amount of waste to be centration, or physical, chemical, or infectious disposed. If neither ash nor sludge is deter- characteristics may pose a substantial present mined to be hazardous, the costs of waste dis- or potential hazard to human health or to the posal could increase as much as 45 percent environment. Under section 3001, EPA is re- (see table 61). However, a preliminary analysis quired to: 1) establish criteria for identifying by the utility industry of various waste streams from coal-fired powerplants indicates that bottom ash, fly ash, and scrubber sludge all could Ch. V/l—Present Federal Coal Policy ● 367

Table 61.— Potential Sludge and Ash Disposal Costs Under RCRA

Percent increase —over base — Case 1: Ash: Nonhazardous Sludge: Nonhazardous...... 0.57-0.65 0.65-1.03 1.22-1.68 45 Case 2: Ash: Hazardous Sludge: Nonhazardous...... , . . . 0.77-0.84 0.65-1.03 1.42-1,87 65 Case 3: Ash: Hazardous Sludge: Hazardous ...... 0.77-0.84 0.90-1.17 1.67-2.01 84 (Case 4, where ash is nonhazardous but sludge is hazardous, is considered extremely unlikely) — — SOURCE Energy Resources Co Inc be classified as hazardous.’” All three wastes Coal Conversion Authority yield substances (primarily toxic trace ele- 4 ments) in concentrations that exceed the al- ESECA ’ was enacted following the 1973 oil lowable limits for drinking water. In addition, embargo in order to reduce imports of natural ash contains concentrations of radionuclides gas and oil by increasing the use of coal in and corrosive substances that approach the their place. Under ESECA, the FEA Administra- allowable Iimits. If either or both of these tor was required to prohibit powerplants, and wastes is Iisted as hazardous, disposal costs possibly other major fuel-burning installations, could increase as much as 84 percent (see from burning natural gas or oil as their primary table 61). energy source if certain conditions were met. These conditions are: Listing ash and/or sludge as hazardous also would change utility disposal practices signifi- ● that the facility has the capacity and nec- cantly. Sludge ponds could be prohibited as essary plant equipment to burn coal; “open dumps” (an area in which there is a rea- ● that the burning of coal by the facility is sonable probability of adverse effects on practicable, that adequate coal supplies health or the environment) and utilities forced and transportation facilities will be avail- to find alternative disposal methods. In addi- able, and that the order wouId not impair tion, the sale or use of wastes probably would a powerplant’s reliabiIity of service; and be discouraged. The National Ash Association ● that EPA either certifies that the facility estimates that more than 80 percent of the util- will be able to comply with applicable ities that burn coal selI or use a portion of their portions of the Clean Air Act by the effec- ash and sludge wastes, The provisions of RCRA tive date of the FEA order or grants a com- that govern transportation of these wastes pliance date extension. could make them noncompetitive. This could In addition, ESECA authorized the FEA Ad- increase disposable ash wastes by approx- ministrator to require a powerplant or other imately 18 milIion tons annualIy at current major fuel-burning installation in the early levels; no comparable estimates were avail- planning process to be designed and con- able for sludge. This effect directly contradicts structed to use coal as its primary energy RCRA’S stated objective of promoting the resource. As with the prohibitions, design or con- covery and recycling of solid wastes. struction requirements were conditioned on an Cost increases also could be expected in the adequate supply of coal and preservation of disposal of coal mine wastes, which contain reliability of service, as well as the ability of significant quantities of potentialIy toxic trace the owner of the facility to meet existing con- metals, if they are listed as hazardous. Poten- tractual commitments and to recover capital tial overlaps between RCRA and SMCRA could investments made as a result of the FEA order. add to these cost increases.

‘“Electric Power Research Institute, The Impact of 4 ’ Public Law 93-319 (June 22, 1974), as amended by RCRA (Public Law 94-580] on Utility Solid Wastes (F P-878, Public Law 94-163 (Dee 22, 1975) and Public Law 95-70 TPS 78-779, August 1978) (July 21, 1977) 362 ● The Direct Use of Coal

Finally, the FEA Administrator was authorized serve natural gas and petroleum for uses other to allocate coal, while EPA was empowered to than electrical generation for which there are issue temporary suspensions of some SIP provi- no feasible substitutes, and 3) to encourage the sions, in order to facilitate coal conversion. greater use of coal, synthetic gas derived from FEA authority to issue conversion orders under coal, and other alternate fuels in lieu of natu- ESECA expired on December 31,1978. ral gas and petroleum. Supporting purposes of the Act include the rehabilitation and upgrad- For a variety of reasons, including ineffec- ing of railroad service and equipment neces- tive management and inadequate funding and sary to transport coal, compliance with all ap- personnel, ESECA did not result in many coal plicable environmental requirements, and as- conversions. On June 30, 1975, FEA issued pro- surance of adequate supplies of natural gas for hibition orders to 74 generating units at 32 agricultural uses. powerplants and construction orders on 143 units at 97 powerplants. By early 1977, EPA The Powerplant and Industrial Fuel Use Act had reviewed 65 of the 74 prohibitions, finding (PIFUA) strengthens the regulatory program that only 11 of the 65 could burn coal immedi- under ESECA in two primary ways. First, PIFUA ately and remain in compliance with the Clean prohibits, with certain exemptions, the use of Air Act. Compliance date extensions were natural gas or petroleum as a primary energy given to 20 more, while 34 were found to resource in new electric powerplants and new quire additional pollution control equip- major fuel-burning installations” and provides ment.42 Other stumbling blocks to the success that no new electric powerplants may be con- of ESECA included the lack of financial incen- structed without the capability to use coal or tives (other than market price) to stimulate any other alternate fuel as a primary energy coal conversions and the lack of statutory pro- source. In addition, PIFUA prohibits existing hibitions for new sources. powerplants from using natural gas as their primary energy source after 1990 and, in the The first National Energy Plan proposed by meantime, from switching from any other fuel the Carter administration anticipated that two- to natural gas and from increasing the propor- thirds of the reduction in projected 1985 oil im- tion of natural gas used as the primary energy ports (3.3 million bbls/d out of 4.5 million source. The Secretary of Energy is granted ad- bbls/d) would be achieved by coal conversions. ditional authority to prohibit the use of petro- The primary means by which these conversions leum and natural gas where certain conditions were to be accomplished was a tax on industry related to technical and economic feasibility use of oil and gas. (The utility sector was ex- are met. pected to switch to coal because of market incentives and was not considered the chief Second, these prohibitions are reinforced target of the proposed legislation. ) However, with a shift in the burden of proof. That is, Congress failed to approve the industrial use under ESECA, the choice of fuel was left up to tax, and the final energy package is designed the owner of a facility, and the Federal Gov- to achieve coal conversions through a regu- ernment was required to prove that a particu- latory program with slightly more authority lar facility could and should use coal. PIFUA, than that granted under ESECA. however, begins with a blanket prohibition against the use of oil and natural gas, and the The primary purposes of the Powerplant and 43 owner of a facility must make a good faith ef- Industrial Fuel Use Act of 1978 (part of the fort to comply with the prohibition and show National Energy Act) are: 1 ) to reduce petro- that despite these efforts he will be unable to leum imports and increase the capability to use indigenous energy resources, 2) to con- 44 The provisions of the Powerplant and Industrial Fuel ‘zProgress in the Prevention and Control of Air Pollu- Use Act are applicable to powerplants and other station in 1976: Annua/ Report of the Administrator of the tionary units that have the design capability to consume Environmental Protection Agency to Congress, S. Dec. any fuel at a heat input rate of at least 100 million Btu No. 95-75, 95th Cong., 1st sess. (November 1977). per hour or to a unit at a site that has an aggregate heat ‘] Public Law 95-620 (Nov. 9, 1978). input rate of at least 250 million Btu per hour. Ch. VII—Present Federal Coal Policy 363

comply and that he is entitled to an exemption under the Clean Air Act soon after PIFUA takes from that prohibition. effect. If those standards are stringent, industrial coal use could be constrained severely in The prohibitions also are reinforced with a the Eastern United States. Because large pow- variety of financial assistance provisions. erplants and industrial boilers are the chief PIFUA provides an additional 10-percent tax target of PIFUA, and because those facilities credit for industrial investment in alternative already plan to use coal to the extent possible, energy property such as boiIers, polIution con- the main effect of PIFUA could be to provide trol technology, and equipment for producing financial assistance to ensure those plans do synthetic fuels from coal. I n addition, invest- not change. Where PIFUA could have a major ment tax credits and accelerated depreciation impact — on smalIer industries — the amount of were denied for new gas and oil burners. coal involved is not as great and exemptions PIFUA also provides loans for up to two-thirds are more easily obtained. of the cost of pollution control equipment for powerplants. Finally, funds were made avail- Other Federal Policy Actions able for the rehabilitation and maintenance of railIines used to transport coal. In addition to the protection from adverse These statutory prohibitions are, however, impacts of coal use afforded to health and the subject to numerous temporary and perma- environment by the above legislation, a variety nent exemptions. In addition, the Department of other Federal policy actions may affect coal production and use. These include the Endan- of Energy (DOE) is given great latitude in interpreting the Act. Therefore, PIFUA’S success in gered Species Act, the National Historic Pres- achieving coal conversions will not be possible ervation Act, the Fish and Wildlife Coordina- to predict until DOE promulgates the final reg- tion Act, and a variety of measures related to ulations under which exemptions will be transportation and transmission. granted. For example, PIFUA permits an ex- To the extent that coal production and use emption if the cost of coal “substantially ex- disrupt the ecology, it may be constrained by ceeds” the cost of oil or natural gas. The defi- the Endangered Species Act of 1973.45 The Act nition of “substantially exceeds, ” the costs to is designed to protect all forms of wildlife (in- be included in the determination and the meth- cluding mammals, birds, reptiles, amphibians, ods for arriving at those costs wilI be set out in fish, shellfish, and other crustaceans, and in- the regulations and will determine the avail- sects) and pIants through conservation pro- abiIity of exemptions under this provision. grams for endangered and threatened species and for the ecosystems upon which these spe- Despite these uncertainties, DOE estimated cies depend. The provisions of the Act that are in June 1977 that a regulatory program alone most relevant to coal production and use are (that is, without an industrial use tax) would in- the prohibitions against “taking” any species crease industrial coal consumption by 66 mil- that the Secretary of the Interior has deter- lion tons in 1985 (as compared to no further mined to be endangered or threatened and legislation) and would yield 700,000 bbls/d in against violating any regulation promulgated oil savings. However, the impact of PI FUA may under the Act, and the requirement that all be difficult to ascertain because most utilities Federal departments and agencies consult with and major industries are not planning new oil- the Secretary to ensure that actions author- or gas-burning facilities. Utilities have reported ized, funded, or carried out by them do not plans to bring 250 new coal-fired units on line jeopardize the continued existence of these by 1985; no new large industrial oil- or gas- species or result in the destruction or adverse fired boilers have been ordered since March modification of their habitat. 1977 and industry projections indicate none are expected. However, these projections Actions related to the production or con- could be undercut by environmental regula- sumption of coal, such as mining or facility tions. EPA plans to announce New Source Per- construction, that would result in the death of formance Standards for industrial boilers 4516 U.S C 1531 et seq 364 The Direct Use of Coal

endangered or threatened species, are con- obtain comments from the Advisory Council strained by the prohibition against taking. I n on Historic Preservation whenever any action addition, the regulations promulgated under may affect a site or structure listed, or found the Act designate habitats that are critical to eligible for listing, in the National Register. In the survival of some species. Any action affect- addition, reguIations promulgated under ing a designated critical habitat is an offense NHPA require the agencies to determine under the Act if it might be expected to result whether there are historic, archeological, archi- in a reduction in the number or distribution of tectural, or cultural resources that may be eli- the species of sufficient magnitude to place gible for listing in the National Register. If the species in further jeopardy or to restrict the there are, the proposed project must be re- potential expansion or recovery of the species. ferred to the agency charged with protection Several of these designated critical habitats of those resources for review. are in major coal-producing counties. As with the Endangered Species Act, NHPA’s The requirement that all Federal agencies requirements affect almost all coal-related ac- consult with the Secretary of the Interior to en- tivities. Significant historic and cultural sure that actions authorized, funded, or car- resources already have become the focus for ried out by them will not result in ecological concern over the impacts of energy develop- displacement or otherwise adversely affect en- ment in the Eastern United States, while the dangered species directly affects almost all preservation of archeological sites is a key issue coal-related activities. For example, most sur- in the Indian lands of the West. However, in face mines require a permit under the Surface very few instances may a proposed project be Mining Control and Reclamation Act. Similar- blocked by NH PA. Rather, the Act requires ly, most coal facilities, such as preparation and that an adequate opportunity to study the his- generating plants, require permits and author- toric or other resource be provided before the izations under a variety of Federal laws such as project proceeds. Therefore, the primary im- the Clean Air and Water Acts. In determining pact of NHPA would be to delay proposed whether actions will adversely affect an endan- coal-related activities that might endanger gered or threatened species, agencies must these resources. consider not only the particular action to be authorized or funded, but also the probable The Fish and Wildlife Coordination Act of 47 secondary effects, such as induced private de- 1970 offers some protection against the velopment. modification of any water body as the result of Once an agency has consulted with the Sec- a Federal or federally permitted project. Under retary of the Interior, the final decision on the Act, Federal agencies must consult with whether or not to proceed with an action lies the Department of the Interior’s Fish and Wild- with the agency itself. That is, the Secretary of life Service and with the State agency having the Interior does not have veto power over ac- jurisdiction over fish and wildlife, prior to tak- tions of other agencies that might adversely af- ing any action on a proposed project. Serious fect critical ecosystems. However, the Act consideration must be given to mitigating makes liberal provision for citizen suits to en- adverse impacts to fish and wildlife, and a join actions that violate the Act or regulations project may be enjoined until the mandated promulgated under it. In these suits the court coordination and consultation have occurred. will give great weight to the Secretary of the The principal coal-related activities that Interior’s opinion about the effect of an ac- may be affected by this legislation include the tion, and will defer to the Secretary to deter- construction of cooling water intake structures mine what modifications are necessary to en- and of barge and other transportation facil- sure that an action does not adversely affect ities. However, these activities also are subject endangered or threatened species. to the requirement that all projects affecting The National Historic Preservation Act of navigable waters obtain a permit from the 19704’ (NH PA) requires all Federal agencies to 4616 U S C. 470 et seq 4716 U. SC. 661 et seq. Ch. VII—Present Federal Coal Policy ● 365

Army Corps of Engineers. I n practice, there- parts of the country. Its greatest potential im- fore, the consultation required under the Fish pact would occur if greatly increased produc- and Wildlife Coordination Act usually occurs tion of Western coal required new highway at the time of application for the Corps permit. construct ion. If water resources will be taken by the project Similarly, where transportation or transmis- and wildlife values destroyed, mitigating meas- sion facilities are routed across public lands, or ures may be required to protect the water flow where the site for a combustion facility is on or even to replace lands lost to construction. public land, the Federal agency having juris- Finally, the Transportation Act of 196648 for- diction over the Iand must issue a permit for bids the taking of publicly owned wildlife use of the right-of-way. There usualIy are statu- refuges and parks as well as public or private tory limits on the width of the corridor or on historic sites for highway construction unless the size of the site, and other limitations may there is no feasible and prudent alternative be imposed by the agency in order to prevent and all steps are taken to minimize harm. This adverse environmental impacts. Again, these provision probably will not pose significant requirements probably would have a greater constraints to coal use because adequate effect in the West where there is the largest transportation facilities already exist in most concentration of Federal land.

IMPLEMENTATON

How these major Federal policy actions are the focus of this discussion is on Federal agen- implemented plays a central role in determin- cies and their responsibilities, it must be kept ing whether they contribute to or obstruct a in mind that State and local laws and their im- coherent national coal policy. The primary fac- plementation also have a substantial impact tors relevant to their effective implementation on the direct use of coal. include the number of agencies with responsibility for regulating coal production and use, Environmental and Social Impacts the extent to which those agencies’ mandates Since the passage of the National Environ- may overlap and conflict, and the number of mental Policy Act (NE PA), all Federal agencies gaps in regulatory programs created by unan- must prepare a detailed E IS on all major ac- ticipated problems. tions significantly affecting the quality of the human environment. Two Federal agencies Institutional Factors have EIS oversight responsibilities: CEQ and EPA. CEQ was established by NEPA to advise The responsibility for implementation of the the President on environmental affairs, to pro- various laws that affect coal production and vide the public with information about envi- use and their impacts on health and the environmental issues, and to monitor other agen- ronment is divided among a variety of admini- cies’ compliance with NE PA. CEQ regulates strative departments and agencies. The major the preparation of EISS, serves as the Federal areas of responsibility for environmental and repository for EISs, reviews and comments on social impacts are environmental impact as- draft EISs, and develops comparative analyses sessment, air and water quality management, on the E I S process. However, CEQ’s role is pri- resource extraction, occupational health and marily advisory; it can neither compel compli- safety, solid waste disposal, and siting and ance with NEPA nor block actions it feels land use. For the promotion of coal use, agen- wouId have unacceptable impacts. cy responsibility covers resource exploration and acquisition, and resource use. Although EPA was established in 1970 to administer a variety of environmental laws and to police 4’49 U S.C 1650 the environmental activities of other agencies 366 ● The Direct Use of Coal by reviewing and publicly commenting on “en- sion prevention; the Geological Survey, Na- vironmentally impacting action s.” As with tional Oceanic and Atmospheric Administra- CEQ, EPA’s role in E IS review is advisory; it can tion, National Aeronautic and Space Admini- make recommendations but cannot block stration, and the Coast Guard, which assist other agencies’ actions unless those actions EPA in water quality surveillance; HEW, which violate other environmental legislation. assists EPA in researching the harmful effects of water pollutants; the Department of justice, A number of State and local governments which aids EPA and the States in enforcing the have enacted environmental policy acts loose- Clean Water Act; and the Department of the ly modeled on NE PA. Their requirements range Interior, which assists EPA in determining the from detailed EISS to advisory planning standards of water quality necessary for wild- mechanisms. life protection. The Federal agency primarily responsible for The State role under the Clean Water Act air quality management is EPA. As discussed in centers on developing and implementing plans previous sections, EPA’s role under the Clean and permit programs consistent with EPA Air Act includes publishing information about guidelines. the effects of airborne pollutants on human health and the environment and about means As mentioned above, there is no comprehen- of monitoring and controlling those pollutants, sive Federal policy for water resource manage- establishing numerical standards for ambient ment. The allocation of water rights tradi- air quality and for pollutant emissions from tionally has been the responsibility of the various sources, promulgating guidelines for States, and means of allocation vary widely. State plans to implement those standards, and However, many Federal agencies have been as- implementing and enforcing the standards in signed duties that affect State allocations. the absence of State action. HEW sponsors First, the Water Resources Council” (WRC) as- some research into the health effects of air- sesses water supplies and, through its River borne pollutants, and the Department of jus- Basin Commissions, coordinates regional wa- tice assists EPA in enforcing the Clean Air Act. ter resource planning. In addition, WRC evaluates water resource requirements and avail- The States have the primary responsibility ability for nonnuclear energy technologies. for implementing and enforcing the Federal air The Department of the Interior sells or leases quality standards in accordance with EPA water supplies from its reclamation projects guidelines. In addition, implementation and and, in cooperation with the Army Corps of enforcement authority may be delegated to Engineers, evaluates reservoir projects for the local government where State law permits and development of domestic, municipal, or indus- where the locality is deemed to be capable of trial water supplies. The Corps also is respon- handling this responsibility. sible for inland waterways in cooperation with As is the case with air quality, EPA has the the Department of Commerce. The Depart- primary Federal oversight responsibility for ment of Housing and Urban Development water quality management. EPA publishes in- assists in water supply and distribution plan- formation about water pollutants and methods ning. The Departments of the Interior and Agri- of control, sets water quality standards and ef- culture cooperate on water conservation and fluent limitations for sources in order to meet utilization projects. These and a variety of those standards, establishes guidelines for other agencies have additional minor and ad- State regulatory and permit programs, and im- visory responsibilities for the management of plements and enforces the Clean Water Act in water resources as they relate to irrigation, the case of State failure to do so. A variety of aquatic life, recreation, flood control, and Federal departments and agencies assist EPA other purposes. in fulfilling this responsibility including the Department of Agriculture, which is responsible for watershed management and runoff ero- 4942 U.S.C. 1962a et seq. Ch. V/l—Present Federal Coal Policy . 367

The Department of the Interior has primary health and safety regulations, and in 1977 the Federal responsibility for the environmental Mine Safety and Health Act shifted the latter and social impacts of resource extraction. duty to the Department of Labor. The Depart- Within the Department of the Interior, the Of- ment of Labor’s Mine Safety and Health Ad- fice of Surface Mining (OSM) implements the ministration (MS HA) will take over MESA’s re- Surface Mining Control and Reclamation Act sponsibilities. Both HEW’s National Institute (SMCRA). Under SMCRA, OSM sets environ- for Occupational Safety and Health and the mental performance standards for all aspects Department of the Interior’s Bureau of Mines of surface mining and for the surface oper- conduct mine health and safety research. ations of underground mines and establishes Federal responsibility for solid waste dis- guidelines for State permit programs designed posal is divided among EPA, the Department to implement and enforce those standards. of the Interior, and the Army Corps of Engi- A variety of other offices within the Depart- neers. Under the Resource Conservation and ment of the Interior are responsible for envi- Recovery Act (RCRA), EPA has general over- ronmental management of Federal coal leases. sight authority for solid waste disposal. EPA is The Geological Survey has overall regulatory required to promulgate guidelines for the authority over extraction operations after leas- transportation and disposal of hazardous and ing decisions have been made, including the nonhazardous wastes of all types (except site-specific conditions to be incorporated in radioactive wastes). The Department of the in- leases as well as the resource conservation terior’s OSM sets minimum environmental per- regulations for Federal lands. The Bureau of formance standards for the disposal of spoil Land Management develops the reclamation and coal-processing wastes. If either of these requirements to be included in mining plans, wastes is Iisted by EPA as hazardous or if E PA’s while the Bureau of Indian Affairs regulates environmental protection standards are more mining activities on Indian lands. stringent than OSM’S, the mine operator will be required to meet the stricter standards. Prior to the passage of SMCRA, State regula- Finally, the Army Corps of Engineers issues per- tion of the environmental impacts of mining mits for the disposal of solid wastes or of varied widely. States that wish to retain regula- dredge and fill material in navigable waters. tory authority over surface coal mining and reclamation operations now must develop Implementation and enforcement of EPA’s comprehensive plans and permit systems in ac- requirements under RCRA and of OSM’S regu- cordance with SMCRA. OSM will regulate the lations under SMCRA may be turned over to mining activities in those States that fail to States that establish approved regulatory pro- develop or enforce a regulatory program. grams. To the extent allowed by these State programs, local governments may control the Until the 1960’s, regulation of the occupa- location of waste disposal through land use tional health and safety impacts of mining was planning and zoning. characterized by conflicts between State and Federal jurisdiction. These conflicts were As with water resource management, no resolved in 1969 with passage of the Coal Mine comprehensive Federal policy exists for land Health and Safety Act, which gave the Depart- use and facility siting. Although the Nation’s ment of the Interior primary regulatory respon- energy goals call for increased reliance on sibility for miner’s health and safety. Within coal, the recent escalation in parties-at-interest the Department of the Interior, the Mining En- to energy development makes it difficult to forcement and Safety Administration (MESA) find acceptable sites for new coal combustion set minimum standards, outlined penalties for facilities. In addition, most of the Federal reg- violations, and established mine closure cri- ulatory programs discussed above indirectly teria. However, the Department of the interi- control facility siting to prevent unacceptable or’s concurrent responsibility for maximizing site-specific environmental and social impacts, energy resource development was found to be but there is little coordination among these incompatible with its duty to enforce mine programs. 368 ● The Direct Use of Coal

Only on Federal lands do Federal agencies gy Organization Act gives DOE control over have any direct control over land use and ener- economic leasing terms and conditions. DOE’s gy facility siting. The Departments of the inte- duties under the 1977 Act include establishing rior and Agriculture supervise most Federal long-term production goals for federally coal lands and have the authority to forbid owned energy resources, developing standards mining where it would be environmentally unfor rates of production from Federal leases, acceptable. For all Federal lands, the agency specifying economic terms and conditions of having jurisdiction over the land must issue a individual leases (for example, eligibility of permit for use of the land as the site for a coal- joint ventures), and setting guidelines for post- related faciIity or for the right-of-way for trans- Iease conditions (such as recommending for- portation or transmission purposes. feiture of a lease that does not meet produc- Indirect controls—primarily constraints— tion rates). To facilitate cooperation between on facility siting may be exercised by CEQ and the Departments of the Interior and Energy in EPA through their role in reviewing EISs. In ad- administering the leasing program, the 1977 dition, a variety of EPA regulations for air and Act created a Leasing Liaison Committee water quality management Iimits the number within DOE but composed of equal numbers of sites available to utilities and industry. of members from both departments. The use of coal is governed mainly by DOE The States have the greatest amount of con- through conversion of existing facilities to trol over facility siting and land use, either coal, the prohibition of new large facilities through their general police power to protect from burning gas or oil, R&D on new technol- the public health and welfare or through the ogy, and regulatory price setting. implementation of federally mandated programs. Under their police power, States can Evaluation control energy resource development through land use planning and zoning, permit require- Many critics of present Federal coal policy ments, and regulation of public utilities. A few and of the agencies that implement it argue States have enacted comprehensive statewide that energy development is overregulated. Cer- land use planning legislation; some only pro- tainly the scope of Federal intervention has vide statewide planning for energy facility grown dramatically in the last decade. The siting; in others all land use and siting remains number of permits, certifications, and author- under piecemeal legislation, much of it imple- izations required to operate a coal mine or a mented at the local level. coal combustion facility has increased substantially. Often several agencies share the The Promotion of Coal Use responsibility for regulating a particular activi- Federal responsibility for resource explora- ty, such as leasing federally owned coal. tion and acquisition rests with the Department Where those responsibilities overlap, conflicts of the Interior, which administers the Federal may occur between the goals of the agencies coal-leasing program. Within the Department involved. For example, limitations imposed on of the Interior, the Geological Survey eval- Federal coal leases by the Department of the uates coal resource data while BLM records Interior to prevent unacceptable environmen- lease applications and collects various fees, tal or social impacts may be incompatible with rents, and royalties. I n addition, other agencies the economic terms and conditions imposed with jurisdiction over the surface of public by DOE to achieve national energy goals. lands, such as the Department of Defense, may Whether the present Federal coal policy is block coal leases on their lands. perceived as counterproductive usually is a function of the interests being represented. im- The responsibility for coal extraction and partial analysis is rare and conventional cost- use is divided between the Departments of the benefit analysis often cannot adequately Interior and Energy. As discussed above, the weigh the tradeoffs between the dolIar costs of Department of the Interior oversees Federal regulation and the resulting unquantifiable en- coal leases. But the 1977 Department of Ener- vironmental and health benefits. Ch. VII—Present Federal Coal Policy 369

On the other hand, some commentators that are not fully understood. In the Western argue that more regulation of coal-related ac- States, the primary concern is the preservation tivities is required, either because of the man- of environmentally valuable scenic areas and ner in which agencies have interpreted their the prevention of the adverse social and eco- Federal mandates, or because gaps or incon- nomic impacts of rapid development. To date, sistencies in those mandates preclude the ex- proposals for Federal land use legislation have istence of either a coherent national coal been designed to encourage statewide plan- policy or a coherent national environmental ning. But many of the existing siting problems, policy. The most significant obstacles include such as air quality management and the long- the lack of comprehensive Federal programs range transport of pollutants, do not respect for coal, water, and land resource manage- State boundaries. Without comprehensive na- ment; the conflict between States rights and tionwide land use planning that directly ad- the need for uniform Federal legislation; the dresses facility siting problems it may not be lack of workable mechanisms for solving inter- possible to meet national energy goals. state or interregional problems; and the lack of mechanisms for long-range planning. Problems also have arisen in implementation of those regulatory schemes that mandate No comprehensive Federal policies current- comprehensive State programs in accordance ly exist for coal leasing, water resource man- with Federal guidelines. Although nationwide agement, or land use and facility siting. A Fed- legislative uniformity in these areas is in the eral coal-leasing policy should be developed public interest, States are under increasing and implemented by the early 1980’s, long be- pressure to reduce spending and are reluctant fore any significant coal supply constraints are to accept the responsibility for major new reg- expected to arise. Water availability and land ulatory programs. Yet if the States wish to pre- use, however, may present obstacles to in- serve their rights to regulate energy develop- creased coal use. ment within their borders, they must accept As discussed above, water supplies tradi- that responsibility. Similarly, where federally tionally have been allocated by the State with mandated State regulatory programs are found some Federal oversight. For the most part, to be inadequate, responsibility for their im- State control of water resources is logical be- plementation and enforcement reverts to Fed- cause of the wide variation in water availabil- eral agencies that have neither adequate per- ity. Thus a regulatory scheme that may be sonnel nor funding to perform those duties. workable in the East, where surface and As discussed in chapter V, a variety of envi- ground water resources are relatively abun- ronmental impacts of energy resource devel- dant, would not be appropriate for the arid opment have become regional problems that and semiarid regions of the West. Yet as the do not lend themselves to management on a competition for water for agricultural, indus- State-by-State basis. Yet the mechanisms for trial, residential, and energy uses increases, a solving interstate pollution problems are cum- national system of priorities may become nec- bersome and ineffective, and the result will be essary. an increase in the number of suits between Similarly, while land traditionally has been States. For example, the State of Kentucky has considered the Nation’s most abundant re- passed a law that requires powerplant oper- source, past abuses and the increasing con- ators to obtain a permit from Kentucky if they cerns of parties-at-interest have begun to limit take water from or discharge waste into the the land available for energy resource develop- Ohio River along the State’s border. This law ment. As with water, the concerns over land effectively gives Kentucky control over power- use and siting have regional variations. In the plant siting along the Ohio River in the States more industrialized East the concerns center of Ohio, Indiana, and Illinois. Kentucky has an- on facility siting patterns; concentrations of nounced that those States must work together coal-fired powerplants in particular areas may to solve their common air and water pollution lead to cumulative and interactive impacts and siting problems or face legal action by

44-102 0 -79 25 370 ● The Direct Use of Coal

Kentucky. To some extent, the existing Federal existing problem, such as lack of development EPA regions could be used to manage inter- of Federal coal leases or the already polluted state pollution problems, but the same issues condition of the Nation’s air and water. Conse- of coordination and cooperation exist at the quently most of the programs and the R&D regional level; there has been very little in- funding is aimed at solving these problems and teraction among the EPA regional offices even little attention is given to long-range planning though environmental management strategies or to researching potential future problems. developed for one region may significantly affect another. For example, Kentucky’s pro- In summary, the piecemeal legislative ap- grams are under the jurisdiction of EPA region proach to energy resource development and IV while Ohio, Indiana, and Illinois are in environmental management has resulted in a region V. The neighboring States of Pennsyl- variety of implementation problems. Some of vania and West Virginia, which share the same these result in additional dollar costs to the de- pollution problems, are under the jurisdiction veloper. Others result from a lack of coordina- of region III. In September 1978, these three tion within and among regulatory agencies, EPA regions established an interregional task such as the solid waste impacts of air pollution force to coordinate pollution control in the control or interstate and interregional energy Ohio River Valley. Such interstate and inter- development impacts. Still other problems, regional cooperation must become the rule such as the obstacles to energy facility siting, rather than the exception if environmental may require additional regulation if the Na- problems are to be solved. Existing mecha- tion’s energy goals are to be met. For the most nisms for this cooperation, such as interstate part, however, these problems could be solved compacts, should be adequate if used effec- if existing legislation were implemented in an tively. effective, coordinated manner.

Finally, most of the Federal policy actions discussed represent a legislative response to an Chapter VIII -POLICY OPTIONS Chapter VllL- POLICY OPTIONS

Implementation ...... 384 Major Policy Problems...... 385 Community Impacts...... 39-1 Overload of Existing Community Servi ces...... 392 Economic Dislocation ...... 392 Social Instability and Quality of Life ...... 393 General Policy Options ...... 393 Specific Policy Options ...... 394 Labor-Management Relations ...... 396

TABLES

Page 62. Environmental Impacts (Land, Water Quality and Quantity, Air Quality)...... # ...... 385 63. Comparison of Policy Options Under Consideration by the Department of the Interior...... Chapter Vlll POLICY OPTIONS

Each of the national energy supply and demand scenarios in this assessment involves a very substantial increase in coal use over the next two decades. There is no doubt that the resource to sustain a high level of use over that period is physically present and accessible. It is also clear that from an engineering standpoint coal can be extracted, processed, and burned at an economic cost that will make it very competitive with alternative fuels. What is not so clear is how the external costs, institutional and social constraints, and other nonmarket factors associated with coal use will affect the validity of the economic and technological analysis. At the extreme, increased coal use could pose such serious external costs to the environment and public health that would make it unacceptable. At a minimum, the process of reducing external costs (e. g., by imposing pollution controls) and coping with internal constraints (e. g., labor-management problems) will moderately increase the economic costs of coal utilization. Given the central place of coal in future U.S. energy planning, it makes a great deal of difference where we ultimately come out on the continuum between minimum and maximum constraints on coal use. In short, the stakes involved in formulating a national coal policy are very high.

The tasks of policy analysis in this area are to identify the potential problems and constraints and to examine the range of governmental policies that offer some promise of ameliorating them. This study does not recommend specific policies, but it identifies policy options, the sorting criteria for choosing among them, and the implications of available choices. The sorting criteria are of three basic types: 1 ) national objectives concerning the level of coal production and use, 2) political and normative values, and 3) pragmatic calculations concerning the relative efficacy of policies and technologies in stimulating production and use and/or minimizing adverse impacts. These are analyzed in sequence.

NATIONAL ENERGY OBJECTIVES

National objectives concerning the magni- requirements. Nevertheless, there are actions tude and timing of coal use set the context for that will provide an additional margin of safe- formulating coal policy. For example, accept- ty against the possibility that these supply pro- able policies for the leasing of Federal coal jections are overly optimistic or that it be- reserves, workplace health and safety, and comes necessary to raise coal’s fraction of U.S. clean air legislation may be different in kind or total energy supply above the levels posited in degree depending on whether the Nation seeks this report. Many of these measures have merit 100, 125, or 150 quadrillion Btu (Quads) of independent of their potential effect on coal energy supply. Similarly, policies designed to supply. The list includes efforts to: 1 ) mitigate compel the conversion of existing industrial the adverse community impacts that might boilers from gas and oil to coal mayor may not constrain coal development, 2) remedy the be necessary depending on the Government’s sources of labor-management disputes and timetable for increased coal use. promptly settle strikes that do occur, 3) anticipate and avert potential coal transporta- In actual fact a sufficient supply of coal tion bottlenecks by upgrading existing modes should be available to meet the three coal use (e.g., railroads) and facilitating the creation of scenarios cited above while satisfying existing new ones (e. g., slurry pipelines), 4) expedite the and pending environmental, health and safety, formation of a leasing policy and the designa- leasing, and related legislative and regulatory tion of eligible tracts, 5) streamline the permit-

373 374 ● The Direct Use of Coal

ting process for new mines, and 6) develop pro- port for technologies, e.g., fluidized-bed com- cedures for anticipating and accommodating bustion (FBC) and solvent-refined coal (SRC) potential objections to new coal facilities in that can help make coal an acceptable fuel for order to avoid extensive Iitigation and delay. small users; 3) RD&D support for improved, less expensive emission control technologies; Demand is more likely to be a constraint on 4) RD&D support for coal gasification and liq- coal development over the next two decades uefaction technologies; and 5) higher prices for than is supply. While demand will probably be natural gas and fuel oil. adequate to sustain all but very high energy scenarios, this is far from certain. Several In general, however, the different plausible broad policy options are available to strength- targets regarding coal production and use for en the future market for coal. These include: 1 ) the remainder of the century do not emerge as tax pressures and incentives to induce utility a critical basis for sorting among legislative and industrial conversion to coal; 2) R&D sup- and regulatory policy options.

POLITICAL AND NORMATIVE VALUES

Values play a critical role in the policy- unemployment, but may have serious adverse making process, yet policy analysis often pro- impacts on the physical environment. ceeds under the assumption that policymaking What follows is a more detailed examination is or can be a clinically objective, value-free of three conflicting value sets: 1 ) production process. In fact, the choice between conflict- maximization or impacts amelioration, 2) the ing courses of action will often and inescap- allocation of decisionmaking responsibility ably reflect subjective judgments concerning concerning coal development between Federal what is desirable. With regard to coal policy, or State and local authorities, and 3) the the most important value conflict involves the allocation of decisionmaking between the relative priority assigned to increasing produc- public or private sectors. The first choice be- tion as opposed to reducing adverse impacts. tween production and impacts values can be Taken together, existing legislation and regula- analyzed in terms of specific tradeoffs. tions define a rough but discernible balance between these two value sets. In broad terms The first tradeoff is between coal extraction future policy must either accept that balance and environmental quality. Mining has a num- or shift it in favor of production or impacts ber of inevitable adverse environmental im- amelioration. This tradeoff, perhaps more than pacts. To some extent these are specific to any other, lies at the heart of national coal either surface or underground, but both forms policy. In one sense, however, the dichotomy is of mining have a range of effects. Although a false one. Adverse impacts lead to con- complete control over these effects is impossi- straints on coal use, and a major reason for ble, all can be greatly reduced with existing technologies and procedures. But these tech- controlling them is to facilitate coal devel- nologies have both costs and limitations. They opment. The environmental goal conflicts with will certainly make coal more expensive. the production goal only when protection Higher prices for coal can have secondary im- measures increase the cost of coal sufficiently pacts on much of the economy, including in- to dampen demand. Other potential value con- flation and unemployment levels. The limita- flicts involve the proper allocation of decisionmaking authority between the public and pri- tions of reclamation and control technologies vate sectors and among Federal, State, local, mean that mining certain coal reserves (e. g., and tribal governments. Conflicts may also oc- under prime farmland) may be precluded al- cur between various impacts-related values; together. e.g., operating a new coal mine may help solve On the other hand, failure to employ avail- a number of community problems, including able controls has its own costs. These can in- Ch. Vlll—Policy Options 375 elude scarred landscapes (often permanent), these circumstances the symmetry is over- subsidence (some of it continuing for a century turned with potential implications for the or more), polIution and siltation of surface balance of political pressures concerning the waters, pollution and disruption of aquifers, tradeoff between energy price and pollution and in some cases, flooding. Secondary costs control. can include a reduction in tourism, damage to Where the policy maker or analyst ultimately agriculture, dim in i shed opportunities for recre- draws the balance in the tradeoff between ation, esthetic impairment, and the need for energy availability and cost on one side and control and reclamation. Whereas costs of em- environmental and health considerations on ploying controls in the form of higher energy the other depends on four considerations: prices are borne by the beneficiaries of coal use, the costs of not using controls tend to fall 1, The severity of the specific impacts being disproportionately on the coalfield communi- analyzed and the equity of their distribu- ties and their inhabitants. tion. 2. Personal values, e.g., economic growth as The second tradeoff is between coal combus- opposed to conservation. tion on the one hand and environmental quali- 3. Attitudes toward risk. The economic costs ty and public health on the other. Burning coal of imposing various controls are reason- to produce energy will unavoidably generate ably predictable, but the environmental emissions with potential adverse impacts on and health costs of foregoing those con- health and the environment. Some emissions trols are not, and the range of possible cannot be practicably controlled with known technologies, while the others can be partly, consequences is very wide. Consequently, policy choices often involve tradeoffs be- but not entirely, eliminated. Carbon dioxide tween the known and unknown or partial- (CO ) emissions belong in the first category 2 ly known. and sulfur oxides (SO ) and nitrogen oxides X 4. Relative value assigned to present and (NO ) in the second. Nevertheless, most imme- X future costs and benefits. The economic diately threatening emissions can be mini- consequences of higher coal prices will be mized with present or pending technologies. felt in the short term, while many of the There are costs. Coal becomes more expensive most important and environmental ef- to burn; environmental problems are created fects (e.g., from carcinogens) will not be by the need for disposal of flue-gas desulfuri- felt for years or even decades. zation (FGD) sludge; and the process of coal conversion by plants is made more expensive The third tradeoff is between coal extraction and time consuming. and community well-being. Mining can have The costs of not controlling emissions in- substantial community benefits relating to clude agricultural crop losses, damage to for- economic growth and employment. The costs ests and freshwater fisheries, adverse impacts can be high as well, including overloaded com- on esthetic and property values, possible alter- munity services, economic dislocation, and ation of global climate over time, and possible social disruption. Which effects will tend to increased incidence of human iIIness and mor- predominate depend on the circumstances of tality due to lung and other diseases. the particular community. The costs of allevi- ating community distress related to coal devel- To the extent to which powerplants are lo- opment tend to take the form of transfers of cated in urban areas, there is a basic symmetry State and Federal resources to the locality– between the costs and benefits of emission e.g., through loans, grants, and bond guaran- control. The urban consumer population bears tees. A bill submitted to the 95th Congress the primary burden of increased energy costs would have allotted $1 billion over the next and benefits from the reduction in pollution decade for this purpose. from nearby plants. The increasing tendency, however, is to site new plants in rural areas or The costs of doing nothing are also real, on the outer fringes of urban centers. Under though not readily quantifiable. These costs in- 376 ● The Direct Use of Coal elude worker dissatisfaction (with consequent impacts minimizer wilI favor such measures as high turnover and unrest), alcoholism and re- stringent standards (requiring the best avail- lated social ills, rapid inflation in the coal- able control technology (BACT)) under the fields, disruption of the local economy, oppor- Clean Air Act for removal of SOX and NOX, ap- tunity costs due to losses in potential income plication of Federal point source air emission from noncoal economic activities (e.g., de- standards to existing as well as new facilities, clines in tourism), and congestion and disrup- the imposition of stringent and detailed regulation of settled community life. The decision of tions implementing the Surface Mining Control where to place the burden of dealing with and Reclamation Act (SMCRA), the classifica- these community problems hinges partly on tion of sludge as a hazardous substance sub- whether future coal development revenues are ject to rigorous disposal standards, and the en- seen as ultimately sufficient to cover the com- forcement of strict criteria (e.g., regarding the munity costs or not. If so, the choice may be impact on water availability in arid regions) in sidestepped by providing loans to cover the selecting sites for coal faciIities. immediate “front-end” costs, which can be With regard to community effects of coal repaid out of future revenues. If not, a choice development, the impacts minimizer will favor must be made where the burden will fall —on policies that cause the coal companies to in- the society as a whole, which presumably ternalize an increased portion of the public benefits from the increased availability of costs (e. g., concerning roads and housing) con- energy; on the individual coalfield communi- sequent to their activity. He or she will tend to ties; or on the utilities and mining companies favor the use of State eminent domain powers and, through them, on the direct consumers of to obtain coal company lands for housing in the energy. Appalachia and in both the East and West will The fourth tradeoff is between coal extrac- support increased community participation tion and workplace health and safety. A cer- and control concerning the decisions of coal tain number of casualties in the form of in- companies that significantly affect the com- juries, deaths, and occupational disease munity. A go-slow, careful approach to further among miners is an inevitable result of coal leasing of Federal coal lands will be preferred. production. Mining, particularly underground, In the tension between production/output ob- is an inherently dangerous occupation. Never- jectives on the one hand and health/safety theless, with current technologies and pro- goals on the other, the impacts minimizer will cedures (e. g., dust sampling and control, safety give preference to the latter. Examples include training, inspections) the risks can be lowered, the application of more rigorous dust control The costs of doing so include higher priced standards and procedures and the use of more coal, and possibly a dampening of productivity Federal safety inspectors in the mines. With re- and output. The latter relationship has yet to gard to labor/management disputes over such be clearly demonstrated. The costs of not act- questions as mine safety and health care cen- ing to reduce the risks to miners are a higher in- ters, the tendency will be to support the cidence of accident and disease, which could miners. result in increased labor unrest. Once again The energy maximizer is defined as the mir- policy makers face a choice between allocating ror image of the above and, as such, would em- the costs of ameliorating impacts to society as brace an opposite set of policies. The above a whole through increased energy prices or al- list of policy issues is merely illustrative and is lowing the costs to fall upon a single group– far from complete. Moreover, not all policies the miners. sort in terms of production and impacts values.

The policy implications of these tradeoffs A second set of competing values relevant are simply illustrated by positing two opposite to coal policy relates to Federal Government ideal types of policymaker — an “impacts mini- regulation of the private sector—a classic mizer” and an “energy maximizer. ” I n address- issue of political ideology. For the sake of con- ing the major issues involved in coal policy the venience, the two competitive perspectives Ch. Vlll—Policy Options ● 377

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.=c: .2 Q. 0 CD c: 0 'E CD !I) CD Q. ! !I) 'E e.~ CD ~ a.0 s: :; 0 E c:CD i 378 ● The Direct Use of Coa/ can be called “proregulatory” and “anti regula - must not be exposed to sounds above a certain tory” — recognizing that these are oversimpli- decibel level. How the company achieves this fied caricatures. In recent years the proregu- objective is not the Government’s concern. latory perspective has been the predominant Similarly, with regard to air pollution, the pro- influence on national policymaking concern- reguIators argue for BACT requirements ing coal. Rooted in the liberal political tradi- whereas their counterparts favor simple emis- tion, proponents of this view tend to give less sion standards. As for siting, the first perspec- priority to the production of coal than to the tive sees merit in detailed uniform site selec- mitigation of its adverse impacts. They see mation criteria whereas the second viewpoint jor tensions between the interests of the coal tends to favor case-by-case negotiation of sites companies and the public and are generally by interested parties within very generaI guide- skeptical of the wilI or ability of these corpora- lines. tions to avoid actions detrimental to the public interest without strong Government pressure A final value choice concerns how decisionmaking authority over coal to do so. They have a high regard for the value development should be allocated among the of public, grassroots participation in decisions various levels affecting coal development. Regulations are of government: Federal, State, local, and tribal. Considerations that argue for a growing viewed positively as an indispensable means of Federal role include: 1 ) there is a clear need for protecting the environment and public health a national policy concerning coal develop- and safety. They provide a uniform, detailed, ment and use, 2) a substantial portion of obligatory code of conduct on the coal compa- known coal deposits underlie Federal lands, 3) nies that is enforceable in the courts. Federal money plays a key role in R&D con- in contrast, adherents of the antiregulatory cerning coal, and 4) scientific evidence in- perspective are associated with the conserva- creasingly documents the regional/interstate tive part of the political spectrum, tend to val- nature of the pollution problem. Coal burned ue energy production over impacts mitigation, in Ohio produces acid rain in New Hampshire. and see the public interest as being best served Pesticides entering the Mississippi River in Il- by according maximum freedom of action to Iinois eventually pollute the drinking water of the productive genius of the private sector. New Orleans, La. The failure to impose mini- Government attempts to regulate economic mum national standards would permit one activity are seen as a recipe for higher costs State to attract industrial investment by lower- and reduced productivity to the detriment of ing its environmental standards, thereby be- all. Some regulation of coal development may coming a pollution haven to the economic and be unavoidable, but it should take the form of perhaps environmental detriment of its neigh- general performance criteria that leave to the bors. Moreover, it is argued that the scenic private company freedom to determine how quality of a State like Utah is a national best to achieve the standard. Wherever possi- treasure and, as a consequence, the Federal ble, broad guidelines and reliance on volun- Government has a responsibility to protect it. tary compliance should be the rule. On the other hand, the potential costs of an These two contrasting philosophies lead to increased Federal role are: 1 ) reduced State very different approaches to specific prob- and local initiative, 2) a diminished ability to lems. Three illustrative examples are noise fine-tune policy to fit local and regional condi- abatement, air pollution control, and coal tions, 3) the possibility of a halfhearted State facility siting. With regard to noise, advocates and local commitment to the successful imple- of the first perspective tend to favor detailed mentation of national coal policy, 4) a risk of requirements concerning the devices and pro- creating a precedent for increased Federal in- cedures that must be used to achieve a reduc- tervention in regional and local affairs general- tion in noise levels in a mine. Scorning this ly, and 5) a belief that Federal requirements “cookbook” approach, the antiregulators fa- concerning air quality, surface mining, water vor only performance standards, e.g., miners quality, and potentially, land use unjustly in- Ch. VIII—Policy Options . 379 terfere with the right of States to develop their cause much Federal environmental legislation resources, attract economic investment, and sets standards and then mandates implemen- draw their own balance between energy and tation by the States— at the Iatters’ expense. environmental goals. For example, the preven- Despite this difficulty the potential tradeoff tion of significant deterioration (PSD) require- between national and subnational decision- ments under the Clean Air Act limit the scope making can be at least partly sidestepped by for industrial development in Utah and Mon- setting broad Federal standards of perform- tana. Provisions of SMCRA constrain the abil- ance to be elaborated and applied by the ity of Kentucky to exploit in-State coal re- States. This strategy has been followed in reserves. Rising pressures on State budgets for cent legislation concerning coal development. fiscal austerity exacerbate the problem be-

EFFICACY CRITERIA

The remaining type of criteria for selecting fects resulting from increased concentrations among available policies and associated tech- of atmospheric COZ. The potential time scale nologies involves an assessment of their utility of environmental damage covers a similarly in solving the specific production, utilization, broad range from virtually instantaneous and and impact problems associated with coal. Un- short-lived phenomena to impacts that are like the previous two sets of criteria, which are slow in developing but that wit I endure for cen- to a significant degree discretionary, the third turies. Environmental issues relate directly to class of criteria involves a determination of matters of great importance to people. What fact, i.e., an assessment of the feasibility and for the environmentalist is a question of public effectiveness of various policy options. The health and the quality of life is for the unevenness of the data base means that the developer a matter of personal livelihood. gaps in relevant knowledge must be clearly identified during the analysis. Governmental concern for the environment is evidenced by an imposing body of legisla- Five major areas of policy concern have tion and regulation administered by a substan- been identified, each with a potential for sig- tial bureaucracy. To a remarkable degree the nificant influence on efforts to expand the pro- legislation has kept pace with advances in duction and combustion of coal. They include scientific knowledge. I n terms of control tech- environmental impacts, community and social nology, legislation has more than kept pace, impacts, labor-management relations, work- i.e., it has in some instances assumed a tech- place health and safety, and leasing of Federal nology-forcing function. coal reserves. The policy options relevant to these areas of concern are analyzed in terms of Achieving a policy consensus on environ- the efficacy criteria cited above. mental questions is always difficult. This reflects, in part, the value conflicts noted ENVIRONMENTAL IMPACTS above. It also reflects important gaps and am- biguities in the scientific evidence, for exam- Environmental considerations are an impor- ple, with regard to the health effects of chronic tant potential constraint on any substantial in- long-term exposure to relatively low levels of crease in coal production and combustion. A certain pollutants. The sheer magnitude and number of special characteristics tend to dis- unprecedented nature of some of the potential tinguish environmental from other concerns. impacts tend to induce skepticism regarding One is the range and scale of potential im- the available data. The combination of strong pacts–from minor aggravations to global ca- emotional commitments and uncertain data is tastrophe. Perhaps the best known example in a sure recipe for political conflict. This tenden- the latter category is the possible climatic ef- cy is exacerbated in the case of coal by the 380 ● The Direct Use of Coal time, effort, and cost involved in developing tant and, while existing technologies may not and implementing environmental controls. be optimal, they are workable and effective Many of the participants in the policy proc- and the outlook-for improvement is reasonably ess approach environmental issues from quite promising. In short, after the investment of different perspectives. One viewpoint assumes substantial economic, technological, and the worst regarding potential adverse impacts human resources over recent years, the foun- on the environment from coal development dation for a viable environmental policy for and use. The burden of proof concerning the coal now exists. environmental acceptability of coal is placed Under these circumstances the priority task on the industry. Adherents to this perspective of policy analysis is to identify ways the ex- would sharply limit coal development until isting policy system can be upgraded. Five ma- control technologies have proven their effec- jor tasks appropriate to this effort are: tiveness. As such technologies become available their universal application would be a 1. Identify gaps in present knowledge re condition of coal development. The alter- garding the nature and magnitude of the native perspective is the mirror image: impacts risks to the environment associated with are assumed to be acceptable and manageable coal utilization and the data required to pending clear evidence to the contrary, the fill those gaps. costs of environmental controls are empha- 2 Indicate the prospects and priority needs sized, and control technologies must meet a for the development of specific control test of economic acceptability as well as effec- technologies as a guide to possible Fed- tiveness. The threshold tolerance of environ- eral support. mental disruption is predictably higher among 3. Examine the existing body of law and supporters of the second perspective. regulation for omissions, inconsistencies, and unproductive or counterproductive A final factor complicating the task of envi- requirements. ronmental policy analysis is the sheer complex- 4. Analyze the prospects for effective imple- ity and comprehensiveness of the field. Policy mentation. options designed to minimize the adverse envi- 5. Identify those specific major issues that ronmental impacts of increased coal use range warrant the priority attention of policy- from very specific technological or managerial makers. actions (e. g., lining of ponds used to hold toxic wastes) to regulatory modifications (e. g., regu- A discussion of preliminary findings relevant lation of stack plume opacity), to broad ques- to each of these tasks follows. tions of strategy and philosophy (e. g., the use of effluent charges and other market-oriented mechanisms in Iieu of regulated controls). Data Gaps and Needs

The era of unregulated environmental im- Present scientific understanding of the en- pacts is clearly past for coal, as for other fuels. vironmental impacts associated with coal is There is in place an elaborate, though still in- deficient in a number of areas. The relevant complete, framework of legislation, regula- policy response by the Federal Government tion, and implementing institutions that con- would be support for research designed to sup- stitute a national policy system for managing ply the required data. The following is a pre- the environmental impacts of increased coal liminary list of areas where such additional reuse. The relevant control technologies are at search is needed: various stages in their evolution from concep- ● tion to maturity— but most have at least rate of accumulation of atmospheric COZ reached the point where a first generation and its impact on climate; technology can actually be applied in coal in- ● atmospheric transport of pollutants, the dustry operations. Control technologies for chemical transformations they undergo, combustion emissions are particularly impor- and the paths they travel; Ch. VIII—Policy OptIons ● 381

● correlation between particular pollutants bustion, CO2, is not susceptible to practical or levels of pollutants and human health control by any known technology. (dose-response relationships); A similar agenda of priority needs can be ● relationship between coal combustion, identified with regard to the control of adverse acid rain, and the productivity of crop- environmental impacts of mining. They in- Iands, forests, and freshwater fisheries; clude ways of making constructive use of land ● patterns and consequences of plume that is subject to uncontrolled subsidence, touchdowns; materials and methods for backfilling and/or ● impacts of SO and photochemical oxi- X sealing abandoned mines, improved tech- dants on human health and agricultural niques for the safe burial of mine wastes, new productivity; methods for constructive use or recycle of ● impacts of fine particulate on human mine wastes, improved techniques for control- health; ling acid mine drainage, and methods for re- ● role of coal combustion in the formation claiming particularly sensitive land forms (e. g., of hydrocarbons and their impact on steep slopes, prime farmland, etc. ) after sur- human health; and face mining. ● physical and chemical interaction of dif- Other control technologies that warrant at- ferent pollutants, soils, and hydrological tention and the commitment of resources are configurations (i. e., the role of site charac- regenerable scrubbers, impermeable land fills teristics in determining the impact of pol- for FGD sludge, and water-conserving designs , lutants and pollutant disposal methods on for energy facilities including dry and wet/dry ground and surface waters). cooling systems.

Development Priorities for Adequacy of Existing Law and Regulations Control Technologies A substantial body of law and regulation A variety of control technologies and tech- relevant to the control of environmental im- niques is presently or prospectively available pacts from coal development is presently in for dealing with the multiple assaults on the place. There remain, however, areas of omis- environment from coal development. These sion, inconsistency, and weakness that warrant vary widely in effectiveness, stage of develop- congressional attention. I n part, the problems ment, and future promise. The task from a pol- transcend coal and relate to a lack of Federal icy standpoint is to identify those areas where policy in such major related areas as water problems remain, where technological innova- resource management, conservation, land use, tion and development are needed, and where and energy facility siting. Mechanisms for Federal actions should make a difference. long-range planning and for resolving inter- With regard to control of the combustion state and interregional problems are generally products of coal the priority needs are for im- weak. There is, moreover, still no comprehensive, consistent national policy toward energy proved NOx control technologies, electrostatic precipitator designs that are effective against generally and coal specifically. For example, small particulate and low-sulfur coal, lower there is no Federal policy to have the prices of all fuels reflect their true relative costs or to cost baghouses, techniques for minimizing provide a consistent regulatory framework for hydrocarbon emissions from small boilers, and all modes of transporting coal. Federal legisla- the improvement of new technologies for combustion (FBC) and fuel cleaning (SRC). The tion and regulation on coal reflect an unre- prospects in each case are sufficiently promis- solved tension between the goals of environ- ing to warrant the commitment of substantial mental protection and energy development, R&D funds. There is also need for continued with the task of drawing the balance left to the upgrading of FCD scrubbers with regard to courts. their reliability, maintenance requirements, Agency mandates and jurisdictions overlap, and costs. One major emission from coal com- as with the Department of Energy (DOE) and

44- 102 0 79 26 382 The Direct Use of Coal the Department of the Interior responsibilities ronmental guidelines. This solution may be for leasing and the Department of the Interior threatened, however, by an increasing inability and the Environmental Protection Agency or unwillingness of States to bear the costs of (EPA) jurisdictions over the implementation of such programs in a time of financial strin- SMCRA. In some cases legislation has resulted gency. in environmental programs seemingly at cross There are some specific areas of omission in purposes. In the past, environmental legis- environmental legislation and regulations con- lation tended to focus on a specific media and cerning coal. Current regulations under the be blind to the effects of control efforts on Clean Air Act do not deal with the long-range other media. More recent legislation has at- transport and transformation of combustion tempted to address this problem, e.g., in for- products. Thus the regulations control sulfur mulating New Source Performance Standards dioxide (S02 ) but not the more dangerous (NSPS) regulations, their impact on nonair en- transformation product—sulfates. They also vironmental quality must be taken into ac- leave small (respirable) particulate and trace count. The problem is in a sense irresolvable hydrocarbons inadequately regulated. The because it is an immutable physical law that small boilers that would be the principal matter cannot be destroyed. Thus the Clean source of hydrocarbons are not federally Air Act amendments that in effect mandate regulated. Other areas where the present legal- FGD scrubbers create a substantial land and regulatory framework is incomplete include water pollution problem in the form of large leasing policy and whether sludge will require quantities of sludge. disposal as a hazardous substance.

Existing law deals creatively with another Table 62 presents a summary of key prob- tension—that between the need for uniform lems and possible new policy initiatives orga- national standards and States rights— by man- nized around specific pollutants in each medi- dating State implementation of Federal envi- um.

Table 62.–Environmental Impacts (Land)

Problem Impacts Solutions/policies Subisdence Disrupts surface use, damages structures, ● Prohibition of underground mining beneath lowers property values. densely populated areas pending demonstrated ability to prevent subsidence. ● Alter law to make mine owner directly responsible to surface owner. ● Government-financed insurance to compensate surface owners for damage resulting from subsidence. ● Tax on underground mining to compensate for future damages. ● Research regarding controlled subsidence: Planned subsidence for active mines; induced subsidence for inactive mines. ● Increased research regarding preventing subsidence by using FGD sludge, FBC sorbent, or other materials, to backfill abandoned mines. ● Research regarding productive uses for land subject to uncontrolled subsidence.

Disposal of mine wastes Surface disposal source of declining esthetic ● R&D regarding reuse of waste materials (gob, preparation plant and property values, erosion, landslides, (e.g., in highway pavement, as a mineral wastes, sludge from treat- and gob pile fires. source, and as backfill for underground ment of acid mine drain- mines. Major objective is to find methods age) and combustion prod- All disposal methods risk pollution of sur- to prevent leaching of toxic materials, to ucts (ash, slag, FGD sludge, face, ground water by leaching. allow disposal under RCRA. FBC sorbent) Ch. Vlll—Policy Options ● 383

Table 62.— Environmental Impacts (Land) —Continued

Problem Impacts Solutions/policies

Reclamation of surface- Inadequately reclaimed land is less produc- ● Monitor implementation of Surface Mine mined lands tive and may be subject to erosion, land- Control and Reclamation Act (SMCRA). slides, and acid mine runoff. ● RD&D regarding feasibility of fully reclaiming and arid Western forest lands, steep Have had enforcement problems with smaller slopes, prime farmland and alluvial valleys. mines. ● Limit surface mining to lands where reclamation to former higher use is virtually certain. Develop criteria by which all coal lands can be classified in terms of their eligibility for surface mining. SMCRA would accomplish this if State programs are strong. Adopt measures that favor underground mining (e.g., requirement that FGD scrubbers be placed on existing as well as new plants).

Acid mine drainage Pollution of surface and ground water to the detriment of both flora, fauna, and commu- ● Active mines: Strengthen enforcement effort nity drinking water. to insure full coverage of small mines, detec- Problem most acute regarding abandoned tion of illegal mining. underground mines in pyrite rich strata. ● Abandoned mines: Lengthen bonding period to ensure permanent acid control. Have had enforcement problems with smaller ● Establish a fund to pay for control failure, mines. paid for by tax on mining. ● RD&D regarding improved control methods and technologies.

Land disposal of ash and Leaching of salts and toxic trace elements ● (See disposal of mine wastes and combus- FGD sludge into ground water and salts, trace elements, tion products under land impacts above.) and small particles into surface flows. ● Research regarding pollutants, soils, and hydrology to obtain detailed understanding of site factors that influence impacts. ● Incentives to use regenerable scrubbers or to recycle waste from nonregenerable systems. ● Monitor employment of existing technologies to determine if present incentives are adequate.

Water consumption require- Stress on limited water supplies in arid . Require water conservation in the design ments of plant cooling sys- regions (e.g., Upper Colorado River Basin). and operation of energy facilities (e.g., dry terns and wet/dry cooling) in water-short areas. ● Water conservation in arid lands agriculture as a means of freeing additional water supplies. Methods include: ● More efficient irrigation. ● Switching to less water intensive crops. ● Adding irrigation efficiency and/or water use requirements to rules governing Fed- eral water projects. ● Reexamination of new impoundment and irrigation projects designed to supply low cost water to farmers. 384 ● The Direct Use of Coal

Table 62.—Environmental Impacts (Air Quality) —Continued

Pollutant Impacts SO Solution/Policies

Stunts agricultural crops. ● Possible adverse health effects. Acid rain. ● Visibility degradation. ●

●

Particulates Adverse health effects of fine particulate. ● Institute particulate emission standards that Visibility degradation. distinguishes by particle size. . Require baghouses on new plants. . R&D regarding new designs for electrostatic precipitators.

Hydrocarbons Possible high levels of hydrocarbon . Increased research regarding chemistry of emissions from small boilers with conse- formation and health impacts. quent adverse impacts on health. ● Increased research regarding levels of hydrocarbon emissions from small boilers. . Establish design standards for small units. ● R&D regarding emission controls for small units. ● Devise system for monitoring and inspecting small units. ● Avoid promoting coal use in small boilers.

Implemental ion tention because implementation questions will loom increasingly large as the basic framework Data may be adequate and regulations ap- of environmental legislation and regulation is propriate, but if the law is not implemented lit- put in place. In the simplest case implementa- ble will be achieved. The process of implement- tion involves the installation of a particular ing environmental rules will require careful at- piece of equipment–with Government im- Ch. Vlll—Policy Options ● 385 posed sanctions the price of failure or recalci- THE ROLE OF COST/BENEFIT ANALYSIS trance. Increasingly, however, implementation All environmental decision making involves rests on more complex and less tangible at least an implicit weighing of costs and actions–planning, management, and general benefits. Even a conscious decision not to procedures. This is due to the site-specific measure costs — as in the Clean Air Act’s re- nature of activities related to coal develop- quirements for establishing ambient air quality ment (e. g., reclamation) and the interaction of standards to protect public health — can be in- environmental impacts with social, political, terpreted as a decision that the benefits of and economic concerns. To the extent that im- health are so high that they must outweigh any plementation (e. g., of combustion controls) costs incurred in its protection. can be based on technical hardware, it will be easier than if it depends on procedures. Im- Much environmental legislation contains plementation questions will focus on the language requiring a consideration of “costs” various major items of recent legislation and in standard-setting. For example, the Clean Air regulation, notably the SMCRA, the Clean Air Act requires EPA to consider, in specifying a Act amendments, the revised requirements NSPS for controlling air pollution, “the cost of and procedures for environmental impact achieving emission reduction(s), any nonair statements (E IS), and the Toxic Substances quality health and environmental impact, and Control Act. The stringency and vigor, in- energy requirements. ” However, in virtually cluding timetables, with which these are inter- every case the costs of control are described as preted and enforced will have a major influ- a constraint rather than as a factor to be bal- ence on the way the balance is drawn between anced against benefits. In all ai and water coal development and environmental protec- legislation spelling out the terms for selecting tion. This in turn will depend in part on how ef- emission limitations, EPA is asked to select the fectively the responsible executive agencies “best technology available,” not the most (EPA, DOE, the Department of the Interior, cost-effective. and the Council on Environmental Quality In most public opinion surveys, Americans (CEQ)) can coordinate their activities. More have supported spending for environmental specific implementation questions relate to improvement, even when such spending the content of forthcoming regulatory deci- causes some economic hardship. However, this sions regarding leasing and whether sludge wilI support is based on the public’s perception be classified as hazardous. Also, the thorny that the benefits of environmental standards issue of how to deal with a State that is out of outweigh their costs. I n the wake of a variety compliance with Federal clean air standards as of regulatory decisions (e. g., the Clean Air Act a consequence of pollution transported from amendments and the new proposed NSPS for out of State will have to be addressed. control of SOX, the proposed mining regulations issued by the Office of Surface Mining) Major Policy Problems designed to strengthen environmental controls, the industries subject to them have at- Among the many policy issues relating to tempted to change public perception about the control of the environmental conse- the balance of costs and benefits. In addition, quences of coal development, three stand out: there have been many calls for requiring regulatory agencies to balance costs and benefits 1, the utility of cost/benefit analysis, and explicitly defend their selected regulatory 2. the role of Government relative to the strategies in these terms. private sector in the development of control technologies, and Arguments raised in favor of requiring cost/ 3. whether national point source emission benefit analysis include the following: standards should be imposed on existing 1. While general quantitative understanding as well as new faciIities. of environmental impacts of coal devel- These are addressed in turn. opment may not be well developed, many 386 ● The Direct Use of Coa/

individual areas of impact can be meas- tion that has been claimed between com- ured. (E. g., some of the costs of reclama- munity death rates and sulfate pollution tion failure, pollution crop damages, costs levels. Respectable scientific support can to municipalities of pollution of drinking be found for estimates of annual deaths water sources. ) Thus, cost/benefit type caused by today’s air pollution ranging analyses may be appropriate for some from zero to tens of thousands. standards, if not for al 1. 3. Even when environmental impacts can be 2. The problems currently associated with quantified in physical terms, it is difficult identifying and appropriately quantifying to translate these impacts into a “lan- benefits may never be resolved unless guage” that allows comparison with regulatory agencies are forced to take monetary costs of control. The state of benefits into account in their decision- the art of such translation is not well ad- making. With a limited research budget, vanced. the environmental agencies are not likely 4. The level of uncertainty involved in iden- to pursue vigorously research that is not tifying and quantifying the benefits of directly required for their regulatory func- pollution control could considerably in- tions. For example, EPA virtually aban- crease the incidence of judicial rejection doned its research program on environ- of environmental standards. For example, mental benefits and disbanded the re- EPA has had considerable difficulty in sponsible organization (the Washington promulgating enforceable effluent guide- Environmental Research Center) in a 1975 lines for water pollution control, which re- reorganization. (Some funding has recent- quire mainly technical and economic ly been restored to this research area.) analysis. A requirement for a careful bal- 3 Analytical techniques for dealing with risk ancing of costs and benefits could make and uncertainty can address many of the matters far worse. problems associated with cost/benefit 5 Any requirement to determine costs and analysis. benefits and/or to balance them in arriv- 4. Public acceptance of expensive environ- ing at regulatory decisions may substan- mental controls may ‘be jeopardized tially delay the standard-setting process. unless the benefits that these controls pro- Aside from the environmental damage vide are clearly identified. that may occur, delays could hamper energy development by adding to the There are a number of arguments against re- uncertainty currently faced by entre- quiring such a formal weighing of costs and preneurs. benefits in environmental standard-setting: At least two options are available for deal- 1. The cost/benefit calculations performed ing with these questions short of requiring ex- in the past by public works agencies such plicit cost/benefit analysis for all standards. as the Bureau of Reclamation and the Ar- Congress could: my Corps of Engineers have produced a widespread aversion to this form of anal- Option A. ysis. Environmental benefits, being inherently difficult to quantify, have tended to Require regulatory agencies to state the ex- be neglected in quantitative evaluations pected benefits of their proposals. This would to the detriment of environmental values. avoid the need for the agencies to conduct the 2 Knowledge about some of the most criti- difficult analysis involved in balancing eco- cal environmental effects of coal develop- nomic costs and poorly quantified benefits ment is inadequate. Major controversies (such as esthetic improvements, statistical rage as to the magnitude and even the ex- risks of health injuries, etc.), but would force istence of specific environmental and an explicit public discussion of benefits and health impacts. A prominent example is probably would provide incentives for benefits the controversy surrounding the associa- research. Ch. Vlll—Policy Options ● 387

Option B. incentive to avoid demonstrating new Establish an independent commission that controls or improvements in existing con- will decide which, if any, forthcoming en- trols. vironmental standards must be set by an ex- ● An equipment manufacturer cannot plicit balancing of costs and benefits. The “demonstrate” a control technology basis for the commission’s decisions would be unless he places it on a commercial-scale the state of the art of impact assessment for plant. To do this he needs the cooperation the pollutants in question. This would take in- of the polluting industry, which might not to account the sharp variations in the state of be forthcoming without Government in- environmental research, although it may not tervention for the reason just indicated. ● provide an incentive for more vigorous re- EPA has been generally quite successful in search (actually, it could provide a negative in- its control development and demonstra- centive if the agencies perceive cost/benefit tion program. Examples of successful con- analysis as an undesirable requirement). The trols developed or improved through this commission couId be given the authority to re- program include combustion modifica- view the environmental research programs of tion for NOX control and flue-gas scrub- the regulatory agencies to ensure that fruitful bers for SOX control. areas of research are appropriately pursued. ● An active R&D role by EPA and DOE is necessary in order to maintain the in- WHO SHOULD DEVELOP house expertise to allow competent, in- POLLUTION CONTROLS? formed policymaking about control levels and technologies required under the Interest in the control of SOX and NOX emissions has led to the development of flue-gas Clean Air and Water Acts. ● In those areas where the polluting indus- S0x and NOX scrubbers, new combustion technologies such as fluidized-bed combustion, tries are public utilities, the behavior of and new fuels such as SRC. Many of these tech- their regulatory commissions can skew nologies are in early stages of development, their behavior away from searching for and all will undergo continued refinement so the most efficient, least expensive con- long as they are considered desirable. The controls. For instance, widespread allowance tinued rapid development of such control of fuel transportation cost “pass- technologies is critical to maintaining an effec- throughs” and delays in granting rate in- tive environmental protection strategy, but the creases for capital expenditures tend to most efficient means to achieve such develop- push utilities away from capital-intensive ment has been a subject of considerable control solutions even if these are the debate within the Government. The major least costly and most effective options in issue is the role Government should play in the long run. either carrying out the required development The major argument in favor of allowing in- itself or supporting comparable efforts by industry to be the prime mover in developing dustry. This debate is equally applicable to control technologies is that Government water and land polIution control. Positions should not attempt to do what private industry range from advocacy of Government “in can do as welI or better: house” development to the commercial stage, ● The polluting industries have the largest to total reliance on industry. (For example, EPA reserve of personnel who are intimately and the Office of Management and Budget familiar with the processes to be con- (OMB) have argued for years over E PA’s active trolled and in an ideal position to develop role in developing scrubbers. ) the most efficient technologies possible. The major arguments in favor of active Gov- In addition, the industries have the strong ernment participation are: incentive to develop controls that are inexpensive and conserving of their re- ● NSPS must be based on demonstrated sources; this incentive may be weak in technologies; therefore, industry has an Government-research activities. 388 ● The Direct Use of Coal

● A private pollution control industry exists vironmental impacts of energy development that will pursue control technology devel- depend strongly on the extent of control of opment even if the polluting industry does nonenergy industry. Thus the environmental not wish to. Also, there are cases of in- hazard posed by SO2 emissions from a power- dustries generating considerable profits plant may be great or slight depending whether from marketing controls they have devel- there are other sources of sulfur emission (e. g., oped for their own plants; this phenom- smelters) nearby. EPA’s control program for in- enon adds considerably to their incentive dustrial processes has been at a low level of for successful and efficient operation of support for several years; increased spending control innovations. in this area could conceivably have an even- ● Private entities such as the EIectric Power tual payoff in removing some constraints from Research Institute (EPRI) are heavily in- energy development (e. g., in present nonattain- volved in pollution control R&D, ap- ment areas). A corollary of this option could be parently at a high level of professional to restore E PA’s authority to pursue large-scale competence. demonstration of energy-related pollution con- ● The need to get facility siting approval in trols; at the moment, DOE has this responsibili- difficult areas— with bad meteorology, ty. Although DOE has recently indicated an in- pre-existence of high levels of air and terest in pursuing the development of im- water pollution, or proximity to sensitive proved controls for existing conversion tech- ecological areas — provides a continuing nologies, its major emphasis in the past has incentive for industry to develop im- been on new technologies such as FBC, gasifi- proved pollution controls. cation, etc. ● The Clean Air Act allows exemptions to This option clearly dismisses the argument NSPS and BACT requirements for firms in- that Government should not be heavily installing promising experimental equip- volved in activities that private industry is ment, providing additional incentive for capable of doing (however, it must be recog- private development. nized that most of the actual work sponsored The options available for dealing with this by the Federal Government is contracted out question are: rather than being conducted in-house).

Option A. Option C. Maintain the status quo, i.e., continue Substantially decrease Government spend- Government spending in control development ing in pollution control development, while at its current level while continuing to coop- taking steps to provide increased incentive for erate with private development of controls (for industry to expand its efforts. These incentives instance, EPA and EPRI have a cooperative might include: 1 ) changing the language of the agreement for sharing research results). This Clean Air Act to make control requirements option recognizes the value of encouraging a more “technology forcing” (as has been done “dual track” of control development and ac- with requirements for automobiles); 2) using cepts the existing incentives for industry economic inducements such as accelerated development of controls as requiring Govern- rates of depreciation for experimental technol- ment participation. ogy, liberal Federal support for capital and operating costs of industry demonstration Option B. projects, Federal assistance in persuading local rate commissions to allow utilities to imme Substantially increase Government spend- diately incorporate the expense of new tech- ing in pollution control technologies, especial- nologies into their rate base, and tax credits for ly in areas where control development does testing of new technologies. not appear to match the seriousness of pollution problems. Although spending for controls This option clearly is derived from the phi- on energy-producing industry is high, the en- losophy that private industry is the ideaI devel- Ch. Vlll—Policy Options ● 389 oper of controls for its own technologies, whiIe coal use, the large quantity of emissions from recognizing that the nature of the marketplace existing powerplants will remain unaffected by requires special incentives to encourage this NSPS and is not expected to decrease substan- development. This option accepts the risk that tially in this time period. The questionable industry could choose to avoid development wisdom, from a national perspective, of simul- of new controls and presents the Federal Gov- taneously requiring maximum controls on new ernment with the choice of either taking harsh powerplants and lenient or no controls on a measures (fines or plant closings) or delaying number of large existing plants is highlighted or loosening control requirements. when the potential costs of controlIing some of the existing plants are examined. For exam- NATIONAL CONTROL STANDARDS FOR ple, if a utility currently using 4 percent sulfur EXISTING FACILITIES coal could obtain 2 percent sulfur coal at a $10/ton premium, it would achieve a 50- Under the present regulatory structure for percent reduction in S02 emissions at a cost of control of air polIution jurisdiction over new $250/ton of emissions reduced. sources is shared by the States and EPA but control over existing sources is the exclusive Because long-term stabilization and reduc- responsibility of the States. This has created tion of SOX emissions depend on the gradual concern about control of long-range, interstate movement to reduced operations and eventual transport of pollution and our ability to con- retirement of the older uncontrolled plants, struct a rational, cost-effective strategy for changes in their expected operational patterns emissions reductions. The divided regulatory and retirement schedules can have severe ef- structure may be adequate for protecting local fects on national emissions levels and air quali- air quality from locally produced pollution, ty. The sharp differences between the op- but it contains no effective mechanism for pro- erating costs of old and new plants due to tecting against air quality degradation caused emission control requirements or the latter by the interstate transport of pollution from may make the intensive operation of older existing sources. This happens because the plants more attractive to the utilities. NSPS re- characteristics that tend to lead to long- quirements could have a perverse effect of in- distance transport —tail stacks and persistent creasing the emissions in some areas by en- winds — also tend to minimize impacts on local couraging a shift of baseload operations to the air quality. Pollution sources with these older, poorly controlled plants and by dis- characteristics usually would be loosely con- couraging their retirement. Computer model- trolled by their SIPS. For example, large coal- ing has tended to confirm the potential for this fired powerplants in the Ohio River Basin have effect. been associated with elevated sulfate levels Individual States are unlikely to change hundreds of miles downwind, while their SIPS voluntarily their SIPs to eliminate these poten- allow them to burn high-sulfur coal with no tial problems. An increase in control require- controls. ments would trade an economic cost to a Because of EPA’s lack of direct control of State’s constituents for a benefit to the existing sources; national strategy must con- residents of other States. I n some cases, in- centrate mainly on restricting emissions from creased control of SOX could require a shift to new sources. The Clean Air Act’s requirement out-of-State sources of coal, hurting in-State for continuous technological controls leads to producers and miners. Finally, there is substan- a high cost of S02 emission reduction for new tial controversy surrounding the impacts of sources; estimates of the cost of the EPA and long-range transport (acid rain, sulfate, health DOE proposals range up to $1 ,000/ton of emis- effects, etc. ) so that the known benefits of sions reduced, and total costs of the NSPS con- emission reductions are less tangible than the trols will be several tens of billions of dollars costs. The options available to Congress for by 1990. Although these controls will slow the dealing with the issue of further controls on ex- rise of SOX emissions in the face of expanding isting faciIities are: 390 ● The Direct Use of Coal

Option A. bodies the idea that risks of the type asso- Maintain the present divided regulatory ciated with coal pollutants are unacceptable. structure and forego additional reductions in However, implementation would be difficult. emissions from existing sources untiI either fur- Besides the cost, the option would present ther research results are obtained or less ex- substantial resource problems: the need to pensive or disruptive control alternatives are quickly construct large numbers of scrubber developed. This option can be combined with installations, the requirement to safely dispose increased funding for research on the impacts of large quantities of scrubber sludge, and the and mechanisms of long-range pollutant trans- need to train large numbers of operating per- port and for development of controls. Control sonnel for new control systems. Given the dif- development would focus on low-cost alterna- ficulties that American utilities have had in tives suitable for retrofit. Examples are com- operating scrubbers, this resource problem petitive low-sulfur/low-ash fuels Iike SRC, low- could substantialIy delay implementation. NO burners, and modifications to elec- X Option C. trostatic precipitators to provide better fine- particle control. This option avoids additional Amend the Clean Air Act to provide for regulatory costs unless they are absolutely Federal control of existing pollution sources. necessary or unless new controls can sharply Selectively increase controls on large facilities reduce costs. The option is essentially a delay- where the SIPs have been determined to be le- ing tactic until more information is obtained nient or when the facilities have been deter- and more options are available. It can be sup- mined to be a major source of problems asso- ported by recognizing that emissions are not ciated with long-range transport of pollutants. expected to rise rapidly in the next decade or Also, increase pressure to enforce SIP dead- so. However, it involves the implicit accept- lines with tight enforcement resources and/or ance of the risk that present emission levels are economic incentives. The SOX controls en- causing significant levels of health and envi- visioned in this option would be primarily low- ronmental damage. These risks are discussed sulfur coals, cleaned coals, and eventually, in detaiI in chapter V. SRC. Selective use of scrubbers might be justified for newer plants. Also, the R&D program described in Option A would be adopted. As in Option B. Option B, this course of action places a high Amend the Clean Air Act to provide for premium on risk avoidance. It considers the Federal control of existing pollution sources. potential dangers attributed to acid rain, fine Require existing facilities to satisfy the same particulate, and sulfates as significant enough emissions standards as new facilities. Exempt to warrant considerable expenditure of control plants that are close to retirement from full funds, but attempts to keep expenditures sig- compliance, but require fuel switching to nificantly below the costs of total control. It clean or cleaned coals when this alternative is recognizes the variations among SIP regula- available. Successful implementation of this tions and the role that location plays in deter- option would drastically cut emissions of SOX mining the seriousness of impacts. Neverthe- and particulate. But because retrofit of con- less, it remains (like scenario B) an expenditure trols is more expensive than incorporating the of considerable funds to combat impacts that controls in the plant design, and the existing for the most part have yet to be definitely coal-fired capacity will represent the majority proved; it can be expected to produce consid- of total coal-fired capacity for several dec- erable opposition from utilities and industry ades, the cost of this option should be in ex- on these grounds. Also, it can be expected to cess of that predicted for the proposed NSPS be opposed by Midwestern States whose for steam electric utility boilers through 1990, powerplants, now burning local coal, might be or several tens of billions of dollars. For some asked to shift to low-sulfur coals from out-of- plants, electricity production costs would in- State sources. This latter problem can be over- crease by 20 percent or more. This option em- come by speeding up the demonstration of ad- Ch. Vlll—Policy Options ● 391 vanced coal-cleaning processes and allowing stances, to supplementing existing policy the States to require their use in favor of out- mechanisms. Second, value disagreements of-State coals. concerning what are positive and what are negative impacts result even where the nature of these impacts is understood. Whether eco- COMMUNITY IMPACTS nomic growth should be viewed as a positive or negative phenomenon is itself the subject of The impacts of coal development on local dispute. Value conflicts extend to other areas. communities and the response of those com- For example, should community impact costs munities will be a significant factor influenc- be borne by energy consumers through forcing ing the future of coal as a national energy the coal companies to internalize such costs source. Some of the impacts— notably the gen- and pass them along in the form of higher eration of investment and employment in eco- prices? Or should such costs be paid out of nomicalIy depressed areas — are almost univer- general tax revenue in the form of Government sally viewed as positive. The adverse impacts, loans and grants to impacted communities? however, are of greatest concern to policy- What is the extent, if any, of Government obli- makers because they may jeopardize the pro- gation to assist communities that will ulti- jected conversion to coal and require ameli- mately benefit economically from Federal pol- orative action by Government. The disloca- icies to stimulate coal use but are unable to tions and social ills associated with boom- adequately cover the “front-end” costs of in- towns may lead to high worker turnover and frastructure and community service develop- low productivity in western mining areas. The ment in the short term? utter inadequacy of such basic social infrastructure as housing, roads, and sewers may Clearly, policies designed to ameliorate severely inhibit efforts to rapidly expand Appa- adverse impacts must recognize these uncer- lachian coal production. Community resist- tainties and value disagreements. This can be ance to siting of coal-fired powerplants may in- done with a policy approach that is basically duce further slippage in already lagging con- accommodational, that seeks to anticipate the struction timetables. Consequently, a viable concerns of interested parties and deal with national energy program would logically in- them in a way that encourages compromise. clude policies designed to alleviate the Such an approach has two principal charac- negative community impacts associated with teristics. coal development. First, all parties affected by increased coal use are able to participate in decisions con- Such policies, if they are to be effective, cerning the location, timing, and scale of coal must recognize two basic characteristics of the developments that directly concern them. Sec- present situation. First, there is considerable ond, Federal policies are designed to distribute uncertainty regarding the nature of coal the risks, costs, and benefits equitably among development impacts and the balance of ben- all parties affected by increased coal develop- efits and costs that will accompany them. Policy perspectives vary accordingly. Pro- ment. The process of participation and consultation has two drawbacks; it can be expensive ponents of community aid programs contend and time consuming. However, to the extent that future tax revenues and other economic benefits of coal development will never cover that adverse impacts can be anticipated and forestalled through consultation with the af- all the costs to the locality, thus necessitating fected communities, the economic costs of a real net transfer of Government funds. An ameliorating those impacts will be lessened. alternative view sees energy growth as similar Moreover, the result can be a general upgrad- in its impacts to other sources of growth and ing of community capabilities. more likely than most to pay its own way in terms of community costs and benefits. From Adverse community impacts associated with this perspective, the Federal Government role coal development take three major forms: 1) should be limited, except in special circum- community services and infrastructure are 392 ● The Direct Use of Coal

overloaded, 2) local economies become over- services and infrastructure are often extremely heated and distorted, and 3) social instability limited because of the characteristically small accompanies a decline in some aspects of the size and isolated location of Western coal quality of life. These are briefly summarized as towns. The explosive increase in demand for a prelude to the analysis of possible policy community services associated with large- responses. scale coal development will occur before coal revenues become available. This front-end fi- Overload of Existing Community Services nancing problem is exacerbated by the present small tax base and lack of bonding history or In many parts of the Eastern coalfields ex- authority of the communities in question and isting services are incapable of coping with the the long Ieadtimes required to initiate coal effects of a rapid expansion in coal develop- production. The problem is in some instances ment. The weakness has multiple dimensions. aggravated by jurisdictional mismatches Local government services and infrastructure where the productive enterprise (and conse- (utilities, police, roads, flood control, etc.) are quently the tax revenue) is located in a dif- often woefully inadequate. Public utilities are ferent political jurisdiction from the locality frequently incapable of meeting any signifi- that must bear the brunt of the social costs. As cant additional demands without an overhaul in the East, supplying sufficient housing is a of the entire system. Consequently the mar- serious problem. The principal causes are in- ginal costs of increased utility services are adequate sources of financing and the limited often very high. The commercial services and volume capacities of local builders. In sum, the supporting infrastructure in the private sec- western efforts to provide community support tor are also weak. Professional and skilled per- to coal development must start largely from sonnel are difficult to attract, given the living scratch. Compared to the East there is virtually conditions in the coal towns. Private invest- no capability in place, but often there is also ment is discouraged by the risks associated no service deficit to make up and no anti- with the historic boom and bust cycle of the quated infrastructure that must be dismantled. coal industry. Local financial institutions have Further, there is nothing comparable to the very Iimited resources. The tax system, particu- pervasive constraint in the East imposed by the larly as it relates to the coal industry, is inade- high and virtually irreducible ratio of popula- quate, reflecting a general weakness in local tion to habitable land. political institutions. Coal lands and enter- prises are characteristically taxed at low, Economic Dislocation sometimes spectacularly low, rates. In many locales housing is in desperately short supply For the coal towns the benefits of a rapidly due to rugged topography, large landholdings expanding coal industry are principally eco- by coal companies, a shortage of mortgage nomic, but there are economic costs to the money, high utility costs, a low volume capaci- community as well. In the East as coal-related ty of local builders, the absence of public incomes and demand for goods and services housing programs, and other causes. Thus, in rise, the commercial sector is often unable to coping with the impacts of increased coal pro- keep pace, with rapid inflation the result. For duction the Eastern coalfield communities those in the community on fixed incomes or begin in a serious deficit situation with already otherwise not positioned to benefit from the inadequate services and supporting infrastruc- income effect of an expanded coal industry, ture. This situation rests, in turn on basic eco- the consequences can be devastating. Other nomic, social, and political underdevelopment costs of coal growth can include a reinforce- rooted in a lack of economic diversification ment of the existing single primary product and absentee ownership of coal-related re- economy, with its associated vulnerabilities. sources. There are opportunity costs as coal development inhibits or forecloses other beneficial The Western coalfields present a different, economic activities, notably recreation and although still troubled, picture. Community tourism. Ch. Vlll—Policy Options ● 393

In the coal boomtowns of the West severe First, improve the access of communities to inflation is also a problem. Opportunity costs information concerning coal development im- are present here as well, particularly disruption pacts. One way would be to establish a single of the rural ranching economy because of coal national energy facility siting schedule, per- development. haps as part of a national energy information service. The objective would be to provide ad- Social Instability and Quality of Life vance information about energy development plans to potentially affected communities. In For many citizens of the community the this regard, DOE might be empowered to gath- social and psychological costs of rapid coal er and disseminate energy-impact-related data development may be the most difficult to available within the Federal Government, in- bear. Heavy coal truck traffic on eastern rural cluding OCS and BLM leasing plans and indus- roads not designed for such use can pose a try projects submitted for Federal licensing or growing threat to public safety and conveni- approval. (Some regional efforts of this nature ence. Overloading of local services plus sheer exist, For instance, E PA’s Region 8 office in congestion can mean increasing emotional Denver publishes a continually updated list of stress and even mark a perceived decline in the planned facilities). On request the Federal quality of life of established eastern commu- Government might provide any locality sched- nities. The boom and bust history of the indus- uled to be impacted by a major new energy try can induce a basic mood of uncertainty facility with an assessment of the effect of that about the future that contributes to the social development on the community. Such an and psychological malaise. In the West, boom- assessment might be conducted as a joint Fed- town conditions can lead to crowding, emo- eral-State-local effort. This could be ac- tional stress, family problems, juvenile delin- complished through existing E IS procedures if quency, crime{ alcoholism, and other social ills they were modified to give added weight to rooted in a pervasive sense of rootlessness and community impacts along with the existing at- impermanence. The situation is exacerbated tention to impacts on flora and fauna. by the tendency of coal development to erode the settled ranching culture of the area. Here Second, increase opportunities for local au- too, uncertainties about the future of the in- thorities and citizens to participate in deci- dustry can reinforce other problems. sions concerning the siting, construction, or expansion of coal facilities. This might involve These factors can adversely influence coal support, in the form of financial assistance and output in a number of ways, but particularly in access to information, of citizen interest terms of their impact on the work force. Miner groups acting as interveners in Government dissatisfaction with community living condi- proceedings concerning facility siting, and tions can translate into high worker turnover, related decisions. Similarly, mechanisms might absenteeism, low productivity, and strikes. be established for giving State, local, and tribal The policy options available for dealing with authorities earlier access to relevant Govern- these problems fall into two categories: gener- ment deliberations than is now commonly ic measures designed to improve the process available. Consideration might also be given to of coping with coal development impacts na- supplementing the modified E I S procedures tionally and specific initiatives designed to suggested above with a requirement that com- solve particular problems, some of which are panies planning to construct energy facilities peculiar to one geographical area. These two propose actions they will take to alleviate categories are discussed in turn. those adverse community impacts that have been identified.

General Policy Options Third, improve the capability of localities to manage coal development impacts. This might Five major policy initiatives of this type can take the form of Federal technical assistance be identified: for development, planning, and impact assess- 394 ● The Direct Use of Coal

ment. The Government could also ease the fi- Administration of the Department of Com- nancial burden on localities seeking to cope merce are prominent examples. A community with adverse impacts. This might involve grant suffering the dislocations of a coal boom can- and loan programs to finance public sector not qua! if y under these criteria. personnel, construction, and other costs. The eligibility requirements of existing Federal Specific Policy Options community assistance programs might be Listed below are specific Federal actions modified to give priority to coal-impacted that might alleviate some of the potential communities. The Federal tax code could be adverse impacts associated with coal develop- amended to encourage prepayment of State ment. These are in addition to the broader and local taxes by industries planning coal fa- generic actions outlined above. cilities. Also Federal programs can be used to encourage State initiatives to deal with com- COMMUNITY SERVICES AND INFRASTRUCTURE munity impacts, e.g., by according priority to ● Target Federal highway funds toward road States that have established mechanisms for construction (including overpasses), im- State assistance to coal communities. Finally, provements, and repairs necessitated by Federal assistance could facilitate direct com- coal development. munication between responsible officials from ● Increase Federal funds available through different coal communities, thereby enabling the Farmers Home Administration for community governments to share experiences water and sewage systems in coal-im- in dealing with energy development impacts. pacted localities and broaden eligibility for such assistance to include communi- Fourth, improve coordination of Federal as- ties with over 10,000 population. Larger sistance programs. A variety of steps might be communities do not presently qualify for taken in this regard. DOE, for example, could FmHA funding. be designated as the lead Federal agency with ● Establish a new Federal loan program to responsibility for coordinating Federal impact finance the construction of public works assistance programs through an interagency needed to meet demands resulting from board at the regional level. An office within coal development. An alternative would DOE could be established to coordinate com- be to provide a Federal guarantee of local munity impact assistance planning with other bonds to finance such construction. energy-related planning. The Federal Regional ● Compel coal development companies to Commissions could be asked to sponsor reg- internalize some of the risk associated ular assessments of coal-related community with front-end financing by prepayment impacts on a regional basis. The Commissions of taxes, provision of certain community might also be accorded a substantive voice in services, the allocation of Federal impact assistance. or guarantees of municipal bonds as a condition for obtaining needed Federal-State coordination might be improved Government licenses and approvals. Al- by a requirement that Federal decisions affect- ternatively, an attempt could be made to ing the siting or expansion of energy facilities induce such actions by coal companies in be compatible with federally approved State return for tax breaks or other induce- impact mitigation strategies. ments. Fifth, modify the point criteria by which the ● Expand Federal subsidy programs for low- eligibility of communities for Federal assist- and moderate-income housing such as the ance is determined. These criteria are present- FmHA homeownership program, Other ly designed to permit assistance to communi- possible Government initiatives to allevi- ties in economic decline by basing eligibility ate the shortage of housing include the on such measures as unemployment and the use of Federal and State eminent domain percentage of substandard housing. Programs authority to obtain land, encouragement under the Department of Housing and Urban of community nonprofit housing corpora- Development and the Economic Development tions with subsidies, modifications of the Ch. VIII—Policy Options ● 395

tax laws to encourage coal development ● Assist community self-help projects (e.g., companies to provide employee housing, civic beautification). and Federal subsidies or guarantees de- ● Fund study by Federal Regional Commis- signed to make mortgage loans with low sions concerning possible regional ap- downpayments available to young cou- proaches to preserving existing farms and ples. ranches. ● Impose a Federal severance tax on coal ● Fund joint study by Federal and State gov- with revenues going to States or localities ernments and Indian tribal governments to provide needed community infrastruc- regarding ways of Iimiting the corrosive ture and services. Use funds generated by impact of energy development on Indian leases of Federal coal lands for the same culture and social systems. purpose. Any comprehensive program to deal with the community consequences of coal develop- ECONOMIC DISLOCATION ment will have at least two objectives: the mitigation of specific adverse impacts and the di- ● Create a stable and predictable demand versification of the local economy. Clearly, for coal by means of a national energy such an effort will strain the resources of local policy clearly committed to substantially jurisdictions and may require supplemental increased coal use through the end of the Federal funding– ing the form of loans, grants, century. or both. ● Encourage non-coal-related private investment in the coal field communities by If it is assumed that revenues generated by use of tax incentives, preference in awards coal development ultimately will prove ade- of Federal contracts, etc. quate to cover the costs of impacts ameliora- ● Give preference to coal-producing areas tion, the money can be raised by local taxes on in siting of Federal installations. the activities of the coal companies supple- ● Levy a national severance tax or royalty mented, if necessary, by Federal loans to cover on coal production and use the revenues front-end costs of public works and other in to establish development banks or trusts frastructure. The coal companies will presum- for investment in coalfield communities. ably pass along the cost of taxes to consumers ● Provide compensatory payments to com- in the form of higher coal (i. e., higher energy) munities that bear the social costs of min- prices. This, in effect, puts coal development ing federally owned coal or of coal devel- on a pay-as-you-go basis with the ultimate ben- opment in adjacent Federal lands. eficiaries of coal production, the energy con- ● Upgrade the capabilities of the Appalach- sumer, paying most of the bill. The feasibility ia Regional Commission and its western of the pay-as-you-go option wiII depend on: counterparts to support a broad range of development programs. 1. how heavily coal development activities ● Help coalfield communities identify and can be taxed without pushing the price of develop alternative sources of economic coal to uncompetitive levels, growth (e. g., reconstruction of a historic 2. whether coal communities are willing and narrow gauge railway as a tourist attrac- able to impose those levies that will cap- tion). ture the potential revenue, and 3. the availability of Federal loans.

SOCIAL INSTABILITY AND QUALITY OF LIFE If it is assumed instead that coal develoD- ● Provide loans, grants, bond guarantees, ment revenues will not cover the external costs etc., to assist coal communities in estab- involved, the choice is between turning to the lishing recreational and social service pro- Federal or State governments for some sort of grams (e. g., family counseling, day care net transfer of funds or continuing the past centers, adult education, parks). practice of allowing the costs to fall on the 396 ● The Direct Use of Coal local communities in the form of environmen- workplace and work process, the social and tal and social deterioration. The limiting fac- political environment of the coalfields, and tors will be the availability of Federal or State the accumulated ill-will and mistrust built up funding and the absorptive capacity, in terms over decades of conflict between the oper- of environmental and social pressures, of indi- ators and miners. vidual coal communities. Policy makers face two basic tasks: first, how Policy makers will also have to consider how to ameliorate the sources of destructive labor- the needed funds will be acquired and distrib- management relations and lay the groundwork uted. In practical terms, the communities have for a more constructive long-term relationship; two methods of raising revenue from coal de- and second, how to deal with another lengthy velopment, a property tax on company-owned strike should it occur. coal lands and facilities within the local juris- Under the present legislation, the Federal diction, and a severance tax on the value or Government can do little to directly alter the quantity of coal actually mined. The difficulty terms or context of labor-management rela- with any local tax is that it may place the com- tions. The principal exceptions are measures munity at a competitive disadvantage com- designed to ensure a growing or stable market pared to other localities in attracting coal infor coal by mandating or inducing the use of vestment. coal instead of gas or oil. The recently passed The Federal Government has a much wider National Energy Act contains a number of choice of sources for funds, including general such provisions, including a prohibition Federal revenues based primarily on the in- against the use of oil and gas in new utility or come tax and a variety of levies specifically on industrial boilers, DOE authority to require coal production and use— including fees, capable facilities to use coal, and restrictions rents, and royalties for leases on Federal land, on the use of gas in existing utility power- and a national coal severance tax. Federal net plants. A stable market should ease the transfers can be made available to coal com- historic insecurity of both operators and munities in the form of direct payments (e. g., miners that has been such a large factor in the revenue sharing, grants, trust funds) according industry’s labor problems. Other measures are to some established formula (e. g., amount of more indirect and relate to the basic social, en- Btu equivalents mined) or through a develop- vironmental, and other ills of the coalfields ment bank that would provide assistance on a that contribute to the miners’ discontent. project-by- project basis. These options are outlined in earlier portions of this chapter. LABOR-MANAGEMENT RELATIONS In the event of another major coal strike the Federal Government will have an interest in The history of labor-management relations achieving a settlement that is prompt, nonin- in the coal industry has been a tumultuous flationary, and that establishes the basis for one. Any analysis of the contribution of coal to long-term labor-management stability. If the U.S. energy requirements must take into ac- latter condition is to be met, the settlement count the possibility of supply disruptions due must be supported by a substantial majority of to work stoppages. This was dramatically dem- rank-and-file miners and must address some of onstrated in 1977-78 when the United Mine the underlying problems noted previously. Workers of America (UMWA) and the Bitumi- nous Coal Operators of America (BCOA) In pursuit of these objectives, five major locked horns in a prolonged 109-day strike that strategies or approaches will be available, as effectively shut down about half of U.S. coal they were during the 1978 strike: output. The reasons for this troubled history 1. reliance on collective bargaining with lim- are multiple and complex. They include char- ited Government intervention, acteristics of the coal market, the ownership 2. collective bargaining with strong Govern- structure of the industry, the nature of the ment involvement, Ch. Vlll—Policy Options ● 397

3. use of Taft-Hartley with limited efforts at an image of Government ineffectiveness in enforcement, dealing with the problems of an industry that 4. Taft-Hartley with vigorous enforcement, has been identified as the key to America’s and energy future. 5. Government seizure of the mines. Each has its own set of opportunities and lia- Collective Bargaining With Strong bilities. Of the five, only the last will require Government Intervention legislation. It should be emphasized that these options are purely instrumental; they are inde- This approach would involve preserving the pendent of any judgment on the substantive framework of collective bargaining while merit of the labor/management issues in dis- bringing substantial Government pressure to pute. bear on one or both parties to modify their negotiating positions. The instrumentalities of pressure will differ depending on whether the Collective Bargaining With Limited operators or the union is the target. Means of Government Intervention influencing the operators could include:

Under this approach resolution of the strike 1, manipulation of Government contracts, would be essentially left to bargaining be- 2. threat of Government seizure of the tween negotiators for UMWA and BCOA. The mines, Federal Government would limit itself to en- 3. vigorous implementation of antitrust laws couraging the negotiators by “jawboning,” regarding horizontal and vertical divesti- meditation, and public appeals to the industry ture, rank-and-file miners. 4. proposed changes in the tax laws (e.g., the coal depletion alIowance, the write off for The major argument in favor of this policy is black lung benefits, rapidity of amortiza- that it enables the Government to avoid a tion, investment credits), direct confrontation with either the operators 5. modifications in leasing reguIations, or the miners. If strike-related damage to the 6. a tightening or loosening of regulations economy can be kept to manageable levels concerning coal imports and exports, (due perhaps to mild weather and increasing 7. changes in the frequency of Federal production from nonunion mines), this strategy health and safety inspections of mines, promises to leave BCOA and UMWA increas- and ingly isolated as their mutual leverage over the 8. a general increasing or lessening of the rest of society declines. Under these condi- Government regulatory and permitting tions the strike may be seen by both labor and burden on the industry. management as increasingly self-defeating, thereby hastening a negotiated settlement. Pressure on the union could take the form of: The principal arguments against this ap- 1. withholding food stamps from strikers, proach are that it offers no assurance of a 2. threats to investigate union finances, quick end to the strike or that a settlement, 3. modifications in National Labor Relations when achieved, will be anything more than a Board regulations to make it either easier temporary truce borne of mutual exhaustion or harder to organize new mines, that leaves the underlying causes of labor 4. threats of preferential Government pur- unrest in the coalfields intact. Moreover, if a chasing from nonunion mines, prompt settlement is not achieved, the credi- 5. greater or lesser Government willingness bility of the Government’s energy policy may to make coal miners exceptions to nation- be seriously undermined with consequent al wage guidelines, and long-term damage to the economy and the ef- 6 an offer to explore means of using public fort to reduce reliance on imported fuels. money to strengthen union health care Finally, a hands-off policy may contribute to programs.

44.102 () - ‘i 1 - 27 398 The Direct Use of Coal

In addition, statements by Government Taft-Hartley With Vigorous spokesmen can be used in an effort to pressure Enforcement or persuade both miners and operators.

With this strategy, every effort would be Taft-Hartley With Limited Enforcement made to use Taft-Hartley to persuade and, if necessary, force miners to return to work. This strategy is similar to that apparently Tools available to the Government include all adopted by the administration following the those listed under the second option plus fines second rejection of a tentative contract by the levied on recalcitrant union locals and arrests rank and file in early 1978. It involves the use of pickets. If necessary, separate agreements of Taft-Hartley to obtain police protection for between UMWA locals and individual coal those miners who want to return to work. The companies would be encouraged. Other as- principal focus would be nonunion mines shut pects of the strategy might include the offer of down due to threats of violence by strikers at a provisional wage increase to miners return- nearby union mines. No effort would be made ing under Taft-Hartley and creation of a White to coerce unwilling miners back into the House Commission to recommend terms of a mines. As an inducement, miners who went new contract. The basic effect of this policy is back to work under a Taft-Hartley injunction to increase pressure on the union by making a could be paid at a new higher wage scale strike illegal for 80 days. Any efforts toward (within Government wage-price guidelines) encouraging local settlements and thereby pending a final settlement. The basic advan- fragmenting the industry are a threat to both tage of this approach is that it permits the Gov- the union and the operators. The result may in- ernment to facilitate a return to production of duce renewed and productive BCOA-UMWA nonunion mines without a major confrontation negotiations under threat of such fragmenta- with striking miners. To the extent that production. tion is increased, the pressure on UMWA and BCOA will mount. Warmer weather, the grow- The principal argument in favor of this oping economic strain on miners and coalfield tion is that it is designed to achieve an im- communities, and an increase in coal prices mediate restoration of coal production. At caused by supply shortages can all contribute present both UMWA and BCOA are seriously to that pressure. divided internally and consequently vulner- There are several arguments against this able to the threat of fragmentation. Given that strategy. First, it does not assure a quick end to vulnerability, a possible outcome of this the strike and thus leaves open the possibility strategy would be to induce the miners and of all the negative economic effects identified operators to resume serious negotiation in in the limited intervention option. Second, by order to forestall the mutual danger posed by tacitly accepting defiance of Taft-Hartley by Government intervention. Also, an activist UMWA miners this policy tolerates disregard posture by the administration should have for the law and may contribute to a general im- some political benefit in terms of providing an pression of Government ineffectiveness in image of decisive national leadership. There energy matters. Third, this approach will prob- may even be an important benefit if it be- ably be widely perceived as favoring the oper- comes necessary to resort to individual agree ators at the expense of the miners. Fourth, the ments between specific union locals and coal underlying assumption is that there is signifi- companies because fragmentation may create cant nonunion coal production that is not the possibility of breaking the historic pattern forthcoming because of a union strike. This of labor relations in the industry. It could may be a false premise. Finally, as with the first create the opportunity for new leadership, new policy option, there is little reason to think ideas, and a new structure for union-industry that a settlement reached under this strategy bargaining. This in turn may make it possible will successfully address the root causes of to address some of the root causes of labor labor unrest. unrest in the Eastern coal fields. Ch. Vlll—Policy Options ● 399

Arguments against the invocation and vigor- pacts, with localized exceptions, were quite ous enforcement of Taft-Hartley center on the manageable. Because of a projected increase danger that the whole effort could be counter- in nonunion western production, a future productive. Previous attempts by the Govern- strike would have even less damaging conse- ment to use Taft-Hartley to force coal miners quences for the national economy. back to work have been uniformly unsuccess- History suggests that if seizure is to be effec- ful. Even a successful attempt could be polit- tive, the authorizing legislation must provide ically damaging by antagonizing other unions the President with the power to control the and blue-colIar workers generalIy. On close ex- conditions under which seizure is carried out. amination, some of the tools available to This means authority to change the terms and Government are of dubious utility. Because conditions of employment, to decide when the many union locals may already be bankrupt, property should be returned to private owner- fines could be ineffective, A cutoff of welfare ship, and to seek injunctions in Federal court if benefits and food stamps may be successfully there is resistance to this control. The Presi- challenged in the courts with the result that dent also has at his command a number of new legislation will be required. Reliance on sanctions — moral, economic, military, judi- Taft-Hartley will clearly antagonize UMWA, cial, and legislative —the use of which Con- and to the extent fragmentation is threatened, gress must be prepared to support if they are BCOA as well. Fragmentation might well result to be effective. in anarchy rather than a new industry structure, with competitive inflationary wage in- On taking control of the mines, the Govern- creases and labor instability the result. Local- ment might try to resolve the impasse that led ized settlements or an industrywide settlement to the strike by mediating between the parties. reached under the threat of fragmentation are More severe Government actions would in- unlikely to systematicalIy address the underly- clude removal of the existing management per- ing causes of labor instability. Also, a strong sonnel, alteration of the conditions and terms and cohesive union wilI be required if the per- of employment, and wage increases (or de- vasive community and environmental prob- creases). Strikes would be forbidden. A deci- lems of Appalachia are ever to be solved. It sion concerning the conditions of takeover will not be easy to reconstitute an industry- might follow an inquiry by a White House wide union; dismemberment of UMWA might Commission and consultations with miners prove to be effectively permanent. Moreover, and operators. The Government could choose a basic tenet of national labor policy is to to negotiate a new contract with the union and facilitate, not undermine, collective bargain- make its acceptance by management a condi- ing. tion for returning the mines to their former ownership. By directly negotiating a new labor contract the Government might be in a posi- Government Seizure of the Mines tion to break the historic cycle of mistrust and hostility in coal labor relations. For example, a If invocation of the Taft-Hartley Act fails to Government-negotiated contract might go far bring settlement of a strike, the remaining op- to meet the miners’ demands concerning such tion of last resort is seizure of the mines by the key noneconomic issues as medical care and Federal Government. Such action would re- safety. At the same time a systematic effort to quire the passage of enabling legislation by improve the quality of life in the coalfield Congress. The case for legislation would pre- communities could alter the environment that sumably be made in terms of the strike’s short- nourished the miners’ discontent. To the extent term impact on the economy and the long- these objectives are achieved, the climate for a term injury done to the Government’s effort to successful implementation of a national ener- meet the Nation’s energy requirements gy policy will be markedly improved. through increased use of coal. It should be noted, however, that retrospective analysis of Arguments for this approach center on the the 1978 strike indicates that the economic im- contention that it is a way of acheiving both a 400 ● The Direct Use of Coal quick and durable settlement. It is seen as an Moreover, in 38 of the seizure cases either extreme remedy necessitated by the severity labor or management obstructed production in and intractability of the problem, This strategy some way while the Government was running is also attractive on the grounds that it will the business. President Truman’s seizure of the probably be welcomed by UMWA and orga- steel mills in 1952 was welcomed by the unions nized labor generally and should convey an but eventually resulted in a 53 day strike. The image of governmental decisiveness and vigor fact that the seizure of the coal mines would to the public as a whole. require congressional legislation raises the possibility of congressional delay or veto. Arguments against this option begin with the Significant congressional reservations. seem observation that the historical record of the likely given the predictable opposition of the use of seizure in labor disputes has not been coal companies and a generalized uneasiness altogether happy. Of the 71 instances in which with seizure as socialistic. To the extent that it has been used since the Civil War, only 40 seizure undermines business confidence in the resulted in agreements between labor and administration, the political costs could be management before the property was returned high. Finally, the seizure or an attempted to its owners. In the 31 remaining instances seizure of the mines wilI preoccupy congres- negotiations took place after the seizure was sional and executive energies and attention at terminated and in 20 cases strikes occurred. the expense of other high priority concerns.

WORKPLACE HEALTH AND SAFETY

Underground mining is a hazardous occupa- be capable of providing an immediate, on tion as measured by the incidence of work-re- the spot reading of dust levels. lated accidents and disease. Health and safety ● Reorganization of the respirable dust- issues have been a major factor behind labor sampling program around the new sam- unrest in the coal industry— including the 109- pler technology and around the concept day UMWA strike of 1977-78. Any substantial of miner control or joint control of the increase in coal production will inevitably be program. Shared management should purchased at the price of thousands of ill and minimize the opportunities for falsifica- injured miners. tion of results that exist in the present program. Health ● Monitoring of the incidence of trace elements in coal dust. A number of measures designed to upgrade ● Support for research to resolve some of the existing dust control system can be iden- the present uncertainty concerning the tified. They include: adequacy of the 2-mg standard.

● Assignment of higher priority to efforts to The Mine Safety and Health Administration control nonrespirable dust. (MSHA) is now considering alternative sam- ● Development of new methods of mitigat- pling systems to improve measuring and re- ing the health impacts of dust from long- porting reliability. Two promising approaches wall mining, including improved respira- are in-mine dust measurement (allowing imme- tor designs, fans, and special ventilation diate correction of excessive dust) and contin- systems. uous, machine-mounted monitoring that ● Development of area sampler technol- would automatically cut power to operating ogies (with appropriate standards) that machinery when dust levels are too high. Both would supplement personal samplers. Un- of these approaches would require new capital like the latter, these area devices should investment and could impede production dur- Ch. Vlll—Policy Options . 401 ing the year or two they were installed. These of emotional strain in a recent survey. Stress costs would probably be offset over time by a and strain are probably associated with absen- lower prevalence of coal workers’ pneumoco- teeism, workplace hostility, and lower produc- niosis (CWP) among workers and lower oper- tivity. Shift rotation may be an important ator-financed compensation expenses. The source of job stress and disruption of family present public costs of black lung compensa- life. It may also be related to adverse health tion are substantial. and safety effects. A Federal policy response Other hazards – “nonrespirable ” dust, trace to this situation could include banning or elements, emissions from machinery fires and modifying certain work practices that research diesel engines, and the like– contribute to res- identifies as key sources of job-stress, and es- piratory illness to one degree or another. These tablishing a program for monitoring workers pollutants may work synergistically with coal for signs of stress. dust, thereby increasing the hazard to the worker. Since the individual miner experiences Safety these hazards cumulatively, research and prevention programs should be structured in holis- As coal production increases, more workers tic, multifactor fashion rather than in terms of are likely to be hired. If accident rates do not single-factor hazards. Federal regulation may improve, the number of fatalities and disabling be necessary to cover the respiratory hazards injuries will double and triple as production the 1969 Act did not address specifically (e. g., and employment doubles and triples. It is trace elements). Improved monitoring and con- unlikely that any major labor-saving technol- trol technologies for these pollutants may be ogy will be commercialized over the next 15 to needed. 20 years that would sharply raise productivity Noise and stress are other significant mine- and reduce the number of workers exposed to health concerns. The National Institute of Oc- . safety hazards. Therefore, it is necessary to cupational Safety and Health (NIOSH) has assess accident prevention strategies in the recommended a tightening of the current noise context of existing mining systems. standards, but neither MSHA nor the Occupa- The 1969 Coal Act sought to prevent coal tional Safety and Health Administration mine disasters. [t has succeeded. The number IOSHA) has proposed implementing regula- and severity of disasters have been cut sub- tions. Miners experience significantly more stantially in the last 8 years. Other legislated hearing loss than nonminers, and some studies safety measures — involving roof support, elec- have linked noise to accidents. A more strin- trical hazards, blasting— have probably re- gent noise standard would undoubtedly reduced fatalities and injuries, but the effects quire additional investment by mine operators. are often difficult to separate and measure. After this initial expense, however, production The principal need in the area of safety is to costs should not be increased and productivity develop a program to reduce the frequency of may be enhanced by lowering workplace noise levels. Medical costs and compensation are disabling injuries (there were 15,000 such in- likely to be reduced if a tougher standard is juries last year, each of which cost more than 2 adopted. months of lost time). Job stress to which noise contributes, has Several measures designed to mitigate the been implicated as an important causal agent problem can be identified: in coronary heart disease, gastrointestinal ● Comprehensive, mandatory safety stand- malfunctions, severe nervous conditions, and ards and design features for machinery. other disorders. ● More safety conscious work procedures in Recent studies have found more anxiety, de- the mine such as preventing the accumu- pression, irritation, and somatic complaints lation of debris along haulage ways. A re- among miners than other blue-colIar workers. lated measure would be to package sup- Underground coal miners reported a high level plies (e. g., cement) in small enough units 402 The Direct Use of Coal

to be handled easily in confined quarters ● A greater voice for miners in safety deci- thereby avoiding back and other muscle sions. injuries. Safety does not come easily or cheaply, ● Specially designed prevention programs Management and workers must practice it con- for high-accident mines devised jointly by tinually. Prevention-consciousness must be in- labor, management, and Federal officials. corporated into the work attitudes of both ● Improved safety education and job train- management and labor. The costs of inade- ing of workers and supervisors. This quate attention to safety are measured in should have measurable safety benefits lower productivity, compensation payments, since so much of the work force is young lost production time, lower morale, absen- and inexperienced. teeism, and medical bills. Upgrading safety ● Greater frequency of visits by Federal often involves capital investment, and may safety inspectors. Studies have shown an lower productivity and output. On the other inverse correlation between the incidence hand, a conscientious approach to safety can of inspections and accidents. help production and productivity, and often ● Research into the relationship among the brings dollar benefits in terms of lower in- pace of work, production quotas, and ac- surance premiums and medical bills, cidents.

LEASING

The most basic policy question concerns any case, available sources of Western coal whether additional leasing of Federal coal will be adequate for the next several years, lands will be required to meet projected in- regardless of the disposition of PRLAs. More- creases in coal demand. Western coal com- over, recent court cases mean that no new prises roughly half of the Nation’s coal leasing will be possible until the early 1980’s at reserves and the Federal Government owns 60 the earliest. percent and indirectly controls another 20 per- By that time it is possible that a tight coal cent of Western coal. The extent to which market could create the conditions for a coal Western coal will be used to meet national land rush in the West. The clearest way for the energy demand is presently unclear due to the Federal Government to defuse such an event is 1977 amendments to the Clean Air Act, which to prepare contingency plans for the orderly may have reduced the attractiveness of West- resumption of coal leasing at that time, This ern coal to utilities. Even if it turns out that will require the Government to select among substantial quantities of Western coal are re- various options for an overall long-term ap- quired, it is not clear how much (if any) new proach. Recently a high-level review commit- Federal coal reserves would have to be leased. tee within the Department of the Interior ad- There are already 18 billion tons of Federal dressed this problem and produced an option coal under lease and another 9 billion tons on paper. land for which preference right lease applications (PRLAs) are pending. However, the status The stated goal of the paper is to suggest of PRLAs is very much uncertain as a conse- alternative approaches for managing coal re- quence of the “commercialization quantities” sources that emphasize environmental and test to be applied to all applications. Coal land use planning and enable the Department from PRLAs could meet national demand for a of the Interior to adjust the amount of coal decade or, alternatively, many PRLAs could be leased to production goals set by DOE. found illegal or unable to pass the commercial quantities test. Given the uncertainties it is im- For each suggested option, land use plan- possible to predict when any new Federal lands ning and environmental standards are em- will have to be made available for leasing. In ployed to assess which “coal resource areas” Ch. Vlll—Policy Options ● 403

are suitable for mining. Within those areas spe- values. ” Using DOE production targets as a cific tracts would be identified for leasing. Pro- goal, leasing targets would be set for those duction goals set by DOE would determine areas found to have the highest priority. In- how many mines would be opened. The op- dustry would then be asked to nominate tracts tions differ as to whether industry or Govern- within the selected areas that it wished to ment identifies the areas and tracts for leasing lease. The frequency and size of leases would and designates the areas to be subject to envi- be timed to meet the leasing targets for each ronmental and land use assessment. area.

Option 1: Option Ill: Industry Nominates Areas and Tracts Government Selects Areas and Tracts for Leasing for Leasing Under the first option proposed by the Re- Under the third option suggested by the Re- view Committee, industry would nominate view Committee, the Government would fol- those areas it desired to mine. The Department low the procedure specified under Option II of the Interior would then perform various for selecting areas for mining and setting leas- land use and environmental studies to deter- ing targets for each area. I n addition, however, mine which of the nominated resource areas the Government would select those specific was suitable for mining. Interior would esti- tracts to be offered for lease without request- mate the production potential of the suitable ing nominations from industry. As with Option areas relation to the production goals set by II the frequency and size of leases would be DOE. A decision on which areas actually to keyed to the area leasing targets. lease would be made taking into account “by trading off the projected resource needs and environmental consequences of develop- Comparison of the Options merit. ” If the areas nominated by industry and found suitable for development failed to pro- Table 63 summarizes the Department of the vide sufficient coal to meet production needs, Interior’s comparison of these three options. then the Department of the Interior would As can be seen, in the Department’s opinion, designate additional areas on its own initia- the more involved the Government becomes in tive. Finally, industry would nominate specific the planning process the higher the cost to the tracts that it desired to lease within each Government and the greater the chance of pro- selected leasing area. The frequency and size duction shortages produced by reason of of leases wouId be adjusted to meet DOE pro- Government errors in selecting areas that are duction goals. not economically suitable for mining. On the other hand, the greater the Government role Option II: the more assurance there will be that adverse Government Identifies Areas for social, economic, and environmental impacts can be minimized. Leasing and Industry Nominates Specific Tracts Whichever approach is ultimately selected, a number of specific issues will have to be Under the proposed second option the selec- clarified. They include logical mining units, tion of potential coal leasing areas would first preference right lease applications, the re- be made by the Department of the Interior. quirements of diligent development and con- Coal areas appearing to have “significant na- tinued operation, estimated recoverable re- tional potential” would be identified and sub- serves, advance royalty payments, and the ex- jected to environmental and land use analysis. change of environmentally sensitive leased Those areas found suitable for leasing would lands for other unleased Federal land. These be “selected and prioritized by comparing topics are examined in chapter V1. There are resource, socioeconomic, and environmental also some important institutional issues con- 404 The Direct Use of Coal

cerning the division of responsibility between of the leasing process, considerable effort will the Department of the Interior and DOE re- be required to prevent it from becoming hope- garding leasing. Given the inherent complexity Iessly lengthy and cumbersome.

Table 63.—Comparison of Policy Options Under Consideration by the Department of the Interior — Option I Option II Option Ill 1. Determination of production goals...... Government Government Government 2. Identifies areas for leasing...... Industry Government Government 3. Identifies tracts for leasing ...... Industry Industry Government 4. Defines areas for environmental planning . . . . Industry Government Government 5. Cost of planning and administration...... — Increasing * 6. Chances for environmental mistakes...... — Decreasing - 7. Chances for production shortages ...... — Increasing - 8. Likelihood of litigation ...... — Decreasing * 9. Consideration of socioeconomic concerns. . . — Increasing

SOURCE: US Department of the Interior

CONCLUSION

With the possible exception of carbon diox- tion will be required to deal with environ- ide pollution, all the significant problems mental, community, health, safety, and other associated with substantially increased coal impacts and to a lesser extent, coal supply and use appear to be solvable. That is, policy reme- demand. Most of that framework already ex- dies exist to make coal a viable fuel option for ists but some does not. Under the best of cir- the United States through 2000. But the fact cumstances there will be difficult problems of that effective policies can be identified does coordination, administration, enforcement, not mean they will be adopted and imple- technological improvement, and cost. In short, mented. If coal use is to be facilitated and the the ingredients for an effective national coal potential adverse impacts of such use con- policy exist, but that achievement will not trolled, a complex network of law and regula- come easiIy or inexpensively. Glossary ACRONYMS

MSHA - Mine Safety and Health Administration NAAQS - National Ambient Air Quality Standards NBS - National Bureau of Standards NEF #1 - National Environmental Forecast No. NEPA - National Environmental P'olicy Act NHPA - National Historic Preservation Act NIH - National I nstitutes of Health NIOSH - National I nstitute for Occupational Safety and Health NIRA - National I ndustrial Recovery Act NO - nitric oxide NO? - nitrogen dioxide NOx - nitrogen oxide NPDES - National Pollutant Discharge Elimination System NRDC - Natural Resources Defense Council NSPS - New Source Performance Standards OSHA -Occupational Safety and Health Administration OSM -Office of Surface Mining PAN - peroxyacyl nitrate PBN - peroxybenzoyl nitrate PIFUA - Powerplant and I ndustrial Fuel Use Act POM - polycycl ic organic matter PRLA - preference right lease application PSD - prevention of significant deterioration RCRA - Resource Conservation and Recovery Act SCS - Soil Conservation Service SIP - State implementation plan SMCRA - Surface Mining Control and Reclamation Act

50 2 - sulfur dioxide SOl - sulfur trioxide SO). -sulfur oxide SRC - solvent-refined coal TDS - total dissolved sol id TSP - total suspended particu lates TVA - Tennessee Vaiiey Authority UARG - Util ity Air Regulation Group UMWA - United Mine Workers of America WHO - World Health Organization WRC -Water Resources Council

407 408 ● The Direct Use of Coal DEFINITIONS

Acre-foot: A measure of water 1 foot deep portation and household services. by an acre in area, or 43,560 ftj. Criteria Pollutants: Six pollutants identified Ambient Air Quality Standards: According to prior to passage of the Clean Air Act the Clean Air Act of 1970, the air quality Amendments which now have established level which must be met to protect the Ambient Air Quality Standards, i.e., sulfur public health (primary) and welfare dioxide, particulate matter, carbon mon- (secondary). Secondary standards are oxide, photochemical oxidants, non- more stringent than Primary Ambient Air methane hydrocarbons, and nitrogen ox- Quality Standards. ides. Anthracite Coal: A hard, high rank coal with Effluent: Any water flowing out of an high fixed carbon. enclosure or source to a surface water or Aquifer: A subsurface zone that yields eco- groundwater flow network. nomicalIy important amounts of water to Elasticity: The fractional change in a wells; a water-bearing stratum or per- variable that is caused by a unit change in meable rock, sand, or gravel. a second variable. Income elasticities are Ash [fly ash): Light-weight solid particles important in energy estimates, since these that are carried into the atmosphere by estimate the changes in quantities of stack gases. energy demanded as incomes change. Base Load: The minimum load of a util ty, Electrostatic Recipitator (ESPJ A device for electric or gas, over a given period of cleaning stack gas of particulate. The time. device first charges particles in the gas Best Available Control Technology (BAC T]: stream and then collects them on an op- A technology or technique that represents positely charged surface. the most effective pollution control that Enhanced Oil Recovery (EOR): A variety of has been demonstrated, used to establish techniques (other than conventional emission or effluent control requirements pumping) for extracting additional quan- for a polluting industry. tities of oil from a well. Bituminous Coal: The coal ranked below an- Fertility Rate: Average number of lifetime thracite. It generally has a high heat con- births per woman. tent and is soft enough to be readily Flue-Gas Desulfurization: The use of a stack ground for easy combustion. It accounts scrubber to reduce emissions of Sulfur ox- for the bulk of all coal mined in this coun- ides. See stack scrubber. try. Black Lung Disease: A group of pulmonary Fuidized Bed: A fluidized bed results when diseases that are common among coal gas is blown upward through finely miners. crushed particles. The gas separates the BTU: British thermal unit, a measure of the particles so that the mixture behaves like energy required to raise one pound of a turbulent liquid. Being developed for water one degree Fahrenheit. coal burning for greater efficiency and en- Coal Gasification: The process that produces vironmental control. synthetic gas from coal. Greenhouse Effect: The potential rise in Coal Liquefaction: Conversion of coal to a global atmospheric temperatures due to

liquid for use as synthetic petroleum. an increasing concentration of C02 in the Commercial Sector: A subsector of service atmosphere. CO, absorbs some of the industries that includes wholesale and heat radiation given off by the Earth, retail trade, schools and other govern- some of which is then reradiated back to ment nonmanufacturing facilities, hospi- the Earth. tals and nursing homes, and hotels. As de- Cross Energy Demand: The total amount of fined, this sector does not include trans- energy consumed by direct burning and Glossary ● 409

indirect burning by utilities to generate presented to Congress by President Carter electricity. Net energy demand includes in April 1977. direct burning of fuels and the energy con- New Source Performance Standards: Stand- tent of consumed electricity. The dif- ards set for new facilities to ensure that ference between gross and net energy de- ambient standards are met and to limit mand is a measure of the energy losses by the amount of a given pollutant a sta- utility conversion to electricity. The dif- tionary source may emit over a given ference between gross and net energy de- time. mand is a measure of the energy losses by Oil Shale: A finely grained sedimentary rock utility convers to electricity. About two- that contains an organic material, ker- thirds of the energy input at the utility is ogen, which can be extracted and con- lost in generation and transmission. verted to the equivalent of petroleum. Gross National Product (GNP): The value of Participation Rate: The percentage of per- all goods and services produced in a given sons 16 years of age or older who are year. GNP is a “value added” concept. It either employed or actively looking for is stated in either current or constant (real) work. I n 1976, the participation rate was dollars. 62.1 percent. Groundwater: Subsurface water occupying Particulate Matter: Solid airborne particles, the saturation zone from which wells and such as ash. springs are fed; in a strict sense, this term applies only to water below the water Peak Power: The maximum amount of elec- table. trical energy consumed in any con- Heat Purmp: A device that moves heat from secutive number of minutes, say 15 or 30 minutes, during a month. one environment to another. I n the winter it moves heat from the outside of a build- Petrochernical Feedstocks: Petroleum used ing to the inside, and in the summer it as an industrial raw material to manufac- moves heat from the inside to the outside. ture goods, such as chemicals, rather than Hydroelectric: Electricity generated by as a source of energy. water power. Prevention of Significant Deterioration Industry: Industry is an aggregate of three (PSD): Pollution standards that have been sectors — manufacturing, mining, and con- set to protect air quality in regions that struct ion. are already cleaner than the Ambient Air In Situ Processing: In-place processing of Quality Standards. Areas are divided into fuel by combustion without mining ap- three categories determining the degree to plies to oil shale and coal. which deterioration in the area will be joule: A unit of energy which is equivalent to allowed. 1 watt for 1 second. 1 Btu = 1,055 Joules. Prime Farmlands: Land defined by the Labor force: The number of persons 16 years Agriculture Department’s Soil Conserva- of age or older who are either employed tion Service based on soil quality, growing or actively looking for work. season, and moisture supply needed to Lignite: The lowest rank coal from a heat produce sustained high crop yields using content and fixed carbon standpoint. modern farm methods. Metallurgical Coal: Coal used in the Primitive Areas: Scenic and wild areas in the steel making process. Its special properties national forests that were set aside and and difficulty of extraction make it more preserved from timber cutting, mineral expensive than steam coal. operations, etc., from 1930-39 by act of Methane: CH,, carburated hydrogen or Congress; these areas can be added to the marsh gas formed by the decomposition National Wilderness Preservation System of organic matter. It is the most common established in 1964. gas found in coal mines. Process Steam and Heat: Steam and heat NEP: National Energy Plan, the plan produced for industrial process uses, such 410 ● The Direct Use of Coal

as the activation of drive mechanisms and mixture of liquid and solid. The primary product processing. application proposed is to move coal long Productivity; The value of goods or services distances (over 300 miles) in a water mix- produced by a worker in a given period of ture. time, such as 1 hour. For the United States Stack Scrubber: An air pollution control e in 1975, this averaged $7.39. Increas s in device that usually uses a liquid spray to output over time are used to measure remove pollutants, such as sulfur dioxide gains in productivity. A variety of time- or particulate, from a gas stream by ab- periods are used, including output per sorption or chemical reaction. Scrubbers worker per year. Also, productivity state- are also used to reduce the temperature ments often refer to gains in private sector of the emissions. output per worker rather than output in Steam Coal: Coal suitable for combustion in the total economy. boilers. It is generally soft enough for easy Quad: One quadrillion (10’5) British thermal grinding and less expensive than units (Btu). metallurgical coal or anthracite. Reclamation: Restoring mined land to pro- Strip Mining: A surface mining method that ductive use; includes replacement of top- removes the overburden that covers the soil, restoration of surface topography, coal seam in a series of parallel strips. waste disposal, and fertilization and Subbituminous Coal: A low rank coal with revegetation. low fixed carbon and high percentages of Reserves: Resources of known location, volatile matter and moisture. quantity, and quality which are Subsidence: The sinking, descending, or economically recoverable using currently lowering of the land surface; the surface available technologies. depression over an underground mine that Residential/ Sector: Includes all primary liv- has been created by subsurface caving. i ng units–houses, apartments, and Sulfates: A class of secondary pollutants mobile homes. Households are classified that includes acid-sulfates and neutral as follows: a) family households, which in- metalIic sulfates. corporate persons who are either married Sulfur: An element that appears in many or blood related; b) primary individual fossil fuels. In combustion of the fuel the households, which are made up either of sulfur combines with oxygen to form single persons or incorporate two or more sulfur dioxide. persons who are neither married or blood- Sulfur Dioxide: one of several forms of related. sulfur in the air; an air pollutant generated Resources: Mineral or ore estimates that in- principally from combustion of fuels that clude reserves, identified deposits that contain sulfur. cannot presently be extracted due to eco- Supply: The functional connection between nomical or technological reasons, and the price of a good and the quantity of other deposits that have not been dis- that good that some agent is willing to sell covered but whose existence is inferred. at that price. The supply function is Retrofit: A modification of an existing struc- generally positive, or (geometrically ture, such as a house or its equipment to speaking) up-sloping, meaning that as reduce energy requirements for heating or price goes up, the quantity supplied also cooling. There are basic types of retrofit: goes up. equipment, such as a heat pump replacing Swing Fuel: A fuel that plays a key role dur- less efficient equipment; and insulation, ing the transition from exhaustible to inex- storm doors, calking, etc., designed to haustible fuels. Coal is viewed by many as lower energy requirements. the swing fuel during the transition. Seam: A bed of coal or other valuable Synthetic Fuel: A fuel produced by mineral of any thickness. biologically, chemically, or thermally Slurry Pipeline: A pipeline that conveys a transforming other fuels or materials. Glossary . 411

Traportation Sector; Includes five sub- Western Coal: Can refer to all coal reserves sectors: 1 ) automobiles; 2) service trucks; west of the Mississippi. By Bureau of 3) truck/bus/rail freight; 4) air transport; Mines definition, includes only those coal- and 5) ship/barge/pipel inc. fields west of straight line disecting Min- Unit Train: “A system “for delivering coal in nesota and running to the Western tip of which a string of cars, with distinctive Texas. Wyoming and Montana (sub- markings and loaded to full visible capaci- bituminous) and North Dakota (1 gnite) ty, is operated without service frills or have the largest reserves. stops along the way for cars to be cut in and out.