transportation of scrap. We are not convinced that we should impose such a pricing scheme upon the railroads and the shippers they serve, even if, as seems very unlikely, we had the authority to do so. Robert L. Oswald, S e c r e t a r y Interstate C o m m e r c e C o m m i s s i o n Washington, D.C. 2 0 4 2 3 (This letter represents t h e informal v i e w of t h e writer, a s stated to C o n g r e s s m a n D o n Fuqua, and i s not binding o n this Commission.)
Dear Sir: The statements by Mr. Oswald reflect neither an understanding on his part of the Institute's position on discriminatory freight rates nor the facts and evidence presented to the Commission. Although space does not permit a thorough rebuttal, it must be noted that Mr. Oswald's portrayal of the Institute's position that freight rates discriminate against the movement of ferrous scrap simply by a "surface comparison of rates," is totally incorrect. lSlS has maintained that the relationship between rates on scrap iron and iron ore should be equitable which does no1 necessarily mean equal. The lSlS position is based on expert metallurgical testimony before the ICC that scrap iron competes directly with iron ore and therefore the rates should be equitable, that is, based on iron units contained in the competing products. To the Institute's knowledge, no creditable evidence has been submitted to the ICC which contradicts this statement and, in fact, the railroads' metallurgical witness in Ex Parte 281 agreed, under cross examination, that scrap iron and iron ore are "trade-off" items and as such obviously compete. l S l S is not asking the ICC to hold scrap rates at "depressed levels." In fact, the ICC, in an order served October 10, 1973, in Ex Parte 270 (SubNo. 6 ) , stated that, "the 1969 burden study discloses that iron and steel scrap is one of the top 20 positive revenue contributors for movements within Official Territory" while iron ore is shown "to be one of the top 20 deficit contributors to railroad net revenues." These results are undoubtedly influenced by gross inequities in the existing railroad freight rate structure. l S l S is not asking the ICC to hold down the rates on scrap iron so as to burden other commodities. Government statistics show that scrap iron is apparently subsidizing the move-
ment of other commodities. Evidence before the ICC has clearly established that scrap iron rates are disproportionately high and should be properly adjusted downward. Based on the record, there can be no other conclusion but that present railroad freight rates discriminate against and restrict the movement and recycling of scrap iron and steel, the major recyclable commodity, to the detriment of the environment. Gerald S. Goldman, D i r e c t o r of Transportation Institute of S c r a p I r o n and Steel, I n c . Washington, D.C. 20006
Dear Sir: The article "Transportation: bugaboo of scrap iron recycling (ES&T, May 1973, p 408)" was interesting. Reading the September Currents, which quotes a Council on Economic Priorities report that suggests a token interest by the steel industry in consumer-used scrap for steelmaking, I believe more is involved in the inability of the scrap industry to sell their product to the steel industry than transportation rates. Steel has a tremendous investment in iron ore mines and ore boats. Steel enjoys stable iron ore prices and low transportation rates, the latter of which is attainable through shipload and heavy unit train shipments. Conversely, steel has a very small investment in consumerused scrap. Shippers of recycled scrap ship from a great number of locations and in small quantities of freight cars. Scrap prices fluctuate and are not as stable as iron ore prices. I believe scrap iron recyclers will achieve marketing success only after they understand the heavy investment made by the steel industry in natural resources, provide a reasonably priced product in quantity to match iron ore costs when a steel manufacturer is considering new investment in natural resources and/or ships, and then prove to the railroads that they will ship heavy tonnages continuously from a recycling plant to a steel mill. All of the metallurgists you can muster before the ICC to plead a case of competition between iron ore and scrap iron are worthless if the steel industry cannot accept this in light of their heavy capital investment in natural resources, as well as an assured supply of resources at a steady and reasonable cost. Marcus S. Kostolich Akron, Ohio 44313
Electron has selected the condensation method of water vapor removal. Refrigerated systems are low in cost and commercially available, plus, the water which is removed from the gas stream is, then, available for analysis by a variety of instruments. Figure 1 i s an illustration of the Thermo Electron stack system for NOx/SOa. it consists of a Model 40 SO2 Analyzer, a Model 41 NO-NOx Analyzer, and the condensing Gas Conditioning System. Connected to this compact system is the heated line, terminated at its other end by the sintered stainless steel probe, inserted in the stack to be sampled. D. THE NO/NOx ANALYZER. The chemiluminescent reaction of NO and 0 3 provides the basis for this improved group of instruments, Specifically, NO + 03 -3 NO2 f Oz f hv. Light emission results when electronically excited NO2 molecules revert t o their ground state. The chemilurninescence i s monitored through an optical filter by a high sensitivity photomultiplier. The output from the photomultiplier is linearly proportional to the NO or NOx concentration. .p1-w*
E. THE SO2 ANALYZER. The reaction chamber of the Model 40 SOa Analyzer IS illustrated In Figure 2. A gas sample is submitted to a source of pulsed ultraviolet illumiriation through a monochromatic filter. Molecules of SOz, energized by the high intensity light source, emit a monochromatic illumination, which, through a narrow-band filter, impinges upon the sensitive surface of a photornultipller tube. The emitted light i s linearly proportional to the concentration of SOa molecules in the sample. These elements assembled as a NOx/SOz stack monitor provide a stable, linear, reliable method meeting the EPA Requirement for continuously monitoring stacks. Additional technical information is available from Thermo Electron for the interested user.
THERM0 ELECTRON CORPORATION Environmental Instruments Division 85 First Avenue Waltham, Massachusetts 02154 Telephone 61 i'/890-9700 Telex 92-3323 Circle NO. 9 on Readers' Service Card
V o l u m e 8, N u m b e r 1 , January 1974
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