PROPOSED NEW 35 ILL.ADM.CODE PART 225

LARGE COMBUSTION SOURCES

)

)

)

PCB R06-25

NOTICE OF FILING

To:

Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

Suite 11-500

100 West Randolph

Chicago, Illinois 60601

Persons included on the

ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that we have today filed with the Office of the Clerk of the

Pollution Control Board the

Testimony

of the following witnesses, copies of which are herewith

served upon you:

Peter M. Chapman, Ph.D.; Gail Charnley, Ph.D., and Attached Exhibits;

J.E. Cichanowicz; William DePriest and Attached Exhibits; James Marchetti; Richard D.

McRanie; Ishwar Prasad Murarka, Ph.D.;

and

Krish Vijayaraghavan

.

/s/

Kathleen C. Bassi

Kathleen C. Bassi

Dated: July 28, 2006

Sheldon A. Zabel

Kathleen C. Bassi

Stephen J. Bonebrake

Joshua R. More

Glenna Gilbert

SCHIFF HARDIN, LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, Illinois 60606

312-258-5500

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE JULY 28, 2006

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Page 1

PROPOSED NEW 35 ILL.ADM.CODE PART 225

LARGE COMBUSTION SOURCES

)

)

)

1.0 Qualifications

My name is Peter M. Chapman. I am an internationally recognized expert in the fields of

aquatic ecology, ecotoxicology, and environmental risk assessment, with particular

expertise and experience in the environmental fate and effects of metals including

mercury. I have published over 150 scientific journal articles and book chapters, written

over 200 technical reports, and made over 100 presentations at scientific meetings. I am

Senior Editor of the international peer-reviewed journal,

Human and Ecological Risk

Assessment

, a member of the Editorial Boards of two other international journals, editor

of a popular, on-going series of scientific discourses, and have held advisory

appointments with the National Research Councils of both Canada and the United States

as well as with the USEPA Science Advisory Board. In 2001 the Society of

Environmental Toxicology and Chemistry (SETAC) awarded me its Founders Award,

their most prestigious award for an outstanding career and contributions to the

environmental sciences. Since 1999 I have been part of the Natural Sciences and

Research Council (NSERC)-funded network of university researchers originally titled

“Metals in the Environment” [www.mite-rn.org] and now titled “Metals in the Holistic

Environment” [www.mithe-rn.org]. My role in the Network is to integrate the work done

by researchers and universities participating in the Network into a risk assessment

framework for decision-making. My specific focus in this regard is metals including

mercury in aquatic ecosystems. My curriculum vita is provided as Attachment 1.

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Page 2

2.0 Summary of Testimony

My testimony initially explains what happens to mercury when it is deposited from the

atmosphere or other sources into aquatic environments. I then evaluate the possibility of a

linkage between mercury emissions from coal-fired power plants in Illinois and mercury

in fish in Illinois waters related to lifting impaired water restrictions.

The basis for Illinois EPA’s proposed mercury rule is well summarized in the testimony

of Jim Ross at page 5: "A key concept in understanding the need and methods for

mercury control is that although mercury air emissions are the target for reductions, the

ultimate goal is to reduce methyl mercury levels in water bodies and, hence, fish tissue."

Accordingly, the focus of my testimony is this “key concept”; specifically, my testimony

answers the following two key questions:

Question 1:

Will reducing inorganic mercury emissions from coal-fired power plants in

Illinois under the proposed rule reduce organic (methyl) mercury concentrations in fish

living in water bodies in Illinois to the same extent?

Question 2:

Will reducing inorganic mercury emissions from coal-fired power plants in

Illinois under the proposed rule ensure that impairment restrictions can be lifted for

water bodies where fish have elevated mercury concentrations?

The answer to both of these questions, as my testimony clearly demonstrates, is “No”.

The goal of the proposed rule, as summarized in Marcia Willhite’s written testimony at

page 4 (“In order to assure that 95% of largemouth bass in Illinois waters may be

consumed in unlimited quantities by sensitive subpopulations, a 90% reduction of

mercury in fish tissue is needed”), will not be achieved.

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Page 3

3.0 Mercury in the Environment

The relationship between inorganic mercury emissions and organic mercury in the

environment including fish is complex

1

.

For instance, when mercury is emitted from

coal-fired power plants it is as an inorganic substance – typically elemental mercury

(Hg

0

), divalent mercury (Hg

2+

, also termed reactive gaseous mercury, or RGM), and

particulate mercury

2

, and can change form as it travels downwind

3

. Inorganic mercury is

also emitted from a wide variety of other sources including motor vehicles, incinerators,

crematoria, forest fires, deep sea vents, volcanoes, oceans, soils, etc

4

. Although estimates

vary, about half the mercury emitted to the atmosphere is natural, and about half is due to

human activities

5

. All states and countries have some level of mercury emissions; the

greatest current levels of human emissions appear to be from China related to its rapid

industrialization

6

.

Contamination due to mercury is a world-wide problem

7

.

Mercury in the atmosphere can be deposited onto land or water via either dry deposition

(e.g., dust) or wet deposition (e.g., rain, snow)

8

. Wet deposition can result in some forms

of mercury coming down closer to emission sources than others. But mercury deposited

to land or water may not remain there; mercury can be re-emitted back to the atmosphere

where it is transported further. For instance, Dr. Keeler (one of Illinois EPA’s witnesses)

and his co-workers have shown that re-emission of dissolved gaseous mercury from Lake

1

Eisler R. 2006. Mercury Hazards to Living Organisms. Published by Taylor and Francis, Boca Raton, FL,

USA.

2

Marcia Willhite’s verbal testimony on June 14, 2006: at page 32 of the transcript of that testimony.

3

Lohman K, Seigneur C, Edgerton E, Jansen J. 2006. Modeling mercury in power plant plumes. Environ

Sci Technol 40: 3848-54.

4

Eisler 2006, op. cit.; also, written testimony of Gerald Keeler at page 3, indicates that motor vehicle

sources contribute mercury to the atmosphere.

5

USEPA. 2005. Mercury emissions: The global context.

www.epa.gov/mercury/control_emissions/global.htm

; also, Landis MS, Vette AF, Keeler GJ. 2002.

Atmospheric mercury in the Lake Michigan basin: Influence of the Chicago/Gary urban area. Environ Sci

Technol 36: 4508-17.

6

Seigneur C, Vijayarghavan K, Lohman K, Karamchandani P, Scott C. 2004. Global source attribution for

mercury deposited in the United States. Environ Sci Technol 38: 555-69; also, Jiang G-B, Shi J-B, Feng X-

B. 2006. Mercury pollution in China. Environ Sci Technol 40: 3673-8; also, Gerald Keeler’s verbal

testimony on June 15, 2006: at page 17 of the transcript of that testimony.

7

Eisler 2006, op. cit.; also, Gerald Keeler’s verbal testimony on June 15, 2006: at page 17 of the transcript

of that testimony.

8

Dvonch JT, Graney JR, Keeler GJ, Stevens RK. 1999. Use of elemental tracers to source apportion

mercury in south Florida precipitation. Environ Sci Technol 33: 4522-7.

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Page 4

Michigan is a process that significantly reduces net atmospheric deposition

9

. In fact, Dr.

Keeler in testimony before the U.S. House of Representatives stated, “…previously

deposited mercury can also undergo chemical transformations that convert it back to the

elemental form that readily leaves the earth’s surface (land and water) to re-enter the

global background of mercury”

10

. Similarly, Illinois EPA’s Technical Support Document

(the “TSD”) mentions mercury volatilizing from water back into the atmosphere. Thus,

once mercury enters the atmosphere, it becomes part of a global cycle of mercury

among land, water, and the atmosphere; past activities continue to affect current

atmospheric mercury concentrations

11

.

The inorganic mercury that remains in water bodies (either from the atmosphere or from

other sources) can undergo different biological and physico-chemical processes (Figure

1). The mercury cycle is a complex biogeochemical system involving both biotic and

abiotic transformations of the different forms of mercury. Inorganic mercury species that

are not reduced to form gaseous elemental mercury have an affinity for particulates and

organic matter and thus will tend, if not re-emitted, to sink down to and accumulate in the

sediments. The sediments of water bodies thus serve as both a sink and a reservoir for

mercury contamination. They can also be a source of potential mercury pollution

12

.

Although most inorganic mercury remains in this form in the sediments, a portion

13

of

that mercury can be converted to an organic form of mercury, methyl mercury. This

conversion occurs primarily by metabolism within sulphate- and iron-reducing bacteria

living in anaerobic sediments, i.e., sediments without oxygen

14

. Mercury methylation

9

Landis MS, Keeler GJ. 2002. Atmospheric mercury deposition to Lake Michigan during the Lake

Michigan mass balance study. Environ Sci Technol 36: 4518-24; Vette AF, Landis MS, Keeler GJ. 2002.

Deposition and emission of gaseous mercury to and from Lake Michigan during the Lake Michigan mass

balance study (July, 1994 – October, 1995). Environ Sci Technol 36: 4525-32.

10

Keeler GJ. 2001. The problem of mercury. Testimony for the U.S. House of Representatives Committee

on Science Hearing on Acid Rain: The State of the Science and Research Needs for the Future. May 3,

2001.

11

Eisler 2006, op. cit.

12

Eisler 2006, op. cit.

13

Marcia Willhite’s verbal testimony on June 14, 2006 states “it has been estimated that .7 to .0006 percent

of total mercury in sediment is methylmercury”: at page 40 of the transcript of that testimony.

14

Fleming EJ, Mack EE, Green PG, Nelson DC. 2006. Mercury methylation from unexpected sources:

Molybdate-inhibited freshwater sediments and an iron-reducing bacterium. Appl Environ Microbiol 72:

457-64; also, Jeremiason JD, Engstrom DR, Swain EB, Nater EA, Johnson BM, Almendinger JE, Monson

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Page 5

generally cannot occur in aerobic (oxygenated) environments; in the water column it can

occur only when conditions are anoxic (there is no oxygen). Methyl mercury production

occurs not just in recently deposited surface sediments but also in much older, deeper

sediments where the mercury was deposited decades previously, even though “old”

inorganic mercury in sediments tends to be less biologically available than “new”

inorganic mercury in sediments

15

. Methyl mercury from these deeper sediments can reach

organisms living in shallower sediments by a process called diagenesis, which typically

occurs in sediments with low organic carbon content. There is a depth beyond which,

absent unusual disturbances, the mercury in the sediments will not reach animals or

plants, but burial to such a depth is typically a slow process under natural conditions. As

noted in the Florida study there is “slow mobilization of historically deposited mercury

from deeper sediment layers to the water column. Until buried below the active zone, this

mercury can continue to cycle through the system”

16

. Thus, even when emissions of

inorganic mercury are reduced, there will be a substantial lag phase before emission

reductions can result in reductions in methyl mercury concentrations in fish.

Production of methyl mercury in sediments is not a readily predictable process and can

be highly variable between water bodies

17

(Table 1). There is not a 1:1 relationship

between inorganic mercury released to the atmosphere and deposited in water bodies and

the level of methyl mercury found in water bodies and fish tissue. For instance, methyl

mercury produced in water bodies from inorganic mercury deposition can be augmented

by direct precipitation of methyl mercury from other sources, including: the atmosphere,

runoff from land, or inputs from other water bodies such as wetlands

18

.

BA, Kolka RK. 2006. Sulfate addition increases methylmercury production in an experimental wetland.

Environ Sci Technol 40: 3800-6.

15

Fleming et al. 2006, op. cit.

16

Florida Dept of Environmental Protection. 2003. Integrating atmospheric mercury deposition with

aquatic cycling in South Florida: An approach for conducting a total maximum daily load analysis for an

atmospherically derived pollutant: at page iii.

17

Marcia Willhite’s verbal testimony on June 14, 2006 notes that the characteristics that impact mercury

methylation are water body specific, can differ between water bodies, and that mercury methylation is

highly dependent on water chemistry and biology, in particular pH, dissolved oxygen, dissolved organic

carbon, nutrients, selenium concentrations, temperature, sulphate concentrations, drainage size to lake

volume ratio, percentage of wetland and watershed, conductivity and water level flucturations: at pages 45

to 47 of the transcript of that testimony. She made similar comments elsewhere in her verbal testimony:

e.g., at page 37 of the transcript of that testimony.

18

Eisler 2006, op. cit.

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Page 6

Example of Physico-Chemical Processes Affecting Mercury Methylation

Physico-Chemical Condition

Enhanced

↑

Decreased

↓

Low dissolved oxygen

Yes

Low pH

Yes

(in water)

Yes

(in sediment)

Increased dissolved organic carbon

Yes

(in sediment)

Yes

(in water)

Increased conductivity or salinity

Yes

Increased nutrients

Yes

Increased selenium

Yes

Increased temperature

Yes

Increased sulphate or sulphide

Yes

Point and non-point source discharges continue to contribute mercury to water bodies.

For example, Marcia Willhite notes at page 144 of the transcript of her June 14, 2006

verbal testimony, that runoff may be a significant source of mercury in southern Illinois.

Interestingly, at page 118 of the transcript of that same testimony, Ms Willhite notes that

historical data suggest that the levels of mercury in fish are higher than expected in

waters in the far southern end of the State.

The TSD indicates (at pages 68 and 69, including Table 4.7) that, at “maximum”

discharge levels, the 137 wastewater point sources in Illinois would discharge

approximately 1.5 tons of mercury per year compared to 45 pounds at an “average”

discharge level. Marcia Willhite confirmed in her testimony (June 14, 2006, at pages 288-

290 of the transcript) that the “maximum” load or discharge level was based on actual

measured maximum flow and maximum mercury concentrations in the flow, which

would comprise approximately 1.5 tons, or about half of the mercury air emissions from

coal-fired power plants as indicated in the TSD (3 tons at page 60). Other un-measured

sources of mercury exist including combined sewer overflows, which Illinois EPA does

not sample for mercury but which contain mercury

20

. Thus other local sources of mercury

19

Developed based on information contained in Eisler 2006, op. cit.

20

Available data on mercury related to combined sewer overflow discharges for the Metropolitan Water

Reclamation District of Greater Chicago reviewed by Dr. Chapman suggest that inputs can be on the order

of tens of pounds per year.

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Page 7

(as well as sources outside the State) will have inputs to different water bodies that likely

are, in some cases, greater than those from coal-fired power plants.

Similarly, production of methyl mercury in the sediments of water bodies is governed by:

microbial community composition, geochemical conditions that affect the activity of

methylating bacteria (e.g., availability of carbon, abundance of electron acceptors such as

sulphate), and availability of inorganic mercury in a suitable (bioavailable) form for

methylation. Availability of carbon and the cycling of sulphur are major constraints on

the process of mercury methylation. For instance, although sulphate is essential for the

methylation process, excessive amounts of sulphate can actually poison the mercury

methylation process by limiting the availability of mercury to methylating bacteria. The

key Florida study cited in the TSD notes, “Sulfate is an important influence on the

production of methylmercury, affecting not only mercury transformations, but also the

biological availability of mercury for uptake….[sulphate] is an important cofactor

controlling the severity of the mercury problem at any given site”

21

. Methyl mercury

concentrations in fresh water bodies in the U.S. may have increased historically due to

increases in atmospheric sulphate deposition.

Decreases in sulphate deposition alone,

with no change in mercury inputs, could result in lower methyl mercury levels in

freshwater fish

22

. It is thus entirely possible that reductions in sulphate deposition rates

resulting from the Acid Deposition Program were at least partly responsible for decreased

methyl mercury concentrations seen, for instance, in Massachusetts from 1999 to 2004.

In addition, demethylation can occur in sediments (Figure 2), also mediated by naturally

occurring microbes – possibly as a defense against mercury toxicity

23

. In most, but not all

anaerobic systems, mercury methylation rates are greater than demethylation rates.

However,

methyl mercury concentrations and production rates vary more than do

inorganic mercury deposition rates

. For instance, a simple change in bacterial activity

alone could “cause an increase in fish mercury concentrations even as atmospheric

21

Florida Dept of Environmental Protection 2003, op. cit., at page vi.

22

Jeremiason et al. 2006, op. cit.

23

Eisler 2006, op. cit.

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Page 8

deposition [from industrial mercury emissions] decreases”

24

. Thus there can be, for

instance, freshwater systems containing relatively high concentrations of inorganic

mercury but relatively low concentrations of methyl mercury because conditions are

either less than optimum for mercury methylation, or demethylation is the predominant

process. And the reverse can also occur. Thus, it is not surprising that the TSD reports

that Illinois lakes with the highest mercury concentrations were not the same lakes as had

fish with the highest mercury concentrations.

When the organic form of mercury, methyl mercury, is present in a water body, this

organic form can biomagnify through food chains via the diet. Biomagnification is the

process by which a few organic chemicals (methyl mercury is one, PCBs are another)

increase in concentrations through successive levels of the food chain as a result of

dietary uptake. Fish absorb methyl mercury when they eat smaller aquatic organisms.

Larger and older fish absorb more methyl mercury as they eat other fish. Aside from the

concentrations of methyl mercury in the water body and sediment, which depend on the

factors discussed above, the level of mercury contamination in fish can be affected by

factors such as changing water levels

25

and dissolved organic matter

26

. In this way, the

amount of methyl mercury builds up as it passes through the food chain. Methyl mercury

generally reaches the highest levels in predatory (piscivorous [fish-eating]) fish at the top

of the aquatic food chain.

Some of the highest recorded mercury levels found in fish are in marine fish such as tuna

and swordfish, which are commonly found in supermarkets in Illinois

27

. Mercury levels

are also higher in older than in younger fish because older fish have had more time to

accumulate higher levels of mercury. In fresh water environments piscivorous fish such

as walleye and northern pike, found at the top of the food chain, tend to have the highest

24

Mason RP, Abbott ML, Bodaly RA, Bullock OR Jr, Driscoll CT, Evers D, Lindberg SE, Murray M,

Swain EB. 2005. Monitoring the response to changing mercury deposition. Environ Sci Technol 39: 14A-

21A.

25

Sorensen JA, Kallemeyn LW, Sydor M. 2005. Relationship between mercury accumulation in young-of-

the-year yellow perch and water-level fluctuations. Environ Sci Technol 39: 9237-43.

26

Ravichandran M. 2004. Interactions between mercury and dissolved organic matter – a review.

Chemosphere 55: 319-31.

27

Burger J, Gochfeld M. 2006. Mercury in fish available in supermarkets in Illinois: Are there regional

differences. Sci Total Environment: in press.

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Page 9

mercury levels in their tissues. Most of the mercury in fish is in the form of methyl

mercury, which can be excreted by fish, but more slowly than inorganic mercury. Thus, if

fish are not exposed to new sources of methyl mercury in their diet they will begin to rid

themselves of the methyl mercury in their bodies. This is not a fast process, but it does

occur faster at higher temperatures than at lower temperatures

28

.

4.0 Mercury in Illinois Water Bodies and Fish

As noted at page 61 of the TDS “Mercury TMDLs are complicated. The mechanisms

controlling mercury accumulation in fish tissue are variable and difficult to model,

resulting in questionable values…sources may be outside the watershed, state or nation.”

However, the key issue related to the proposed rule is, as previously noted, the

relationship between inorganic mercury emitted from coal-fired power plants in Illinois

and organic (methyl) mercury in fish in Illinois waters.

As noted above, the pathway for inorganic mercury from the power plants reaching the

fish would be via atmospheric deposition into water bodies containing those fish. The

mercury would then have to accumulate in the sediments where some of it would be

transformed into the organic (methylated) form which would then accumulate in fish via

dietary uptake. Further, to have any possible health impact on an Illinois resident, that

resident would need to eat such fish. Whether or not consumption of fish with elevated

mercury concentrations will impact the health of human consumers requires

consideration of factors including the protective effects of selenium in tissues

29

.

The relationship between the power plant mercury emissions and mercury in fish in

Illinois can be assessed using two key pieces of information: sediment mercury data, and

fish mercury data. To obtain this information, Illinois mercury sediment and fish tissue

data for the past 30 years were downloaded from the USEPA’s STORET data base. The

specific focus was on waters where fish had total mercury concentrations above threshold

values of 0.1 and 0.23 ppm (mg/kg wet weight). The State of Illinois uses an initial

28

Eisler 2006, op. cit.

29

Raymond LJ, Ralston NVC. 2004. Mercury:selenium interactions and health implications. Seychelles

Med Dental J 7: 72-7.

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Page 10

threshold value of 0.06 ppm for advising no more than one meal per week of fish (range

of 0.06 to 0.22 ppm); however, because this value has been close to or below the

detection limits used by some chemical analytical laboratories, a value of 0.1 ppm was

used to provide more dependable data for comparison purposes

30

. Fish mercury values of

0.23 ppm and above are subject to the special mercury advisory

31

. Tables 2 and 3

summarize these data, and Figures 3 and 4 present these data in graphical form. The

mercury sediment concentrations were at times both higher and lower than the fish

concentrations.

Thus, there is no consistent relationship between total mercury

concentrations in sediments and mercury concentrations (primarily methyl mercury) in

fish tissues of impaired waters.

Power plant locations and Illinois impaired waters are also shown in Figures 2 and 3.

Exceedances of 0.1 and 0.23 ppm total mercury levels in fish were not always found at

sites in close proximity to power plants, nor were impaired waters always associated with

power plants. Moreover, given that the winds in Illinois are primarily south, southwest

and north, northwest in the winter

32

, emissions from power plants do not appear to be

responsible for all waters in Illinois impaired due to mercury (e.g., Rock River). Thus,

there is no clear and consistent relationship between Illinois coal-fired power plants

and methyl mercury concentrations in fish in Illinois waters.

This finding is not

unexpected given the complexity of the global mercury cycle. Although there is no

question that coal-fired power plants are significant sources of mercury to the

atmosphere, they are not the largest sources of mercury deposited in Illinois

33

. These

emissions cannot be directly related to mercury concentrations in fish collected from

30

Illinois EPA, in the TSD, assumes that if mercury is not detected, it is present at 50% of the detection

limits [cf Marcia Willhite’s verbal testimony of June 14, 2006: e.g., at pages 84-85 and pages 158-160 of

the transcript of that testimony]. However, this practice is questionable given that it means that mercury is

assumed to be present when it may not be. Better methods exist for dealing with values below detection

limits: e.g., Shumway RN, Azari RS, Kayhanian M. 2002. Statistical approaches to estimating mean water

quality concentrations with detection limits. Environ Sci Technol 36: 3345-53; also, Helsel DR. 2005.

More than obvious: Better methods for interpreting nondetect data. Environ Sci Technol October 15, 2005:

419A-23A.

31

Clarification regarding the 0.06 and 0.23 ppm mercury values was provided by Dr. Hornshaw in verbal

testimony on June 14, 2006: at pages 25 and 26 of the transcript of that testimony.

32

Gerald Keeler’s verbal testimony of June 15, 2006: at page 32 of the transcript of that testimony.

33

K Vijayaraghavan in his testimony at page 7 estimates “U.S. coal-fired power plants are calculated to

contribute 19% of mercury deposition in Illinois in 2006.”; also, see Section 3.0, page 4 of the present

document (Testimony of Peter M. Chapman)

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Page 11

nearby water bodies. Further, Illinois’ proposed rule would only result in a 4% reduction

in depositions in Illinois from Illinois coal-fired power plant mercury emissions

compared to the CAMR

34

, which would likely not result in a measurable decrease in

mercury concentrations in fish in Illinois water bodies compared to the CAMR. As noted

at page 3 of Gerald Keeler’s testimony, “The relationship between the emissions of

mercury to the atmosphere from any one plant and the amount received at any receptor is

complex.” Interestingly, as noted by Thomas Hornshaw in his verbal testimony of

June 16, 2006 (at pages 84-85 of the transcript), Illinois fish tissue mercury levels are

lower than in some other Great Lakes States.

The discussion above explains the “no” answer to Question 1 (Section 2.0). The

discussion below explains the “no” answer to Question 2 (Section 2.0).

The Illinois 2004 Section 303(d) List

35

was reviewed, to identify water bodies considered

impaired by the State due to mercury and/or PCB concentrations. Table 4

36

summarizes

these sites, listing water body name, site name, and whether the site is impaired due to

levels of mercury and/or PCBs. Fifty-five of the 74 sites (74%) in Illinois listed as

impaired due to mercury would continue to be impaired even if full compliance with the

proposed rule were achieved and the projected fish mercury reductions were achieved.

The presence of PCBs renders the proposed rule ineffective at removing impairment

restrictions. Thus, even if fish mercury levels were to drop below the State mercury

threshold for impaired waters, which is highly unlikely as noted previously, the

classification of these sites as impaired would not change.

5.0 Florida, Massachusetts and Ohio Studies: Relevance to Illinois

We have found no published studies that specifically evaluate coal-fired power plant

mercury emissions and trends in methyl mercury levels in fish. The TSD relies on data

from Florida and Massachusetts to support its conclusion that reducing local coal-fired

power plant inorganic mercury emissions will similarly reduce local fish methyl mercury

34

Testimony of K. Vijayaraghavan at page 7.

35

Illinois Environmental Protection Agency, IEPA/BOW/04-005.

36

Source: Appendix A of the IEPA 2004 document.

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Page 12

levels. A study in Ohio is also mentioned in testimony by IEPA witness Dr. Keeler,

however complete details of this study (i.e., the full report) have not been provided by

Dr. Keeler.

As noted in the TSD, Massachusetts has implemented mercury reduction programs, but

has not specifically focused on coal-fired power plants. The Massachusetts study

37

monitored mercury concentrations in Largemouth bass (LMB) and yellow perch (YP)

from 1999 to 2004. The authors noted at page viii that “Over this period consistent and

substantial statistically significant decreases in YP and LMB fish tissue mercury

concentrations occurred in most lakes sampled.” However, decreases did not occur in all

lakes (about 24% showed no decreases for YP and about 35% showed no decreases for

LMB), the level of decrease was variable, and there were some inconsistencies (e.g., at

page 7, “an apparent large temporal increase in tissue mercury concentrations between

1999 and 2004” in one lake and “a slight increase over the 1999 value” for 2004 fish

tissue data from another lake). It was estimated (at page viii) that mercury emissions in

the main deposition area identified in the TSD “decreased by about 87% between the late

1990’s and 2004 due to new pollution controls on municipal solid waste combustors

(MSWC) and the closure of medical waste incinerators (MWIs) and a MSWC in the

area.” But there was far from a 1:1 relationship between decreased emissions and

decreased methyl mercury concentrations in fish; in fact, the Massachusetts study

38

concluded that “…significant reductions from out-of-state mercury sources will likely be

needed to achieve water quality and public health objectives in Massachusetts.” The page

and a half in the TSD dedicated to the Massachusetts study provides an overly simplified

summary of this complex study, as does Marcia Willhite’s testimony.

Similarly, the TSD does not deal fully with the Florida study, which is a modeling study

that makes predictions that do not appear to be supported by available data. Marcia

Willhite, in her testimony, also simplifies the findings of the Florida study. Just a few of

37

Massachusetts Dept of Environmental Protection. 2006. Massachusetts Fish Tissue Mercury Studies:

Long-Term Monitoring Results, 1999-2004.

38

Massachusetts Dept of Environmental Protection. 2006. op. cit., at page viii.

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Page 13

the caveats noted at page v of the Florida study report include

39

: the major assumption

that all mercury deposited via wet deposition was from local sources which cannot be the

case given global cycling of mercury; the acknowledgment that mercury cycling cannot

yet be fully modelled; and the fact that different areas might respond differently due to

site-specific differences (e.g., different habitat, food web dynamics and water quality). Of

note, Figure 5.7 in the TSD is labeled “Relation between Atmospheric Mercury Load and

Body Burden in Largemouth Bass”, whereas in the original Florida study (Figure 9, at

page 40) it is labelled “Predicted Hg concentrations in age 3 largemouth bass as a

function of different long term constant annual rates of wet and dry Hg(II) deposition.”

The fact this is a prediction rather than reality is not mentioned in the TSD.

The actual field data reported in the Florida study do show some correlations between

reducing emissions and decreases in methyl mercury concentrations in some biota at

some locations, which is not unexpected. However, the actual data do not show a 1:1

relationship and in some locations show no correlation, which is also not surprising given

the simplifications made by the model which the authors of the Florida study

acknowledge but which the TSD does not mention. There are several examples in the

Florida study of differences between the 1:1 prediction and the reality. For example,

although emissions showed a declining trend from 1994 to 2000, mercury wet deposition

for this same time period remained relatively constant (Figure 24 at page 81 of the

Florida study report). The Florida study report at pages 81-82 assessed trends in mercury

concentrations in biota based on levels in Largemouth bass from 12 sites across Florida, 9

of which were in the Everglades and at least 3 of which were in the study area. There

were enough data in only a little over half of the available data sets to conduct statistical

tests for significance. The two sites with the most consistent declines are shown in the

TSD (Figure 5.5, basically the same figure as Figure 25, at page 83 in the Florida study

report). What is not mentioned in the TSD is that there were also examples of no declines

as well as of increases in fish methyl mercury concentrations. In fact, as noted in the

Florida study report (at page 81) and as confirmed by Gerald Keeler in his verbal

testimony on June 15, 2006 (at page 13 of the transcript), about half the cohorts in the

39

Florida Dept of Environmental Protection, op. cit.

---

Page 14

study area showed no change. The “bottom line” is that, although the Florida modeling

suggests a 1:1 relationship between inorganic mercury emissions and methyl mercury

concentrations in fish, this relationship is not supported by actual data and, given the

simplifications inherent in the model, is highly unlikely to reflect the “real-life” situation.

6.0 Conclusions

At the start of my testimony (Section 2.0) I asked and answered “no” to two key

questions, below:

Question 1:

Will reducing inorganic mercury emissions from coal-fired power plants in

Illinois under the proposed rule reduce organic (methyl) mercury concentrations in fish

living in water bodies in Illinois to the same extent?

Question 2:

Will reducing inorganic mercury emissions from coal-fired power plants in

Illinois under the proposed rule ensure that impairment restrictions can be lifted for

water bodies where fish have elevated mercury concentrations?

The reasons for my answers follow from my detailed testimony above. Reducing

inorganic mercury emissions from coal-fired power plants will result in a decreased level

of inorganic mercury deposition. However, even if reductions in mercury depositions

were to occur in Illinois, reductions in methyl mercury concentrations in local fish will

not occur to the same level as the emission reductions. Mercury is a global problem, not

just a local problem, and the pathways from inorganic mercury emissions to methyl

mercury in fish are complex and governed by site-specific differences that are not readily

predictable

40

. Generalizations such as a 1:1 relationship do not reflect reality.

The

amount of methyl mercury in fish is site specific, as confirmed by Marcia Willhite (see

footnote 18), and is not related simply to the amount of inorganic mercury that is

deposited to a water body.

Moreover, even if mercury levels in Illinois water bodies were

reduced below levels of potential concern, elevated levels of PCBs would still result in an

“impaired” designation for the vast majority of those water bodies.

40

Eisler 2006, op. cit.

---

Page 15

The goal of the proposed rule, as summarized in Marcia Willhite’s written testimony at

page 4 (“In order to assure that 95% of largemouth bass in Illinois waters may be

consumed in unlimited quantities by sensitive subpopulations, a 90% reduction of

mercury in fish tissue is needed”), will not be achieved.

---

Page 16

Table 2

Relationship between total mercury concentrations in sediments (mg/kg dry weight) and

fish tissues (mg/kg wet weight). Source: USEPA’s STORET data base. Values represent

sites with fish tissue mercury levels at or above 0.1 mg/kg wet weight. Fish data for the

year referenced; sediment data for samples collected within a 5-year period of the fish

tissue data collection date (2.5 years before and after the date of the tissue collection)

.

Sediment values shown are an average sediment concentration of these 5 years.

County

Total Mercury in Fish Tissue

(mg/kg wet weight)

Total Mercury in

Sediments (mg/kg dry

weight)

Year Fish Data Collected

Jackson

0.185

0.052

1986

Jackson

0.15

0.052

1990

Jackson

0.167

0.115

1988

Jackson

0.167

0.077

1988

Fayette

0.184

0.03

1978

Fayette

0.184

0.04

1978

Fayette

0.13

0.04

1979

Fayette

0.1

0.03

1980

Fayette

0.1

0.035

1980

Fayette

0.205

0.03

1981

Fayette

0.205

0.04

1981

Fayette

0.205

0.035

1981

Fayette

0.205

0.035

1981

Fayette

0.1

0.035

1983

Macoupin

0.26

0.048

1990

Coles

0.21

0.1

1991

Coles

0.1

0.1

1991

Champaign

0.16

0.215

1981

Kankakee

0.12

0.04

1978

Kankakee

0.12

0.05

1978

Kankakee

0.14

0.53

1988

Kankakee

0.14

0.08

1988

Henry

0.22

0.055

1981

La Salle

0.13

0.14

1988

La Salle

0.12

0.029

1990

Henry

0.143

0.037

1978

Henry

0.143

0.03

1978

Cook

0.15

0.331

1974

Cook

0.47

0.061

1990

Cook

0.47

0.1

1990

Cook

0.273

0.1

1991

Cook

0.1

0.221

1990

Cook

0.46

0.091

1991

Cook

0.19

0.49

1981

---

Page 17

Table 3

Relationship between total mercury concentrations in sediments (mg/kg dry weight) and

fish tissues (mg/kg wet weight). Source: USEPA’s STORET data base. Values represent

sites with fish tissue mercury levels at or above 0.23 mg/kg wet weight. Fish data for the

year referenced; sediment data for samples collected within a 5-year period of the fish

tissue data collection date (2.5 years before and after the date of the tissue collection)

.

Sediment values shown are an average sediment concentration of these 5 years.

Total Mercury in

(mg/kg wet

Collected

Coles

0.113

0.23

1979

Coles

0.113

0.26

1979

Cook

0.49

0.24

1981

Cook

0.49

0.25

1981

Cook

0.49

0.27

1981

Cook

0.49

0.23

1981

Cook

0.061

0.61

1988

Cook

0.074

0.47

1990

Cook

0.1

0.26

1991

Cook

0.1

0.25

1992

Cook

0.1

0.31

1991

Cook

0.1

0.27

1992

Cook

0.221

1.4

1988

Cook

0.091

0.46

1991

Du Page

0.1

0.27

1998

Effingham

0.016

0.4

1989

Effingham

0.018

0.33

1989

Effingham

0.023

0.23

1989

Effingham

0.027

0.29

1989

Effingham

0.029

0.33

1989

Fayette

0.035

0.27

1978

Jackson

0.052

0.25

1986

Macoupin

0.048

0.26

1990

Clay

0.016

0.42

1989

Clay

0.024

0.81

1989

Clay

0.012

0.28

1989

---

Page 18

Table 4

Summary of current information on waters listed as impaired due to mercury, PCBs, or both as

documented in Appendix A of the Illinois 2004 303(d) List (IEPA/BOW/04-005). IEPA, 2004.

Illinois 2004 Section 303(d) List. Bureau of Water, Watershed Management Section, Planning

Unit. IEPA/BOW/04-005.

Water Body

Site Name

Acres

Impaired?

Reduction

Impaired

Listing?

Des Plaines

IL_G-15

3.47 miles

NO

IL_G-22

4.14 miles

NO

IL_G-26

3.32 miles

NO

IL_G-28

8.82 miles

NO

IL_G-30

5.14 miles

NO

IL_G-32

6.08 miles

NO

IL_G-35

5.1 miles

NO

IL_G-36

6.92 miles

NO

IL_G-03

15.08 miles

NO

IL_G-11

5.17 miles

NO

IL_G-23

2.65 miles

NO

IL_G-39

11.12 miles

NO

IL_G-07

10.22 miles

NO

IL_G-08

0.77 miles

YES

IL_G-25

6.78 miles

YES

IL_G-26

3.32 miles

NO

IL_G-01

2.71 miles

NO

IL_G-12

8.35 miles

NO

IL_G-14

4.87 miles

NO

Chicago River

IL_HCB-01

2.56 miles

NO

Devils Kitchen

IL_RNJ

810 acres

YES

Little Grassy

IL_RNK

1000 acres

YES

Campus

IL_RNZH

40 acres

NO

Marquette Park Lagoon

IL_RHE

40 acres

YES

E. BR. DuPage R.

IL_GBL-08

5.53 miles

YES

IL_GBL-10

4.63 miles

YES

Salt Creek

IL_GL

11.19 miles

NO

IL_GL-03

10.38 miles

NO

IL_GL-09

11.78 miles

NO

IL_GL-10

3.64 miles

NO

IL_GL-19

3.1 miles

NO

---

Page 19

Table 4

Summary of current information on waters listed as impaired due to mercury, PCBs, or both as

documented in Appendix A of the Illinois 2004 303(d) List (IEPA/BOW/04-005). IEPA, 2004.

Illinois 2004 Section 303(d) List. Bureau of Water, Watershed Management Section, Planning

Unit. IEPA/BOW/04-005.

Water Body

Site Name

Acres

Impaired?

Reduction

Impaired

Listing?

Cedar (Jackson)

IL_RNE

1800 acres

YES

Calumet-Sag Channel

IL_H-02

10.35 miles

NO

Little Calumet R. N.

IL_HA-05

5.06 miles

NO

Little Calumet R. S.

IL-HB-01

8.6 miles

YES

IL_HB-42

406 miles

YES

Arrowhead (Cook)

IL_RHZE

14 acres

YES

Midlothian Reservoir

IL_RHZI

25 acres

NO

Petticone Creek

IL_QA-C4

0.27 miles

NO

Lake-In-The-Hills 1W

IL_RTZZ

54 acres

YES

Rock River

IL_P-14

10.91 miles

NO

IL_P-20

13.62 miles

NO

IL_P-23

0.96 miles

NO

IL_P-15

21.19 miles

NO

IL_P-06

8.57 miles

NO

IL_P-21

18.36 miles

NO

IL_P-04

19.54 miles

NO

IL_P-06

8.57 miles

NO

IL_P-24

25.18 miles

NO

IL_P-25

15.13 miles

NO

IL_P-09

5.62 miles

NO

Illinois River

IL_D-31

25.49 miles

NO

IL_D-32

13.89 miles

NO

IL_D-16

6.58 miles

NO

IL_D-09

20.09 miles

NO

IL_D-01

35.09 miles

NO

IL_D-20

1.17 miles

NO

IL_D-23

10.52 miles

NO

IL_D-05

12.19 miles

NO

IL_D-10

9.38 miles

NO

IL_D-30

19.92 miles

NO

---

Page 20

Table 4

Summary of current information on waters listed as impaired due to mercury, PCBs, or both as

documented in Appendix A of the Illinois 2004 303(d) List (IEPA/BOW/04-005). IEPA, 2004.

Illinois 2004 Section 303(d) List. Bureau of Water, Watershed Management Section, Planning

Unit. IEPA/BOW/04-005.

Water Body

Site Name

Acres

Impaired?

Reduction

Impaired

Listing?

Kankakee River

IL_F-01

11.54 miles

YES

IL_F-04

10.04 miles

YES

IL_F-12

1.76 miles

YES

IL_F-16

9.57 miles

YES

IL_F-02

13.46 miles

YES

IL_F-03

1.97 miles

YES

Kinkaid

IL_RNC

3475 acres

NO

Wabash River

IL_B-01

4.73 miles

NO

IL_B-06

7.51 miles

NO

IL_B-03

15.21 miles

NO

Monee Reservoir

IL_RFH

46 acres

YES

Big Bureau Creek

IL_DQ-03

5.31 miles

NO

Bracken

IL_SDZA

172 acres

NO

---

Page 21

Figure 2

The Mercury Cycle

---

Page 22

Figure 3

Relationship Between Total Mercury Concentrations in Sediments (mg/kg dry

weight) and Fish Tissue Concentrations (mg/kg wet weight) Greater Than or

Equal to 0.1 and Their Proximity to Listed Impaired Waters and Coal-Fired

Power Plants in Illinois.

Note: the information plotted comprises locations with

sediment and tissue data collected from the same site within a 5-year period.

Scale 1: 5,216,518

---

Page 23

Figure 4

Relationship Between Total Mercury Concentrations in Sediments (mg/kg dry weight) and Fish

Tissue Concentrations (mg/kg wet weight) Greater Than or Equal to 0.23 and Their Proximity to

Listed Impaired Waters and Coal-Fired Power Plants in Illinois.

Note: the information plotted

comprises locations with sediment and tissue data collected from the same site within a 5-year period.

Scale 1: 5,216,518

---

Page 24

Education:

Ph.D., Benthic Ecology, University of Victoria, Victoria, BC, 1979

M.Sc., Biological Oceanography, 1976

B.Sc., Marine Biology, 1974

Affiliations:

Member, American Water Works Association

Member, North American Benthological Society

Member, American Society for Testing and Materials

Charter Member, Estuarine Research Federation

Member, Society of Environmental Toxicology and Chemistry (SETAC)

Member, Water Environment Federation

Awards:

Founders Award, Society of Environmental Toxicology and Chemistry, 2001

Region 10 award for resolving environmental issues, Port Valdez, Alaska, 1996

Languages:

English and Spanish

Publications:

Over 150 journal articles and book chapters

Over 200 technical reports

Over 100 presentations at meetings

Experience:

2004 – Present

Golder Associates Ltd.

North Vancouver, BC

Senior Environmental Scientist, Principal

Responsibilities include directing, designing, and managing environmental studies in

Arctic, temperate, and tropical ecosystems. Primary areas of expertise and

responsibilities are in ecotoxicology, risk assessment, and aquatic ecology. Areas of

specialisation include weight of evidence assessments and metals fate and effects,

especially selenium.

1979 – 2004

EVS Environmental Consultants

North Vancouver, BC

Senior Environmental Scientist/Principal

Responsibilities included directing, designing, and managing environmental studies in

Arctic, temperate, and tropical ecosystems. Primary areas of expertise and

responsibilities were ecotoxicology, risk assessment, and aquatic ecology. Areas of

specialisation included weight of evidence assessments and metals.

1977 – 1979

Environment Canada/Dept. Fisheries and Oceans

Victoria, BC

Independent Contractor

Conducted independent research on aquatic oligochaete distributions in the Fraser

River and assessed metal body burdens in aquatic benthos from various areas.

Published several papers and one book chapter based on this work.

1976 – 1979

University of Victoria

Victoria, BC

Teaching and Research Assistant

Prepared laboratories for undergraduate classes and provided lectures during

laboratory classes. Involvement in research activities included species collections

(terrestrial and aquatic), laboratory and field studies.

---

ECOTOXICOLOGY/TOXICITY TESTING Page 1 of 1

PROJECT RELATED EXPERIENCE – ECOTOXICOLOGY/TOXICITY

TESTING

Ecotoxicology

North and South America, Europe, Australasia

•

Directed development and source evaluation studies of chemical contaminants in water and

sediment.

•

Designed, directed and conducted studies involving sewage treatment plants, mining,

manufacturing, pulp and paper, wood processing, hazardous waste disposal, landfill operations, oil

and gas, smelting and food processing.

•

Conducted pioneering toxicity studies in Arctic, temperate, and tropical ecosystems.

Toxicity Testing

North and South America, Europe, Australasia

•

Nationally and internationally recognised expert in ecotoxicology.

•

Developed

and

verified

national

and

international

bioassessment

protocols

for

measuring/predicting toxicity and bioaccumulation.

Example Publications

International Peer-Reviewed Literature

Chapman, P.M. and J. Anderson. 2005. A decision-making framework for sediment contamination. Integr.

Environ. Assess. Manage. 1: 163-173.

Chapman, P.M. and M.J. Riddle. 2005. Toxic effects of contaminants in polar marine environments.

Environ. Sci. Technol. 38: 200A-207A.

Wang, F., R. Goulet, and P.M. Chapman. 2004. A critique of testing sediment biological effects with the

freshwater amphipod

Hyalella azteca

. Chemosphere 57: 1713-1724.

McDonald, B.G. and P.M. Chapman. 2002. PAH phototoxicity – An ecologically irrelevant phenomenon?

Mar. Pollut. Bull. 44: 1321-1326.

Chapman, P.M., H. Bailey, and E. Canaria. 2000. Toxicity of total dissolved solids (TDS) from two mine

effluents to chironomid larvae and early life stages of rainbow trout. Environ. Toxicol. Chem. 19:

210-214.

Wang, F. and P.M. Chapman. 1999. The biological implications of sulfide in sediment - a review focusing

on sediment toxicity. Environ. Toxicol. Chem. 18: 2526-2532.

Chapman, P.M. 1998. New and emerging issues in ecotoxicology - the shape of testing to come? Austral.

J. Ecotox. 4:1-7.

Chapman, P.M. 1997. Acid volatile sulfides, equilibrium partitioning, and hazardous waste site sediments.

Environ. Manage. 21: 197-202.

Chapman, P.M. 1990. The Sediment Quality Triad approach to determining pollution-induced degradation.

Sci. Tot. Environ. 97-8: 815-825.

---

ENVIRONMENTAL RISK ASSESSMENT

Page 1 of 2

PROJECT RELATED EXPERIENCE – ENVIRONMENTAL RISK

ASSESSMENT

Various Projects

North and South America, Europe, Australasia

•

Involved in ecological risk assessment since this process was formalised in the 1980s.

•

Conducted ecological risk assessments for government and industry.

•

Served, at the request of the U.S. Environmental Protection Agency Risk Assessment Forum, as a

peer reviewer for various agency guidance documents.

•

Published extensively on ecological risk assessment.

Global Experience

South America, Europe, Australasia

•

Senior Editor of the international peer-reviewed journal, Human and Ecological Risk Assessment.

•

Advisory and consulting services to the governments of Australia, Peru, Indonesia, Hong Kong,

ASEAN (Association of South East Asian Nations).

•

Helped set up the first Master’s degree in Ecotoxicology in Portugal.

•

Conducted pioneering toxicity testing studies in the Arctic, North Sea, and Venice lagoons.

•

Lectured, taught, and worked extensively in Europe, South East Asia, Australia, and South

America (fluent in Spanish).

•

Independent, external examiner for Ph.D. dissertations in Spain, Finland, Canada, the U.S.,

Denmark, and Australia.

•

Numerous lectures and presentations to the public, high school and university classes, business

and professional groups.

Large-Project Expertise

North and South America, Europe, Australasia

•

Responsible for synthesis of all studies conducted through NSERC (Natural Sciences and Engineering

Research Council) under the Metals in the Environment Research Network (MITE-RN; www.mite-

rn.org). MITE-RN ran for 5 years and involved 7 major Canadian Universities and over 20 Principal

Investigators from those Universities plus graduate students and other collaborators.

•

Currently providing similar services to the successor of MITE-RN, the Metals in the Holistic

Environment Research Network (MITHE-RN); www.mithe-rn.org

.

•

Directed regional-scale risk assessments in Alaska (Port Valdez), Papua New Guinea, Irian Jaya,

Chile, and Peru.

Example Publications

International Peer-Reviewed Literature

Campbell, P.G.C., P.M. Chapman, and B. Hale. 2006. Risk assessment of metals in the environment. pp

102-131, In: Hester, R. E. and R. M. Harrison (eds.), Chemicals in the Environment: Assessing and

Managing Risk. Issues in Environmental Science and Technology Volume 22, Royal Society of

Chemistry, Cambridge, UK.

Chapman, P.M., F. Wang, C. Janssen, R.R. Goulet, and C.N. Kamunde. 2003. Conducting ecological risk

assessments of inorganic metals and metalloids – Current status. Human Ecol Risk Assess 9: 641-697.

[This paper was selected as the Ecological Risk Assessment Paper of the Year 2003]

Chapman, P.M., B.G. McDonald, and G.S. Lawrence. 2002. Weight of evidence frameworks for sediment

quality and other assessments. Human Ecol. Risk Assess. 8: 1489-1515.

Chapman, P.M. 2002. Ecological risk assessment (ERA) and hormesis. Sci. Tot. Environ.288: 131-140.

---

ENVIRONMENTAL QUALITY MGT/AQUATIC ECOLOGY Page 1 of 2

PROJECT RELATED EXPERIENCE – ENVIRONMENTAL QUALITY

MANAGEMENT/AQUATIC POLLUTION ASSESSMENT

Environmental Quality

North and South America, Europe, Australasia, Arctic

•

Intimately involved in the process and methods for developing environmental quality guidelines,

both nationally and internationally.

•

Advisor to the federal governments of both the United States and Canada for environmental

toxicology and biomonitoring assessment policy and protocols.

•

Participated in and led aspects of international (South American, European, and Australasian)

monitoring development projects.

•

Published extensively on the subject of environmental quality guidelines.

•

Member of the International Standards Organization, representing Canada.

Pollution Assessment

North and South America, Europe, Australasia, Arctic

•

Developed the internationally recognised and accepted Sediment Quality Triad concept for

determining pollution-induced degradation in aquatic habitats.

•

Directed projects (for government and industry) for various studies involving biological

monitoring; assessment of toxicant levels (including Priority Pollutants) in tissues, sediments, and

water; ecological surveys; literature reviews for ranking environmental contaminants; and

bioassessment (e.g., toxicity testing).

Dredging/Sediment Projects

USA, Canada, and elsewhere

•

Peer reviewed the U.S. Environmental Protection Agency/Army Corps of Engineers

[USEPA/USACE] “Green Book” on ocean disposal.

•

Contracted author for the EPA/USACE Inland Testing Manual for Waters of the U.S.

•

Designed and implemented monitoring and assessment projects for aquatic dredging in fresh,

marine, and estuarine waters world-wide.

Example Publications

International Peer-Reviewed Literature

Chapman, P.M., W.S. Douglas, M.C. Harrass, R.M. Burgess, D.D. Reible, W.H. Clements, A.H.

Ringwood, C. Hogstrand, and W.J. Birge. 2005. Workgroup summary report on the role of SQGs and

other tools in different aquatic habitats. In: Wenning, R., C. Ingersoll, G. Batley, and M. Moore (eds.),

Use of Sediment Quality Guidelines (SQGs) and Related Tools for the Assessment of Contaminated

Sediments. SETAC Press, Pensacola, FL, USA.

Chapman, P.M., F. Wang, D.D. Germano, and G. Batley. 2002. Porewater testing and analysis: The good,

the bad and the ugly. Mar. Pollut. Bull. 44: 359-366.

Chapman, P.M. 2001. Utility and relevance of aquatic oligochaetes in ecological risk assessment.

Hydrobiologia 463:149-169.

Chapman, P.M., F. Wang, W. Adams, and A. Green. 1999. Appropriate uses of sediment quality values for

metals and metalloids. Environ. Sci. Technol. 33: 3937-3941.

Chapman, P.M., P.J. Allard, and G.A. Vigers. 1999. Development of sediment quality values for Hong

Kong Special Administrative Region: a possible model for other jurisdictions. Mar. Pollut. Bull. 38:

161-169.

---

EXPERT WITNESS AND PEER REVIEW

Page 1 of 1

PROJECT RELATED EXPERIENCE – EXPERT WITNESS AND PEER

REVIEW

Expert Witness

USA and Canada

•

Four trials with testimony.

•

Two trials with attendance but no testimony as cases settled.

•

Two depositions (one videotaped).

•

One pending trial.

•

Appeared as an expert witness on eight occasions before the Northwest Territories (Canada) Water

Board, and on one occasion before the Nunavut (Canada) Water Board.

•

Provided expert advice, but not testimony, during five judicial or quasi-judicial Hearings in

Canada.

•

Clients include both government (e.g., U.S. Department of Justice) and industry.

Peer Reviewer

USA, Canada, Australasia, Europe

Currently:

•

Peer reviewer for over 20 international scientific journals.

•

Peer reviewer for American, Canadian, Australian, New Zealand, and European granting agencies.

•

Senior Editor for Debates/Commentaries and Perspectives for the international, peer-reviewed

journal, Human and Ecological Risk Assessment.

•

Editor of the Learned Discourses in the Society of Environmental Toxicology and Chemistry

(SETAC) Globe.

•

Editorial Board of the international journal, Marine Pollution Bulletin.

•

Editorial Board of the international journal, Environmental Toxicology and Chemistry.

Previously:

•

Member, U.S. Environmental Protection Agency, Science Advisory Board (SAB), Sediment

Criteria Subcommittee.

•

Member, Washington State Biomonitoring Science Advisory Board (BSAB).

•

Member, Canadian Environmental Advisory Council (advised four different Canadian Ministers

of Environment).

•

Member, NRC Committee on the Bioavailability of Metals in Sediments.

•

Member, U.S. Environmental Protection Agency, Science Advisory Board, Global Climate

Change Subcommittee.

•

Member, Editorial Board, Chemosphere.

•

Member, Sewage Treatment Review Panel.

•

Member, International Technical Advisory Panel on Ecotoxicity.

---

METALS AND METALLOIDS Page 1 of 1

PROJECT RELATED EXPERIENCE – METALS AND METALLOIDS

Metals and Metalloids

North and South America, Europe, Australasia, Arctic

•

Past member of the International Technical Advisory Panel on Ecotoxicology, for nonferrous

metals.

•

Participated in an OECD Expert Workshop on Toxicity Testing of Metals and Metalloids as Chair

of an International Expert Group.

•

Participated in a Canada/European Union Expert Workshop on Persistence and Bioaccumulation

of Metals and Metalloids as a speaker and workshop rapporteur.

•

Participated in a World Health Organization Expert Workshop on Global Criteria for Zinc.

•

Extensive experience and expertise with metals from sources including mining, smelters, sewage,

and landfills.

•

Extensive publications regarding metals fate and effects in the environment.

Example Publications

International Peer-Reviewed Literature

Adams, W. and P.M. Chapman (eds.), 2005. Assessing the Hazard of Metals and Inorganic Metal

Substances in Aquatic and Terrestrial Systems. SETAC Press, Pensacola, FL.

Chapman, P.M. 2005. Inorganic metals and metalloids ERA – Recent advances and implications for LCIA.

pp. 214-219. In: A.A. Dubreuil (ed.), Life Cycle Assessment of Metals – Issues and Research

Directions. SETAC Press, Pensacola, FL.

Chapman, P.M. and C. McPherson. 2004. Possible selenium thresholds for trout. SETAC Globe 5(6):

22-25.

Chapman, P.M. and F. Wang. 2000. Issues in ecological risk assessment of inorganic metals and

metalloids. Human Ecol. Risk Assess. 6: 965-988.

McPherson, C.A. and P.M. Chapman. 2000. Copper effects on potential sediment test organisms: the

importance of appropriate sensitivity. Mar. Pollut. Bull. 40:656-665.

Chapman, P.M. 1999. Selenium - a potential time bomb or just another contaminant? Human Ecol. Risk

Assess. 5: 1122-1137.

Wang, F., P.M. Chapman, and H. Allen. 1999. Misapplication of equilibrium partitioning coefficients to

derive metals sediment quality values. Mar. Pollut. Bull. 38: 423-425.

Chapman, P.M., F. Wang, C. Janssen, G. Persoone, and H. Allen. 1998. Ecotoxicology of metals in aquatic

sediments: binding and release, bioavailability, hazard, risk and remediation. Can. J. Fish. Aquat. Sci.

55: 2221-2243.

Chapman, P.M., H.E. Allen, K. Godtfredsen, and M.N. Z’Graggen. 1996. Evaluation of BCFs as measures

for classifying and regulating metals. Environ. Sci. Technol. 30: 448-452.

---

SEWAGE EFFLUENT AND TREATMENT

Page 1 of 1

PROJECT RELATED EXPERIENCE – SEWAGE EFFLUENT AND

TREATMENT

Sewage

North and South America, Europe, Australasia, Arctic

•

Extensive project experience assessing fate and effects of sewage effluents.

•

Evaluations for cities with populations over 1,000,000 and small local discharges.

•

Expert advice regarding design and placement of sewage discharges to minimise environmental

concerns.

•

Expert advice regarding levels of sewage treatment required relative to the receiving environment.

•

Interpretative advice and studies regarding environmental effects and regulatory requirements.

•

Member, Sewage Treatment Review Panel (Greater Vancouver Regional District).

Example Publications

International Peer-Reviewed Literature

Chapman, P.M. 2006. Determining when contamination is pollution – weight of evidence determinations

for sediments and effluents. Environ. Intern. (in press).

Chapman, P.M., K. Ho, W. Munns, K. Solomon, and M.P. Weinstein. 2002. Issues in sediment toxicity and

ecological risk assessment. Mar. Pollut. Bull. 44: 271-278.

McPherson, C.A., A.R. Tang, P.M. Chapman, and L.A. Taylor. 2002. Toxicity of 1,4-dichlorobenzene in

sediments to juvenile polychaete worms. Mar. Pollut. Bull. 44: 1405-1414.

Chapman, P.M. 2000. Whole Effluent Toxicity (WET) Testing - usefulness, level of protection, and risk

assessment. Environ. Toxicol. Chem. 19: 3-13.

Taylor, L.A., P.M. Chapman, R.A. Miller, and R.V. Pym. 1998. The effects of untreated municipal sewage

discharge to the marine environment off Victoria, British Columbia, Canada. Water Sci. Technol. 38:

285-292.

McGroddy, S. and P.M. Chapman. 1997. Is mercury from dental amalgam an environmental problem?

Environ. Toxicol. Chem. 16: 2213-2214.

Chapman, P.M., J. Downie, A. Maynard, and L. Taylor. 1996. Deodorizer residue and coal in marine

sediments contaminants or pollutants? Environ. Toxicol. Chem. 15: 638-642.

Chapman, P.M., M.D. Paine, A.D. Arthur, and L.A. Taylor. 1996. A triad study of sediment quality

associated with a major, relatively untreated marine sewage discharge. Mar. Pollut. Bull. 32: 47- 64.

Chapman, P.M. 1996. A test of sediment effects concentrations: DDT and PCB in the Southern California

Bight. Environ. Toxicol. Chem. 15: 1197-1198.

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1994. Sediment studies provide key

information on the need to treat sewage discharged to sea by a major Canadian city. Water Sci.

Technol. 28: 255-261.

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JOURNAL PUBLICATIONS Page 1 of 9

JOURNAL PUBLICATIONS

[* = Editorials or Letters to the Editor]

Chapman, P.M., C. McPherson, and C. MacCay. In Preparation. Greater contamination and effects pre-

than post-mining: a case study. Arch. Environ. Contam. Toxicol.

Lofts, S., P. M. Chapman, I. Schoeters, R. Dwyer, S. Sheppard, M. McLaughlin, et al. In Preparation.

Appropriate critical loads of metals to terrestrial environments. Environ. Sci. Technol.

Liber, K., M.D. Paine, C.A. McPherson, B.S. Kelemen, P.M. Chapman, and I.K. Birtwell. In Preparation.

Effects of suspended placer mining sediment on juvenile Chinook salmon and arctic grayling embryos

in experimental systems. Can. J. Fish. Aquati. Sci.

Chapman, P. M. In press. Future environmental science: “Status humana”, man as the measure. Human

Ecol. Risk Assess.

Chapman, P.M. In press. Determining when contamination is pollution - weight of evidence determinations

for sediments and effluents. Environ. Intern.

Chapman, P.M., B. McDonald, P.E. Kickham, and S. McKinnon. In Press. Global geographic differences

in marine metals toxicity. Mar. Pollut. Bull.

McDonald, B. G. and P. M. Chapman. 2006. Assessing selenium effects: A weight of evidence approach.

Integr. Environ. Assess. Manag. (in press).

*Chapman, P. M. 2006. When is peer review excessive? Examples from peer review Hell. Human Ecol.

Risk Assess. 12: 423-426.

Joillet, O., R. Rosenbaum, P. M. Chapman, T. McKone, M. Margnia, M. Scheringer, N. van Straalen, and

F. Waniah. 2006. Establishing a framework for Life Cycle Toxicity Assessment: Findings of the

Lausanne review workshop. Int. J. Life Cycle Assess. 11: 209-212.

*Chapman, P. M. 2006. Emerging chemicals – emerging problems? Environ. Toxicol. Chem. 25: 1445-

1447.

Chapman, P. M. and Hollert, H. 2006. Should the Sediment Quality Triad become a tetrad, a pentad, or

possibly even a hexad? J Soil Sed 6: 4-8.

*Calado, R. and P. M. Chapman. 2006. Aquarium species: deadly invaders. Mar. Pollut. Bull. 52: 599-601.

*Chapman, P.M. and L.M. Guerra. 2005. The “So what?” factor. Mar. Pollut. Bull. 50: 1457-1458.

Chapman, P.M., R.R. Goulet, and F. Wang. 2005. Response to Borgmann et al. (2005) – sediment toxicity

testing with

Hyalella azteca

. Chemosphere 61: 1744-1745.

Chapman, P.M. and M.J. Riddle. 2005. Polar marine toxicology – future research needs. Mar. Pollut. Bull.

50: 905-908.

Chapman, P.M. and J. Anderson. 2005. A decision-making framework for sediment contamination. Integr.

Environ. Assess. Manage. 1: 163-173.

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JOURNAL PUBLICATIONS Page 2 of 9

Chapman, P.M. and M.J. Riddle. 2005. Toxic effects of contaminants in polar marine environments.

Environ. Sci. Technol. 38: 200A-207A.

Wang, F., R. Goulet, and P.M. Chapman. 2004. A critique of testing sediment biological effects with the

freshwater amphipod

Hyalella azteca

. Chemosphere 57: 1713-1724.

*Chapman, P.M. and M.J. Riddle. 2004. Reply to Wells: there really is a paucity of polar marine

ecotoxicity data! Mar. Pollut. Bull. 48: 606-607.

*Chapman, P.M. 2004. Indirect effects of contaminants. Mar. Pollut. Bull. 48: 411-412.

Chapman, P.M. 2004. Modifying Paracelsus’ dictum for sediment quality (and other) assessments. Aquat.

Ecosyst. Health Manage. 7(3): 1-6.

*Riddle, M.J. and P.M. Chapman. 2004. Polar ecotoxicology – a missing link. Antarctic Sci. 15(3):317.

*Wells, P., J. Baker, P.M. Chapman, M. Elliott, P. Hutchings, K. Mann, P. Olive, J. Pearce, D. Phillips, and

C. Sheppard. 2003. From mimeos to e-copy – a tribute to Professor R.B. (Bob) Clark, founding editor

of the

Marine Pollution Bulletin

. Mar. Pollut. Bull. 46: 1051-1054.

*Chapman, P.M. and R.C. Loehr. 2003. Relevant environmental science. Environ. Toxicol. Chem. 22:

2217-2218.

*Chapman, P.M. and M.J. Riddle. 2003. Missing and needed: polar marine ecotoxicology. Mar. Pollut.

Bull. 46:927-928.

Chapman, P.M., F. Wang, C. Janssen, R.R. Goulet, and C.N. Kamunde. 2003. Conducting ecological risk

assessments of inorganic metals and metalloids – Current status. Human Ecol Risk Assess 9: 641-697.

[This paper was selected as the Ecological Risk Assessment Paper of the Year 2003]

McPherson, C.A., A.R. Tang, P.M. Chapman, and L.A. Taylor. 2002. Toxicity of 1,4-dichlorobenzene in

sediments to juvenile polychaete worms. Mar. Pollut. Bull. 44: 1405-1414.

McDonald, B.G. and P.M. Chapman. 2002. PAH phototoxicity – An ecologically irrelevant phenomenon?

Mar. Pollut. Bull. 44: 1321-1326.

Chapman, P.M., B.G. McDonald, and G.S. Lawrence. 2002. Weight of evidence frameworks for sediment

quality and other assessments. Human Ecol. Risk Assess. 8: 1489-1515.

Grapentine, L., J. Anderson, D. Boyd, G.A. Burton, C. De Barros, G. Johnson, C. Marvin, D. Milani, S.

Painter, T. Pascoe, T. Reynoldson, L. Richman, K. Solomon, and P.M. Chapman. 2002. A decision-

making framework for sediment assessment developed for the Great Lakes. Human Ecol. Risk Assess.

8: 1641-1655.

Burton, G.A.Jr., P.M. Chapman, and E.P. Smith. 2002. Weight of evidence approaches for assessing

ecosystem impairment. Human Ecol. Risk Assess. 8: 1657-1673.

Burton, G.A. Jr., G.E. Batley, P.M. Chapman, V.E. Forbes, C.E. Schlekat, P.E. Smith, P.J. den Besten, J.

Barker, T. Reynoldson, A.S. Green, R.L. Dwyer, and W.R. Berti. 2002. A weight of evidence

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JOURNAL PUBLICATIONS Page 3 of 9

framework for assessing sediment (or other) contamination: Improving certainty in the

decision-making process. Human Ecol. Risk Assess. 8: 1675-1696.

*Chapman, P.M. and C. Sheppard. 2002. Letters to the editor. Mar. Pollut. Bull. 44: 577-578.

*Chapman, P.M. 2002. Mistakes made/lessons learned. Environ. Toxicol. Chem. 21: 891-893.

Batley, G.E., G.A. Burton, P.M. Chapman, and V.E. Forbes. 2002. Uncertainties in sediment quality

weight-of-evidence (WOE) assessments. Human Ecol. Risk Assess. 8: 1517-1547.

Chapman, P.M., K. Ho, W. Munns, K. Solomon, and M.P. Weinstein. 2002. Issues in sediment toxicity and

ecological risk assessment. Mar. Pollut. Bull. 44: 271-278.

Chapman, P.M. 2002. Defining hormesis - Comments on Calabrese and Baldwin (2002). BELLE

Newsletter 10(2):31-33.

Chapman, P.M., F. Wang, D.D. Germano, and G. Batley. 2002. Porewater testing and analysis: The good,

the bad and the ugly. Mar. Pollut. Bull. 44: 359-366.

Chapman, P.M. 2002. Ecological risk assessment (ERA) and hormesis. Sci. Tot. Environ.288: 131-140.

Chapman, P.M. 2002. Integrating toxicology and benthic ecology: Putting the eco back into ecotoxicology.

Mar. Pollut. Bull. 44: 7-15.

*Chapman, P.M. 2001. How toxic is toxic? Mar. Pollut. Bull. 42: 1279-1280.

Chapman, P.M. 2001. Utility and relevance of aquatic oligochaetes in ecological risk assessment.

Hydrobiologia 463:149-169.

Chapman, P.M. 2001. Final comments: Implications of hormesis to ecotoxicology and ecological risk

assessment (ERA). BELLE Newsletter 10 (1):23-25 and

Human Exp. Toxicol. 20:529-531.

Chapman, P.M. 2001.The implications of hormesis to ecotoxicology and ecological risk assessment.

BELLE Newsletter 10 (1): 2-8 and

Human Exp. Toxicol. 20:499-505.

Chapman, P.M. 2001. Reflections on the future of hormesis. Critical Rev. Toxicol. 31 (4&5): 649-657.

Chapman, P.M. and F. Wang. 2001 Assessing sediment contamination in estuaries. Environ. Toxicol.

Chem. 20: 3-22.

Chapman, P.M. 2000. The Sediment Quality Triad (SQT) - then, now and tomorrow. Int. J. Environ. Pollut.

13:351-356.

Hill, R.A., P.M. Chapman, G.S. Mann, and G.S. Lawrence. 2000. Ecological risk assessments. Soil and

Groundwater Cleanup October/November :12-16.

Chapman, P.M. and F. Wang. 2000. Issues in ecological risk assessment of inorganic metals and

metalloids. Human Ecol. Risk Assess. 6: 965-988.

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JOURNAL PUBLICATIONS Page 4 of 9

McPherson, C.A. and P.M. Chapman. 2000. Copper effects on potential sediment test organisms: the

importance of appropriate sensitivity. Mar. Pollut. Bull. 40:656-665.

Hill, R.A., P.M. Chapman, G.L. Mann, and G.S. Lawrence. 2000. Level of detail in ecological risk

assessments. Mar. Pollut. Bull. 40: 471-477.

*Chapman, P.M. 2000. Why are we still emphasizing screening level numbers? Mar. Pollut. Bull.

40:465-466.

Chapman, P.M. 2000. Whole Effluent Toxicity (WET) Testing - usefulness, level of protection, and risk

assessment. Environ. Toxicol. Chem. 19: 3-13.

Chapman, P.M., H. Bailey, and E. Canaria. 2000. Toxicity of total dissolved solids (TDS) from two mine

effluents to chironomid larvae and early life stages of rainbow trout. Environ. Toxicol. Chem. 19:

210-214.

Chapman, P.M., F. Wang, W. Adams, and A. Green. 1999. Appropriate uses of sediment quality values for

metals and metalloids. Environ. Sci. Technol. 33: 3937-3941.

Chapman, P.M. 1999. Selenium - a potential time bomb or just another contaminant? Human Ecol. Risk

Assess. 5: 1122-1137.

*Chapman, P.M. 1999. Conflict of interest rules. Mar. Pollut. Bull. 38: 745-747.

Wang, F. and P.M. Chapman. 1999. The biological implications of sulfide in sediment - a review focusing

on sediment toxicity. Environ. Toxicol. Chem. 18: 2526-2532.

Chapman, P.M. 1999. Risk assessment and the precautionary principle: a time and a place. Mar. Pollut.

Bull. 38: 944-947.

Chapman, P.M. and G.S. Mann. 1999. Sediment quality values (SQVs) and ecological risk assessment

(ERA). Mar. Pollut. Bull. 38: 339-344.

Wang, F., P.M. Chapman, and H. Allen. 1999. Misapplication of equilibrium partitioning coefficients to

derive metals sediment quality values. Mar. Pollut. Bull. 38: 423-425.

Chapman, P.M., P.J. Allard, and G.A. Vigers. 1999. Development of sediment quality values for Hong

Kong Special Administrative Region: a possible model for other jurisdictions. Mar. Pollut. Bull. 38:

161-169.

Chapman, P.M. 1998. New and emerging issues in ecotoxicology - the shape of testing to come? Austral. J.

Ecotox. 4:1-7.

*Chapman, P.M. 1998. Detection limits and biological effects. Mar. Pollut. Bull. 36: 758-759.

Chapman, P.M., F. Wang, C. Janssen, G. Persoone, and H. Allen. 1998. Ecotoxicology of metals in aquatic

sediments: binding and release, bioavailability, hazard, risk and remediation. Can. J. Fish. Aquat. Sci.

55: 2221-2243.

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JOURNAL PUBLICATIONS Page 5 of 9

Taylor, L.A., P.M. Chapman, R.A. Miller, and R.V. Pym. 1998. The effects of untreated municipal sewage

discharge to the marine environment off Victoria, British Columbia, Canada. Water Sci. Technol. 38:

285-292.

DelValls, T.A. and P.M. Chapman.1998. Site-specific sediment quality values in the Gulf of Cadiz (Spain)

and in San Francisco Bay (USA) using the sediment quality triad and multivariate analysis. Ciencias

Marinas 24: 313-336.

Chapman, P.M., A. Fairbrother, and D. Brown. 1998. A critical evaluation of safety (uncertainty) factors

for ecological risk assessment. Environ. Toxicol. Chem.17: 99-108.

*Chapman, P.M. and J. Giddings. 1997. Scientists need good manners and to be scientists. Mar. Pollut.

Bull. 11: 852.

Chapman, P.M., P. Anderson, S. Carr, V. Engle, R. Green, J. Hameedi, M. Harmon, P. Haverland, J.

Hyland, C. Ingersoll, E. Long, J. Rodgers Jr., M. Salazar, P.K. Sibley, P.J. Smith, P.C. Swartz, B.

Thompson, and H. Windom. 1997. General guidelines for using the Sediment Quality Triad. Mar.

Pollut. Bull. 34: 368-372.

McGroddy, S. and P.M. Chapman. 1997. Is mercury from dental amalgam an environmental problem?

Environ. Toxicol. Chem. 16: 2213-2214.

Murdoch, M.H., P.M. Chapman, D.M. Johns, and M.D. Paine. 1997. Chronic effects of organochlorine

exposure in sediment to the marine polychaete

Neanthes arenaceodentata

. Environ. Toxicol. Chem.16:

1494-1503.

Murdoch, M.H., P.M. Chapman, D.M. Norman, and V.M. Quintino. 1997. Spiking sediment with

organochlorine

compounds

for

toxicity

testing.

Environ.

Toxicol.

Chem.

16:1504-1509.

*Chapman, P.M. 1997. Is bioaccumulation useful for predicting impacts? Mar. Pollut. Bull. 34: 282-283.

Chapman, P.M. 1997. The Precautionary Principle and ecological quality standards/objectives. Mar. Pollut.

Bull. 34: 227-228.

Chapman, P.F. and P.M. Chapman. 1997. Second Warning! NOECs are inappropriate for regulatory use.

Environ. Toxicol. Chem. 16: 125-126.

Chapman, P.M. 1997. Acid volatile sulfides, equilibrium partitioning, and hazardous waste site sediments.

Environ. Manage. 21: 197-202.

Paine, M.D., P.M. Chapman, P.J. Allard, M.H. Murdoch, and D. Minifie. 1996. Limited bioavailability of

sediment PAH near an aluminum smelter: contamination does not equal effects. Environ. Toxicol.

Chem. 15: 2003-2018.

Chapman, P.M., H.E. Allen, K. Godtfredsen, and M.N. Z’Graggen. 1996. Evaluation of BCFs as measures

for classifying and regulating metals. Environ. Sci. Technol. 30: 448-452.

Chapman, P.M., I. Thornton, G. Persoone, C. Janssen, K. Godtfredsen, and M.N. Z’Graggen. 1996.

International harmonization related to persistence and bioavailability. Human Ecol. Risk Assess. 2:

393-404.

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JOURNAL PUBLICATIONS Page 6 of 9

Chapman, P.M., J. Bridgman, J. Kitegawa, D. Dickason, and A. Dailey. 1996. Science and common sense

in Port Valdez, Alaska. Mar. Pollut. Bull. 3-2: 254-256.

Chapman, P.M. 1996. Presentation and interpretation of Sediment Quality Triad data. Ecotoxicology 5:

327-339.

Chapman, P.M. 1996. A test of sediment effects concentrations: DDT and PCB in the Southern California

Bight. Environ. Toxicol. Chem. 15: 1197-1198.

Chapman, P.M., J. Downie, A. Maynard, and L. Taylor. 1996. Deodorizer residue and coal in marine

sediments contaminants or pollutants? Environ. Toxicol. Chem. 15: 638-642.

Chapman, P.M., M.D. Paine, A.D. Arthur, and L.A. Taylor. 1996. A triad study of sediment quality

associated with a major, relatively untreated marine sewage discharge. Mar. Pollut. Bull. 32: 47-64.

Chapman, P.M., R.S. Cardwell, and P.F. Chapman 1996. A warning: NOECs are inappropriate for

regulatory use. Environ. Toxicol. Chem. 15: 77-79.

Chapman, P.M. 1995. Sediment quality assessment: status and outlook. J. Aquat. Ecosys. Health. 4:

183-194.

Chapman, P.M. 1995. Do sediment toxicity tests require field validation? Environ. Toxicol. Chem. 14:

1451-1453.

Chapman, P.M. 1995. Ecotoxicology and pollution - key issues. Mar. Pollut. Bull.

31: 167-177.

Chapman, P.M. 1995. Bioassay testing for Australia as part of water quality assessment programs. Aust. J.

Ecol. 20: 7-19.

Chapman, P.M. 1995. Extrapolating laboratory toxicity results to the field. Environ. Toxicol. Chem. 14:

927-930.

Chapman, P.M., M.D. Paine, T. Moran, and T. Kierstead. 1994. Refinery water (intake and effluent) quality

experimental comparison of 1970s with 1990s toxicity testing. Environ. Toxicol. Chem. 13: 897-909.

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1994. Sediment studies provide key

information on the need to treat sewage discharged to sea by a major Canadian city. Water Sci.

Technol. 28: 255-261.

Chapman, P.M. 1993. Are arctic marine invertebrates relatively insensitive to metals? Environ. Toxicol.

Chem. 12: 611-614.

Chapman, P.M. 1993. The role of ecotoxicology in environmental impact (EIA). Environ. Profess. 15:

139-144.

Chapman, P.M. and C. McPherson. 1993. Comparative zinc and lead toxicity tests with arctic marine

invertebrates and implications for toxicant discharges. Polar Record 29: 45-54.

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JOURNAL PUBLICATIONS Page 7 of 9

Chapman, P.M. 1992. Pollution status of North Sea sediments - an international integrative study. Mar.

Ecol. Prog. Ser. 91: 313-322.

Stebbing A.R.D., V. Dethlefsen, R.F. Addison, M. Carr, P.M. Chapman, W.P. Cofino, C. Heip, L. Karbe,

M.N. Moore, and AD Vethaak. 1992. Overall summary and some conclusions from the ICES/IOC

Bremerhaven Workshop. Mar. Ecol. Prog. Ser. 91: 323-329.

Chapman, P.M., R.C. Swartz, B. Roddie, H. Phelps, P. van den Hurk, and R. Butler. 1992. An international

comparison of sediment toxicity tests in the North Sea. Mar. Ecol. Prog. Ser. 91: 253-264.

Butler, R., P.M. Chapman, P. van den Hurk, B. Roddie, and D.E. Thain. 1992. A comparison of North

American and European oyster larval toxicity tests on North Sea sediments. Mar. Ecol. Prog. Ser. 91:

245-251.

van den Hurk, P., P.M. Chapman, B. Roddie, and R.C. Swartz. 1992. A comparison of North American and

Western European infaunal amphipod species in a toxicity test on North Sea sediments. Mar. Ecol.

Prog. Ser. 91: 23 7-243.

Chapman, P.M. 1992. Ecosystem health synthesis: can we get there from here? J. Aquat. Ecosystem

Health. 1: 69-80

Chapman, P.M. 1991. Environmental quality criteria - what type should we be developing? Environ. Sci.

Technol. 25: 1353-1359.

Chapman, P.M., R.N. Dexter, H. Anderson, and E.A. Power. 1991. Evaluation of effects associated with an

oil platform using the Sediment Quality Triad. Environ. Toxicol. Chem. 10: 407-424.

Chapman, P.M., E.R. Long, R.C. Swartz, T.H. DeWitt, and R. Pastorok. 1991. Sediment toxicity tests,

sediment chemistry and benthic ecology do provide new insights into the significance and management

of contaminated sediments - a reply to Robert Spies. Environ. Toxicol. Chem. 10: 1-4.

Chapman, P.M. 1990. The Sediment Quality Triad approach to determining pollution-induced degradation.

Sci. Tot. Environ. 97-8: 815-825.

Long, E.R, M.F. Buchman, S.M. Bay, R.J. Breteler, R.S. Carr, P.M. Chapman, J.E. Hose, A.L. Lissner, J.

Scott, and D.A. Wolfe. 1990. Comparative evaluation of five toxicity tests with sediments from San

Francisco Bay and Tomales Bay, California. Environ. Toxicol. Chem. 9: 1193-1214.

Chapman, P.M. 1989. Toxicity measurement and reduction procedures (biomonitoring and TRE programs).

Water Pollut. Res. J. Canada. 24: 81-90.

Chapman, P.M. 1989. Current approaches to developing sediment quality criteria. Environ. Toxicol. Chem.

8: 589-599.

*Chapman, P.M. 1989. A bioassay by any other name might not smell the same. Environ. Toxicol. Chem.

8: 551.

Chapman, P.M. 1987. Oligochaete respiration as a measure of sediment toxicity in Puget Sound,

Washington. Hydrobiologia 155: 249-258.

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JOURNAL PUBLICATIONS Page 8 of 9

Chapman, P.M. and R.O. Brinkhurst. 1987. Hair today, gone tomorrow (induced setal changes in tubificid

oligochaetes). Hydrobiologia 155: 45-55.

Chapman, P.M., R.N. Dexter, and L.S. Goldstein. 1987. Development of monitoring programs to assess the

long-term health of aquatic ecosystems - a model from Puget Sound, U.S.A. Mar. Pollut. Bull. 18: 521-

527.

Chapman, P.M., R.N. Dexter, and E.R. Long. 1987. Synoptic measures of sediment contamination, toxicity

and infaunal community structure (the Sediment Quality Triad) in San Francisco Bay. Mar. Ecol. Prog.

Ser. 37: 75-96.

Chapman, P.M., R.C. Barrick, J.M. Neff, and R.C. Swartz. 1987. Four independent approaches to

developing sediment quality criteria yield similar values for model contaminants. Environ. Toxicol.

Chem. 6: 723-725.

Chapman, P.M., J.D. Popham, J. Griffin, D. Leslie, and J. Michaelson. 1987. Differentiation of physical

from chemical toxicity in solid waste fish bioassays. Water Air Soil Pollut. 33: 295-308.

Mitchell, D.G., P.M. Chapman, and T.J. Long. 1987. Acute toxicity of the glyphosate herbicides Roundup

and Rodeo to rainbow trout, chinook and coho salmon. Bull. Environ. Contam. Toxicol. 39:

1028-1035.

Mitchell, D.G., P.M. Chapman, and T.J. Long. 1987. Seawater challenge testing of coho salmons molts

following Roundup herbicide exposure. Environ. Toxicol. Chem. 6: 875-878.

Chapman, P.M. 1986. Sediment quality criteria from the Sediment Quality Triad - an example. Environ.

Toxicol. Chem. 5: 957-964.

Chapman, P.M. and R.O. Brinkhurst. 1986. Setal morphology of the oligochaetes

Tubifex tubifex

and

Ilyodrilus frantzi

(

capillatus

) as revealed by SEM. Proc. Bio. Soc. Wash. 99: 332-327.

Chapman, P.M. and D.G. Mitchell. 1986. Acute tolerance tests with the oligochaetes

Nais communis

(Naididae) and

Ilyodrilus frantzi

(Tubificidae). Hydrobiologia 137: 61-64.

Mearns, A., R. Swartz, J. Cummins, P. Dinnell, P. Plesha, and P.M. Chapman. 1986. Inter-laboratory

comparison of a sediment toxicity test using the marine amphipod

Rhepoxynius abronius

. Mar. Envir.

Res 18: 13-37.

Morgan, J.D., D.G. Mitchell, and P.M. Chapman. 1986. Individual and combined toxicity of manganese

and molybdenum to mussel (

Mytilus edulis

) larvae. Bull. Environ. Contam. Toxicol. 37: 303-307.

Williams, L.G., P.M. Chapman, and T.C. Ginn. 1986. A comparative evaluation of bacterial luminescence,

oyster

embryo

and

amphipod

sediment

bioassays.

Mar.

Environ.

Res.

19: 225-249.

Chapman, P.M. 1985. Effects of gut sediment contents on measurements of metal levels in benthic

invertebrates - a cautionary note. Bull. Environ. Contam. Toxicol. 35: 345-347.

Long, E.R. and P.M. Chapman. 1985. A sediment quality triad: measures of sediment contamination,

toxicity and infaunal community composition in Puget Sound. Mar. Pollut. Bull. 16: 405-415.

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JOURNAL PUBLICATIONS Page 9 of 9

Mitchell, D.G., J.D. Morgan, G.A. Vigers, and P.M. Chapman. 1985. Acute toxicity of mine tailings to four

marine species. Mar. Pollut. Bull. 16: 450-455.

Chapman, P.M. and R.O. Brinkhurst. 1984. Lethal and sublethal tolerances of aquatic oligochaetes with

reference to their use as a biotic index of pollution. Hydrobiologia 115: 139-144.

Chapman, P.M. and R. Fink. 1984. Effects of Puget Sound sediments and their elutriates on the life cycle of

Capitella capitata

. Bull. Environ. Contam. Toxicol. 33: 451-459.

Geesey, G.G., L. Borstad, and P.M. Chapman. 1984. Influence of flow-related events on concentration and

phase distribution of metals in the lower Fraser River and a small tributary stream in British Columbia,

Canada. Water Res. 18: 233-238.

Chapman, P.M. and E.R. Long. 1983. The use of bioassays as part of a comprehensive approach to marine

pollution assessment. Mar. Pollut. Bull. 14: 81-84.

Chapman, P.M. and J.D. Morgan. 1983. Sediment bioassays with oyster larvae. Bull. Environ. Contam.

Toxicol. 31: 438-444.

Brinkhurst R.O., P.M. Chapman, and M.A. Farrell. 1983. A comparative study of respiration rates of some

aquatic oligochaetes in relation to sublethal stress. Int. Revue. Ges. Hydrobiol. 68: 683-699.

Chapman, P.M., M.A. Farrell, and R.O. Brinkhurst. 1982. Relative tolerances of selected aquatic

oligochaetes to individual pollutants and environmental factors. Aquat. Toxicol. 2: 47-67.

Chapman, P.M., M.A. Farrell, and R.O. Brinkhurst. 1982. Relative tolerances of selected aquatic

oligochaetes to combinations of pollutants and environmental factors. Aquat. Toxicol. 2: 69-78.

Chapman, P.M., M.A. Farrell, and R.O. Brinkhurst. 1982. Effects of species interactions on the survival

and respiration of

Limnodrilus hoffmeisteri

and

Tubifex tubifex

(Oligochaeta, Tubificidae) exposed to

various pollutants and environmental factors. Water Res. 16: 1405-1408.

Chapman, P.M., G.P. Romberg, and G.A. Vigers. 1982. Design of monitoring studies for priority

pollutants. J. Water Poll. Control Fed. 54: 292-297.

Thompson, K.A., D.A. Brown, P.M. Chapman, and R.O. Brinkhurst 1982. Histopathological effects and

cadmium-binding protein synthesis in the marine oligochaete

Monopylephorus cuticulatus

following

cadmium exposure. Trans. Am. Micros. Soc. 101: 10-26.

Chapman, P.M. 1981. Evidence for dissolved glucose uptake from seawater by

Neocalanus plumchrus

(Arthropoda, Copepoda). Can. J. Zool. 59: 1618-1621.

Chapman, P.M. 1981. A new species of

Homochaeta

(Oligochaeta:Naididae) from the West Coast of

Canada. Proc. Biol. Soc. Wash. 94: 455-457.

Chapman, P.M. 1981. Seasonal changes in the depth distributions of interstitial salinities in the Fraser River

estuary, British Columbia. Estuaries 4: 226-228.

Chapman, P.M. 1981. Measurements of the short-term stability of interstitial salinities in subtidal estuarine

sediments. Estuarine Coastal Shelf Sci. 12: 67-81.

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JOURNAL PUBLICATIONS Page 10 of 9

Chapman, P.M. and R.O. Brinkhurst. 1981. Seasonal changes in interstitial salinities and seasonal

movements of subtidal benthic invertebrates in the Fraser River estuary, BC. Estuarine Coastal Shelf

Sci. 12: 49-66.

Chapman, P.M. and R.O. Brinkhurst. 1980 Salinity tolerance in some selected aquatic oligochaetes. Int.

Rev. Geasamtem Hydrobiol. 65: 499-505.

Chapman, P.M., M.A. Farrell, and R.O. Brinkhurst. 1980. The tolerances of selected aquatic oligochaetes

to pollutants and environmental factors. Amer. Zool. 20: 1291-1293.

Chapman, P.M. 1979. The prostomial pit in

Bothrioneurum vejdovskyanum

Stolc (Oligochaeta) - a note on

detail revealed by SEM. Proc. Biol. Soc. Wash. 93: 812-813.

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CHAPTERS IN BOOKS Page 1 of 3

CHAPTERS IN BOOKS

Chapman, P.M. 2006. Environmental risk assessment of metals – present status, future prospects. In: H.

Allen and C. Janssen (eds.), Environmental Risk Assessment of Metals: New Concepts and

Applications. CRC Press, USA (in preparation).

Campbell, P.G.C., P.M. Chapman, and B. Hale. 2006. Risk assessment of metals in the environment. pp

102-131, In: Hester, R. E. and R. M. Harrison (eds.), Chemicals in the Environment: Assessing and

Managing Risk. Issues in Environmental Science and Technology Volume 22, Royal Society of

Chemistry, Cambridge, UK.

DelValls, T.A., P.M. Chapman, P. Drake, M.D. Subida, C. Vale, D.F. de al Reguera, J. Blasco. 2006.

Benthos sediment quality assessments. In: D. Barcelo and M. Petrovic (eds.), Sediment Quality and

Impact Assessment of Pollutants. Elsevier Press, New York, NY (in press).

Scrimshaw, M.D., T.A. DelValls, J. Blasco, and P.M. Chapman. 2006. Sediment quality guidelines and

weight of evidence assessments. In: D. Barcelo and M. Petrovic (eds.), Sediment Quality and Impact

Assessment of Pollutants. Elsevier Press, New York, NY (in press).

Green, A.S., P.M. Chapman, H.E. Allen, P.G.C. Campbell, R.D. Cardwell, A. Crook, K. De

Schamphelaere, K. Delbeke, D.R. Mount, and W.A. Stubblefield. 2006. Toxicity for hazard

identification of metals and inorganic metal substances. In: Adams, W. and P.M. Chapman (eds.),

Assessing the Hazard of Metals and Inorganic Metal Substances in Aquatic and Terrestrial Systems.

SETAC Press, Pensacola, FL, USA. (in press).

Chapman, P.M. 2005. The Aznalcácollar accident (April 1998) – Some comments. pp 371-374 In: A.

DelValls Casillas and J. Blasco Moreno (eds.), Integrated Assessment and Management of the

Ecosystems Affected by the Aznalcácollar Mining Spill (SW Spain). IOC/ICAM/UNESCO Technical

Report.

Chapman, P.M. and B.G. McDonald. 2005. Risk assessment using the Sediment Quality Triad. Chapter 10,

pp. 305-330, In: C. Blaise and J.-F. Férard (eds.), Small-Scale Freshwater Toxicity Test Investigations,

Volume 2: Hazard Assessment Schemes. Kluwer Academic Press, Netherlands.

Chapman, P.M., R.M. Burgess, W.H. Clements, W.S. Douglas, M.C. Harrass, C. Hogstrand, D.D. Reible,

and A.H. Ringwood. 2005. Uncertainties in assessments of complex sediment systems. Pp 687-744. In:

Wenning, R., C. Ingersoll, G. Batley, and M. Moore (eds.), Use of Sediment Quality Guidelines

(SQGs) and Related Tools for the Assessment of Contaminated Sediments. SETAC Press, Pensacola,

FL, USA.

Chapman, P.M., W.S. Douglas, M.C. Harrass, R.M. Burgess, D.D. Reible, W.H. Clements, A.H.

Ringwood, C. Hogstrand, and W.J. Birge. 2005. Role of sediment quality guidelines and other tools in

different aquatic habitats. Pp 267-309. In: Wenning, R., C. Ingersoll, G. Batley, and M. Moore (eds.),

Use of Sediment Quality Guidelines (SQGs) and Related Tools for the Assessment of Contaminated

Sediments. SETAC Press, Pensacola, FL, USA.

Chapman, P.M. 2005. Inorganic metals and metalloids ERA – Recent advances and implications for LCIA.

pp. 214-219. In: A.A. Dubreuil (ed.), Life Cycle Assessment of Metals – Issues and Research

Directions. SETAC Press, Pensacola, FL, USA.

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CHAPTERS IN BOOKS Page 2 of 3

Chapman, P.M., K. Ho., W. Munns, K. Solomon, and M.P. Weinstein. 2002. Issues in sediment toxicity

and ecological risk assessment. pp. 1-3. In: M.P. Weinstein and W.S. Douglas (eds), Sediment Toxicity

Risk Assessment: Where Are We and Where Should We Be Going? Sea Grant, Cambridge,

Massachusetts.

Chapman, P.M. 2002. Integrating toxicology and benthic ecology: putting the eco back into ecotoxicology.

pp.43-58. In: M.P. Weinstein and W.S. Douglas (eds), Sediment Toxicity Risk Assessment: Where Are

We and Where Should We Be Going? Sea Grant, Cambridge, Massachusetts.

Chapman, P.M. and F. Wang. 2000. Issues in environmental risk assessments of metals. pp.505-507. In:

J.A. Centeno, P. Collery, G. Vernet, R.B. Finkelman, H. Gibb, and J-C. Etienne (eds), Metal Ions in

Biology and Medicine, Volume 6. John Libbey, Montrouge, France.

Chapman, P.M. 1998. Issues of uncertainty in aquatic ecology and toxicology. pp. 131-139. In: W.J.

Warren-Hicks and D.R.J. Moore (eds.), Uncertainty Analysis in Ecological Risk Assessment. SETAC

Press, Pensacola, Florida.

Chapman, P.M. 1997. Death by mud: amphipod sediment toxicity tests. pp.451-463. In: P.G. Wells, K. Lee,

and C. Blaise (eds.), Microscale Aquatic Toxicology - Advances, Techniques and Practice. CRC Press,

Boca Raton, Florida.

Chapman, P.M., M. Cano, A. Fritz, C. Gaudet, C. Menzie, M. Sprenger, and W. Stubblefield. 1997.

Sediment ecological risk assessments at hazardous waste sites. pp.83-114. In: C.G. Ingersoll, T. Dillon

and G.R. Biddinger (eds.), Ecological Risk Assessment of Contaminated Sediments. SETAC Press,

Pensacola, Florida.

Chapman, P.M. 1995. Recent perspectives in integrated monitoring. pp.651-657. In: M.R. Servos, K.R.

Munkittrick, J.H. Carey, and G. van der Kraak (eds), Environmental Fate and Effects of Pulp and

Paper Mill Effluents. St. Lucie Press, Boca Raton, Florida.

Chapman, P.M., E.A. Power, and G.A. Burton, Jr. 1992. Chapter 14. Integrative assessments in aquatic

ecosystems. pp. 313-340. In: G.A. Burton, Jr. (ed.), Contaminated Sediment Toxicity Assessment.

Lewis Publishers, Chelsea, Michigan.

Power, E.A. and P.M. Chapman. 1992. Chapter 1. Assessing sediment quality. pp. 1-18. In: G.A. Burton,

Jr. (ed.), Contaminated Sediment Toxicity Assessment. Lewis Publishers, Chelsea, Michigan.

Power, E.A., K.R. Munkittrick, and P.M. Chapman 1991. An ecological impact assessment framework for

decision making related to sediment quality. pp. 48-64. In: Mayers, M.A. and M.G. Barron (eds.),

Aquatic Toxicity and Risk Assessment: Fourteenth Volume, ASTM STP 1124.

Chapman, P.M. 1988. Summary of biological effects in Puget Sound - past and present. pp 169-183. In:

D.A. Wolfe and T.P. O’Connor (eds.), Oceanic Processes in Marine Pollution: Vol. 5, Urban Wastes in

Coastal Marine Environments. Robert E. Krieker Pub. Co., Malabar, Florida.

Chapman, P.M. 1988. Marine sediment toxicity tests. pp. 391-402. In: J.J. Lichtenberg, F.A. Winter, C.L.

Weber, and L. Fredkin (eds.), Chemical and Biological Characterization of Sludges, Sediments,

Dredge Spoils, and Drilling Muds. ASTM STP 976.

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CHAPTERS IN BOOKS Page 3 of 3

Chapman, P.M., D.M. Leslie, and J.G. Michaelson. 1987. Why fish mortality in bioassays with aluminum

reduction plant wastes don’t always indicate chemical toxicity. pp. 677-688. In: R.D. Zabreznik (ed.),

Light Metals 1987. The Metallurgical Society of AIME, Denver, Colorado.

Chapman, P.M., R.N. Dexter, R.M. Kocan, and E.R. Long. 1985. An overview of biological effects testing

in Puget Sound, Washington - methods, results and implications. pp. 344-363. In: R.D. Cardwell, R.

Purdy, and R.C. Bahner (eds.), Aquatic Toxicology and Hazard Assessment: Seventh Symposium,

ASTM STP 854.

Reish, D.J., P.M. Chapman, and C. Pesch. 1985. Section 806. Toxicity test procedures for annelids. pp.

756-764. In: APHA Standard Methods for the Examination of Water and Wastewater, 16th Edition.

Chapman, P.M., L.M. Churchland, P. Thompson, and E. Michnowsky. 1980. Heavy metal studies with

oligochaetes. pp. 841-506. In: R.O. Brinkhurst and D.G. Cook (eds.), Aquatic Oligochaete Biology.

Plenum Press, New York New York.

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LEARNED DISCOURSES

Page 1 of 1

LEARNED DISCOURSES

Hellou, J., P.M. Chapman, J. Neff, K. Gustafson, S. Mala Bard, M. Parsons, and K. Hedley. 2005.

Serendipity and environmental science: is there a place for serendipity in science? SETAC Globe 6(1):

35-36.

Chapman, P.M. and C. McPherson. 2004. Possible selenium thresholds for trout. SETAC Globe 5(6):

22-25.

Chapman, P.M. and M.J. Riddle. 2003. Polar ecotoxicology. SETAC Globe 4(6): 34-35.

Chapman, P.M. 2003. Appropriately protecting against selenium in aquatic environments. SETAC Globe

4(3).

Gobas F. A. P. C., R. Purdy, G. Granville, C. Cowan-Ellsbery, J. Gannon, M. Lewis, and P. M. Chapman.

2001. Proposal for hazard identification of organic chemicals based on inherent toxicity. SETAC

Globe 2(4): 33-34.

Chapman, P.M., W.J. Birge, W.J. Adams, R. Barri, T.L Bott, A. Burton, T.K. Collier, H.L. Cumberland,

W.S. Douglas, L.L. Johnson, G.W. Luther III, T.O’Connor, D.S. Page, P. Sibley, L.J. Standley, and

R.J. Wenning. 2001. Sediment quality values (SQVs) - challenges and recommendations. SETAC

Globe 2 (2): 24-26.

Chapman, P.M. and D. Di Toro. 2001. The Society for Environmental Engineering, Ecological Toxicology

and Chemistry (SE

3

TAC). SETAC Globe 2 (2): 32-33.

Chapman, P.M. 2000. Aquatic oligochaetes are useful for (but underutilized in) ecological risk assessment

(ERA). SETAC Globe 1 (5): 32-33.

Chapman, P.M. 1999. Hazard ranking of inorganic metals and metal compounds. SETAC News 19 (6):

21-22.

Chapman, P.M. 1999. Are persistence, bioaccumulation and toxicity (PBT) appropriate criteria for ranking

the hazards of inorganic metals and metal compounds? International Council on Metals and the

Environment Newsletter 8 (3): 1-2.

Chapman, P.M. 1998. Are we really measuring dissolved metals? SETAC News 18 (6): 25-26.

Ethier, G. and P.M. Chapman. 1998. Risk ranking of metals and metal compounds. SETAC News 18(4):

23-24.

Chapman, P.M. 1997. Is bioaccumulation useful for predicting impacts? SETAC News 17(6): 19-20

Chapman, P.M., B. Anderson, S. Carr, V. Engle, R. Green, J. Hameedi, M. Harmon, P. Haverland, J.

Hyland, C. Ingersoll, E. Long, J. Rodgers Jr., M. Salazar, P.K. Sibly, P.J. Smith, R.C. Swartz, B.

Thompson, and H. Windom. 1997. Considerations for using the Sediment Quality Triad. SETAC News

17(2): 17-18.

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LEARNED DISCOURSES

Page 2 of 1

Chapman, P.M. 1996. SEM:AVS does not predict sediment toxicity. SETAC News 16(2): 13-14.

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Peter M. Chapman

DEBATES/COMMENTARIES

Page 1 of 1

INTRODUCTIONS TO DEBATES/COMMENTARIES

Chapman, P.M. 2004. Ecological risk assessments at petroleum-contaminated terrestrial sites. Human Ecol.

Risk Assess. 10: 183-184.

Chapman, P.M. 2002. Immunotoxicology and risk assessment - present prospects, future directions. Human

Ecol. Risk Assess. 8: 217-252.

Chapman, P.M. 1999. Does the Precautionary Principle have a role in risk assessment? Human Ecol. Risk

Assess. 5: 885-888.

Chapman, P.M. 1999. The role of soil microbial tests in ecological risk assessment. Human Ecol. Risk

Assess. 5: 657-660.

Chapman, P.M. 1998. Imprecision of risk assessment numbers II - An inexact science? Human Ecol. Risk

Assess. 4: 243-244.

Chapman, P.M. 1997. Imprecision of risk assessment numbers I - Recent agency directions. Human Ecol.

Risk Assess. 3: 665-666.

Chapman, P.M. 1997. Multiple chemical sensitivity IMCS/Idiopathic Environmental Intolerances (IEI).

Human Ecol. Risk Assess. 3: 127-128.

Chapman, P.M. 1996. The role of biomarkers in risk assessment. Human Ecol. Risk Assess.

2: 243-244.

Chapman, P.M. 1996. Beyond quotients: costs and benefits of using quantitative risk assessment

approaches in regulatory programs. Human Ecol. Risk Assess. 2: 10.

Chapman, P.M., 1995. Homocentric versus biocentric - viewpoints in risk assessment. Human Ecol. Risk

Assess. 1: 467-469.

Chapman, P.M. 1995. How useful are single species toxicity tests? Human Ecol. Risk Assess. 1: 163-166.

Chapman, P.M. 1995. How should numerical criteria be used? Human Ecol. Risk Assess. 1: 1-4.

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Peter M. Chapman

EDITORIAL PUBLICATIONS Page 1 of 1

EDITORIAL PUBLICATIONS

Adams, W.J. and P.M. Chapman (eds). 2006. Assessing the hazard of metals and inorganic metal

substances in aquatic and terrestrial systems. SETAC Press, Pensacola, FL.

Adams, W.J. and P.M. Chapman (eds). 2005. Summary Booklet: Assessing the hazard of metals and

inorganic metal substances in aquatic and terrestrial systems. SETAC Press, Pensacola, FL.

EPA/U.S.ACOE. 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the U.S. -

Testing Manual. U.S. Environmental Protection Agency and U.S. Army Corps of Engineers. EPA-

823-B-98-004. Washington, D.C.

Wu, R.S.S., C. Sheppard, R.M. Atlas, P.M. Chapman, D.W. Connell, E.D. Goldberg, A.D. McIntyre, and

P.S. Rainbow (eds). 1995. Selected papers from the International Conference on Marine Pollution and

Ecotoxicology, Hong Kong, January 1995. Mar. Pollut. Bull. 31: 478 pp.

Chapman, P.M., F.S. Bishay, E.A. Power, K. Hall, L. Harding, D. McLeay, M. Nassichuk, and W. Knapp

(eds.). 1991. Proceedings of the 17th Annual Aquatic Toxicity Workshop, Vancouver, BC, November

5-7, 1990. Can. Tech. Rep. Fish. Aquat. Sci. 1774. 1223 pp.

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Peter M. Chapman

PUBLISHED PROCEEDINGS

Page 1 of 4

PUBLISHED PROCEEDINGS

Chapman, P. M. 2006. Monitoring and managing risks of selenium toxicity in the aquatic environment. In:

Proceedings of the 33

rd

Annual Aquatic Toxicity Workshop. October 1 to 4, 2006, Jasper, AB. Can.

Tech. Rept. Fish. Aquatic Sci. (in press).

Chapman, P. M., H. Ohlendorf, B. McDonald, A. De Bruyn, R. Jones. 2006. A comprehensive conceptual

model for managing selenium inputs from coal mines. In: Proceedings of the 33

rd

Annual Aquatic

Toxicity Workshop. October 1 to 4, 2006, Jasper, AB. Can. Tech. Rept. Fish. Aquatic Sci. (in press).

Wernick, B., P. M. Chapman and L. Patterson. 2006. Developing a long-term plan for monitoring aquatic

effects from an oil spill to Wabamun Lake. In: Proceedings of the 33

rd

Annual Aquatic Toxicity

Workshop. October 1 to 4, 2006, Jasper, AB. Can. Tech. Rept. Fish. Aquatic Sci. (in press).

Wernick, B., P. M. Chapman and L. Patterson. 2006. The effects of an oil spill on the benthic invertebrate

community of Wabamun Lake. In: Proceedings of the 33

rd

Annual Aquatic Toxicity Workshop.

October 1 to 4, 2006, Jasper, AB. Can. Tech. Rept. Fish. Aquatic Sci. (in press).

Carmichael, N. B. and P. M. Chapman. 2006. Baseline selenium in sculpins related to the northeast coal

zone. In: Proceedings of the 30th Annual British Columbia Mining Reclamation Symposium – “Case

Studies of Reclamation and Environmental Protection”, British Columbia Technical and Research

Committee on Reclamation, Smithers, BC, June 19-22, 2006.

Davidson, S. and P. M. Chapman. 2006. Selenium source characterization and receiving environment

monitoring at the Kemess South Mine. In: Proceedings of the 30th Annual British Columbia Mining

Reclamation Symposium – “Case Studies of Reclamation and Environmental Protection”, British

Columbia Technical and Research Committee on Reclamation, Smithers, BC, June 19-22, 2006.

Chapman, P.M. 2005. Determining when contamination is pollution – weight of evidence determinations

for sediments and other environmental compartments. pp. 5-6 In: The Environment: A Challenge for

the Scientific Research. Sociedad Iberoamericana de Contaminación y Toxicologia Ambiental,

September 25-28, 2005, Cadiz, Spain.

Chapman, P.M. 2005. Selenium status – Elk River Valley, BC. (9 pages) In: W. Price, B. Hart, B. Dixon, P.

Jarman, B. Riordan, M. Freberg, and C. Howell, Proceedings of the Twenty-Ninth Annual British

Columbia Mining Reclamation Symposium – “The Many Facets of Mine Reclamation”, British

Columbia Technical and Research Committee on Reclamation, Abbottsford, BC, September 19-22,

2005.

Chapman, P.M. 2005. Selenium monitoring and management – new mines (15 pages) In: W. Price, B. Hart,

B. Dixon, P. Jarman, B. Riordan, M. Freberg, and C. Howell, Proceedings of the Twenty-Ninth Annual

British Columbia Mining Reclamation Symposium – “The Many Facets of Mine Reclamation”, British

Columbia Technical and Research Committee on Reclamation, Abbottsford, BC, September 19-22,

2005.

[Awarded the Tony Milligan Book Prize for Best Presentation]

Chapman, P.M. 2004. Serendipity is the future of aquatic toxicology. In: L.E. Burridge, K. Haya, and A.J.

Niimi, Proceedings of the 31

st

Annual Aquatic Toxicity Workshop. October 24 to 27, 2004,

Charlottetown, PEI. Can. Tech. Rept. Fish. Aquatic Sci. 2562: 123.

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Peter M. Chapman

PUBLISHED PROCEEDINGS

Page 2 of 4

Chapman, P.M. 2004. Selenium from coal mining in the Elk River Valley, British Columbia, Canada. In:

L.E. Burridge, K. Haya, and A.J. Niimi, Proceedings of the 31

st

Annual Aquatic Toxicity Workshop.

October 24 to 27, 2004, Charlottetown, PEI. Can. Tech. Rept. Fish. Aquatic Sci. 2562: 84-85.

Chapman, P.M. and J. Anderson. 2004. A decision-making framework for contaminated sediments. In: L.E.

Burridge, K. Haya, and A.J. Niimi, Proceedings of the 31

st

Annual Aquatic Toxicity Workshop.

October 24 to 27, 2004, Charlottetown, PEI. Can. Tech. Rept. Fish. Aquatic Sci. 2562: 33.

Chapman, P.M. 2004. Selenium from coal mining in the Elk River Valley. In: The 4 Rs: Reclamation,

Revegetation, Research and Risk. Proceedings for the 28

th

Annual British Columbia Mine Reclamation

Symposium. British Columbia Technical and Research Committee on Reclamation. Cranbrook, BC,

June 21-24, 2004. Chapter 19.

Chapman, P.M., F. Wang, R.R. Goulet, and C. Kamunde. 2003. Hazard and ecological risk assessments of

metals, metalloids and inorganic metal substances. In: K. Hedley, S. Roe, and A.J. Niimi, Proceedings

of the 30

th

Annual Aquatic Toxicity Workshop. September 28 to October 1, 2003, Ottawa, ON. Can.

Tech. Rept. Fish. Aquatic Sci. 2510: 31-32.

McDonald, B.C. and P.M. Chapman. 2002. Sediment PAH phototoxicity – An ecologically irrelevant

phenomenon? In: C.V. Eichkoff, G.C. van Aggelen, and A.J. Niimi. Proceedings of the Twenty-Ninth

Annual Aquatic Toxicity Workshop. September 29-October 2, 2002, Whistler, BC. Can. Tech. Rept.

Fish. Aquatic Sci.2438: 131-132

Chapman, P.M. 2002. Weight of evidence determinations in ecological risk assessment. In: C.V. Eichkoff,

G.C. van Aggelen, and A.J. Niimi. Proceedings of the Twenty-Ninth Annual Aquatic Toxicity

Workshop. September 29-October 2, 2002, Whistler, BC. Can. Tech. Rept. Fish. Aquatic Sci. 2438:

123.

Bailey, H.C., E.J. Raggett, P.M. Chapman, and F.M. Murphy. 2002. Development of an environmental

effects monitoring program for the Eskay Creek Mine. In: C.V. Eichkoff, G.C. van Aggelen, and A.J.

Niimi. Proceedings of the Twenty-Ninth Annual Aquatic Toxicity Workshop. September 29-October

2, 2002, Whistler, BC. Can. Tech. Rept. Fish. Aquatic Sci. 2438: 18.

Chapman, P.M. 2001. The utility and use of sediment quality values (SQVs). p. 82. In: North Pacific

Marine Science Organizations (PICES) 10

th

Annual Meeting, October 5-13, 2001, Victoria, BC,

Canada.

Chapman, P.M. 2001. Hormesis, ecological risk assessment (ERA) and risk management. In: J.M.

McKernan, B. Wilkes, K. Mathers, and A.J. Niimi. Proceedings of the Twenty-Eighth Annual Aquatic

Toxicity Workshop. September 30 - October 3, 2001, Winnipeg, Manitoba. Can. Tech. Rept. Fish.

Aquatic Sci. 2379: 52.

Raggett, E.J., H.C. Bailey, and P.M. Chapman. 2001. Development of an environmental effects monitoring

program of Homestake’s Eskay Creek Mine. In: Proceedings of the Twenty-Fifth Annual BC Mine

Reclamation Symposium, Campbell River, BC. September 24-27, 2001. British Columbia Technical

and Research Committee on Reclamation Biotech Publishers Ltd., Richmond, BC.

Landry, F., F.M. Murphy, I.D. Sharpe, A. Fikart, and P.A. Chapman. 2000. Eskay Creek mine

environmental effects monitoring (EEM) program. In: K.C. Penney, K.A. Coady, M.H. Murdoch,

W.R. Parker, and A.J. Nimi (eds). Proceedings of the Twenty-Seventh Annual Aquatic Toxicity

Workshop, October 1 - 4, St. John’s, Newfoundland. Can. Tech. Rept. Fish Aquat. Sci. 2331: 53.

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Peter M. Chapman

PUBLISHED PROCEEDINGS

Page 3 of 4

Chapman, P.M. 2000. Bringing ecology back into toxicology. In: K.C. Penney, K.A. Coady, M.H.

Murdoch, W.R. Parker, and A.J. Nimi (eds). Proceedings of the Twenty-Seventh Annual Aquatic

Toxicity Workshop, October 1 - 4, St. John’s, Newfoundland. Can. Tech. Rept. Fish Aquat. Sci.

2331:109.

Chapman, P.M. 2000. Selenium - Environmental chemistry and toxicity issues. pp. 148-159. In:

Proceedings of the Twenty-Fourth Annual BC Mine Reclamation Symposium, Williams Lake, BC,

June 19-22, 2000. British Columbia Technical and Research Committee on Reclamation, Bitech

Publishers Ltd., Richmond, BC.

Chapman, P.M. 1999. Environmental quality guidelines provide guidance not goals. In: E.G. Baddaloo,

M.H. Mah-Paulson, A.G. Verbeek, and A.J. Niimi (eds.). Proceedings of the Twenty-Sixth Annual

Aquatic Toxicity Workshop, October 3-6, Edmonton. Can. Tech Rept. Fish Aquat. Sci. 2293:1.

Chapman, P.M. 1999. Selenium freshwater quality determinations. In: R.Van Coillie, R. Chasse, L. Hare,

C. Julien, L. Martel, C. Thellen, and A.J. Niimi (eds.). Proceedings of the Twenty-Fifth Annual

Aquatic Toxicity Workshop, October 18-21, Québec City. Can. Tech. Rept. Fish. Aquat. Sci. 2260:64.

Bailey, H., E. Canaria, and P.M. Chapman. 1999. Mine effluent-related total dissolved solids (TDS) and

water quality criteria. In: R.Van Coillie, R. Chasse, L. Hare, C. Julien, L. Martel, C. Thellen, and A.J.

Niimi (eds.). Proceedings of the Twenty-Fifth Annual Aquatic Toxicity Workshop, October 18-21,

Québec City. Can. Tech. Rept. Fish. Aquat. Sci. 2260:73.

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Peter M. Chapman

PUBLISHED PROCEEDINGS

Page 4 of 4

Chapman, P.M., A. Fairbrother, and D. Brown. 1997. The use of safety (uncertainty) factors in toxicology

and risk assessment. p. 76, In: A.J. Niimi, J.L. Parrott, and D.J. Spry (eds.). Proceedings of the

Twenty-Forth Annual Aquatic Toxicity Workshop, Niagara Falls, Ontario. October 19-23, 1997. Can.

Tech. Rep. Fish Aquat. Sci. 2192.

Chapman, P.M., P.J. Allard, and G.A. Vigers. 1997. Hong Kong sediment quality values and

decision-making. pp. 68-72. In: J.S. Goudey, S.M. Swanson, M.D. Treissman, and A.J. Niimi (eds.),

Proceedings of the Twenty-Third Annual Aquatic Toxicity Workshop, Calgary, Alberta, October 6-9,

1996. Can. Tech. Rep. Fish. Aquatic Sci. 2144.

Murdoch, M.H., P.M. Chapman, D.M. Johns, and M.D. Paine. 1996. Chronic effects of pesticide exposure

in sediment to the marine polychaete

Neanthes arenaceodentata

. p. 83. In: K. Haya and A.J. Niimi

(eds.). Proceedings of the Twenty-Second Annual Aquatic Toxicity Workshop, St. Andrews, New

Brunswick, October 2-4,1995. Can. Tech. Rep. Fish. Aquat. Sci. 2093.

Chapman, P.M. 1995. Toxicology and decision-making. pp. 142-156. In: D. Watson, K.-S. Ong, and G.

Vigers (eds.). Advances in Marine Environmental Management and Human Health Protection.

ASEAN Criteria and Monitoring. ASEAN-Canada Cooperative Program on Marine Science, Kuala

Lumpur, Malaysia.

Taylor, L.A., P.M. Chapman, R.A. Miller, and R.V. Pym. 1995. Victoria’s wastewater discharges: effects

on the marine environment. pp. 1-15. In: Proceedings of Puget Sound Research 1995. Puget Sound

Water Quality Authority, Washington, U.S.A.

Chapman, P.M. and C.A. McPherson. 1993. The tolerance of arctic marine invertebrates to zinc and lead

and implications for arctic chemical discharges. pp.7-22. In: E.G. Baddaloo, S. Ramamoothy, and J.W.

Moore (eds.), Proceedings of the Nineteenth Annual Aquatic Toxicity Workshop, October 4-7, 1992,

Edmonton, Alberta. Can. Tech. Rept. Fish Aquat. Sci. 1942.

Chapman, P.M., C. Heip, and W. Cofino. 1993. What is the pollution status of North Sea sediments? pp.

375-396. In: E.G. Baddaloo, S. Ramamoothy, and J.W. Moore (eds.), Proceedings of the Nineteenth

Annual Aquatic Toxicity Workshop, October 4-7, 1992, Edmonton, Alberta. Can. Tech. Rept. Fish

Aquat. Sci. 1942.

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1993. Do sewage discharges from Victoria

(B.C.) pose a major environmental problem? -toxicity and related studies. pp.429-435. In: E.G.

Baddaloo, S. Ramamoothy, and J.W. Moore (eds.), Proceedings of the Nineteenth Annual Aquatic

Toxicity Workshop, October 4-7. 1992, Edmonton, Alberta. Can. Tech. Rept. Fish Aquat, Sci. 1942.

Chapman, P.M. 1993. The bottom line is sediment: fact & fallacies. pp. 3-10. In: Assessment and

Treatment of Contaminated Sediments in the North Branch Chicago River: a model approach for an

urban waterway. U.S. Dept of Interior - Bureau of Mines, and Northeastern Illinois Planning

Commission. Chicago, IL.

Chapman, P.M. 1992. Regulatory uses of aquatic toxicology - pitfalls and opportunities. pp.2-12. In: A.J.

Niimi and M.C. Taylor (eds.), Proceedings of the Eighteenth Annual Aquatic Toxicity Workshop,

September 30 - October 3, 1991, Ottawa, ON. Can. Tech. Rept. Fish. Aquat. Sci. 1863.

Chapman, P.M. 1991. Environmental quality benchmarks - are we doing it right? pp.33-35. In: Pacific

Paper Expo 1991, Technical Conference Proceedings, December 4-6, 1991, Vancouver, BC.

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Peter M. Chapman

PUBLISHED PROCEEDINGS

Page 5 of 4

Chapman, P.M. 1989. Sediment quality criteria - developmental approaches. pp. 412-414. In: Oceans ’89,

Proceedings. Marine Technology Society and Oceanic Engineering Society, Washington, DC.

Chapman, P.M. 1989. Sediment toxicity tests - the bottom line for scientists, the public, managers and

regulators. pp. 21.0-21.20. In: In Search of Environmental Solutions, Lambton Industrial Society,

Sarnia, Ontario.

Chapman, P.M. 1989. Salmonid toxicity studies with Roundup. In: Proceedings, Carnation Creek Herbicide

Workshop. December 8-10, 1987, Nanaimo, BC.

Chapman, P.M. 1988. Salmonid toxicity studies with Roundup. pp. 82-92. In: A Summary of Proceedings

for the Herbicides Issues Seminar. June 28-29, 1988, Richmond, BC., Monsanto Canada.

Chapman, P.M. 1987. Biological field sampling. In: ASEAN-Canada Workshop on Pollution and Other

Ecological Factors in Relation to Living Marine Resources, June 23-26, 1987, Phuket, Thailand.

Chapman, P.M. 1987. Sediment quality criteria - water we waiting for? In: S.M. Woods (ed.), Report on

Ocean Dumping R and D Pacific Region, Department of Fisheries and Oceans 1984-1985. Canadian

Contractor Report of Hydrography and Ocean Sciences.

Chapman, P.M., D.M. Leslie, and J.G. Michaelson. 1987. Why fish mortality in bioassays with aluminum

reduction plant wastes don’t always indicate chemical toxicity. pp. 677-688. In: R.D. Zabreznik (ed.),

Light Metals 1987. Conference Proceedings, the Metallurgical Society of AIME.

Chapman, P.M. 1986. Sediment bioassay tests provide toxicity data necessary for assessment and

regulation. pp. 178-197. In: G.H. Geen and K.L. Woodward (eds.), Proceedings of the Eleventh

Annual Aquatic Toxicity Workshop: November 13-15, 1984, Vancouver, British Columbia. Can.

Tech. Rept. Fish. Aquat. Sci. No. 1480.

Nix, P. and P.M. Chapman. 1986. Monitoring of underwater blasting operations in False Creek, BC. pp.

194-211. In: O.D. Greene, F.R. Englehardt, and R.J. Paterson (eds.), Proceeding of the Workshop of

Effects of Explosives Use in the Marine Environment. Ottawa, ON. Canadian Oil and Gas Lands

Administrative Technical Report 5.

Chapman, P.M., L.M. Churchland, P. Thompson, and E. Michnowsky. 1978. Tubificid oligochaetes as

monitors of heavy metal pollution. pp. 278-294. In: P.T.S. Wong et al. (eds.), Proceedings of the Fifth

Annual Aquatic Toxicity Workshop, November 7-9, 1978, Hamilton, ON. Fish. Mar. Ser. Tech. Rept.

862.

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Peter M. Chapman

PUBLISHED TECHNICAL REPORTS AND THESES Page 1 of 2

PUBLISHED TECHNICAL REPORTS AND THESES

Chapman, P.M. 2005. Selenium status report 2004 – Elk River Valley, BC. Elk Valley Selenium Task

Force, Sparwood, BC, Canada.

Chapman, P.M. and C. McPherson. 2003. Selenium status report 2003 – Elk River Valley, BC. Elk Valley

Mines Environmental Management Committee, Sparwood, BC, Canada.

Chapman, P.M. et al. IWG (Inorganics Working Group). 2001. Categorization of inorganic substances on

the Domestic Substances List (DSL). Findings and Recommendations from the Inorganics Working

Group (IWG). Environment Canada, Hull, PQ, Canada.

Chapman, P.M. 1996. Hazard identification, hazard classification and risk assessment for metals and metal

compounds in the aquatic environment. International Council on Metals and the Environment, Ottawa,

ON. 31 pp.

Cherr, G., P. Dinnel, R. Caldwell, R. Cardwell, and P.M. Chapman. 1994. West coast marine species

chronic protocol variability study: Criteria for acceptable variability of marine chronic toxicity test

methods. Washington State Biomonitoring Science Advisory Board Report No. 1. Washington

Department of Ecology, Olympia, WA.

Cherr, G., P. Dinnel, R. Caldwell, R. Cardwell, and P.M. Chapman. 1994. West coast marine species

chronic protocol variability study: Evaluation of results and recommended test methods. Washington

State Biomonitoring Science Advisory Board Report No. 2. Washington Department of Ecology,

Olympia, WA.

Lidstone, D., P.M. Chapman, W.L. Fisher, and K.R. MacCrimmon. 1993. Report of the Sewage Treatment

Review Panel: The Stage Two Liquid Waste Management Plan Process. Greater Vancouver Regional

District, Burnaby, BC.

Chapman, P.M. 1992. Sediment Quality Triad Approach. pp. 10-1 to 10-18. In: Sediment Classification

Methods Compendium. U.S. Environmental Protection Agency, EPA-823-R-92-006.

Lidstone, D., P.M. Chapman, W.L. Fisher, and K.R. MacCrimmon. 1992. Report of the Sewage Treatment

Review Panel. Greater Vancouver Regional District, Vancouver, BC.

Paine, M. and P.M. Chapman. 1992. Implementation of refinery effluent biomonitoring plan, tier I.

Canadian Petroleum Product Institute, CPPI Report #92-8, October 1992. 48 pp + Figs. + Tables +

Appendices.

Chapman, P.M. and E.A. Power. 1990. Sediment toxicity evaluation. American Petroleum Institute

Publication No.4501. Health & Environmental Sciences, April 1990. 209 pp. Order No. 841-45010.

Chapman, P.M. and K.R. Munkittrick. 1989. Interlaboratory comparison of the

Daphnia magna

acute

lethality bioassay. PACE Report No. 89-4. Petroleum Association for Conservation of the Canadian

Environment, Ottawa, ON. 28 pp.

Chapman, P.M. and D.G. Cook 1988. Listing toxics under CEPA - is the chemistry right? Canadian

Environmental Advisory Council ISBNO-662-16239-0. 20 pp.

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Peter M. Chapman

PUBLISHED TECHNICAL REPORTS AND THESES Page 2 of 2

Campbell, P.G.C., A.G. Lewis, P.M. Chapman, A.A. Crowder, W.K. Fletcher, B. Imber, S.N. Luoma, P.M.

Stokes, and M. Winfrey. 1988. Biologically available metals in sediments. National Research Council

of Canada Associate Committee on Scientific Criteria for Environmental Quality and Division of

Chemistry. Report No. 27694. Ottawa, Ontario. 296 pp.

Chapman, P.M., R.N. Dexter, S.F. Cross, and D.G. Mitchell. 1986. A field trial of the Sediment Quality

Triad in San Francisco Bay. NOAA Tech. Memo NOS OMA 25. 127 pp.

Chapman, P.M., R.N. Dexter, and L.S. Goldstein. 1985. Development of effective regional environmental

quality monitoring approaches for Puget Sound, Washington, U. S.A. NOAA Tech. Memo. NOS OMA

22. 177 pp.

Chapman, P.M., R.N. Dexter, R.D. Kathman, and G.A. Erickson. 1985. Survey of biological effects of

toxicants upon Puget Sound biota. IV. Interrelationships of infauna, sediment bioassay and sediment

chemistry data. NOAA Tech. Memo. NOS OMA 9. 57 pp.

Dexter, R.N., L.S. Goldstein, P.M. Chapman, and E.A. Quinlan. 1985. Temporal trends in selected

environmental parameters monitored in Puget Sound. NOAA Tech. Memo. NOS OMA 19. 166 pp.

Quinlan, E.A., P.M. Chapman, R.N. Dexter, D.E. Konasewich, G.A. Erickson, B.R. Kowalski, T.A. Silver,

and C.C. Ebbesmeyer. 1985. Toxic chemicals and biological effects in Puget Sound: status and

scenarios for the future. NOAA Tech. Memo. NOS OMA-10. 334 pp.

Chapman, P.M., R.N. Dexter, J. Morgan, R. Fink, D. Mitchell, R.M. Kocan, and M.L. Landolt. 1984.

Survey of biological effects of toxicants upon Puget Sound biota. III. Tests in Everett Harbor, Samish

and Bellingham Bays. NOAA Tech. Memo. NOS OMS-2. 48 pp.

Chapman, P.M., D.R. Munday, J. Morgan, R. Fink, R.M. Kocan, M.L. Landolt, and R.N. Dexter. 1984.

Survey of biological effects of toxicants upon Puget Sound biota II. Tests of reproductive impairment.

NOAA Tech Report NOS 102 OMS I. 58 pp. + appendices.

Chapman, P.M., G.A. Vigers, M.A. Farrell, R.N. Dexter, E.A. Quinlan, R.M. Kocan, and M. Landolt. 1982.

Survey of biological effects of toxicants upon Puget Sound biota. I. Broad-scale toxicity survey.

NOAA Tech. Memo. OMPA-25. 98 pp.

Konasewich, D.E., P.M. Chapman, G.A. Vigers, E. Gerencher, and N. Treloar. 1982. Effects, pathways,

processes and transformation of Puget Sound contaminants of concern. NOAA Tech. Memo. OMPA-

20. 357 pp.

Chapman, P.M. 1979. Seasonal movements of subtidal benthic communities in a salt wedge estuary as

related to interstitial salinities. Ph.D. Thesis, University of Victoria. 222 p.

Chapman, P.M. 1975. Uptake and assimilation of dissolved glucose from seawater by

Calanus plumchrus

V and its use in overwintering nutrition. M. Sc. Thesis, University of Victoria. 62 p.

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Peter M. Chapman

CO-AUTHORED U.S. EPA SCIENCE ADVISORY BOARD (SAB) REPORTS Page 1 of 1

CO-AUTHORED U.S. EPA SCIENCE ADVISORY BOARD (SAB) REPORTS

SAB. 1995. An SAB Report: Review of the Agency’s Approach for Developing Sediment Criteria for Five

Metals. Prepared by the Sediment Quality Criteria Subcommittee of the Ecological Processes and

Effects Committee, U.S. EPA Science Advisory Board, Washington, DC. EPA-SAB-EPEC-95-OXX.

SAB. 1995. Science Advisory Review of the Technical Basis for Listing Ammonia on the Toxics Release

Inventory (TRI). Report of the Toxics Reporting Subcommittee of the Ecological Processes and

Effects Committee, U.S. EPA Science Advisory Board, Washington, DC. EPA-SAB-EPEC-LTR-

95-001. 5 pp.

SAB. 1992. Technical Review of “Evaluation of Dredged Materials Proposed for Ocean Disposal - Testing

Manual”. Report of the Sediment Quality Subcommittee of the Ecological Processes and Effects

Committee, U.S. EPA Science Advisory Board, Washington, DC. EPA-SAB-EPEC-92-014. 20 pp.

SAB. 1990. Review of the EPA Draft Research Plan: Global Climate Research Program. Report of the

Global Climate Research Subcommittee, U.S. EPA Science Advisory Board, Washington, DC.

EPA-SAB-EC-90-001. 20 pp.

SAB. 1989. Evaluation of the Apparent Effects Threshold (AET) Approach for Assessing Sediment

Quality. Report of the Sediment Quality Subcommittee of the Ecological Processes and Effects

Committee. U.S. EPA Science Advisory Board, Washington, DC. EPA-SAB-EETFC-89-027. 16 pp.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 1 of 9

PUBLISHED ABSTRACTS

Chapman, P. M. 2006. Environmental risks of inorganic metals and metalloids: A continuing, evolving

scientific odyssey. Presented at the Twenty-Seventh Annual Meeting of the Society of Environmental

Toxicology and Chemistry, November 13-17, 2005, Baltimore, MD.

Chapman, P. M., H. Ohlendorf, B. McDonald, A. de Bruyn, R. Jones. 2006. A comprehensive selenium

management model for coal mining. Presented at the Twenty-Seventh Annual Meeting of the Society

of Environmental Toxicology and Chemistry, November 13-17, 2005, Baltimore, MD.

Chapman, P.M. 2005. Environmental science in 2030: environmentally relevant, or don’t bother. Presented

at the Twenty-Sixth Annual Meeting of the Society of Environmental Toxicology and Chemistry,

November 13-17, 2005, Baltimore, MD.

Chapman, P.M., B. McDonald, P. Kickham, S.J. McKinnon. 2005. Global geographic differences in marine

metals toxicity. Presented at the Twenty-Sixth Annual Meeting of the Society of Environmental

Toxicology and Chemistry, November 13-17, 2005, Baltimore, MD.

Chapman, P.M. 2005. Ecotoxicological implications of bioavailability. Presented at the NIEHS, USEPA

and ATSDR Workshop on Bioavailability, November 9-10, 2005, Newark, New Jersey, USA.

Hunt, J., S. Taylor, and P.M. Chapman. 2005. Sediment quality assessment in the South Arm Hunger

River. Ecotox Australia, September 2005, Melbourne.

Chapman, P.M. 2005. A decision-making framework for contaminated sediments applicable to the

Canadian Great Lakes and elsewhere. Presented at the 15

th

Annual Meeting of SETAC Europe, May

22-26, 2005, Lille, France.

Chapman, P.M. and Anderson, J. 2004. A decision-making framework for contaminated sediments

applicable to the Canadian Great Lakes and elsewhere. Presented at the Twenty-Fifth Annual Meeting

of the Society of Environmental Toxicology and Chemistry, November 14-18, Portland, OR, USA.

Chapman, P.M. 2004. Indirect effects of contaminants and other stressors. Presented at the Twenty-Fifth

Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 14-18,

Portland, OR, USA.

Chapman, P.M. 2003. Ecotoxicological studies really count in polar environments. Presented at the

Twenty-Fourth Annual Meeting of the Society of Environmental Toxicology and Chemistry,

November 9-13, Austin, Texas.

Kamunde, C.N. and P.M. Chapman. 2003. Delineating pathways of metal accumulation in freshwater fish:

Improving uptake predictions for ecological risk assessment of metals. Presented at the Twenty-Fourth

Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 9-13, Austin,

Texas.

Adams, W.J., P.M. Chapman, P.G.C. Campbell, P. Doyle, S. Robertson, I. Schoeters, E. Smolders, J.

Westall, W. Wood, A. Green, and C.E. Schlekat. 2003. Hazard identification approach for metals and

inorganic metal substances. Presented at the Twenty-Fourth Annual Meeting of the Society of

Environmental Toxicology and Chemistry, November 9-13, Austin, Texas.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 2 of 9

Chapman, P.M. 2003. Ecotoxicology in polar environments – Environmental risk and management.

Presented at the Society of Environmental Toxicology and Chemistry Asia/Pacific and Australasian

Society for Ecotoxicology Meeting, September 28-October 1, Christchurch, New Zealand.

Burton, G.A., G.E. Batley, P.M. Chapman, V.E. Forbes, E.P. Smith, T. Reynoldson, C.E. Schlekat, P.J.

Den Besten, A.J. Barker, and A.S. Green. 2002. Weight of evidence framework: Improving certainty in

the decision-making process. Presented at the Twenty-Third Annual Meeting of the Society of

Environmental Toxicology and Chemistry, November 16-20, Salt Lake City, Utah.

Chapman, P.M. and B.G. McDonald. 2002. Is PAH phototoxicity an ecologically irrelevant phenomenon?

Presented at the Twenty-Third Annual Meeting of the Society of Environmental Toxicology and

Chemistry, November 16-20, Salt Lake City, Utah.

Chapman, P.M. 2002. Biocriteria as part of weight of evidence determinations in ecological risk

assessment. Presented at the Twenty-Third Annual Meeting of the Society of Environmental

Toxicology and Chemistry, November 16-20, Salt Lake City, Utah.

Chapman, P.M. 2002. Issues in risk and life-cycle assessment of metals and metalloids. Presented at the

International Workshop on Life Cycle Assessment and Metals. April 15-17, 2002, Montréal, PQ.

Chapman, P.M. 2001. The utility and use of sediment quality values (SQVs). Presented at the 10

th

Annual

Meeting of the North Pacific Marine Science Organization (PICES). October 11 - 13, 2001, Victoria,

BC.

Chapman, P.M. 2001. Does hormesis have a role in ecological risk assessment (ERA)? Presented at the

Twenty-Second Annual Meeting of the Society of Environmental Toxicology and Chemistry,

November 11 - 15, 2001, Baltimore, MD.

Chapman, P.M. and G. Lawrence. 2001. Risk management of contaminated sediments in Homebush Bay,

Australia; Sediment Quality Triad studies (SQT) and ecological risk assessment (ERA). Presented at

the Twenty-Second Annual Meeting of the Society of Environmental Toxicology and Chemistry,

November 11 - 15, 2001, Baltimore, MD.

Chapman, P.M. 2000. Linking sediment toxicity and benthic population studies: Where are we and where

should we be going? Presented at the Sea Grant Workshop, Options for Dredged Material Disposal

Management. December 3 - 6, 2000, Cambridge, Massachusetts.

Chapman, P.M. and F. Wang. 2000. Sediment risk assessment in estuaries is not the same as for fresh or

marine environments! Presented at the Twenty-First Annual Meeting of the Society of Environmental

Toxicology and Chemistry, November 12 - 16, 2000, Nashville, Tennessee.

Chapman, P.M. 2000. Putting the ecology into ecotoxicology. Presented at the Tenth Meeting of the

Australian Marine Sciences Association, July 11-14, Sydney, Australia.

Chapman, P.M. 2000. Biological uptake in marine organisms. Presented at the Victoria and Esquimalt

Harbours Environmental Action Program (VEHEAP) Sediment Workshop. June 29, 2000, Victoria,

BC.

Chapman, P.M. 2000. Interpreting/integrating multiple endpoints. Presented at the Third SETAC (Society

of Environmental Toxicity and Chemistry) World Congress. May 21-25, 2000, Brighton, U.K.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 3 of 9

Chapman, P.M. 2000. Issues in Environmental Risk Assessments of Metals. Presented at the Sixth

International Symposium on Metal Ions in Biology and Medicine, May 7-10, 2000, San Juan, Puerto

Rico.

Chapman, P.M. 1999. U-Shaped (or

β)

concentration-response curves: the case for a paradigm shift.

Presented at the Twentieth Annual Meeting of the Society of Environmental Toxicology and

Chemistry, November 14-18, 1999, Philadelphia, PA.

Chapman, P.M. 1999. Selenium, salmon, science and site-specific guidelines. Presented at the Symposium

on Selenium in Aquatic Environments: Biogeochemistry, Remediation, Criteria, Risk Assessment,

Toxicity, Modeling, Speciation Analysis, and Ecology, June 7-8, 1999, San Francisco, CA.

Chapman, P.M. 1999. U-shaped concentration - response curves: implications for ecotoxicology. Presented

at the 1999 meeting of the Pacific Northwest Chapter of the Society for Environmental Toxicology and

Chemistry, May 13-15, 1999, Vancouver, BC.

Chapman, P.M. 1999. New and emerging issues in ecotoxicology, or The shape of testing to come.

Presented at the Royal Australian Chemistry Institute/Australasian Society for Ecotoxicology

EnviroTox’99 Conference, February 7-10, 1999, Geelong, Australia.

Chapman, P.M. 1998. Whole effluent toxicity testing - problems and solutions. Presented at the Nineteenth

Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 15-19, 1998,

Charlotte, NC.

Chapman, P.M. 1998. Using sediment quality values in ecological risk assessment of dredging operations.

Presented at the Nineteenth Annual Meeting of the Society of Environmental Toxicology and

Chemistry, November 15-19, 1998, Charlotte, NC.

Chapman, P.M., H. Bailey, and E. Canaria. 1998. Toxicity of total dissolved solids (TDS) from mine

effluent related to water quality criteria. Presented at the Nineteenth Annual Meeting of the Society of

Environmental Toxicology and Chemistry, November 15-19, 1998, Charlotte, NC.

Chapman, P.M. 1998. Sediment quality values (SQVs), ecological risk assessment (ERA) and dredged

material management. Presented at the U.S. Army Corps of Engineers Workshop on Environmental

Risk Assessment and Dredged Material Management: Issues and Application, February 17-20, 1998,

San Diego, CA.

Allard, P.J., P.M. Chapman, C.A. McPherson, and G.A. Vigers. 1997. Development and application of

interim sediment quality criteria for dredged material disposed in Hong Kong. Presented at the

Eighteenth Annual Meeting of the Society of Environmental Toxicology and Chemistry, November

16-20, 1997, San Francisco, CA.

Chapman, P.M., A. Fairbrother, and D. Brown. 1997. The use of safety (uncertainty) factors in risk

assessment. Presented at the Eighteenth Annual Meeting of the Society of Environmental Toxicology

and Chemistry, November 16-20, 1997, San Francisco, CA.

Chapman, P.M. and R. Parrish. 1997. In search of bioavailability. Presented at the Eighteenth Annual

Meeting of the Society of Environmental Toxicology and Chemistry, November 16-20, 1997, San

Francisco, CA.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 4 of 9

DelValls, T.A. and P.M. Chapman. 1997. The use of multivariate analysis to link the Sediment Quality

Triad components defining site-specific sediment quality values in the Gulf of Cadiz (Spain) and in

San Francisco Bay (USA). Presented at the Second Symposium on the Atlantic Iberian Continental

Margin, September 16-20, 1997, Cadiz, Spain.

Chapman, P.M. 1996. Difficulties testing the aquatic toxicity of sparingly soluble metals. Presented at the

Seventeenth Annual Meeting of the Society of Environmental Toxicology and Chemistry, November

17-21, 1996, Washington, DC.

Chapman, P.M. 1996. Is bioaccumulation useful for predicting impacts? Presented at the Seventeenth

Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 17-21, 1996,

Washington, DC.

Chapman, P.M., C. McPherson, and C. MacCay. 1996. Natural pollution and the NPDES permit process:

the Red Dog Mine, Alaska. Presented at the Seventeenth Annual Meeting of the Society of

Environmental Toxicology and Chemistry, November 17-21, 1996, Washington, DC.

Chapman, P.M. 1996. CRD outfalls and other projects: cost effective, understandable environmental

studies. Presented at the British Columbia Wastewater Association Annual Conference, Kelowna, BC,

April 22-24, 1996.

Murdoch, M.H., J.V. Stewart, J.L. Crane, C.A. McPherson, and P.M. Chapman. 1995. Reference toxicant

test results - what do we do with them? Presented at the Second SETAC (Society of Environmental

Toxicology and Chemistry) World Congress, November 5-9, 1995, Vancouver, BC.

Watson, T., M. Rankin, E. Garay, P.M. Chapman, B. Power, L. McCarty. 1995. Approaches for developing

probability distribution functions for acceptable toxicity reference values in risk management.

Presented at the Second SETAC (Society of Environmental Toxicology and Chemistry) World

Congress, November 5-9, 19953 Vancouver, BC.

DeWitt, T.H., R.C. Swartz, J.Q. Word, K.J. Scott, and P.M. Chapman. 1995. From death to extinction:

interpreting existing and forthcoming amphipod sediment toxicity tests. Presented at the Second

SETAC (Society of Environmental Toxicology and Chemistry) World Congress, November 5-9, 1995,

Vancouver, BC.

Allard, P.J., P.M. Chapman, M.H. Murdoch, M.D. Paine, and D. Minifie. 1995. Further evidence for

limited bioavailability of sediment PAH from an aluminum smelter. Presented at the Second SETAC

(Society

of

Environmental

Toxicology

and

Chemistry)

World

Congress,

November 5-9, 1995, Vancouver, BC.

Chapman, P.M., J. Bridgman, J. Kitagawa, G. Dickason, and A. Dailey. 1995. Science and common sense

in Port Valdez, Alaska, Presented at the Second SETAC (Society of Environmental Toxicology and

Chemistry) World Congress, November 5-9, 1995, Vancouver, BC.

Murdoch, M.H., P.M. Chapman, D.M. Johns, and M.D. Paine. 1995. Chronic Effects of pesticide exposure

in sediment to the marine polychaete,

Neanthes arenaceodentata

. Presented at the Twenty-Second

Annual Aquatic Toxicity Workshop, October 1-4. 1995, St. Andrews, New Brunswick.

Pastorok, R.A., J.W. Anderson, M.K. Butcher, J.E. Sexton, G. Cherr, P. Dinnel, R. Caldwell, R. Cardwell,

and P.M. Chapman. 1995. Inter- and intra-laboratory variability of marine chronic toxicity test

methods. Presented at the 1995 Environmental Conference of the Technical Association of the Pulp

and Paper Industry (TAPI).

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 5 of 9

Chapman, P.M. 1994.Toxicology and decision-making. Presented at the Conference on ASEAN Criteria

and Monitoring: Advances in Marine Environmental Management and Human Health Protection.

October 24-28, 1994, Singapore.

Murdoch, M.H., D.M. Norman, V.M. Quintino, and P.M. Chapman. 1994. Spiking sediments with

organochlorines for toxicity testing. Presented at the Twenty-First Annual Aquatic Toxicity Workshop,

October 2-5. 1994, Sarnia, ON.

Murdoch, M.N., D.M. Norman, and P.M. Chapman. 1994. Sediment spiking for toxicity testing. Presented

at the Fifteenth Annual Meeting of the Society of Environmental Toxicology and Chemistry (SETAC),

October 31 - November 3, 1994, Denver, CO.

Cherr, G., P. Dinnel, R. Caldwell, R. Cardwell, and P.M. Chapman. 1994. Criteria for acceptable variability

of Washington State marine chronic toxicity methods. Presented at the Pacific Northwest meeting of

the Society of Environmental Toxicology and Chemistry (SETAC), May 13-14, 1994, Victoria, BC,

and at the Fifteenth Annual Meeting of SETAC, October 31 - November 3, 1994, Denver, CO.

Pastorok, R-A., J.W. Anderson, M.K. Butcher, J.E. Sexton, G. Cherr, P. Dinnel, R. Caldwell, R. Cardwell,

and P.M. Chapman. 1994. Inter- and intra-laboratory variability of Washington State marine chronic

toxicity test methods. Presented at the Pacific Northwest meeting of the Society of Environmental

Toxicology and Chemistry (SETAC), May 13-14. 1994, Victoria, BC, and at the Fifteenth Annual

Meeting of SETAC, October 31 - November 3, 1994, Denver, CO.

Paine, M.D., P.M. Chapman, C.A. McPherson, M.H. Murdoch, and D. Minifie. 1994. Limited

bioavailability of sediment PAH in Kitimat Arm, BC. Presented at the Pacific Northwest meeting of

the Society of Environmental Toxicology and Chemistry (SETAC), May 13-14, 1994, Victoria, BC,

and at the Fifteenth Annual Meeting of SETAC. October 31 - November 3, 1994, Denver, CO.

Chapman, P.M. and R. Peltier. 1993. Global trends in regulatory ecotoxicology. Presented at the Hong

Kong Government Environmental Protection Department, Workshop on Regulatory Ecotoxicology,

December 7-9, 1993, Hong Kong.

Chapman, P.M. 1993. Sediment bioassay testing (murder through mud). Presented at the Hong Kong

Government, Environmental Protection Department, Workshop on Regulatory Ecotoxicology,

Dec. 7-9, 1993, Hong Kong.

Chapman, P.M. and R. Peltier. 1993. Incorporation of test protocols in the regulation of dredged material

disposal in the U.S. Presented at the Hong Kong Government, Environmental Protection Department,

Workshop on Regulatory Ecotoxicology, Dec. 7-9, 1993, Hong Kong.

Chapman, P.M. 1993. Integrative assessments of contaminated sediments - including the Sediment Quality

Triad: tomorrow’s tools, today’s answers. Presented at the Hong Kong Government, Environmental

Protection Department, Workshop on Regulatory Ecotoxicology, Dec. 7-9, 1993, Hong Kong.

Chapman, P.M. 1993. Ecotoxicology - poisons, doses, dos and don’ts. Presented to the Institution of Water

and Environmental Management, Dec. 7, 1993, Hong Kong.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 6 of 9

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1993. Sediment studies provide key

information on the need to treat sewage discharged to sea by a major Canadian city. Presented at the

Specialized IAWPRC Conference, Contaminated Aquatic Sediments: Historical Records,

Environmental Impact and Remediation, June 14-16, 1993, Milwaukee, Wisconsin.

Chapman, P.M. 1992. Uses and misuses of aquatic toxicology. Presented at the Thirteenth Annual Meeting

of the Society for Environmental Toxicology and Chemistry, November 12, 1992. Cincinnati, OH.

Chapman, P.M. 1992. Integrative sediment assessments. p.14. In: EPA Forum on the Extent and Severity of

Contaminated Sediments, April 21-22, 1992. Chicago, IL.

Chapman, P.M. and C.A. McPherson. 1992. Scientific, site-specific discharge limits for a lead/zinc mine in

the high Arctic. Presented at the Thirteenth Annual Meeting of the Society for Environmental

Toxicology and Chemistry, November 12, 1992. Cincinnati, OH.

Chapman, P.M. and C.A. McPherson. 1992. Limits for zinc discharge into the Arctic Ocean north of

Resolute Bay. Presented at the Nineteenth Annual Aquatic Toxicity Workshop, October 4-7,

Edmonton, Alberta.

Chapman, P.M., C. Heip, and W. Cofino. 1992. Pollution status of North Sea sediments - an integrative

assessment. Presented at the Thirteenth Annual Meeting of the Society for Environmental Toxicology

and Chemistry, November 12, 1992. Cincinnati, OH.

Chapman, P.M., C. Heip, and W. Cofino. 1992. What is the pollution status of North Sea sediments?

Presented at the Nineteenth Annual Aquatic Toxicity Workshop, October 4-7, Edmonton, Alberta.

Chapman, P.M., M.D. Paine, and A.W. Maynard. 1992. Scientific studies to determine the extent, severity

and significance of pollution due to sewage discharged from the CRD’s Clover and Macaulay Point

outfalls. Presented at a conference on Liquid Waste Issues in the Victoria Area, October 28-29, 1992,

Victoria, BC.

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1992. Are relatively untreated marine sewage

discharge always a major environmental problem? Presented at the Thirteenth Annual Meeting of the

Society for Environmental Toxicology and Chemistry, November 12, 1992. Cincinnati, OH.

Chapman, P.M., A.D. Arthur, M.D. Paine, and L.A. Taylor. 1992. Do sewage discharges from Victoria

(BC) pose a major environmental problem? - toxicity and related studies. Presented at the Nineteenth

Annual Aquatic Toxicity Workshop, October 4-7, Edmonton, Alberta.

Cross, S.F., J.M. Boyd, P.M. Chapman, and R.O. Brinkhurst. 1991. A multivariate approach for defusing

spatial impacts using the Sediment Quality Triad. p. 886. In: P.M. Chapman et al. (eds.) Proceedings of

the Seventeenth Annual Aquatic Toxicity Workshop: November 5-9, 1990, Vancouver. Can. Tech.

Rep. Fish. Aquat. Sci. 1774.

Clark, J.R., P.R. Parrish, P.M. Chapman, K.M. Jop, K. Kline, and J.Q. Word. 1991. Comparison of risk

assessment decisions for a bioremediation fertilizer using Alaskan and standard test species. Presented

at the Twelfth Annual Meeting of the Society for Environmental Toxicology and Chemistry,

November 3-7, 1991, Seattle, WA.

Chapman, P.M. 1990. What type of environmental quality criteria should we be developing? Presented at

the Eleventh Annual Meeting of the Society for Environmental Toxicology and Chemistry, November

11-15, 1990, Washington, DC.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 7 of 9

Chapman, P.M. 1990. The environmental quality triad. Presented at Globe ’90, March 19-23, 1990,

Vancouver, BC.

Chapman, P.M., J. Lazorchak, D. Neptune, D. McMullen, D. Peck, M. Stainton, B. Cummins, M.

Samoiloff, B. Schumacher, and D. McKenzie. 1990. Quality assurance issues related to laboratory

assessment of aquatic ecosystems. Presented at the Eleventh Annual Meeting of the Society for

Environmental Toxicology and Chemistry, November 11-15, 1990, Washington, DC.

Cross, S.F., J.M. Boyd, P.M. Chapman, and R.O. Brinkhurst. 1990. A multivariate approach for defining

spatial impacts using the sediment quality triad. Presented at the Seventeenth Annual Aquatic Toxicity

Workshop. November 5-7, Vancouver, BC.

Harding, L.E., P.M. Chapman, D. Goyette, and J. Boyd. 1990. Response of five bioassays to Vancouver

Harbour Sediments. Presented at the Eleventh Annual Meeting of the Society for Environmental

Toxicology and Chemistry, November 11-15, 1990, Washington, DC.

Chapman, P.M. 1989. Sediment toxicity testing. Presented at the National Symposium on Water Quality

Assessment, October 16-19, 1989, Fort Collins, Colorado.

Chapman, P.M., 1989. Current approaches to developing sediment quality criteria. Presented at Oceans 89,

September 18-21, 1989, Seattle, WA.

Chapman, P.M., R.N. Dexter, H. Anderson, and E.A. Power. 1989. Environmental effects of an oil

production platform as determined using the Sediment Quality Triad. Presented at the Tenth Annual

Meeting of the Society for Environmental Toxicity and Chemistry, October 28-November 2, 1989,

Toronto, ON.

Munkittrick K.R. and P.M. Chapman. 1989. An inter-laboratory comparison of the

Daphnia

acute lethality

bioassay and the concept of a range of toxicity. Presented at the Tenth Annual Meeting of the Society

of Environmental Toxicity and Chemistry, October 28 - November 2, 1989, Toronto, ON.

Chapman, P.M. 1988. Potential cause (chemical contaminant concentrations) and effects measurements

(laboratory and field) related to bioavailability. Presented at the International Symposium on the Fate

and Effects of Toxic Chemicals in Large Rivers and their Estuaries, October 10-14, 1988, Québec

City, Québec.

Chapman, P.M. 1988. Sediment toxicity testing: where are we and where are we going? Presented at the

Ninth Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 13-17,

1988, Arlington, Virginia.

Chapman, P.M. 1988. Experimental (laboratory) and observational (in situ) bioeffects measurements:

which is preferable? Presented at the 1988 Annual Meeting of the American Society of Limnology and

Oceanography, June 12-16, 1988, Boulder, Colorado.

Chapman, P.M. 1987. Sediment toxicity testing as part of the Sediment Quality Triad. Presented at the

Eighth Annual Meeting of the Society of Environmental Toxicology and Chemistry, November 9-12,

1987, Pensacola, Florida.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 8 of 9

Chapman, P.M. 1987. Application of the sediment quality triad to monitoring environmental impacts in

estuaries. Presented at the Ninth Biennial International Estuarine Research Conference, October 25-30,

1987, New Orleans, Louisiana.

Chapman, P.M. 1987. Marine environment monitoring. Two-day seminar series presented June 29-30,

1987, Bogor, Indonesia.

Chapman, P.M. 1987. Sediment bioassays - an essential element of past, present and future pollution

studies. Presented at the Annual Meeting of the Northwest Scientific Association, March 26- 27, 1987,

Tacoma, WA.

Chapman, P.M. 1987. Development of sediment quality criteria based on and for the protection of fisheries

resources. Presented at the American Fisheries Society Meeting, January 28-30, 1987, Portland,

Oregon.

Chapman, P.M., R. Deverall, R. Jones, and G. Marsh. 1987. Environmental monitoring 1986 for the Iona

Deep Sea Outfall Project. Presented at the Fraser River Estuary Workshop, February 24-25, 1987,

Vancouver, BC.

Dexter, R.N., P.M. Chapman, and L.S. Goldstein. 1987. The use of monitoring data to indicate trends in

water quality. Presented at the Annual Meeting of the Northwest Scientific Association, March 26-27,

1987, Tacoma, Washington.

Chapman, P.M. 1986. Development of sediment quality criteria using laboratory and field bioeffects data.

Presented at the Seventh Annual Meeting of the Society of Environmental Toxicology and Chemistry,

November 2-5. 1986, Arlington, Virginia.

Chapman, P.M., R.N. Dexter, L. Goldstein, and E.R. Long. 1986. Development of monitoring programs to

assess the long term health of aquatic ecosystems - a model from Puget Sound, U.S.A. Presented at the

Sixth International Ocean Disposal Symposium, April 21-25, 1986, Ansilomar, California.

Chapman, P.M., R.N. Dexter, E.R. Long, S.F. Cross, and D.G. Mitchell. 1986. Application of the Sediment

Quality Triad (chemistry, bioassay, infauna) to determine pollution-induced degradation in San

Francisco Bay. Presented at the Symposium on Toxic Chemicals and Aquatic Life: Research and

Management, September 16-18, 1986, Seattle, Washington.

Chapman, P.M., R.N. Dexter, E.R. Long, S.F. Cross, and D.G. Mitchell. 1986. Field testing of the

Sediment Quality Triad (chemistry, bioassay, infauna) to determine pollution-induced degradation in

San Francisco Bay. Presented at the Sixth International Ocean Disposal Symposium, April 21-25,

1986, Ansilomar, California.

Williams, L.G., P.M. Chapman, and T.C. Ginn. 1986. A comparative evaluation of marine and sediment

toxicity using bacterial luminescence, oyster embryo, and amphipod sediment bioassays. Presented at

the Symposium on Toxic Chemicals and Aquatic Life: Research and Management, September 16-18,

1986, Seattle, Washington.

William, L.G., P.M. Chapman, and T.C. Ginn. 1986. A comparative evaluation of marine sediment toxicity

using bacterial luminescence, oyster embryo, and amphipod sediment bioassays. Presented at the Sixth

International Ocean Disposal Symposium, April 21-25, 1986, Ansilomar, California.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 9 of 9

Chapman, P.M. 1985. Sublethal sediment bioassays using oligochaete respiratory response. Presented at the

Thirty-third Annual Meeting of the North American Benthological Society, June 25-29, 1985,

Corvallis, Oregon.

Chapman, P.M. 1984. Capabilities, limitations and interpretation of data from marine sediment bioassays.

Presented at the 1984 West Coast Regional Meeting of the National Council of the Paper Industry for

Air and Stream Improvement, May 8-9, Portland, Oregon.

Long, E.R. and P.M. Chapman. 1984. Sediment bioassays: their use in Puget Sound. Presented at the Fifty-

First Conference of the Pacific Northwest Pollution Control Association, October 29-30, 1984,

Eugene, Oregon.

Mitchell, D.G., J.D. Morgan, J.L. Cronin, D.A. Cobb, G.A. Vigers, and P.M. Chapman. 1984. Acute lethal

marine bioassay studies for the U.S. Borax Quartz Hill Project. Presented at the Eleventh Annual

Aquatic Toxicity Workshop, November 12-14, Richmond, BC

Nix, P. and P.M. Chapman. 1984. Short-term effects of dredging contaminated sediments in an industrial

harbor - False Creek, Presented at the Pacific Estuarine Research Regional Meeting, April 27-28,

NOAA Western Regional Center, Seattle, WA.

Chapman, P.M. and R.O. Brinkhurst. 1982. Lethal and sublethal toxicity studies with aquatic oligochaetes.

Bull. Can. Soc. Zool. 13:31.

Chapman, P.M. 1983. Results of sediment toxicity testing in Puget Sound. Presented at the Pacific

Estuarine Research Society Regional Meeting, September 23-24, Western Washington University.

Chapman, P.M., M.A. Farrell, and R.O. Brinkhurst. 1981. The effects of pollutants on aquatic oligochaetes

- laboratory bioassay studies. Presented at the Twenty-Ninth Annual Meeting of the North American

Benthological Society, April 27-30, 1981, Provo, Utah.

Brinkhurst, R.O., M.A. Farrell, D. McCullough, and P.M. Chapman. 1981. The respiration rates of selected

aquatic oligochaetes and their relation to pollution tolerance. Presented at the Twenty-Ninth Annual

Meeting of the North American Benthological Society, April 27-30, 1981, Provo, Utah.

Chapman, P.M. 1980. Seasonal movements of subtidal benthic communities in the Fraser River estuary, pp.

383-384. In: R.O. Brinkhurst and D.G. Cook (eds), Aquatic Oligochaete Biology. Plenum Press, New

York.

Chapman, P.M. and R.O. Brinkhurst. 1980. Seasonal movements of subtidal benthic oligochaete

populations in a salt wedge estuary, pp. 21-22. In: Proceedings of a Special Symposia in Estuarine

Oligochactes. Presented at the Twenty-Eighth Annual Meeting of the North American Benthological

Society, March 26-28, 1980, Savannah, Georgia.

Chapman, P.M. and R.O. Brinkhurst. 1978. Seasonal salinity effects on subtidal benthic communities in a

salt wedge estuary. Abs. Limnol. Oceanogr., University of Victoria.

Chapman, P.M. and J.L. Littlepage. 1975. Incorporation of dissolved organic matter by Calanus plumchrus.

Abs. Limnol. Oceanogr., Oregon State University.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 10 of 9

UNPUBLISHED MANUSCRIPTS AND REPORTS

McPherson, C. A., P. M. Chapman, S. J. McKinnon, M. L. Fanning, B. J. Burd, J. Olson, N. Markovic-

Mirovic, and G. Brooks. 2006. Lions Gate outfall, 2005 sediment effects survey. Prepared for the

Greater Vancouver Regional District, Burnaby, BC.

McPherson, C.A., P.M. Chapman, S.J. McKinnon, B.J. Burd, M.L. Fanning, J. Olson, M.C. Hamilton, and

F. Chen. 2006. Iona Deep Sea Outfall, 2005 environmental monitoring program: Sediment effects

survey. Prepared for the Greater Vancouver Regional District, Burnaby, BC.

Chapman, P. M. 2005. Elk Valley Mines 25-year selenium program 2006-2030. Prepared for the Elk

Valley Mines Environmental management Committee, Sparwood, BC.

Chapman, P.M. 2005. Elk Valley Mines 5-year selenium program 2006-2010. Prepared for the Elk Valley

Mines Environmental management Committee, Sparwood, BC.

Chapman, P.M. 2005. Development of a Canada-Ontario decision-making framework for contaminated

sediments in the Great Lakes (and elsewhere). Prepared for Environment Canada, Burlington, ON.

Chapman, P.M. 2005. Recommendations for whole effluent toxicity (WET) testing approaches for the

Water Corporation of Western Australia. Prepared for Oceanica Consulting Pty Ltd, Nedlands,

Western Australia.

McDonald, B., C. McPherson, and P.M. Chapman. 2005. Weight of evidence (WOE) assessment of effects

of selenium released from coal mines in Alberta to resident fish and waterfowl. Prepared for Elk

Valley Coal Corporation, Calgary, AB.

McPherson, C.A., P.M. Chapman, S.J. McKinnon, M.L. Fanning, B.J. Burd, J. Olson, F. Chen, and M.C.

Hamilton. 2005. Lions Gate Outfall, 2004 sediment effects survey. Prepared for the Greater Vancouver

Regional District, Burnaby, BC.

McPherson, C.A., P.M. Chapman, S.J. McKinnon, B.J. Burd, M.L. Fanning, J. Olson, M.C. Hamilton, and

F. Chen. 2005. Iona Deep Sea Outfall, 2004 environmental monitoring program: Sediment effects

survey. Prepared for the Greater Vancouver Regional District, Burnaby, BC.

McPherson, C.A., P.M. Chapman, M.K. Lee, B.J. Burd, M.L. Fanning, J. Olson, M.C. Hamilton, and F.

Chen. 2004. Iona Deep-Sea Outfall, 2003 environmental monitoring program: Sediment effects survey.

Prepared for the Greater Vancouver Regional District, Burnaby, BC.

McPherson, C.A., P.M. Chapman, M.K. Lee, M.L. Fanning, J. Olson, and F. Chen. 2004. Lions Gate

Outfall, 2003 sediment effects survey. Prepared for the Greater Vancouver Regional District, Burnaby,

BC.

Chapman, P.M., C. McPherson, and D. McKeown. 2003. Environmental Impact Report 2003. Prepared for

BHP Billiton Diamonds Ltd., Yellowknife, NWT.

Elphick, J. and P.M. Chapman. 2003. Sediment quality triad - Equity Mine 2002 environmental effects

monitoring program: Goosly Lake. Prepared for Placer Dome Canada, Equity Division, Houston, BC.

Elphick, J. and P.M. Chapman. 2003. Equity Mine environmental effects monitoring program: summary

and weight of evidence – 2002 program. Prepared for Placer Dome Canada, Equity Division, Houston,

BC.

McPherson, C.A., H.C. Bailey, P.M. Chapman, M.K. Lee, B.J. Burd, M.L. Fanning, M.D. Paine, M.C.

Hamilton, and F. Chen. 2003. Iona deep-sea outfall, 2002 environmental monitoring program:

sediment effects study. Prepared for the Greater Vancouver Regional District, Burnaby, BC.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 11 of 9

Chapman, P.M. 2002. Environmental fate and impacts of MTBE discharged from Chevron Canada’s

Burnaby refinery. Prepared for Chevron Canada, Burnaby, BC.

McDonald, B. and P.M. Chapman. 2002. Ecological relevance of photo-induced toxicity of polycyclic

aromatic hydrocarbons in freshwater environments. Prepared for Murphy Oil USA, Superior, WI.

Chapman, P.M. 2000. Design of selenium monitoring program for the Elk Valley Mines. Prepared for the

Elk Valley Coal Mines, Environmental Management Committee, Sparwood, BC.

Paine, M.D. and P.M. Chapman. 2000. Assessment of sediment chemistry in the Iona receiving

environment. Chapter 2. In: Development of a Receiving Environment Monitoring Approach to Liquid

Waste Management, Progress Workshop 2, December 4, 2000, Support Materials Part 2 of 3: Iona

WWTP Receiving Environment, Draft Technical Reports. Prepared for the Greater Vancouver

Regional District, Burnaby, BC.

Chapman. P.M. 2000. Guidelines/standards for environmental monitoring reports. Report prepared for BHP

Diamonds, Yellowknife, NWT.

Chapman, P.M., J. Wilcockson, D. Hodgins, and E. Gerencher. 2000. Ecological risk opinion: water lot

leases of Gold River facility. Report prepared for Bowater Pulp and Paper Canada, Inc. Gold River,

BC.

Chapman, P.M., H. Bailey, and B. Yung. 2000. Preliminary site investigation for 7510 Hopcott Road,

Delta, BC. Report prepared for Morguard Investments Ltd., Toronto, Ontario.

Chapman, P.M., R. Baker, M. Daykin, and F. Wang. 2000. Environmental impact report 2000. Report

prepared for BHP Diamonds, Yellowknife, Northwest Territories.

Lawrence, G. and P.M. Chapman. 2000. Human health risk assessment for ingestion of selenium-exposed

fish. Prepared for Cardinal River Coals Ltd., Hinton, Alberta.

Lawrence, G. and P.M. Chapman. 2000. Elk River Basin human health risk assessment for ingestion of

selenium-contaminated fish. Prepared for Elk River Basin Coal Producers, British Columbia.

Chapman, P.M., F. Wang, and C. McPherson. 1999. A critique of the ANZECC and ARMCANZ (1999)

water quality guidelines. Report prepared for the Minerals Council of Australia and the Kwinana

Industries Council.

Chapman, P.M., M. Burchett, P. Campbell, W. Dietrich, and B. Hart. 1999. Fourth report of the OK Tedi

Mines Ltd. (OTML) Peer Review Group. Report prepared for OTML, Papua New Guinea.

Chapman, P.M., M. Burchett, P. Campbell, W. Dietrich, and B. Hart. 1999. Third report of the OK Tedi

Mines Ltd. (OTML) Peer Review Group. Report prepared for OTML, Papua New Guinea.

Wang, F. and P.M. Chapman. 1998. Compilation of world-wide sediment quality guidelines for metals and

metalloids. Report prepared for the International Lead Zinc Research Organization, the International

Copper Association, and the Nickel Producers Environmental Research Organization, Research

Triangle Park, North Carolina.

Chapman, P.M., M. Burchett, P. Campbell, W. Dietrich, and B. Hart. 1998. Second report of the OK Tedi

Mines Ltd. (OTML) Peer Review Group. Report prepared for OTML, Papua New Guinea.

Bailey, H.C., E. Canaria, and P.M. Chapman. 1998. Fertilization and viability of rainbow trout embryos in

Coeur mine effluent. Toxicity of total dissolved solids (TDS) in Coeur mine effluent to rainbow trout

swim-up fry. Report prepared for Coeur Alaska, Juneau, Alaska.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 12 of 9

Bailey, H.C., E.C. Canaria, J.R. Elphick, L.J. Suffredine, M.J. Maddison, A.P. Coombs, Y.J. Meng, E.J.

Thys, C.J. Merchant, M.K. Lee, and P.M. Chapman. 1998. Toxicity to total dissolved solids (TDS) in

Red Dog mine effluent. Fertilization and viability of rainbow trout and chum salmon embryos. Report

prepared for Red Dog Mine, Anchorage, Alaska.

Bailey, H.C., E. Canaria, and P.M. Chapman. 1997. Toxicity of total dissolved solids (TDS) in Coeur mine

effluent to rainbow trout swim-up fry. Report prepared for Coeur Alaska, Juneau, Alaska.

Bishay, F. and P.M. Chapman. 1997. Assessment of different approaches for evaluating effluent quality.

Report prepared for Teck Corporation, Vancouver, BC.

Yang, A., H.C. Bailey, and P.M. Chapman. 1997. Toxicity of total dissolved solids (TDS) in Coeur mine

effluent to

Selenastrum capricornutum

. Report prepared for Coeur Alaska, Juneau, Alaska.

Bailey, H.C., E. Canaria, and P.M. Chapman. 1996. Toxicity of total dissolved solids (TDS) in Red Dog

mine effluent - early life stages of rainbow trout and larval

Chironomus tentans

. Report prepared for

Cominco Alaska, Anchorage, Alaska.

Chapman, P.M. 1998. Report on tributyltin applications at Shell's Jumping Pound Facility. Report prepared

for Evans Martin Wilson, Calgary AB.

Chapman, P.M. 1998. Review comments on draft report: Selenium mobilization from surface coal mining

on the Elk River Basin, British Columbia: A survey of bioaccumulation. Report prepared for Elkview

Coal Corporation, Sparwood, BC.

Chapman, P.M. 1998. Aquatic effects monitoring program (AEMP) technical overview working document.

Report prepared for BHP Diamonds, Yellowknife, NWT.

Chapman, P.M., P. Allard, G. Lawrence, D. Lincoln, and R. Stevenson. 1998. Detailed human health and

ecological risk assessment of Homebush Bay sediments. Report prepared for the Office of Marine

Administration, Sydney, Australia.

Chapman, P.M. 1997. Comments on the misuse of persistence for classifying zinc in EPA’s Draft

Prioritized Chemical List. Report prepared for the American Zinc Association, Washington DC.

Chapman, P.M. 1997. Peer review of U.S. EPA’s Ambient Aquatic Life Water Quality Criteria for

Tributyltin (March 31, 1997 draft). Report prepared for the Cadmus Group, Washington, DC.

Chapman, P.M. 1997. Problem formulation report - Domtar Liverpool Site, Surrey, British Columbia.

Report prepared for Klohn-Crippen, Vancouver.

Chapman, P.M. 1997. Preliminary comments on apparent increase in aquatic copper levels related to the

OK Tedi Mine. Report prepared for BHP Minerals, Papua New Guinea.

Chapman, P.M., R. Baker, and G. Mann. 1997. Preliminary problem formulation document. Report

prepared for Ladner Downs, Vancouver.

Chapman, P.M., R. Baker, and G. Mann. 1997. Environmental status data report. Report prepared for

Ladner Downs, Vancouver.

Chapman, P.M., P. Campbell, and B. Hart. 1997. First report of the OK Tedi Mines Ltd. Peer Review

Group. Report prepared for BHP Minerals, Papua New Guinea.

Chapman, P.M., C. McPherson, and M. Daykin. 1997. Comments on the proposed NPI (and comparison to

similar international programs) - Will it work? Can it be improved? Report prepared for Minerals

Council of Australia et al., Melbourne, Australia.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 13 of 9

Chapman, P.M., C. Wren, and M. Dube. 1997. Aquatic effects monitoring: study design, final report.

Report prepared for Natural Resources Canada/CANMET, Ottawa, ON.

McPherson, C.A. and P.M. Chapman. 1997. Generic requirements for setting up an ecotoxicity testing

facility in Papua New Guinea related to the OK Tedi Mine. Report prepared for BHP Minerals, Papua

New Guinea.

Chapman, P.M. 1996. Comparing and interpreting WET test data. Report prepared for Cominco Alaska,

Anchorage.

Chapman, P.M. 1996. Effluent toxicity effects on receiving waters. Report prepared for the Cominco Red

Dog Mine, Alaska.

Chapman, P.M. 1996. Summary of Expert Panel comments on The Contaminated Sites Regulation. Report

prepared for the City of New Westminster, BC.

Chapman, P.M. 1996. Analysis of ecological significance and regulatory meaning of whole effluent

toxicity tests and limits. Report prepared for Ketchikan Pulp Company, Ketchikan, Alaska.

Chapman, P.M., P. Kiffney, F. Bishay, and G. Mann. 1996. Aquatic effects monitoring: field survey report

Myra Falls mine site. Report prepared for Natural Resources Canada/CANMET, Ottawa, ON.

Chapman, P.M., P. Kiffney, I. Watson, and F. Bishay. 1996. Aquatic effects monitoring: field survey report

Sullivan Mine. Report prepared for Natural Resources Canada/CANMET, Ottawa, ON.

Chapman, P.M. and E. Szenasy. 1996. Technical review of ecological components of Contaminated Sites

Regulation. Report prepared for various members of the business community.

Chapman, P.M., I. Watson, and G. Mann. 1996. Aquatic effects monitoring: field survey report Lupin Mine

site. Report prepared for Natural Resources Canada/CANMET, Ottawa, ON.

Chapman, P.M., C. Wren, and M. Dube. 1996. Aquatic effects monitoring methods to determine mining

effects: recommendations for 1997 sites, final report. Report prepared for Natural Resources

Canada/CANMET, Ottawa, ON.

McGroddy, S. and P.M. Chapman. 1996. Bioavailability of mercury from dental amalgam. Report prepared

for the Capital Regional District, Victoria, BC.

Chapman, P.M., C.A. McPherson, V. Zitko, S. Blenkinsopp, and K. Brix. 1995. Report of the Expert Group

on “Mechanics of handling suspensions”. Discussion paper prepared for OECD Workshop on Toxicity

Testing, September 5 - 8, 1995, Ottawa, ON.

Allard, P.J., M.D. Paine, M.H. Murdoch, and P.M. Chapman. 1995. 1994 Alcan Marine Monitoring

Program Intensive Study. Report prepared for Alcan Smelters and Chemicals Ltd., Kitimat, BC.

Murdoch, M.H., P.M. Chapman, and M.D. Paine. 1994. Southern California damage assessment surface

water injury: sediment. Report prepared for the U.S. Department of Commerce, National Oceanic and

Atmospheric Administration, Seattle, Washington.

Godtfredsen, K., P.M. Chapman, D.M. Johns, F. Dillon, and M.D. Paine. 1994. Data analysis of 1993

sediment chemistry off the Macaulay Point outfall and recommended sediment monitoring program

sampling design. Report prepared for the Capital Regional District, Victoria, BC.

Sloan, N.A., E.A. Power, and P.M. Chapman. 1994. Monitoring methods for marine sewage outfalls

discharging over subtidal hard substrates: a review with application to Clover Point outfall. Report

prepared for the Capital Regional District, Victoria, BC.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 14 of 9

Chapman, P.M., L.I. Bendell-Young, and P. Stecko. 1994. Presence, extent and severity of sediment

contamination in Heal/Durrance/Tod Creek-Stages I and 2. Report prepared for the Capital Regional

District, Victoria, BC.

Paine, M.D., M.H. Murdoch, and P.M. Chapman. 1994. 1994 intensive study plan, Report prepared for

Alcan Smelters and Chemicals Ltd., Kitimat, BC.

Chapman, P.M., M.H. Murdoch, M.D. Paine, G.S. Rosenthal, and C.A. McPherson. 1994. Marine

monitoring program pilot study. Report prepared for Alcan Smelters and Chemicals Ltd., Kitimat, BC.

Godtfredsen, K.L., D.M. Johns, F. Dillon, and P.M. Chapman. 1994. Qualitative assessment of cargo

residue washdown in the Great Lakes. Report prepared for the Lake Carriers Association, Cleveland,

Ohio.

Rosenthal, G.A. and P.M. Chapman. 1994. Preliminary trawling - 1993 pilot study. Report prepared for

Alcan Smelters and Chemicals, Kitimat, BC.

McPherson, C.A. and P.M. Chapman. 1994. Sediment sampling interpretative report and details of

proposed 1994 benthic community structure studies. Report prepared for Alcan Smelters and

Chemicals, Kitimat, BC.

Paine, M.D., P.M. Chapman, E.A. Power, and A.M. Crampton. 1993. Proposed Alcan marine monitoring

program 1993 - 2000. Report prepared for Alcan Smelters and Chemicals, Kitimat, BC.

Sagert, P., P.M. Chapman, and A. Donnelly. 1993. Creating an equitable discharge permit fee system.

Report prepared for the Industrial Sector of the Technical Working Group for Permit Fee Revisions,

Vancouver, BC.

Chapman, P.M. (editor and principal author). 1993. Revision of pollution control criteria for mining,

smelting and related industries of British Columbia: effluent discharges to water and land/solid waste

discharges to water and land. Six separate reports prepared for the BC Ministry of Environment,

Victoria, BC.

Stecko, P., P.M. Chapman, and C.A. McPherson. 1993. Cominco SNIP Mine sediment monitoring program

1993. Report prepared for Cominco SNIP Operations, Smithers, BC.

Murdoch, M.A., A. Crampton, and P.M. Chapman. 1993. Cominco SNIP Mine environmental effects

monitoring program - 1992 - interpretative summary report. Report prepared for Cominco SNIP

Operations, Smithers, BC.

Paine, M.D. and P.M. Chapman. 1993. Cominco SNIP Mine environmental effects monitoring program -

1992. Report prepared for Cominco SNIP Operations, Smithers, BC.

Chapman, P.M., A. Arthur, M.D. Paine, J. Vanderleelie, A. Maynard, J. Downie, and S. Cross. 1992.

Sediment and related investigations off the Macaulay and Clover Point sewage outfalls. Report

prepared for the Capital Regional District, Victoria, BC.

Chapman, P.M., C.A. McPherson, and M.D. Paine. 1992. Cominco Snip Mine environmental effects

monitoring program 1991. Interpretative Summary Report. Report prepared for Cominco Snip

Operations, Smithers, BC.

Chapman, P.M. and C.A. McPherson. 1992. Cominco Snip Mine’s sediment monitoring program 1991 -

Data Report. Report prepared for Cominco Snip Operations, Smithers, BC.

Chapman, P.M. and C.A. McPherson. 1992. Studies into the biological significance of Garrow Lake

discharge to Arctic marine waters. Report prepared for Cominco Ltd., Vancouver, BC.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 15 of 9

Chapman, P.M. and L. Dear. 1992. Lack of biomagnification and relative toxicity of cadmium, copper, lead

and zinc in marine organisms, with emphasis on Arctic species. Report prepared for Cominco Ltd.,

Vancouver, BC.

McPherson, C.A. and P.M. Chapman. 1989 - 1991. Valdez sediment toxicity program. Report prepared for

ENSR Consulting and Engineering, Boulder, Colorado.

Chapman, P.M. and M.D. Paine. 1991. Implementation of refinery effluent biomonitoring plan, Tier 1.

Report prepared for the Canadian Petroleum Product Institute, Ottawa, ON.

Power, E.A., M.D. Paine, N. Musgrove, and P.M. Chapman. 1991. Refinery outfall effects on sediments

and the relevance of AET/EQP sediment quality criteria. Report prepared for the American Petroleum

Institute, Washington, DC.

Chapman, P.M. and E.A. Power. 1990. Environmental assessment of refinery Inner Harbor, Aruba. Report

prepared for Esso Caribbean and Central America, Miami.

Chapman, P.M. and E.A. Power. 1990. Monitoring program for refinery Inner Harbor. Report prepared for

Lago Oil and Transport Co., Ltd., Aruba.

Chapman, P.M., E.A. Power, and P. Grindlay. 1990. Development of refinery effluent biomonitoring plan.

Report prepared for the Petroleum Association for Conservation of the Canadian Environment, Ottawa,

Ontario.

McPherson, C.A. and P.M. Chapman. 1990. Development and application of a sediment quality triad

approach to determine pollution-induced environmental degradation. Phase 1: sediment toxicity

testing. Report prepared for Science and Professional Services Canada, Richmond, BC.

Power, E.A. and P.M. Chapman. 1990. Guidance for Canadian Ocean Dumping 1990: 1) Proposed

amendments to DEPA Part III and the Ocean Dumping Regulations, 1988; 2) Reference site selection

and acceptability. Report prepared for Environment Canada, C & P, West Vancouver, BC.

Chapman, P.M. and K. Munkittrick. 1989. Inter-laboratory comparison of the Daphnia magna acute

lethality bioassay. Report prepared for the Ontario Petroleum Association, Willowdale, Ontario.

Chapman, P.M. and E.A. Power. 1989. An assessment of potential chronic sublethal effects related to

Element 1 of the U.S. Navy Homeport project. Report prepared for the U.S. Department of the Navy,

Everett, Washington.

Chapman, P.M., J. Crowley, J. Cronin, and J.M. Herman. 1989. Assessment of possible environmental

effects of relocation of Chevron Richmond Refinery once through seawater cooling water discharge.

Report prepared for Chevron U.S.A., Richmond, California.

Chapman, P.M., C.A. McPherson, and K.R. Munkittrick 1989. An assessment of the Ocean Dumping tiered

testing approach using the Sediment Quality Triad. Report prepared for the Institute of Ocean

Sciences, Sidney, BC.

Chapman, P.M., P. Grindlay, R. Deverall, M. Landolt, and L. Fanning. 1989. Iona deep-sea outfall

monitoring 1989. Study 2.0: Biota pathology and contaminant body burden. Report prepared for the

Greater Vancouver Regional District, Burnaby, BC.

Grindlay, P., E.A. Power, and P.M. Chapman. 1989. Iona deep sea outfall monitoring 1989. Study 1.0:

Evaluation of pre-discharge data. Report prepared for the Greater Vancouver Regional District,

Burnaby, BC.

McPherson, C.A. and P.M. Chapman. 1989. Bioassay and chemical analysis of sediments located west of

the Esso Ioco Refinery. Report prepared for Esso Petroleum Canada, Toronto, Ontario.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 16 of 9

McPherson, C.A., E.A. Power, and P.M. Chapman. 1989. Bioassay and chemical analyses of sediments in

the vicinity of the Esso Ioco Refinery. Report prepared for Esso Petroleum Canada, Port Moody, BC.

McPherson, C.A., E.A. Power, and P.M. Chapman 1989. Chemical characterization and bioassay testing of

sediments from Oakland Harbor. Report prepared for the U.S. Army Corps of Engineers, San

Francisco, California.

Chapman, P.M. 1988. A review of current approaches for developing sediment quality criteria. Report

prepared for the American Petroleum Institute, Washington, DC.

Chapman, P.M., R.N. Dexter, H. Andersen, and E.A. Power. 1988. Sediment toxicity evaluation-testing of

field collected sediments and evaluation of the Sediment Quality Triad concept. Report prepared for

the American Petroleum Institute, Washington, DC.

Chapman, P.M., R.N. Dexter, and R. Rousseau. 1988. Development and testing of biological methods for

use in nationwide, monitoring of marine and estuarine environments - studies in San Francisco Bay

using the bivalve larvae bioassay with

Mytilus edulis

. Report prepared for U.S. NOAA, Seattle,

Washington.

Chapman, P.M., R.N. Dexter, and R. Rousseau, 1988. Development and testing of biological methods for

use in nationwide monitoring of marine and estuarine environments - studies in San Francisco Bay

using the

Rhepoxynius abronius

amphipod sediment bioassay. Report prepared for U.S. NOAA,

Seattle, Washington.

McPherson, C.A., E.A. Power, and P.M. Chapman. 1988. Chemical characterization and bioassay testing of

sediments from Richmond Harbor. Report prepared for the U.S. Army Corps of Engineers, San

Francisco, California.

McPherson, C.A. and P.M. Chapman. 1988. Bioassays and bioaccumulation testing for ocean disposal of

sediment from the Alcatraz disposal site. Report prepared for the U.S. Army Corps of Engineers, San

Francisco, California.

Power, E.A. and P.M. Chapman. 1988. Sediment toxicity evaluation-determination of appropriate test

methods. Report prepared for the American Petroleum Institute, Washington, DC.

Power, E.A. and P.M. Chapman. 1988. Analysis and bioassay testing of sediments collected from San

Francisco harbor approaches to Piers 80 and 94. Report prepared for the U.S. Army Corps of

Engineers, San Francisco, California.

Power, E.A. and P.M. Chapman. 1988. Analysis and bioassay testing of sediments collected from Oakland

inner harbor. Report prepared for the U.S. Army Corps of Engineers, San Francisco, California.

Power, E.A. and P.M. Chapman. 1988. Analysis and bioassay testing of sediments collected from Oakland

outer harbor. Report prepared for the U.S. Army Corps of Engineers, San Francisco, California.

Power, E.A. and P.M. Chapman. 1988. Analysis and bioassay testing of sediments collected from

Richmond inner harbor. Report prepared for the U.S. Army Corps of Engineers, San Francisco,

California.

Power, E.A., C.A. McPherson, and P.M. Chapman. 1988. Chemical characterization and bioassay testing of

sediments collected from Mare Island. Report prepared for the U.S. Army Corps of Engineers, San

Francisco, California.

Chapman, P.M. 1987. A chemical and toxicological evaluation of sediments from San Pablo Bay. Report

prepared for Chevron, U.S.A., Richmond, California.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 17 of 9

Chapman, P.M. and S. Becker. 1986. Recommended protocols for conducting laboratory bioassays on

Puget Sound sediments. Report prepared for the U.S. EPA, Region 10, Seattle.

Chapman, P.M. and R. Deverall. 1986. Review of environmental monitoring 1986-Iona Deep Sea Outfall

Project. Report prepared for the Greater Vancouver Regional District, Vancouver, BC.

Chapman, P.M., R. Deverall, D. Popham, and D.G. Mitchell. 1986. Environmental monitoring 1986 - Iona

Deep Sea Outfall Project. Report prepared for the Greater Vancouver Regional District, Vancouver,

BC.

Maynard, A.W., P.M. Chapman, and S.F. Cross. 1986. Evaluation study of the Inland Waters Directorate

data base for total cyanide measurements in Western Canada (1974-1983), and the analytical

methodology used to derive this data base. Unpublished report prepared for Environment Canada. 78

pp.

Chapman, P.M., 1985. Studies to determine the cause of death of rainbow trout fry in bioassays of bake

oven scrubber sludge and north dump baghouse dust. Report prepared for Intalco Aluminum, Ferndale,

Washington.

Chapman, P.M. 1985. Preliminary histological analysis of rainbow trout killed in bioassay tanks containing

bake oven scrubber sludge and north dump baghouse dust. Report prepared for Intalco Aluminum,

Ferndale, Washington.

Chapman, P.M. 1985. Effects of water-based chemical dispersants and chemically dispersed crude oil on

marine biota data from field experiments. Report prepared for Tetra Tech, Inc., Bellevue, Washington.

Chapman, P.M. 1985. Environmental assessment related to deaths of young herring in Lower Ward Creek,

Alaska. Report prepared for Louisiana Pacific Corporation, Ketchikan, Alaska.

Chapman, P.M. and D.G. Mitchell. 1985. Variations in somatic characteristics of aquatic oligochaetes.

Report prepared for the Department of Fisheries and Oceans.

Mitchell, D.G. and P.M. Chapman. 1985. Acute toxicity of Roundup herbicide to coho salmon, chinook

salmon and rainbow trout, and saltwater challenge tests with coho salmon. Four separate reports

prepared for Monsanto, St. Louis, Missouri.

Pastorak, R.A., P.M. Chapman, P. Booth, J.H. Stern, and L.L. Hornsby. 1985. Fate and effects of oil

dispersants and chemically dispersed oil in the marine environment. Report prepared for Minerals

Management Service, Los Angeles, California.

Chapman, P.M. 1984. Sediment bioassays in Blair Waterway, Commencement Bay. Report prepared for

URS Engineers, Seattle, Washington.

Chapman, P.M. 1984. Bioassay analyses of sediments to be dredged from the Duwamish East Waterway.

Two separate reports prepared for the Port of Seattle, Washington.

Chapman, P.M. 1984. Fish bioassay testing of Intalco Spent Potliner (SPL) and dust collector material.

Report prepared for Intalco Aluminum, Ferndale, Washington.

Chapman, P.M. 1984. Bioassay tests of Terminal 5 soil leachates. Report prepared for the Port of Seattle,

Washington.

Chapman, P.M. and C. Barlow. 1984. Sediment bioassays in various BC coastal areas. Report prepared for

the Environmental Protection Service.

Chapman, P.M., RN. Dexter, D.E. Konasewich, and G.A. Erickson. 1984. Application of information on

Puget Sound ecosystems to pollution-related issues. I. Predictions of contaminant effects. Report

prepared for the U.S. Department of Commerce.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 18 of 9

Mitchell, D.G. and P.M. Chapman. 1984. Acute toxicity of Rodeo/X-77 herbicide to coho salmon, chinook

salmon and rainbow trout and saltwater challenge tests with coho salmon. Four separate reports

prepared for Monsanto, St. Louis, Missouri.

Mitchell, D.G., J.D. Morgan, G.A. Vigers, and P.M. Chapman. 1984. Report on acute lethal marine

bioassay studies for the U.S. Borax Quartz Hill Project. Report prepared for Bechtel Group, Inc., San

Francisco, California.

Mitchell, D.G., G.A. Vigers, J.D. Morgan, P.G. Nix, P.M. Chapman, and R.W. Deverall. 1984. Report on

acute, chronic and sublethal bioassays and bioaccumulation studies for the Quartz Hill Project,

Southeast Alaska. Report prepared for U.S. Borax and Chemical Corp., Los Angeles, California.

Nix, P. and P.M. Chapman. 1984. Monitoring Program for Expo ‘86 Dredging and Dumping Activities in

False Creek, BC. Report prepared for Expo ‘86, Vancouver, BC.

Tokar, E. and P.M. Chapman. 1984. Morse Lake/Masonry Pool Fishery investigations. Report prepared for

URS Engineers, Seattle, Washington.

Chapman, P.M. and R. Fink. 1983. Additional marine sediment toxicity tests in connection with toxicant

pretreatment planning studies, Metro Seattle. Report prepared for the Municipality of Metropolitan

Seattle, Seattle, Washington.

Gerencher, E. and P.M. Chapman. 1983. Metals analyses during dredging at Vancouver Shipyards, Ltd.

Report prepared for Vancouver Shipyards, North Vancouver, BC.

Gerencher, E. and P.M. Chapman. 1983. Metals analyses during dredging at Neptune Terminals, Ltd.

Report prepared for Neptune Terminals, North Vancouver, BC.

Gerencher, E. and P.M. Chapman 1983. Metals analyses during dredging at Vancouver Wharves, Ltd.

Report prepared for Vancouver Wharves, North Vancouver, BC.

Nix, P. and P.M. Chapman. 1983. Monitoring of underwater blasting operations in False Creek. Report

prepared for CH2M Hill Canada Ltd., Calgary, Alberta.

Sykanda, A. and P.M. Chapman. 1983. Air quality monitoring for H

2

S during tanker loading operations.

Report prepared for Trans Mountain Pipe Line Co. Ltd., Vancouver, BC.

Chapman, P.M. and R.D. Kathman (eds.). 1982. British Columbia Marine Copepoda: An Identification

Manual. By: G.A. Gardner and I. Szabo. Prepared for Department of Fisheries and Oceans.

Chapman, P.M. and R.D. Kathman (eds.). 1982. British Columbia Marine Copepoda: An Annotated

Bibliography. By: G.A. Gardner and I. Szabo. Prepared for Department of Fisheries and Oceans.

Chapman, P.M. and D. Munday. 1982. Marine biological studies at the Finnerty Cove outfall, Victoria, BC.

Report prepared for Stanley Associates Engineering Ltd., Victoria, BC.

Chapman, P.M. and D. Munday. 1982. Marine biological studies in connection with a proposed industrial

park outfall at Campbell River, BC. Report prepared for Stanley Associates Engineering Ltd., Victoria,

BC.

Chapman, P.M., M.A. Farrell, R.M. Kocan, and M. Landolt. 1982. Marine sediment toxicity tests in

connection with toxicant pretreatment planning studies, Metro Seattle. Report prepared for the

Municipality of Metropolitan Seattle.

---

Peter M. Chapman

PUBLISHED ABSTRACTS Page 19 of 9

Chapman, P.M., D. Munday, and G.A. Vigers. 1982. Monitoring program for heavy metals and elemental

sulphur at Vancouver Wharves, Ltd. Report prepared for Vancouver Wharves Ltd., North Vancouver,

BC.

Kathman, R.D., J.B. Coustalin, and P.M. Chapman. 1982. Preliminary report: benthic invertebrates from

Amuay Bay, Venezuela. Report prepared for AWARE, Inc., Tennessee.

Munday, D., P.M. Chapman, D. Moore, and G.A. Vigers. 1982. Development and comparative

demonstration of a remote quantitative replicate (R.Q.R.) benthos sampler. Report prepared for the

Research Secretariat of British Columbia.

Whelen, M.A. and P.M. Chapman. 1982. Relative abundance of juvenile salmonids at two sites in the

North Arm Fraser River related to the proposed Eburne Saw Mills Modernization program. Report

prepared for Canadian Forest Products Ltd., Vancouver, BC.

Chapman, P.M. 1981. Physical oceanography and marine biological studies Skidegate Channel, Queen

Charlotte Islands. Report prepared for Stanley Associates Engineering Ltd., Victoria, BC.

Chapman, P.M., M.A. Farrell, and D. McCullough. 1981. The respiration rates of selected aquatic

oligochaetes. Report prepared for Department of Fisheries and Oceans.

Chapman, P.M., M.A. Farrell, and D. McCullough. 1981. Changes in the respiration rates of selected

aquatic oligochaetes exposed to individual pollutants and environmental factors. Report prepared for

Department of Fisheries and Oceans.

Chapman, P.M., M.A. Farrell, and K. Teng. 1981. Effects of species interactions on the survival and

respiration of

Limnodrilus hoffmeisteri

and

Tubifex tubifex

(Oligochaeta, Tubificidae) exposed to

various pollutants and environmental factors. Report prepared for Department of Fisheries and Oceans.

Chapman, P.M., M.A. Farrell, and G.A. Vigers. 1981. Relative tolerances of selected aquatic oligochaetes

to individual pollutants and environmental factors. Report prepared for Department of Fisheries and

Oceans.

Chapman, P.M., M.A. Farrell, and G.A. Vigers. 1981. Relative tolerances of selected aquatic oligochaetes

to combinations of pollutants and environmental factors. Report prepared for Department of Fisheries

and Oceans.

Reid, B.J., R.W. Deverall, P.M. Chapman, and A.W. Maynard. 1981. Experimental investigation into the

accumulation of cadmium by the polychaete worm Capitella capitata and the bivalve Macoma balthica.

Report prepared for Department of Fisheries and Oceans.

Chapman, P.M. 1980. Identification and analysis of oligochaete samples collected from the lower Fraser

River, February - August 1977. Prepared for the Habitat Protection Section, Department of Fisheries

and Oceans.

Chapman, P.M., D. Munday, and G.A. Vigers. 1980. Determination of contaminant levels in fish species

from the Fraser River. Prepared for the Habitat Protection Section, Department of Fisheries and

Oceans.

Chapman, P.M., D. Munday, and G.A. Vigers. 1980. Monitoring of polychlorinated biphenyls in the lower

Fraser River - a data report. Prepared for the Environmental Protection Service.

Chapman, P.M., W.R. Olmsted, and D. Storr. 1980. Stage One environmental impact assessment of a

proposed Vancouver Island Gas Pipeline - Williams Lake to Comox and Squamish Lateral:

climatology, marine and freshwater aquatic systems. Report prepared for Westcoast Transmission

Company Ltd.

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Peter M. Chapman

PUBLISHED ABSTRACTS Page 20 of 9

Thompson, K.A., A. Cribb, D. Brown, and P.M. Chapman. 1980. Histopathology and metallothionein

synthesis resulting from cadmium exposure of the oligochaete

Monopylephorus irroratus

. Prepared for

the Ocean Ecology Section, Department of Fisheries and Oceans.

Chapman, P.M., E.R. McGreer, and G.A. Vigers. 1979. Preliminary marine baseline study and monitoring

of wash down operations, Vancouver Wharves Ltd., North Vancouver, BC. Prepared for Vancouver

Wharves Ltd.

Chapman, P.M., D. Moore, and G.A. Vigers. 1979. Evaluation of METRO’s experimental design and

toxicant literature review. Prepared for the Municipality of Metropolitan Seattle by EVS Environment

Consultants Ltd. 313 p.

Chapman, P.M., L.M. Churchland, P. Thompson, and E. Michnowsky. 1979. Heavy metals in benthic

animals and sediments in the lower Fraser River, British Columbia. Prepared for the Inland Water

Directorate, Department of Fisheries and the Environment.

---

1

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED NEW 35 ILL.ADM.CODE PART 225

CONTROL OF EMISSIONS FROM

LARGE COMBUSTION SOURCES

)

)

)

)

)

PCB R06-25

TESTIMONY OF GAIL CHARNLEY, Ph.D.

My name is Dr. Gail Charnley. I am a recognized expert in the fields of toxicology and

environmental health risk analysis. I received my PhD in Toxicology from the Massachusetts

Institute of Technology in 1984 and my AB degree with honors in Molecular Biology from

Wellesley College in 1977. I consult primarily in the areas of toxicology, risk assessment, and

risk management policy. I have over 20 years of experience in the biological, chemical, and

social policy aspects of environmental and public health protection. I have been the executive

director of the Presidential/Congressional Commission on Risk Assessment and Risk

Management and director of the Toxicology and Risk Assessment Program at the National

Academy of Sciences. I currently serve on two National Academy of Sciences committees that

focus on improving the scientific basis for limiting risks from chemical and radiological hazards.

I am a fellow of the Society for Risk Analysis (and served as president of that society in 1998

and 1999) and am a member of the Society of Toxicology. I have been asked to address the

topic of health issues associated with methylmercury in fish and coal-based power plant mercury

emissions in general, and several related issues raised in the Illinois Environmental Protection

Agency’s

Technical Support Document for Reducing Mercury Emissions from Coal-Fired

Electric Generating Units

(TSD) and in Dr. Deborah Rice’s

Review of the nervous system and

cardiovascular effects of methylmercury exposure

in particular.

Relationship between power plant mercury emissions and fish methylmercury concentrations

Much of what appears in the media about fish, mercury, and power plants implies that

---

2

mercury comes directly out of power plants, falls directly onto nearby fish, turns into

methylmercury, and threatens public health. The TSD also appears to reflect that thinking. The

implication of such a scenario would be that reducing mercury emissions from power plants

would lead directly to less methylmercury in fish and better public health. The TSD further

implies that reducing power plant mercury emissions by a certain percentage would lead to the

same percentage decrease in fish methylmercury levels. Such a simple and direct relationship

between mercury emissions and local fish methylmercury levels is not supported scientifically.

The amount of methylmercury in fish is a function of many factors. Most of the mercury

emitted from power plants in the US ends up in the global atmosphere and is deposited

somewhere else. Most of the mercury that is deposited in the US comes from somewhere else.

According to the US Environmental Protection Agency (US EPA), about half of global mercury

emissions are naturally occurring, emitted from sources that include volcanoes, forest fires,

oceans, and soils.

1

Mercury that is deposited into water bodies, whatever the source, has to be

converted to methylmercury by microorganisms in the sediments. That methylmercury has to be

taken up by fish and those fish have to be caught and eaten. The extent to which mercury

deposited into water bodies—whether natural, global, local, and/or the result of human

activities—actually turns into methylmercury and gets into fish is very site-specific, depending

on factors like water chemistry, pH, temperature, sunlight, nutrient levels, and other site-specific

characteristics.

2

As a result, the amount of methylmercury in fish is not related simply to the

amount of mercury that is available. A lake with high mercury levels in its sediment can have

fish with low methylmercury levels and a lake with lower mercury levels can have fish with

higher methylmercury levels. In fact, the TSD reports that Illinois lakes with the highest

mercury concentrations were not the same as the lakes containing fish with the highest mercury

concentrations.

1

US Environmental Protection Agency (2005).

Mercury Emissions: The Global Context

.

Washington, DC. http://www.epa.gov/mercury/control_emissions/global.htm

2

Summarized in: Center for Science and Public Policy (2005).

Making Sense of State Fish

Advisories

. Washington, DC. Page 54. http://ff.org/centers/csspp/pdf/20050228_hgfishadvisories.pdf

---

3

In a recent report from a workshop convened by the Society for Environmental

Toxicology and Chemistry, scientists concluded,

3

“It is not clear whether changes in mercury

input will result in a linear change in mercury methylation. Computer models, such as one

developed for the Florida Everglades, tend to predict a linear response, but there are little data to

support the predictions . . . [D]ecision makers need more than mercury concentrations to be able

to ensure defensible interpretation of the indicators, such as methylmercury in fish. Other

necessary information includes land use; food-web structure; the introduction of exotic species;

point-source discharges; changes in climate, atmospheric chemistry, and acidic deposition; and

hydrological regimes (e.g., retention time and water level fluctuation) . . . Other factors such as

sulfate and organic matter that impact bacterial activity, could also possibly cause an increase in

fish mercury concentration even as atmospheric deposition decreases.”

Studies attempting to correlate trends in environmental mercury levels with trends in

methylmercury levels in freshwater fish are limited. To my knowledge, there are no published

studies specifically evaluating power plant mercury emissions and trends in fish methylmercury

levels. The TSD relies on data reported in a Florida Department of Environmental Protection

report

4

to support its conclusion that reducing power plant mercury emissions and deposition will

reduce local fish methylmercury levels. The TSD omits the Florida data that are inconsistent

with that conclusion, however, and presents only the data that support it. Data were collected

from 12 Florida locations,

5

but the TSD provides data from only two locations in the Everglades.

The data from those two locations appear to support the TSD’s conclusions about direct

relationships among mercury emissions, mercury deposition, and methylmercury accumulation

3

Mason RP, Abbot ML, Bodaly RA, Bullock, OR Jr, Driscoll CT, Evers D, Lindberg SE, Murray

M, Swain EB (2005). Monitoring the response to changing mercury deposition. Report on a workshop

convened at the 2004 annual meeting of the Society of Environmental Toxicology and Chemistry.

Environmental Science and Technology 39:14A-22A

4

Florida Department of Environmental Protection (2003).

Integrating Atmospheric Mercury

Deposition with Aquatic Cycling in South Florida: An approach for conducting a Total Maximum Daily

Load analysis for an atmospherically derived pollutant

.

5

Ibid, page 81

---

4

in fish but data from other locations do not.

In the Florida report, regulation of mercury emissions from medical waste incinerators

was concluded to have reduced estimated point-source mercury emissions between 1990 and

2000 by 93% (based on unpublished data).

6

Data from the Mercury Deposition Network

obtained at one site in the Everglades were used to assert that deposition of mercury via rain at

that site declined by 25% between 1994 and 2002.

7

However, Figure 24 in the Florida report

shows clearly that between 1994 and 2000, the time period of interest, there was no decline in

deposition.

8

The direction of trends in largemouth bass mercury concentrations for an

unidentified number of fish caught at 12 Florida locations between 1988 and 2000 was evaluated

using a nonparametric test for slope (unpublished data cited in Florida 2003).

9

As can be seen in

Exhibit 1, the samples overall were fairly evenly split between declining trend and no or

increasing trend. Consistent declining trends across age groups were seen at three of the

locations sampled, a consistent lack of trend was seen at four locations, and an increasing trend

was seen at one location. The other locations showed some declines and some absence of

change depending on the age of the fish. The Florida study has not been peer-reviewed or

published in a peer-reviewed scientific journal.

There are a number of additional reasons why it is likely that extrapolating the potential

impact of lower incinerator mercury emissions in the Everglades to the potential impact of lower

power plant mercury emissions in Illinois is tenuous at best. First, the mercury emitted from

incinerators is different from the mercury emitted from power plants. Most incinerator mercury

is water-soluble and deposits close to incinerators;

10

most power plant mercury is thought to be

6

Ibid, page 76

7

Ibid, page 78

8

Ibid, page 81

9

Ibid, page 82

10

Ibid page 88

---

5

elemental, not water soluble, and ends up becoming part of global atmospheric mercury.

11

Second, the Everglades are a unique, tropical ecosystem that is strikingly different from the

decidedly non-tropical ecosystems found in Illinois. They are likely to differ greatly in terms of

water chemistry and other factors that determine the extent to which deposited mercury becomes

fish methylmercury.

12

And third, there was no contemporaneous determination of whether

reduced mercury emissions actually led to reduced local mercury deposition, which would have

had to have occurred if there were a connection between local mercury emissions and local

freshwater fish methylmercury concentrations. Incinerator controls were initiated in 1987 but

deposition measurements were not taken until 1994 and 1995.

13

The TSD also relies on data from Massachusetts to support its conclusion about a direct

relationship between mercury emissions and fish methylmercury concentrations. While the

Massachusetts study does suggest a decrease in fish methylmercury concentrations in two

species following the elimination of nearby medical waste incinerators and implementation of

stringent limits on municipal solid waste incinerators, most of the data supporting that conclusion

consist of only two sampling points over time per location; when three data points were

available, no statistically significant decline is apparent.

14

Furthermore, the majority of the

reported decreases in fish methylmercury did not occur until 36-48 months after the observed

decreases in mercury emissions and the magnitude of the decreases in fish methylmercury did

not approach the magnitude of the decreases in emissions (

?

25% to 32%

?

versus

?

87%). Those

11

Lohman K, Seigneur C, Edgerton E, Jansen J (2006). Modeling mercury in power plant

plumes. Environmental Science & Technology 40:3848-3854; Edgarton ES, Hartsell BE, Jansen JJ

(2006). Mercury speciation in coal-fired power plant plumes observed at three surface sites in the

southeastern US. Environmental Science & Technology (pre-pub available online,

http://pubs.acs.org/cgi-bin/abstract.cgi/esthag/asap/abs/es0515607.html)

12

US Environmental Protection Agency (2005).

Regulatory Impact Analysis of the Clean Air

Mercury Rule. Final Report

. EPA-452/R-05-003. Office of Air Quality Planning and Standards.

Research Triangle Park, NC. Page 3-16

13

Florida report, page 80

14

Massachusetts Department of Environmental Protection (2006).

Massachusetts Fish Tissue

Mercury Studies: Long-Term Monitoring Results, 1999-2004

, Figures 4 and 5

---

6

observations support a nonlinear relationship between emissions and fish methylmercury

concentrations, suggesting that a 90% reduction in emissions in Illinois is unlikely to lead to a

90% reduction in fish methylmercury concentrations, as implied by the TSD. Also, as with

Florida, those results are not likely to be validly extrapolated to coal-based power plants because

of the different speciation characteristics of mercury emissions from power plants and the

importance of speciation to the extent of local deposition. The Massachusetts study also has not

been published in the peer-reviewed scientific literature and appears preliminary in nature due to

the small number of samples.

The TSD makes a plausible case for reducing power plant mercury emissions as a general

matter. What it does not do is make a case for reducing emissions faster or deeper than would

occur if federal regulations were implemented instead. In fact, the TSD omits information that

illustrates the effectiveness of federal regulations. For example, Figures 5.1 and 5.2 in the TSD

compare US EPA’s map of mercury deposition from all sources with its map of mercury

deposition if there were no coal-based power plants in the US. Omitted are the US EPA maps

that generally accompany those figures showing the impact of federal regulations (see Exhibit

2).

15

In other words, the TSD shows maps illustrating the fact that US power plants contribute to

mercury deposition in the US but fails to show how effectively federal regulations would reduce

that deposition. However, as discussed above, reducing mercury emissions in Illinois may or

may not affect methylmercury levels in Illinois fish. And even if it does, reducing Illinois

methylmercury fish tissue concentrations to below the Illinois fish tissue mercury consumption

advisory levels will not eliminate fish consumption advisories in Illinois because of the presence

in Illinois fish of other substances such as polychlorinated biphenyls.

16

It seems worth pointing out that in the US overall, according to the National Marine

15

US Environmental Protection Agency (2005).

Technical Support Document: Methodology

Used to Generate Deposition, Fish Tissue Methylmercury Concentrations, and Exposure for Determining

Effectiveness of Utility Emission Controls: Analysis of Mercury from Electricity Generating Units

. Pages

6-11. http://www.epa.gov/ttn/atw/utility/ria_final.pdf

16

Testimony of Dr. Peter Chapman, Table 3

---

7

Fisheries Service, more than 75% of the fish we eat is imported and half of what we eat comes

from a can.

17

Based on data from the US Department of Agriculture, of those who eat fish in the

US, about 10% of the fish they eat comprises freshwater fish

18

(not all of which would be

methylmercury-contaminated). In the State of New York, 98% of sports anglers surveyed

reported that they either don’t eat what they catch at all or eat it less frequently than once per

month.

19

In Wisconsin, of the women of childbearing age who reported eating fish, less than

one-third reported eating sport fish and there was no difference between their hair mercury levels

and those of women who did not eat sport fish.

20

There is no information available on the extent to which Illinois anglers consume what

they catch. It is not possible to tell from the studies cited in the TSD the extent to which anglers

in general eat what they catch or the extent to which the fish that are eaten are contaminated with

methylmercury. US data show that fishing is positively correlated with income,

21

so most

anglers are unlikely to be subsistence anglers and data based on all anglers in Illinois cannot be

used to represent subsistence anglers. It is possible that there are some subsistence anglers in

Illinois whose families may be at risk from methylmercury from Illinois fish but the TSD does

not identify them or characterize the extent of the problem, so it is not possible to characterize

the extent of the potential benefits. Even if reducing power plant mercury emissions in Illinois

does turn out to lower methylmercury levels in some local fish, that reduction will benefit only

17

US National Marine Fisheries Service (2003).

Per Capita Consumption

http://www.st.nmfs.gov/st1/fus/fus03/08_perita2003.pdf

18

Annapolis Center (2003).

Mercury in the Environment: The Problems, the Risks, and the

Consequences

. http://www.annapoliscenter.org

19

Li Q, Vena JE, Swanson MK (2005). Reliability of sport fish consumption in the New York

State Angler Cohort Study. Environmental Research 97:142-148

20

Knobeloch L, Anderson HA, Imm P, Peters D, Smith A (2005). Fish consumption, advisory

awareness, and hair mercury levels among women of childbearing age. Environmental Research 97:220-

227

21

US Fish & Wildlife Service (2002).

2001 National Survey of Fishing, Hunting, and Wildlife-

Associated Recreation

---

8

that small proportion of the people in Illinois who rely on Illinois freshwater predator fish as

their primary protein source in the areas where those reductions actually occur. Of course,

benefiting “only a small proportion of the people” does not imply that those people don’t deserve

to be protected, it implies that reducing mercury emissions should not be oversold as a means of

improving public health and protecting children in general.

Obtaining specific data on who the women of childbearing age are in Illinois whose

children are actually potentially at risk from methylmercury present in Illinois fish would

facilitate a more informed discussion of the potential benefits of either CAMR or the proposed

rule. In its CAMR reconsideration decision, US EPA has concluded that after CAIR and CAMR

are implemented, the only people who would remain potentially at risk from utility-attributable

fish methylmercury would be the 99

th

percentile recreational fishers and mean Native American

subsistence fishers who consume solely freshwater fish contaminated at the 99

th

percentile

level.

22

Given that the likelihood of such a scenario is poor, US EPA concludes that utility-

attributable mercury emissions remaining after implementation of CAIR and CAMR are not

reasonably anticipated to pose hazards to public health.

23

While it seems logical to assume that reducing power plant or other mercury emissions

will lead to reductions in local fish methylmercury levels, available data do not provide much

support for that conclusion. The relationship between mercury emissions and fish

methylmercury levels appears to be highly site-specific, so it is likely that reducing power plant

mercury emissions could lead to lower fish methylmercury levels in some places in Illinois and

not in others. Predicting where changes might occur is not possible with currently available data.

The people currently at risk from methylmercury in Illinois fish are also unknown. It is therefore

22

US EPA also notes that the overwhelming majority of tribal populations live outside areas most

impacted by utility-attributable mercury deposition and elevated utility-attributable fish tissue levels.

23

US Environmental Protection Agency (2006). Revision of December 2000 Clean Air Act

Section 112(n) Finding Regarding Electric Utility Steam Generating Units: and Standards of Performance

for New and Existing Electric Utility Steam Generating Units: Reconsideration. Final rule. 40 CFR Part

60. EPA-HQ-OAR-2002-0056; FRL-8180-4

---

9

not possible to predict whether and to what extent reducing power plant mercury emissions will

result in reduced fish methylmercury concentrations in Illinois or the extent to which any such

reductions would lead to reduced risk in Illinois. Any claims that Illinois’ state-specific

proposed rule will protect high consumers of Illinois fish any better than will the federal rule are

supported neither by the TSD nor by science.

Methylmercury and developmental toxicity

No one questions Dr. Rice’s and the TSD’s conclusion that methylmercury can be toxic

to the developing brain. The extent to which methylmercury poses a risk at current

environmental levels of exposure is debated among scientists and among national and

international organizations responsible for protecting public health. Such organizations in the

US and worldwide have evaluated methylmercury risks very differently than have either the US

EPA or IL EPA. The discussion of methylmercury toxicity in the TSD does not reflect the

debate or the different conclusions that have been drawn by different scientists and organizations

about what methylmercury exposure level does or does not pose a risk. The TSD does not

critically analyze the available data and presents studies in a way that biases the reader, with no

discussion of the considerable uncertainties involved. There is no discussion of the weight of

scientific evidence. Both the TSD and Dr. Rice’s testimony give equal weight to all studies

reporting adverse effects and observations, providing no critical analysis of what might be more

or less likely, failing to discuss the uncertainties inherent in the studies, and failing to reflect the

conclusions of the investigators themselves.

For example, in Dr. Rice’s discussion of the 9-year-old followup study in the Seychelles,

she states, “An adverse association was found between postnatal exposure and performance on

the grooved pegboard using the non-preferred hand, with no other adverse effects.” She does not

point out that there were more than 60 end points evaluated (only one of which was negatively

correlated with methylmercury exposure) nor does she report the authors’ conclusion: “These

data do not support the hypothesis that there is a neurodevelopmental risk from prenatal

---

10

[methylmercury] exposure resulting solely from ocean fish consumption.”

24

Nor does she note

that the average methylmercury concentration in fish in the Seychelles is similar to that in

commercial fish consumed in the US (0.3 ppm) but that women in the Seychelles consume an

average of 12 fish meals per week,

25

so their exposures greatly exceed most exposures in the US.

If methylmercury exposure in the Seychelles greatly exceeds methylmercury exposure in the US

and failed to produce adverse effects, then adverse effects in the US are even less likely. Dr.

Rice then states that the subsequent study of Huang et al. (2005),

26

evaluating potential nonlinear

associations, “suggested adverse effects above 12 ppm in maternal hair on several measures . . .”.

Again, she omits the authors’ conclusion: “We conclude that this reanalysis supports the

primary linear analysis, showing little evidence for a prenatal adverse effect.”

27

The TSD also omits from discussion recent studies that conflict with its conclusions

about methylmercury’s developmental toxicity. For example, the 9-year-old Seychelles

followup study discussed above indicated that children exposed to higher levels of

methylmercury because their mothers ate more fish when they were pregnant scored higher on

some tests of brain development than children who were exposed to lower levels of

methylmercury because their mothers ate less fish. As discussed, earlier studies of the same

children showed no adverse effects of methylmercury exposure on tests of brain development. A

recent study of children in the UK reported that increasing umbilical cord mercury levels were

not associated with increased cognitive impairment but that increasing prenatal fish consumption

24

Myers GJ, Davidson PW, Cox C, Shamlaye CF, Palumbo D, Cernichiari E, Sloane-Reeves J,

Wilding GE, Kost J, Huang LS, Clarkson TW (2003). Prenatal methylmercury exposure from ocean fish

consumption in the Seychelles child development study. Lancet 361:1686-1692. Page 1686

25

Ibid

26

Huang LS, Cox C, Myers GJ, Davidson PW, Cernichiari E, Shamlaye CF, Sloane-Reeves J,

Clarkson TW (2005). Exploring nonlinear association between prenatal methylmercury exposure from

fish consumption and child development: evaluation of the Seychelles Child Development Study nine-

year data using semiparametric additive models. Environmental Research 97:100-108

27

Ibid page 100

---

11

was associated with improved cognition.

28

A different study of the same group of kids in the UK

found that the children of mothers who ate more fish during pregnancy and were exposed to

more methylmercury had IQs five points higher than the children of mothers who ate less.

29

A

preliminary study in Massachusetts found similar results.

30

In all cases, the cognitive benefits

were attributed to the omega-3 fatty acids found in fish. Omega-3 fatty acids are essential for

appropriate nervous system development and function. Other micronutrients found in fish are

also considered important contributors to successful brain development or are even capable of

preventing neurotoxicity.

31

The results of the Seychelles and UK studies do not suggest that

methylmercury is good for children, but they do demonstrate that the benefits of fish clearly

overcome its potential threats, even in the children of women who derive most of their dietary

protein from fish and are exposed to higher levels of methylmercury as a result. They also help

explain why effects were seen in the Faroe Islands but not the Seychelles. In the Faroes, the

principal source of methylmercury exposure was pilot whale meat while in the Seychelles, the

only source was fish. If the benefits of eating fish can outweigh the risks from methylmercury, it

is not surprising that where there were fewer benefits from fish, the effects of methylmercury

were more likely to be manifested. Neither Dr. Rice nor the TSD include this explanation for the

differing results.

Another possible explanation for the different results observed in the Faroe and Seychelle

Islands is the presence of high concentrations of polychlorinated biphenyls (PCBs) in pilot whale

blubber in the Faroes. Dr. Rice mentions this possibility but then dismisses it, citing the

28

Daniels JL, Longnecker MP, Rowland AS, Golding J, ALSPAC study team (2004). Fish intake

during pregnancy and early cognitive development of offspring. Epidemiology 15:394-402

29

Hibbeln (2006)

Nutrition, the brain and mental ill health

. Cleave Lecture. Presented at the

conference “Generating Healthy Brains,” 17 January 2006. London

30

Oken E, Wright RO, Kleinman KP, Bellinger D, Amarasiriwardena CJ, Ju H, Rick-Edwards

JW, Gillman MW (2005). Maternal fish consumption, hair mercury, and infant cognition in a U.S.

cohort. Environmental Health Perspectives 113:1376

31

Clarkson TW, Strain JJ (2003). Nutritional factors may modify the toxic action of methyl

mercury in fish-eating populations. Journal of Nutrition 133:1539S-1543S

---

12

epidemiologic re-evaluations of the study ruling out confounding by prenatal exposure to PCBs

and the conclusion of the National Academy of Sciences report on methylmercury.

32

What she

fails to mention is that the neither the re-evaluations nor the NAS committee considered the

possibility of post-natal developmental effects from PCBs exposure via breast milk. This

omission is particularly surprising given that Dr. Rice’s own research has demonstrated

developmental neurotoxicity in infant monkeys fed PCBs postnatally in formula at a dose

equivalent to about half that experienced by the children in the Faroes.

33

Dr. Rice has even co-

authored a review concluding that prenatal PCB exposure was associated with poorer

performance on the Boston Naming Test in the Faroes (the endpoint upon which the NAS and

US EPA methylmercury risk assessments were based).

34

And, according to the Faroes study

investigators themselves, when the effects of prenatal exposure to PCBs were properly controlled

for, the correlation between methylmercury exposure and poorer performance on the Boston

Naming Test was no longer statistically significant.

35

As Exhibit 3 shows, the level of PCBs to

which the children were exposed in the Faroe Islands was almost double the level demonstrated

to produce neurologic effects in infant monkeys and almost 1,000 times higher than US EPA’s

reference dose for PCBs. It is my opinion and that of many other scientists that the results of the

Faroe Islands study at best should be attributed to combined exposure to methylmercury and

PCBs.

Methylmercury exposure limits

The US Centers for Disease Control (CDC) reports that children and women of

32

National Academy of Sciences/National Research Council (2000).

Toxicological Effects of

Methylmercury

. National Academy Press. Washington, DC

33

See, for example, Rice DC (1998). Effects of postnatal exposure of monkeys to a PCB mixture

on spatial discrimination reversal and DRL performance. Neurotoxicology and Teratology 20:391-400

34

Schantz SL, Widholm JJ, Rice D (2003). Effects of PCB exposure on neuropsychological

function in children. Environmental Health Perspectives 111:357-376

35

Grandjean P, Weihe P, White RF, Debes F, Araki S, Yokoyama K, Murata K, Sørensen N, Dahl

R, Jørgensen, PJ (1997). Cognitive deficit in 7-year-old children with prenatal exposure to

methylmercury. Neurotoxicology and Teratology 19:417-428

---

13

childbearing age in the US have methylmercury levels in their blood well below those that have

been reported to produce adverse effects.

36

Exhibit 4 illustrates the relationships among the

methylmercury levels reported to produce adverse effects, US EPA’s reference dose, or

recommended exposure limit, and actual environmental exposure. According to the National

Academy of Sciences report, an umbilical cord blood mercury level of 85 micrograms per liter

was associated with a 5% likelihood of poorer performance on the Boston Naming Test, a test of

memory, among children in the Faroe Islands, where people rely primarily on seafood as their

source of dietary protein.

37

That value is referred to as a benchmark dose or BMD.

38

US EPA

used a blood mercury level of 58 micrograms per liter—a conservative, health-protective lower

limit on 85 micrograms per liter (BMDL)

39

—as the basis for calculating a methylmercury

reference dose. A reference dose is defined by US EPA as “an estimate of an exposure . . . that

is likely to be without an appreciable risk of adverse effects over a lifetime.” The reference dose

for methylmercury, 5.8 micrograms per liter, was obtained by dividing 58 micrograms per liter

by an uncertainty factor of 10, in order to protect any unusually sensitive individuals. The

average mercury blood level in women of childbearing age reported by the CDC was 0.83

micrograms per liter, with 5.7% of the women tested having blood mercury levels above 5.8

micrograms per liter

40

(i.e., exceeding US EPA’s reference dose) (see inset in Exhibit 4). None

of this representative cross-section of women who have been tested in the US had blood mercury

levels approaching 85 micrograms per liter, the value calculated in the National Academy of

Sciences report as being associated with a 5% change in performance on the memory test.

36

US Centers for Disease Control and Prevention (2005).

Third National Report on Human

Exposure to Environmental Chemicals

. http://www.cdc.gov/exposurereport/

37

National Academy of Sciences (2000).

Toxicological Effects of Methylmercury

. National

Academy Press. Washington, DC

38

US EPA defines benchmark dose or BMD as “a dose that produces a predetermined change in

response rate of an adverse effect compared to background.”

39

US EPA defines BMDL as “a statistical lower confidence limit on the dose at the BMD.”

40

US Centers for Disease Control and Prevention (2005). Third National Report on Human

Exposure to Environmental Chemicals. http://www.cdc.gov/exposurereport/3rd/pdf/results_01.pdf

---

14

Exhibit 5 shows another way to compare exposures. In addition to blood levels, mercury

exposure can be reflected in hair. Exhibit 5 shows (1) measurements of mercury levels in the

hair of the women in the Faroe Islands who ate methylmercury and PCB-contaminated pilot

whales and whose children tended to perform more poorly on the Boston Naming Test as their

mothers’ exposure to mercury increased;

41

(2) US EPA’s reference dose, or recommended limit

on methylmercury exposure;

42

(3) the average mercury level found in the hair of US women of

childbearing age tested by the CDC;

43

(4) the upper 90

th

percentile mercury level in US women

of childbearing age; and (5) the mercury level reported for a sample of mothers in Japan.

44

Both

Exhibits 4 and 5 show that the mercury level associated with neurodevelopmental deficits in the

Faroe Islands is much higher than the levels of mercury exposure in US women. The Japanese

data provide an interesting contrast and were used by the Japanese investigators to calculate that

more than 90% of Japanese women have mercury levels that exceed US EPA’s reference dose

for methylmercury.

45

As far as I know, there is no epidemic of poor neurodevelopmental

performance in Japan.

Other regulatory agencies and scientific organizations in the US and Europe have

identified quantitative exposure levels for methylmercury—based partly on science but mostly

on policy—that are considered to be limits on safety. Such limits are goals that, if exceeded,

41

Grandjean P, Weihe P, Burse VW, Needham LL, Storr-Hansen E, Heinzow B, Debes F, Murata

K, Simonsen H, Ellefsen P, Budtz-Jørgensen E, Keiding N, White RF (2001). Neurobehavioral deficits

associated with PCB in 7-year-old children prenatally exposed to seafood neurotoxicants.

Neurotoxicology and Teratology 23:305-317

42

US Environmental Protection Agency (2001).

Water Quality Criterion for the Protection of

Human Health: Methylmercury

. Office of Water. Washington, DC

http://www.epa.gov/waterscience/criteria/methylmercury/document.html

43

US Centers for Disease Control (2001). Blood and hair mercury levels in young children and

women of childbearing age—United States, 1999. Morbidity and Mortality Weekly Report 50:140-143

44

Iwasaki Y, Sakamoto M, Nakai K, Oka T, Dakeishi M, Iwata T, Satoh H, Murata K (2003).

Estimation of daily mercury intake from seafood in Japanese women: Akita cross-sectional study.

Tohuku Journal of Experimental Medicine 200:67-73

45

Ibid page 67

---

15

may warrant actions to reduce exposure, although exceeding a limit does not imply lack of

safety. Most exposure limits for methylmercury are advisory levels and not regulatory

requirements. Exhibit 6 shows the exposure levels considered protective by different

organizations. All of the protective exposure levels identified in Exhibit 6 are based on

methylmercury’s ability to produce developmental neurotoxicity. Most were based on the data

from the Seychelles study mentioned above although some also considered the Faroe Island and

New Zealand data. Some derived a benchmark dose from the dose-response relationship for

methylmercury exposure and developmental neurotoxicity. In other cases, a no-observed-

adverse-effect level (NOAEL) was identified, that is, the median maternal hair concentration

from the highest exposure group in the Seychelle Islands study (which, as noted above, found no

significant positive association between exposure and abnormality). The benchmark dose or

NOAEL, expressed as concentrations of mercury in blood or hair, was then converted to the

dose of methylmercury from fish that would produce that blood or hair concentration. Finally,

that dose was divided by an “uncertainty factor” to obtain a dose considered to be without

deleterious effects by accounting for the possibility that some people might be more sensitive to

methylmercury toxicity than others. The resulting dose is considered the amount of

methylmercury that can be consumed daily without producing developmental neurotoxicity even

in the most sensitive children. US EPA calls such limits reference doses (RfDs), the Agency for

Toxic Substances and Disease Registry calls them chronic minimal risk levels (MRLs), and

others refer to them as tolerable daily intakes (TDIs).

As Exhibit 6 indicates, the methylmercury exposure limits derived by different

organizations vary by an order of magnitude. The different limits result from different decisions

about which study was the most representative or valid, the approach taken to evaluate the

relationship between dose and response, and the choice of uncertainty factor. None of those

choices are necessarily “right” or “wrong” scientifically, although some may reflect the weight

of the scientific evidence better than others. They represent different policy choices made by

equally competent scientists looking at the same data, making different decisions for different

reasons, leading to different conclusions. As such, they illustrate the important role that policy

choices make in decisions about limiting chemical exposures and the limited role that science

---

16

often ends up playing.

The US EPA is the only agency that did not include the Seychelles study in its reference

dose calculation, thereby excluding the study in which methylmercury exposure occurred solely

through fish, as it does in the US, and that could not have been confounded by PCBs in breast

milk or pilot whale blubber. Excluding the Seychelles study produces a more stringent reference

dose than would be possible otherwise. A more stringent reference dose produces a lower

acceptable fish methylmercury concentration than would be obtained based on other

organizations’ values. A lower acceptable fish methylmercury concentration suggests that more

fish exceed the limit and more people could be at risk than would result otherwise. More fish

exceeding the limit and more people potentially at risk drives public concern about mercury in

fish and, ultimately, about power plant emissions. Thus the policy—not scientific—decision to

exclude the Seychelles data from consideration (despite the fact that the rest of the world appears

to rely primarily on the Seychelles data) has contributed to greater public concern in the US

about methylmercury and its potential sources than would be likely to occur otherwise.

The impact of different policy choices on acceptable fish methylmercury concentrations

is illustrated in Exhibit 7. The first column of Exhibit 7 shows the parameter values chosen by

US EPA as the basis for developing its methylmercury fish tissue residue criterion for freshwater

and estuarine fish.

46

The following columns show how varying one parameter value, by

choosing a value used by one of the other organizations shown and substituting it for US EPA’s

value, produces a completely different fish tissue residue criterion. Using a different value for

the reference dose or a different value for the assumption about fish consumption produces

residue criteria that vary by an order of magnitude, providing further illustration that different

policy choices lead to different conclusions about risk.

Of particular note in Exhibit 7 is the difference among assumptions about average daily

fish consumption. US EPA recommends a default fish intake rate of 17.5 grams/day to

46

Environmental Protection Agency (EPA) (2001).

Water Quality Criterion for the Protection of

Human Health: Methylmercury

. EPA-823-R-01-001. Office of Water. Washington, DC

---

adequately protect the general population of fish consumers,

47

based on the 1994 to 1996 data

from the USDA’s CSFII Survey.

48

US EPA also recommends default fish intake rates for

recreational and subsistence fishers of 17.5 grams/day and 142.4 grams/day, respectively.

49

IL

EPA has chosen the latter estimate as the basis for its fish tissue methylmercury criterion,

50

so

the IL criterion applies to subsistence fishers, not the general population or even most sports

anglers. US EPA subtracts the contribution to methylmercury exposure attributable to marine

seafood from the daily intake rate, although IL EPA does not. The IL criterion is thus intended

to protect the most-exposed, worst-case women of childbearing age who are subsistence fishers

relying almost solely on the most contaminated freshwater predator fish in Illinois as their source

of protein. As noted above, the TSD has not identified or characterized the locations and

numbers of those people potentially at risk, making an evaluation of any potential benefits

provided by the state’s proposed rule impossible and any claims regarding its superior benefits

compared to CAMR wholly untenable.

The derivation of a reference dose or other criterion is thus based on many policy choices

in order to serve regulatory purposes and has little scientific basis. Despite numerous assertions

to the contrary (including Dr. Rice’s), women whose exposures exceed US EPA’s

methylmercury reference dose are

not

“at risk” of having developmentally impaired children.

US EPA is careful to point out that, while exposure at or below a reference dose indicates that a

health risk is unlikely, people who are exposed to a substance above its reference dose should not

be considered at risk: “. . . exceeding the [reference dose] is not a statement of risk.”

51

US

47

US Environmental Protection Agency (2000). Methodology for deriving ambient water quality

criteria for the protection of human health. EPA-822-B-00-004. Office of Science and Technology, Office

of Water. Washington, DC. http://www.epa.gov/ostwater/humanhealth/method/complete.pdf

. Page 4-24

48

US Department of Agriculture (1998). 1994–1996 Continuing Survey of Food Intakes by

Individuals and 1994–1996 Diet and Health Knowledge Survey. Agricultural Research Service.

Washington, DC

49

US Environmental Protection Agency (2000). Methodology for deriving ambient water quality

criteria for the protection of human health. EPA-822-B-00-004. Office of Science and Technology, Office

of Water. Washington, DC. http://www.epa.gov/ostwater/humanhealth/method/complete.pdf

. Page 4-24

50

Based on Table 4.3 in the TSD

51

US Environmental Protection Agency (2004).

Exposure and Human Health Reassessment of

2,3,7,8-Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds National Academy Sciences

---

18

EPA’s Regulatory Impact Assessment for the Clean Air Mercury Rule states, “It is also

important to note that the [reference dose] does not define a bright line, above which individuals

are at risk of adverse effect.”

52

In other words, while exposures at or below a reference dose are

unlikely to pose a risk, the converse—that exposures exceeding a reference dose are likely to

pose a risk—is not the case. The number of children “at risk” is determined by the dose-

response relationship, not by the number of people whose doses or blood mercury levels exceed

the reference dose at a single point in time.

Methylmercury and cardiovascular toxicity

There is a large body of evidence demonstrating the cardiovascular benefits of fish

consumption in adults.

53

While most of the studies reporting an inverse association between fish

consumption and cardiovascular effects did not specifically evaluate mercury exposure, it is

reasonable to assume that people who eat more fish are exposed to more mercury. The

American Heart Association recommends that individuals consume two servings of a variety of

fish weekly, both for the benefits of omega-3 fatty acids and because fish tends to be low in

saturated fats, which contribute to elevated cholesterol levels.

54

A study of Finnish men has been pointed to recently as evidence that mercury exposure is

associated with cardiovascular disease. That study found an association among the highest third

of hair mercury content and an approximately 60% greater prevalence of coronary heart and

cardiovascular diseases compared to men with the lower two-thirds of hair mercury content.

55

(NAS) Review Draft

. National Center for Environmental Assessment. Office of Research and

Development. Washington, DC. Page 14

52

US Environmental Protection Agency (2005).

Regulatory Impact Analysis of the Clean Air

Mercury Rule

. EPA-452/R-05-003. Office of Air Quality Planning and Standards. Research Triangle

Park, NC. Page 9-2

53

See review by Kris-Etherton PM, Harris WS, Appel LJ for the Nutrition Committee of the

American Heart Association (2002). Fish consumption, fish oil, omega-3 fatty acids, and cardiovascular

disease. Circulation 106:2747-2757

54

American Heart Association Dietary Guidelines for Healthy Adults,

http://www.americanheart.org/presenter.jhtml?identifier=4561

55

Virtanen JK, Voutilainen S, Rissanen TH, Mursu J, Tuomainen TP, Korhonen MJ, Valkonen

VP, Seppanen K, Laukkanen JA, Salonen JT (2005). Mercury, fish oils, and risk of acute coronary

---

19

The men least likely to experience heart problems were those who had both low levels of hair

mercury and high blood levels of fatty acids found in fish that are known to reduce the risk of

heart disease. Attempts to correlate hair mercury content with fish consumption were tenuous,

with only one third of the men in the highest hair mercury group reporting higher fish

consumption than the other study participants. No information was provided on whether high- or

low-mercury-containing types of fish were consumed. Contrary to the large body of

epidemiologic evidence showing a negative correlation between fish consumption and heart

disease, the population of Eastern Finland has a high rate of heart disease in spite of high fish

consumption,

56

suggesting that factors other than methylmercury are responsible for elevated

risk.

57

The Finnish results were considered preliminary by the American Heart Association,

which has concluded that when consumed according to established FDA/US EPA guidelines, the

cardiovascular benefits of eating fish far outweigh the risks for middle-aged and older men and

women after menopause.

58

Conclusion

I do not dispute Dr. Rice’s and the IL EPA’s consideration of methylmercury as a

developmental neurotoxicant about which we should be concerned. I do not dispute that

methylmercury exposure should be limited to the extent possible during pregnancy while

maintaining the many healthy benefits of fish consumption, which includes nutrients essential to

the development of healthy brains. I think that a more balanced discussion of methylmercury

toxicity that reflects ongoing scientific and policy debates is desirable so as to avoid conveying

an inappropriate level of certainty about methylmercury’s dose-response characteristics and to

events and cardiovascular disease, coronary heart disease, and all-cause mortality in men in Eastern

Finland. Arteriosclerosis, Thrombosis, and Vascular Biology Arteriosclerosis, Thrombosis, and Vascular

Biology 25:222-227

56

Salonen JT, Seppänen K, Nyyssönen K, Korpela H, Kauhanen J, Kantola M, Tuomilehto J,

Esterbauer H, Tatzber E, Salonen R (1995). Intake of mercury from fish, lipid peroxidation, and the risk

of myocardial infarction and coronary, cardiovascular, and any death in Eastern Finnish men. Circulation

91:645-655

57

Smith KM, Sahyoun NR (2005). Fish consumption: recommendations versus advisories, can

they be reconciled? Nutrition Reviews 63:39-46

58

American Heart Association (AHA) (2005). Fish, Levels of Mercury and Omega-3 Fatty

Acids. http://www.americanheart.org/presenter.jhtml?identifier=3013797

---

20

better illustrate the extent to which its reference dose reflects more policy than science. The fact

that other public health organizations have evaluated methylmercury’s risks differently than did

US EPA itself illustrates the widespread differences of opinion that are possible in terms of

scientific interpretation and policy choices.

I do not dispute the desirability of limiting mercury emissions from coal-based power

plants as a means of limiting its contribution to fish methylmercury levels in places where it may

be significant. I do dispute the simplistic notion that limiting power plant mercury emissions in

Illinois is going to have a direct and noticeable impact on Illinois fish methylmercury levels, on

Illinois methylmercury exposures, or on public health in Illinois. A tremendous amount of

uncertainty remains regarding the relationship between power plant mercury emissions and fish

methylmercury levels and toxicity, but the weight of the scientific evidence does not suggest that

they are simply and directly related. The public health benefits of limiting Illinois mercury

emissions are being oversold and the benefits of limiting mercury emissions deeper and faster

than is required by US EPA are political only.

---

Exhibit 1

Trends in largemouth bass methylmercury

concentrations at 12 Florida locations, 1988-2000

Source: Florida (2003)

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE JULY 28, 2006

---

Exhibit 2

Effectiveness of federal mercury rules

Deposition From US Power Plants in

2001

Deposition From US Power Plants After

CAIR, CAMR, and Other Clean Air Act

Programs in 2020

Source: USEPA (2005)

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE JULY 28, 2006

---

0

2

4

6

8

10

12

14

Faroes adult::

pilot whale & fish

Faroes child:

pilot whale & fish

Seychelles adult:

fish

Hg RfD = 0.1

PCBs RfD

= 0.02

Developmentally

neurotoxic level of

PCBs in infant monkeys

Mercury

PCBs

μg/kg/day

Source: Modified from Dourson et al. (2001)

Exhibit 3

Contaminant intakes in the Faroe and Seychelle Islands

---

Blood mercury concentration (μg per liter)

5% poorer

performance

in Faroes

EPA reference

dose

(women of

childbearing

0

0.8

Blood mercury

level comparison

women

---

0

2

4

6

8

10

12

14

16

18

5

%

i

n

c

r

e

a

s

e

i

a

b

n

o

r

m

a

l

B

o

s

t

o

N

a

m

i

n

g

T

e

s

r

e

s

p

o

n

s

e

A

v

e

r

a

g

E

P

A

r

ef

e

r

en

c

e

d

o

s

e

<0.1

U

S

a

v

e

r

ge

U

S

90

t

p

er

c

e

n

t

i

l

Exhibit 5

J

a

p

a

n

e

s

a

v

e

r

a

g

e

---

Exhibit 6

Exposure Limits for Methylmercury

Organization

ATSDR

EPA

RIVM

WHO

Exposure

Limit

b

0.3

chronic MRL

0.1

RfD

0.1

TDI

0.23

TDI

0.3 to 1

RfD

Study

Seychelles

Faroes

Seychelles

Seychelles,

Faroes

Seychelles

Study Dose

b

1.3

0.9 to 1.5

1.3

1.5

0.9 to 3

Uncertainty

Factor

d

4.5

10

10

3.2

3

Year

1999

2001

2000

2003

1998

a

Abbreviations for organizations: ATSDR, Agency for Toxic Substances and Disease Registry;

EPA, Environmental Protection Agency; RIVM, National Institute for Public Health and the

Environment, The Netherlands; WHO, World Health Organization; ICF, ICF Inc.; TERA,

Toxicology Excellence for Risk Assessment

b

Exposures expressed in units of micrograms methylmercury per kilogram body weight per day

c

Abbreviations for exposure limits: MRL, minimal risk level; RfD, reference dose; TDI,

tolerable daily intake

d

Uncertainty factors are used to lower the acceptable exposure level to the extent considered

protective of nearly all people.

Source: Based in part on Toxicology Excellence in Risk Assessment’s International Toxicity

Estimates for Risk Database (ITER) (2006). http://www.tera.org/iter/

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE JULY 28, 2006

---

1

Environmental Protection Agency (EPA) (2001).

Water Quality Criterion for the Protection of

Human Health: Methylmercury

. EPA-823-R-01-001. Office of Water. Washington, DC. Page 7-1

Exhibit 7

Impact of Changing Assumptions on EPA’s

Change assumption as per

Parameter

US EPA,

a,c

IL

EPA

b,d

WHO

e

US

ATSDR

e

IL

PIRG

b,f

ICF/

TERA

e

Exposure limit

(

:

g/kg/day)

0.1

0.23

0.3

0.3 to 1

Relative source

contribution

g

0.027

Body weight (kg)

70

Daily fish intake (kg)

0.0175

0.14

0.049

concentration limit

(mg/kg or ppm)

0.3

0.04

0.7

0.9

0.1

0.9 to 2.9

a

For organization abbreviations, see Exhibit 6.

b

IL EPA, Illinois Environmental Protection Agency; PIRG, Illinois Public Interest Research

Group

c

This column shows the assumptions used by USEPA to calculate its limit on permissible

methylmercury concentrations in freshwater and estuarine fish using the following equation:

1

BW × (RfD – RSC)

TRC =

FI

Where:

TRC =

Fish tissue residue criterion (mg methylmercury/kg fish) for freshwater and

estuarine fish (i.e., limit on acceptable fish methylmercury concentration)

RfD =

Reference dose = 0.0001 (mg methylmercury/kg body weight/day)

RSC =

Relative source contribution (subtracted from the RfD to account for marine fish

consumption) estimated to be 2.7 × 10

-5

mg methylmercury/kg body weight/day

BW =

Human body weight default value of 70 kg (for adults)

FI =

Fish intake; total default intake is 0.0175 kg fish/day for general adult population

ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE JULY 28, 2006

---

d

IL EPA assumes an average fish consumption rate of 0.14 kg/day, ten times higher than US

EPA, leading to a fish tissue concentration limit ten times more stringent than US EPA’s.

e

These organizations recommend methylmercury exposure limits that are two to ten times higher

than US EPA’s, leading to fish tissue concentration limits two to ten times less stringent than US

EPA’s.

f

IL PIRG assumes an average fish consumption rate of 0.045 kg/day, about three times higher

than US EPA and three times lower than IL EPA, differences reflected in its resulting fish tissue

methylmercury concentration limit.

g

Only US EPA accounts for marine fish consumption as a contributor to average daily

methylmercury intake by subtracting its contribution from that of freshwater and estuarine fish.

IL EPA and IL PIRG use their fish tissue methylmercury limits as though all methylmercury

exposure results from Illinois freshwater fish.

---

1

PROPOSED NEW 35 ILL.ADM.CODE PART 225

LARGE COMBUSTION SOURCES

)

)

)

PCB R06-25

Rulemaking - Air

Testimony of J.E. Cichanowicz

To the

Illinois Pollution Control Board

A REVIEW OF

THE STATUS OF MERCURY CONTROL TECHNOLOGY

Prepared By:

J. E. Cichanowicz

Consultant

236 N. Santa Cruz Avenue

Suite #202

Los Gatos, CA 95070

July 28, 2006

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

2

EXECUTIVE SUMMARY

My name is J. Edward Cichanowicz. I have provided independent consulting services since

1993 to the utility sector in evaluating environmental control technology, and defining

compliance strategies. Prior to that time, I was employed by the Electric Power Research

Institute for 15 years, focusing on developing control technologies for NOx, as well as SO

2

and

particulate matter. Preceding my employment at EPRI, I worked as a research engineer for the

Energy & Environmental Research Corporation (since acquired by GE Power Systems),

concerned with developing low NOx burners for coal.

I received a BS in Mechanical Engineering at Clarkson University, and a MS in Mechanical

Engineering at the University of California at Berkeley, where I also completed the bulk of

coursework for the doctoral degree.

The attached document entitled “A Review of the Status of Mercury Control Technology”

summarizes my evaluation of the readiness of mercury (Hg) control technology for use in

complying with the proposed Illinois Environmental Protection Agency (IEPA) Rule AQPSTR

06-02. The document consists of a discussion of technical feasibility, an Appendix A that

contains the assumptions used to project Hg control performance and cost that was applied to

economic modeling, and an Appendix B that contains assumptions defining performance and

cost of controls for NOx, SO2, and particulate matter that was applied to modeling CAIR

compliance.

The response of the U.S. utility industry to support the development of Hg control technology

has been unprecedented – since 2001, over 25 commercial-scale demonstrations have been either

completed or are in progress. The large number of demonstrations is warranted by the myriad of

plant designs, coal types, and existing environmental control systems to which Hg control

technology could be applied. This comprehensive approach is essential – the population of

power plants is as varied and diverse as people, with no two alike. Thus, it is important to

consider a wide array of plants, operating in a demonstration mode for extended periods, to

generalize evolving knowledge.

Despite extensive background work by IEPA staff and consultants, there are several major

shortcomings in the rule that complicate, if not prevent, compliance. First, the targeted outlet

content of Hg - in many cases less than 1 microgram/m

3

- is too low to be accurately monitored

for compliance. The testimony of Mr. R. McRanie will address the specific reasons why. In this

testimony, I will accept – without verification or other validation - that such measurements can

be made to within a reasonable degree of accuracy, precision, and bias. Section 2.4.2 and 2.4.3

describe why I believe the cumulative effect of measurement uncertainty, variability in coal

composition, and variability in process operation require a design Hg removal target of at least

93-95% to consistently deliver 90%.

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

3

Second, despite impressive results at selected demonstrations, the control technology that is the

focal point of interest - activated carbon injection (ACI) - is not yet sufficiently developed to

consistently deliver high Hg removal under the varied conditions in Illinois. For ACI within an

existing ESP, several demonstrations recorded 90% or better Hg removal. However, these

results reflect short-term tests and 30 day trials, thus the degree these controls can provide

satisfactory 24/7/365 service is uncertain.

There are two reasons this uncertainty persists. First, as noted in Section 3, the history of

environmental control evolution has taught us long-term experience - on the order of one year -

is required before commercialization. Operating trials of a 30-day duration, although an

impressive and a necessary first step, are inadequate. In coal-fired applications, environmental

controls are exposed to extremely dilute concentrations of trace constituents of coal, which can

accumulate on surfaces, and within reaction vessels, to threshold levels where they assert an

impact. The case study of the hot-side ESP – addressed in Section 3.4 – chronicles what can

happen when a control option is adopted prematurely. The failure of the hot-side ESP to provide

the reliable particulate matter control as originally envisioned exemplifies the risks. An example

of successful technology evolution is that of flue gas desulfurization, as described in Section 3.1.

However, several decades of operating experience, and abandoning unit-specific SO

2

limits for

tradable emission “allowances” was required to effect this development. The use of ACI with

existing ESPs could endure the same fate as hot-side ESPs - the accumulation of carbon could

assert detrimental effects on particulate matter removal or reliability, similar to the way the year-

long accumulation of sodium on emitting electrodes compromised the hot-side ESP. That

carbon will accumulate is certain - Section 8.4.5.4 of the Technical Support Document cites such

accumulation of carbon as a factor why 30 day tests exhibit higher Hg removal than short-term

tests. IEPA should recognize that carbon accumulation could assert negative as well as positive

impacts.

Also of concern for ACI within an ESP is the possibility of efforts to meet Hg limits triggering

New Source Review (NSR). As described in Section 5.6.5, with the Pollution Control Project

provisions of NSR vacated by the U.S. Court of Appeals on June 24, 2005, collateral increases in

emissions – regardless of the reason – can require NSR. Illinois generators could face the

prospect of a state-mandated regulation imposing federal control requirements.

The alternative means to deploy ACI - in a fabric filter environment (e.g. TOXECON I) –

provides a much higher opportunity for success, although at a steep price. Even for this

approach, 90% Hg removal is not commercially proven – results from the one-year trial

completed in 2004 at Gaston did not document 90% removal, but suggest such outcome may be

possible. Although 90% Hg removal is the target for the 270 MW Presque Isle demonstration,

these results are only now being generated, and on a short-term basis. Early operation at Presque

Isle has been stymied by equipment problems that, although perhaps not representing fatal flaws,

reflect problems amenable only to long-term testing. Notwithstanding the belief by the Presque

Isle project team that 90% Hg removal is certain, to date there is no data defining such results for

more than brief test periods.

These uncertainties are important in Illinois. The use of ACI in existing ESPs should recognize

the relatively small size of ESPs, as measured by the specific collecting area (SCA). Figure 5.1

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

4

in Section 5.3 compares the population distribution of ESPs in Illinois to the national population,

and to the demonstration units. Figure 5-1 shows Illinois ESPs to be extremely small when

compared to the demonstration units. Further, Table 5-1 in Section 5.6 summarizes the

significant ESP modifications – in some cases complete ESP replacements - implemented to six

of the most frequently cited demonstration sites. I do not believe that achieving 90 and 93% Hg

removal on units such as St. Clair and Meramac – featuring ESPs of 720 and 400 SCA,

respectively – portends the same result on the small ESPs at stations such as Will County and

Hennepin.

IPEA argued that ESP size is not relevant, but comparing Hg removal data from key

demonstrations suggests such a relationship exists. Figure 5-2 in Section 5.6.2. compares Hg

removal (either maximum measured or at 3-10 lbs/MACF) for various demonstrations, and

suggests there is some factor either directly or indirectly related to ESP SCA that impacts Hg

removal. Figure 5-2 is not intended to reflect any fundamental theorem of carbon Hg absorption,

or ESP residence time, but rather projects an anecdotal relationship. Figure 5-2 shows the

highest Hg removals have been attained on large, state-of-art ESPs that have in many cases

replaced the original equipment. Further, as described in Section 5.6.4, I believe the detrimental

impact of ACI on small ESPs is well-represented by the experience of Yates 1. Section 5.6.4.

also summarizes discussions with staff at Progress Energy Lee Unit 1, which emphasizes the

need to consider Exhibit 73 data as preliminary, as suggested by Mr. Nelson in his testimony.

There is a confluence of events under which the IEPA regulation could be attained – the goals of

the Presque Isle Demonstration would have to be realized quickly and without further equipment

complications; ACI within small ESPs in Illinois would have to be able to sustain carbon

injection and provide Hg removal on a long-term basis at or near the best performance measured

with short-term tests; and engineering and construction staff and process equipment would have

to be available to support rapid application of fabric filter-based (e.g. TOXECON I) technology

to more than 60% of the units. The details of equipment selection, inventory, and cost will be

addressed in the testimony of Mr. J. Marchetti.

In summary, I conclude there is insufficient data to demonstrate that Hg control technology is

available today to assure compliance with the Agency's proposed Hg rule. The data available

from short-term tests of conventional or halogenated carbon injection before ESPs is clearly

insufficient to project such compliance. Moreover, there is even less short-term data describing

the performance of these sorbents within a fabric filter environment, to assure a reasonable

certainty of compliance. Nevertheless, in order to project possible costs to achieve compliance

and its impact on mercury deposition, I prepared the relationships described in Appendix A that

allows compliance decisions to be mimicked, without conceding the available data allows these

decisions. Based on these assumptions, I conclude that the capital cost of meeting the mercury

rule would exceed 1.77 billion dollars.

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

5

THE STATUS OF MERCURY CONTROL TECHNOLOGY

SECTION

TITLE

PAGE

1

Introduction

6

2

Illinois Proposed Rule: What Does It Really Ask?

7

3

Evolution Of Environmental Control Technology and Cost

17

4

Inherent Mercury Removal From Environmental Controls

24

5

Mercury Specific Control Technologies

30

6

Process Guarantees

44

7

Scheduled and Demonstration Plans

47

8

Conclusions

49

REFERENCES

50

Appendix A Summary Of Assumptions Defining

Hg Control Technology Performance And Cost for Use in

Evaluating Proposed State Hg Rules

55

Appendix B Summary Of Assumptions Defining The Performance And

Cost Of SO2, NOx, And Particulate Matter For

CAIR Compliance

75

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

6

INTRODUCTION

This document concerns the proposed Rule AQPSTR 06-02 by the Illinois Environmental

Protection Agency, addressing control of mercury (Hg) emissions from coal-fired power plants.

Specifically, this document addresses the technical feasibility and cost of Hg control technology,

without the benefit of additional demonstration projects to be completed prior to 2012.

Generating companies throughout the U.S. are evaluating and preparing to implement control

technology to meet the Federal Clean Air Mercury Rule (CAMR). The commitment by the

utility industry in this endeavor cannot be questioned. Since 2001, the utility industry has

hosted, or is presently hosting, over 25 commercial-scale demonstrations and performance tests,

and numerous slip-stream or pilot plant tests, to explore various Hg-reduction strategies.

Regardless, as recently stated by the U.S. Department of Energy (DOE), the need to continue

demonstration and commercialization activities still exists, to support reliable and cost-effective

deployment of Hg controls. Consequently, additional demonstration projects will continue

through at least 2012 (Feeley, 2005b). The commitment by the utility industry for fast-track

development, generalization, and commercialization of Hg controls in the U.S. is unprecedented.

In parallel with this effort, the U.S. utility industry has addressed two other air quality-related

mandates – completing the installation of selective catalytic reduction (SCR) for NOx control (to

meet the one-hour ozone standard), and compliance steps for the Clean Air Interstate Rule

(CAIR). By May of 2006, approximately 120 GW of generating capacity in the U.S. will have

been retrofitted with SCR NOx control. Regarding the CAIR, Phase I requires compliance for

either NOx or SO2 in 2009 and 2010, respectively, with Phase II compliance by 2015. By 2010,

a total of 90 GW of generating capacity is anticipated to be retrofit with both SCR NOx control

and flue gas desulfurization (FGD).

The implications of compliance actions prompted by CAIR for Hg control are significant, and

should not be underestimated. Deploying advanced environmental controls for NOx, SO2, and

improving particulate matter control equipment provides a reliable platform from which to

optimize and implement Hg controls. The ability to leverage CAIR-prompted control

technology for Hg control will be to the financial and environmental benefit of the CAIR-

affected regions. Accelerating the Hg control mandate through proposed state-specific rules will

lead to higher compliance costs in the long-term, and interfere with adopting the most effective

CAIR strategy in the near term.

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

7

ILLINOIS PROPOSED RULE: WHAT DOES IT REALLY ASK?

2.1. INTRODUCTION

The proposed Illinois Environmental Protection Agency (IEPA) Hg rule is interpreted to require

90% Hg removal, or meet a system-wide Hg emission average of 0.008 lbs/GWh. The proposed

rule also includes a provision to allow a shortfall of performance to as low as 75%, as long as

either the system average of 90% or the outlet rate of 0.008 lbs/TBtu is attained. This structure –

requiring 90% but accommodating units that cannot achieve targeted performance – is proposed

to provide for flexibility to address the variable needs of utility systems.

First, the premise that conventional coal cleaning provides 47% Hg removal for Illinois basin

coals, and that the average content of Illinois basin coal fired can be considered to be 5.43

lbs/TBtu appears optimistic, compared to alternative sources. Consequently, the conclusion that

87% Hg removal will suffice for compliance – allegedly within the capability of most units with

SCR and FGD – is unfounded.

The proposed IEPA Hg rule requires Hg removal significantly beyond 90%, and offers little

flexibility. To achieve the rule as proposed, actual design targets will probably need to target 93-

95%, when accounting for (a) uncertainty in measurement of mercury in coal and in flue gas, (b)

variability in mercury content of coal, (c) variability in process operations. Further, the

flexibility to allow a “compromise” of mercury removal to 75% for some units requires an

increase in mercury removal to beyond 90% on other units, to attain system compliance.

2.2.

ROLE OF COAL CLEANING AND BASELINE HG CONTENT

The Illinois EPA Technical Support Document (TSD) presents on pages 101-103 an analysis

stating that (a) median Illinois Hg content is 10.24 lbs/TBtu, and (b) conventional coal cleaning

provides an average of 47% Hg removal, lowering the average Hg content of Illinois coal as-

fired to 5.43 lbs/TBtu. The basis for this statement appears to be a presentation by M. Rostam-

Abadi of the Illinois State Geologic Survey (ISGS) to a November, 2005 meeting of the Illinois

Clean Coal Institute (ICCI).

The basis for the 47% Hg reduction appears to be a bar chart on Slide #4, for which supporting

data is not presented.

This value appears high compared to data published recently by Akers

(2006). It is possible that 47% Hg reduction from a limited number of coal samples could have

been witnessed, which may not be representative of coal-fired. Further, the reduction in Hg or

any other constituent by coal cleaning depends on the “energy recovery”, or the amount of coal

discharged with the removed byproducts. This important variable is not defined.

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

8

Akers (2006) reports the removal effectiveness of conventional coal cleaning for arsenic,

chromium, Hg, and selenium for 24 commercial-scale tests. For these eastern bituminous and

Appalachian coals, an average of 37% Hg removal was noted; only four Illinois coals were tested

but the 35% Hg reduction for these samples mirrors that for all coals.

The consequences of the ISGS value of 47% - too high in my opinion – is to underestimate by

several percentage points the Hg reduction to meet the proposed fixed Hg emission rate. Using

the 37% value determined by Akers (2006), and following the logic of the TSD, the average Hg

content of Illinois coal as-fired is estimated to be 6.45 lbs/TBtu (compared to the 5.43 lbs/TBtu

reported in the TSD). This value implies an approximate 89% Hg removal, not 87%, to meet the

presumptive fixed limit of 0.008 lbs/GWh.

As will be shown in subsequent sections, the consideration of Hg variability in coal, and the

uncertainty in measurement and operations, further elevates the targeted Hg design rate to

significantly exceed 90 and approach 95%.

2.4. VARIABILITY AND UNCERTAINTY IN PLANT HG EMISSIONS

Selecting a fixed emission rate as the basis for a standard historically considers not the average

fuel and operating conditions, but reasonable boundaries for each. These conditions should not

be “worst-case”, but approximate challenging combinations of fuel composition and operation

that are likely to be encountered. Regulatory agencies, including the U.S. EPA, have used

statistical concepts to describe these conditions for a number of recent rulemakings.

Specifically, the EPA when utilizing data describing the performance of controls that are

considered BACT will employ not the average performance, but that which can be attained with

a high degree of confidence, such as 90, 95, or 99%. Most recently, in setting fixed limits for

CAMR, EPA statistically accounted for variability in (a) Hg content of coal, (b) inaccuracy of

measuring Hg, and (c) variability in operating a power generating system or environmental

control processes (Wayland, 2005).

Even where a fixed percent Hg removal is required instead of a fixed outlet emissions rate,

variability not only in measurement and also process operations must be accounted for (Cole,

2002).

The methodology used to derive target Hg emission rates in state proceedings does not consider

variability in coal Hg content, measurement, or process operations. State agencies may believe

variability is irrelevant as a 12 month rolling average will eliminate the impact of variations.

Consequently, a 90% Hg removal rate contemplated by many states actually mandates design

targets such as 93-95%. The reasons for this are discussed in this section, and also considered in

more detail in the testimony of Richard McRanie to the Illinois Pollution Control Board (PCB).

---

Testimony of J.E. Cichanowicz:

Mercury Control Technology

9

2.4.1. The Variability in Coal Hg Content

Coals fired in Illinois consist of subbituminous Powder River Basin (PRB) and eastern

bituminous sources. The variability in Hg content has been characterized extensively through

the 1999 ICR program (Part II), and supplemented in the past several years by others who have

studied fuel composition as part of strategic planning for CAMR. It is instructive to examine

coal Hg content in terms of both mean values and the variability.

Figures 2-2 to 2-4 depict coal Hg content for PRB coals obtained from Campbell County,

Wyoming, and the Illinois Basin. These data have been obtained from the 1999 ICR Part II

program. Figure 2-2 presents the cumulative distribution of Hg content, the latter expressed as

lbs/TBtu. Figures 2-3 and 2-4 present the same data expressed in terms of the number of

shipments that contain Hg within a given range.

Figure 2-2. Distribution of Hg in Campbell County PRB, Illinois Basin Coals (lbs/TBtu)

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0

5

10

15

20

25

Hg Content (lbs/Tbtu)

Cumulative Percent of Population Below Target Value

Illinois

Campbel County, WYl

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

10

Figure 2-3. Distribution of Hg by Shipment, Campbell County PRB (lbs/TBtu)

0%

2%

4%

6%

8%

10%

12%

14%

16%

1

4

6

9

11

13

16

18

21

23

26

28

30

33

37

39

43

59

Hg Content (lbs/Tbtu)

Percent of Shipments Within Stated Range

Figure 2-4. Distribution of Hg by Shipment, Illinois Basis coal (lbs/TBtu)

0%

5%

10%

15%

20%

25%

30%

1

3

5

7

9

11

13

15

17

30

Hg Content (lbs/Tbtu)

Percent of Shipments Within Stated Range

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

11

The variability in coal from the Illinois basis has been reported in the TSD to feature a mean

value of 10.54 lbs/TBtu. Data is not presented for the mean and standard deviation of Hg in coal

from PRB sources. Whereas the TSD assigned a washed coal Hg content of 5.43 lbs/TBtu

(considering a 47% credit for coal washing), the Campbell County PRB data shows the median

Hg content to be 7.0 lbs/TBtu.

The analysis on page 102 of the TSD does not consider the mean Hg content of coal presently

fired in Illinois, or the variability in Hg content. Specifically, the analysis concludes an output

rate of 0.008 lbs/GWh is appropriate, assuming coal washing at 47% delivers coal with an

average of 5.43 lbs/TBtu to Illinois power stations. Notably, the presentation by Rostam-Abadi

delivered to the ICCI Mercury Meeting reports the Hg content of Illinois coals that are

“marketed” is 6.6 lbs/TBtu, exceeding the calculated 5.43 lbs/TBtu baseline.

The percentage Hg removal required to meet a given Hg outlet rate depends on the whether the

mean value

or the more statistically meaningful

mean value plus one standard deviation

is used

in calculating the target removal. For example, the PRB coal depicted in Figure 2-3 exhibits a

mean Hg content of 6.06 lbs/MBtu, with the mean value plus one standard deviation equal to

9.65 lbs/TBtu. An output rate of 0.61 lbs/TBtu, while requiring 90% removal from a mean

value, would require 93.7% from the mean plus one standard deviation.

A 12 month rolling average will to some extent reduce the variability of coal Hg content.

However, with long-term coal purchase contracts extending multiple years, and some PRB coals

exhibiting significantly greater Hg than other PRB coals, there is no certainty coal Hg content

will be uniform over this period.

2.4.2. Measurement Uncertainty

The IEPA proposes that long-term Hg measurements be conducted using the monitoring

practices adopted for the CAMR, under EPA 40 CFR Part 75, Subpart I, Hg Mass Emission

Provisions; and also 40 CFR Part 75, Appendix K, Quality Assurance and Operating Procedures

for Sorbent Trap Monitoring Systems. Further, the analysis of coal Hg content is proposed to be

conducted by ASTM D3684-01. The relative accuracy of these measurements must be

considered in targeting Hg removal rates. Although the 12 month averaging period reduces the

importance of week-by-week or even month-by-month variations in the accuracy of

measurements, the role of systematic errors must be accounted for.

The DOE acknowledged the uncertainty in Hg measurements by continuous Hg monitors, and

noted this uncertainty within a recently issued cost report (DOE, 2006):

“The vapor phase mercury measurements taken by CEM have a degree of uncertainty due to the

presence of extremely low mercury concentrations in the flue gas, which makes the quality

assurance and quality control (QA/QC) practices of field contractors extremely important

”.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

12

Hg CEMS (Continuous Emissions Monitoring Systems)

Several studies have addressed the relative accuracy of Hg CEMS instrumentation. The premise

of the RATA analysis is that relative accuracy must be within 20% to be accepted as a valid,

certified measurement. Given the evolutionary nature of Hg CEMS, there is no documented

reason to believe that the sum of all errors - either over-reporting or under-reporting Hg content -

over a 12 month period will equally compensate. Accordingly, based on this concern, and the

testimony of Mr. Richard McRanie regarding the accuracy of Hg CEMS measurements, a

measurement uncertainty of between 10 and 20% will be assumed.

Coal Hg Content

The accuracy of measuring Hg in coal is important for contemplated regulations that specify an

Hg percentage reduction from input values. Errors and bias associated with the measurement of

Hg content in coal – either over or under the actual Hg value – can affect whether the unit will be

compliant with this form of regulation.

The uncertainties in Hg measurement were addressed in an early study by EPRI that was

conducted in concert with the ICR coal measurement program. The results showed that for the

most widely used ASTM D3684 method, employing the oxygen-bomb approach, both a high and

low bias of reported Hg content was witnessed among participating laboratories. Specifically, a

high bias to actual Hg content was noted for low ash coals, while a low bias to actual Hg content

was noted for high ash coals (Goodman, 2006). Another widely used method – EPA 7476 –

exhibited a low bias. Most of the bias was restricted to less than 20%, but 10 and 15% variations

from accepted values were frequently noted.

This uncertainty in measurements of Hg in coal was quantified by correlating the relationship

between Hg in coal and that measured in fly ash (Wilson, 2006). This analysis compared the

results of Hg measurements in coal from two labs which tested six different coal samples. The

comparison of Hg measurements obtained by the two laboratories for the six samples exhibited

variability from +60% to -57%, with an average variability of 13% for all samples. Accordingly,

an operator receiving coal analysis that under-reports the coal Hg content may not be credited

with a 90% Hg reduction. A 12 month rolling average does not necessarily compensate for these

variations. Consequently, Hg control technology design must account for this uncertainty.

Finally, a key quality assurance index of Hg measurement both in coal and flue gas is the closure

of an Hg balance at a power station where both measurements have been conducted. In

evaluating the Hg closure measurements conducted recently for TXU Corporation in

commercial-scale equipment, researchers at the University of North Dakota EERC cited that

“obtaining mercury mass balances of +/-20% is considered excellent” (Laudal, 2004). A

measurement accuracy of +/- 20% will compromise determining if 90% Hg removal is attained,

and a 12 month rolling average will not necessarily compensate for these variations.

Consequently, Hg control technology design must account for this uncertainty by targeting to

perhaps 93 and 95% Hg removal.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

13

2.4.3. Operational Variability

Operational variability addresses the change in the production and removal of Hg due to changes

in boiler operation, flue gas temperature, and sorbent distribution and injection rate.

The fate of Hg present in the coal entering the boiler – to be oxidized, remain in an elemental

state, or react and transform into particulate matter – will depend on the combustion environment

within the boiler, and the nature of deposits on tubes in the convective pass and other heat

exchangers. For activated carbon injection (ACI) into an Electro Static Precipitator (ESP), the

variability in Hg removal will be due to the distribution and mass rate of sorbent injected, and the

amount of carbon accumulated and removed from collecting plate surfaces, due to plate rapping

and entrainment. For ACI into a fabric filter, Hg removal variability will depend on the

distribution of sorbent into the particulate collector, and how the mechanism of filter bag

cleaning influences the exposure of sorbent collected on the bags to flue gas.

Several 30 day tests of ACI into an ESP and a one year-long trial with ACI into a fabric filter all

exhibit variations in Hg outlet. Specifically, data from 30 day trials at Holcomb, Meramac, and

St. Clair suggests that, depending on the unit, Hg removal varied between approximately 85%

and 97+%. The average Hg removal reported for these trials - 91% for St. Clair and 93% for

Holcomb and Meramac – suggest these variations are not of consequence. Perhaps more

significant is the variability in Hg control at Yates 1, where the injection of 4 lbs/MACF of

conventional activated carbon into a small ESP produced total Hg removal of 60-85% - the result

of inherent variations in boiler operation, sorbent injection rate, and inherent Hg removal.

The design target for Hg controls should consider such variability. Similar to addressing

measurement uncertainty, is reasonable to assess a 3-5% design premium upon a performance

target of 90% Hg removal.

2.5. THE IMPACT OF VARIABILITY AND UNCERTAINTY

The significance of the preceding discussion on variability of Hg content, measurement, and

operations is that a rational design strategy will incorporate a design margin.

The collective impact of these variations can significantly impact the target design removal to

achieve a fixed Hg outlet value. For example, consider the required Hg removal efficiency to

meet a proposed limit of 0.008 lbs/GWh, as a function of mean coal Hg content (expressed as

lbs/TBtu). For this coal, the value of one standard deviation is 20% of the mean value. Figure 2-

5 quantifies the impact of Hg content and measurement uncertainty on the required removal rate

to meet an Hg emission rate of 0.008 lbs/GWh. Four scenarios are presented which are defined

as follows:

(a) Scenario A.

Mean value Hg content, no margin for measurement or operations

. The

mandate to meet 0.008 lbs/GWh requires 90% Hg removal when the average Hg content

is 7.3 lbs/TBtu.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

14

(b) Scenario B.

Mean value + one standard deviation Hg content, no margin for

measurement or operations

. The mandate to meet 0.008 lbs/GWH requires 91.6% Hg

removal for the same mean Hg value of 7.3 lbs/TBtu.

(c) Scenario C.

Mean value Hg content, 20% margin “overcontrol”.

An increase in Hg

removal to 92% is required for the 7.3 lbs/TBtu coals, from the 90% value if no margin is

considered.

(d) Scenario D.

Mean value + one standard deviation Hg content, 20% margin

“overcontrol”.

An increase in Hg removal to 93.3% is required for the 7.3 lb/TBtu coal,

compared to 90% if the mean value and no margin are considered.

Consequently, the ability to meet 0.008 lbs/GWh will require a premium beyond a 90%

reduction. Even considering the benefits of a 12 month rolling average, uncertainty in Hg

measurement and operations will likely require targeting for at least 93-95% to insure

compliance with a 90% control requirement.

Figure 2-5. Comparison of Four Design Scenarios on Hg Removal Required for 0.008 lbs/GWh

84.0%

86.0%

88.0%

90.0%

92.0%

94.0%

96.0%

98.0%

02

468

10

12

14

Coal Hg Content As-fired, lbs/TBtu

Percent Hg Reduction to Meet 0.008 lbs/GWh

Baseline: Mean Coal Hg, No Margin

Mean Coal Hg + 1 SD, No Margin

Baseline Coal + 20% Margin

Mean Coal+ 1SD, plus 20% Margin

Figure 2-6 presents an alternative graphic describing how design targets for coal Hg content and

operating variability influence the required Hg removal. As an example, the Hg content and

variability for Cordero Rojo PRB coal is employed. Figure 2-6 depicts Hg removal required, as

a function of coal Hg content (ppm basis), to meet an Hg emission target of 0.008 lbs/GWh.

Also shown is the Hg removal required to meet an Hg emission target of 0.0064 lbs/GWh, the

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

15

latter representing a 20% margin that may be required for compliance. The Hg content is noted

for Cordero Rojo PRB coal, for both the mean value and the mean + one standard deviation.

Figure 2-6 shows for the mean Cordero Rojo value of 0.065 ppm, Hg removal of 87% and 90%

is required to provide an outlet Hg rate of 0.008 and 0.0064 lbs/GWH, respectively. However,

for the coal Hg content defined by mean plus one standard deviation, an increase in Hg removal

to 90% and 94% is required to meet the same respective values.

Figures 2-5 and 2-6 demonstrate how basing a regulation on mean Hg content, without

considering design or operating margins, implies a lower Hg removal rate than may be required.

In particular, Figure 2-6 shows how mean Hg values and eliminating margin suggests 88% Hg

removal adequate, while accounting for one standard deviation and a 20% design margin implies

93% Hg removal is required. This difference is considered significant.

Figure 2-6. Role of Coal Variability, Measurement Uncertainty on Design Target for 0.008

lbs/GWh

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0.0000 0.0100 0.0200 0.0300 0.0400 0.0500 0.0600 0.0700 0.0800 0.0900 0.1000 0.1100 0.1200

Coal Content of Hg, ppm

Hg Removal Required, %

Cordero

Rojo: Mean

Value

Cordero Rojo:

Mean + 1

Standard Dev

Hg% Removal

To Meet 0.008

lbs/GWh

Hg% Removal

To Meet 0.0064

lbs/GWh

94 vs 88%

Hg Removal

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

16

2.6. SYSTEM AVERAGING

A provision of the IEPA proposal is the ability for an owner to elect an Hg control target to as

low as 75%, provided the generating system of units can still deliver 90% Hg overall from a base

cap. In reality, given the unproven nature of Hg controls and the challenge of meeting even the

90% Hg removal target, this provision adds little flexibility as there is little or no margin by

which to “overcontrol” and compensate for an under-performing unit.

The discussion in Section 2.3 noted that 30 day trials at Holcomb, Meramac, and St. Clair

showed Hg instantaneous, hourly-based Hg removals as high as 95 and 97% were measured

(including the small but important inherent Hg removed); but these are required to offset periods

of operation where Hg removal is 85%. The ability to record Hg removal at 95+% for short

periods of time is required to attempt to maintain 90%, and simply not be available to

compensate for performance shortfalls.

A simple example demonstrates the challenge. Consider as an example a system consisting of

two units, equal in all features - generating capacity, heat rate, and coal Hg content – but one unit

cannot achieve the targeted Hg removal of 90%. Even if technically possible – one unit

operating at 95% Hg removal could only offset an Hg removal compromise to 85%; lower Hg

removal cannot be offset by this equivalent one unit. Rather, multiple units or a significantly

larger unit would be required to provide the offset for a malperforming unit at 75%.

Specifically, and for identical operating conditions, a 600 MW unit operating at 95% Hg removal

would be required to offset the emissions from a 200 Mw unit that was limited to 75% Hg

removal.

Given the challenge to maintain even 90% Hg removal over a 12 month basis due to variations in

coal content, measurement uncertainty, and operations, the provision to allow units within a

system to compensate for compromised Hg removal is of little value. Most Illinois units will

need to design for 93-95% to meet a 12 month rolling average of 90%.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

17

EVOLUTION AND COST OF ENVIRONMENTAL CONTROL TECHNOLOGY

3.1.

INTRODUCTION

The evolution of environmental controls for coal-fired power plants has historically required an

extended period for process development, testing, and full-scale commercialization. The

distinguishing feature of capital-intensive process equipment is that product lifetime is measured

in decades, and not months or years as with consumer products. Further, the penalties for

malperformance or failure of an environmental control system are not limited to a shortfall in

environmental control capability or higher operating cost, but actually challenge the reliability of

the plant. Given the limitations of suppliers’ guarantees, a development schedule that

systematically addresses the uncertainties in performance and reliability is prudent. This section

will show by historical example the importance of providing adequate time for technology

evolution.

It is important to convey the magnitude of the penalty Owners will incur due to process failure or

malperformance. The consequence is not simply a matter of implementing minor equipment

modifications, or increasing reagent injection to meet Hg removal targets, or to construct an

averaging plan with other units in the system. Such issues, although problematic, should not

prevent early deployment. Rather, premature technology application can force maintenance

outages or load limits, which translate into significant cost penalties, or encourage widespread

application of a technology before optimization is complete.

There is much history to invoke in demonstrating the challenges of commercializing

environmental controls. The experience with wet flue gas desulfurization, selective catalytic

reduction (SCR) NOx control, and hot-side electrostatic precipitators for particulate removal is

reviewed as examples.

3.2. WET FLUE GAS DESULFURIZATION

3.2.1. Technology Evolution

Control options for wet FGD have evolved to where at present SO2 removal of 95% is

considered state-of-art, and for many coals 98% removal is attainable.

As summarized by Dalton (1985) and Boward (2003), early FGD applications were

characterized by SO2 removal shortfalls, but most significantly reliability problems. The latter

were due to excursions in process chemistry that promoted deposition and scaling, that limited

load or forced early outages. Specifically, Boward (2003) states that:

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

18

”These first systems were often prototypes. A plethora of problems resulted from the application

of this technology to the larger sizes and constraints of utility systems. To a certain extent, many

of these systems were pre-commercial in nature, since technology was often commercially

implemented before being demonstrated at sufficient scale”.

Consequently, both SO2 removal targets and more importantly reliability were often

compromised. Early surveys of FGD equipment operation showed the reliability of first-

generation FGD equipment was poor due to a lack of understanding of basic process chemistry,

which in turn, promoted scaling and deposition within absorber vessels and reaction tanks.

Specifically, Laeske (1983) reported that in 1978, FGD reliability for FGD process equipment

was 53%, 69%, and 94% respectively for high, medium, and low sulfur coals. Figure 3-1

presents, for the first decade of FGD evolution, the annual capacity of FGD addition and the

cumulative design SO2 removal efficiency. It was not until almost 10,000 MW of generating

capacity had been equipped with FGD that the first installation of the design commonplace today

– the lime or limestone–based open spray tower – was installed. The equipment used in most of

these first-generation installations has since either been modified or replaced, or represents a

design concept no longer favored.

Figure 3-1. The First Decade of Flue Gas Desulfurization (FGD) Evolution

0

1000

2000

3000

4000

5000

6000

7000

1968

1970

1972

1974

1976

1978

1980

1982

Year Of FGD Installation

Generating Capacity Installed Per Year, MW

0

10

20

30

40

50

60

70

80

90

100

Cumulative FGD Design SO2 Removal, %

FGD Capacity

DesignSO2

Removal

Lowman Unit 2: 1st

Predecessor of

Present-day FGD

20 Years to Reliabiliy Provide

90-95% SO2 Removal

1982 Reliability

Survey:

High S: 53%

Med S: 69%

Low S: 94%

As noted by Boward (2003), it was not until the 1980s and the genesis of “forced oxidation”

FGD designs that meaningful improvements in FGD reliability were achieved. Given that the

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

19

first lime and limestone-based equipment was commercially sold in the early-mid 1970s, and that

several units were converted to or adopted forced oxidation in 1985, it took approximately 10

years of evolution and development with lime or limestone-based FGD to achieve a reliable

design.

Thirty years later, after over 100,000 MW of experience world-wide, the following FGD

attributes are state-of-art: 93% to 98% SO2 removal; the use of a single absorber tower; the

production of high quality gypsum byproduct for sale or management as landfill; and relatively

low power demand. This observation suggests that adequate experience is required to deliver

reliable, high performance environmental control technology.

3.2.2. Cost Evolution

Low and unacceptable reliability – particularly for FGD equipment designed for medium and

high sulfur coals – was partially responsible for the initial high capital cost of FGD equipment.

Specifically, Boward (2003) describes the decrease in conventional FGD capital cost from

$400/kW in the 1970s to $200/kW in the early 1990s, and notes that both improvements in

process chemistry and eliminating spare absorbers modules (through the provisions of the 1990

Clean Air act Amendments) as key contributing factors. Significantly, the large FGD cost

decrease was due to both structural changes in the regulations that allowed for emissions

allowance exchange, and resulting simplification of design, as well as 20 years to solve process

chemistry problems.

At present, FGD costs have escalated due to higher performance demands, retrofit to more

difficult units, and the general escalation in construction materials and trade labor (experienced

by all major construction projects). On almost a weekly basis, generators announce plans for

advanced FGD processes that exceed $300/kW. The most recent – issued on July 20, 2006 by

Allegheny Energy – cites the 1,710 MW Hatfield’s Ferry station will retrofit a 95% SO2 capital

FGD system, for approximately $320/kW.

3.3. SELECTIVE CATALYTIC REDUCTION (SCR) NOx CONTROL

3.3.1. Technology Evolution

The evolution of SCR NOx control spans three decades, with much of the important experience

generated in Europe and Japan prior to application to U.S. coal-fired power plants.

Figure 3-2 presents a timeline of SCR technology evolution (Cichanowicz, 2001). As shown in

Figure 3-2, and as detailed in the referenced paper, the first commercial SCR installations

occurred in Japan in the early-mid 1980s, on coals with sulfur content generally less than 0.70%,

and thus well below those fired in Europe and the U.S. These early applications required only

modest (50-80%) NOx reduction.

Based on about 3,000 MW of coal-fired experience in Japan that were operating by 1982, the

then Federal Republic of Germany instituted strict NOx regulations that required retrofit of SCR

to approximately 5,000 MW of capacity in the time frame of 1987 to 1989. One of these units

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

20

(Franken) was reportedly the first commercial unit to consistently achieve 90% NOx reduction.

Prior to these first commercial German applications, at least 25 pilot plant tests were initiated in

1984 and run for approximately one year. The experience with SCR technology in Japan did not

identify two key problems witnessed in early German applications: poisoning of catalyst, and

contamination of ash with excess ammonia. Regarding catalyst poisoning, pilot plant tests

identified the rapid deactivation of SCR catalyst by arsenic, a phenomena not recognized by the

Japanese experience. Results from these pilot plants and the early commercial units in Germany

that encountered early catalyst deactivation lead to the first generation of arsenic–tolerant

catalysts.

Figure 3-2. Timeline of SCR Key Events

Further, experience in Japan that 5 ppm of residual NH3 in flue gas would be acceptable proved

to be false with German and European coals. Due to differences in ash composition, the 5 ppm

rule-of-thumb residual NH3 limit that was successful in Japan was revised to 2 ppm, to avoid ash

contamination and loss of fly ash sales.

Several of the first coal-fired SCR applications in the U.S. encountered problems after one year

of operation. Most significantly, the SCR process at the Logan Generating Station experienced

limited NOx removal and excess residual NH3. Accelerated poisoning of catalyst was witnessed

at the Orlando Utilities Commission (OUC) Stanton Unit 3, and ultimately related to

shortcomings in the fuel purchase specification. The first retrofit of SCR to an existing coal-

fired boiler in the U.S. – at the PSNH Merrimack Station – encountered air heater plugging

1975

1980

1985

1990

1995

2000

20-30 pilot plants on oil,

gas, and refinery gas

EPDC Takara Unit 1:

250 MW demo (80%,

low dust)

Arsenic

“episode”

witnessed in

pilot plants

1

st

U.S. gas-fired

unit: LADWP

Haynes

1

st

evidence of As

poisoning in the U.S.

(OUC/Stanton Unit 2)

Chugoku Electric:

Shimoneski (175

MW, 50%)

Hokkaido Electric:

Tomato-Atsuma

(1/4 x 250 MW)

FRG passes

Government

Ordinance for

Large Boiler

Installations –

100 ppm

First German unit:

Neckarwerke

Altbach/Deizisau

Unit 5 (420 MW)

1

st

New U.S. Coal

Unit: Carneys Point

1

st

Retrofit U.S. Coal

Unit: Merrimack

New Madrid,

Paradise

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

21

problems from excess residual NH3. The Merrimack elevated NH3 problem was not due to

catalyst deactivation but to flue gas ductwork design. None of these problems were fatal flaws,

and all proved amenable to remedial actions. This experience demonstrates that even with 15

years of operating experience in Japan and Europe, the initial, broad deployment of SCR to the

U.S. encountered problems.

By some accounts, the most significant problem with SCR was not encountered until 2001, when

a high sulfur coal-fired unit generated excess SO3 emissions which increased stack plume

opacity. For many applications, controlling plume opacity appears manageable but the cost is

not negligible. A recent evaluation of reagent-based SO3 mitigation strategies shows the annual

operating cost can approach that for reagent supply (Dombrowski, 2004). Accordingly, SO3

mitigation represents an additional operating cost not quantified or acknowledged by the SCR

process developers.

A second unforeseen problem with U.S. SCR installations has been blockage of the catalyst

openings with large particle ash (LPA). Georgia Power’s first SCR, at Plant Bowen Unit 1, was

only able to operate for 69 days before the catalyst was completed plugged with LPA. These ash

particles are 5-7 mm diameter agglomerates of low density that can be swept past the economizer

hoppers and into the SCR reactors. LPA was noted only occasionally in German experience,

considered an anomaly, and thus completely unforeseen as an issue in the U.S. Although no

formal survey of LPA-related issues has been conduced, it is believed that 1 in every 4 or 5 units

incurs some degree of LPA plugging that compromises SCR performance.

To summarize, broad Japanese and German experience with SCR did not prevent several notable

problems in U.S. applications that, if not fatal to operation, compromised reliability and

increased cost compared to developer’s projections.

3.3.2. Cost Evolution

Perhaps more relevant to Hg control cost is the case of SCR NOx control in terms of capital cost

and balance-of-plant impacts.

The U.S. EPA and equipment suppliers significantly underestimated the capital cost of SCR.

Early cost studies by EPA projected SCR capital cost to be approximately $60/kW for a 400 MW

unit, decreasing to less than $40/kW for units of 600 MW and greater (EPA, 1995). Three SCR

cost surveys conducted since 2003 show SCR capital exceeds EPA’s projections by a factor of 2

to 3. A trend in which SCR capital cost increased for the first several commercial units installed

since the mid-late 1990s was noted (Cichanowicz, 2004). The reasons for escalation in cost from

the early applications are unclear, but likely because the first SCR equipment was installed on

units atypical of the fleet ultimately retrofit. Specifically, the early SCR installations may have

required less complex process equipment, and imposed less site interference and thus installation

cost. In contrast to these mid-1990s estimates by EPA and the Institute of Clean Air Companies

(ICAC), the average of all units in the cited 2004 survey is $120/kW, with the units installed in

2004 approximating $140/kW. SCR costs of this magnitude were reaffirmed by other surveys

(Hoskins, 2003, and Marano, 2006), with the most recent also confirming a spike in capital costs

after 2003.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

22

Despite the overwhelming evidence of high SCR cost in these recent surveys, the U.S. EPA as

recently as 2004 was still utilizing SCR capital cost estimates of $80/kW in projecting the cost to

comply with the CAIR (EPA, 2006a, and Khan, 2004).

Significantly, early SCR cost estimates did not account for balance-of-plant impacts that were

only recognized after full-scale application. Specifically, the production of SO3 as a byproduct

of SCR was ignored by process suppliers until full-scale evidence from an SO3-induced plume at

AEP’s Gavin station validated concerns. This issue – widely recognized as problematic for

medium-high sulfur coal-fired units – has required reagent injection on 15 plants to date, a

number which is anticipated to increase. Based on estimates of reagent injection costs

developed by EPRI (Dombrowski, 2004), the annual operating cost can approach $0.5-1 M per

year, rivaling that for ammonia reagent.

It should be noted the expansion in SCR installations to a projected 120,000 MW of capacity by

2010 has created a market for catalyst that has significantly reduced catalyst unit price. Catalyst

unit price has decreased from over $15,000/m

3

in 1979 to below $4,000/m

3

in 2006, due to

competition between numerous suppliers world-wide, and the advent of catalyst regeneration.

This price decrease, which required at least 15 years to evolve, has been more than offset by

other factors.

3.4. HOT-SIDE ELECTROSTATIC PRECIPITATORS

Perhaps the most relevant example of the consequences of accelerating evolving technology is

the case of the hot-side electrostatic precipitator (ESP). In the mid-1970s, the particulate matter

(PM) removal efficiency of state-of-art ESPs stagnated, due to limits on the ability to deliver

adequate power for particle charging caused by the electrical resistivity of the collected ash. The

use of low sulfur western coals exacerbated this problem, as the ash residing on the collecting

plate presented a high electrical resistivity that limited delivered power and ESP performance.

Subsequently, it was theorized that relocating the ESP from the “cold-side” of the air heater

(processing flue gas at temperatures of 300-400 F) to the “hot-side” of the air heater (processing

flue gas at 600-700F) would significantly reduce the electrical resistance imposed by the

collected fly ash layer. Several pilot plants evaluations were completed and results with first-

generation designs suggested this approach would be successful.

The early experience prompted application of hot-side ESPs on several new units, which after

about one year operation incurred operating problems. Most significantly, Gulf Power’s Lansing

Smith station incurred persistent PM removal problems, incurring relatively high opacity beyond

predicted levels. Subsequent diagnostic tests determined that the micro-layer of fly ash directly

adjacent to the collecting plate was characterized by depleted sodium; an element necessary to

provide electrical mobility, and control resistivity.

These diagnostic tests – and further follow-up with pilot plant studies – showed that the use of

conditioning agents to deliver sodium into the ESP could restore performance. Even under these

conditions PM removal was not ideal and many owners elected to convert hot-side units to the

traditional cold-side approach. Interestingly, a key unit in the chronology of demonstration

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

23

testing for activated carbon injection (ACI) – the WE Energies Pleasant Prairie Station – was

initially designed to utilize a hot-side ESP. The performance limitations of this design were

recognized prior to construction, prompting the owner to change the ductwork enabling the same

ESP to operate as a cold-side unit. The initial decision for Pleasant Prairie to utilize a hot-side

ESP resonates today in terms of prompting the large SCA, and ability to accommodate ACI.

Approximately five years of diagnostic tests at commercial scale were required to resolve the

hot-side ESP issues. Incurring such a problem today would require less time - the electrical

properties of the ESP are monitored better, and numerous pilot plants are available for diagnostic

work. However, 2-3 years of additional testing and development of commercial equipment

would likely be required.

3.5 SUMMARY

This section has related the significant time and experience required to commercially prove the

feasibility of an evolving environmental control technology, particularly where a chemical

process is required to achieve 90% removal of a given chemical species.

•

For conventional wet flue gas desulfurization, 7-10 years of experience and development

was required for process equipment to deliver SO2 removal to near 80%, although

reliability for medium and high sulfur applications was limited to 54 and 69%,

respectively. The cost for FGD has decreased significantly since the first years of

deployment, but required several decades and a change in the form of the regulation to

allow compliance on a system and not a unit-specific basis.

•

For SCR NOx reduction, approximately 5-10 years of development and experience was

required to generalize the technology for German power plants; however this experience

did not avoid problems of excess residual NH3 and arsenic-induced poisoning. The cost

of SCR has significantly exceeded early projections by EPA and the supplier community.

•

Hot-side ESPs never received broad commercialization, and this concept has for the most

part been abandoned as a candidate for new units. Existing hot-side ESPs operate usually

with some type of additive for sodium replenishment, or use higher sodium coals. The

WE Pleasant Prairie station – initially conceived as a hot-side ESP but adopted to cold-

side before construction – is a testament to the challenges of accelerated

commercialization.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

24

INHERENT MERCURY REMOVAL FROM ENVIRONMENTAL CONTROLS

4.1. INTRODUCTION

Existing environmental control technologies for coal-fired power stations will remove Hg from

flue gas, in amounts that vary widely, depending on equipment configuration and coal

composition. As first demonstrated by the ICR, Part III data (EPRI, 2000) and numerous site-

specific Hg control demonstrations, inherent Hg capture by existing environmental controls can

range from essentially zero to nearly 90%. Specifically, negligible Hg removal is noted for PRB

and lignite coal-fired units, while Hg removal of nearly 90% and possibly beyond for some

eastern bituminous coal-fired units is measured with SCR and wet FGD. Up to 95% Hg removal

is noted for similar coal units equipped with dry FGD and a fabric filter.

Significantly, equipment installed in response to CAIR-required reductions in SO2 and NOx will

provide a platform for effective and reliable Hg control. As will be described in this section,

these expenditures will provide the essential ingredients for any environmental control process:

good mixing of reagent or sorbent with dilute flue gas constituents; adequate residence time for

contacting and reaction; and control of process conditions (temperature, gas composition, etc.) to

prompt reactions. These very same process conditions will maximize Hg removal. More

important than cost is reliability – the strategies and equipment retrofit for CAIR will provide a

basis for Hg control.

The most probable equipment configurations to be installed consist of either (a) dry FGD and a

fabric filter for SO2/PM control, (b) a wet FGD for SO2 control, preceded by the existing ESP or

fabric filter for PM control, and (c) SCR for NOx control, in combination with either option (a)

or (b). These configurations do not exhaust the list of options as other technologies are

available: selective non-catalytic reduction (SNCR) for NOx; combustion controls for NOx that

can assist Hg removal through increasing ash carbon content; and other multi-pollutant controls.

However, given the timeframe specified by CAIR and degree of SO2 and NOx control required,

most owners are anticipated to deploy options (a), (b), or (c) above.

Prior to addressing the CAIR compliance options, Hg removed as particulate within an ESP or

fabric filter will be addressed.

4.2. HG REMOVED AS PARTICULATE (VIA ESP OR FABRIC FILTER)

The removal of particulate-bound Hg is a starting point for determining inherent Hg reductions at

existing coal-fired plants. Particulate Hg can be captured by either an ESP or a fabric filter, or

other process control equipment. Further, Hg that is not in particulate form can be subsequently

captured by the carbon retained in fly ash, depending on the carbon content and its physical

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

25

features. Test results from field demonstrations in recent years have shown that many factors –

in particular competition between Hg and SO

3

for access to absorption sites – affect the amount

of Hg removed by carbon.

4.2.1. Hg Removal Correlation: ESPs

In their 2000 analysis of the ICR data, EPRI attempted to capture the relationship between Hg

removal, equipment configuration, and coal composition (EPRI, 2000). EPRI developed a

correlation describing Hg removal across process equipment, such as a cold-side ESPs, as a

function of coal chloride content. Specifically, for the case of calculating inherent Hg removal

from a cold-side ESP, EPRI proposed the correlation:

Hg Removal = 0.1233*[ln (coal Cl content, as ppm)] + [-0.3885]

EPRI further noted that the measured Hg removal could range from zero to 55% for the units

tested. This correlation also recognizes the role of coal chloride content on inherent Hg removal,

not only for ESPs, but for a variety of process equipment.

4.2.2. Role of ESP Size

The ESP design characteristic known as specific collecting area (SCA) – defined as the

collecting plate surface area normalized by the gas flow rate – is fundamental to ESP

performance. A higher SCA implies more surface area available for collection of charged ash

particles, and depending on the equipment layout, greater residence time for Hg absorption.

Figure 4-1 presents the cumulative distribution of SCA values for the national ESP population,

including the host demonstration sites for most sorbent injection demonstrations. It is possible

that high SCA enables high Hg removal within the ESP – both inherent and induced by activated

carbon injection - simply due to the residence time and exposure of carbon in the ash to flue gas

Hg. Data from commercial-scale tests that suggests Hg removal is influenced by SCA, which

may be consistent with fundamental analysis that suggests mass transfer between particles and

flue gas is favorably affected by large SCA (Clack, 2006).

A further contributing factor to variable inherent Hg control within an ESP is boiler operation.

The key factors may relate to (a) operating load, (b) flue gas flow rate, (c) temperature of the

ESP, (d) combustion conditions, and (e) the physical characteristics of carbon produced and

retained in the fly ash. Each of these factors can influence inherent Hg removal, and to be

discussed subsequently, the performance of ACI.

In summary, the inherent Hg removal within an ESP is highly variable, depends on fly ash

carbon content, coal composition including chlorides, and possibly the physical size (e.g. SCA

value) of the ESP, as well as boiler operation.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

26

Figure 4-1. Distribution of SCA Value: National ESP Population

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0

200

400

600

800

1000

1200

Specifc Collection Area, SCA (ft2/1000acfm)

Frequency Distribution

4.3. DRY FLUE GAS DESULFURIZATION (FGD) AND FABRIC FILTER

The use of lime-based dry FGD coupled with a fabric filter is anticipated to provide a common

compliance tool for CAIR, particularly for owners that anticipate continued use of PRB coal.

This FGD process is referred to as “dry” in that water injected with the lime reagent into flue gas

at nominally 300-350 F is completely evaporated, lowering flue gas temperature, but not to the

moisture saturation temperature where water will condense. A second particulate control device,

specifically a fabric filter, is required to collect the dry products of sulfation. Specifically,

predominantly CaSO4 is produced from SO2 and the Ca introduced as lime – which generates

particles that must be captured.

Historically, a dry FGD followed by a fabric filter has been used on coals with less than 2%

sulfur content. One factor limiting sulfur content is a restriction on the quantity of water that can

be injected without reducing the flue gas temperature to near moisture saturation, where water

would condense. Despite development programs using 5-10 MW pilot scale facilities in the mid-

1980s to generalize dry FGD to higher sulfur coal, most applications today are with 2% sulfur or

less coals.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

27

The ability to leverage the investment for dry FGD with Hg removal is inviting, given that a

considerable component of the cost is the large reaction vessel that could improve dispersing

reagent within flue gas. Specifically, the dry FGD vessel (also referred to as a spray dryer) will

offer 6-8 seconds of residence time for gas contacting, with mixing of lime promoted by the use

of a high speed atomization head spinning at 100,000 rpm. Consequently, the combination of

residence time and turbulence within the vessel promotes contacting of sorbent with flue gas.

The well-mixed sorbent ultimately is collected on the fabric filter, where it accumulates and is

exposed top flue gas. The extended contact time between sorbent accumulated on the filter and

flue gas Hg provides potential to remove significant Hg. A key advantage of coupling Hg

removal with dry FGD is the relatively low operating temperature of the fabric filter, a result of

injecting water through the high speed atomizers.

The disadvantage of the dry FGD process is that the alkaline environment necessary to react with

SO2 also removes chlorides and other halogen species that promote Hg oxidation. As a

consequence, early ICR data and subsequent testing funded by the DOE-NETL showed that

PRB-fired units equipped with dry FGD derived only 25% Hg removal (Sjostrom, 2006a, Slide

#3). The low inherent Hg removal of 25-30% was corroborated through baseline testing at

Sunflower Electric’s Holcomb Station (Sjostrom, 2006a, Slide #9). As will be discussed in

Section 4, the halogens critical to high Hg removal can be introduced with sorbent injected for

Hg removal. Consequently, the dry FGD with fabric filter presents a reliable platform from

which additional Hg removal can be obtained.

It is possible that PRB and eastern bituminous coal could be blended to establish higher sulfur,

higher chloride content coal that may improve Hg removal. There has been success with

blending PRB with 15% western bituminous coal where Hg capture increased from near 0 to

near 80% (Sjostrom, 2006a, Slide 20). However, at Basin Electric’s Laramie River station –

employing an ESP for the second particulate collector in lieu of a fabric filter – coal blending did

not provide encouraging Hg removal. Specifically, blending from 16 to 20% western bituminous

coal with PRB elevated Hg removal from 0 to 10% (Sjostrom, 2006a, Slide 21). Accordingly,

the blending of higher chloride coal to improve Hg removal is an interesting but uncertain option

with regard to Hg removal.

4.4. WET FLUE GAS DESULFURIZATION (FGD)

The use of wet FGD following particulate matter removal by either a fabric filter or ESP will

also remove Hg, by amounts that vary depending on coal composition and FGD chemistry. It is

generally believed that oxidized Hg, which is water soluble, will be removed in a wet FGD

process, with the actual fraction of Hg removed depending on process chemistry (Blythe, 2004).

Specifically, it is believed within the FGD “slurry”, oxidizing conditions and prevalence of

sulfate over sulfite promote the capture and retention of Hg. Accordingly, any action that

promotes the oxidation of elemental Hg - such as forced oxidation or the use of SCR NOx

control - appears to increase Hg removal. The Hg removal potential for FGD will be described

both with and without SCR.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

28

Hg Removal Wet FGD without SCR

Figure 4-2 (extracted from Chu, 2006) compares FGD Hg removal for units equipped with both

SCR and FGD. The measured Hg removal attributable to only wet FGD (e.g. data without SCR)

for the nine sites ranged between 45 and 70%. The physical and chemical mechanism by which

Hg is removed – and does not either evade capture or is captured but re-emitted – is presently the

subject of research (Blythe, 2005).

FGD with SCR

Figure 4-2 data describing Hg removal with both SCR and FGD shows that for six systems Hg

removal ranged from 72% to more than 92%. These data are based on short-term tests without

long-term confirmation of reproducibility or longevity. Three of the power plant systems

exhibited short-term test results equal to or exceeding 90% Hg removal.

Both Chu (2006) and Senior (2006) have published an insightful depiction of the role of SCR on

Hg oxidation. Figure 4-3, also extracted from Chu (2006), depicts the amount of oxidized Hg

that leaves the SCR reactor as a function of coal chloride content. The amount of Hg oxidized –

determinate to the Hg removed - is highly variable, and while generally related to coal chloride,

exhibits significant variability for coals with similar chloride value.

The data in both Figures 4-2 and 4-3 suggests 90% Hg removal may be a reasonable target, but

at present cannot be presumed for wet FGD, even with SCR. Figures 4-2 and 4-3 suggest that

90% Hg removal is the exception and not an expected outcome.

Finally, the question of the fate of Hg removed by FGD must be addressed to insure that

byproducts incorporating power plant-derived gypsum, such as wallboard, do not release

significant captured Hg. Several studies are in progress, involving a major wallboard supplier

(U.S. Gypsum). Initial results from this analysis have been posted on the DOE-NETL web site.

Pending confirmation that Hg removed in the FGD and reporting to gypsum is not problematic, a

wet FGD process appears to offer a robust and reliable platform to remove Hg.

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

29

Figure 4-2. The Role of SCR on Removal of Hg by FGD (after Chu, 2006)

Figure 4-3. The Role of SCR on Removal of Hg by FGD (after Chu, 2006)

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Testimony of J.E. Cichanowicz:

Mercury Control Technology

30

MERCURY SPECIFIC CONTROL TECHNOLOGIES

5.1. INTRODUCTION

A large number of Hg control concepts have been identified and evaluated at scales ranging from

laboratory test apparatus to commercial-scale equipment. The objective of this section is not to

provide a thorough review of these options – Feely (2005b) and Srivastava (2006) have provided

such a review. Rather, this section will highlight key near-term concepts and emphasize the