IN THE MATTER OF
:
To :
Dorothy Gumi, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD E C^ 1 V E D
CLERKS OFFICE
MAY 2 3 2006
PROPOSED NEW 35 ILL.ADM
.CODE PART 225
CONTROL OF EMISSIONS FROM
LARGE COMBUSTION SOURCES
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. 0. Box 19276
Springfield, Illinois 62794-9276
Dated : May 19, 2006
NOTICE OF FILING
PCB R06-25
Rulemaking - Air
Pollution
STATE OF
Control
ILLINOIS
Board
Marie E. Tipsord
Hearing Officer
Illinois Pollution Control Board
James R
. Thompson Center
100 West Randolph
Suite 11-500
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 PARTICIPANT PRAIRIE STATE GENERATING COMPANY, LLC's
PREFILED QUESTIONS,
copies of which are herewith served upon you
.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
:
)
PCB R06-25
PROPOSED NEW 35 ILL.ADM.CODE PART 225 ) Rulemaking - Air
CONTROL OF EMISSIONS FROM
)
LARGE COMBUSTION SOURCES
)
PRAIRIE STATE GENERATING COMPANY, LLC'S
PREFILED QUESTIONS
Prairie State Generating Company, LLC has the following questions for the witnesses identified
by the Illinois Environmental Protection Agency ("IEPA") and relating to their prefiled
testimony in the above captioned matter . Prairie State Generating Company, LLC reserves the
right to prefile additional questions for IEPA witness James Staudt based on his revised pre-filed
testimony to be filed on May 19, 2006 .
Thomas Hornshaw
I .
What do Illinois fish measurements show about the long-term trend of mercury in fish?
Is it going up? Is it going down?
2.
Hornshaw states that there are no surveys of how much fish Illinois anglers consume
(page 4) . Are national surveys of fish consumption relevant to Illinois anglers? Doesn't the
largest fish consumption occur near the coasts?
Gerald Keeler
1 .
Have the details of your Steubenville modeling been made publicly available?
2.
You state that 70% of the mercury wet deposition in Steubenville comes from coal-fired
power plants . How far have you traced back power plant plumes to reach that conclusion?
Hundreds of miles?
3 .
Have you modeled what mercury wet deposition you would predict in Steubenville after
the implementation of CAMR? Have you modeled what the mercury wet deposition in
Steubenville would be if all coal-fired power plants were required to reduce emissions by some
percentage (70, 80 or 90%)?
4.
Would you expect coal-fired power plants to contribute 70% of the mercury wet
deposition at every location in the U.S .? If not, what is the contribution of Illinois coal-fired
power plants to mercury wet deposition in Illinois?
Christopher Romaine
RECEIVED
CLERK'S OFFICE
MAY 2 3 2006
Pollution
STATE OFControl
ILLINOIS
Board
1 .
Please explain how the proposed rule gives a plant credit for coal washing?
2.
On page 10 of your prefiled testimony, you discuss the federal PSD requirements . Aren't
HAPs excluded from the PSD provisions?
3 .
On page 11, you state that the Illinois monitoring requirements are "essentially identical"
to the federal requirements
. How are they different?
4.
Are reliable mercury emissions monitors commercially available? If yes, who are the
manufacturers? What is each manufacturer's time-frame to deliver and install a monitor from
date of purchase?
5 .
Does IEPA intend to propose an amendment to the rule to address situations where a
source has applied the appropriate technology but is unable to achieve the proposed standards?
If yes, when will it be proposed and what is the scope of the proposal
. If no, what is IEPA's
basis for not addressing such situations in the rule?
Jim Ross
1.
On page 5 of your testimony you state that as many as 10% of the children in the U.S.
"have been exposed to excessive levels of mercury in the womb ." What studies are you referring
to? Please explain the discrepancy between your 10% value and the 6% value another Illinois
EPA witness (Jeffrey Sprague) cites on page 3 of his testimony?
2.
Where did you get the estimate of 7022 pounds of mercury emissions in 2002 that is cited
on page 7 of your testimony?
3 .
On page 8 you state that the court challenges to EPA's listing decision were
"unsuccessful"
. Why were they unsuccessful? Did the court rule on the merits of EPA's
December 2000 action or did it find that a challenge was premature and could be brought before
the court when EPA completed its mercury rulemaking?
4
.
At various places in your testimony you talk about mercury hot spots
. Has Illinois
defined what is meant when the term "hot spot" is used? Is Illinois EPA using the same
definition that EPA used in the CAMR rulemaking? What specific "hot spots" have been
identified in Illinois? If "hot spots" have been identified, what evidence is there that they are the
result of coal-fired power plant emissions
5.
On page 10 of your testimony, you cite percentage reductions that EPA estimates will
occur as a result of CAMR
. Are these percentage reductions derived from comparing the 1999
emissions to those from CAMR Phase 1 and 2 or are they from comparing a plant's emissions to
the amount of mercury entering in the coal?
6.
Has Illinois conducted a detailed analysis to show what the incremental reductions in
mercury deposition would be in going beyond CAMR to the proposed standards? If so, has
2
IEPA analyzed how those reductions (assuming reductions will occur) affect mercury levels in
fish in Illinois?
7.
What fish advisories are predicted to be eliminated as a result of Illinois' proposed
mercury rule?
8 .
Has the Illinois EPA conducted a detailed analysis of the health benefits that would result
from going beyond CAMR?
9.
What analyses has Illinois EPA performed to determine the incremental implementation
costs of going beyond EPA's CAMR rule to comply with the limits in the proposed rule?
James Staudt
1 .
What is the basis for your cost estimate of $32-37 million to comply with the Illinois
proposed rule? Please explain in detail .
Marcia Willhite
1 .
Has Illinois conducted a detailed analysis to show what the incremental reductions in
mercury deposition would be in going beyond CAMR to the proposed standards? If so, has
IEPA analyzed how those reductions (assuming reductions will occur) affect mercury levels in
fish in Illinois?
David Foerter
1 .
Please describe in detail the criteria you use for concluding that a technology is
"commercially available ."
3
RECEIVEDCLERK'S
OFFICE
MAY 2 3 2006
Pollution
I, the undersigned, certify that on this
OControl
Board
day of May, 2006,1 have served by first-class
mail with sufficient postage affixed the attached PARTICIPANT PRAIRIE STATE
GENERATING COMPANY, LLC'S PREFILED QUESTIONS, upon the following persons
:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
and by first-class mail with sufficient postage affixed to the following persons
Marie E
. Tipsord
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph
Suite 11-500
Chicago, Illinois 60601
tip sormna,ipcb.state.il.us
the participants listed on the
ATTACHED SERVICE LIST
CERTIFICATE OF SERVICE
4
Gina Roccaforte, Assistant Counsel
Charles E
. Matoesian, Assistant Counsel
Jolm 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 a,epa.state.il.us
fina.roccaforte(cb, epa. state . il.us
William A
. Murray
Special Assistant Corporation Counsel
Office of Public Utilities
800 East Monroe
Springfield, Illinois 62757
bnnirravncwlp
.com
Christopher W . Newcomb
Karaganis, White & Mage, Ltd .
414 North Orleans Street, Suite 810
Chicago, Illinois 60610
cnewcombna,k-w.com
Faith E . Bugel
Howard A. Lerner
Meleah Geertsma
Environmental Law and Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 60601
fbugel ra,elpc.org
David Rieser
James T. Harrington
McGuire Woods LLP
77 West Wacker, Suite 4100
Chicago, Illinois 60601
drieser(a,mcguirewoods .com
iharringtonna,mcguirewoods
.com
Bruce Nilles
Sierra Club
122 West Wisconsin Avenue, Suite 830
Madison, Wisconsin 53703
SERVICE LIST
N. Ladonna Driver
Katherine D . Hodge
Hodge Dwyer Zeman
3150 Roland Avenue, P .O. Box 5776
Springfield, Illinois 62705-5776
nldriver(,hdzlaw .com
Bill S . Forcade
Katherine M . Rahill
Jenner & Block
One IBM Plaza, 40"' Floor
Chicago, Illinois 60611
bforcade(cDjenner.com
krahill n,i enner.com
Keith I. Harley
Chicago Legal Clinic
205 West Monroe Street, 4"' Floor
Chicago, Illinois 60606
kharley kentlaw .edu
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
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
5
