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CENTER
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L C Illinois Pollution Control Board
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IL
606
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Chicago, IL 60601
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Re: Comments on Proposed New 35 ILL . ADM
. CODE 225,
Rc
EIV
E D
Emissions from Large Combustion Sources (Mercury)
; R06-25
.15 1V=st North Avenue
Chica9o, 11, 50647-5415
(773) 278-4800
fax (773) 276-3640
www .
c
n t. o rg
5OIRP OF DIRECTORS
Grorge A . Vir.yord
CN,11
Robert wrissbourd
VICE CNAIp
John Cleveland
S=fRET~RY
Ellen Seirtmoa
TREASURER
Scott Bernstein
Lee Sty
Jonathon Bayer
Joseph Gross
Anne Nollett
Nancy Juda
Steven McCullough
Susan Mudd
Mary Nelson
Mary O'Connell
io Partcn
.,ce Redmond
Kathryn Tholln
Kathryn Tholln
CEO
Scott Bernstein
PRMVINT
Stephen A . Perkins, Ph,e
.
SENIOR VICE PRESIDENT
Jacquelyne P . Grimshaw
VICE PRescoeNT
STRATEGIES FOR LIVABLE COMMUNITIES
F .wa-O•M•I+FIiN+~M-IMw•~ ru .-r+M-JR
September 20, 2006
SEP 2 0 20
The Center for Neighborhood Technology supports the proposed
Pollution
STATE
rule
OF
Control
ILLINOIS
filed
Board
with the Illinois Pollution Control Board by the Illinois Environmental Protection
Agency, as amended and including the Ameren and Dynegy proposals ("the rule")
.
This rule is necessary to protect the health of the citizens of Illinois and is both
technologically feasible and cost effective .
Dear Honorable Members of the Board ;
First, the rule is necessary to protect the health of Illinois citizens, especially
Illinois children
. Mercury is a neurotoxin that passes through the placenta and
poisons fetal brain development
. Every day, thousands of developing fetuses,
newborns and young children are exposed to mercury when pregnant and nursing
women eat contaminated fish, or children eat fish themselves
. Six to ten percent of
women of childbearing age in the U .S
. are estimated to have mercury levels high
enough to put their developing children at increased risk
for developmental problems
from mercury poisoning . That translates to more than 100,000 women of
childbearing age in Illinois whose blood mercury levels may exceed the federal
recommended limit.
Further, coal fired power plants in Illinois have resulted in severe mercury
hot spots in the state
. Illinois is ranked fourth in the nation for having the most
severe mercury pollution hot spots . The southern Great Lakes experience one of the
highest deposition rates in the U .S. In this region, local and regional sources are the
main cause of elevated mercury concentrations, with the great majority of mercury
contamination coming from coal fired powers plants. Coal plants produce 71% of the
mercury pollution emitted in Illinois and the 60% in Great Lakes states as a whole
.
Fish in Lake Michigan and all Illinois waterways are contaminated with mercury .
The Illinois Department of Public Health has issued "fish advisories" warning
pregnant women, women of childbearing age and children to limit their consumption
of fish from every lake, river and stream in Illinois
.
Consequently, regulating the leading source of mercury pollution in Illinois
-
coal-fired power plants -
will reduce mercury exposure and the resulting ill health
effects of exposure. Studies show a direct relationship between mercury deposition
and mercury levels in fish . These studies conclude that reducing emissions of
mercury lowers mercury concentrations in fish, regardless of contributions from
natural or foreign sources . One study has shown that a reduction in local
atmospheric mercury emissions led to a decline of more than 80% of mercury
contamination in fish.
CNT, page 2,
The Illinois nile is necessary because the federal rule rrnrvsed by the Bush
administration is inadequate to address the problem of mercury contamination in Illinois
. The
Bush Administration's rule will perpetuate mercury hot spots like those in Illinois by allowing
coal plants to continue using older technology and also purchase the right to continue polluting at
high levels rather than installing equipment to clean up their plants and protect our health and
environment.
The Illinois rule as drafted (including amendments and Ameren's and Dynegy's
proposals), is sound and will be effective . First, states such as Georgia, Maryland,
Massachusetts, Michigan, Minnesota, New Jersey and Pennsylvania, among others, have
initiated proposals with mercury reductions from power plants similar to those in the Illinois
proposed rule, demonstrating that this rule is reasonable and the bases for the rule are sound .
Second, the IEPA and proponents made the necessary showing at the hearings and in filings that
the rule is both technically feasible and economically reasonable
.
•
The technology for controlling mercury in accordance with the requirements of the rule is
readily available . Activated carbon injection ("ACI"), with brominated or halogenated
sorbents where appropriate, has been shown to achieve 95-percent capture rates in short-
term tests for all ranks of coal, burned in Illinois .
•
The technology is also economically reasonable . The reductions required by the
proposed rule could be achieved while costing Illinois residential consumers only $0
.69
more per month, on average . Commercial businesses would pay about $5
.82 more on
average, while the average industrial bill would increase $305 .47 monthly. The cost of
ACI per unit is approximately is less than one million dollars
.
•
Where 90% is not achievable with ACI alone, other pollution control options can be used
to achieve 90%, including controls for other pollutants that provide additional mercury
reductions.
Finally, there is sufficient flexibility in the rule for operators to choose a compliance
pathway that is appropriate for them in terms of both means and timing of achieving the
necessary reductions, The flexibility built into the rule includes
:
•
The initial averaging period,
•
The output based standard,
•
The temporary technology-based standard, and
•
Ameren and Dynegy's proposed multi-pollutant standard,
Ameren and Dynegy's support for the rule demonstrates that facilities within the state of Illinois
can achieve the required reductions contained in the proposed rule in a cost-effective manner .
For these reasons, the Center for Neighborhood Technology supports the proposed rule
and encourages the Board to vote in favor of the rule.
Kathryn Tholi
Chief Executive Officer, CNT
Celiter for
1 `lighborhood
Technology
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Date
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