BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
R06-25
PROPOSED NEW 35 ILL. ADM. CODE 225
)
(Rulemaking – Air)
CONTROL OF EMISSIONS FROM
)
LARGE COMBUSTION SOURCES (MERCURY)
)
NOTICE OF FILING
TO:
Dorothy Gunn
Gina Roccaforte, Assistant Counsel
Clerk
Charles E. Matoesian, Assistant Counsel
Illinois Pollution Control Board
John J. Kim, Managing Attorney
James R. Thompson Center
Air Regulatory Unit,
100 W. Randolph St. , Suite 11-500
Division of Legal Counsel
Chicago, Illinois 60601-3218
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
Marie E. Tipsord
P.O. Box 19726
Hearing Officer
Springfield, Illinois 62794-9276
Illinois Pollution Control Board
john.kim@epa.state.il.us
James R. Thompson Center
charles.matoesian@epa.state.il.us
100 W. Randolph, 100 W. Randolph
gina.roccaforte@epa.state.il.us
Chicago, Illinois 60601-3218
tipsorm@ipcb.state.il.us
SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that I have today filed electronically with the Clerk of
the Illinois Pollution Control Board
PRAIRIE STATE GENERATING COMPANY,
LLC’s PREFILED QUESTIONS,
copies of which are herewith served upon you.
By: _[s] Mary Frontczak___________________
Mary Frontczak (Reg. No. 6209264)
DATED: July 28, 2006
Mary Frontczak
Peabody Energy
701 Market Street
St. Louis, Missouri 63101-1826
(314) 342-7810
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
R06-25
PROPOSED NEW 35 ILL. ADM. CODE 225
)
(Rulemaking – Air)
CONTROL OF EMISSIONS FROM
)
LARGE COMBUSTION SOURCES (MERCURY)
)
PRAIRIE STATE GENERATING COMPANY, LLC’s
PREFILED QUESTIONS
Prairie State Generating Company, LLC has the following questions for the
witnesses identified below relating to their prefiled testimony in the above captioned
matter.
Anne Smith
:
1.
Could you please explain what Figure 4 of your testimony shows?
2.
Is it fair to conclude from Figure 4 that Ameren would be expected to expend far
more annually under the Illinois proposed rule without the multi-pollutant control
strategy (“MCS”) than it would had Illinois adopted the model CAMR? Is it fair to
conclude that those annual expenditures could range from almost 10 times as much in
2009 to still over 2 times as much in 2021?
3.
Over the entire time period of Figure 4, what is the cumulative difference in
present value costs between compliance with CAIR/CAMR versus the Illinois rule
without MCS? Would you expect that these cost differences would be similar for other
utilities in Illinois?
Peter M. Chapman
:
1.
Do you expect that a 90% reduction in mercury emissions from Illinois power
plants will result in a similar reduction in methylmercury concentrations in fish in
Illinois? If not, why not?
2.
Do you believe there is a linear relationship between mercury reductions in power
plant emissions and mercury reductions in fish tissue?
3.
Do you believe that a 90% reduction in mercury emissions from coal-fired power
plants in Illinois will cause the water restrictions on mercury to be lifted in Illinois? If
not, why not.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
Gail Charley:
1.
In your testimony you state that the TSD does not critically analyze the health
data on methylmercury. Could you explain why you hold this opinion?
2.
If Illinois EPA had critically analyzed the methylmercury health effects data how
would it have changed their analysis?
3.
In the last sentence of your testimony you conclude: “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 U.S. EPA are political only.”
a.
Why do you believe that the public health benefits are being oversold?
b.
Had IEPA conducted a scientifically balanced analysis what would it have
shown?
c.
Is it fair to say that you believe that there is little or no public health
benefit from reducing mercury emissions from coal-fired power plants either
faster or more deeply than EPA has required under CAMR? If so, why?
J. E. Chicanowicz:
1.
In your testimony you indicate that to meet a 90% emission limit a plant would
need to be designed to achieve at least 93 to 95% control.
a.
Could you explain why this is the case?
b.
Is mercury control different in nature than controlling SO
2
or NO
x
? If so,
how?
c.
Has the past testing of activated carbon injection shown that 93 to 95% of
mercury can be achieved over the long term?
2.
Could you describe the balance-of-plant issues that could arise from the addition
of activated carbon to a coal-fired power plant?
a.
Are these the same balance-of-plant issues that could arise from the use of
halogenated carbons?
b.
Have some balance-of-plant issues already arisen at the full-scale use of
activated carbon at the Presque Isle station?
3.
For medium and high sulfur coals, has 90% removal of mercury been
demonstrated?
a.
Are there special control problems presented by these coals?
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
b.
Do high SO
3
levels limit the effectiveness of halogenated activated carbon
in controlling mercury emissions?
4.
In your testimony you suggest that the available supply of bromine could affect
the future costs of compliance with stringent mercury limits.
a.
Could you explain this concern?
b.
Have you attempted to quantify how much bromine would be used
annually to produce the activated carbon needed for mercury removal from coal-
fired power plants?
William DePriest
:
1.
What are the technical problems of reducing mercury emissions from high sulfur
coals?
2.
Has it been demonstrated that 90% mercury control of high sulfur coals can be
achieved over the long-term? If not, what level of control do you believe is possible?
Richard D. McRanie
:
1.
Are data substitution provisions needed or useful for command-and-control
regulations like those proposed by Illinois or is data substitution needed primarily for a
trading program where every ounce of mercury must be tracked? If data substitution is
not as important, what would you suggest be done with “bad” monitoring results?
2.
In your view, should the Illinois TSD have addressed monitoring issues? Why?
How significant is Illinois’ omission?
3.
Has EPA ever conducted CEM monitoring at a plant with mercury emissions as
low as those proposed by IEPA? If so, what were the results of that testing?
4.
If as your testimony suggests that the error band (tolerance) of mercury CEMs is
plus or minus 1.0 micrograms per cubic meter, isn’t it true that a plant with zero actual
mercury emissions could still produce a mercury monitoring result that showed it was out
of compliance with Illinois’ proposed standard of 0.8 micrograms/cubic meter?
a.
Isn’t this a measurement that is below the detection limit of the method?
b.
Are you aware of any case where a regulatory agency has imposed a
regulatory limit below the level that can be accurately measured?
5.
To provide a reliable measurement of a 0.8 microgram per cubic meter limit what
method detection limit would you like to see? Is it likely given the state of science today
that mercury CEMs will have this low a detection limit by 2009?
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
Ishwar Prasad Murarka:
1.
If a plant must dispose of its ash because it is not acceptable for making concrete,
how much would that add to the cost of operation of the plant?
2.
If mercury-laden halogenated activated carbon is deemed to be a hazardous waste,
how much would that add to the cost of disposal?
Krish Vijayaraghavan:
1.
Did the TEAM results presented in your testimony contain any conversion of
ionic mercury to elemental mercury in the plume?
a.
Are you aware that measurements by Eric Edgerton at Atmospheric
Research Analysis, Inc. indicate this conversion occurs?
b.
How would your results have been affected if the mercury conversion
were added?
2.
Have you reviewed the testimony of Dr. Keeler and the limited information that is
available on his receptor modeling at Steubenville?
a.
Are Dr. Keeler’s results different and unexpected from the earlier
modeling results of AER or EPA?
b.
Can a receptor model be used to make predictions about the future effects
of a regulatory program?
3.
Have you reviewed Exhibit 65, “Preliminary Mercury Modeling Results for June
2002”? If yes, what is your interpretation of the data?
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
CERTIFICATE OF SERVICE
I, Mary Frontczak, certify that I served electronically the attached PRAIRIE STATE
GENERATING COMPANY, LLC’S PREFILED QUESTIONS upon the following this
7th day of August, 2006:.
Dorothy Gunn
Marie E. Tipsord
Clerk
Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
100 W. Randolph St. , Suite 11-500
100 W. Randolph, 100 W. Randolph
Chicago, Illinois 60601-3218
Chicago, Illinois 60601-3218
tipsorm@ipcb.state.il.us
Gina Roccaforte, Assistant Counsel
Charles E. Matoesian, Assistant Counsel
John J. Kim, Managing Attorney
Air Regulatory Unit
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19726
Springfield, Illinois 62794-9276
john.kim@epa.state.il.us
charles.matoesian@epa.state.il.us
gina.roccaforte@epa.state.il.us
and electronically and by first-class mail with postage prepaid and affixed thereon to the
persons listed on the
ATTACHED SERVICE LIST
.
[s] Mary Frontczak______
DATED: August 7, 2006
Mary Frontczak
Reg. No. 6209264
Peabody Energy
701 Market Street
St. Louis, Missouri 63101-1826
(314) 342-7810
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
SERVICE LIST
(R06-25)
William A. Murray
Special Assistant Corporation Counsel
Office of Public Utilities
800 East Monroe
Springfield, Illinois 62757
bmurray@cwlp.com
N. Ladonna Driver
Katherine D. Hodge
Hodge Dwyer Zeman
3150 Roland Avenue, P.O. Box 5776
Springfield, Illinois 62705-5776
nldriver@hdzlaw.com
Christopher W. Newcomb
Karaganis, White & Mage, Ltd.
414 North Orleans Street, Suite 810
Chicago, Illinois 60610
cnewcomb@k-w.com
Bill S. Forcade
Katherine M. Rahill
Jenner & Block
One IBM Plaza, 40
th
Floor
Chicago, Illinois 60611
bforcade@jenner.com
krahill@jenner.com
Faith E. Bugel
Howard A. Lerner
Meleah Geertsma
Environmental Law and Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 60601
fbugel@elpc.org
Keith I. Harley
Chicago Legal Clinic
205 West Monroe Street, 4
th
Floor
Chicago, Illinois 60606
kharley@kentlaw.edu
David Rieser
Jeremy R. Hojnicki
James T. Harrington
McGuire Woods LLP
77 West Wacker, Suite 4100
Chicago, Illinois 60601
drieser@mcguirewoods.com
jharrington@mcguirewoods.com
S. David Farris
Manager, Environmental, Health and
Safety
Office of Public Utilities, City of
Springfield
201 East Lake Shore Drive
Springfield, Illinois 62757
dfarris@cwlp.com
Bruce Nilles
Sierra Club
122 West Washington Avenue, Suite 830
Madison, Wisconsin 53703
bruce.nilles@sierraclub.org
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006
SERVICE LIST
(R06-25)
Sheldon A. Zabel
Kathleen C. Bassi
Stephen J. Bonebrake
Joshua R. More
Glenna L. Gilbert
Schiff Harden, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
szabel@schiffhardin.com
kbassi@schiffhardin.com
sbonebrake@schiffhardin.com
jmore@schiffhardin.com
ggilbert@schiffhardin.com
James W. Ingram
Senior Corporate Counsel
Dynegy Midwest Generation, Inc.
1000 Louisiance, Suite 5800
Houston, Texas 77002
Jim.Ingram@dynegy.com
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, AUGUST 7, 2006