this category and has failed to find such fault), one would be intellectually as well as legally, obliged to accept such findings. Cutler and Goldman attempted to lend the requisite aura of legitimacy and impartiality to their position through reference to findings of t h e Battelle Memorial Institute study, "The Impact of Railroad Freight Rates on the Recycling of Ferrous Scrap," by T. M . Barnes. I t is of interest in evaluating the weight to be given Battelle's study that D r . Cutler, even though employed as executive director of the Institute of Scrap Iron and Steel, was author of a significant portion of the study and was responsible for the transportation values referred to in the article in your magazine. I am attaching for your perusal a copy of the Battelle study, a copy of an article from the July/August 1970 issue of Waste Age magazine by Dr. Cutler, and a copy of m y comments on the Battelle study (which were written before I lea.rned that Cutler, not Barnes, had developed the transportation values). Several facts should be noted: 1) Much of Section B of the Battelle study is taken verbatim from the Waste Age article, without reference. 2) The technique and transportation values for Section C were supplied to Battelle by the Institute and used without attribution. I verified this fact in a telephone conversation with Mr. Barnes. 3) My comments demonstrate the erroneous nature of most of the transportation values used, and contain alternative values which reverse the results given in the Battelle study. I submitted my c o m ments to both Mr. Barnes and Dr. Cutler. M r . Barnes acknowledged my effort in the phone call mentioned earlier. D r . Cutler has not replied. Richard L. Lewis St. Louis-San Francisco Railway Co. St. Louis, Mo. 63101
More on DDT
Dear Sir: Robert M . Devlin, in his A Renaissance?" article, "DDT: ( E S & T . April 1974, p 3 2 2 ) , neglects to discuss one very important problem associated with the use of DDT-the problem of DDT resistance in insects. While the lives of millions o f human beings may have been saved by the use of DDT in the past, "the lives of millions of human beings" cannot continue to "depend on D D T , " as Dr. Devlin suggests they will, if the incidences of insect resistance continue to increase. I n a cursory search of the literature, I found that the American Chemical Society held a "Symposium on the Biochemistry of Insect Resistance" at the 165th ACS National Meeting, Dallas, Tex.. April 1973, and that
Robert L. Metcalf discussed DDT resistance in his review article on "DDT Substitutes" (Metcalf, R. L., "DDT Substitutes," CRC-Critical Reviews of Environmental Control. August 1972, p 2 5 ) . In this article, Dr. Metcalf cited many examples of DDT resistance in insect species, some of which have hampered m a larial control efforts. Resistant species include the housefly, Musca domestica: the human body louse, Pediculus corporis: the bedbug, Cimex lectularius: the German c o c k roach, Blatta germanica: the codling moth, Carpocapsa pomonella: the corn earworm, Heliothis zea: the cabbage looper, Trichoplusia ni. at least 19 species of culicine mosquitoes and at least 15 species of anopheline mosquitoes. DDT resistance in A. stephensi has resulted in malarial outbreaks in Iran, Iraq, and India. I n addition, Dr. Devlin discusses the problems of analyzing for DDT residues, particularly the possibility of PCB-contaminated DDT extracts. However, Dr. Devlin fails to mention the possibility that DDT can photodegrade to PCB through the intermediate dichlorobenzophenone (DCB) (Moilanen. K . W . . and Crosby, D.G., "Vapor-Phase Photodecomposition of p.p'-DDT and I t s Relatives," No. 21, Pesticide Chemistry Division, 165th ACS National Meeting, Dallas, Tex., April 9-13, 1973). Finally, Dr. Devlin states (paragraph 4) that "The only effective control of the tussock moth is DDT." I n the same E S & T issue in which Dr. Devlin's article appears, is published a letter from Bert Van Tassell of Nutrilite Products. I n c . Mr. Van Tassell claims that Nutrilite's tussock moth polyhedrosis virus and Biotrol XK (Bacillus fhuringiensis) achieved 99% and 95% control, respectively, of the tussock moth when applied aerially to forested land. The information that I turned up in one-half hour on the topics that Dr. Devlin addresses in his article leads m e to conclude that Dr. Devlin did not thoroughly research the topics h e reported on. In any future unbiased article o n DDT, the studies and claims that I mentioned should be presented and evaluated. Linda J. Gardiner Center for the Environment & Man, Inc. Hartford. Conn. 06120
Wet scrubber and sludge Dear Sir: I wish to clarify two items that appeared in the article, "The largest U.S. wet scrubber syst e m . " ( E S & T . June 1974. p 516). Radian Corp. does not have a scrubber sludge treatment process per se. We are under contract to the Electric Power Research Institute to examine the environmental acceptability of the surface disposal of scrubber
sludge. Further, in our work on the process design of limestone wet scrubber systems in conjunction with Joy Manufacturing Co., we have achieved better scrubber sludge-handling characteristics by virtue of process modifications. This is not a treatment process, however. Finally, Radian Corp. is not located in Dallas, but Austin, Tex. Donald M. Carlton, President Radian Corp. Austin, Tex. 78766 Four Corners
Dear Sir: Your one-sided cover story ( € S & T , June 1974, p 516) about the Four Corners pollution controls was akin to ascribing perpetual nemotion to the electric car-you glected to mention the batteries. I t is a delusion to imply the fine antipollution efforts being made by Arizona Public Service Co. have been selfstarting. Countless hours of effort by one, then a hundred, then thousands of citizens beginning in 1966 and later by state officials led to law suits, U.S. Senate investigations, and literally weeks of hard-fought regulatory hearings prior to where your story begins. The "moving target" APS c o m plains of largely resulted from their own efforts at these regulatory hearings to establish weak and ineffectual emission restrictions. At 1969 New Mexico hearings, power c o m panies spent one full day arguing that 97% control of fly ash was the best attainable at Four Corners. Dust emitted from the plant at 9 7 % cleanup would be over 100 tons per day, nearly the same tonnage of particulates as is emitted by all sources in Los Angeles. I t is not surprising that as soon as regulators discovered 97% was far from the best, the target was appropriately moved. APS's discussion of scrubber reliability also tells but half the story. To be sure. there have been problems with the scrubbers which, at least during shakedown, reduced the capacity factor of the units. However the capacity factor never got as low on units with scrubbers as it did during shakedown on the larger, newer units without scrubbers. According to APS data for the 12 months ending September 1973, the capacity factor for three units with scrubbers averaged 65.4%: the capacity factor for two units without scrubbers averaged 65.0% at Four Corners. Nobody likes malfunctions, but pollution control problems should be told in context with the other problems industry normally accepts without battle or fanfare. John R. Bartlit, State Chairman New Mexico Citizens for Clean Air & Water Los Alamos, N.M. 87544 Volume 8, Number 9, September 1974
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