y 4

P HEATING PLAN T RENOVATION AND U P G R A D I N G ^ ^

GOVERNMENT , z "

s

I ENTS

b o ra g e

I 'M 

SEP 30 >a / 0

/ K f c 4 ? ^ u N 0 / i « S l T Y

KANSAS 8 T ^ U N ' "

r t S ' HEARING

BEF ORE TH E

S MITTEE ON BUILD INGS AND GROUNDS

OF T H E

tf MITTEE ON PUBLIC WORKS 

UNIT ED STATES SENAT E

NIN ETY-F OU RTH CONG RESS

SECOND SES SIO N

ON

A PRO POSAL TO RENOVATE AND UPGR AD E TWO GSA 

HE ATING PLA NTS

JU NE 18, 1976

SERIA L NO. 94-H47

Pr in te d fo r t he use o f th e Com mittee on Pu blic Works

75-4302 0

IL S . GO VE RN MEN T PR IN TI NG OF FI CE

WAS HI NG TO N : 1976
COMMITTEE ON PUBLIC WORKS

JENN INGS RANDOLPH, West Virginia, Chairma n

EDMUND S. MUSKIE, Maine 

JO SE PH M. MONTOYA, New Mexico 

MIKE GRAVEL, Alaska

LLOYD M. BENTSEN, Texas 

QUE NTIN N. BURDICK, No rth Da kota 

JOHN C. CULVER, Iowa

ROBERT MORGAN, No rth Ca rolin a 

GARY’ HART, Colorado

JAM ES L. BUCKLEY, New York 

HOWARD H. BAKER, J r., Tennessee 

ROBERT T. STAFFORD, Verm ont 

JAMES A. McCL URE, Idaho 

PE TE V. DOMENICI, New Mexico

M. Barry Meyer, Chief Counsel and Chief Cleric

Bailey Guard, Mi nority St af f Director

Leon G. Billings and Richard D. Grundy, Senio r Pro fessional Staff Members

J ohn W. Yago, Jr., Assista nt Ch ief Clerk; Phil ip T. Cummin gs, As sistan t Chief Counsel

Harold H. Brayman, Senio r Pro fessional St aff Mem ber (M ino rity )

Pro fessional and research staf f: Karl R. Braithwaite, J ames W. Case (A ssistant Counse l), P aul Chim es , Trenton Crow, Katherin e Y. Cud lip p, Paul F. Ebelt oft, Jr ., 

George F. Fenton, Jr ., Randolph G. Flood, Kathaleen R. E. Forcum, Ann Garrabrant, Richard T. Greer, Richard M. Harris (A ss ista nt Cou nsel), Wesley F. 

H ayden, Richard E. Herod (A ssista nt Counsel, M in or ity ), Veronica A. Holland, 

Ronald L. Katz, J udy F. P are nte, J ohn B. P urinton, Jr ., J ames D. Range, W. Lee

Raw ls, Charlene A. Stu rb itt s, E. Stevens Swain, Jr ., Sally W. Walker, and Haven

Whitesid e

Sub co mm itt ee on Build ings and Grounds

ROBERT MORGAN, No rth Carolina , Chairman

MIK E GRAVEL, Alaska 

JOHN C. CULVER, Iow a

HOWARD H. BAK ER, J r., Ten nessee 

JAM ES A. McCL URE, Idaho
CON T E N T S

Morgan, Hon. Robert, U.S. Senator from the Sta te of North Carolina, P a g e

opening statem ent of___________________________________________ 1

LIST OF WITNESSES

Wendehack, Fred, Deputy Assistant Commissioner for Buildings Manage­ ment, Public Buildings Service, General Services Ad minis tration; accompanied by Wolfgang Zoellner, Directo r, Repair an d A ltera tion Divi­ sion; Ken Ward, Manager, Heating. Operation, and Transm ission; Joh n Galuardi, Regional Adm inistrator, Region 3; and Arnold Hespe, Legal Counsel, Region 3_____________________________________________ 20

ADDITIONAL MATERIAL

Comparison of 40 pla nts_________________________________________ 30 Dis trict of Columbia, comments of_________________________________ 30 General Services Administration, responses to written question s________ 46 Prospectus ______________________________________________________ 2

(in )

HEATING PLANT RENOVATION AND UPGRADING

FRID A Y , JU N E 18, 197 6

U nited S tates S en at e,

Com mit tee on P ubl ic W orks, 

Subcomm itt ee on B uildin gs and Grounds,

W a&Kington, D.C.

The subcommittee met at 9 :08 a.m., pursuant to call, in room 1114, 

Dirksen Senate Office Building, Hon. Robert Morgan (chairman of 

the subcommittee) presiding.

Prese nt: Senators Morgan and Gravel.

OPE NIN G STATEMENT OF HON. ROBERT MORGAN, TJ.S. SENATOR 

FROM TH E STATE OF NORTH CAROLINA

Senator Morgan. We will call the meeting to order.

For the record, we are meeting today to discuss GSA’s proposal to 

renovate and upgrade their two heating plants downtown which fu rnish the steam for most of the Government buildings.

We are advised that the District has filed a lawsuit against GSA 

because of the fact that the two plants are violating—according to 

their allegations—air and water pollution laws and regulations.

In recent weeks the Congress has been severely criticized by the 

press and even the courts because GSA has told them tha t the problem cannot be corrected unless we authorize more money. GSA is 

asking for $23.4 million.

Both the District Government and General Accounting Office contend this amount is not necessary, and th at work required to eliminate 

pollution and comply with the law would cost less than h alf a million 

dollars, which GSA could spend without approval.

I just wanted this to be a matter of record before we proceed, and 

some of my questions will be addressed along this line.

[The prospectuses being discussed follow:]

(!)
2

PROSPECTUS NUMBER: PDCOOO23 

BUILDING NUMBER : DCOOO2ZZ

PROSPECTUS FOR PROPOSED ALTERATION 

UNDER THE PUBLIC BUILDINGS ACT OF 1959, AS AMENDED 

WEST HEATING PLANT WASHINGTON, DC

1. SUMMARY OF PROPOSED PROJECT:

This prospectus provides fo r repa irs and altera tions which should be 

undertaken at th is f a c ility fo r it s continued use in prov iding adequate 

heating and hot water services to the Federal agencies in the Washington, DC, 

area u til iz in g the optimum fuel fo r energy and complying with the local 

and Federal environmental requirements. Major items of work include the 

conversion of two boile rs from o il only to m ulti-fu el includ ing coal 

capability, in s ta lla ti o n of a new dry ash removal system; in sta lla tio n 

of three ad ditio na l pre cip ita to rs ; and replacement of a manual elevator 

with a new automatic ele vato r. The above items w il l be programmed to be 

completed with in fi v e years aft e r approval of th is prospectus. This 

pr oje ct does not inclu de (1) the day-to-day pre ventative maintenance and 

recu rring maintenance re pairs, includ ing pa intin g and poin ting, which 

must be undertaken an nually to keep the plan t in opera ting co nd ition , 

and (2) repairs and improvements which may be occasioned by an emergency 

or breakdown which in te rr upts use of the plan t.

2. ESTIMATED MAXIMUM COST:

Au thoriza tion requested................................................. $3,100,000

3. DESCRIPTION AND JUSTIFICATION OF WORK:

At the present tim e, two of the five opera tional boile rs at th is plan t 

are o il -fir e d . These two boile rs (i. e . #3 and #5) w il l be converted to 

m ulti-fu el capability in ord er to u til iz e coal as a fu el.

The new dry ash -handling system w il l be capable of removing a ll partic ula te 

matter and conform to the D is tr ic t of Columbia a n ti-p o llu tio n codes.

The in s ta lla ti o n of three ad ditio na l pre cip itato rs fo r removal of partic ula te s 

from the flue gases w ill bring th is plan t in to conformance with the 

Federal and D is tr ic t Clean A ir Requirements. This w il l provide one 

pre cip itato r per b o ile r, in lieu of one pre cip itato r per two boile rs .

The fr eig ht elev at or is hazardous fo r both personnel and equipment, and 

cannot be rep aired to acceptable safety standard s. This pr ojec t w il l 

replace the exis ting manual elev ator with a new automatic elev ator.
PROSPECTUS NUMBER: PDCOOO23 

BUILDING NUMBER : DCOOO2ZZ

The West Heating Pla nt in co nju nctio n w ith the Ce ntral Heatin g Plan t 

pro vid es steam fo r he atin g and hot wa ter to Government build in gs in the 

downtown area of Washington, DC. This pla nt is s tru c tu ra ll y sound and 

is ess entia l to pro vid in g these se rvices to 112 pr es en t lo ca tions and 

a ll fu tu re Federal b u ildin gs to be loca ted in th is area o f the c it y . I t 

has an occupiable area o f 109,000 square fe et and houses 80 General 

Se rvices Adm in is tration employees.

4. DISCUSSION OF ALTERNATIVES:

a. Replace the f a c ilit y w ith a new modern str u ctu re .

The present value co st o f constructing and m aint aining an eq uivale nt 

build in g fo r a comp arative pe rio d is $68,095,300. The pres en t value 

co st o f a lt e ri n g and m ain ta in in g the presen t build in g is $34,978,000.

The co st effectiveness ra tio o f constructing to a lt e rin g is :

$68,095,300 = 1.95 (C onst ru ct in g)

$34,978,000

b. Pro vide a s im il a r amount o f space in a modern leased f a c ilit y .

There is no leased space in the Washington, DC, area comparable to the 

West Heating Plant f a c ilit y . The co st ra tio o f th is a lt e rn a ti v e is no t 

availa ble or applic able .

c. Proceed w ith the re p a ir and a lt e ra ti o n p ro je c t.

Because of the above constr uction co st ra tio , i t is more economical to 

proceed w ith the proposed a lt e ra ti o n p ro je ct.

5. CURRENT HOUSING COST:

Occup iable Area Annual Cost

Ope ratio n, Maintenance

and Upkeep Costs 109,000 s q .ft. *$3,3 18,70 0

*T his co st is ap po rtion ed among 112 build in gs served by th is system.

6. COMPREHENSIVE HOUSING PLAN:

This is b a sic a lly a re p a ir and a lt e ra ti o n p ro je ct and w ill no t a ff e c t 

the housing o f Federal agencie s in Washington, DC; th e re fo re , the 

comprehensive housing plan only re fl e c ts the housing plan fo r th is 

bu ild in g .
PROSPECTUS NUMBER: PDCOOO23 

BUILDING NUMBER : DC0002ZZ

See a tt a c h e d E x h ib it B.

7. ENVIRONMENTAL DATA

In th e develo pm ent o f t h is p r o je c t, s tu d ie s wer e made to d e te rm in e th a t 

th e p r o je c t w ould be accom plis hed in s t r i c t co m plian ce w it h th e purp oses 

and in t e n t o f E x e c u ti v e O rd er 115 14 " P r o te c tio n and En ha nc em en t o f 

E n vir o n m e n ta l Q u a li ty " and w ould co m ply w it h th e re q u ir e m e n ts o f S e c ti o n 

1 0 2 (2 )(c ) o f th e N a ti o n a l E n viro n m e nta l P o li c y A c t o f 1969 (P .L . 91- 

1 9 0 ), as am ende d, an d th e g u id e li n e s p re s c rib e d by th e C ou n cil on 

E n viro n m e nta l Q u a li ty .

8. STATEMENT OF NEED:

I t has been d e te rm in e d th a t th e im p le m e n ta ti o n o f t h is p r o je c t w il l 

p ro v id e n e ce ssa ry h e a ti n g fo r th e F ed e ra l b u ild in g s fr o m a c e n tra l 

s o urc e a t maximum e f f ic ie n c y , th e re b y , c o n s e rv in g v a lu a b le energ y 

re s o u rc e s and e f f e c t in g s u b s ta n tia l c o s t s a v in g s to th e Gov ern ment. I t 

has been f u r t h e r d ete rm in e d th a t i t is in th e b e s t in t e r e s t o f th e 

Gov er nm en t to r e t a in t h is p la n t to p ro v id e t h is s e rv ic e .

S u b m itte d a t W a sh in g to n , DC, o n _________ MAR 1 u ______________________ ___

Reco mmended:

C om m is sio ner, P u b li c B u il d in g s S e rv ic e

Appro ve d :
5

PROSPECTUS NUMBER: PDCOOO23 

BUIL DING NUMBER : DC 000 2ZZ

SUPPLEMENTAL DATA

PROSPECTUS FOR PROPOSED ALTERATION

r

PROJECT UNDER THE PUBLIC BUILDINGS ACT OF 1 9 5 9 , AS AMENDED

WEST HEATING PLANT WASHINGTON, DC

1 . F a c i l i t y S t a t i s t i c a l I n f o r m a t i o n :

D ate B u i l t : 194 8

S i t e A re a : 9 1 ,0 0 0 s q . f t

F a c i l i t y A re a G r o s s : 1 0 9 ,0 0 0 s q . f t

O c c u p ia b le A r e a : 1 0 9 ,0 0 0 s q . f t

P a r k in g S p a c e s : 45

A c q u i s i t i o n C o s t o f L an d a n d B u i l d i n g : $ 8 ,6 3 4 ,0 0 0

R e p la c e m e n t C o s t:

C o n s t r u c t i o n $ 4 4 ,6 9 0 ,0 0 0

S i t e a n d E x p e n s e s $ 1 1 ,0 0 7 ,9 0 0

Num be r o f E m p lo y ee s i n B u i l d i n g : 80

A n n u al C o s t o f O p e r a t i o n , M a in te n a n c e ,

an d R e p a ir : $ 3 ,3 1 8 ,7 0 0

U s e f u l L i f e , R e n o v a te d B u i l d i n g : 30 y e a r s

U s e f u l L i f e , New B u i l d i n g : 50 yea :r s

2 . C o s t D a ta ;

A u t h o r i z a t i o n r e q u e s t e d $ 3 ,1 0 0 ,0 0 0

C o s t o f t h i s p r o j e c t - $ 3 ,1 0 0 ,0 0 0 = $ 2 8 .4 4 /0 S F

1 0 9 ,0 0 0

C o s t E f f e c t i v e n e s s R a t i o

L e a s e d S p a c e = N/A 

A l t e r e d S p a c e

( L e a s in g )

C o n s t r u c t i o n 

A l t e r e d S p a c e

$ 6 8 ,0 9 5 ,3 0 0

$ 3 4 ,9 7 8 ,0 0 0

1 .9 5 ( C o n s t r u c t i o n )
6

E x h ib it A

BUILDING NAME ADDRESS NUMBER

West H e a ti n g P la n t W a sh in g to n , DC DC0002ZZ

DE SC RIPT ION OF WORK

PROPOSED PROSPECTUS 

(CURRENT EST IMATE)

C o n v ers io n o f b o i l e r s # 345 fro m o i l f i r e d t o m u lti- f u e l

f ir e d in c lu d in g m o d if ic a tio n s to th e f u e l h a n d li n g

e q u ip m en t. ______________

I n s t a l l a t i o n o f 3 a d d itio n a l p r e c i p i t a t o r s to m ee t a i r

p o l lu t io n re q u ire m e n ts 5 8 6 ,0 0 0

R epla ce m ent o f m an ua l e le v a t o r w it h a new a u to m a ti c on e 9 0 ,0 0 0

I n s t a l l a t i o n o f new d ry ash h a n d li n g sy ste m to m ee t

w a te r p o l l u t i o n re q u ir e m e n ts 1 .4 4 3 .0 0 0

D esi gn an d s u p e rv is io n 304.0 0 0

A u th o r iz a tio n R e q u este d __ $3,1 00 ,0 00 . .
▼

EXHIBIT "B"

Comprehensive Housing ?lan

S u il d in g Name

WEST HEATING PLANT

A d d res s

WASHINGTON, DC

2 -1 1 -7 6 Number

DC0002ZZ

De pa rt m en t or Age nc y P e r so n n e l O cc u p ta b le Are a ( Sq . F t .)

G e n e ra l S e r v ic e s A d m in is tr a tio n 80 1 0 9 ,0 0 0

-
A
9

PROSPECTU S NUMBER: PDC00013 

BUI LDI NG NUM BER : DC0001 ZZ

PRO SPE CTU S FO R PROPOS ED ALT ERA TIO N 

UNDER THE PLcL IC BU IL DINGS ACT OF 1959, AS AME NDE D

CE NT RA L HEATING PLANT WAS HIN GTO N, DC

1. SUM MARY OF PRO POS ED PR OJ EC T:

This p rospectus p rov ide s for rep air s and altera tio ns which shoul d be 

und ert ake n at this fac ility in ord er that it ma y contin ue to provide 

ade quate hea ting and hot wa te r serv ices to the Federa l ag enc ies in the 

Washington, D. C. , area. Th is p roject pro pos es the replacement o f two 

(2) obs olete boilers, and a sh han dli ng equi pment: new facili tie s for 

coal pulverizing, fee dwater tre atment an d han dli ng of coal; equipm ent 

for removal of particul ate s from the flue gases; and replace men t of 

fee dwater pumps. The work c over ed by this pro jec t incl udes all o f the 

majo r items that are m an da to ry for continued o per ati ons in the immediate 

future. The abov e items are pro gra med to be com pleted wi th in 5 years 

after approval of the pro spe ctu s. It does not include (1) the day -to - 

day preventiv e m ainte nan ce and recurr ing repairs inclu din g p aintin g and 

pointing, which mus t be un de rt ak en an nua lly to k eep the p la nt in o pe ratin g condition, and (2) repairs and altera tio ns wh ic h may b e occasione d 

by an emergency or breakdown wh ic h interrupts use of the plant.

2. ESTIMATED M AXI MUM C OST:

Aut horization requ est ed ..................................... $20,300,000.

3. DES CRIPTION AND J USTI FI CA TI ON OF WO RK :

At the present time, two of the six boil ers at this building h ave b een 

repla ced by oil-fi red boile rs und er the aut hor ity of a pre viously 

appro ved pr ospectus. The fou r rem aining bo ile rs are o ver 4 0 years old, 

inefficient, and able to o pera te at less than 70 perc ent o f the ir rated 

cap acity and are, in a ddi tio n, no longer consi der ed reli able. Two (2) 

ne w energy efficient, mu lt i-fuel boi lers will repl ace two (2) existing, 

badl y deteriora ted boilers.
PROSPECTUS NUMBER: PDC00013 

BUILDING NUM BER : DC00 01ZZ

The new boilers will have mult i-fuel cap abi lit y a nd w ill use pu lv erized 

coal as the primar y fuel s> nee this is pr ese ntl y the most abu nda nt fuel 

avai lable. Additional coal handli ng e qui pment is pr opo sed to per mi t the 

simult ane ous unloading o f two rai lro ad c ars of coal.

The new dry ash handling equip men t will be capable o f con taining 

par ticulate matter from the b ot to m as h in c onf ormance wit h D ist ric t 

of Columb ia anti-pollution codes.

The ins tallation of a new feedwater tre atment system wil l remo ve boile r 

scale causing materials from the w at er used in the p rod uct ion of steam. 

New fuel han dling equipment, inclu din g con veyors and hoppers, wil l be 

ins tal led so that the v ari ous type s of fuel can be eff ici ent ly hand led. 

The ins tallation of e qui pment for the remo val of p articulat es fro m the 

flue gases is to be pr ovi ded in o rder to con form with the C lean Ai r Act. 

The presen t feedwater pumps w hi ch are obsole te, worn and inefficient, 

and lack the capa city to provide suf fic ien t w ate r servi ce to th e boilers 

wil l be replaced.

The C en tral Heating Plant was specifically co nst ruc ted to supply steam 

for heating and hot water in Go ve rnment buil din gs in the dow ntown area 

of Washin gto n, D.C. The building is str ucturally s ound and the pla nt is 

essen tia l to provide these ser vic es to 112 present locations and all 

future Federal buildings to be loc ate d in this area o f the city. It has 

an occupia ble area of 139,300 squ are feet and hous es 90 Gene ral Servic es 

Adm inistration employees. The re are no special OSHA requ ire men ts for 

this project.

4. DISCUS SIO N OF ALTE RN AT IV ES :

a. Replace the faci lity w it h a n ew mod ern structure.

It is est imated that it wou ld co st $69,569,000 to replace the bui ldi ng 

if c ons tru cti on were to start in fiscal year 1976. The c ost ratio of 

this altern ati ve to alt ere d spac e is 1.75 to 1.00.

b. Provide a similar amo unt of space in a modern lease d facility.

There is no leased space in the Washin gto n, D.C., area com parable to the 

Central Hea ting P lan t facility. The cost rat io of this alterna tiv e is 

not availa ble or applicable.
11

PROSPECT US NUMB ER: PDC0 0013 

BUI LDING N UMBE R : DC0 001ZZ

4. DISCUSS ION OF A LT ER NA TI VE S: (Cont'd)

c. Pro ceed wi th the rep air and altera tio n projec t.

Bec aus e of the above constru cti on cost ratio, it is more econo mic al to 

pr oceed w it h the prop ose d rep air and altera tio n projec t.

5. CURREN T HOUSING COST:

Oper ation, Mai ntenance 

and Up kee p Co sts

Occ upiable Are a

139,3 00 sq. ft.

Ann ual Cos t

*53,162 ,11 0

‘Thi s cost is appo rtioned among the 112 buildings serv ed by this facility.

6. COMPREHEN SIV E HOU SING PLAN:

This project is basic all y a rep air and alt eration p roject. There w ill be 

no reloc ati on of personnel in thi s build ing.

See att ached Exhibit B . *

7. ENVIR ONM ENT AL DA TA :

In the dev elo pme nt of this projec t, studies w ere m ade to det ermine that 

the projec t woul d be accompl ish ed in stri ct com pli anc e with the pur pos es 

and inten t of Executive Ord er 11514 "Protection and Enhance men t of 

Environme nta l Qualit y" and would co mp ly wit h the requi rem ent s of S ect ion 

10 2( 2) (c) of the N ational Environmental Policy Act of 1969 (P.L. 91-19 0), 

as amended and the gui delines pres cr ib ed by the Cou nci l on Environ men tal 

Quality.

A draf t environmental statem ent has bee n prepar ed and will be sub mit ted 

with the prospectus. Completion o f this pro jec t will be a step tow ard 

br inging a major nonconfor min g facility into con for man ce with r equ ire d 

air and water quality standards an d will decr ease the requi rem ent s for 

dredging of the coal and ash sed iment from the Washing ton channel.

8. STATEMENT OF N EE D:

It has bee n dete rmined that the accom pli shm ent of this projec t will 

pr ovide necess ary heating for the Fed era l bui ldi ng from a central
12

PROSPECTUS NUMBER: PDC00013 

BUILDING NUMBER : DC0001ZZ

8. STATEMENT OF NEED: (Cont'd)

source using a domestically abundant energy resource, and ensure 

compliance with existing environmental legislative acts. It has been 

further determined that it is in the best interest of the Government 

to retain this plant to provide this service.

Submitted at Washington, DC on MAR 1 7 1976

1 2 1976

Recommended:

Approved:

' Commissioner, Public Buildings Service

{Lw» ___

istrator of General Services
13

PROS P E C T U S NU MB ER : PD COOO13 

BUIL D I N G N U M B E R : DC0001ZZ

SUPPLEMENTAL DATA

P R O S P E C T U S F O R PROPOSED ALTER A T I O N

PR OJ EC T U N D E R T H E PUBLIC BUILDINGS A C T OF 19 59 , AS AMENDED

C E N T R A L HEATING PLA NT

1. Faci l i t y Statis tical I n f o r m a t i o n :

WASHINGTON, DC

D ate Bu il t:

Site Ar ea :

Facil i t y A rea Gr os s:

O c c upiable Ar ea :

Parking Sp ac es :

Acquisition Cost of Land a n d Buil di ng :

Replacement C os t:

Construction 

Sites an d Ex pe nses 

Number of Employ ees in Building:

Annual C ost of Op eration, Maintenance, and Re pa ir : 

Useful Li fe , Renovated Building:

Usef u l Li fe , New Bu il ding:

2. C o s t Da ta

C o s t of Thi s Project - 5 1 4 5 . 7 2 / O S F = ($ 20 ,3 00 ,0 00 ) 

139,3 00

193 4

95 ,832 sq. ft. 

17 5,000 sq. ft. 

13 9,300 sq. ft. 

Non e 

$7,502,218

$57,113,000

$12,456,000

90

$3,162,110

40 ye ar s 

50 yea rs

C o s t Eff ec ti ve ness Ra tio

L e ased Sp ace = N / A

A l t e r e d Sp ac e

C o n s t ruction “ $104,242,000

A l t e r e d Sp ac e $59,661,000

= N/A (Le asing)

= 1.7 5 (C on st ru ct io n)

75-602 0 - 76 -2
14

EXHIBIT A

BU IL DIN G NAME ADDR ESS

CENTRAL HEATING PLANT WASHINGTON, D.C .

DESCR IPTION OF WORK

PROPOSED PROSPECTUS 

(CURRENT ESTIMATE)

INSTALL TWO (2) MULTI-FUEL BOILERS d e sig n e d f o r maximum 

e n e rg y c o n s e rv a ti o n . They w i l l be b u i l t to use e i t h e r 

p u lv e r iz e d c o a l o r o i l w ith th e c a p a b i l it y o f b e in g co nv e rte d f o r b u rn ab le t r a s h . The b o i l e r s r

 c o n s tr u c te d o f 

fo rg e d s t e e l , a re a p p ro x im ate ly 70 f e e t h ig h w it h a 20 

X 20 f o o t b a s e , and w i l l f i t i n th e same a re a as th e 

e x is t in g b o i le r s . T her e w i l l be no ch an ge in th e b u ild ­

in g s tr u c tu r e r e q u ire d . B ec au se o f th e b o i le r s iz e i t 

may be n e c e s s a ry to lo c a te th e p r e c i p i t a t o r s on th e r o o f. 

T hese b o i le r s g e n e ra te s u p e r s a tu r a te d 40 5° F( 20 7° C) st eam 

a t 250 po un ds p e r sq u a re in ch p r e s s u r e a t an o u tp u t r a t e 

o f 220,0 00 po un ds o f stea m p e r h o u r.

5 1 6 ,1 6 1 ,0 0 0 .

INSTALL ELECTRONIC PRECIPITATORS. T^ie p a r t i c l e s in th e 

f lu e a re io n iz e d by a h ig h v o lta g e (9 0,0 00 v o lts ) and 

th e n c o lle c te d on e l e c t r i c a l l y c h a rg e d p l a t e s , th u s p r e ­

v e n ti n g p a r t i c u l a te m a tte r fro m p o l lu t in g th e atm o sp h ere . 

P h y s ic a lly , th ey a re ab o u t 28 f e e t sq u a re an d a b o u t 30 

f e e t h ig h w it h an 11 fo o t h ig h c o l l e c t o r b e n e a th th e 

u n i t . Eve ry e f f o r t w i l l be made t o e r e c t th e s e u n its 

w ith in th e f lu e s in s id e th e to p f lo o r o f th e b u ild in g .

1 ,0 8 2 ,0 0 0

INSTALL FEEBWATER SYSTEMS f o r tw o (2) new b o i l e r s . T h is 

sy ste m w i l l t r e a t b o th new w a te r i n to th e sy st em an d 

c o n d e n sa te w a te r r e tu r n in g from th e st eam sy ste m . T h is 

c o n s is t s o f pu mps, d e a e r a ti n g ta n k s an d th e ch em ic al 

( z e o l it e ) w a te r s o fte n in g sy ste m to p re v e n t th e b u il d u p 

o f s c a l e , whi ch c lo g s th e b o i l e r tu b e s an d r a p id ly d e ­

g ra d e s e f f ic ie n c y o f th e b o i l e r s . T h is sy st em mus t 

h a n d le 1 ,6 8 0 ,0 0 0 po und s o f w a te r p e r h o u r. P h y s ic a lly , 

t h i s sy st em r e q u ir e s 8 ta n k s o f 8 fo o t d ia m e te r by 10 

f o o t h e ig h t w it h th e a s s o c ia te d p ip e , pumps an d v a lv in g , 

u s in g ap p ro x im ate ly 2,0 0 0 sq u a re f e e t o f f lo o r sp a ce .

1 ,8 3 2 ,0 0 0

INSTALL A “DRY" ASH SYSTEM f o r th e re m oval o f th e bott om 

a sh from th e s e new b o i l e r s . T h is sy st em w i l l c o n s is t o f 

a t l e a s t two e x h a u ste r pumps d r iv e n by 125 hors epow er 

e l e c t r i c m o to rs , u s in g s t e e l p ip in g an d c o n n e c to rs o f 

a p p ro x im ate ly 18 in c h d ia m e te r. T h is sy st em w i l l 

c o l l e c t th e c o a l a sh fro m th e b o i l e r b a se a s i t i s 

g e n e ra te d fro m th e f i r e an d th e n p ip e d by Vacuum to th e 

c o ll e c ti o n s i l o s . T hre e (3) a s h c o ll e c ti n g s i l o s o f 30 

f o o t h e ig h t by 16 fo o t d ia m e te r w i l l be i n s t a l l e d to 

c o l l e c t th e ash an d p ro v id e a t o t a l l y e n c lo se d d is p o s a l 

sy ste m , th e re b y com ply in g w ith th e e n v ir o n m en ta l r e q u ir e ­

m en ts .

1 ,0 5 0 ,0 0 0
BUILDING NAME

C e n tra l H eati n g P la n t

15

ADDRESS

S h eet 2 o f 2 S h eet

W ash in gto n, DC

NUMBER

DC0001ZZ

DESCRIP TIO N OF WORK

PROPOSED PROSPECTUS 

(CURRENT ESTIMATE)

INSTALL A TEMPORARY WASTE WATER ASH SYSTEM. T h is sy st em 

m ust be i n s t a l l e d to h a n d le th e b o tt o m a sh fro m th e 

b o i l e r s o p e ra tin g d u rin g th e d e m o liti o n an d e re c tio n 

p e rio d o f ap p ro x im ate ly th r e e y e a r s . T h is sy st em w ill 

r e q u ir e i n s t a l l a t i o n o f tw o (2) 20 f o o t h ig h x 20 f o o t 

d ia m e te r ta n k s , co u p le d w ith pum ps and 18 in ch p ip e from th e o p e ra tin g b o i l e r s . T h is sy ste m w i l l p re v e n t an y 

in c r e a s e in p o llu tio n d u rin g t h i s p e r io d .

175,0 00

T o ta l $ 20,3 00,0 00*

* T o ta l C o st in c lu d e s

$ 1 ,9 8 9 ,4 0 0 f o r d e sig n and 

s u p e rv is io n . T h is d e sig n 

an d s u p e rv is io n c o s t has be en 

p r o - r a te d in to th e c o s ts 

sho wn f o r each o f th e 

wo rk ite m s .

GS* OC 74 .7 4* 3
EXHIBIT B

Com pre hen si ve H ou sing P la n

B u il d in g Name

C e n tr a l H eati n g P la n t

A ddre ss

W as hin gto n, DC

Num ber

DC0001ZZ

D ep ar tm en t o r Age ncy P e rs o n n e l O ccu p la b le A re a ( Sq . F t . )

G en era l S e rv ic e s A d m in is tr a ti o n 90 139 ,30 0

The re w ill be no r e lo c a tio n o f p e rso n n e l in t h i s b u il d in g .

0 5
*

S ou th E a st C or ner

R ec’d F eb ru ary 19 75

C e n tr a l H ea ti n g P la n t , W a sh in g to n , IX
No rth West Co rner

R ec ’d Fe br uary 197 5C en tr al H ea ting P la n t, W as hi ng to n, DC

o o
19
20

Senator Morgan. Who is going to present the case this morning?

Mr. Wendehack. I am, sir.

Senator Morgan. If you would, for the record, please identify yourself by name and position, and also those with you. I think that would 

be the better way to proceed.

STATEMENT OF FEED WENDEHACK, DEPUTY ASSISTANT COMMISSIONER FOR BUILDINGS MANAGEMENT. PUBLIC BUILDINGS

SERVICE, GENERAL SERVICES ADMINISTRATION; ACCOMPANIED

BY WOLFGANG ZOELLNER, DIRECTOR, REP AIR AND ALTERATION DIV ISIO N; KEN WARD, MANAGER, HEATING, OPERATION,

AND TRANSMISSION; JOHN GALUARDI, REGIONAL ADMINISTRATOR, REGION 3; AND ARNOLD HESPE, LEGAL COUNSEL, REGION 3

Mr. W endehack. My name is Fred Wendehack. I am Deputy Assistant Commissioner for Buildings Management. On my left is Mr. 

Wolfgang Zoellner, Director of the Repair and Alteration Division, 

Central Office. On my direct right is Mr. Ken Ward who is the Chief 

of the Plants in the Washington, D.C., area. On his rig ht is Mr. John 

Galuardi who is Regional Administrator for region 3 and who has the 

responsibility for the entire Washington area and surrounding territory. On his right is Mr. Arnold Hespe who is the Legal Counsel for 

region 3, in case there are any legal questions that come up.

Senator Morgan. Are you going by a prepared statement?

Mr. Wendehack. I could make a few opening remarks as to what 

the projects entail, if you would like, sir.

Senator Morgan. All rig ht; if you would.

Mr. Wendehack. Would you like me to address both plants or just 

the central plant at this time? They are tied together. I could address 

both of them at the same time.

Senator Morgan. Why don’t you do that.

Mr. Wendehack. The prospectus for the central heating plant, as 

we mentioned, requested authorization to replace two 42-year-old 

coal-fired boilers that we can no longer depend on with two multifuel 

boilers designed to burn either pulverized coal or oil, or possibly in 

the future any energy source tha t might be developed to meet the 

emergencies of the period.

The replacement of the boilers is necessary, first, to meet the steam 

load requirements of the 112 buildings in the Washington, D.C., area 

and to maximize the use of coal-burning capacity, the most readily 

available fuel that we have at this time.

In addition, electronic precipitators will be installed to remove pollutants from the smokestacks, and a dry ash system to collect the ashes 

from the boilers will be installed. This is to prevent the Potomac from 

being polluted.

Both of the latter pieces of equipment are necessary to bring the 

plants in compliance with the Clean Air Act and Water Act of 1970.

The prospectus for the west heating plant requests authority to convert the two oil-fired boilers to multifuel, so that we will be able to burn 

more abundant fuel. Also, three additional precipitators and a dry ash 

system will be installed to brin g it into compliance with the Clean Air 

Act and Water Act.
21

The two plants combined are connected by a 6-mile steam route th at 

connects the two plants together and provides steam to 112 buildings 

in the Washington, D.C., area. The central heating plant has been in operation since 1934, and the 

west heating plant since 1948.

Senator Morgan. Where are they located ?

Mr. Wendehack. The central plant is located righ t beside the A griculture Building on 12th and I). The west plant is over in the Georgetown area, along the Rock Creek area.

Senator Morgan. You say they are tied together by 6 miles of line?

Mr. Wendehack. There is 6 miles of steam tunnel th at ties the plants 

together and ties into the 112 buildings.

Senator Morgan. The 6 miles include the tunnels going to the 

buildings?

Mr. Wendehack. Tha t is correct.

Senator Morgan. Can you give us details of the D.C. Government’s 

lawsuit against GSA resulting from alleged air and water pollution 

by these plants?

Mr. Wendehack. On Jun e 5, 1975, a lawsuit was brought against 

GSA by the District for failure to meet the Clean Air Act standards. 

We are in noncompliance with those acts.

Senator Morgan. In what way ?

Mr. Wendehack. In terms of the particulate m atters tha t are going 

into the atmosphere and in terms of the bottom ash tha t is going into 

the Potomac.

Senator Morgan. What have you done in recent years to improve 

the pollution emissions?

Mr. Wendehack. Wc have gone through a long series of steps on 

these plants. Actually, back in 1968 we got started on trying to do 

something on two aspects. One was to try to take care of the fact that four of our boilers were reaching the end of their useful life. These are four old coal-fired boilers, stoker-fired burners, which are extremely dirty, and the precipitators do not take care of the pollution into the air. Second, we are aiming at, as I say, getting rid of the pollution. The Clean A ir Act of 1970, of course, was passed, and this expedited our 

efforts to try to take care of the two problems. As a result, in 1970 a prospectus for conversion to oil and gas was approved by the Congress. At this time, of course, we were primarily aiming at tryin g to clean up—by using the oil—clean up the atmosphere and also the pollution to the Potomac. In 1971, Congress appropriated the first money for this conversion.

Senator Morgan. How much was that ?

Mr. Wendehack. For the central plant, $11.4 million, the total of 

two prospectuses. And the west plant was $8.6 million. In July of 1972, a contract was awarded for the bulk of the work necessary in the central and west plants to take care of the environ­ mental requirements and also to take care of our needs for the capacity 

of the plant.

We estimated at that time, by 1976, June of this year, that we would 

be in compliance with the Clean Air Act and also have the necessary 

capacity th at we needed.
22

Un fortu na tel y, in 1973, ou r conv ersion proje ct, like many of the 

proje cts across the co un try , was interru pted because of the fac t th at 

the oil emb argo was on and there was heavy emphasis placed on th e 

country to conserve oil.

As a resu lt, we stop ped the conversio n, at a po in t two-thi rds of t he 

way throug h the project, we s topped the conversion to oil.

In iti ally un der these prosp ectu ses, at the cen tra l p lant we were g oin g 

to ins tal l six 200,000-pound boile rs—a total of 1,200,000 pounds. Tha t 

was a pproved by th at prospectus.

During th e desig n p hase, it was de termined i t w ould be m ore efficient 

an d better op eration all y if we installed thr ee 400,000-pound boilers— 

ag ain a to tal of 1,200,000 pounds.

Sin ce we stopped th e project tw o-third s of th e way th roug h, we only 

ins tal led two 400,000-pound boilers. Th at left us short in cap acity by 

400,000 pounds. Of these two boilers, one came on line in December of 

1975------

Se na tor Morgan. Is th at b urning oil ?

Mr. W endehack. It is b urning oil. The second one is in the process of 

being finally accepted by the Governme nt. The co ntr actor has n ot y et 

tu rn ed it over to us. T ha t one will also burn oil.

A t t he west plan t, t wo of the boilers the re were converted to oil.

Se na tor Morgan. H ow many boilers do you have at the centr al 

pl an t?

Mr. Wendehack. W e hav e six boilers a t the centr al pla nt. Fo ur of 

them are 42 years ol d ; the old stoke r-fired boilers.

At the west plant there are five boilers; two are oil and th ree are coal.

Se na tor Morgan. W ha t exa ctly do you prop ose to do th at is covered 

by this prosp ectus ?

Mr. Wendeiiack. A t t he centra l plan t we will be insta lling two new 

mult ifu el boilers which, as I men tioned, will give us a capability to 

bu rn whatever fuel is most economic in value to the country .

Se na tor Morgan. Incl ud in g coal ?

Mr. Wendehack. In clud in g coal. It will be b low n-in coal. Th e coal 

will be crush ed and blow n in. It will be a lot more efficient boiler. The 

oil could also be used if we ha d to. The boilers e ventu ally could be used 

fo r b urning trash, if we ha d to, or possibly other fuel, such as alcohol, 

or wh ate ver became available on the ma rke t. So we have a w ide ran ge 

of latitu de as to wha t type s of fuel we can use d ependin g on the needs 

fo r th e co untry at the time.

We inte nd to bu rn coal because, it is cheap er; pa rticul ar ly the fac t 

we can go to the pulve riz ed coal now, which is cheap er than the 

sto ker coal. O f course, it will save the oil.

We antic ipa te that by ma xim izing the use o f these mu ltifuel boilers 

and the coals that are at the west pla nt we sho uld be able to save in the 

neighb orhood of abo ut 27 million gallon s of oil pe r year in lieu of 

bu rn ing oil full time.

Se na tor Morgan. W ha t is going to happen to the other two boilers 

1 hat are 42-years old ?

Mr. Wendehack. T hey will rem ain in place. They, as I mentioned, 

have reached the end of th ei r useful life. We can’t plan on their relia ­

bility beyond anoth er 5 years . They will rem ain in place. Th ey will 

be pu t into standb y. How ever, they do not meet the pollution req uir ements eithe r, and the ir use wou ld just be in an extreme emergency.
23

Senator Morgan. What are you going to do at the west plant?

Mr. Wendehack. At the west plant, we are converting the two oils to dual fuel, again, so that we have the capability of burning coal. We 

will be putting in three additional precipitators. Those three additional precipitators will be placed on the three coals tha t are in existence now to meet the Clean Air Act standards. We will also be installing a dry ash handing system so that we do 

not pollute the Potomac. Those are the prime projects.

Senator Morgan. Let’s go back to the lawsuit a minute. W hat spe­ cifically does the District of Columbia allege in their lawsuit? M hat 

did they say you were not doing?

Mr. Wendeiiack. I would like to ask Mr. Hespe to answer since he 

is thoroughly involved in this.

Mr. I Iespe. Actually, there are three counts in the lawsuit. The first count is we are polluting the air by the particulates going into the air. 

Tha t is the first count. The second count is th at we have our coal stored outside; and with the rain and water coming down on the coal, certain acids or minerals 

go into the water and that pollutes the water. The other complaint is that the wet-ash system that we use, the water 

sloughs go from the plan t into the Potomac. So we are polluting under three counts. Actually, we have to admit 

that.

Senator Morgan. How much coal do you burn a day ?

Mr. Wendeiiack. I beg your pardon?

Senator Morgan. How much coal do you burn a day; how many 

tons?

Mr. Wendeiiack. Mr. Ward?

Mr. Ward. It depends really on the weather conditions and how cold a winter it is. We have burned as much as 209,000 tons per year. During the past year—we were burning oil besides coal therefore the 

figure was drastically reduced.

Senator Morgan. W hat are your plans for sheltering the coal you 

burn once you complete this work ?

Mr. Wendehack. That is part of the prospectus, to cover the coal, 

so we don’t have that problem.

Senator Morgan. Tha t would be a relatively inexpensive job, would 

it not ?

Mr. Wendeiiack. Yes, sir. I am not sure of the exact cost, but we can 

provide the exact cost for the record. [The information referred to follows:]

Further review of the problem reveals that a more practical method for han­ dling the small amount of acid run off from the coal is to divert this run off to the plant water sump system where the acid will be neutralized. This can be 

done for approximately $7,500.

Senator Morgan. Let’s assume you did not have an environmental problem. What would be the condition of the six boilers? I believe you 

said there are six at the central plant.

Mr. Wendeiiack. Six at the central plant.

Senator Morgan. Four of them you say are extremely old, 42 years 

old?

Mr. Wendeiiack. Th at is right.

Senator Morgan. Are the other two new ?
24

Mr. W endehack. Yes, sir , they are.

Se na tor Morgan. Y ou are ju st go ing to brin g two new ones on line?

Mr. Wendehack. Tha t is rig ht. The two new ones th at will be coming on line will be 220,000 p ounds per hour of steam , a to tal of 440,000 

pounds of steam. Th is will i n effect complete the or iginal ca pac ity that 

was proposed and approv ed under the pro spectus of 1972. In oth er 

wor ds, we will end up with ap proxim ate ly 1,200,000 pound s tota l ca pacity a t th e centr al pla nt.

Se na tor Morgan. Is this wh at you set out to do in 1972 ?

Mr. W endehack. Th at is correct, s ir.

Se na tor Morgan. H ow m uch money was spent the n and wha t was the 

pro jec ted cost?

Mr. Wendehack. For the central plan t, the autho riz ati on was 

ap prox im ate ly $11.4 mill ion . P art of th at am ount was obligated. H ow ­

eve r, because of sto pp ing th e conv ersion abo ut tw o-third s of the way 

throug h, we are in the proce ss o f receivi ng cred its from th e contrac tor. 

Th e exact amount we do no t know as yet. It is depen den t on the 

am ou nt of work he did an d so forth . But we are receiving credits 

ag ains t that.

Se na tor Morgan. W ou ld you estimate you spent h al f of it ?

Mr. Wendehack. I would estimate th at we hav e spe nt more th an 

th at because we did do tw o- third s of the work, a nd the co ntract or had 

don e some w ork on the t hir d boiler.

Se na tor Morgan. You now say the p lant is g oin g to cost how m uch ?

Mr. Wendehack. The new proposal, or this pro posal before you, 

is $20.3 m illion.

Se na tor Morgan. Th at is ju st for the ce ntral pl an t ?

Mr. W endehack. Th at is ju st for the ce ntr al plant.

Se na tor Morgan. You p rop ose d to do it all in 1972 for $11.4 million ?

Mr. Wendehack. In 1972, the tot al was $11.4 million. How ever, 

since th at time there hav e been some changes th at have affected us 

significantly . The 5 years o f escalat ion h as incr eased the cost by about 

50 percent.

Second, we are going to insta ll more efficient boilers. These multifuel boilers are more efficient and much more com plex because they 

can burn various typ es of fuel.

Thi rd , we a re going to a special pulve rizing syste m th at will allow 

us to bu rn a lower grad e of coal and receive op erating cost savings. 

Since more coal will be used, we will be ha vin g ad ditio na l hand lin g 

req uirem ent s for the coal.

Se na tor Morgan. W ill the two boilers that were ins talled under t he 

1972 pro jec t be able to b ur n pul ver ized coal ?

Mr. Wendehack. The tw o oil-fired ?

Se na tor Morgan. Yes.

Mr. Wendehack. No; not at this time , sir. They would have to be 

converted in o rder to b ur n coal.

Se na tor Morgan. L et ’s go back to the law suit again . Ar en ’t Fe deral 

fac ilities exem pt from po llu tio n laws and reg ula tions?

Mr. H espe. No, sir. I have to qu ali fy tha t. As fa r as the subs tan tive 

law is concerned, as fa r as the sta nd ards are concern ed, we mu st 

comply.

We do not have to com ply with the procedura l requirements of a 

St ate or local gov ernme nt. By th at I mean we do n’t have to ge t a
25

permit or comply with the other internal operations. So we are not 

subjected to their procedural requirements. The Supreme Court held in two cases, which were decided in June 

of this year, th at the Federal Government must comply with the sub­ stantive requirements but not with the procedural requirements. I can 

refer you to those two cases, if you would like, sir.

Senator Morgan. You might give us the citations on them.

Mr. IfEsrE. One is the PJnvironmental Protection Agen cy v. California. It is number 74-1435. It was decided on June 7, 1976.

The other case is Hancock v. Train. That number is 74-220. That 

also was decided on June 7, 1976.

Senator Morgan. Wha t States did they involve; or was it the 

District?

Mr. H f.spe. The Hancock case involved the State of Kentucky. The 

EP A case involved the State of California.

Senator Morgan. Has the lawsuit brought by the District been 

completed ?

Mr. H espe. No, sir.

Senator Morgan. What is the status of that?

Mr. Hespe. The District of Columbia filed a motion for partial 

summary judgment. The Federal Government opposed that motion 

based on the fact we had done everything we could have done. We in our response followed the history of our plants from 1968 

until the current time. We pointed out tha t Congress had approved 

our prospectus in 1970, that contracts had been awarded, and due to the change in the oil situation and the energy crisis we had to terminate the contracts, and tha t we now have to go through the new 

procedure, get a new prospectus, to put us in compliance.

The court recognized that we had done everything tha t we possibly 

could and that we were the victim of circumstances. Therefore, the 

court refused to grant the motion which the District had requested and 

decided they would take no further action at the present time. The judge did ask tha t we keep the court advised as to what our 

progress is in bringing the plants into compliance.

Senator Morgan. Their motion pending now is to strike that 

judgment?

Mr. Hespe. At this point it is still before the court, and it will 

stay there-----

Senator Morgan. It is in limbo, in other words?

Mr. Hespe. That is correct.

Senator Morgan. Was there any kind of consent agreement between 

GSA and EPA?

Mr. Hf.spe. Yes. sir. there was at one time.

Senator Morgan. What type of an agreement?

Mr. Hespe. W hat was the question ?

Senator Morgan. What was the consent agreement?

Mr. Wendf.iiack. I can provide the consent agreement for the 

record.

Senator Morgan. Why don't you tell me now.

Mr. Galuardi. I signed the consent agreement. The consent agreement was between myself and the regional office of the EPA in 

Philadelphia.
26

The consent agreement states tha t the General Services Administration would pursue a policy which would be to bring the plants into 

compliance with the District of Columbia’s air pollution and water 

pollution laws, and that the timetable would be established whereby 

we would seek the authority from the Congress and the necessary appropriations to bring those plants into compliance.

Senator Morgan. When was this done ?

Mr. Galuardi. It was approximately August of 1975.

Mr. W endehack. We were to be in compliance by 1979.

Air. Galuardi. The consent agreement was conditional in that it 

was necessary to seek the necessary authorization from the Congress. 

But the agreement was that we would attempt to get the authorization 

from the Congress.

Senator Morgan. Does this project, o r anything that you have done 

with regard to the heating plan t, require an environmental impact 

statement ?

Mr. Wendehack. Yes, sir.

Senator Morgan. Have you made one?

Mr. W endeiiack. We have filed a dra ft environmental impact statement within the last couple of months. Comments are coming in on 

that. We will proceed with the full environmental statement once the 

comments have been received.

Senator Morgan. Is that on the project you propose ?

Mr. Wendehack. That is for the central heating plant; yes, sir. The 

west plant, the draft environmental statement has not yet been issued.

Senator Morgan. How long does it take you to prepare these 

statements ?

Mr. Wendeiiack. Once they are published, the public has to be given 

90 days to comment on that. Our actual time for preparing it is normally about 3 months.

Senator Morgan. When you entered into your consent agreement, 

and began your impact statement, did you set up any time schedules 

as to when this action would be taken ?

Mr. W endehack. In the consent agreement there was a time frame 

set up as to when we would take the action. In both cases, in both 

plants, the action was to be completed by 1979.

We have fallen somewhat behind tha t schedule now as a result of 

delays in getting the whole process completed.

Senator Morgan. The District Government contends, as I understand it, tha t you can comply at a cost of less than half a million 

dollars, fairly quickly, and it would not require congressional review 

and approval.

Is that a correct statement ? I f so, what do you say about it ?

Mr. Wendehack. No, sir. We do not agree with that. At the west 

plant, for example, in order to come into compliance, we have got to 

install both precipitators for the particulate matter going into the 

air and a dry ash system to take care of the bottom ash going into the 

Potomac. That cost alone is about $2 million. We cannot proceed with 

that project without getting congressional authorization.

At the central plant again we have four 42-year-old boilers which are 

polluting the air. No. 1, we have got to replace them in order to retain 

the sufficient capacity that we need.
27

Once we do, we have go t to pu t p recipitators and bottom ash han dling 

capability on those. In both cases we need the au thor ization to proceed.

Se nator Morgan. I have here p age 5 of the co urt re cord of a hearing 

befo re the ju dg e on May 3 of this year. Sta tem ent No. 9 dealt with GSA 's contention th at measures cannot be tak en wi thou t congressional ap prov al. If states, “A ga in, it is the District’s conten tion th at the re are less costly measures whi ch can be un derta ken whi ch will not req uir e cong ressional ap pr ov al ; th at is, measure s can be undertaken which wou ld cost less t ha n ha lf a million 

do lla rs.”

Mr. Galuardi. There are some actions we can tak e, Se na tor , and we 

are doing it alread y. Unf or tuna tely , las t wi nter we ha d a problem which was th at we bu y coal fro m a certa in p ar t of the country , th e Is ­

lan d Cree k Coa l Co. There w as a d eliver y o f b ad coal which a rrived, which was very d if ­ ficult for us to c ontrol, and it s ent an excessive am ount of pa rti cu late m atter into th e air. Until such tim e as we could get th e coal out of the system, we had to keep bu rn in g it. We received no fu rt her coal. The conte ntion was we d id not have ade qua te con trol over the coal being delivered. We are now estab lis hing con trols whereby we have people who will go to the mine an d establish a q ua lity control system whereby we will be assure d th at we obtain the righ t kind o f coal from the mine and not get som eth ing into our system and the refore hav e to 

bu rn it ou t to get rid of it. Th e othe r th in g we are doing is there is the ash system. We have sort of a jury-ri gg ed system th at we can pu t toge ther to reduce the am ount of ashes g oin g into t he P oto ma c. Tha t is pu rel y a jury-ri gg ed 

system . It is necessary on a perm anent basis to in stall wh at we are askin g for 

under this prospectu s: a dry ash rem ova l system.

Se na tor Morgan. Did you pu rsu e th eir suggestions to see if they 

were based on any kin d o f s ign ificant da ta, or w hethe r this was ju st an 

allegation on th ei r pa rt?

Mr. Galuardi. The law yers fro m the Dist ric t of Colum bia have 

sta ted th is position. We have no t received any specifics fro m the 

Distri ct as to wh at they had in mind. They do n’t know our pla nt as well as we do, and we do n’t know that the y have an ythi ng very sig nif ica nt because we have looked at ou r plant. Nev erth eless, we would be glad to go back and ta lk to them.

Se nator Morgan. W ha t abo ut GA O ? H av en ’t the y made some kind 

of study alon g th is same line ?

Mr. Wend eha ck. GA O has talk ed to us in the past, abou t a year 

ago, rega rd ing the then pro posal as fa r as c apaci ty on the plants. We 

wen t th roug h q uite a series of stu die s. We have ad jus ted the request. A t th at tim e the proposa l was for three ad ditio na l boilers. We felt we needed them fo r the future. We have ad jus ted back to two a dd ition al boilers at thec en tral p la nt u nder this pro posal. We are assu red th is will ca rry us throug h 1985 as fa r 

as cap acity.

Se nator Morgan. I am pu rsui ng the question because I th in k we 

ou gh t to tr y to dis tin guish between wh at we are doing, for the purp ose
28

of controlling pollution, and what we are doing because a plant needs 

revamping.

Now, GSA has been quoted in the press as saying the reason they 

are polluting the air is because they didn’t have congressional 

appropriations.

It seems to me that if what the District contends is true, then the 

responsibility has been placed unduly on the Congress. It seems to 

me th at there should have been some kind of inquiry, if the District 

made that kind of allegation, as to what specifically were their contentions and how they thought you could do it.

Mr. Wendehack. Senator, I believe we have been somewhat misquoted on that. Our position has been tha t we have got to do the 

steps that we have proposed in this prospectus in order to handle 

two problems. No. 1 is the capacity requirement for the plant, which 

would be a continuation of a capacity tha t we originally got authority for under the 1972 prospectuses.

Second, as I mentioned, there will probably be about 4 million 

dollars’ worth of work between the two plants tha t needs to be done 

for environmental purposes.

Our statements to the courts and so forth were merely statements 

of the process tha t we have to go through in getting authority to 

proceed with the project. We explained that we had to go through 

OMB and through the Congress to get authorization to spend any 

funds on a project of this size.

I think we have been somewhat misquoted in directing any blame 

on the Congress. We are extremely pleased that the Congress has been 

willing to respond so quickly and listen to our problems and have 

this hearing held so quickly.

Senator Morgan. We don’t want to be led into it under any misapprehension of the facts. In other words, if you could have taken 

care of these pollution problems by building shelters or buildings for 

your coal and doing some other things-----

Mr. Wendehack. Sir, the problems that have been referred to here 

as far as the acids caused by the coal being exposed to rain and so 

forth are minor problems. We cannot correct the air pollution problem without precipitators at the plants. We cannot permanently 

handle the pollution of the Potomac and the Tidal Basin without 

the proper bottom ash handling equipment.

I can address the capacity situation for you and give you a 

rundown on the capacity requirements of the plant versus the load 

requirements, if you would like.

Senator Morgan. Wh at do you mean by capacity?

Mr. Wendehack. Let me go through the capacity requirements 

versus the load requirements of the plants so you may more fully 

understand our needs as far as the plan t requirements.

There are three basic types of capacity tha t I think have been 

referred to. GAO was refe rring to No. 1 in their statements, name 

plate capacity; that is, the rated capacity or the design capacity of 

the boilers when they are new.

As I mentioned, we have got a total of 11 boilers at these two 

plants. The nameplate capacity, when they were new, was 2,700,000 

pounds of capacity per hour of steam generation. However, like an
29

old car tha t has gone 150,000 miles, boilers get old. They no longer have the horsepower or capability to generate steam at tha t rate. The present total available capacity, the derated capacity of the boilers, these 11 boilers, is 2,300,000 pounds per hour. As I have mentioned, four of these boilers are 42 years old. They are very unreliable. They are reaching the end of their life. We can’t depend on them for any long-term planning beyond the next 5 years. This actually leaves us with a total capacity that we can depend on for the future of 1,700,000 pounds—subtracting the 600,000 from the 2,300,000 which those four coals are able to put out at this point. By the way, tha t will leave us with seven boilers left between the 

two plants. We know tha t under operating conditions, under load conditions, you must have some standby boilers available if for any reason one of your boilers or two of your boilers go off line. They may go off line because of control problems, a burnout of your grating, a myriad of different problems tha t may shut them down for 1 or 2 weeks 

or even a month. The standby capacity that we are asking for is about 30 percent. T would like to submit for the record a study tha t we did that com­ pared 40 other plants on capacity. These are private plants and plants 

across the country.

[The information follows:]

7 5 -6 0 2 0 - 76 - 3
P a g e 2 3 , L in e 15 WEST AND CENTRAL HEATING PLANTS

HEARING MATERIAL

- - - - - - ATT ACH MEN T '£

TABLE IV-4

Co mpa ris on o f IDHA fi DHS S t a t i s t i c s A ct ua l Maximum.

(IDHA S t a t i s t i c s a re fo r C ale ndar 1974) Maximum Hou rly * c Hou rly Se nd -O ut Ca? a - Co . Se nd -O ut C a ra c if .' U

No. C it y Company Name M lb M ’ lb use

1. New York, NY C o n so li d ate d Edi so n Co. o f NT’* 12 ,740 15 ,1 50 2 P h ila d e lp h ia , PA P h il a d e lp h ia E le c tr ic Co. 2,48 2 3, S57

D e tr o it, MI D e tr o it Edi so n Co. 1,7 28 2,97 1 r r

4. B os to n, MA Bo ston Edi so n Co. 1,83 0 2, 00 5

5. In d ia n a p o lis , IN In d ia n a p o li s Power 5 L ig ht Co.* 1,29 2 1,73 3 6. R o c h est er, NY R ochest er Gas 6 E le c. Cor p. * 1,11 8 1,37 5

M ilw au ke e, WI W is co ns in E le c tric Power Co. 91S 1,64 0 •7— 8. B a lt im o re , MD B altim ore Gas 5 E le c tr ic Co.* 678 990 Q. C le v e la n d , Oil C le vela nd E le c. Ill u m in a ti n g Co. 896 1, 52 0 K" 10. Day to n, OH Da yto n Power 5 L ig ht Co. 508 982 - 11. De nv er, CO P u b li c S crv . Co. o f Col or ad o 440 580 7"

12. P itts b u r g , PA A llen gh en v Co un ty Ste am Htg. Co. 668 1,04 1 £ 2 13 . S e a t t l e , KA S e a ttle Ste am Co rp . S98 923 x * 5 14. T oro nto , ON, Can ada T or on to H y d ro -E le c tr ic System - 434 560 - - 15 . H a rri s b u rg , PA P ennsy lv ania Power 6 L ig ht Co. 376 500 ’ -- 16. San F ra n c is c o , CA P a c ific Gas 5 E le c tr ic Co. 530 375

17. L an si ng, MI Board o f Wate r fi L ig ht 225 A 30 ; •

18. Grand R apid s, MI Consum ers Power Co. 234 5S019. D ulu th , MN D ul ut h Ste am Co rp. 227 32020. •; fjp Ohio Edi so n Company 2C3 50*

'T hes e co m pa nies were c lo s e ly comp are d to th e D i s t r i c t H ea ti ng Sy ste m.

6 - 2 9 - 7 6
Page 23, l in e 15 * WEST AND CE NT RA L^HE AR ING PL AN TS ATTACHMENTS

Comparison o f IDKA & DUS S ta tis tic s

(IDHA S ta tis tic s are fo r Calendar 1974)

Co. '

No. C ity

21. Vancou ver, BC, Canada22. Eugene, OR

23. Winnipe g, MB, Canada

24. Spokane, WA

25. To ledo , OH26. Birm ingham , AL

27. Youngstown, OH2c. St. Paul , MM

29. H a rt fo rd , CT30. Ro ch ester, MM

31 . Houston , TX

32. W ilk es-B arre, PA33. Concord, NH

34. Piq ua, OH

35. St. Joseph, MO

36. S p rin g fi e ld , OH

37. S o u th fi e ld , MI

38. N a sh ville , TN

39. Rice Lake, WI

40. San Anto nio , TX

Company Mare

Cen tra l Heat D is tr ib u ti o n Ltd . 

Eugene Water & E le c tr ic Board 

Winnipeg Hydro CSH D iv is io n Washington Water Power Company 

Toledo Edison Company 

Alabama Power Company 

Ohio Edison Company 

No rth ern States Power Company H artfo rd Steam Se rvice Company 

Rochester Public U t ilit ie s Houston Na tural Gas Coro. 

W ilk es- Barre Steam Heat Co. 

Concord Steam Corp.Mun icipal Power System 

S t. Joseph Lig ht & Power Co. Ohio Edison Company 

Dayton Hudson Pro pertie s 

N ashvill e Thermal Tra nsfe r Corp Rice Lake Steam Corp.

C ity Water Board

ActualMax-imum

Ho urly

Send-Out

M lb

MaximuHo urly

Send-OutCac ac itvM 1 b

r . - - _

b •'' ■"

260 4"

141 530 . 24.;225 330 57.7

280 437 5' .2

190 305 52.2

203 475 £ Z . '

163 250 72. '

240 55.

1 T.-3 • r

SO

150 375 40 . ‘

153 34] 45.0

65 112 55.2

59 J 7773

80 150 ou . ;

79 253 22.5

42 110 33.2

65 213 29.3

- - - 23.1 30 23.0

* >

Keep Freedom in Four Future With U S. Savings Bonds

• t

r •

V

6 -2 9 -7 6

>

Av

I
TABLE IV-4

Comparison of IDHA S DHS S ta tis tic s

(IDHA S ta tis tic s ar e fo r Calen dar 1974)

Co.

No. City ' Company Name

Ac tual

Maximum

Hourly

Send-Out

M lb

Maximum

HourlySend-OutCap ac ity

M lb

% of Capab i li t y used

1. New York, NY Con so lida te d Edison Co. of NY* 12,740 15,130 84 .2 '

2 P h il ad elp h ia , PA Phil adelp hia E le c tr ic Co. 2,482 3,8 57 64.4

-7? D e tr o it , MI D etr o it Ediso n Co. 1,72 8 2,97 1 ST. 2

4. Bo sto n, MA Boston Ed iso n Co. 1 1,850 2,0 05 92 .35. In d ia n ap o li s, IN In dia napolis Power 5 Light Co.* 1,29 2 1,73 5 74.5

6. Roc he ster , NY Roc he ster Gas 6 Ele c. Corp.* 1,11 8 1,87 5 59.6

-5 7 Milwaukee, WI Wisconsin E le c tr ic Power Co. 915 1,6 40 55

8. Bal tim or e, MD Baltim ore Gas 5 E le c tr ic Co.* 678 990 68 .5

9. Cle ve la nd , OH Cl ev elan d E le c. Il lu m in ati ng Co. 896 1,320 67 .9

10. Dayton, OH Dayton Power 6 Light Co. 508 982 5-1.7

11. Denver, CO Pu bl ic Se rv. Co. of Colorado 440 580 75 .9

12. P it ts b u rg , PA Allen gheny County Steam Htg. Co. 668 1,041 64 .2

13. S e a tt le , WA S e a tt le Steam Corp. 598 925 64 .6

14. To ro nto, ON, Canada To ron to H ydro -E le ct ri c System 434 560 77.515. H ar risb urg , PA Pe nn sy lv an ia Power 5 Light Co. 376 500 ’ 75.2

16. San Fra nci sc o, CA P acif ic Gas 5 E le c tr ic Co. 330 375 88 .0

17. La ns ing, MI Board of Water 5 Li gh t 223 430 51 .9

18. Grand Rap ids, MI Consumers Power Co. 234 380 61.6

19. Duluth, MN Duluth Steam Corp. 227 320 70.9

20. Akron, OH Ohio Edison Company 205 307 66.8

*These com panies were c lo sely compared to the D is tric t He ating System
Comparison o f IDHA & DHS S ta tis tic s

(IDHA S ta tis tic s are fo r Calendar 1974)

Co.

No. C ity

Vancou ver, BC, Canada

Company Name

Ac tual

Maximum

Ho urly

Send-Out

M lb

Maximum

Ho urly

Send-OutCa pa city

M lb

% o f Capab il i t 

used

21. Ce ntral Heat D is tr ib u ti o n Ltd . 260 535 48.622. Eugene, OR Eugene Water & E le c tr ic Board 141 580 24.3

23. Win nipeg, MB, Canada Winnipeg Hydro CSH D iv is io n 225 390 57.7

24. Spokane, WA Washington Water Power Company 280 457 61 .3

25. To ledo , OH Toledo Edison Company 190 305 62.326. Birm ingham , AL Alabama Power Company 203 476 42.6

27. Youngstown, OH Ohio Edison Company 183 260 70.428. St. Paul , MN No rthern States Power Company 240 350 68.6

29. H a rt fo rd , CT H artfo rd Steam Se rvice Company 155 339 45.7

30. Ro ch ester, MN Rochester Public U t ilit ie s 90 150 60.0

31 . Houston, TX Houston Na tural Gas CorD. 150 375 40.0

32. W ilk es-B arre, PA W ilk es -B ar re Steam Heat Co. 158 341 46.333. Concord , NH Concord Steam Corp. 65 112 58.0

34. Piq ua, OH Mun icipal Power System 59 80 - 73.8

35. St. Joseph, MO St. Joseph Lig ht & Power Co. 80 150 53.3

36. S p rin g fi e ld , OH Ohio Edison Company 79 258 30.6

37. S o u th fie ld , MI Dayton Hudson Pro pertie s 42 110 38.2

38. N a sh ville , TN N ashvill e Thermal Tra nsf er Corp. 65 218 29.8

39. Rice Lake, WI Rice Lake Steam Corp. - - 40. San Anto nio , TX C it y Water Board 23.1 80 28.0
34

Mr. Wendehack. The avera ge sta ndby capacit y th at these pla nts 

pro vid e in orde r to insu re co ntinuity of work is 30 perce nt. Th is is 

con sistent with w hat we are pr ov idi ng .

If we were left with only the seven boilers and 1,700,000 pou nds of 

total capacit y, pre dic ate d on a n et o f 30 percen t standby, we have only 

now a ne t r eliabl e of 1,100,000 pounds.

If we relat e th at to the loading requirements at thes e plants, our 

peak load occ urred in 1970, wh ich was 1,295,000 poun ds. Tha t occu rred 

at an 8-de gree tem perature , avera ge tem perat ure outsid e, an d a 4- 

degree low te mpe rature fo r the d ay.

Two th ings have occurre d since th at time fram e. No. 1, a t th at time 

we h ad ap prox im ately 36,500,000 sq uare feet o f build ing s on line th at 

we had to provide steam for . Sin ce th at time we have adde d over 4 

million square fee t of building s— fo r a total now of 40,500,000 squa re 

feet. In ad ditio n, by 1980 we expec t to have an othe r 1,800,000 square 

feet on lin e.

Th e second th in g is th at du ring the past 6 years, we have had a 

co nti nuing wa rm ing tre nd in we ath er and , as a res ult, we have not 

reached those tem perat ure conditio ns th at we did in 1970.

However, we have done quite a bit of checkin g with the weath er 

bureau. We know the we ath er tem pe ratures run throug h ap prox imately a 15-year cycle. We have been in an upwa rd trend o f the cycle. 

By 1978, b ased on a ch art they provide d, we will be g oin g b ack into a 

cooling tren d again as part of th at 15-year cycle, and we very conceivably and very likely will reach tem perat ures a gain th at we h ad in 

1970, and pos sibly much co lder.

But ap plyi ng those tem perat ures th at we had to con tend with in 

1970 aga inst the new load, as f ar as the bu ild ing load— and t he ca lcu lation s pro ced ure s are the same as the indu str y uses—we know th at we 

hav e at lea st 1,430,000 pou nds of req uir em ent ri ght now. Th is, as I 

mentio ned , will increase with more workload —build ing —co min g on 

line.

Th is prosp ectus proposes th at we have a total cap acity, ag ain before we conside r standby capacity, of 2,140,000 pounds. App ly in g the 

30 percen t sta nd by for eme rgen cy, which is con sistent with the indu str y pra ctices, we will have a rel iab le service capability on an ongoing basis of 1,498,000 pound s.

Th is is v ery consistent with the load ing r equ ireme nts th at we an tic ipat e up thr ou gh 1985.

Se nator Morgan. L et me go back. You did say th at the west plan t 

and c entra l pl an t operate togeth er?

Mr. Wend eha ck. That is ri gh t, sir.

Se na tor M organ. You s ay in yo ur pro spe ctu s th at the c en tra l plan t 

serves 112 bu ild ings at an annual cost of $3,162,000. An d you say the 

west pl an t s erving the same build ings does it fo r $3,318,000. O f course, 

th at is only $118,000 or so. But why the difference ?

Mr. Wendeha ck. The re are 112 b uildings th at are served betw een 

the two pla nts. The do lla r cost is ad ditiv e for a total of $6 million , 

wh ate ver t he total is.

Se nator Morgan. T his is n ot co mbined for both ?

Mr. Wend ehack. No. W e sp lit the cost between the two building s.

Se nator Morgan. I see.
35

Mr. Wendehack. Th e to tal is $6 millio n som eth ing , whate ver the 

to ta l is there.

Se na tor Morgan. H as OM B app rov ed this prospectu s ?

Mr. Wendehack. The cen tra l p lant, u nder the requir em ent of O MB, 

was sub mitted to OMB because it was ove r $10 mi llio n. It was ap ­

proved b y OMB befo re we s ubmi tte d it to you. The west plan t, whi ch was un de r $10 millio n, did no t have to be su bm itted to OMB . However, we did sub mit the m a copy, as is our practic e with any pro spe ctu s we sub mit to the Congress un de r $10 

millio n.

Se na tor Morgan. You ta lk about steam in thes e 112 bui ldings. Do 

you use hot wa ter anywhere?

Mr. Wendehack. Th e bu ild ings are sup plied with stea m only to 

building s. How ever, the bu ild ings ’ hea t exchan gers are used to heat 

yo ur necessary ho t wa ter for the buildin gs.

Se na tor Morgan. W ha t abo ut chilled wat er?

Mr. Wendehack. We on ly s up ply thre e buildin gs with chi lle d water. 

Tha t is Agriculture South , the Agr iculture A dm inist ratio n Bu ild ing , 

and the Fo rre stal Bu ilding .

Se na tor Morgan. W ha t about the ot he r b uildin gs ? Do they gene rate 

th ei r own ?

Mr. Wendehack. In othe r bu ild ings we have chillers an d ai r conditio ning systems withi n the building s.

Se na tor Morgan. Are all Go vernm ent build ing s in the Distri ct 

heated by steam?

Mr. W end ehack. All GS A build ings ?

Se na tor Morgan. Yes.

Mr. W endehack. I don ’t believe a ll of them are.

Mr. Galuardi. In th e Di str ict , yes.

Mr. Wendehack. OK. Yes, s ir.

Se na tor Morgan. I s the GS A reimb urs ed for these serv ices by the 

various d ep artm en ts, or is it by direct ap prop ria tio n?

Mr. Wend eha ck. As fa r as the build ing s GS A opera tes, they are 

serviced und er the SLU G charges and we finance those costs. T he bu ild ­ ings th at are oth er than GS A op era ted , such as the Sm ith sonia n, or nongovern me nt building s such as the Am eric an Red Cross, in these building s t he y reim burse us on a q ua rte rly bi llin g basis ba sed on meter 

readings.

Se na tor Morgan. Le t’s go back to yo ur standby boilers. Do y ou have 

any now?

Mr. Wendeha ck. Do we have any sta nd by boilers now?

Se na tor Morgan. Yes.

Mr. Wend eha ck. Our capacit y now is pre dic ated on the fo ur 42- 

yea r-old boilers. Th at pro vid es us th e sta nd by cap acity. Ho we ver , as I men tioned, th e capability of those boilers is fac t ru nn in g out. We just cannot rely on them any fu rthe r, con sidering th at we have the 

res ponsibility of 112 building s in the District of Colu mbia .

Se na tor Morgan. Are the re any alternatives other than in stallin g 

new ones, in case these boilers gave out ?

Mr. W end eha ck. We ha ve mad e a sig nificant numb er of studies. W e 

have had a pr iv at e firm investigate. We hav e had a gr ea t deal of in ­

house inv estig ati on. We have no viable a lte rna tiv es.
36

We inv est iga ted the alternative of going back on ou r energ y conser vation efforts. Un der ou r energ y conserv atio n efforts, we tu rn off 

the he at in the ev ening an d on th e weekend in order to conserve en ergy.

We inv est iga ted th e possib ility of going back to the he ating of these 

build ings aroun d the clock in or de r to reduce t he peak loa d somewhat. 

However, this altern ati ve is very nonviable as fa r as op erating costs. 

I t would mean th at as a minim um it would cost us an ad ditio na l $4 

millio n a y ear in fuel costs and ele ctrical costs in the b uildings because 

of ha ving to run the ai r ha nd lers and so fo rth in or de r to keep the 

bu ild ing tem perat ure up.

Th is does no t consider the ad ditio na l manpo wer we wou ld have to 

pu t on ag ain to man this activ ity . I feel we have inv est iga ted every 

possible altern ati ve, and thes e are ou r altern atives .

Se na tor Morgan. I n y ou r prosp ectus yo u ind ica te the only alternatives as being replace ment of the bu ild ing or leasing space. Wa s any 

conside ration give n sim ply to insta lli ng precipita tors or other equip ­

ment necessa ry to comply wi th the D.C. req uirements?

Mr. Wendehack. A s fa r as th e com parison in the prospe ctu s, th at 

is a no rm al review th at we g o throug h as fa r as co mpa rin g the costs 

of constru ction versus leasin g vers us repa iri ng the in sta lla tio n th at we 

are presen tly occup ying.

We use the “ present value an aly sis ” to determ ine wh eth er it is more 

economical to go to a leased bu ild ing or co nstruct a new building.

Th ere are no leased bu ild ings avai lab le th at could pos sibly meet our 

needs in this pa rti cu lar case. New con struction wou uld be astron om ical. Th ere fore, under ou r prese nt value analy zatio n basis it was concluded we must tak e the repa irs to this building.

Se na tor Morgan. D id I un de rstand you to say ea rli er that the re are 

two new oil boile rs on line.

Mr. Wendehack. Th ere is one on line now. The second one is u nder 

final co ntr act completion. Th ere are a few problems with it. We have 

not ye t accepted the boiler. But upon acceptance of th at boiler there 

will be two new oil-fired boilers. The total of each is 400,000 pounds, 

fo r a total of 800,000 pound s. Th is is a t the c en tra l plant.

Se na tor Morgan. I f vo ur two new mult ifu el boilers are installed, 

wh at kind o f coal ha nd lin g equip me nt will be requir ed ? Will they use 

the same eq uipment or w ill you have to have new equ ipm ent?

Mr. Wendehack. No, sir . Because of the fact we will be relyin g 

pr im ar ily on coal to meet ou r nor mal requirements an d using the oil 

to hit the peaks, we will have to have ad ditio na l coal ha nd lin g 

capacity. Plu s, as I me ntioned, we are going to be pulve riz ing lowgr ad e coal and blowing it into the boilers.

Se na tor Morgan. Will all fo ur boilers of the centr al plan t th at 

ha ve n’t been changed be bu rn in g pulverize d coal too, o r ju st th e two?

Mr. W endehack. Ju st th e two.

Se na tor Morgan. T he ot he r two will be sta nd by ?

Mr. W endehack. The y w ill be pu t in mothb alls.

Se na tor Morgan. W ill they be sta ndby ?

Mr. M endeback. A s I me ntioned, in an emergency where we had to 

use them , we would have to fire them up. But then we w ould be in noncom pliance with th e a ir pollutio n s tan dards.
37

Senator Morgan. Then you would have to have your present coal 

handling equipment for tho^c, wouldn’t you?

Mr. Wendehack. Yes, sir. They are stoker-fired boilers. They are 

not the same type of boilers as the multifuels.

Senator Morgan. How many p recipitators are proposed for the new 

central heating plant?

Mr. Wendehack. Two for the new boilers.

Senator Morgan. One for each boiler ?

Mr. Wendehack. One for each boiler.

Senator Morgan. Why are you proposing three for the west plant?

Mr. Wendehack. At the west plant, the two boilers—numbers three 

and five boilers, I believe it is—which were converted under the previous prospectus, already have precipitators on them. The other three which are coal-fired do not have sufficient precipitators to take 

care of the pollution in the air. Senator Morgan. What about your ash collector silos?

Mr. Wendehack. The silos?

Senator Morgan. Yes.

Mr. Wendehack. Three at each plant.

Senator Morgan. Are there any structural or architectural changes 

you are going to have to make to accommodate these new boilers?

Mr. Wendehack. We do not believe so. We feel we will be able to 

accommodate it in the existing building structures.

Senator Morgan. If the new ash disposal systems were installed 

tha t you are asking for, what would happen to the residue?

Mr. Wendehack. It will be taken away to an EP A approved 

landfill.

Senator Morgan. Tha t would take a tremendous landfill, wouldn’t 

it ? By truc k ?

Mr. Wendehack. By truck.

There is also, Mr. W ard mentions here, the possibility that it could go into construction of cinder blocks also. We can utilize it that way.

Senator Morgan. Is there any approved dumping ground identified 

in your environmental impact statetment?

Mr. Wendeiiack. No, sir; there is not. But it will be a requirement 

of the contract that it lie an EPA-approved dumping ground.

Senator Morgan. H ow f ar away do you estimate you would have to 

go?

Mr. Wendeiiack. I am not really sure. I don't know if the region 

can answer that question or not.

Mr. Galuardi. I think most dumping sites are in Prince Georges 

County. I t is probably a m atter of 6 or 8 miles.

Senator Morgan. What kind of oil handling and storage facilities 

exist now at both of these locations ?

Mr. Wendeiiack. As far as capacity ?

Senator Morgan. Yes.

Mr. Wendeiiack. I believe T have those figures. At the central plant, 

there are 7.500 tons of coal storage capacity and four oil tanks which 

hold 1.130,000 gallons. At the west heating plant, there are 8,000 tons of capacity for coal 

and 796,000 gallons of oil.
38

Senator Morgan. If this project is approved, how many boilers will 

be left tha t are not multifuel, except the two standby at the central 

plant ?

Mr. Wendehack. That are not multifuel?

Senator Morgan. Yes.

Mr. Wendehack. There will be two a t the central plan t th at will be 

the oils and three at the west plant which will be the coals.

Senator Morgan. Will they oe standby, too ?

Mr. Wendehack. No. All of those boilers will be used. The only 

two that will be put into mothballs will be the two 42-year-old remaining boilers.

Senator Morgan. The three at the west plant now use pulverized 

coal?

Mr. Wendehack. No, sir. They use stoker coal.

Senator Morgan. Will they on the project ?

Mr. Wendehack. No, sir.

Senator Morgan. Will they still not be polluting the air?

Mr. Wendehack. They will not be polluting the air. We will be 

putting in precipitators and bottom ash capacity.

Senator Morgan. The main reason you are replacing the two here 

is because of their age ?

Mr. Wendehack. At the central plant, yes, sir.

Senator Morgan. What is the rated output capacity of these new 

boilers ? Did you tell us tha t ?

Mr. Wendehack. 220,000 pounds each, for a total of 440,000 

pounds.

Senator Morgan. Did you give us an average daily load demand on 

the combined heating plants from October to March ?

Mr. Wendehack. We have gone through calculations on that. That 

was one of the questions that GAO had raised.

On a rough average, we calculated that an average load would be 

around 850,000 pounds. I want to stress a couple of points on that.

Average load, as far as a heating plant or a utility plant, has absolutely no meaning. I might make an analogy of comparing it to a 

person tha t can't swim who asks what the depth of a pool is, and 

somebody tells him the average depth is four feet. If he steps off into 

the 4-foot end, he is fine. If he steps off into the eight-foot end, he is 

out of luck.

We may have on a particu lar day during the w inter a 75-degree 

day where we don’t have to provide any steam. But then on another 

day in the same month we may drop down to 4 degrees, and we will 

then have to hit a peak of some 1,500,000 pounds.

Senator Morgan. Is this Senate office building on that line?

Mr. Wendehack. No. Your building is on a separate heating plant, 

the Capitol heating plant.

Senator Morgan. I was going to ask you if you could save some 

heating capacity by cutting off the heat now. We had hot air coming 

out one day this week.

Mr. Wendehack. No, sir. We have gone through an extensive 

energy conservation program in our buildings and cut back the heat 

to 65 to 68 degrees.
30

Senator Morgan. One more question, before I go into three or four 

others that have been proposed by some of the members. Does the authorization requested here include any refrigeration or 

chiller-line alterations ?

Mr. Wendehack. No, sir.

Senator Morgan. Upon completion of this project, can you meet 

performance standards under the Clean Air Act ?

Mr. Wendeiiack. Yes, sir.

Senator Morgan. K arl, you were talking about under the new law.

Mr. Braithwaite. No; the existing law.

Mr. Wendeiiack. Yes, sir.

Senator Morgan. Have these changes been coordinated with the District and EPA? We talked about EPA . Have you coordinated 

these proposals with the District ?

Mr. Wendeiiack. I am sure we have.

Mr. Zoellner. The environmental impact statement did go to the District of Columbia before being published, if that is what you are 

referring to.

Senator Morgan. Did they comment on it ?

Mr. Wendeiiack. I believe they are in the process of commenting 

now.

Mr. Galuardi. The District has commented. They have basically 

restated their position that we are in violation.

Senator Morgan. Have they expressed any position with regard to 

whether these proposals will clear up the problem ?

Mr. Galuardi. I don’t think they have. We have the problem of seeing what their regulations are and determ ining whether or not technically what we are installing will do it. Our experts, both in­ house and consultants we have hired who are experts in the field, 

have stated we will comply.

Mr Wendeiiack. I don’t think the District has any way of determining whether or not what we are doing will comply. But we 

know it will comply.

Senator Morgan. John, will you make sure tha t the District’s comments go in the record ?

Mr. Purinton. Yes.

[The material requested follows:]

Government of the District of Columbia,

E xe cu tive Offic e, 

Washington, D.C., May 28,1976.

Mr. J ames F. Steele, Jr.,

Acting Assistant Commissioner, Office of Operating Programs, Public Building Service, General Services Administratio n. (Region 3), Washington, D.C. (Attention of Mr. William W. Sayers (3-MC TE)).

Dear Mr. Steele : Enclosed are comments of the Exec utive Branch of the District of Columbia Government on the draft Environmental Impact Stateme nt (DEIS) for the Multi-Fuel Boiler, Central Heatin g and Refrigeration Plant. These comments have been prepared and coordinated by the Municipal Planning Office in collaboration with other District agencies, including: The Corpora­ tion Counsel Departm ent of Environm ental Services, and the Department of 

Tran sportation. I wish to express the Dist ric t’s ap preciation for affording us the opportunity to comment on the DEIS. We look forw ard to working with the General Serv­ ices Adm inistration to upgrade the operation of the Central Pla nt to bring it
40

into compliance with District and Fed era l air and water pollution control laws 

and regulations.

Sincerely,

Ben W. Gilbert, Director. Enclosure.

Comments on the Draft Environmental Impact Statement No. EDC-76001

on Multifuel Boilers : Central Heating and Refrigeration Plant, Washington, D.C.

The District of Columbia Government Executive Branch has reviewed the

Dr aft Environmental Impact Stateme nt, Number EDC 76001, Multifuel Boilers: 

Central Heatin g and Refrigeration Pla nt, Washington, D.C. Districts agencies 

partici pating in this review includ e: the Corporation Counsel, Departm ent of 

Environmental Services, Department of Housing and Urban Development, Departme nt of Transpo rtation, Office of Budget and Management Systems, and 

Municipal Plan ning Office. The following comments have been coordinated and 

consolidated by the Municipal Planning Office. They discuss the Dis tric t's general, legal and technical concerns over the proposal and its dr aft environmental 

impact statement (EIS3).

general comments

The dr af t EIS describes and eva luates the proposed modifications to the facilities at the G.S.A. Central Heating and Refrigeration Pla nt (“C entral Pla nt” ). 

The modifications are designed to bring the Central Pla nt into compliance with 

both District and Federal air and wa ter pollution control laws and regulations 

The Central Pla nt is currently in violation of applicable District law and will 

remain so, according to the EIS, un til the modifications are complete.

LEGAL IMPLICATIONS: DISTRICT OF COLUMBIA V. SAMPSON

The District of Columbia has brought suit aga inst officials of the General 

Services Administration to enforce compliance of the operation of the Central 

Pla nt and of the West Heating Plan t with the District’s air and wa ter pollution 

laws, which these officials have a duty to obey under Section 118 of the Clean 

Air Act Amendments of 1970 (42 U.S.C. 1857f), Section 313 of Fed eral Water 

Pollution Control Act of 1972 (33 U.S.C. 1323 and ) Executive Order 11752. This 

litiga tion, District of Columbia v. Sampson, Civil Act No. 75—1017, is pending in 

the United States District Court for the District of Columbia. G.S.A. officials 

have acknowledged that they are bound by the District laws in the operation of 

these two facilities. They have also admitted to the Court th at they are in 

violation of District law with regard to visible and partic ulate emissions into 

the air and ash discharges into the Potomac River.

Because of the very lengthy period required to complete the modification and 

to bring the Central Plant into compliance with Dis trict law, Judge George L. 

Ha rt of the United States District Court has encouraged the General Services 

Adm inistration to pursue tem porary of interim measures which can also be 

taken to brin g the operation into compliance, or closer to compliance. Such measures would decrease as much as possible the amount of emissions and the time 

period in which the operation of the Central and West Pla nts remain in violation of local law.

INTERIM MEASURES

It is the legal position of the District of Columbia that it is mandatory that 

the present operation s of the Cen tral Pla nt be modified so as to bring its operations (and those of the West Plant) into compliance or closer to compliance immediately, and tha t this can be accomplished through interim measures. It is 

anticip ated by GSA th at the proposed modifications for the Cen tral Pla nt in the 

draft EIS can be completed in a period of 141 weeks from the time procurement 

procedures are initiated.

Unfortunate ly, the draft EIS does not indic ate any program of interim measures which can bring the Central Pl an t into compliance or closer to compliance.

The only interim measure proposed in the draft EIS is the installatio n of a 

temporary ash handling system for two of the four coal-fired boilers at the 

Central Plant. These two boilers will not be replaced. Once the other two coalfired boilers at the Central Pla nt are replaced, the dr aft EIS sta tes that use of
41

the two coal-fired boilers utilizin g the temporary ash handlin g system will be 

suspended. In the lawsuit, GSA officials have talk ed in term s of “abandonm ent” of these boilers. However, the dr af t EIS does not indicate th at these boilers will be removed or that they or the ir control equipm ent will be modified. The possibility remains, therefore, th at these two coal-fired boilers may be used again at some time in the future w ithout having been equipped with control equipment 

to bring the ir emissions within allowable levels. The District has advised the Court th at furth er operation of these boilers in violation of the air pollution 

laws is not acceptable. It is our opinion th at the re are several interim measures th at can be im­ mediately taken to bring the operatio n of the Centra l Pla nt (and of the West Plant) into compliance or closer to compliance with District law. These interim 

measures should includ e:

(1) Converting the boilers to a complying grade of oil. (2) Operating complying boilers to the maximum extent possible. Ins tall necessary equipment to enable Boilers No. 3 and 4 to operate at maximum load. (3) Before non-complying boilers are used, steam supplied should be reduced 

proportionately to each building supplied by th e plant. (4) Emissions from each boiler should be continuously monitored by ins talling suitable monitoring equipm ent.

(5) Immediate measures shou ld be ins titu ted to prev ent the discharge of acidic waters form the coal storag e areas/coa l tra ps into the storm drains and 

sewers from the coal storage areas/c oal traps into the storm drains and sewers 

of the District of Columbia, into the Potomac River or into Rock Creek. (6) Immediate measures should be institu ted to prevent the discharge of ashes into the storm dra ins and sewers of the District of Columbia into the 

Potomac River, or into Rock Creek. (7) GSA should burn only good q uality coal in its boilers. Coal samples should 

be analyzed, prio r to being used, to ensure th at the coal meets the specifications. (8) The damaged steam transmission conduits from the West Heating Pla nt 

in the vicinity of the Ellipse in the District of Columbia should be immediately 

repa ired or replaced.

TECH NICAL COMMENTS

The following comments apply to various technical aspects of the draft E IS : (1) The number of multi-fuel fired boilers to be installed is indicated in the 

dr aft EIS as two on page 3 and as thre e on i>age 15 Table 1. The latte r figure is used in the determination of futur e air quality from mathematical modeling. (2) The formula given to calculate the District ’s allowable par ticu late emis­ sion from fuel burning equipment on Page 21, Table VII is incorrect. The correct formula is 0.17455 h

-023822

.

(3) In the event of an oil spill during filling of tank s, provisions should be 

made to prevent the oil entering the storm sewer.

(4) The draft EIS does not address the methods of handling dust caused 

during coal handling. This should be corrected in the final EIS. (5) The latest control technology for controlling particulat e emissions from coal-fired boilers is the use of fabric filters. Since the subject document does not consider any altern ative to a precipitator, we feel th at fabric filters and 

other control equipment should be evaluated. (6) The proposed macerated pap er storage and handling building and at least 

one existing building are partly sited in public space. The D.C. Surveyor has no record of a request for a street closing action being filed with his office. The General Services Adm inistration should advise the District of its inte nt in this 

matter.

(7) The G.S.A. should include a traffic circulation plan, maintenance of traffic plan (during construction) and related information in the EIS. We consider 

this to be pertinent to the dr af t EIS, and that it should be pa rt of the dr aft stateme nt. This information is essential if any adverse transp ortation impacts 

are to be identified.
42

Government of the District of Columbia,

Executive Office, 

Washington, D.C., June 8, 1976.

Mr. J ames F. Steele, Jr.,

Acting Assistant Commissioner, Office of Operating Programs, Public Building

Service, General Services Admin istratio n (Region 8), Washington, D.C.

(Attention of Mr. William W. Sayers (3-MC TE).)

Dear Mr. Steele : Enclosed are additional comments of the Executive Branch

of the District of Columbia Government on the draft Environmental Impact 

Statement (DEIS) for the Multi-Fuel Boiler, Central Heating and Refrigeration Plant. These comments have been coordinated by the Municipal Plan ning 

Office in collaboration with other District agencies partici pating in the review 

of the DEIS, including: the Corporation Counsel, Department of Environm ental 

Services, Departm ent of Tran sportation, and Department of Housing and Community Development. For your ready reference, a copy of our previous comments is also enclosed.

I wish to express again the District ’s appreciation for affording us the opportunity to comment on the DEIS. We look forward to working with the General Services Adm inistration to upgrade the operation of the Central Plan t to 

bring it into compliance with District and Federal air and water pollution control laws and regulations.

Sincerely,

Ben W. Gilbert, Director.

Enclosure.

Comments on the Draft Environmental I mpact Statement No. EDC-76001, 

Multifuel Boilers: Central Heating and Refrigeration Plant, Washington, D.C.

Additional Comments

The following comments supplement the District comments furnish ed to the

General Services Administration on May 28, 1976. They have been coordinated 

with the previous comments and the agencies partici pating in the review7

 of the 

subject draft environmental impact statem ent (D EIS).

DIST RICT OF COLUMBIA URBAN REN EWAL LAND

The DEIS indicates, on page 6, that a macerated paper handling facility is 

no longer included in the project. Howrever, Site Plan No. 1 of the DEIS shows 

a structure for pap er handling and what app ear s to be a turn -around for truc k 

service to this facility. The structure app ear s to be located with in the rightof-way of D Street, S.W., and the are a for the turn-aro und appears to require 

land extending south of the D Street right-of-way.

This land south of D Street and land adjacent to it have been acquired foi 

redevelopment by the D.C. Redevelopment Lan d Agency pursua nt to the Urban 

Renewal Plan for the Southwest Urban Renewal Area, Project C. The Plan does 

not provide for the turn -around shown for the paper handling facility. Exp ansion of the D Street right-of-way to provide for the turn-around w’ouid requ ire 

amendment of the Plan.

The Final EIS (F EI S) should elim inate the app arent conflict of the present 

description in the tex t with the site plan for it in the DEIS. The FE IS should 

also clarify whether or not the project will require any of the urba n renew’al 

land along D Stree t.

Senator Morgan. If coal is the prime fuel, how can reduction of 

emissions be achieved when it is essentially a higher pollutant?

Mr. Wf.ndeiiack. The precipitators and the bottom ash handling 

will take care of the pollutants.

Senator Morgan. Will this take care of it, and meet the standards?

Mr. Wendehack. And meet the standards.

Senator Morgan. Is there any other way you could achieve a higher 

degree of clean air?

Mr. Galuardi. You can burn all oil. But the b urning of all oil, we 

just predict for this last fiscal year, if we did that, burn number two
43

fuel oil, which is the higher priced fuel, it would cost us in operating costs $1.2 million a year more th an using coal.

Mr. Wendehack. We could not meet the capacity unless we had all 

the boilers converted to oil, and we could still not meet our peak demand. We could handle the average situation. But when you get into 

the higher requirements—and during the past year, for example, I 

believe we hit over a million pounds of steam requirement at least 

one-third of the time. 20 to 25 percent of the time—that without burning coal, we just will not be able to meet the load requirements.

Senator Morgan. You say it would cost $1.2 million more. What 

is the total cost of fuel now, for the 112 buildings?

Mr. Ward. The present budget, Senator, which again is predicated 

upon a cold winter, the budget I can answer for the District heating 

system is $18 million, and 60 percent of t hat would be fuel.

Senator Morgan. Sixty percent?

Mr. Ward. Sixty percent of the $18 million.

Mr. Galuardi. $10.8 million.

Senator Morgan. What precautions have been taken to meet sulfur 

dioxide standards, for the change in fuel?

Mr. Wendehack. We are keeping the quality of oil and coal we buy 

controlled so that we stay within the sulfur requirements.

Senator Morgan. What kind of contracts do you have, to insure 

the quality of coal ?

Mr. Galuardi. The Defense Supply Agency is the main agency 

which buys all fuels. GSA buys under their contract. We have been 

buying basically from the same line fo r many years, Island Creek Coal 

Co. I am not sure where they are located. I think it is West Virginia.

The sulfur content both of the oil and coal is very critical. The 

States have established different kinds of standards with regard to 

the sulfur dioxide emissions. Virginia and Maryland have decided 

that you measure the sulfur dioxide emissions at the stack. The Distric t of Columbia has stated they want to measure the sulfur at the 

fuel th at is being imported.

Therefore, they have established a standard, and we have to buy 

the fuel which you test the fuel itself to measure the sulfur in it. 

Therefore, we are buying the fuel from Island Creek Coal Co. It is 

the lowest sulfur coal we can get. I think it is .9 percent.

Mr. Wendehack. The only other alternative we would have in the 

future if coal or oil was not available would be, like any other plants 

that have to meet the requirements, to go to scrubbers.

Mr. Galuardi. There is a problem with sulfur in oil also, which is 

critical. Basically what you t ry to do here is make sure the heating 

system furnishing the Federal agencies in the District of Columbia, 

do not have to rely upon imported oil.

At the present time, the oil which is necessary that has the lowest 

sulfur content only comes from overseas. There are no internal, within 

the United States, plants which produce the low sulfur oil, at least on 

the eastern seaboard. Most of the oil has to come from overseas. Most 

of it is coming from Venezuela. It is all imported oil. You have to 

get the low sulfur content oil.

The other problem we have is the distribution system is not set up 

to give you that low sulfur oil. They have to have a large enough customer to be able to furnish you with tha t low sulfur oil.
44

i

1:P

e n o ^ made the total contractual arrangements with those 

distribution people to get the low sulfur oil. Basically I go back that 

these two boilers are needed so that the U.S. Government does not become dependent on overseas oil to keep the Federal agencies in warmth 

in the District of Columbia.

Senator Morgan. From the prospectus and what you sav, I think 

you have established a reasonable need for this work. But I have no 

other real way of knowing, except from what you say.

The thing that worries me is that we don't have any system of 

checks on the request. I have no way of knowing whether your estimate is high or low, except what I read in here about cost overruns.

I frankly feel we ought to have some better determination of cost, 

and how it is going to be handled, before we go ahead with approval. 

But I am not completely prepared to proceed this morning.

If we approve the project, and you start it, are we going to be confronted with another cost overrun, like the Visitors Center? These are 

the things I wish I knew.

Mr. Galuardi. We would know the answer to that very shortly because we would expect that we would put this contract on the market 

and have it ready for awarding in about a 3-month period. At that 

time we would know for sure whether or not we have the right authorization. V e would not be able to proceed with the award of the 

contract if it does exceed the authorization.

Senator Morgan. Why did they award the contract for the Visitors 

Center, if it was not within the limits of th eir authorization?

Mr. Galuardi. We don’t handle the Visitors Center. The National 

Park Service does.

Senator Morgan. I thought you did this for all Federal buildings 

in Washington.

Mr. Wendehack. Not special purpose type buildings; only office 

type buildings.

Senator Morgan. Aren’t they bound by the same laws that GSA is, 

with regard to letting contracts?

Mr. Galuardi. They are, yes.

Senator Morgan. Would GSA let a contract like that, for a Federal 

building in Washington?

Mr. Galuardi. I am not familiar with their problems. I think it is 

a contract claim that is causing the overrun on the National Visitors 

Center.

Senator Morgan. What do you mean, a contract claim? Changes?

Mr. Galuardi. It is a change of some sort; either a design error or 

added scope of work. I am not familiar with it.

Mr. Wendehack. I think we have a very good track record in avoiding cost overruns. I think our estimates are usually very sound. Assuming we get appropriations for the money to spend on it and within the 

time frame of the original prospectus budget, then we have had a very 

good record as far as staying within our authorization.

Senator Morgan. If this committee recommends approval, will you 

give me positive assurance th at GSA will not let the contract for this 

work unless it comes within the authorization, unless they come back 

first to this committee ?

Mr. Wendehack. We will give you our 100-percent assurance. That 

is our policy.
45

Se na tor Morgan. I assure you i f I am still on t hi s c ommittee, a nd i f you don’t do that, you will hav e tro uble ge tti ng any more 

autho riz ati ons.

Mr. Wendehack. Th at is ou r policy. Ou r reg ion al offices reco gnize 

that. That is the policy we follow. We do no t proceed wi th a proje ct unless we hav e a prospectus ap prov ed and unless we h ave the limit. We do hav e under the law 10 perce nt au thor ity to escalate a pr ospectus. I th in k you are aw are of that.

Se na tor Morgan. I know th at. But if we app rov e this co ntract, will 

you g ive me the assurance t hat y ou won’t let th e co ntr act, even with a 

10-p ercent escalation?

Mr. Galuardi. We wo uld n’t be allow ed to anyhow because the 10- perce nt esc alation has to occur. Since the au thor ization is abo ut to occu r an d we ar e about to aw ard the c ontract, there is no way we could 

use the 10-p ercent e scalation fa ct or anyhow. We do no t use the 10 percent at all. We are in a be tte r position on this co ntract th an we a re on mo st oth ers because we alre ad y hav e i t d e­ signed. W ith a design you ca n be more specific as to w ha t the cost is. You r cost estimato rs hav e som eth ing to actua lly look at. They can come a lot closer. You have to realize the cost is wh atev er the ma rket says it is going to cost an d no t necessa rily wh at estim ato rs say it is 

going to cost. So we are about to go out an d find out w hat th e cost is when we place it on tn e market. We feel we have a good est imate an d we will get good pric es from contract ors . Ho we ver , the re is a lim ited numb er of con­ tra ctor s who can do this work. Now in the Un ite d St ates i t is t ur ni ng out th at the numb er of peo ple who hav e the ca pa bility of prov idi ng these kin ds of fac ilities are rapidly dec reas ing. We a re somewhere be­ tween a very small boi ler f or sma ll comm ercial op era tio ns an d th e very lar ge ones th at are bu ilt fo r he ati ng in pow er com panies. So we are 

somewhere in between. Th e numb er of people bu ild ing th at kind are ra pi dl y disap peari ng. So there fore we have to presum e we are going to get a very good price 

fro m those people.

Mr. Wendehack. We will give you our word, my word, th at we will 

come back here if there is any problem.

Se na tor Morgan. T hat I appre cia te, because th is o ther system wo rries me. Se nator Buckley has some questions and wou ld like you to sub mit wr itten answers. I also would like to reserve th at righ t, for any o ther 

com mittee members.

Mr. W endehack. All r ight, sir.

Senator Morgan. I f any com mittee mem ber has questions, we will 

get them to you.

[Responses to ad ditio na l questions fo llo w:]

75-6 02 0 - 76 - 4
46

UNIT ED ST AT ES OF AM ER IC A 

GENER AL SER VIC ES A D M IN IS TR A TIO N

W a s h in g t o n , d c 20405

A u g u st 6 , 19 76

Honorable Robert Morgan 

Chairman, Subcommittee 

on Buildings and Grounds 

Committee on Public Works 

United States Senate 

Washington, DC 20510 

Dear Senator Morgan:

We appreciate your continued interest in the Central 

and West Heating Plants Prospectuses. Answers to 

your question submitted by your letter of July 23, 

1976, are attached. This is a complicated project 

that has stimulated a very thorough review by all 

interested parties. We hope in our answers that 

we have been fully responsive.

If there is any way we can be of further assistance 

to your Committee in this matter, we stand ready to 

oblige and will coordinate with your very tight 

sch edule.

Sin cer ely ,

ra ck E ck erd 

I m in i s t r a to r

Enclosure
47

CENTRAL AND WEST HEATING PLANTS D.C. 

ANSWERS TO SENATE QUESTIONS 

Aug us t 2, 1976

1. QUESTION: A pr ospectu s subm itte d on May 1970, s ta te d th e re were s ix c o a l- fir e d b o il e rs a t th e C entral Heatin g P la n t, ap pr oa ch ing 

th e end o f th e ir u se fu l l i f e , and proposed re plac em en t w it h new 

g a s -fi re d u n it s . In s t a lla tio n o f new p r e c ip it a to rs was als o prop os ed . This was ap prov ed June 1971, and $1 0, 79 5, 90 0 auth orized 

fo r th e wor k. What has been done sin ce then ?

ANSWER: C ontr act was awa rde d on J u ly 25 , 1972, to pro vid e fo r 

in s ta ll a tio n o f 3 o i l - f i r e d u n it s and p r e c ip it a to rs . In li n e 

w it h th e P re s id e n t' s message to Congress November 8, 197 3, The 

E ff e c ts o f th e O il Embargo, the convers io n p ro je c t was stop ped on December 12, 1973. T h is sto pp ag e has re s u lt e d in o n ly two o i l- f ir e d 

u n it s and p r e c ip it a to rs be in g in s ta ll e d .

2. QUESTION: A c o n tr a c t was awarded in 1972 fo r re mov ing fo u r o f th e 

s ix o ld b o il e rs and in s t a llin g th re e new o i l - f i r e d u n it s . Why d id n 't 

th e c o n tr a c t s p e c if y re mov ing and re p la c in g a ll s ix , as th e pro spe ctus a u th orize d?

ANSWER: D ur in g th e desig n phase o f th e p r o je c t, i t was de te rm ined

by th e a r c h it e c tu ra l engin eer th a t th e re pla cem ent o f th e s ix c o a lfir e d b o il e rs cou ld be ac co mplishe d w it h th e in s t a lla t io n o f th re e 

new o il u n it s havin g th e same to ta l c a p a c it y as s ix o f th e sm a lle r 

u n it s . A c c o rd in g ly , i t was o n ly ne ce ss ar y to rem ove fo u r o f th e 

o ld u n it s an d, in o rd e r to keep th e p ro je c t c o s t w it h in th e pro spe ctus a u th o r it y , i t was de cide d to abandon th e re m ain in g two u n it s 

in pla ce .
48

3. QUESTION: Why was i t then proposed to in s ta ll o il -fir e d units when 

gas-fired un its had been authorized only the yea r before?

ANSWER: At the time th at the prospectus was prepared in the fa ll

of 1969, GSA authorized design of the Central and West Pla nts to be 

converted to natural gas fir in g . The prospectus dated May 6, 1970, 

was approved by the Senate on June 11, 1970, and by the House on 

June 23 , 1971.

At the same tim e, the Clean A ir Act of 1970 and Executive Order 

11507 dated February 4, 1970 e n ti tl e d "Prevention , Control and 

Abatement of A ir Pollu tio n at Exist in g Federal F a c il it ie s " provided 

dir ectio n fo r GSA to se lect gas and o il fo r a ll heating plan ts 

re su ltin g in the v ir tu a l elim in atio n of coal burning. By June 

1971, the ar ch ite ct-eng inee r presented a fi n a l design repo rt 

which contained the prov ision to burn na tural gas, Number 2 fu el 

o il and Number 6 fuel o il. The in clus ion of o il fir in g ca p ab ility 

was lo gic al because the b o ile r co nf igur at ion fo r o il is the same as 

fo r gas.

Soon a ft e r award of the co ns tru ction co ntract on July 25, 1972, the 

Washington Gas Ligh t Company advised th at i t could not pro vide us 

with na tural gas except fo r li g h ti n g o ff purposes. We were immed ia te ly con fronted with the re a liza tion th at we were reduced to a 

sin gle fuel capabili ty . On January 8, 1973, the Federal Power 

Commission issued a polic y statement which placed natural gas used 

as b o ile r fuel in the lowest p rio rit y of service fo r pip elin e companies which find i t necessary to c u rta il deliveries.
49

4. QUESTION: Only two old boilers were removed and on ly two new ones were in sta lle d , along with new p re cip itato rs , ye t the work cost $11 m il lio n . This is the same as o rig in a lly estimated fo r replacement 

o f a ll boilers . What happened?

ANSWER: Please note th at the $11.4 m illio n includ es $653,000 of prospectus auth ority approved in Prospectus No. 1, dated A p ril , 1963. Work completed again st the f ir s t prospectus amounted to $581,900, leav ing a balance fo r uncompleted work of $10.9 m illio n . The co ntract fo r in s ta llin g the two new boilers along with pre cip itato rs was awarded in July , 1972, in the amount o f $9,214,349. Please note th at the cost o f three boile rs approaches the cost o f the replacement fo r six bo ile rs because they provide the same capa city. Although the o ri g in a l contract pro vided fo r three bo ile rs , one was subsequently delete d (see cr edits under Question No. 7). Work now accomplished in the plan t has been 

summarized in the answer to Question No. 6.

The work stoppage le ft fo ur old coal boile rs in place. Because the space was not needed fo r the two new bo ile rs , and, to conserve funds, 

on ly two of the boile rs were removed.
50

5. QUESTION: Was in sta llin g the Zeolit e water softenin g equipment, now 

requested, a pa rt of the origin al contract? I f no t, why wasn't 

su ita bl e equipment in sta lle d so the two new bo ile rs could be operated 

at fu ll cap acity?

ANSWER: The prospectus 08-0001-2 dated May 6, 1970, did not speak to 

the matter of Zeo lite water softening equipment. The inte rim re por t 

of the designer, dated September 1970, stated "Depending on the 

re su lts of an up-to-da te water an alysis of the new boile rs , i t is 

pres en tly fe lt that th is system w il l be adequate fo r the future 

plan t needs." At that time, the b o ile r sizes had not ye t been 

determined.

The in v it a ti o n to bid did go fo rt h (Contract GS-03B-15693) with no 

ad ditio na l water treatment fo r the 400,000 pph o il and ga s- fir ed 

boile rs . However, the boile r manufacturer of these two bo ile rs 

th ere after sta ted his requirements to be zero hardness. Therefore,

GSA, through more studies and in co ns ulta tio n with it s water che mistry 

co ns ultant, Hall Laboratories, Calgon Corporation and the boile r 

manufacturer, resu lted in the conclusion that the maximum hardness 

of the water be lim ite d to zero hardness. The exist in g feedwater 

equipment used fo r the coal-fire d boile rs allowed 15 ppm hardness, 

ther ef or e, i t was mandatory th at GSA obtain ad ditio na l feedwater 

softe ning equipment fo r the two o il - fir e d boile rs . Therefore, in 

the summer of 1974, i t was estimated that we could in s ta ll an ad ditio na l 

water so fte ning capabili ty as an in te rim answer to the problem fo r 

the two o il bo ile rs with in our auth ority (under $500,000). Procurement 

fo r the Zeolit e tanks was started on August 20, 1974, and de liv er y 

occurred p ri o r to Apr il 1976.

However, while wa iting fo r the deliv ery of the Ze olite equipment, 

the development of the to ta l plan and prospectus fo r the Central 

Plant con tinued, and i t was during th is period that i t was determined 

that i t would be in the best ove ra ll in te re st of the Government 

to inc lud e a to ta l water softening system in the proposed prospectus, 

one which would take care of the two addi tio na l m ulti-fu el boile rs , 

includ ing a ll the necessary pipin g and pumps, the deaerating tanks, 

and de m olition , and structu ra l changes necessary fo r a complete 

integrated feedwater system. Since the to ta l cost of the to ta l 

wa ter-treatment system fo r the two o il bo ile rs and the two new m u lt ifuel boile rs req uires specific Congressional approval anyway, the 

Zeo lit e equipment is included as part of the $1,832,000 as lis te d 

in the cu rren t prospectus.
6.

51

QUESTION: In testim on y give n by GSA at 

i t was sta te d th a t only pa rt o f the $11 

been oblig ate d. How much a c tu a lly was,

ou r re ce nt June 18 hearing 

4 m il li o n auth oriz ed had 

and fo r what?

ANSWER: A ll o f the $11.4 m il li o n auth or ized has been used as

ite mized below fo r bo th pros pe ctus es :

Pro je cts completed:

Renovation and ex te ns io n o f ele vato r 

Improvements to high voltage system 

Re pa ir o f e le c tro s ta tic p re c ip it a to r 

A dditio nal ro o f access

Mod er niza tio n o f e le c tric a l drive-a sh pumps 

In s ta ll a ti o n o f a d d it io n a l ash tan ks and lin e s 

Replacement o f coal ch ute

Replacement o f sto ker dri ves and two feed 

pump tu rb in es

B o il e r ash p it s and su pp or ts re b u il t

$ 93,188

16,283 

93,215 

8,141 

49,348 

73,271 

32,566

144,606

71,282

In s ta ll a ti o n o f a d d it io n a l tran sf orm er and m odific ations 

to e le c tric a l system

Replacement o f low voltage sw itchb oa rd 

Replacement o f two b o il e rs 

Ex tension o f chimney st ack 

In s ta ll a ti o n of a ir compressor

In s ta ll a ti o n of p re c ip it a to rs fo r two new o il b o ile rs 

Re wirin g and w ate rp ro ofing o f e le c tric a l co nd uits 

W in te rization o f co olin g tow er

51,887 

46,786 

10,255,827 

63,455 

33,500 

333,140 

39,750 

23,550 

$11 ,443,808

*See c re d it s Qu estion No. 7
52

7. QUESTION: I t was also stated th at GSA is now in the process of

rece iving cr ed its from the co ntract or , but the exact amount is not 

yet known. What was de leted from the contrac t?

ANSWER: GSA has received cre dits from the co nt ra ctor fo r the

de le tio n of one bo ile r and four o il storage tanks in the amount 

o f $1.5 m illio n . As to why we did not get more than $1.5 m illio n back, 

costs oth er than the manufacture of the b o ile r were invo lved , i. e ., 

co ntract or's overhead costs fo r his time, tr a ve l, othe r manufacturing 

or order costs, etc.

8. QUESTION: Is n 't there some record or documentation of work act ually 

done by the contractor? I f no t, how can the cre dits be figured?

ANSWER: Yes. On large co ns tru ction pr ojec ts o f th is siz e a CPM is 

prepared at the beginning o f the pr oje ct and is updated re gul ar ly 

to determine what items o f work have been completed by the Contractor.

Also , a Co nstructio n Progress Report is completed each month during 

the work period from which the value of completed work and it s 

percentage of the entire pro je ct can be determined.

The most eff ective way o f determin ing the amount of work actu ally 

done by the Co ntractor is by vis ua l inspection of the work in the 

fie ld . Visual insp ec tio n, in ad ditio n to te sting of equipment, 

pro vides the basis of how each item of work is paid fo r.
53

9. QUESTION: Is any li ti g a tio n now in progress, or an tic ipated ?

ANSWER: There is no li tig a tio n in progress or an tic ip ate d w ith

regard to the Central Heating Plan t co ns tru ction co nt ra ct.

10. QUESTION: The testimony states some work was done on a th ir d b o ile r. 

What was done?

ANSWER: No fi e ld work was done on co ns tru ction of a th ir d b o ile r.

However, the bo ile r man ufacturer had fabricated only the b o ile r 

drums fo r the th ir d b o ile r. This equipment was sold back to the 

co ntract or by the Government fo r a 100% cre dit.

The fu el o il storage and tr ansfe r system which is a shared f a c ility 

was in sta lle d with ca pa citie s to serve three o il - fir e d bo ile rs . Because s ig n if ic a n t redesign of the system would have been re qu ire d, i t 

was determined not to change the ca pa citie s of the pumps and pipin g 

system to serve two o il - fir e d b o ile rs . However, the storage capacity 

of the system was reduced by 40%.

11. QUESTION: Have both the new o il- fir e d bo ile rs now in place been 

accepted by GSA, withou t q u alificatio n?

ANSWER: The new o il -fir e d boilers have now been accepted and are going

through the normal procedure associated with a large co ns tru ction 

pro je ct to co rrec t defic ie nc ie s and omissions. Fin al payment to 

the Co ntractor is being with he ld u n ti l a ll de fic ie nc ie s and 

omissions are corre cte d.
54

12. QUESTION: One o f our s ta ff re ce n tly looked at these two new

b o ile rs and was advised of numerous deficie nces, which he observe d. 

As an example, two of the fo ur bu rners in one o f them were not 

work ing, and two in the oth er co uld no t generate enough heat to 

"purge " or cle an the u n it , which is a ro utine opera tio nal necess it y . Why is th is , and what is being done abo ut it ?

ANSWER: A ll burners now work in b o ile rs 3 and 4 and can be

ma nually purged at any tim e. These items are on the co n tr a cto r' s 

l i s t fo r autom atic purging at his expense. These item s are pa rt 

of the deficie ncie s and omissions (D 's & 0 's ) mentioned in the 

answer to the pre vious que stion.

13. QUESTION: We were informed th a t a ll of the main va lve s are le akin g, 

even though some have been replac ed or re paired, and pre ssu res 

cannot be maintaine d. This includ es not on ly the tem perature contro l va lve s but the blowdown va lves, which w il l no t ho ld. Who w ill 

replac e thes e, and when, and who w ill pay fo r it ?

ANSWER: The on ly valve s known to be leak ing on the new b o ile rs are 

two 2 inch steam valves on the atom izing steam systems and blowdown 

va lve s on the re ar of the new b o il e rs . Two new 2 inc h valve s have 

been pro cured and w il l be in s ta ll e d du rin g the summer shutdown fo r 

re p a ir s. The blowdown va lve stem le ngth of tr ave l appears to need 

re adju sting. A ll o f the above items are on the deficie n cie s and 

omissions (D 's & 0 ‘ s) l i s t fo r co rr e ctio n by the contracto r at his 

expense.
55

14. QUESTION: A long handled rod must be used to ad just the bypass 

valves manually, so that o il temperatures can be maintained.

This is guesswork-, and temperatures cannot be adju sted au tomatically 

by the console co nt ro ls, which makes the system undependable. How 

is th is expla ined, and what is going to be done about it ?

ANSWER: The origin al temperature control elements fo r the o il

heaters were manufactured fo r a minimum pre-heat of 180 degrees, 

which is too high in view of the high viscosity of the fuel o il now 

being rec eived. Those pre-heat co ntrol elements have been re ­

placed with 120 degree elements which permits a lower temperature, 

better vis cosity and be tter ato mization fo r burning, co rrec tin g 

the problem. Prio r to replacement of temperature co ntrol element, 

a reach rod was in sta lle d on a steam bypass valve to permit manual 

co ntrol of o il temperature. While th is required more opera tor at te nti o n , i t was not "guesswork" because a thermometer was av aila ble on 

the opera ting fl o o r to indica te o il temperature.

The reference to "console con tr o ls ' is not understood since there 

are no o il temperature co ntrols associa ted with the control console.
56

15. QUESTION: We are informed that the co nt ra ctor who in sta lle d the 

boile r co ntrol consoles has since gone bankrupt. Who does GSA 

turn to , fo r co rrec tio n of these de fic ienc ies?

ANSWER: The above comment is apparently a reference to a subco ntractor. This equipment is pres en tly under warranty by the 

manufacturer again st defects in fa brication and in sta lla tio n u n til 

December 15, 1975, fo r Boiler No. 3 Control Panel and February 9, 

1977, fo r Boi le r No. 4 Control Panel. I f problems arise which are 

deemed to be covered by the warranty, the Government w il l work 

through the prime, general contractor to get the problems corrected. 

After wa rranties ex pire, GSA w il l be res ponsible fo r maintenance 

and repa ir of equipment. Prio r to settle me nt of the co ntract, 

a ll "p un ch lis t" items (D's & 0's ) and equipment tests w il l be 

complete and approved.

16. QUESTION: Another th in g is th at flue ash is not being removed, due 

to in s u ff ic ie n t heat, and must be wetted down and hauled away.

What eff ect has th is had on the opera tion ge ne rally , and how w il l 

the situa tion be corrected?

ANSWER: This comment is not understood. The flue ash (which is fly 

ash) is being removed in a normal manner by the dry ash handling 

system. To pre ven t partic le s from blowing they are "wetted down" 

during tran sp or ta tio n away from the pla nt. There is no eff ect on oper 

ations and no situa tion req uires co rrection.
57

17. QUESTION: We are to ld that water going through the two new bo ile rs is being tre ated with a mixture of lim e, soda, and phosphate, fed by hand in to a mechanical mixer. However, th is tends to bu ild up in the tubes, crea tin g a serious problem. How w il l in s ta lla ti o n of 

the proposed new Zeolit e equipment co rrec t th is?

ANSWER: Water treatm ent fo r a ll boile rs at Central Heating Plant is pre sently in two stages. In the f ir s t stage (p re -b oiler) lime and soda are fed . These chemicals are fed by hand in to chutes leading to mixing tanks. The feed from these tanks is automatic and in propor­ tion to the amount o f water which must be added to the system to replace losses. The re sult of th is pre -b oile r treatment is a reduc­ tion of water hardness to approximately 15 pa rts per m illio n and a 

reduction in dissolv ed solid s.

The second stage of water treatment takes place inside the boile rs . Chemicals are added to the bo ile r feedwater lin e from a separate chemical feed system to rea ct with the water hardness minerals to form a less adherent sludge instead of hard, adherent scale. Some of th is sludge is removed by blowing out sludge and water from the lowest parts of the bo ile r. I f the chemicals sodium phosphate and sodium hydroxide were not pre sent, instead of sludge being formed, a 

hard scale would re su lt in the bo ile r tubes.

The new o il boile rs are of modern design "High Heat Release" per cubic foot of furnace volume. There fore, at the higher loads, say above 200,000 pph, the heat flux at various places with respect to the flame placement can approach a co nd ition causing "f ilm boili ng" in the tube ra th er than nucleate boilin g. This re su lts in local high tube metal temperature which ra pid ly attra cts any depositing type ma terial which insu lates the tube metal from the water, heating 

the tube more, u n ti l i t is ductile and tube rupture occurs.

The new Zeo lite equipment w il l provide the pre -b oiler water treatment 

which w il l reduce water hardness to zero.
58

18. QUESTION: The prospectus ind ica tes a cost of $1.8 m illio n fo r 

in s ta lla ti o n of feedwater system. How much of th is is fo r the 

Zeo lite in sta lla tion ?

ANSWER: The Zeo lit e equipment is not a system by it s e lf but is a 

pa rt of the to ta l feedwater system and cannot be operated independently. 

There is no lo gical way of breaking out the cost separately. The 

to ta l feedwater system, as shown in the prospectus, includes pumps, 

piping , deaerating tanks and Zeo lite equipment.

In re a lity the to ta l feedwater system at an estimated cost of 

$1.8 m illio n includes the 8 Zeo lite tanks purchased fo r $263,638.

The to ta l system w il l include pumps, deaeration tanks, piping , 

related item s, and w il l also include de molition , ele ctr ic a l and 

st ru ctu ra l changes in the plan t it s e lf .

19. QUESTION: The response to one of the questions posed by Mr. Braith waite 

o f our Committee s ta ff re fe rs to forma tion o f su lfu ri c acid when boile rs 

are operated at less than 150,009 lb s. per hour ca pa city, which causes 

sc aling and co nt rib ut es to the pollution problem when lin es are dra ine d. 

What e ff e c t does th is have on the pla n t's ov er all operation?

ANSWER: Operation at less than 150,000 lb s. per hour causes s u lf u ric 

acid to be deposited in the ele ctr o sta tic pre cip itato rs . This acid 

w il l at tack stee l and w il l ultim ate ly destroy the pre cip itato rs .

Boi le rs running withou t the pre cip itato rs in ta ct re s u lt , in atmospheric p o llu tio n . The re su lt, th ere fo re , of opera ting at les s than 

150,000 lb s. per hour would be th at these two new boile rs would become 

unusable, probably in 1 to 2 years , u n ti l the pre cip itato rs were 

replaced. However, the boile rs w il l not be operated at les s than 

180,000 pph.
59

20. QUESTION: Inform ation furnishe d fu rt her sta tes th at the pr oje ct 

is designed to in s ta ll six Z eolite water so fte ning un its, and that 

treatm ent w il l be adequate "as soon as au th or izat ion by Congress 

and opera ting co nd itio ns perm it." We have already heard about 

Congress delaying th is work, but what are the opera ting co nd ition s 

th at must permit i t to be done?

ANSWER: The in s ta lla ti o n o f the Zeo lite un its inv olv es removal

o f some exi sting water tr eatin g equipment (to provide space), 

structu ra l altera tions, and re -p ip in g of the basic feedwater 

system. Since the Feedwater System is common to a ll b o ile rs , the 

work can only be done during times the plan t can be shutdown 

comp lete ly fo r a period o f 6 months,which is during summer months. 

During th is summer months shutdown, the West Heating Plan t w il l 

be able to carry the lower summer load.

21. QUESTION: GSA already has th is Zeo lite equipment, haven't they, 

which we are to ld is so necessary and so c rit ic a l? Why ha sn 't 

i t been installe d?

ANSWER: GSA pru dently purchased these un its in advance, to speed 

up th e ir a v a ila b il it y fo r in s ta lla ti o n . They are a long term 

procurement item with about a year elap sing between purchase order 

and deliv ery . The pre-purchase was an e ff o rt to shorter, the exposure of the bo ile rs to hardness in the boiler feedwater.

The new water treatment system w il l serve both the exis ting two 

o il fire d bo ile rs and the proposed two m ulti-fu el bo ile rs as an 

integrated system. We could have in sta lle d the Zeo lite equipment 

in to the ex istin g system to serve only the o il boile rs , but opt 

to wait fo r a to ta l system serving a ll four bo ile rs thereby 

ob taining a more e ffi c ie n t system at a more economical cost.
60

22. QUESTION: When was i t procured and how?

ANSWER: The procurem ent s ta rt e d August 30, 1974,on a re qu es t fo r

quote s No. 117952 and d e liv e ry oc curre d p rio r to A p ril 1976.

The need was known, the s p e c if ic a ti o n s were a v a ila b le , the design 

was comp lete, the es tim ated co st was w it h in GSA's a u th o ri za tio n 

and the funds were made a v a ila b le . The purchase was made throug h 

normal channe ls by the GSA Federal Sup ply Serv ice, on the open 

mar ke t, by s o li c it in g bids and awarding to the low bid der to fa b ri 

ca te and d e liv e r.

23. QUESTION: Why is i t in clu ded, a t th is la te date , in the prospectu s now be fore us?

ANSWER: See answer to Number 5.
61

24. QUESTION: This prospectus, which has been reviewed by OMB and submitted to our Committee fo r approval, requests in s ta lla ti o n of two new boile rs . We have learned that only a year ago GSA adver­ tised fo r bids on in s ta llin g two ad ditio na l new boile rs at the Central Heating Plan t. Why was th is not submitted fo r the Comm itte e's approval?

ANSWER: The FY-75 R&A ap prop ria tio n contained $10.2 m illio n fo r the purchase of two boile rs . Under the then schedule, i t was plan­ ned to have the prospectus fo r the heating plan t before the Congress and ho pe fully approved during fisca l year 1975. Because of the ti g h t time frame involved, s o li c it a ti o n was placed on the market fo r the purchase of two bo ile rs in anticip ation of the prospectus being sub­ mitted to and approved by Congress. However, because of ad m inistra tiv e and oth er delays experienced in processing the prospectus, the prospectus was not subm itted on time and the bids were therefore cancelle d fo r lack of auth ority .

25. QUESTION: Under what auth orization was i t done and why was no. mention made of i t , eith er in the curre nt prospectus or elsewhere?

ANSWER: See answer to Number 24.

75-602 0 - 76 - 5
62

26. QUESTION: What is GSA's real plan fo r the Central Heating Plant?

How many new bo ile rs do they re a lly want, and why haven't they been 

more candid with the Committee?

ANSWER: GSA re a lly wants a heatin g system th at is (1) re lia b le ,

since the measure of a hea ting system’ s success is continuity of 

op eration; (2) e ffic ie n t, since we wish to operate econom ically 

burning the most p le n ti fu l and economic fu e l; (3) e ff e c ti v e , since 

we de sir e sa fety of personnel and plan t and conformance to en viron ­

mental co nstra in ts.

GSA's real plan fo r the Central Heating Plant is as sta ted within 

the prospectus aw aiting appro val. We re a lly want the two new 

m u lti- fu e l boile rs so th at we can meet the an tic ipat ed steam demand 

through 1985. We have no comment on the candid infere nce othe r than 

th at statement is un just and unwarranted.

27. QUESTION: We are to ld by GSA th at i f th is pr oje ct is n 't promptly 

approved, the funds appro priate d fo r i t in the FY-1976 budget w il l 

be lo s t. Please expla in th is .

ANSWER: The FY-76 funds fo r th is pr oje ct w il l not be lo s t since

GSA has carryover auth ority o f $40 m illio n .
63

28. QUESTION: We have been inform ed th a t the same argument was used 

la s t ye ar when GSA wanted to go ou t fo r bids on two new b o il e rs . 

Are ther e any comments? Was the money lo s t, or w ill i t be?

ANSWER: Please re fe r als o to Question No. 24. In FY-75, we had $10.2 m il li o n in the budget (one -yea r money - no ca rr yo ve r) , and since we could no t award the Ce ntral He ating P la n t, the money was used to accom plish o th e r high p r io r it y pro je cts in 1975 th a t were 

programed fo r 1976.

29. QUESTION: D id n 't the appro priations b ill fo r FY-76 s ti p u la te th at 

funds would remain a va ila b le u n til expended?

ANSWER: Yes, in FY-76 $40 m il li o n ou t o f the appro priation b ill 

can be carr ie d ov er.
64

30. QUESTION: Testimony was given at the hearing that GSA has a cu rren t 

require ment fo r more than 1.4 m illio n lb s. of steam per hour. How 

was th is determined?

ANSWER: A 10 year an aly sis of maximum steam demand in pounds of

steam per hour dis closes a peak o f 1,295,000 on January 9, 1970.

The average temperature fo r th at day was +8°F with one inch of 

snow, a wind velo city of 21 mph, and 52% of possible sunshine.

The low fo r the day was +4°F and the day prev iously was windy and 

co ld. January, 1970, was the co ldes t month in the past 10 years.

Weather s ta ti s ti c s show th at th is +4°F or a lower temperature can 

occur every 5 years. We choose the +4°F temperature base on a 

10 year basis rather than a more severe recorded -6°F on a 50 yea r 

ba sis . This se lection is not cons erva tive, bu t, re fle cts an 

engin eering decision which is also the basis upon which the membership o f the In te rn ation al D is tr ic t Heating Associa tion determines 

it s maximum possible de-rated ho urly steam generation ca pa city.

January 9, 1970, peak of 1,295,000 pph supplied a ca lculat ed 

36,553,000 gross square fe et of build in g area overa ll. Since then 

and u n til the winter of 1975 - 1976, an estimated 7,232,740 gross 

square fe et of space was added to the system and 3,389,000 square 

fe et of space was de leted, fo r a net increase of 3,843,740 square 

fe et o f area. This 10.8% increa se in space equates to an an tic ip at ed 

steam demand increase of 1,430,000 pph, provided the same meteorolo gic al cond ition s exis t as did on January 9, 1970.

Washington, D.C. is experiencing a long range average temperature 

ri se an tic ip at ed to begin declin in g by 1979. Such de cline w il l 

increa se the pro bability of reaching or exceeding GSA's projec ted 

maximum steam demands.
65

31. QUESTION: Backup inform ation furnis hed to us indica tes th at 36.6 m illio n square fe et of build in g area were being served by the two heating plan ts in 1970. But th is included the old Navy and Muni­ tions bu ild ings which had large open areas and were badly insu lated, in ad ditio n to othe r obsolete structures th at have been demolished. Is i t fa ir to compare the load required to heat these bu ild ings w ith the much less er ou tput req uired fo r modern o ff ic e bu ild ings 

constructe d since th at time?

ANSWER: I t is a more than fa ir comparison since 2,800,000 square fe et out of 3,400,000 square fe et vacated were composed of Navy- Munitions Bu ilding s which were low heat loss bu ild ings ( i. e . re ­

inforced concrete construction.)

The new James Fo rre stal Build in g, Federal Reserve Annex, Hirshorn Museum, J. Edgar Hoover FBI Building, Department of Labor Building, U. S. Tax Court, South Portal Building, and A ir and Space Museum are testimonies to the s p ir it of arc hitectu ra l freedom. They are acres of gla ss, open underneath tc the breezes of w in te r, and some contain miles of hot water d is tr ib u tio n systems where the radiators are located at the exte ri o r glass, immediately su bjec t to fre ezing 

in the event of steam cu rtailm en t.

Even i f we granted th at these new bu ild ings are considered to be more impervious to transmission of heat, i t must be re ca lle d th at the vast m ajo rity of the build in g being served in 1970 were heavy monumental 

structu re bu ild ings such as the Federal Tria ng le.
66

32. QUESTION: Data furnis hed by GSA, al so , indica tes fu tu re requirements 

by 1980, which includ e an expanded Bureau of Engraving Build in g, a 

downtown Eisenhower Civic Center, and new S.W. Federal Employment area. 

Why is i t believed th at any o f these w il l ever be con stru cted?

ANSWER: A ll of the pr ojec ts proposed were the re su lt of the plan ning 

availa ble at the time the la s t survey was made. The Bureau o f Engraving 

Build ing prospectus was before Congress. The Eisenhower Civ ic Center 

was a via ble pr oje ct at the time and is s t ill being talke d about. Like 

the Pennsylvania Avenue P ro je ct, i t lived, died , and now is resu rre cted .

The S.W. Federal Employment Area was a pr ojec t planned fo r 1978. In 

view of new budgetary co ns iderations i t w il l be slipped to 1980 - 1981.

A ll o f the bu ild ings lis te d were the bu ild ings most li k e ly to be approved 

fo r co nst ru ct ion, according to the many sources contacted , i. e . , D.C. 

Government, Department of the Treasu ry, Smithsonian In s ti tu ti o n , etc.

The a rt of planning is to anticip ate success. Our ob je ct ive is to 

provide economical steam upon demand, both e ff ic ie n tly and safe ly .
67

33. QUESTION: We are to ld th e h ig h e st re co rd ed demand was 1.3 m illio n lb s ., and th is was when th e obsole te b u il d in g s were bein g s e rv ic e d , in c lu d in g se vera l o ld WW I s tr u c tu re s , a ll o f which have sin ce been 

to rn down. The 11 b o il e rs now o p era tin g have a com bined o f 2. 3 

m illio n lb s . o r 77 pe rc ent in exc ess o f th e maximum re co rd ed demand. I f th e fo u r o ld b o il e rs in th e C entr al p la n t were r e tir e d , 

th e re would s t i l l be a 1.7 m illio n lb s c a p a c it y , o r n e a rl y 30 

perc ent ov er th a t re q u ir e d . Why ar e any new b o il e rs needed?

ANSWER: The

West p la n ts is

com bined c a p a b il it y o f th e b o il e rs a t 

2.3 m illio n pounds o f stea m per ho ur

th e C entral 

(p p h ):

Coal O il T o ta l

C entral 4 Q 150 2 0 400 1,40 0 pph

West 3 P 175 1 0 200

1 0 175 +900 pph

Elev en b o il e rs in c lu d in g 4- 43 y r. o ld co al b o il e rs 2,300 pph

Since th e fo u r co al b o il e rs a t th e C entral P la n t mu st be r e tir e d , 

we ta ke away 600 -600 pph

T o ta l dera te d c a p a c it y o f seven (7 ) b o il e rs 1,70 0 pph

We must pr ep ar e fo r th e e v e n tu a li ty o f th e la rg e s t b o il e r a t each p la n t be ing out o f s e rv ic e a t any one tim e . A c c o rd in g ly , we must ta ke 

away one 400 fro m C entr al and one 200 fro m West (S tand by C apa city) -600 pph 

Net re li a b le c a p a cit y o f fiv e (5 ) b o il e rs 1,100 pph

W ith two new m u lt i- fu e l b o il e r s , we can add 440 +440 pph T?5'40 pph

Our c a lc u la te d peak demand was 1,430 ,0 00 pph in 1975 w it h a 

p ro je cte d maximum stea m demand o f 1,5 40 ,0 00 pph in 1980 and 

1, 65 3,00 0 pph fo r 1985.

NOTE: WHILE A NUMBER OF OLD BUILDINGS WERE DISPOSED OF, MANY NEW BUILDINGS WERE ADDED, MORE THAN OFFSETTING THE LOSS OF SPACE 

(SEE ATTACHMENT A ).
68

G ro ss S quare F e e t S erv ed By

The C e n tr a l And West

H e a ti n g P la n ts

1970 - 1980

Yea r

1970 (B ase )

Added

D.C. L ib r a r y , O c to b e r, 197 2 

F e d e ra l R ese rv e An ne x, O c to b e r, 1973 

H ir sh h o rn Museum, Nov em be r, 1974 

J . Edg ar Hoo ve r B u il d in g , Nov em be r, 1974 

D epart m ent o f Lab or B u il d in g , Nov em be r, 1974 

U .S . Ta x C o u rt , Ju n e , 1974

S outh P o r ta l B u il d in g , D ec em be r, 1975 

A ir an d Spa ce Museum, D ec em be r, 1975 

TOTAL

G ro ss

S quare F e e t 

(GSF)

3 6 ,5 5 3 ,0 0 0

344,0 00

215,0 00

17 0,2 00

2 ,3 9 7 ,0 0 0

1 ,8 0 2 ,0 0 0

217,0 00

887,5 40

1 ,2 0 0 ,0 0 0

7 ,2 3 2 ,7 4 0

D e le te d

Nav y B u il d in g , March , 197 0 

M u n it io n s B u il d in g , M ar ch , 197 0 

Tem po ra ry B u il d in g E, M ar ch , 1970 

130 0 E S t r e e t , March , 1970 

1711 New Yo rk Ave nu e, M ar ch , 1970 

W in de r Ann ex , 1974

17 23 -2 5 F S tr e e t, 197 4 

TOTAL

To Be Added B efo re 1980

1 ,4 2 8 ,0 0 0

1 ,4 2 8 ,0 0 0

215,0 00

71,0 00.

215,0 00

9,0 00

23,0 00

3 ,3 8 9 ,0 0 0

F e d e ra l Home Lo an Bank B oa rd 

N a ti o n a l G a ll e ry o f A rt An nex 

D i s t r i c t o f Colum bia C o u rt h o u se 

195 1 C o n s titu tio n Av enue (E x te n s io n ) 

TOTAL

400,0 00

591,0 00

700,0 00

10 0, 00 0

1 ,7 9 1 ,0 0 0

ATTACHMENT A
69

34. QUESTION: Furth er, we are informed that the 2.3 m illio n lbs. capa city fig ure shown is one a rb it ra ril y "de-rated" by GSA, re ­ fl e c ti n g a 20 percent redu ction below the actual ra ting. Wouldn't th at indica te a curre nt excess of more than 100 perce nt, based on the highest recorded demand of 1.3 m illio n lbs. Doesn't i t also indica te a 93 percent excess over the 1.43 m illio n lbs. now stated as GSA's 

cu rren t need?

ANSWER: The 2.3 m illio n pph capacity was not a rb it ra ril y derated by GSA. Boilers and th e ir au xilia ri es are b u il t to produce a given amouht o f steam. This is ca lle d the boiler "Name Plate" ca pa city. As equip­ ment ages, i t reaches a stage of de te rio ra tio n so th at maintenance and re pair cannot keep i t operating at a fu ll load co nd ition or at an econo­ mical cost. The load th at a boile r can actu ally ca rry at normal operating cond itio ns is ca lle d the "derated" capability. I t is not possible to accurately pred ict the actu al, or derated capabili ty at any fu tu re time because of many unknown fa cto rs . For example, the cap ab ility of a boile r may improve aft e r replacement of a major piece of a u x ilia ry equipment.

Estimates concerning the system capabili ty are based upon experience which indic ates th at two boile rs can be out of service fo r repa irs when an on line unit fa il s . With the planned replacement of c rit ic a l a u x il i­ aries fo r bo ile rs at the West Heating Plant and the replacement of some boile rs in the Central Heating Plan t, the r e lia b il it y of the to ta l system 

w il l be s ig n if ic a n tl y improved.

I t is assumed th at only one boile r would be down fo r repa irs during the peak load cond ition and th at one could fa il at any tim e. Because of rapid­ ly changing co nd ition s, the in a b il it y to accurately pre dict future av ailable fuels and the cond itio ns and repa irs of bo ilers , projec tions past 10 to 15 years in the fu tu re are d iffic u lt . However, these data in dica te that the proposed system w il l be adequate unless unforeseen co ns tru ction adds s ig n if ic a n t amounts of new space.

A ll of the origin al major equipment is s t ill in service and a major po rti on of the equipment has become obsolete. Spare pa rts can no longer be obtained and most are exceedingly cost ly to fa bricate "i n house". Many parts cannot be fa bricate d, and the equipment w il l have to be re­ placed upon fa ilu re of these c rit ic a l pa rts . This situation causes excessive maintenance and re pair costs , with boile rs being unavailab le 

when needed because of delays in repa irs .
70

The exis ting coal-fire d bo ile rs w il l no longer produce steam at th e ir 

rated ca pa city, due to the degeneration of tubes, fir e boxes, stokers 

and au xilia ry equipment.

The cu rre nt system fre qu en tly has three un its forced out of service at 

one time. During December, January and February of 1973, 1974 and 1975, 

there were two or more bo ile rs out of opera tion 46.7% of the time.

During the same heating seasons (December through February), there 

were 37 days when three or more boile rs were out of opera tion due to 

malfunctions. Therefore, we know th at three bo ile rs can be out of 

service during peak load periods.

Attached are three papers supplementing th is ma tter:

1. Comparison of In te rn at ional D is tr ic t Heating Assoc iation 

s ta ti s ti c s de picting the maximum hourly send-out capacity (derated) 

together with the percent of capability of 40 steam heating systems 

GSA w il l compare very favo rably with the IDHA 72% capabili ty 

u ti li z e d , i. e . , GSA w il l have to ta l capacity of 2,140,000 pph, 

with the two m ulti-fu el boile rs operating and assuming one 

400,000 pph boile r and one 200,000 pph boile r incapable of

being fire d fo r a percent capacity u ti li z a ti o n rate of 71.9%.

2. Sp ec ific causes of bo ile r fa ilu re

3. Effects of a system fa il u re
COMPARISON OF IDHA STATISTICS

(IDHA S ta tis tic s are fo r Calen da r 1974)

Co.No. C it y Company Name

Actu alMaximum

H ourly

Sen d- ou t

M lb

Maximum 

H ourly 

Sen d- ou t 

Capaci t y

M lb

% o f 

Capab i l i t y used

1. New Y ork , NY C onsolid ate d Ed ison Co. o f NY* 12 ,74 0 15 ,13 0 84 .2

2. P h il a d e lp h ia , PA P h il a d e lp h ia E le c tric Co. 2,48 2 3,8 57 ’ 64 .2

3. D e tr o it , MI D e tr o it Ed ison Co. 1 ,728 2,971 58 .2

4. Bos to n, MA Bo ston Ed ison Co. 1,85 0 2,00 5 92 .3

5. In d ia n a p o li s , IN In d ia n a p o li s Power & L ig h t Co.* 1,2 92 1 ,735 74 .5

6. Rocheste r, NY Roc he ster Gas & E le c tr ic . C orp .* 1 ,118 1,87 5 59 .6

7. Milw au ke e, WI W isco ns in E le c tric Power Co. 915 1,64 0 55 .8

8. B a lt im o re , MD B a ltim ore Gas & E le c tric Co.* 678 990 68 .5

9. C le vela nd, OH Cle ve la nd E le c tric Ill u m in a tin g Co 896 1,32 0 67 .9

10. Day to n, OH Dayto n Power & L ig h t Co. 508 982 51 .711. De nver, CO P u b lic S erv ic e Co. o f Color ad o 440 580 75 .9

12. P it ts b u rg , PA Alle ngheny County Steam Htg . Co. 668 1,041 64 .2

13. S e a tt le , WA S e a tt le Steam Corp. 598 925 64 .6

14. T o ro n to , ON, Canada Toro nto H y d ro -E le c tr ic System 434 560 77 .515. H a rr is b u rg , PA Pennsy lvania Power & L ig h t Co. 376 500 75 .2

16. San F ra n cis co , CA P a c if ic Gas & E le c tric Co. 330 375 88 .0

17. Lansin g, MI Board o f Wa ter & L ig h t 223 430 51 .9

18. Grand Rap id s, MI Consummers Power Co. 234 280 61 .6

19. D u lu th , MN D ulu th Steam Corp. 227 320 70 .9

20. Akr on , OH Ohio Ed iso n Co. 205 307 66 .8

* These com panies were c lo s e ly compared to the D is t r ic t Heatin g System.

Attach ment 1
COMPARISON OF IDHA STATISTICS

(IDHA S ta tis tic s are fo r Calen de r 1974)

Company Name

Van co uv er, BC, Canada 

Eugene, OR

W innipe g, MB, Canada 

Spoka ne, WA 

Tole do, OH 

Birm ingh am , AL 

Youngstow n, OH 

S t. P aul, MN 

H a rtf o rd , CT 

R ocheste r, MN 

Hou ston , TX 

W ilke s-B a rr e , PA 

Co nc ord, NH 

Piqua , OH 

S t. Jo se ph , MO 

S p rin g fie ld , OH 

S o u th fi e ld , MI 

N a s h v il le , TN 

Rice La ke , WI 

San A n to n io , TX

C entral He at D is trib u tio n L td . 

Eugene Water & E le c tric Board 

Winnipe g Hydro CSH D iv is io n 

Washin gton Water Power Co.

To ledo Ed ison Co.

Alabama Power Co.

Ohio Ed ison Co.

N orthern S ta te s Power Co. 

H a rt fo rd Steam S erv ic e Co. 

Roc he ster P u b lic U t i l i t i e s 

Houston N atu ra l Gas Corp. 

W ilke s-B arr e Steam He at. Co. 

Concord Steam Corp.

M unic ip al Power System 

S t. Joseph L ig h t & Power Co.

Ohio Ed ison Co.

Dayto n Hudson P ro p e rt ie s 

N a s h v il le Thermal T ra n sfe r Corp. 

Rice Lake Steam Corp.

C it y Water Board

A ctu al Maximum

Maximum H ourly % Of

H ourly Se nd -out CapaSen d- ou t C apaci ty bi 1i t y

M lb M lb used

260 535 48 .6

141 580 24 .3

225 390 57 .7

280 457 61 .3

190 305 62 .3

203 476 42 .6

183 260 70 .4

240 350 68 .6

155 339 45 .7

90 150 60 .0

150 375 40 .0

158 341 46 .3

65 112 58 .0

59 80 73 .8

80 150 53 .3

79 258 30 .6

42 110 38 .2

65 218 29 .8

23.1 80 28 .0

Atta ch m en t 1 (C o n t'd )
73

Spe cific Failures or Malfunctions of Equipment

While the obsolescence and dete riora tion of the basic equipment or un its of the D is tr ic t Heating System create problems, c u rta il ­ ments of steam often re sult from the fa ilu re or malfunction of spe­ c if ic pa rts of the o il -fir e d boilers . Among the parts that malfunction or f a il are these:

Induced dra ft (I .D .) fan speed detectors

Forced dra ft (F.D.) fan speed detectors

Flame detectors

A ir co ntrol instruments

E le ctr ic switch ing tra ns ient s

Annunciator cards

Atomizing steam valves

Oil pressure regulators

Oil pump/heater sets

Water lev el co ntrolle rs

Solenoid valves

Gas ig nitio n

Feedwater pumps

I.D . fan drives (many modes)

F.D. fan drives (many modes)

B oile r tubes

stoker drives (many modes)

Connecting rods on stokers

Stoker drive co ntrolle rs

Grates (many modes)

Ash grinders

Water columns

Soot blowers

Safety valves

E le ctr ic switch gears

Hydraulic lin es (f o r sto ke r drives )

Pre ci pita to rs (e le c tr ic and mechanical)

Bric k work in furnace and ash p it

Ash Pits

Feedwater regulators Gasket in manholes, hand holes and steam header pipes

Attachment 2

75-6 02 0 - 76 - 6
74

Effe cts of the System's Failure

Some of the ef fe cts of the fa ilu re of the D is tr ic t Heating 

System to supply steam during the heating season, in ad ditio n 

to the huge loss of pro ductive time and money to send Federal 

employees home on Adm inistra tiv e leave, includ e the fo llo win g:

1. The Bureau of Engraving stops printing money.

2. The HEW Medical Research experiments also are stopped, 

with the re su lts po ssibly destroyed.

3. Agr icultu ra l Research experiments also are stopped, with 

the resu lts po ssibly destroyed.

4. Museums' irrep lace ab le a rt work is subje ct to damage.

5. The National Archive 's documents are endangered.

6. M ilita ry computer programs, such as those in the Forresta l 

Building and the White House, invo lving National Defense 

are inte rrup te d.

7. The State Department's support of the Secretary of State 

is inte rrup te d.

8. The Justice Department functions are impaired or stopped.

9. FBI criminal computers and records are not av ailable 

fo r fie ld use.

10. The D.C. Government would be inte rrup te d.

11. The Treasury Department computers would be stopped, 

inclu ding disbursement of checks.

Attachment 3
75

35. QUESTION: How is GSA compensated fo r steam furnish ed to non-Government 

bu ild ings ? How is the amount determined? Would ra te be af fe ct ed 

by the new work proposed?

ANSWER: GSA is compensated fo r steam furnished to non-Government

bu ild in gs through the means of the GSA Form 2957. Under the prov ision s 

o f the Federal Bu ild ing Fund, an oblig atio n is receive d from the nonGovernment bu ild in g fo r steam to be consumed. This obligation is a 

firm price commitment consummated every qu arter.

The amount to charge fo r steam is determined based upon the estima ted 

cost o f opera tion divid ed by the estimated consumption of steam in 

thousands of pounds per hour. Operating costs inc lud e a ll costs except 

major re pair and replacement items, such as are contained in the prospectus. The amount to charge is determined based upon the an alys is of 

expense and income. An adju stment is made to the next quarter's ob lig ation depending on whether too l i t t l e or too much money was ob lig at ed fo r 

the exis ting qu arter.

The steam rates would not be af fe ct ed by the cost of the items contained 

in the prospectus. The steam rates would be affected i f a le ss er cost 

fuel cou ld not be burned and/o r i f the re be no action, or the prospectus 

and ove ra ll plan t physical dete riora tion affects increased maintenance 

and re pair.

36. QUESTION: The prospectuses do not indica te any altern atives to 

the work proposed at both pl ants . Why not?

ANSWER: The prospectuses present the best plan developed by GSA. 

Alte rn at e courses of ac tio n were con sidered, rejected and exp lain ed 

in the Environmental Impact Statement.

Copy o f Environmental Impact Statement atta ched.
37. QUESTION: In the in te re st of economy, at th is tim e, why can't

on ly the work be done th at is necessary to comply with D.C. and EPA 

requirements?

ANSWER: (1) To add new pre cip itato rs to the fo ur 43 year old

derated boilers , which would be size d and usable on a fu tu re 

modernization pro je ct, would cost an estimated $5,150,000. This 

work would cover de molition of old pre cip itato rs , in s ta lla ti o n 

o f new pre cip itato rs , str uctu ra l m od ifica tio ns , fan revision s, 

controls, e le ctr ic a l m od ifica tio ns , duct work, in sula tion, and 

arc hitectu ra l screen wall at roof . Since we have not attempted 

any design of th is type of approach, (because present boile rs must 

be replaced, reg ard less of th is ac tio n) we cannot at th is time be 

assured th at th is is phys ically po ssible.

(2) To add mechanical separators plus pre cip itato rs to the fo ur old 

bo ile rs , coverin g th e ir present derated capacity on ly, would cost 

an estim ated $3,085,300. These pre cip itato rs would be unusable fo r 

the fu tu re moderniz atio n of the boile rs and would have to be replaced at th at time.

COMMENTARY:

We do not have design fo r eith er of these alte rn ate s. To get such a 

prospectus approved, complete the design, procure a co ntract or , fa bric at e 

and ere ct , w il l invo lve three years or more.

I f A .l. is chosen, the pre cip itato rs would remain in place during a 

fu tu re modernizatio n pro je ct, and the co ntractor would be prevented from 

using the roof access fo r the erec tio n of the boile rs and thereby m at er ia lly increase the cost of the pro je ct. Regardless of a ll th is , the old boile rs 

must be replaced w ithin the next five years. Since i t would take some three 

years to design and in s ta ll these pre cip itato rs , we would be by th at time 

re a lizin g the end of the useful lif e of the boilers , and would end up with 

new pre cip itato rs on useless boilers , withou t the capability of meeting peak 

steam demands.

I f A .2. i f chosen, the money use would be marginal as the pre cip itato rs
77

would be demolished when the old boile rs reach a "p oin t of no re tu rn " w ithin the next fi v e years . Since design and co ns tru ction of these pre cip i­ ta to rs w ill take three years, th e ir useful life w il l be only two years since 

the boile rs w il l be at the end o f th e ir useful life .

38. QUESTION: The Final Environmental Impact Statement dated June 25, 1976, is tit le d Central Heating Plant. W ill there be another one 

fil e d fo r the West Heating Plant?

ANSWER: Yes, GSA w il l pu blish a D ra ft Environmental Impact Statement 

fo r the West Heating Plan t.
QUESTION: EPA's response to the d ra ft statement, which is included 

in the fin a l, sta tes that they need more information and o ff e r 

sug gestio ns. There is no evidence in the Fin al Impact Statement 

th at GSA ever complied, or th at EPA approves withou t q u a lific a tio n . 

W ill ad ditio na l exhib its be submitted?

ANSWER: The Dra ft Statement was revise d, takin g in to account 

EPA's comments and suggestions and published as a Final Statement 

and then dis trib ute d on June 25, 1976. EPA, by le tt e r to GSA dated 

Ju ly 2, 1976, stated : "We have reviewed the Final Environmental 

Impact Statement fo r the proposed pro je ct. Based on th is rev iew , we 

have no ob jections to the fu rt h e r development o f the Central Heating 

Plan t as de scrib ed." No additio nal exhib its w il l be submitted at 

th is time.

QUESTION: The D. C. Government's comments also comprise on ly questions 

and suggestions. Fu rth er, they re fl e c t a b e lie f that tra sh-burnin g 

boile rs w il l be used, and po in t out rig ht -o f-way problems that w ill 

be encountered with tru ck fa c il it ie s . Has D. C. fi le d comments 

in dicatin g un qu alified appro val, and why are they not included in 

th is Final statement?

ANSWER: The pro je ct, as revise d does not include paper-handling

fa c il it ie s or truck fa c il it ie s fo r tra sh . The Final Statement explaine d th is and responded to a ll of the oth er comments to the Dra ft 

Statement offered by the D is tr ic t of Columbia. The Municipal Planning 

O ffice of the D is tr ic t, at a meeting of the National Capita l Planning 

Commission on August 5, 1976, intro duced a le tt e r from the Corporation 

Counsel of the D is tr ic t dated Ju ly 30, 1976. A po rtion of th is le tt e r 

reads as follo ws: "The D is tr ic t has no legal ob jection to the projec t 

as cu rrent ly planned so long as i t leads to bringing the subje ct 

boile rs in to compliance with D is tr ic t a ir pollu tion laws. Therefore, 

any measures, both inte rim and long term, which can be implemented to 

achieve such compliance should be undertaken as soon as po ss ible."
79

41. QUESTION: The National Ca pitol Planning Commission's response com- prises on ly suggestions but does not indica te appro val. Why not, 

and is such approval an tic ipated ?

ANSWER: The National Ca pitol Planning Commission in it s December 10, T974, le tt e r to GSA stated th a t the Commission "approved the pr elim in ary s it e and bu ild in g plans fo r the expansion and improve­ ment of the Central Heating Plant . . .w ith the recommendation th at the GSA, in the pre paration of fi n a l site and build in g plan s:

1. Obtain from the Redevelopment Land Agency a rig h t of en try in to the urban renewal tr a c t south of D Stree t to pe rm it 

truc k maneuvering; and

2. Design the fa c il it ie s along the ra ilr oad sid ing so as no t to preclude a ir space build in g development over these fa c il it ie s 

and access to D Stree t.

The 2 recommendations re fe r to the paper handling fa c il it y which has been delete d from the prospectus and the proposed pro je ct. Approval o f fi n a l site and build in g plans fo r th is pr oje ct w ill be sought from the Commission at it s August 5, 1976, meeting.

42. QUESTION: Why wasn't release of the Fin al Environmental Impact Statement withhe ld u n ti l a ll approvals had been given?

ANSWER: The Environmental Impact Statements were w ritten in accordance with the Council on Environmental Qua lity Guide line s. The Dra ft Statement was dis tr ib u te d to oth er Government agencies, the A-95 clearing-ho use designee, and the publ ic. The Dra ft Statement was revised, takin g in to account the substan tive comments rece ived , and was then published as a Final Statement. I t is not po ssible to include concurrences on the revisio ns to the Dra ft Statement and the Final Statement in the Final Statement. There is nothing in the Guidelines to in dic ate th at approvals are requested from ot he r agencies on any statem ent. The Nation al Ca pitol Planning Commission indica ted th at they would not gra nt fi n a l approval of the pro je ct unless 30 days had passed since pu blish ing the Final Statement.
80

G enera l S e rv ic e s A d m in is tr a ti o n 

C en tr a l H eati ng P la n t - E nvir onm enta l Q uest io ns 

J u ly 12 , 1976

This p e rta in s to th e l a t e s t s e t o f q u e sti o n s re c e iv e d from th e Senate 

P u b li c Works Co mm itte e w it h re sp o n se s fro m G ener al S e rv ic e s A d m in is tr a ti o n 

T his data concern s e n v ir o n m en ta l a sp e c ts only an d do es n o t a d d re ss th e 

m a tt e r o f th e ne ed to accom pli sh c e r ta in work because o f th e ag e an d 

u n r e l i a b i l i t y o f b o ile r s an d a s s o c ia te d eq uip m en t. The o v e r a ll pla n 

re m ain s, th a t o f e i t h e r in s t a l l i n g new eq ui pm en t in th e C e n tr a l H ea ting 

an d R e f rig e ra ti o n P la n t, a s w e ll as in th e West H eati ng P la n t, o r o th e r 

m ea su re s must be ta k e n t h a t wo uld en ab le th e s e p la n ts t o use th e mos t 

a v a ila b le f u e ls , comp ly w it h n a ti o n a l la w s, an d d e a l w it h envir onm enta l

co n ce rn s.

The f iv e q u e sti o n s r e f e r r e d to a re l i s t e d w it h an sw er s in th e o rd e r 

o f t h e i r p re s e n ta ti o n .
81

Que stion 1. Could you id e n ti fy th e s p e c ific de sign ad ju st m en ts th a t have

be en made to in su re th a t th e bu rn in g of so li d wa ste fu e l

( e ith e r as a dry fu el or a f t e r co nve rs io n to o i l or gas )

would no t in te rfe re with th e f u l l e ff ic ie n c y of th e p o ll u ­

tio n con tr o l equ ipm ent and would no t le ad to corr o sio n of

th e b o il e r, pip es or o th e r p a rts of th e syste ms?

Re spon ses: Althou gh so li d was te fu e l is no t a p a rt of th is pro sp ectu s,

th e b o il e rs and p r e c ip ita to rs are s p e c ific a lly de sign ed to f ir e

co al, o i l , gas , and mac erated pa pe r. The pa pe r must be

fire d in co nd uc tio n w ith anoth er fu e l (20% or le s s paper) .

Due to th e natu re of f u e ls #

bu rn ing of co al and p re c ip it a ti o n

o f co al ash is th e b asic co n sid era ti o n among th ese fuelsWhen th e de sign han dle s c o a l, th en o i l , gas , and pa pe r

are au to m ati call y co ve re d.

A ll Sol id wa ste fu e l w ill be ca rb on or hy dr o/ ca rb on based

with th e su lf u r co nte nt c o n tr o ll e d . The p re c ip ita to rs a re

de sign ed to be oper at ed a t ele v ate d te m per at ure s which pre ­

cl ude co nd en sa tion and in h ib it corr osi on. The a i r p re h eate r

ha s co rr osi on r e s is ta n t co n str u cti o n on th e co ld en d. Under

th ese condit io ns no in c re a se in corr osio n w il l oc cu r.
82

Q uest io n 2 . The W as hin gto n, D.C. a re a has a s u b s ta n tia l a i r p o llu tio n prob le m 

ca us ed by h ig h le v e ls o f o x id a n t. The o x id a n t i s form ed fro m th e 

co m bin at io n o f h y d ro c a rb o n s, n it ro g e n o x id e s an d s u n lig h t. In 

a d d it io n , NO2 i s a p o llu ta n t re g u la te d under th e C le an A ir Ac t 

in dependen t o f i t s c o n tr ib u tio n to th e fo rm ati o n o f o x id a n t.

Ta bl e X I, pa ge 25 o f th e appen dix D o f th e D ra ft E nvir onm enta l 

Im pact Sta te m ent in d ic a te s th a t in some a re a s th e e m is si o n s from 

th e new p la n t wou ld u se up 77% o f th e a v a ila b le a i r q u a lity un de r 

th e n a ti o n a l am bie nt a i r q u a lity sta n d a rd s ev en i f i t were assum ed 

th a t a b s o lu te ly no NO2 o th e r th an th e powe r p la n ts em is si o n s we re 

c o n tr ib u te d to th e a r e a . Sin ce th e h e a tin g p la n t is lo c a te d ver y

c lo se to two la r g e m ajo r com mu ting r o u te s , t h i s i s n o t an a c c u ra te

ass u m p ti o n .

Given th e s e ’p o te n tia l a i r p o llu tio n pro ble m s an d th e f a c t th a t co nt r o l o f n it r o g e n o x id e s w ill ne ed to be em ph as iz ed in th e fu tu re beca us e o f th e p ro je c te d gr ow th tr e n d s fo r t h i s p o llu ta n t in a l l a re a s 

o f th e c o u n tr y , i t wou ld be very u s e fu l to ha ve th e F e d e ra l govern ­

me nt le a d th e way in th e ad o p ti o n o f te c h n iq u e s f o r th e c o n tr o l o f 

n it ro g e n o x id e s . I wou ld a p p re c ia te havin g you c o n ta c t th e Envir onm en ta l P r o te c tio n Ag ency an d g a in t h e ir s u g g e s ti o n s as to th e way 

in which th e b o i l e r d e sig n and p o llu tio n c o n tr o l sy st em s m ig ht be 

m odif ie d so as to u se te c h n iq u es which w ill m in im iz e th e re d u c ti o n 

o f n it ro g e n o x id e s e m is sio n s to th e e x te n t f e a s i b l e .

R es pons e: Some N0x

 o c cu rs n a tu r a l l y in c o al and o i l an d t h i s w ill si m pl y go

th ro ug h th e b o ile r un ch an ge d and be p u t ha ck in to th e en vir onm ent.

Hi e re m ain der o f N0x

 i s a s s o c ia te d w it h co m bust io n and is forme d a t
83

h ig h flam e te m p e ra tu re s. The b o i l e r s a re desi gned w it h th e 

l a r g e s t fu rn ac e volum e which w i l l f i t th e sp ac e a v a ila b le , p ro ­

v id in g re a so n a b le h e a t re le a se /C U F t . T his p lu s th e fu rn ac e w a te r 

w a ll tu b e h e a t a b so rp ti o n c o n tr o ls flam e te m p era tu re so N0x

 i s m in ­

im al .

The b o ile r s a re h e a ti n g o rie n te d w hi ch means th e f u l l h e a t r e le a s e 

c o n d it io n i s sp o ra d ic and u n d er w in te r w eat her c ir c u m sta n c e s. The 

no m in al lo a d s th ro ughout th e y e a r w i l l be a t le s s e r h e a t r e le a s e cont d itio n s and a t re duced N0x

 fo rm a ti o n .

The b o ile r s w ill ha ve C>2 m o n it o rs an d 0£ d e v ic es (c o n ti n u o u s /r e c o rd - 

in g ) whi ch w ill c o n tr o l th e am ount o f excess a i r wh ich is a c o n tr o l 

o f th e am ount o f NO*. T his e x c e ss a i r w ill be h e ld a t a minimum 

p ro ducin g th e minimum N0x

 p o s s ib le .

The EPA has be en c o n ta c te d an d th e on ly in fo rm a ti o n 

g iv en was t h a t GSA mus t mee t th e new so u rc e sta n d a rd 

f o r N0x

 (4 0 CFR 6 0 ). I f b o i l e r m an ufa ct ure 's m ee ts th e s e 

re q u ir e m e n ts , th ey mee t th e EPA re q u ir e m e n ts and

rec om me nded a c tio n .
Q u est io n 3 : The C e n tr a l H eati n g P la n t is lo c a te d w it h in a few b lo c k s o f

th e Thomas J e f fe rs o n M em orial an d th e W as hing ton Monument. The re d u c ti o n of

p a r tic u la te m a tt e r, and e s p e c ia lly th e re d u c ti o n o f fin e p a r t i c u l a t e m a tt e r, 

w i l l p la y a r o le in im pro vi ng th e v i s i b i l i t y o f th o se h i s t o r i c a l s i t e s fro m 

th e su rr o u n d in g a re a s . T his i s an im p o rt an t i n t e r e s t fo r th e to u ri st* w h o

v i s i t W as hi ng to n, DC.

Co uld you p le a s e in v e s tig a te th e advanta ges an d d is a d v a n ta g e s 

o f u sin g p o llu tio n c o n tr o l equip m en t o th e r th a n e l e c t r o s t a t i c p r e c ip ita to r s

(s uch as bag house s) wh ich m ig ht hav e a g r e a te r ch an ce o f c o n tr o llin g more

p a r tic u la te em is si ons an d e s p e c ia lly c o n tr o llin g th e fin e p a r t i c u l a t e

em is sio n s and p ro vid e us w it h a d is c u s s io n o f th a t in v e s tig a tio n ?

R es ponse : I n i t i a l l y , two ty p e s o f P a r ti c u la te Rem oval Sy stem s ha d be en

c o n sid e re d fo r th is p r o je c t, i . e . , e l e c t r o s t a t i c p r e c ip ita to r s and fa b ric 

f i l t e r s u n its . C o n sid e ra ti o n o f p a r tic u la te rem ov al sy st em s h a s be en li m it e d 

to h ig h e f f ic ie n c y ty p e equip m ent.

a . B ag ho us es . To a ch ie v e and m a in ta in h ig h e f f ic ie n c y c le a n in g o f . 

th e flu e g a se s , th e sy st em m us t be d esi gned w it h a low a i r - t o - c l o t h r a t i o . 

The re q u ir e m e n ts fo r a bag ho use o f t h i s s iz e , app ro x im ate ly 36 f t . by 44 f t . 

would be d i f f i c u l t to accomm odate w it h in th e sp ac e a v a ila b le a t th e C en tr a l 

P la n t. A d d it io n a ll y , s e p a ra to rs a re re q u ir e d ah ea d o f th e f i l t e r s fo r hig h 

e f f ic ie n c y c le a n in g .

(1 ) Flu e g ase s fro m o i l f ir e d b o ile r s te n d to c lo g th e f i l t e r

medium p o re s re q u ir in g mo re fre q u e n t ba g re p la c em e n t.
(2 ) The dan ger o f f i r e s a t e le v a te d te m p e ra tu re s (4 50 °F ) is 

g r e a te r th an w ith p r e c ip ita to r s .

(3 ) O pera ti on an d m ain te nance c o s ts a re e xpecte d to be h ig h e r th a n 

fo r p r e c ip ita to r s . C a p it a l c o s ts a re expec te d to be com para ble . (S ee J o u rn a l 

o f A ir P o ll u ti o n C ontr ol A s s o c ia ti o n Dec. 19 75 . Per fo rm an ce an d c o s t 

co m pari so n be tw ee n F a b ri c F i l t e r s and A lt e rn a te P a r ti c u la te C o n tr o l 

T e c h n iq u e s.)

(4 ) Ba ghouses mu st be h e a te d d u ri ng b o ile r sh ut do wns to p re v e n t 

fo u li n g and f a ilu r e du e to m o is tu re .

(5 ) Ba ghouses re q u re g r e a te r fa n hors epow er th a n p r e c i p i t a t o r s .

(6 ) To m a in ta in a 99.5 p e rc e n t p a r tic u la te c o lle c ti o n e f f ic ie n c y 

w h il e in je c tin g a d d it iv e s (l im e , n a h c o lite ) to p r o te c t th e fa b r ic med ia 

would re q u ire d e si g n in g fo r a low a i r - t o - c l o t h r a tio n ( 3 :1 ) .

(7 ) A hig h in c id e n c e o f ba g f a ilu r e and fo u li n g due to m o is tu re , 

s u lf u r o x id e s, and o th e r fu e l ash co mpo ne nts w ill r e q u ir e fre q u e n t sh utdo wn 

o f f i l t e r i n g comp artm en t an d c o n ti n u a l and expensi ve m ain te nance.

b . P a r tic u la te S c ru b b e rs . P a r ti c u la te scru b b ers a re a p o s s ib le . 

p o llu tio n c o n tr o l devic e f o r b o i l e r s and a d is c u s s io n o f such eq ui pm en t 

i s in c lu d e d . A scru b b er is a d e v ic e wh ich uses a liq u id to s e p a ra te p a r t i c u ­

la t e s from a ga s st re am . The v e n tu r i scru b b er i s commonly .u se d to a ch ie v e 

h ig h p a r tic u la te remov al e f f i c i e n c i e s (99 + p e rc e n t). Dus t re m ov al is 

p rim a r il y a fu n c ti o n o f th e energ y con sum ed to achie ve d u s t to l iq u id c o n ta c t 

R equir ed c o n ta c t is achie ved by p a ss in g li q u id and d u s t th ro ugh an o r i f i c e 

o r v e n tu r i th r o a t, wh ere th e v e lo c ity is d ra m a ti c a ll y in c re a s e d , and 

c o lle c ti o n e ffic ie n c y is p rim a r il y a fu n c ti o n o f p re s s u re dr op a c ro ss th e

s c ru b b e r th r o a t.
Ve ry few s c ru b b e rs ha ve be en us ed fo r p a r tic u la te c o n tro l a lo n e. 

T h e ir c h ie f advan ta ge is t h a t th ey ca n be d esi gned fo r both p a r tic u la te and 

gas eo us p o llu ta n t re m oval. . A lthough hig h

e f f ic ie n c y c o lle c tio n o f p a r t i c u l a t e i s f e a s ib l e , p a r t i c u l a t e re m ov al by 

sc ru b b er d e v ic es is n o t rec omme nde d fo r th e CHP b ecause:

(1 ) At 9 9.5 p e rc e n t p a r tic u la te re m oval, th e o p e ra ti n g p re s su re 

dro p o f a v e n tu r i s c ru b b e r could be as h ig h as 60 in ch es o f w a te r.

(2 ) O p e ra ti n g c o s ts fo r th is d e v ic e a re g e n e r a lly 2 to 3 tim es 

h ig h e r th a n th o se o f f a b r ic f i l t e r s and e l e c t r o s t a t i c p r e c i p i t a t o r s .

(3 ) Sp ac e re q u ir e m e n ts fo r scru b b er mo du les and w ast e w ate r 

tr e a tm e n t and re c y c lin g a re g r e a te r th a n o th e r p a r tic u la te c o n tr o l a lte r n a tiv e

(4 ) W itho ut a d d itiv e in je c tio n , c o rro s io n o f th e sc ubber would occu r

(5 ) A bra si on i s a m ajo r pr ob le m in p a r tic u la te sc ru b b e rs.
87

Qu estio n

Qu es tio n

Res ponse :

4. On May 17, Mr- W illiam W. Sa ye rs of th e Gen eral S erv ic es 

A dm in is tr at io n re ce iv ed a l e t t e r from Dr- B ailus Wa lker, J r - , 

D ir ecto r of th e Bureau of A ir and Water Q ual ity C on tr ol of th e 

Government of th e D is tric t o f Colum bia- Tha t l e t t e r lis te d 

e ig h t sp e c if ic ste p s which co ul d be ta ke n im mediat ely to 

re du ce th e p o ll u ti o n from th e c e n tr a l hea ting p la n t. Could 

you ex pla in ste p s you are ta kin g to comply w ith th ese re q u ests 

o r i f such st eps are no t bei ng ta ken , expla in why you have 

ch os en to r e je c t th ese su ggest io ns?

a- Co nv ertin g th e b o il e rs to a com plying grad e of o ilTh ere is no need to us e any gr ad e of fu e l o th er th an th a t 

bei ng use d a t pre se ntIn Answ ers to In te rro g a to rie s Pro posed by Defen da nts (Se con d 

S e t) , th e D is tr ic t o f Columbia s ta te s th a t i t does no t hav e 

s u ffic ie n t in fo rm at io n to s ta te th a t th e o il f ire d b o il e rs 

a t th e C entr al and West p la n ts a re in ca pab le o f me eti ng 

a p p li cab le D is tric t a i r p o ll u ti o n law s- Also, th a t no 

gr ad e of o il lig h te r th an number 6 fu el o i l ne ed s to be 

bu rn ed .

As of th is da te th e ev id en ce from st ack te s ti n g co nd uc ted 

in d ic a te s th a t a l l o i l f ire d b o il e rs are in co mplianc e when 

bu rn in g No- 6 o il- Ref er en ce R ese arc h -C o tt re ll P a rtic u la te 

Tes t Survey of u n it s 3 and 4, C en tr al He ating P la n t da te d 

March, 1976 ; P a rtic le Data L abora to ri es, LTD., West Hea ting 

P la n t B oil er 3, GSA Or der No- 01692514, da te d Octob er 8, 1975;
88

an d P a r t i c l e Data L a b o ra to rie s , LTD., We st H eati ng P la n t 

B o il e rs 4 an d 5, date d May 12, 19 75 .

The new p r e c i p i t a t o r s numb ers 3 an d 4 a t th e C e n tr a l p la n t 

were in com pliance by a c o m fo rt ab le m arg in . The re novate d 

p r e c ip ita to r s nu mbe rs 3 an d 5 a t th e West p la n t, which a re 

id e n tic a l u n its , had p h y s ic a l c o n s tr a i n ts a t th e ti m e o f th e 

t e s t i n g . Ho we ver, th e r e s u l t s ta k e n co m p o sit ely in d ic a te 

co m plian ce in a l l ra n g e s. S p e c if ic a lly , No. 5 f a ile d a t 

hig h lo ad (1 7 5 ,0 0 0 pp h) an d No- 3 f a ile d a t low lo ad 

(a b o u t 65,0 00 p p h ). S ub seq u en tl y , i t was d is c o v e re d th a t 

hig h v o lt a g e i n s u la to r s were cra cked in numb er 3 an d 5 in d ic a ti n g th a t th e b o ile r s wo uld comp ly i f te s te d w it h new b ru sh ­

in g s.

I t i s e sti m a te d t h a t i t wo uld c o s t $1 75,0 00 to make th e 

n e c e ssa ry a l t e r a t i o n s to B o il e rs No. 3 an d 4 a t C e n tr a l p la n t 

and B o il e rs No. 3 an d 5 a t West p la n t to c o n v e rt the m to bu rn 

a l i g h t e r g ra d e o f f u e l.
89

Q uest io n b. O p e ra ti n g co mplying b o ile r s to th e maximum e x te n t p o s s ib le . In ­

s t a l l n e c e ssa ry eq uip m en t, to en ab le B o il e rs No. 3 an d 4 to o p e ra te a t maximum lo ad .

R es po ns e: Co mp lying b o ile r s a re bein g o p e ra te d to th e maximum e x te n t p r a c t i c ­

a b le . B o il e rs No. 3 an d 4 a t th e C e n tr a l P la n t w i l l ha ve a d eq u a te 

w a te r tr e a tm e n t in s ta lle d to e n ab le th e ir o p e ra ti o n a t maximum lo ad

a s so on as p ro je c t a u th o r iz a tio n by C on gr es s an d o p e ra ti n g c o n d itio n s p e rm it . The p r o je c t i s d esi g n ed to i n s t a l l s ix Z e o lite W ater 

S o fte n in g U n it s (c o st o f s ix u n i t s now on ha nd was ab o u t $ 2 7 0 ,0 0 0 ). 

E sti m a te d c o s t to i n s t a l l w i l l be about $700,0 00. T his work i s 

n e c e s s a ry p r io r to o p e ra ti n g th e b o ile r s ab ov e on e h a l f lo ad b e ­

cau se zero p a r ts per m il li o n w a te r h ard n e ss i s re q u ir e d by th e 

b o i l e r m a n u fa ctu re s. Any w a te r h a rd n e ss ab ov e zer o c a u se s s c a li n g 

o f th e w a te rsid e o f th e b o i l e r tu b s wh ich could u ltim a te ly s e v e re ly 

damage th e b o ile r s . E x p eri en ce sho ws th a t we re m ai n in a s a fe 

ra nge an d do n o t e x c e s s iv e ly s c a le th e b o ile r s when o p e ra ti n g a t 

h a l f d esi gned lo a d . We d a re n o t in c re a se t h is f i r i n g r a t e .

B o il e rs 3 and 4 ha ve g e n e ra te d s u lf u r ic a c id a t lo a d s lo w er th an 

150 ,0 00 pp h. C u rr en t summer lo a d s avera ge 17 5, 00 0 pp h. We d a re 

n o t o p e ra te th e se p a r tic u la r o i l f ir e d b o ile r s because th e y a re 

n o t y e t r e l i a b l e o p e r a tio n a lly (c an su dden ly go o f f - l i n e w it h an 

im m ed ia te lo s s o f stea m g e n e ra tin g c a p a b ilit y ) and because we

can n o t kee p one or both o i l f i r e d b o ile r s o n -li n e lo w er th an 

150 ,0 00 pph bec au se of th e s u l f u r i c a c id g e n e ra ti o n c a p a b ilit y .

75-602 0 - 76 - 7
Q uest io n c : B ef ore non-c om ply in g b o ile r s a re u se d , st ea m su p p li e d sh ou ld 

be re d u c ed p r o p o r ti o n a te ly to ea ch b u il d in g su p p li e d by th e 

p la n t.

R es po ns e: T her e i s no f e a s ib le me tho d a t th e st ea m p la n t whereb y stea m ca n 

be re du ce d p r o p o r tio n a te ly to ea ch b u il d in g s u p p li e d . The re aso n i s th a t 

stea m is su p p li e d to st eam re d u c in g s ta t io n s a t th e b u il d in g s a t o r ab ou t 

250 p s i. This p re s s u re i s re duced s e v e ra l ti m e s , th e f i r s t re d u c ti o n be tw ee n 

60 -8 0 p s i u s u a lly , w it h th e u lt im a te p re s su re u s u a ll y bein g 5 p s i. Any 

p re s su re se nse d by th e 5 p s i v a lv e a t o r ab ov e 5 p s i w ill r e s u lt in th e 5 p s i 

sy stem c o n ti n u in g to dem and st ea m , wh ich means th a t th e d is tr ib u tio n sy st em 

wo uld ha ve to o p e ra te lo w er th a n 5 p s i to lim it a l l b u il d in g s p r o p o r ti o n a te ly . 

T his is an im p o s s i b ility du e to p ip e s iz e s , i n a b i l i t y o f st ea m a u x ilia r ie s 

to fu n c ti o n under 175 p s i , i n a b i l i t y o f th e hig h p re s s u re d rip conden sa te 

lin e s to o p e ra te , an d many o th e r re a so n s . GSA has no c o n tr o l over th e 

25 p e rc en t st ea m dem and by o th e r th a n GSA o p e ra te d b u il d in g s .

The only me tho d o f lo ad c o n tr o l wo uld be to a n tic ip a t e th e demand and lo w er 

a l l b u il d in g te m p e ra tu re s by b u il d in g p ers o n n el v ia th e th e rm o sta ts in ad va nc e 

Due to lower b u il d in g te m p e ra tu re s, fo r ex am ple how much re d u c ti o n would be 

n e ce ssa ry in o rd e r to mee t an u n p re d ic ta b le w e ath e r c o n d it io n . T his me tho d 

would alway s be u n s a ti s f a c to r y .
Q u est io n d . E m is si ons from ea ch b o i l e r sh ould be co nt in uousl y m onit ore d by

R esponse:

i n s t a l l i n g s u ita b le m o n it o rin g eq uip m en t.

Em is si ons fro m c o al an d o i l f ir e d b o ile r s w ill be c o n ti n u o u s ly 

m onitore d by th e i n s t a l l a t i o n o f s u ita b le m o n it o ri n g eq uip m en t 

whi ch i s bein g p u rc h a se d . The D i s t r i c t o f Co lum bia h as n o t y e t 

in d ic a te d th e le v e l o f m o n it o rin g to be re q u ir e d by i t b u t th e se 

u n its w ill me et fe d e ra l re q u ir e m e n ts .

The i n s t a l l a t i o n o f m o n it o rin g eq ui pm en t i s e sti m a te d to be $1 60 ,0 00 

fo r se ven c o al b o ile r s an d $120 ,0 00 fo r fo u r o i l b o i l e r s , t o t a l ­

lin g $280,0 00 . E sti m ate d i n s t a l l a t i o n a tt a in m e n t d a te f o r f u l l 

im p li m en ta ti o n i s Ju ne 30, 19 77 .

The i n s t a l l a t i o n o f m o n it o rin g eq ui pm en t w ill n o t in th em selv es

re duce p o llu tio n .
92

Q uest io n e . Im med iate m ea su re s sh ould be i n s t i t u t e d to p re v en t d is c h a rg e of 

a c id ic w a te rs fro m th e c o a l sto ra g e a re a /c o a l tr a p s in to th e 

st orm d ra in s and se w ers o f th e D i s t r i c t o f Co lum bia o r in to

Rock Creek o r th e Potom ac R iv e r.

R es ponse : We a re e li m in a ti n g th e d is c h a rg e o f a c id ic w ate r to st orm se wer s 

and d r a in s . At th e C e n tr a l p l a n t , we a re a s c e rta in in g w het her o r n o t th e 

D.C . Go vernm ent w ill a ll o w th e c o n n e c ti o n to be in to a s a n ita r y se w er ra th e r 

th a n in to th e e x is tin g st orm d r a in . The a lte r n a tiv e a c tio n c onte m pla te d is 

to i n s t a l l p ip in g fro m th e sump to th e s lu ic e w ate r p ip in g w it h in th e p la n t 

whe re d ilu tio n w ill e li m in a te an y p o s s ib le tr a c e o f a c id c o n c e n tr a ti o n . The 

e sti m ate d c o st is $7,5 00. E sti m a te d com ple ti on d a te is Se pt em be r 3 , 1976.

At th e West p la n t, t e s t s in d ic a te co mplying w a te r. Ho wever, we w ill pump th e 

sump w ate r in to th e s lu ic e p ip in g a t an e sti m ate d $11,0 00. E sti m ate d 

co m ple ti on d a te is Se ptem be r 3 , 19 76.
93

Q uest io n i .

R es ponse :

Im m ed ia te m ea su re s sh ould be i n s t i t u t e d to p re v e n t th e d is c h a rg e 

o f a sh e s in to th e st orm d r a in s an d se w er s o f th e D i s t r i c t o f 

Colum bia o r in to Rock C re ek o r th e Potom ac R iv e r.

A p r o je c t i s un de rw ay th a t w i l l p re v e n t th e d is c h a rg e o f a sh e s by 

Ju ne 30, 19 77 . At th e West p la n t an e sti m a te d $327,4 16.0 0 w i l l 

i n s t a l l a w a te r c le a n in g sy st e m u s in g s e p e ra to rs . T his p r o je c t 

i s d e s ig n e d , fo rw ard ed to 3MCO, an d is a w ait in g a u th o r iz a tio n to 

p ro c e e d . At th e C e n tr a l P la n t, $283,8 96.0 0 fo r e s s e n t i a l l y th e 

same p r o je c t as a t West P la n t. T his ' p ro je c t i s desi g n ed an d is 

re a d y f o r is s u e f o r b id d in g p u rp o s e s.

The m os t c o s tly an d l e a s t d e s ir a b le s o lu ti o n i s to pump th e o v e rfl ow in to a h o ld in g ta n k an d t h e r e a f te r tr a n s f e r th e w a te r in to 

ta n k tr u c k fo r d is p o s a l. A p o te n tia l c o n tr a c to r e s ti m a te s a c o st 

o f bet w ee n $2 0.0 0 an d $40.0 0 p e r th ousa nd g a llo n s . An e x p erie n ce d 

vo lum e o f 60, 00 0 g a ll o n s on a l i g h t lo ad da y wo uld am ount to a 

c o s t o f $1 20 0. 00 p e r day. A heav y lo ad da y would a p p ro x im a te ly

d ouble t h is am ou nt.

A p ro d u c t new to us i s a c e n t r if u g a l scre e n c o n c e n tr a to r whi ch may 

remov e down to 60 ppm o f su sp ended s o lid s , th u s a ll o w in g u s to n o t 

i n s t a l l th e s e p e ra to rs m entioned abo ve, pro vid ed t h i s 60 ppm was 

d ilu te d by 100 p e rc e n t w a te r w it h o u t s o lid s . C ost could be $4 0,

000.0 0 in s t a l l e d .

The dry ash sy stem c o n te m p la te d by th e p ro s p e c u ts e s wo uld e li m in a te 

th e w a te r p o llu tio n pro ble m e n t i r e l y .
Que stion g- GSA should bum only good qual ity co al in i ts boil ers .

Response:

Coal samples should be ana lyz ed, pri or to being use d, to 

ensure th at th e co al meets the sp ecif ic ati ons.

The coal sp ec ifie d fo r GSA boil ers is of good quality as 

sup plied under th e terms of US Government procurement regul at io ns and is from same source as th at used by the D is tr ic t 

of Columbia. A procedu re has been es ta bl is he d th at w ill 

allow the anal ysi s of co al , p ri or to combustion by GSA, 

from both co al su pp lies to be eff ecti ve August 1, 1976- 

(>1«) Island Creek Coal Company w il l supp ly th e inform ation 

as to coa l co nten t fo r $70.00 per co al tr a in . (TWX giv ing 

content and ca r numbers).

(2) A si m ilar agreement is pending with the General Coal 

Company.

The D. C. Government nei th er te s ts nor re qu ires a te s t repo rt 

of the co al consumed by it-
95

Que stion h.

Respo nse :

The damaged steam tr an sm is sio n conduit s from th e West 

Hea tin g P la n t in th e v ic in ity o f th e E ll ip se in th e 

D is tr ic t of Columbia sh ou ld be im mediat ely re p air ed or 

re pla ced .

The a p p li c a b ility o f th is questi o n to th e m at te r a t hand 

is quest io nable . However, th e ste am li n e in th e v ic in it y 

o f th e E ll ip se w il l be re p a ir e d du ring th e week of 

Ju ly 12, 1976 , when th a t p a rt o f th e tr an sm is si on li n e can 

be ta ke n ou t of se rv ic e fo r nec es sa ry re p a ir s . I t is 

nec es sa ry fo r bo th C entr al and West p la n ts to be "on 

lin e " to be ab le to sh ut down th e E ll ip se steam lin e s .

We had th re e d efe cti v e ex pa ns io n jo in ts removed nea r to 

17 th S tr e e t in November, 197S a t a cost of $2 6,00 0. The 

work co ntem plated w ill be co mpleted by Ju ly 17, 1976 , a t 

a co st of $1 0,60 0. We co ul d not e ffe c t th e l a t t e r re p a ir s 

dur in g th e sp ri ng o f 1976 as pl an ne d, be ca us e of th e in ­

a b ility a t th a t tim e o f c e rta in val ves ot "h old ."

The re p a ir o f undergroun d ste am li n e s are a co nt in uo us 

main ten an ce pr oc ed ur e o f th e He ating Ope ra tion and 

Trans mission Ar ea. The ste am lin e s un der th e E ll ip se are 

in th e pr oc es s of re p a ir how eve r replac em en t of li n e se cti o n s 

i f re quir ed ca nn ot be made u n til bo th Steam p la n ts are in 

o p era ti o n . The re p a ir of un de rgroun d steam lin e s shou ld 

n o t be cove red in a pro sp ectu s fo r b o il e r p la n t m od ific atio n s but pro per ly in a pro sp ectu s fo r th e ste am tr an sm is sio n 

sys tem -
96

Q ues tion 5.

Re sp on se :

P le a se d is c u s s th e c o m p a ti b il it y o f th e w a te r p o llu tio n 

c o n tro l syst em yo u p la n to us e w ith th e p e rm it you a re 

to re c e iv e u nder P.L . 92 -500 ?

Th ere a re tw o sy st em s th a t a re pla nne d fo r i n s t a l l a t i o n as 

p a r t o f th e d e sig n co ver ed unde r th e p ro s p e c tu s fo r th e 

C en tr a l H eati n g P la n t- Both sy st em s a re n e c e s sa ry fo r 

com pliance w it h th e c o n d it io n s o f th e pro pose d NPDES 

p e rm it , ( e s ta b l is h e d by P-L - 92 -5 00 , F e d e ra l W at er P o ll u ti o n 

C o n tr o l A c t) .

(a ) A dry a sh a i r h an d li n g sy stem is d esi gned a s a p a rt 

o f th e tw o new M u lt i- F u e l B o il e rs . Thi s w i l l rem ove any 

p o s s i b i l i t y o f w a te r p o llu ti o n fro m th e o p e ra ti o n o f 

th e s e new b o i l e r s .

(b ) As an in te rim m ea su re , GSA w ill i n s t a l l eq ui pm en t 

fo r th e re m oval o f as h p a r t i c l e s fro m th e p re s e n t h y d ra u li c 

ash re m oval sy st em a t th e C e n tr a l H ea ting P la n t. This 

p r o je c t w i l l i n s t a l l eq ui pm en t wh ich w ill rem ove th e 

su sp en ded a sh p a r t i c l e s fro m th e h y d ru a li c ash remov al 

sy st em o v erf lo w t o th e st orm se w er . Thi s sy st em w ill be 

u i t l i z e d in c o n ju n c ti o n w ith th e two o ld c o a l f ir e d s to k e r 

b o ile r s t h a t w ill be p re sse d in to s e rv ic e to pr od uc e stea m 

d u ri n g c o n s tr u c tio n o f th e new m u lt i- fu e l b o i l e r s . P rese n t 

p la n s c a l l f o r th e i n s t a l l a t i o n an d o p e ra ti o n o f th e new 

eq ui pm en t p r i o r to Ju ne 30, 19 77 . Thi s eq ui pm en t w ill 

c le a n up th e w a te r d is ch arg ed fro m th e h y d ra u li c ash r e ­

moval sy st em to mee t th e re q u ir em en t f o r su sp en de d s o lid s 

c o n c e n tr a ti o n e s ta b li s h e d by th e pro pose d NPDES perm it fo r 

th e C e n tr a l H eat in g P la n t.
97

S e n a te M in o rity

HEARING MATERIAL 

WEST AND CENTRA!. HEATING PLANTS 

WASHINGTON, DC

QUESTION - 1

I am a d v is e d t h a t GAO b e l i e v e s t h a t wor k n e c e s s a r y t o 

m eet e n v ir o n m e n ta l la w s and r e g u l a t i o n s can be a c c o m p lis h e d 

w ith f a r l e s s mo ney th a n r e q u e s t e d in th e s e tw o p r o s p e c t u s e s . 

Wou ld you p l e a s e comm ent on t h i s c o n te n tio n ?

ANSWER

We do n o t kn ow w hat in f o r m a tio n GAO h a s to a r r i v e a t su c h 

c o n c lu s io n s o r w h at t h e i r e s t im a te d c o s t i s . H ow ev er , 

b a s e d on GSA e n g in e e r in g e x p e r t i s e a s w e ll a s re co m m e n d a ti o n s 

fr om c o n s u l ti n g f ir m s , th e tw o p l a n t s r e q u ir e th e f o llo w in g 

e q u ip m e n t t o e li m in a t e b o th a i r an d w a te r p o l l u t i o n :

CENTRAL HEATING PLANT

1. I n s t a l l tw o e l e c t r o n i c p r e c i p i t a t o r s 

E s tim a te d c o s t $ 1 .1 m i l l i o n

2 . I n s t a l l d ry a sh sy ste m

E s tim a te d c o s t $ 1 .1 m i l l i o n

TOTAL ESTIMATED COST $ 2 .2 m i l l i o n

WEST HEATING PLANT

1. I n s t a l l t h r e e e l e c t r o n i c p r e c i p i t a t o r s

E s tim a te d c o s t $ .6 m i l l i o n

2 . I n s t a l l d ry a sh h a n d lin g sy s te m

E s tim a te d c o s t $ 1 .4 m i l l i o n

TOTAL ESTIMATED COST $ 2 .0 m i l l i o n

GSA:<BS 6 -1 8 -7 6
98

QUESTION - 2

Wo uld you p le a s e b re a k o u t th e w or k n e c e s s a r y in e a c h 

p r o s p e c tu s t o p r o v id e e n v ir o n m e n ta l c o m p li a n c e an d w or k 

n eed ed f o r o t h e r r e a s o n s ? In e a c h p r o s p e c t u s , w h a t i s 

y o u r c o s t e s t im a te f o r wor k n e c e s s a r y t o co m pl y w ith 

e n v ir o n m e n ta l re q u ir e m e n ts ?

ANSWER

The e n v ir o n m e n ta l wor k r e q u ir e d h a s b een b ro k e n o u t i n 

o u r a n sw e r t o q u e s tio n Nu mb er O ne. Th e re m a in in g p r o ­

p o se d w or k t o m ee t ste am de m an ds o f th e p l a n t and t o 

e n s u re maxim um u se o f c o a l i s a s f o llo w s :

CENTRAL HEATING PLANT

1. I n s t a l l tw o m u l t i - f u e l b o i l e r s 

E s tim a te d c o s t

2 . I n s t a l l fe e d w a te r sy ste m f o r tw o 

new b o i l e r s

E s tim a te d c o s t

TOTAL ESTIMATED COST

WEST HEATING PLANT

1 . C o n v e rs io n o f tw o o i l b o i l e r s t o 

m u l t i - f u e l

E s tim a te d c o s t

2 . R e p la c e e l e v a t o r 

E s tim a te d c o s t

TOTAL ESTIMATED COST

$ 1 6 .1 m i l l i o n

$ 1 .8 m i l l i o n 

$ 1 7 .9 m i l l i o n

$ 6 7 7 ,0 0 0

$ 9 0 ,0 0 0 

$ 7 6 7 ,0 0 0

6 -1 8 -7 6
99

QUESTION - 3

Have these prospectuses been reviewed and approved by 

OMB?

ANSWER

OMB requires the submission of all prospectuses that are 

$10 m illion or more. Consequently, the prospectus 

for the Central Heating Plant was reviewed and approved 

by OMB prior to submission to the Senate Public Works 

Committee and the House Public Works and Transportation 

Committee. The West Heating Plant prospectus is less 

than $10 million and, therefore, did not require prior 

approval by OMB. However, a copy was sent to OMB 

simultaneously with submission of this prospectus to 

the Congress.

GSArUBS 6-18-76
100

QUESTION - 4

The v a r io u s ite m s in th e p r o s p e c tu s e s w i l l be pr og ra m m ed 

to be c o m p le te d w i t h in f i v e y e a r s . How lo n g do yo u e x p e c t 

w i l l be r e q u ir e d t o c o m p le te th o s e p o r t i o n s o f th e work 

w hic h w i l l p r o v id e co n fo rm an ce w ith a n t i - p o l l u t i o n co d es? 

W il l t h i s a s p e c t o f th e wor k be g iv e n p r i o r i t y ?

ANSWER

The a n t i - p o l l u t i o n wor k w i l l be g iv e n h ig h p r i o r i t y in b o th 

p r o s p e c t u s e s . P r o v id in g we o b ta in a p p r o v a l f o r th e C e n tr a l 

H e a ti n g P l a n t , i t i s p la n n e d to aw ar d a c o n t r a c t f o r th e 

e n t i r e D r o je c t by S ep te m b er o f 1976 w ith a c o n s t r u c t i o n 

c o m p le ti o n d a te o f 1979. Th e i n s t a l l a t i o n o f a new te m ­

p o ra ry w et a sh sy s te m sc h e d u le d f o r J u l y 19 77 w i l l e li m in a t e 

th e w a te r p o l l u t i o n p ro b le m u n t i l th e new m u l t i - f u e l 

b o i l e r s w ith th e new d ry a sh s y s te m go l i n e in th e f a l l o f 

1979. The a i r p o l l u t i o n p ro b le m s w i l l be m it i g a t e d by 

in s p e c t i o n o f th e c o a l s u p p lie d t o th e p l a n t t o e n s u re 

t h a t GSA r e c e iv e s th e q u a l i t y o f c o a l c o n t r a c t e d f o r . The 

f l y a sh p ro b le m w i l l be t o t a l l y c o r r e c te d wh en th e new 

m u l t i - f u e l b o i l e r s w ith p r e c i p i t a t o r s go on l i n e in th e 

f a l l o f 1979.

At th e W es t H e a tin g P l a n t , i t i s p ro p o s e d t o i n s t a l l on e 

p r e c i p i t a t o r and th e d ry a sh sy s te m in 19 77 and th e 

re m a in in g tw o p r e c i p i t a t o r s in 1978.

GSA” !tbS 6 -2 1 -7 6
QUESTION - 5

W il l th e wo rk p ro p o s e d in t h e s e tw o p r o s p e c t u s e s p r o v id e 

c o m p le te c o m p li a n ce w it h e x i s t i n g D .C . an d F e d e r a l 

e n v ir o n m e n ta l s t a n d a r d s ?

ANSWER

Th e wor k p ro p o se d u n d er t h e s e tw o p r o s p e c tu s e 's w i l l p r o v id e 

f o r c o m p le te c o m p li a n c e w it h e x i s t i n g D .C . an d F e d e r a l 

e n v ir o n m e n ta l s t a n d a r d s .

QUESTION - 6

W i ll t h i s wo rk p r o v id e an y c o s t s a v in g s in te rm s o f e n e rg y 

u t i l i z a t i o n o r f u e l e x p e n d it u r e s ? W ill f u e l e f f i c i e n c y be 

im p ro ved ?

ANSWER

Th e tw o p r o s p e c tu s p r o j e c t s w i l l p r o v id e GSA '•w ith 

f o u r m u l t i - f u e l b o i l e r s c a n a b le o f b u rn in g a v a r i e t y 

o f f u e l s a v a i l a b l e now an d in th e f u t u r e . D ep en d in g 

on c u r r e n t c o s t o f v a r i o u s f u e l s , we ca n bu rn 

w h at b e s t s u i t s th e s i t u a t i o n . In t o d a y 's m a rk e t t h a t 

mea ns we w i l l u se c o a l a s th e m a jo r s o u r c e o f f u e l . In 

th e f u t u r e , s y n t h e t i c g a s , s y n t h e t i c o i l , s h a le o i l , 

d e r i v a t i v e s , e t c . may b e a v a i l a b l e a s f u e l . We 

c a n n o t f o r e t e l l th e f u t u r e c o s t o f an y f u e l , b u t 

we w i l l be a b le t o u t i l i z e th e m ost e f f i c i e n t f u e l a v a i l ­

a b le c o n s id e r in g e n e r g y c o n s e r v a t i o n , ec on om y o f o p e r a t io n s 

an d e c o l o g i c a l c o n c e r n .

F u e l e f f i c i e n c y w i l l be im p ro ved s i n c e th e e f f i c i e n c y o f 

th e new b o i l e r s w i l l be a p p r o x im a te ly 15% h i g h e r th an 

th e b o i l e r s b e in g r e p l a c e d .
102

Se na tor Morgan. Tha nk you very much . We will conclude th is 

hearing.

I here upon, at 10 :15 a.m., the subcomm ittee recessed, to reconvene 

subje ct to the call of the Ch air.]

O