Microsoft Word - R06-25 082106 afternoon hearing transcript

1337

ILLINOIS POLLUTION CONTROL BOARD

August 21, 2006

IN THE MATTER OF:

) R06-25

)

PROPOSED NEW 35 ILL. ADM. CODE PART 225 )

5 CONTROL OF EMISSIONS FROM

)

LARGE COMBUSTION SOURCES (MERCURY)

)

REPORT OF PROCEEDINGS held in the

8 above-entitled cause before Hearing Officer Marie

9 Tipsord, called by the Illinois Pollution Control

10 Board, taken before Tamara Manganiello, RPR, a

11 notary public within and for the County of Will and

12 State of Illinois, at the James R. Thompson Center,

13 100 West Randolph Street, Chicago, Illinois, on the

14 21st day of August, 2006, commencing at the hour of

15 1:00 p.m.

L.A. REPORTING (312) 419-9292

1338

1 A P P E A R A N C E S:

ILLINOIS POLLUTION CONTROL BOARD

100 West Randolph Street

Suite 11-500

Chicago, Illinois 60601

(312) 814-3461

BY: MS. MARIE TIPSORD, HEARING OFFICER

MS. ANDREA S. MOORE, BOARD MEMBER

MR. TIMOTHY J. FOX, ATTORNEY ASST. TO MOORE

MR. NICHOLAS J. MELAS, BOARD MEMBER

MR. G. TANNER GIRARD, ACTING CHAIRMAN

MR. ANAND RAO, SR. ENVIRONMENTAL SCIENTIST

MR. THOMAS E. JOHNSON, BOARD MEMBER;

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

BY: MR. JOHN J. KIM, MANAGING ATTORNEY

MR. CHARLES E. MATOESIAN, ASST. COUNSEL;

AYRES LAW GROUP

1615 L Street, N.W.

Suite 1350

Washington, D.C. 20036

(202) 452-9200

BY: MR. RICHARD E. AYRES;

SCHIFF HARDIN, L.L.P.

233 South Wacker Drive

6600 Sears Tower

Chicago, Illinois 60606

(312) 258-5646

BY: MS. KATHLEEN C. BASSI

MR. STEPHEN J. BONEBRAKE

MR. SHELDON A. ZABEL;

L.A. REPORTING (312) 419-9292

1339

1 A P P E A R A N C E S

CHICAGO LEGAL CLINIC, ENVIRONMENTAL LAW PROGRAM

205 West Monroe Street

Fourth Floor

Chicago, Illinois 60606

(312) 726-2938

BY: MR. KEITH I. HARLEY;

DYNEGY MIDWEST GENERATION, INC.

1000 Louisiana Street

Suite 5800

Houston, Texas 77002

(713) 767-0450

BY: MR. JAMES W. INGRAM, SR. CORPORATE COUNSEL

L.A. REPORTING (312) 419-9292

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MS. TIPSORD: Good afternoon. This is

the sixth day of hearing at our second round

of hearings in this proceeding. My name is

Marie Tipsord and I'm the hearing officer.

For those of you who may be new,

this is R06-25 In the Matter of Proposed New

35 Ill. Adm. Code 225, Control of Emissions

From Large Combustion Sources (Mercury).

With me today to my immediate left

is Dr. Tanner Girard and to my immediate

right is Andrea Moore, the presiding board

member. To Ms. Moore's right is her attorney

assistant Tim Fox. To Mr. Fox's right is

Board member Nicholas Melas. To

Dr. Girard's left is Anand Rao from our

technical unit. And to his left is Tom

Johnson, another of our board members.

Also present today are Kathleen

Crowley, our senior attorney and Connie

Newman. If any members of the press are

present and have questions, they should

contact Connie Newman.

Today we're going to start our

hearing I understand first with a statement

L.A. REPORTING (312) 419-9292

1341

from Mr. James Ingram; is that correct?

MR. INGRAM: Yes, ma'am.

MS. TIPSORD: And then we'll go to the

testimony of Krish Vijayaraghavan, Gail

Charnley, Peter Chapman and then we'll decide

what order we're doing Richard McRanie, C.J.

Saladino and Andy Yaros tomorrow.

At the back of the room there are

sign-up sheets for the notice of service

list. There is also copies of the Department

of Commerce and Economic Opportunity letters

indicating that they will not be doing an

amicus in this proceeding. And I also see

that with us today is Mr. John Knittle, who

is Tom Johnson's assistant. With that,

Mr. Ingram?

MR. INGRAM: Madam Hearing Officer,

Members of the Board, Jim Ingram, attorney

for Dynegy Midwest Generation, Inc. If I

may, I'd like to provide to the parties

present a copy of a joint statement of the

Illinois Environmental Protection Agency and

Dynegy Midwest Generation, Inc., that I have

filed with the clerk of the Illinois

L.A. REPORTING (312) 419-9292

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Pollution Control Board in this matter today.

Recognizing that this joint

statement comes well after the deadline of

July 28 for filing pre-filed testimony in

opposition to the proposed Illinois mercury

rule, I have not prepared testimony

concerning the joint statement and assume

that as such it will be received as a comment

on the proposed rule.

Under Section 102600 of the rules

of the Illinois Pollution Control Board, the

Board is allowed to revise proposed

regulations before adoption in response to

suggestions made at hearing and in written

comment. And Dynegy is asking in the joint

statement that the Board revise the proposed

regulation in this proceeding to include the

multi-pollutant standard as revised in the

attachment to the joint statement of Illinois

Environmental Protection Agency and Dynegy

Midwest Generation, Inc., that I have filed

today.

Dynegy has pre-filed testimony in

opposition to the proposed mercury rule in

L.A. REPORTING (312) 419-9292

1343

conjunction with Midwest Generation, Inc.,

through our attorneys, Schiff Hardin. To the

extent that portions of that testimony

contradict the joint statement filed today, I

would request that the hearing officer and

the Board disregard those portions that do

contradict as to Dynegy -- as the testimony

of Dynegy. If I may?

MS. TIPSORD: Just for clarification,

this has been filed in the clerk's office --

MR. INGRAM: Yes, it has.

MS. TIPSORD: -- as a public comment?

Do you want to enter it as an exhibit in the

hearing as well or just as a public comment?

MR. INGRAM: I would enter it as an

exhibit.

MS. TIPSORD: All right. We'll enter

it as an exhibit then, as well.

MR. INGRAM: But it will not be

supported by testimony today.

MS. TIPSORD: Understood.

(Documents tendered to

the Board from

Mr. Ingram.)

L.A. REPORTING (312) 419-9292

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MS. TIPSORD: Thank you. If there's

no objection, we will mark this as Exhibit

No. 125. Seeing none, it is Exhibit 125.

And I would note that the clerk's

office, I'm sure, has given it a

corresponding public comment number in the

six or 7000s someplace. And, actually, I can

check at break and get back to everyone what

the public comment number is on that as well.

MR. INGRAM: Thank you.

MS. TIPSORD: Thank you. Mr. Zabel?

MR. ZABEL: For the record, Madam

Hearing Officer, Sheldon Zabel. At this

point in time I would formally withdraw the

appearance of Schiff Hardin, which includes

myself, Mr. Bonebrake, Ms. Bassi, Mr. Moore

and Mr. Gilbert on behalf of Dynegy Midwest

Generation, Inc. We would continue to

represent the other parties for whom we have

appeared in this proceeding.

MS. TIPSORD: And just for the record,

can you identify who those other parties are?

MR. ZABEL: Yes. Midwest Generation,

L.L.C., Southern Illinois Power Cooperative.

L.A. REPORTING (312) 419-9292

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MS. TIPSORD: Thank you. And will you

be filing something with the clerk's office?

MR. ZABEL: I can file a formal

withdrawal, of course. A written withdrawal

MS. TIPSORD: That would probably be

easier for the clerk's office.

MR. ZABEL: I just wanted, before we

proceeded today, to make that clear on the

record.

MS. TIPSORD: Understood. Thank you

very much. With that, I believe we're ready

to go to Krish Vijayaraghavan and can we have

him sworn?

MR. KIM: Before we continue, I just

wanted to give you the last word that I had

heard on the Steubenville report.

MS. TIPSORD: That's right.

MR. KIM: Dr. Keeler is on a beach

somewhere but he has spoken with us and what

he has represented to us is this: That he

spoke with the -- he contacted and spoke with

the editorial office of Environmental Science

and Technology. Apparently what's going to

happen next is they are going to or they have

L.A. REPORTING (312) 419-9292

1346

sent galleys or proofs of the article to him.

He has two weeks to make -- he's probably had

these for a little while. He had two weeks

to make any changes he felt were necessary.

At that point, if they received nothing, they

were going to publish it. The date that he

received it from them was a September 7th

publish date, you know, with or without, I

guess, any comments that he had. So what he

was told by the publication was that

September 7th would be the last date by which

it should be published.

MS. TIPSORD: Thank you. If we could

have Mr. Vijayaraghavan sworn in.

(Witness sworn.)

MR. KIM: Could we have just -- and I

apologize -- two minutes for Mr. Ayres to

arrive? He's going to be conducting the bulk

of the questioning to Mr. Vijayaraghavan.

MR. AYRES: Thirty seconds?

MR. KIM: Thirty seconds.

MS. TIPSORD: I'll give you a whole

minute.

(Brief pause.)

L.A. REPORTING (312) 419-9292

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MS. TIPSORD: I have been handed the

pre-filed testimony of Mr. Vijayaraghavan.

If there's no objection, we'll mark that as

Exhibit 126. Seeing none, it's marked as

Exhibit 126.

MS. BASSI: And I had indicated to you

that there were a couple of additional

references and here they are as well. So

this gets tacked onto the end.

MS. TIPSORD: If it's all right with

everyone, instead of marking this as a

separate exhibit, we'll just make it as an

addendum to 126. Is that okay with everyone?

We'll do that then.

MS. BASSI: Would you please introduce

yourself and then we will have a PowerPoint

slide that goes through and kind of

summarizes Mr. Vijayaraghavan's testimony and

I hope we'll clarify some of the maps that

are at the end of your testimony that I just

handed out.

MR. AYRES: Ms. Bassi?

MS. BASSI: Yes, sir?

MR. AYRES: Is this testimony that you

L.A. REPORTING (312) 419-9292

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just handed out the same as the one that was

pre-filed --

MS. BASSI: Yes, sir.

MR. AYRES: -- or in addition to it?

MS. BASSI: No. This is the same as

what's filed.

MR. AYRES: So these slides are new?

MS. BASSI: Yes. And I will have

copies. Well, the slides are mostly the same

as what's in your testimony. There are a

couple of additional ones and so I will be

handing that out separately.

MR. AYRES: Okay.

MS. TIPSORD: You will be handing out

an entire copy of this?

MS. BASSI: Yes.

MS. TIPSORD: The PowerPoint

presentation, for the record.

MR. AYRES: Madam Chairman, just

before we begin, this is additional testimony

which we haven't had a chance to review.

MS. TIPSORD: Understood.

MS. BASSI: I'm sorry, you haven't had

a chance to review what?

L.A. REPORTING (312) 419-9292

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MR. AYRES: What you're going to add

by way of the slides.

MS. BASSI: It won't confound you.

I'm sorry, did you give an exhibit number to

the testimony?

MS. TIPSORD: One-twenty-six.

MS. BASSI: Thank you.

MS. TIPSORD: When he's ready to start

the presentation, we'll move.

MR. VIJAYARAGHAVAN: Good afternoon,

Hearing Officer. My name is Krish

Vijayaraghavan. I'm a staff engineer at

Atmospheric & Environmental Research, AER.

We provide the research --

MS. TIPSORD: Hang on. That

microphone is not going to work at all.

MR. VIJAYARAGHAVAN: It has too much

static. I could speak up.

MS. TIPSORD: Okay. Let's try that or

we can also try one of the other microphones.

MR. VIJAYARAGHAVAN: I'm a staff

engineer at Atmospheric & Environmental

Research or AER, which is a research and

consulting firm based in Massachusetts near

L.A. REPORTING (312) 419-9292

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Boston. And we provide consulting services

both to government and industry. Most of the

staff have advanced degrees and a substantial

number have PhDs, so the focus is on

fundamental research and consulting. For

example, we received the American

Meteorological Society award for outstanding

services by a corporation.

The company has offices around the

United States and I represent the San

Francisco bay area office that specializes in

air quality studies. And my area of

expertise is the atmospheric modeling of

mercury, ozone and particulate matter. I

have a bachelor's degree in chemical

engineering from the Indian Institute of

Technology and a master's degree in chemical

engineering from the University of Kansas and

a master's degree in environmental

engineering from the Georgia Institute of

Technology.

I have conducted numerous studies

of the modeling of mercury deposition both

over the United States and globally and have

L.A. REPORTING (312) 419-9292

1351

published numerous peer-reviewed scientific

papers, made conference presentations and

written technical reports. For example,

recently I was an invited speaker at the

mercury session of the annual meeting of the

national atmospheric deposition program. And

with that, I conclude my opening brief.

MR. AYRES: Mr. Vijayaraghavan? If I

said that properly?

MR. VIJAYARAGHAVAN: You got it.

MR. AYRES: Who are the primary

clients of AER?

MS. TIPSORD: Could we wait until he

finishes his slide presentation and then

we'll do questions?

MR. AYRES: Certainly.

MS. TIPSORD: Let's let him do his

opening statement first.

MR. AYRES: Okay.

(Brief pause.)

MS. TIPSORD: We're going to mark

this, which is the hard copy of the slide

presentation, as exhibit number 127, if

there's no objection. Seeing none, it's

L.A. REPORTING (312) 419-9292

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Exhibit 127. Go ahead, Mr. Vijayaraghavan.

(Brief pause.)

MS. TIPSORD: Why don't you go ahead

and start the preliminary questions while

we're waiting on the signal to get fixed.

That way we won't be losing much time.

Mr. Ayres?

MR. AYRES: Mr. Vijayaraghavan, I

asked earlier who the primary clients are of

the firm, AER, that you're associated with?

MR. VIJAYARAGHAVAN: AER has clients

in both government and industry. For

example, U.S. EPA, NASA, and then the

utilities from industry, then you have the

automobile manufacturers, the CRC, which

represents a consortium of research

organizations. So we have a range of both

private industry and government clients.

MR. AYRES: And what percentage would

you say was -- of your revenues, let's say,

is from private industry?

MR. VIJAYARAGHAVAN: Well, it's hard

to tell because I'm not in the executive

management position, but it's -- I don't

L.A. REPORTING (312) 419-9292

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think I can put a number on it. It's not --

I don't think one is -- either one is more

than 75 percent. But it's hard for me to

quantify. So there isn't either one that has

a significant competence. By either one, I

mean industry versus government.

MR. AYRES: Would the majority of the

revenues probably be from industry?

MR. VIJAYARAGHAVAN: That might be

likely, but I couldn't quantify it. For

example, one of our clients was LADCO for a

mercury study that we did for them. So at

the same time, we've also done work for the

utilities so we've got a balance.

MR. AYRES: Could you tell us a little

bit about the TEAM model? Is that a

proprietary model or is it available for

public review?

MR. VIJAYARAGHAVAN: TEAM is available

for public review. It has been published in

the literature. But the development of TEAM

was funded by EPRI, which is a utility

consortium. So as can be naturally expected,

they would want to be informed before TEAM is

L.A. REPORTING (312) 419-9292

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made use of. However, we have transferred

TEAM to state organizations. For example,

NYSERDA, the New York State Department, we've

transferred TEAM to them and have, in fact,

provided training to state officials out

there.

MS. TIPSORD: Excuse me, for the court

reporter, EPRI is capital E, capital P,

capital R, capital I.

THE COURT REPORTER: Thank you.

MR. VIJAYARAGHAVAN: And NYSERDA was

N-Y-S-E-R-D-A.

MR. AYRES: And we'll do this to you

all afternoon. I'm sorry. So has the TEAM

model then been peer reviewed in any event?

MR. VIJAYARAGHAVAN: Yes. The TEAM

model has been peer-reviewed. It's been also

published extensively in the peer-reviewed

literature. I believe we have about seven to

eight publications in international journals.

It's been critically reviewed by scientific

researchers who review such journals.

MR. AYRES: And has it been

benchmarked against other models?

L.A. REPORTING (312) 419-9292

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MR. VIJAYARAGHAVAN: Yeah. We have

compared TEAM with -- we have compared TEAM

with models such as CMAQ and other chemistry

transport models and we have benchmarked it

against data. Now, benchmarking is a tricky

proposition because you don't want to really

compare apples to oranges when you, say,

compare a chemistry transport model to a

receptor model.

But as has been cited in my

testimony, we did a rough comparison with the

results of the receptor modeling study done

by Dr. Keeler and we seem to be within the

range of uncertainty of his numbers so that

serves as a fairly good benchmark.

MR. AYRES: So what benchmark that has

been done, has been done internally; is that

correct.

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: Has it just been done by

your staff or has it been done by clients?

MR. VIJAYARAGHAVAN: When they

transferred TEAM to NYSERDA, they tested the

model, as well. But I'm not aware of

L.A. REPORTING (312) 419-9292

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publications that they published that came

out of that study.

MR. AYRES: Has it ever been accepted

by a regulatory agency for purposes of

regulation?

MR. VIJAYARAGHAVAN: I don't think

that issue has ever come up. Firstly,

mercury regulations have been quite recent,

so we are talking about a very specific type

of model, chemistry transport models as

opposed to other types of models, say, for

example, a methylation model or a lake model.

So historically, since these regulatory

models are relatively new, TEAM has -- the

issue has not come up. And we have not

received any requests for assistance in, you

know, making TEAM to be a regulatory model.

So, no, that has not come up.

MR. AYRES: EPA does use the CMAQ

model for that --

MR. VIJAYARAGHAVAN: Right.

MR. AYRES: -- purpose, though, don't

they?

MR. BONEBRAKE: Just for

L.A. REPORTING (312) 419-9292

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clarification, Mr. Ayres, you're referring to

U.S. EPA?

MR. AYRES: Yes. Thank you. U.S. EPA

uses the CMAQ --

MR. VIJAYARAGHAVAN: Right.

MR. AYRES: No. The CMAC -- CMAQ

model?

MR. VIJAYARAGHAVAN: That is correct.

MS. TIPSORD: Even we can't keep track

of the acronyms.

MR. AYRES: Are we ready for the

slides?

UNIDENTIFIED SPEAKER: No.

MS. BASSI: Are those all of your

introductory questions?

MR. AYRES: I don't think --

MS. BASSI: Can you think of more?

MR. AYRES: Perhaps. I would like to

pause at this point, if I may.

MS. BASSI: We could go to the other

questions, if you want.

MS. TIPSORD: The pre-filed questions?

MS. BASSI: While we struggle with the

machinery, let's go ahead with question

L.A. REPORTING (312) 419-9292

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number one.

MR. VIJAYARAGHAVAN: Question number

one: On Page 3 of his testimony,

Mr. Vijayaraghavan states that the relative

proportions of Hg0, Hg2+ and Hgp differ in

time and location, and the fractions of HG2+

and Hgp can be considerably larger near

man-made sources. Is a 20 kilometer by 20

kilometer grid spacing the most appropriate

model resolution to assess Hg deposition

close to emission sources? Is it true that

within the 20 kilometer by 20 kilometer grid

cell, the deposition amount at a point of

maximum deposition would be averaged together

with lower deposition amounts to arrive at

the average deposition amount over that large

area.

Answer: No. A plume model is

actually the most appropriate to assess Hg

deposition close to an emission source.

However, a plume model is typically not

applicable to model a large number of

different types of sources. For example, in

the case of mercury modeling you also have

L.A. REPORTING (312) 419-9292

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area sources. And a grid-based model, such

as TEAM, is most appropriate for the

simulation of atmospheric mercury deposition

over the state of Illinois.

We applied a grid model with 20

kilometer grid spacing because our objective

was to assess Hg deposition both close to and

far from emission sources. Also, a plume

model, if applied, tends to predict lower

power plant contributions to mercury

deposition than a grid-based model over an

area commensurate with the grid size.

This was shown in our work

published in the Journal of the Air & Waste

Management Association. The reference would

be Seigneur, et al., 2006(b). And that's

cited in my testimony, as well.

And this lower prediction is

typically because a plume model will

correctly transport the mercury, SO2 and NOx

aloft in the plume, whereas the grid model

tends to distribute the plume material closer

to the ground. All of the emissions are kind

of instantaneously released in the grid cell

L.A. REPORTING (312) 419-9292

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and then they're disposed down to the surface

by vertical diffusion.

In response to the second part of

the question: Yes, the deposition flux

reported over a grid cell represents an

average over the grid cell area. However, a

single point of maximum deposition in a 20

kilometer by 20 kilometer grid cell is a moot

issue because deposition over a larger

geographic area is really what is needed and

not at a single point when you're looking at

estimating contribution to water sheds.

Also, the grid cell value itself

that was arrived by averaging could be

artificially high because the plume material

is dispersed to the surface grid cell too

rapidly in a grid-based model.

MR. AYRES: Isn't the -- aren't the

emissions which are within the grid space in

the model emitted at a single point in the

model?

MR. VIJAYARAGHAVAN: Emissions are

emitted at a single point, that is correct.

MR. AYRES: And that's whether or not

L.A. REPORTING (312) 419-9292

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the actual point -- whether there's actually

one point at which they're emitted or several

points at which they're emitted within that

cell, correct?

MR. VIJAYARAGHAVAN: Well, the way we

do it is if you have multiple sources within

a grid cell. First, you compute plume rise.

So you see, because of the temperature,

velocity, the height of the stack, et cetera,

you see how far out the plume goes and there

you release the emissions in that particular

grid cell.

So if two different sources happen

to be in the same 20 kilometer by 20

kilometer grid cell, they would both be

released in the same grid cell.

MR. AYRES: They would both be

released in --

MR. VIJAYARAGHAVAN: In the same grid

cell. But it is not at a single point in the

grid cell because in a grid-based model your

grid is one entity. In a sense, you divide

up your modeling domain into a 3-D gridded

mesh and you release the emissions within a

L.A. REPORTING (312) 419-9292

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specific grid cell aloft. So there isn't

really one point in the grid cell where the

emissions are released. It is in a specific

grid cell which encompasses the location of

the source.

MR. AYRES: So the emissions are

released as if they are evenly released

throughout the grid cell?

MR. VIJAYARAGHAVAN: Yeah. And that

is a limitation of a grid-based model. And

what Mr. Ayres is referring to is known as

horizontal dilution where you have the

emissions being released and then they are

spread across the grid cell. So in this

case, a 20 kilometer by 20 kilometer grid

cell.

MR. AYRES: Aside from Lake Michigan,

do you know the extent of the largest lake in

Illinois?

MR. VIJAYARAGHAVAN: I have a -- I

think in the context of deposition modeling,

waters of interest is actually the water

sheds of Illinois and I have a map here that

has the water sheds of Illinois and those are

L.A. REPORTING (312) 419-9292

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significantly larger -- typically

significantly larger than the 20 kilometer

grid cells that we're modeling with.

MS. TIPSORD: And what map are you

referring to?

MR. VIJAYARAGHAVAN: For the record,

the map is titled Major Water Sheds of

Illinois. This is a map prepared by the

Illinois State Water Survey.

MS. TIPSORD: Is it in your testimony?

MR. VIJAYARAGHAVAN: No.

MR. AYRES: I was asking about lakes

rather than water sheds.

MR. VIJAYARAGHAVAN: Yes. The size of

the water shed will be larger than the sizes

of the lake. And the reason I'm talking

about -- and, specifically, no, I do not know

the size of the lake. But I bring up the

issue of water sheds because we're talking

about the same concept, deposition to a water

shed initially.

MR. AYRES: It would be surprising,

wouldn't it, if the largest lake was

20 kilometers square or 20 square kilometers

L.A. REPORTING (312) 419-9292

1364

in area?

MR. BONEBRAKE: I'm going to object.

He's already testified that he doesn't know

the answer to the question that Mr. Ayres is

yet again asking.

MS. TIPSORD: I think he's asking for

his opinion at this point. So go ahead and

answer as best you can.

MR. VIJAYARAGHAVAN: Well, outside of

Lake Michigan one would not expect lakes to

be of the order of hundreds of kilometers,

I'm sure.

MS. TIPSORD: Ms. Bassi, could we

enter that as an exhibit, please?

MS. BASSI: I do not have multiple

copies of this. We will have them tomorrow.

I was not anticipating giving it to you.

MS. TIPSORD: Thank you. This is

Major Water Sheds of Illinois. We'll mark

this as Exhibit 128, if there's no objection.

Seeing none, it's Exhibit 128. Go ahead,

Mr. Ayres. I apologize for interrupting you.

MR. AYRES: Since your model predicts

deposition as averages in 20 kilometer square

L.A. REPORTING (312) 419-9292

1365

grids, doesn't that mean that the model

cannot tell us what the deposition is at the

average or even the largest Illinois lake

other than Lake Michigan?

MR. VIJAYARAGHAVAN: Let me repeat,

again. What we do in the model is release

the emissions in a grid cell, then you

simulate the chemistry and the transport and

the deposition of the mercury. So if you use

a finer grade resolution, then you're going

to get the mercury deposition that falls

within that particular grid cell. But one of

the problems associated with that is you have

what I earlier talked about, which was

artificial vertical dispersion. So your

plume material is -- in a grid-based model,

the plume material is artificially dispersed

to the ground too rapidly. That's the first

point I would like to make.

And the second point, as I just

mentioned, the deposition to a single point

is a moot issue because what you're really

interested in is deposition to a larger

geographic area comparable to a water shed.

L.A. REPORTING (312) 419-9292

1366

MS. TIPSORD: And I would like to note

just for the record that Exhibit 128 is

prepared by the Illinois State Water Survey.

MR. AYRES: Aren't we also interested

in the peak deposition? If a particular lake

is receiving deposition from a source that is

a point source, as these sources all are, at

a high concentration, higher than the average

in the 20 kilometer square grid; isn't that

of interest?

MR. VIJAYARAGHAVAN: First of all,

mercury concentrations are not the issue

here. It's mercury deposition.

MR. AYRES: I'm sorry. Deposition.

MR. VIJAYARAGHAVAN: Unlike, say,

particulate sulfate. And the HUC,

hydrological code, is the typical component

that's used when you're looking at estimating

the effects of mercury deposition.

MR. AYRES: Deposition actually occurs

as a result of emissions from point sources,

doesn't it?

MR. VIJAYARAGHAVAN: Deposition arises

out of several sources, mercury enriched

L.A. REPORTING (312) 419-9292

1367

soils, point sources, automobiles, refineries

and such.

MR. AYRES: Let me ask the question

another way. Deposition from utilities comes

as a result of emissions from point sources,

does it not?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And it travels, to some

extent, in plumes we know as a matter of

fact, don't we?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And your model attempts to

model the behavior of those activities in the

atmosphere. But in reality, we know that

there are places where emissions may be

considerably higher because of the fact that

they're particularly affected by a plume,

don't we?

MR. VIJAYARAGHAVAN: I mean, there

is -- I don't know what you mean when you say

we know that there are places particularly

affected by --

MR. AYRES: Don't we --

MS. TIPSORD: Let him finish his

L.A. REPORTING (312) 419-9292

1368

answer, Mr. Ayres.

MR. VIJAYARAGHAVAN: I was just trying

to state your question again. You said do we

not know that there are places affected by

the plumes? I do not follow your statement.

But that seems to be an opinion.

MR. AYRES: It seems to be?

MR. VIJAYARAGHAVAN: It seems to be an

opinion that you state.

MR. AYRES: I'm asking you a question

which is: Do you not know that, in fact, in

the real world as opposed to the model world

some places are affected by plumes from power

plants more than the average over a 20

kilometer area?

MR. VIJAYARAGHAVAN: By definition,

the average is going to be smaller than the

maximum, that is correct.

MR. AYRES: So since your model

predicts deposition in 20 kilometer square

grids, doesn't it mean it can't tell us what

the peak concentrations in the real world are

within those grids?

MR. VIJAYARAGHAVAN: Again, I presume

L.A. REPORTING (312) 419-9292

1369

you're referring to depositions because

mercury concentrations are not at issue.

MR. AYRES: I thought I said

deposition. But if I didn't, I stand

corrected.

MR. VIJAYARAGHAVAN: Right. So, no,

again, let me state deposition to a water

shed is what is at issue here. Firstly, if

you have grid-based models with a 20

kilometer grid such as ours, you are going to

have horizontal dilution, which is what we

were discussing just now. At the same time,

you are also going to have artificial

vertical dispersion. So it is quite possible

that this average value that we are talking

about is actually larger than the real world

deposition or concentration.

MR. AYRES: Are we ready?

MS. TIPSORD: Are we ready?

UNIDENTIFIED SPEAKER: We're still

working on it.

MS. TIPSORD: Sorry.

MS. BASSI: Are we ready for number

two?

L.A. REPORTING (312) 419-9292

1370

MS. TIPSORD: Question number two.

MR. VIJAYARAGHAVAN: Question number

two: On Page 10, Mr. Vijayaraghavan notes

that U.S. coal-fired power plants are

calculated to contribute 19 percent of

mercury deposition in Illinois in 2006. For

the Illinois grid cells, only four out of 474

20 kilometer by 20 kilometer grid cells

receive more than half of their mercury

deposition from U.S. coal-fired power plant

emissions.

Question A: How is the 19 percent

figure calculated if some cells receive more

than 50 percent of their deposition from U.S.

emissions?

And Question B: Where are the

four Illinois grid cells that receive more

than half of their mercury deposition from

U.S. coal-fired power plant emissions. What

is the maximum percentage for any Illinois

cell?

Answer A: To calculate the

19 percent number, we compared two different

scenarios. We compared the 2006 base

L.A. REPORTING (312) 419-9292

1371

scenario with our scenario number two where

we zero'd out mercury emissions from all

coal-fired power plants in the U.S. Then we

subtract the total deposition in Illinois

between those two scenarios and find that as

a percent of the base number.

So we subtract the base and the

zero-out scenario and find that as -- and

convert that to a fraction of the base number

and that's how we arrive at the 19 percent

number.

Answer B: Four Illinois grid

cells, or less than 1 percent of Illinois

area, are calculated to receive more than 50

percent of their deposition from all U.S.

coal-fired power plant emissions. These four

grid cells are in, one, Wabash County, two,

Peoria County/Tazewell County, three,

Randolph County and, four, Montgomery County.

The maximum percentage is 63 percent.

MR. AYRES: To go back to the

19 percent figure, if I could?

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: That 19 percent figure

L.A. REPORTING (312) 419-9292

1372

represents the average in all cells; is that

what your saying?

MR. VIJAYARAGHAVAN: Yes. We compute

the total deposition in all cells and

subtract out the zero'd number from the base.

MR. AYRES: Okay.

MS. BASSI: May I insert here? Does

everyone understand what zero-out means?

MR. VIJAYARAGHAVAN: For the record,

by zero'd I mean we set to zero mercury

emissions from all coal-fired power plants in

the U.S. and we run our model and compute

what the deposition is. So, in essence,

you're looking only at deposition from

sources other than U.S. coal-fired power

plants.

MR. AYRES: I'm sorry. Could you also

repeat the four county names? We got a

couple of them but not all of them.

MR. VIJAYARAGHAVAN: Right. The four

would have been, one, Wabash County, two,

Peoria County and Tazewell County, three,

Randolph County, four, Montgomery County.

MR. AYRES: Do these counties have

L.A. REPORTING (312) 419-9292

1373

power plants located in them? Can you tell

us that?

MR. VIJAYARAGHAVAN: Yes these

counties have power plants in them.

MS. TIPSORD: If I may? Just out of

curiosity, could you tell us how many, for

example, in Peoria/Tazewell?

MR. VIJAYARAGHAVAN: Sure. Let me go

ahead and give you the full.

MS. TIPSORD: Okay.

MR. VIJAYARAGHAVAN: The first, Wabash

County, is actually the maximum contribution

that's in a grid cell that spans the

Illinois/Indiana border and includes the

Gibson Power Plant, which is in Indiana just

across the Wabash River from Mt. Carmel. And

the Peoria County/Tazewell County that Madam

Hearing Officer referred to has got the ED

Edwards/Powerton Plant.

MS. TIPSORD: And go ahead with the

rest.

MR. VIJAYARAGHAVAN: Yes. And the

other two would be Baldwin and Coffeen.

MS. TIPSORD: Thank you.

L.A. REPORTING (312) 419-9292

1374

MR. JOHNSON: Where did you say the

Indiana source was?

MR. VIJAYARAGHAVAN: It's the Gibson

Plant, which is across the Wabash River just

across from Mt. Carmel. Since you bring it

up, I came across an issue where the Illinois

attorney general actually filed suit against

the Indiana plant for cross-state pollution.

It's just across from Mt. Carmel in

southeastern Illinois.

MS. TIPSORD: Are we ready for

question three then?

MR. VIJAYARAGHAVAN: Question three:

Related to the 2010 CAIR/CAMR -- it's an

acronym, C-A-I-R slash C-A-M-R -- simulation,

Mr. Vijayaraghavan notes that Illinois grid

cells show decreases in mercury deposition of

up to 51 percent. There is only one grid

cell in Illinois that shows an increase of

less than 1 percent in mercury deposition.

Question A: Where are the

Illinois grid cells that have decreases in

deposition that are less than 51 percent?

Question B: Where is the Illinois

L.A. REPORTING (312) 419-9292

1375

grid cell that has no decrease in mercury

deposition in 2010 due to CAMR?

Answer to A: All Illinois grid

cells but one have decreases in deposition

that are less than 51 percent.

Answer to B: The Illinois grid

cell that showed no decrease in simulated

mercury deposition in 2010 due to CAMR is

near St. Louis.

MS. BASSI: Number four. Go ahead.

MS. TIPSORD: I'm sorry. You said the

area of St. Louis?

MR. VIJAYARAGHAVAN: Yes.

MS. TIPSORD: You mean East St. Louis?

MR. VIJAYARAGHAVAN: Yeah. Actually,

it's a grid cell that spans the

Illinois/Missouri border. And the power

plant out there is Ameren power plant in

Missouri. It's right across the border. May

I go on to question four.

MS. BASSI: Yes.

MR. VIJAYARAGHAVAN: Question four:

On Page 11 of his testimony,

Mr. Vijayaraghavan states that the TEAM

L.A. REPORTING (312) 419-9292

1376

results for 2010 CAMR with 90 percent

Illinois controls indicated, in relative

terms, most of the Illinois area shows

decreases of 1 to 5 percent due to the

Illinois 90 percent emission reductions with

only a few grid cells with decrease in the 15

to 35 percent range.

Question A: How many grid cells

had decreases in the 15 to 35 percent range?

Where are they located.

Answer to A: Eleven grid cells,

or about 2 percent of Illinois area, are

simulated to experience between 15 to

35 percent decreases. These grid cells are

located in following counties: One, Mason,

two, Randolph, three, Peoria/Tazewell, four,

Putnam, five, Montgomery, six, Cook, seven,

Will, eight, Will again, nine, Lake, ten,

Jasper, and eleven, Cook.

Question 5: According to

Mr. Vijayaraghavan, the 2020 CAIR/CAMR

simulation leads after 10 years to lower

mercury deposition in Illinois than the 2010

CAIR/CAMR simulation with 90 percent Illinois

L.A. REPORTING (312) 419-9292

1377

mercury control except for three grid cells

in Illinois where very small increases are

predicted.

Where are the three Illinois grid

cells where 2020 CAIR/CAMR would lead to 3

percent increases in mercury deposition?

Answer A: The three Illinois grid

cells where 2020 CAIR/CAMR would lead to very

small, i.e., less than 3 percent, increases

in mercury deposition are the following

counties; Peoria/Tazewell, Christian and

Will.

MR. AYRES: Madam Chairman, I'd like

to ask some questions about the modeling

method, if I may, to follow-up?

MS. TIPSORD: Please do.

MR. AYRES: Mr. Vijayaraghavan, would

you say that the deposition of mercury from

the atmosphere is a complex phenomenon, one

that is difficult to model with atmospheric

models?

MR. VIJAYARAGHAVAN: Yeah. The

deposition of mercury, much like transport of

sulfate, the deposition of sulfate, all

L.A. REPORTING (312) 419-9292

1378

atmospheric phenomena are complex to model.

And, typically, our modeling system we try to

keep ourselves abreast of scientific advances

and use new laboratory data and such and we

try to publish our book as quickly as

possible. But overall it is a rather complex

science.

MR. AYRES: And the reason why it's so

complex is that there are so many variables

in play, isn't it?

MR. VIJAYARAGHAVAN: Right. Just as

in the modeling of any other atmospheric

species or for that matter a chemical species

such as ozone, mercury is also quite

difficult, that is correct.

MR. AYRES: I think maybe there are

some additional complications and I'll try to

get to those. But let's start by going

through some of the variables that have to be

included, as I understand it anyway. And you

can inform us.

In an atmospheric model like this

to make predictions, first, could you tell us

how you set the initial conditions for your

L.A. REPORTING (312) 419-9292

1379

model? In other words, for the contents of

the air masses in the grid box at the

beginning of the modeling exercise.

MR. VIJAYARAGHAVAN: Right. We

actually set our initial conditions from a

global mercury model that we run so we have a

chemistry transport model that spans the

globe and that provides both initial and

moderate conditions of mercury for our TEAM

modeling.

MR. AYRES: And how did you establish

the boundary conditions, the conditions at

the exterior of the box that your modeling?

MR. VIJAYARAGHAVAN: Right. Again,

the global mercury modeling provides --

(inaudible).

THE COURT REPORTER: Provides what

conditions?

MR. VIJAYARAGHAVAN: The global

mercury model provides boundary conditions of

mercury. And, again, our global mercury

model has been well published in the peer

review literature.

L.A. REPORTING (312) 419-9292

1380

MR. AYRES: And is there a name for

that model?

MR. VIJAYARAGHAVAN: Yeah. It's

called CTM.

MR. AYRES: CGM?

MR. VIJAYARAGHAVAN: C, as in

chemistry, T as in transport, M as in model.

CTM.

MR. AYRES: And is that a model that

you developed?

MR. VIJAYARAGHAVAN: Yeah. The model

originated out of Harvard University.

Originally, it was the G-I-S-S circulation

model. And a variation of this model is also

used by Harvard University currently. And

those are the origins for that model.

MR. AYRES: Is that known as

Geos-Chem?

MR. VIJAYARAGHAVAN: That is correct.

Yes, sir.

MR. AYRES: Where in the United States

is the actual highest observed deposition of

mercury in terms of regions?

L.A. REPORTING (312) 419-9292

1381

MR. VIJAYARAGHAVAN: Well, we are

talking about observed deposition here and

observed deposition is typically wet

deposition because dry deposition

measurements are harder because they have to

measure mercury concentrations and then

estimate the dry deposition. Whereas with

wet deposition, you measure the mercury

content in the rainfall.

So when we talk about observed

deposition, we have to necessarily talk about

observed wet deposition. And, typically, the

higher areas of deposition are Florida, for

example, along the gulf coast and part of the

northeast.

MR. AYRES: Are you aware that the

Geos-Chem model predicts the highest

deposition of mercury in the U.S. in the west

from Wyoming south toward Mexico?

MR. VIJAYARAGHAVAN: The recent paper

by Harvard University on the Geos-Chem

actually had a very good performance

evaluation against the mercury deposition

network. So their highest depositions

L.A. REPORTING (312) 419-9292

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correspond well with observed deposition.

MR. AYRES: Is this a change from the

earlier version or what?

MR. VIJAYARAGHAVAN: I do not -- this

is a model that's used by Harvard University,

again, and published by them so, I'm sorry, I

do not know the answer to your question.

MR. AYRES: Okay. Then you have to

include emissions, some variable for

emissions in your model, correct?

MR. VIJAYARAGHAVAN: Yes. That is

correct.

MR. AYRES: How do you determine the

mercury emissions for purposes of your model?

MR. VIJAYARAGHAVAN: Mercury emissions

are obtained from different inventories. For

example, you have mercury. Obviously, you

have both anthropogenic and natural

emissions. In anthropogenic emissions, you

have emission from utilities, from

automobiles and such. So we tend to go to a

variety of sources. There isn't one single

source that we use for our information.

Again, we've published about two to three

L.A. REPORTING (312) 419-9292

1383

papers that discuss the mercury emissions

inventory used in our modeling system.

One of the examples would be, for

example, the National Emissions Inventory.

For power plants, we have EPRI'S

well-documented inventory for mercury --

speciated mercury emissions and such.

MR. AYRES: It is true, though, isn't

that, there are very few actual measurements

of mercury from -- mercury emissions from

power plants?

MR. VIJAYARAGHAVAN: If you looked at

a percentage of the total power plants in the

country, yes, you do not have a majority of

the plants with continuous emission monitors,

which is relatively a state of the science.

So there is some level of scientific

estimation that goes into this emissions

modeling.

MR. AYRES: And we know that mercury

content in coals varies by quite a bit, don't

we?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And we also know that

L.A. REPORTING (312) 419-9292

1384

pollution control equipment can affect the

mercury emissions?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And we also know, don't

we, that the chlorine content of coal can

affect mercury emissions?

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: So there are a number of

things which could be affecting emissions

from actual power plants, most of which have

not been measured? They may have been

measured in individual places, but they're

not commonly measured?

MR. VIJAYARAGHAVAN: Right. If your

question is has every single plant in the

U.S. measured actual mercury emissions, the

answer would be no.

MR. AYRES: So to some extent, there's

guesswork involved in trying to create one of

these inventories?

MR. VIJAYARAGHAVAN: Right. There is

some level of uncertainty in emissions.

MR. AYRES: So then once you have --

your model has emitted the mercury in the

L.A. REPORTING (312) 419-9292

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air, it has to try to simulate the chemistry

of those emissions in the atmosphere, doesn't

it?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: Where do your assumptions

on the chemistry come from for this modeling

exercise?

MR. VIJAYARAGHAVAN: Right. As I

mentioned earlier, we obtained laboratory

data, kinetic data, reviewed the literature,

we've published a few papers ourselves. One

of the earliest papers on mercury chemistry

was published by our vice president,

Dr. Seigneur. That would be a 1994 paper.

And this is one of the seminal books on

mercury chemistry.

So we both actively researched

this and at the same time keep ourselves

informed about new laboratory data and

kinetic data, and that would be as published

in the literature. And that would be our

primary source of information.

MR. AYRES: That data is not based on

measurements in the atmosphere downwind of

L.A. REPORTING (312) 419-9292

1386

power plants, though, is it?

MR. VIJAYARAGHAVAN: Mercury -- we are

talking about fundamental mercury chemistry.

Mercury chemistry can be determined both in a

lab and in the field. And to answer your

question, no. There is an example of

measurements actually made downwind of power

plants, for example, as published by

Edgerton, et al., in 2006. There is evidence

of --

MR. AYRES: Published by whom? I'm

sorry.

MR. VIJAYARAGHAVAN: Spelling,

E-D-G-E-R-T-O-N.

MR. AYRES: Okay.

MR. VIJAYARAGHAVAN: (Continuing) --

which shows there is some reduction of

mercury -- divalent mercury to elemental

mercury happening in power plant plumes.

MR. AYRES: You testified that mercury

comes in a reactive form, which you call Hg2,

as we've seen in the different notations.

MR. VIJAYARAGHAVAN: Right. Hg2

because that's the correct chemical

L.A. REPORTING (312) 419-9292

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nomenclature. But as you rightly point out,

it's typically referred to as RGM or reactive

gaseous mercury.

MR. AYRES: And then a less reactive

elemental form, which you denoted, Hg0,

right?

MR. VIJAYARAGHAVAN: Yes. Again,

because it's a zero oxidation state.

MR. AYRES: Yeah. So Hg2 or the

reactive gaseous mercury is deposited readily

through wet deposition while Hg0 or elemental

mercury is not readily deposited, correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: So your model needs to

make assumptions about how much of each

species of mercury is emitted and also take

account of the chemical reactions that take

place once it is emitted into the atmosphere,

correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: Would you say that those

atmospheric reactions are well understood or

poorly understood or what?

MR. VIJAYARAGHAVAN: I wouldn't say

L.A. REPORTING (312) 419-9292

1388

they are understood with 100 percent

certainty. Mercury chemistry is a dynamic

science. And as I mentioned before, both

keep ourselves abreast of new data as

published in the literature and published a

few papers ourselves, as well.

MR. AYRES: In the atmosphere, as I

understand it, there are transformations back

and forth perhaps from these two species once

they are in the air?

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: And, in particular, there

is some transformation of Hg2 into Hg0; is

that correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And you need to account

for that change in your model?

MR. VIJAYARAGHAVAN: Right. We do.

There are two aspects to that. Just very

briefly, these transformations that Mr. Ayres

is referring to could both happen in the gas

phase or in cloud droplets. And we account

for the reduction of divalent mercury to

elemental mercury in the aqueous phase. But

L.A. REPORTING (312) 419-9292

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there is some new evidence that this also

happens in the gas phase and that would lower

our power plant contributions to

deposition -- the simulated contributions.

But we do not account for that.

MR. AYRES: So somewhere in your model

there is an equation or an algorithm or -- I

don't have the right term -- a gadget which

attempts to reproduce that rate of the

transformation from Hg2 to Hg0, right?

MR. VIJAYARAGHAVAN: Right. There are

several such reactions, right.

MR. AYRES: And could you tell the

Board whose rate reactions you used in there?

Are those ones you generated or are they ones

you take from the literature?

MR. VIJAYARAGHAVAN: Yeah. They came

from the literature. They've been reported

in our paper published, that would be

Seigneur, et al., 2006(a).

Mercury chemistry is a dynamic

science and there is continuously new data

available on whether the oxidation of Hg0 to

Hg2 is happening faster or slower. And,

L.A. REPORTING (312) 419-9292

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similarly, the reduction, as Mr. Ayres is

referring to, is happening faster or slower.

There are some papers that show that the

reduction is happening slower. But, again,

there are other books that point out that

even if this reduction wasn't happening, a

surrogate reduction or a similar reduction

has to happen to justify the measured

concentrations of mercury in the atmosphere.

MR. AYRES: Would some of that work

have been done by someone named -- I think

it's Ariya or Ariyat? I'm not sure I have

the name correct.

MR. VIJAYARAGHAVAN: Yeah. Ariya.

That would be Dr. Parisa Ariya.

MS. TIPSORD: Could you spell that for

the record?

MR. VIJAYARAGHAVAN: Yes. The first

name Patrick, Apple, R-I-S-A. The last name

is A-R-I-Y-A.

MS. TIPSORD: Thank you.

MR. AYRES: And is it her coefficients

that you used in your model?

MR. VIJAYARAGHAVAN: Excuse me.

L.A. REPORTING (312) 419-9292

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MS. BASSI: Just one second, please.

(Brief pause.)

MR. VIJAYARAGHAVAN: So the answer to

the question would be the use of the data of

Behkonen spelled B-E-H-K-O-N-E-N, and Lin,

L-I-N.

MR. AYRES: Do you know of the work of

a Dr. Heinz or Mr. Heinz on this issue?

MR. BONEBRAKE: Mr. Ayres, do you have

a spelling on the name?

MR. AYRES: I believe it's like

ketchup, but I'm not sure.

MR. VIJAYARAGHAVAN: No, I'm not

familiar with that.

MR. AYRES: You're not familiar with

that? Okay. Does your model include halogen

chemistry?

MR. VIJAYARAGHAVAN: Yeah we include

chlorine chemistry.

MR. AYRES: I couldn't hear you.

MR. VIJAYARAGHAVAN: Chlorine

chemistry.

MR. AYRES: Chlorine chemistry.

MR. VIJAYARAGHAVAN: There is also

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some evidence that another halogen bromine

could oxidize elemental mercury to divalent

mercury, thereby increasing the global

contribution of mercury to deposition in the

U.S., but we do not account for that.

MR. AYRES: And what rate coefficients

do you use for the halogen chemistry?

MR. VIJAYARAGHAVAN: So that would be

elemental mercury plus chlorine gas going to

HgCL2, a rate constant of 2.6 times ten to

the negative 18 centimeter cubed per molecule

per second. The reference is Ariya, et al.,

2002.

MR. AYRES: So you're using the

coefficients developed by Ariya?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And does your model

include a variable for the effect of sea salt

and its associated bromines and other

halogens?

MR. VIJAYARAGHAVAN: Only chlorine.

MR. AYRES: Only chlorine?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: Meteorology is another

L.A. REPORTING (312) 419-9292

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variable that must be included in an

atmospheric model like yours; isn't that

correct?

MR. VIJAYARAGHAVAN: That's correct.

MR. AYRES: Could you tell us how

that's taken into account in your model?

MR. VIJAYARAGHAVAN: Yes. We use

meteorology from the Nested Grid Model which

is a model developed by NOAA, the National

Oceanic and Atmospheric Administration. We

obtained wind, pressure and temperature from

the NGM. We also obtained clouds and

precipitation from actual observations of

several thousand stations both from NCAR and

NATP databases.

MR. BONEBRAKE: Can you spell out

those acronyms?

MR. VIJAYARAGHAVAN: Yes. The

acronyms would be NCAR, N-C-A-R, and N-A-T-P.

MR. AYRES: Dr. Keeler explained in

his testimony to the Board that his studies

showed precipitation events were very

important in determining the deposition of

mercury. Does your model include empirical

L.A. REPORTING (312) 419-9292

1394

data on precipitation events and storms?

MR. VIJAYARAGHAVAN: I think I got

your question right except for the last

two words. Did you say precipitation --

MR. AYRES: And storms.

MR. VIJAYARAGHAVAN: -- In storms.

MR. AYRES: And storms. Perhaps it's

the same thing.

MR. VIJAYARAGHAVAN: Firstly, we used

clouds and precipitation from actual

observations at several thousand stations.

In terms of precipitation from storms, all

this is accounted for in the meteorology that

is not present in the model. And, in fact,

there is evidence now that thunderstorms that

could penetrate the stratosphere actually

wash out the global mercury -- all of global

mercury that is up there and deposit it as

reactive mercury. And that is something that

we did not account for so we underestimate

the global contribution of mercury to

deposition because of that.

MR. AYRES: So does the model include

some sort of algorithm that simulates storm

L.A. REPORTING (312) 419-9292

1395

events or how does it work?

MR. VIJAYARAGHAVAN: No, it does not.

And because of that reason, sometimes we tend

to underestimate global contributions.

MR. AYRES: But you said there is data

there from --

MR. VIJAYARAGHAVAN: Yeah. The data

does not account for these intense

thunderstorms. I presume you're talking

about these severe thunderstorm events --

MR. AYRES: Yes.

MR. VIJAYARAGHAVAN: And, no, we do

not account for that.

MR. AYRES: You do not account for

that?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: Okay. Now, don't some of

these variables we've been discussing vary in

a predictable and rather continuous way? For

example, the emissions from a power plant

probably vary according to time of day

because load varies in a predictable way from

one time of day to another?

MR. VIJAYARAGHAVAN: That is correct.

L.A. REPORTING (312) 419-9292

1396

MR. AYRES: Would a model such as

yours be at its best in dealing with such

predictable, continuous phenomena?

MS. BASSI: Would you define what you

mean by "at its best", please?

MR. AYRES: I think it says what it

says.

MS. BASSI: Well, what is its worst?

It doesn't make sense to me.

MR. AYRES: I think the witness

understands the question.

MR. VIJAYARAGHAVAN: My understanding

is your question is how does the model

account for such events? Is that it.

MR. AYRES: No my question is isn't it

easier -- I'll put it another way. Isn't it

easier for a model such as yours to account

for phenomena that are regular, continuous,

predictable?

MR. VIJAYARAGHAVAN: Right. Again, by

definition of grid-based model, it tends to

discretize continuous events. So you're not

capturing the exact continuum. Instead, you

are replacing it by discrete events. So

L.A. REPORTING (312) 419-9292

1397

you're not -- it's actually capturing --

you're capturing the essence of the event.

MR. AYRES: But some of the phenomena

that can affect deposition are very

discontinuous and unpredictable, aren't they?

For example, thunderstorms.

MR. VIJAYARAGHAVAN: True. And that

is a problem you face. But chemistry

transport models are the only -- such as

TEAM -- are the only type of models that can

be used to do a predictive modeling. And

even in those situations you're going to run

into events where, for example, the state

wants to control emissions in 2009 or 2010.

Can you predict intense thunderstorm activity

in 2009 and 2010? No, you can't. So you

have to go with typical events rather than

unique occurrences, which could eschew those

simulated results but are not representative

of typical situations.

MR. AYRES: If thunderstorms are an

important determinant of deposition, then

that would a limitation on the ability to

predict in your model, wouldn't it?

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1398

MR. VIJAYARAGHAVAN: Yeah. In fact,

the model because of that it tends to

under-predict the global contributions

because as I mentioned before, you have these

intense thunderstorms called overshooting

tops. So the atmosphere is typically divided

into the troposphere and the stratosphere and

then a couple of layers above that. You have

these intense thunderstorms that penetrate

the upper troposphere and the lower

stratosphere and you have -- there's now

evidence that there's a global pool of

mercury and you're washing out that mercury

in thunderstorms. So the model event -- yes,

by not capturing these thunderstorms, the

model is not capturing that global pool of

mercury so it's actually we are

over-predicting local or regional

contributions.

MR. AYRES: Well, wouldn't it also

fail to predict the local or regional

contributions, as well, if it didn't take

into account thunderstorms?

MR. VIJAYARAGHAVAN: Yeah. That

L.A. REPORTING (312) 419-9292

1399

component, which appears in thunderstorms,

that is correct.

MR. AYRES: And didn't Dr. Keeler say

in his testimony to the Board in June that

most of the deposition he measured in

Steubenville occurred during storm events?

MR. BONEBRAKE: Object to Mr. Ayres'

characterization. The testimony says what

the testimony says.

MR. VIJAYARAGHAVAN: I mean, if you

can show me which page I can read it and say,

yes, that's what he said.

MR. AYRES: All right. I have no more

questions of this witness.

MS. TIPSORD: All right. Then let's

do the slide presentation.

(Brief pause.)

MR. VIJAYARAGHAVAN: This presentation

is about the modeling work regarding the

mercury proposed rule. The atmospheric

chemistry of mercury is a tiny size. It's

quite complex. Mercury exists in three

forms; elemental, divert and Hgp. There's

Hg0, Hg2 and Hgp existing in both a gaseous

L.A. REPORTING (312) 419-9292

1400

and aqueous phase. In the aqueous phase they

are referring to droplets of liquid droplets

in the atmosphere. And as discussed earlier

today, we have continuous --

MS. TIPSORD: Excuse me, could you

move over here because she can't see your

face and she needs to see you. It helps her

to be able to see you. Thank you.

MR. BONEBRAKE: Are you hearing him

okay?

THE COURT REPORTER: I'll be better

now.

MR. VIJAYARAGHAVAN: So these three

species of mercury transform between each

other in the atmosphere. So we can show

mercury is accounted for by gaseous oxidation

and reductions between Hg0, Hg2 and also

absorption to particulate matter. And these

three species of mercury speciation form

because they have very different deposition

characteristics.

Hg0 is not very soluble in water

and has a very low dry deposition velocity so

it can be transported globally. There is

L.A. REPORTING (312) 419-9292

1401

some demonstrated evidence of anthropogenic

emissions of mercury being transported from

Asia to the U.S. and that's largely because

of the low deposition characteristic of Hg0.

So it tends to be transported globally.

Hg2, on the other hand, is very

soluble. It's about a million times more

soluble than Hg0 and it also absorbs readily

on surfaces so it tends to be rapidly removed

both by wet and dry deposition with a

relatively shorter lifetime because of that.

Hgp is mostly in the fine particle

range and its characteristics tend to be

between Hg0 and Hg2 so Hgp will remain in the

atmosphere for several days if you don't have

precipitation. If you have rain, it's going

to wash it out just as in Hg2.

The model of atmospheric mercury

that we used is called TEAM, which is Trace

Element & Analysis Model. This is part of

our multi-scale modeling system that I will

be discussing next. The meteorology is from

the 1998 meteorology, winds, temperature and

pressure from the Nested Grid Model of NOAA,

L.A. REPORTING (312) 419-9292

1402

the National Oceanic & Atmospheric

Administration, and clouds and precipitation

from observations obtained from several

thousand stations from NCAR, N-C-A-R, and

NADP, the National Atmospheric Deposition

Program.

Emissions from EGUs or electrical

generating units were obtained -- were

developed by Charles River and I'm going to

be discussing that in a subsequent slide.

These are developed both for 2006 and future

year emission scenarios.

Emissions from non-EGU sources for

1998/1999 meteorology were updates done for

waste incinerator emissions. The modeling

domain or the grid that we used has a 20

kilometer horizontal grid spacing that is

over the central and eastern United States.

And the boundary conditions for this model

were obtained from our global mercury model

that we discussed earlier. And this is of

extreme importance because, again, in long

range transport of mercury it is important to

use good boundary conditions.

L.A. REPORTING (312) 419-9292

1403

The next slide shows a schematic

of our multi-scale modeling system. The CTM

global model stands alone and has a grid

resolution or grid spacing that provides

speciated boundary conditions of mercury both

temporary and it's widely varying. TEAM, our

continental model, this box right there, and

that, in turn, provides speciated mercury

conditions of mercury to our regional model

while in grid TEAM. So all of the maps I'm

going to be showing you today are from this

regional grid, which has a 20 kilometer

horizontal grid spacing.

The modeling system known as TEAM

has been published in the literature as being

well evaluated both using wet deposition from

the Mercury Deposition Network and speciated

air concentrations of mercury. The

performance evaluation has been published in

the peer-reviewed literature.

Also, we have compared the TEAM

deposition over Lake Michigan with estimates

by Drs. Landis and Keeler. It's called the

Lake Michigan Mass Balance Study. And those

L.A. REPORTING (312) 419-9292

1404

are estimates for wet, dry and total

deposition are comparable.

The TEAM simulated contribution at

Steubenville was 62 percent, which is within

the range reported by Dr. Keeler as part of

his study which was 70 percent plus or minus

15 percent. And, again, TEAM was part of a

multi-scale modeling system which includes

global mercury model, which is also being

well evaluated against the data.

In this part of the study we used

different emission scenarios. All of these

scenarios used the same meteorology, boundary

conditions and emissions from sources other

than power plants. So the only thing

different between the different scenarios was

emissions from EGUs.

In particular, we did five

different emission scenarios. The first was

a 2006 scenario, one we refer to as 2006

base.

The second would be a zero-out of

all coal-fired power plants in the U.S. In

essence, we take all coal-fired power plants

L.A. REPORTING (312) 419-9292

1405

in the U.S. and set the mercury emissions

from those power plants to zero and that is

our zero scenario or scenario number two.

Scenario number three was a 2010

CAIR and CAMR scenario. So the clean air and

the state rule and the clean air mercury rule

is applied to all states in 2010.

And scenario number four is an

Illinois rule scenario where we get a 90

percent reduction in Hg emissions from all

EGUs in Illinois. Note that we do not apply

the TTBS.

For EGUs in other states, we used

2010 CAIR/CAMR emissions. Note that mercury

emissions for EGUs in all states for all

these scenarios were provided by CRA

International.

And, finally, scenario number five

was a 2020 CAIR and CAMR scenario for all

states. So to summarize, again, we have five

scenarios; a base scenario, a zero scenario,

a 2010 CAMR scenario, a 2010 CAMR with the

Illinois rule scenario, and a 2020 scenario.

Here are the results from the base

L.A. REPORTING (312) 419-9292

1406

scenario. What you see on here is wet plus

dry deposition of Hg2 in the 2006 base case.

These are mercury emissions from all sources

and result in deposition that arises because

of the transport and deposition of those

mercury emissions.

This is figure one in my

testimony. The units are not very clear on

this graphic. They are micrograms per square

meter per year. The yellows and pinks and

reds are areas with higher deposition. In

general, we find that the mercury deposition

that's between 10 to 30 micrograms per square

meter over the area here over mostly lakes in

the United States were scattered areas

between 30 and 50 micrograms per square

meter. And I studied the areas higher than

30. If we look closer at Illinois, the

mercury deposition ranges from typically

between 10 and 20 micrograms per square meter

with scattered areas between 20 and 30 and

isolated cells higher than 30.

The next graphic is a similar

slide of the zero-out scenario number two.

L.A. REPORTING (312) 419-9292

1407

So, in essence, we suspect mercury emissions

from all U.S. coal-fired power plants are

zero. These are the simulated deposition

fluxes of mercury. This corresponds to

figure two in my testimony. Again, the units

are micrograms per square meter per year.

The deposition fluxes in Illinois are between

10 and 20 micrograms per square meter with

some isolated areas higher than 20

micrograms.

Moving on to scenario number

three, which corresponds to figure three in

my testimony, this graphic shows the total,

i.e., wet plus dry deposition of mercury in

the 2010 CAIR/CAMR scenario. The units,

again, are micrograms per meter per year.

The deposition of mercury in Illinois ranges

for the most part from 10 to 20 micrograms

per square meter, but in some scattered areas

are greater than 20 micrograms.

So far we've looked at the base

scenario, a zero to all U.S. coal-fired power

plants, and the 2010 CAIR/CAMR scenario.

Next, we look specifically at the

L.A. REPORTING (312) 419-9292

1408

Illinois rule scenario. Here we use

CAIR/CAMR for other states and for Illinois

we use the Illinois rule. This corresponds

to particular testimony. So, again, what we

see here is wet versus dry deposition of

mercury in micrograms per square meter per

year in the Illinois rule scenario or

scenario number four.

The deposition of mercury ranges

from 10 to 20 micrograms per square meter

over most of Illinois. To get a better sense

of what impacts these different scenarios

have, I'm going to be showing later different

slides so you can see what is the difference

from the base to each of these scenarios.

That gives us a better idea of how much

impacts or how much reductions in deposition

we are seeing because it's kind of hard to

compare the two deposition slides. So that's

going to be coming up shortly.

And, finally, to the next slide we

look at scenario number five, which is a 2020

CAIR/CAMR scenario. And that was chosen

because this is what was proposed by U.S.

L.A. REPORTING (312) 419-9292

1409

EPA. This corresponds to figure five in my

testimony. Given, again, our graphics on

here, what you see is where it describes

deposition of mercury. Over most of Illinois

the deposition is between 10 and 20, but in

some isolated areas in southern Illinois

there are greater than 20 micrograms.

Moving on to the next slide, this

is a big picture or a summary, if you will,

of the deposition in Illinois in the

different scenarios. So the different rows

correspond to the five scenarios. Note that

the order is slightly different from the

slides shown before. So the order in years

is 2006 base, 2010 CAIR/CAMR scenario, then

the Illinois rule scenario, 2020 CAIR/CAMR

scenario, and the scenario where U.S.

coal-fired emissions is zero.

This table was adapted from Table

one in the testimony. It has similar

information but the units have been changed

to pounds per year from milligrams per year.

The first column here shows the total wet

plus dry deposition of mercury in pounds per

L.A. REPORTING (312) 419-9292

1410

year in each of these scenarios. In the 2006

base, it's 7704 and decreases by 5 percent to

the next scenario, which is 2010 CAIR/CAMR.

So the second column you'll see on

here is additional benefit or decrease you're

going to get going from one scenario to the

next. So going from the base to 2010 CAIR

and CAMR, you see a 5 percent decrease in

deposition.

Going from a 2010 CAIR/CAMR to the

Illinois rule scenario, you see an additional

four percent decrease in deposition.

Going to the 2020 CAIR and CAMR

scenario, you see an extra 5 percent

reduction in deposition. And most of this is

happening because of the reductions you're

seeing in emissions from power plants in

other states resulting in a lower deposition

in Illinois.

And, finally, the zero-out all

U.S. coal-fired power plant emissions is an

additional 6 percent. The last column

here -- the second column we are looking at

additional benefits or a percent difference,

L.A. REPORTING (312) 419-9292

1411

if you will, between any scenario and the

next scenario.

The last column, on the other

hand, shows the percent it changed from the

2006 base scenario. So you're going with

5 percent in 2010 CAIR/CAMR, 10 percent, that

is more like 9.5 percent that's being rounded

off to 10 percent for the Illinois rule, and

with 2020 CAIR/CAMR we have 14 percent and

with the zero we have 19 percent.

This 19 percent, again, is the

same number we discussed earlier today, the

effect of all U.S. coal-fired power plants on

deposition in Illinois. And I have

highlighted this 4 percent here and, again,

in the box below a 4.4 percent decrease in

Illinois mercury deposition is the additional

reduction in deposition you get in going from

the 2010 CAIR/CAMR scenario to the Illinois

rule scenario.

The next few slides show

differences in deposition between two

scenarios. Here you have the 2010 CAIR/CAMR

minus the 2006 base. So the greens, the

L.A. REPORTING (312) 419-9292

1412

blues and the dark blues represent regions

where the 2010 CAIR/CAMR results in lower

deposition data than in the 2000 base. This

is figure six in my testimony. One can see

that the model simulates between one and

10 micrograms per square meter, decreasing

deposition typically in large parts of

Illinois. And I know it's hard to tell, but

there are a few areas which are higher than

ten. Again, the units are microgram per

square meter. So this is a change in total

deposition going from the 2006 base to the

2010 CAIR/CAMR scenario.

The next slide is going to show

the same thing. So now we are on slide 16,

which shows the percent change in deposition

of mercury from the 2006 base to the 2010

CAIR/CAMR scenario. This is figure seven in

my testimony. The units here are percent.

So the model simulates between 1 and 10 or

less than 10 percent decrease in deposition

over most of Illinois. And in scattered

areas shows a decrease between 10 and

30 percent.

L.A. REPORTING (312) 419-9292

1413

The next slide we are comparing

the 2010 CAIR/CAMR scenario with the Illinois

rule scenario. So slide 17 shows the change

in total deposition of mercury between the

Illinois rule scenario and the 2010 CAMR

scenario. Again, the greens and blues

reference areas where the mercury deposition

is lower than the Illinois rule. This is

figure eight in my testimony.

In terms of decreases, most of

Illinois has less than 2 micrograms per

square meter of mercury deposition, lower

than Illinois rule as compared to the 2010

CAIR/CAMR scenario. Isolated areas have

decreases that are greater than

two micrograms per square meter.

This is another representation of

the same plot, but this time there is a

percent change. So slide 18 shows a percent

change in deposition of mercury between the

2010 CAMR scenario and the Illinois rule

scenario. In essence, this tries to simulate

what is the additional reduction in

deposition you're going to get when you go

L.A. REPORTING (312) 419-9292

1414

from the 2010 CAIR/CAMR scenario to the

Illinois rule scenario. So the additional

reductions you will get from the position of

the Illinois rule.

Large parts of Illinois have

between 1 to 5 percent decreases in

deposition. Some scattered areas have

between 5 and 15 percent and a few isolated

grid cells have between 15 and 35 percent.

This is from figure nine in my testimony.

MS. BASSI: Does this also show

increases in deposition in some places?

MR. VIJAYARAGHAVAN: Yes. So there

are a few scattered areas where you see some

increases in deposition and that is because

the slides change, suggesting the rate of

retrofits at these locations. But we expect

most of these increases to disappear by 2015.

This is a representation of

another slide, but just so we are comparing

slides with the same scale, this one is

figure eight in my testimony but with the

same color scale as figure six. So I'm going

to flip back and forth between this slide and

L.A. REPORTING (312) 419-9292

1415

the next one. So both of them have the same

color scale, but this slide shows a

difference between the Illinois rule and the

2010 CAMR, and the next slide is going to

show the difference between the base and the

CAMR. So you're going from base to CAMR and

then CAMR to Illinois rule. So if you flip

back and forth and focus on --

MR. AYRES: Can I ask a question at

this point?

MR. VIJAYARAGHAVAN: Yes, please.

MR. AYRES: Would you say the -- if

you could back up slightly there. When you

talk about the -- from the map with the

CAIR/CAMR impact on it. It was just before

you moved to the end, I guess. No, the next

one.

MR. VIJAYARAGHAVAN: Comparing base to

CAMR.

MR. AYRES: The question is -- it

doesn't matter. That's fine. When you say

CAIR or CAMR, are you talking about when we

reach full implementation of CAMR?

MR. VIJAYARAGHAVAN: Yeah. This is as

L.A. REPORTING (312) 419-9292

1416

implemented in 2010. Not --

MR. AYRES: I was trying to find the

next slide.

MS. TIPSORD: Just go to the next

slide.

MR. AYRES: That one, number one.

That's the 20 -- I'm sorry. I'm looking for

the one that's 2020.

MR. VIJAYARAGHAVAN: We haven't gotten

to that. Are you talking about a different

plot or actual deposition?

MR. AYRES: I thought this was 2020.

MR. VIJAYARAGHAVAN: No. This is

2010.

MR. AYRES: Do you have a 2020?

MR. VIJAYARAGHAVAN: Yeah. I'm sure

there's one here. I haven't come to that

yet.

MR. AYRES: What is assumed here in

terms of mercury reductions? It is assumed

that the actual emissions of mercury will be

at or below the CAMR cap at that point?

MR. VIJAYARAGHAVAN: Yeah. For all

states other than -- are you talking about

L.A. REPORTING (312) 419-9292

1417

Illinois? Yes. This is at or below the CAMR

cap, yes.

MR. AYRES: And you recall that that

rule provides for banking and trading?

MR. VIJAYARAGHAVAN: Yeah. And if you

want, these emissions were developed by CRA

International, specifically for 2010

CAIR/CAMR scenario taking into account

whatever needs to be taken into account going

back into the necessary -- but the question

is probably more appropriate for CRA.

MR. AYRES: We don't have them in

front of us.

MR. VIJAYARAGHAVAN: Right. But I can

just state --

MR. BONEBRAKE: Just so the record is

clear, Ann Smith from CRA was available to

provide testimony and she was here last week.

MR. VIJAYARAGHAVAN: But I see your

question. Yes, it does (inaudible) --

THE COURT REPORTER: I didn't hear

you.

MR. VIJAYARAGHAVAN: I said it does

take into account.

L.A. REPORTING (312) 419-9292

1418

So, now, again, we're comparing

two different situations going from 2006 base

to 2010 CAMR and going from the 2010 CAMR to

Illinois rule. If you go to look at this in

terms of percent, this is slide 21, so if you

compare slides 21 and 22, they are the same

color scale. This gives you a sense of what

are the differences between the two

scenarios. So I'm not going to go over this

because it's a repeat of what I showed

before, that slide 21 is just a repeat of

another slide, which is the color scale

change. So 21 and 22 are shown together

again just for additional comparison.

For example, here in 21, you'll

see that the percent decrease is between 1 to

10 percent decrease is going from 2010

CAIR/CAMR to Illinois rule scenario. And if

you go to slide 22, you'll find that, again,

most of Illinois is between 1 to 10 percent

decrease with some isolated areas from 10 to

30 percent decrease.

These slides are shown for

reference. Note that we are comparing the

L.A. REPORTING (312) 419-9292

1419

Illinois rule scenario and 2020 scenario.

Note that the 2020 scenario is obviously not

the same point in time as the Illinois rule

scenario, but just to get a sense of how much

the change would be.

This is the Illinois rule scenario

minus the 2020 CAIR/CAMR. Here, you find up

to one to five micrograms per square meter

higher in most areas with some isolated

areas. For example, in Pennsylvania, they

are much higher. In Illinois, the southern

part of the state shows between one and five

micrograms per square meter per year is

higher in the Illinois rule scenario compared

to 2020 CAIR/CAMR. And, again, note that

this Illinois rule scenario and 2010 so one

should keep that in mind when looking at this

slide.

The next slide is a similar slide

with the sign of the percent change. So this

shows you how much higher deposition you're

going to get in terms of a percent between

Illinois rule and the 2020 CAIR/CAMR rule.

This is slide 24 and corresponds to figure 11

L.A. REPORTING (312) 419-9292

1420

in my testimony. Again, keep in mind that

the Illinois rule refers to the 2010

scenario.

Moving on, in conclusion, the TEAM

mercury modeling system was applied to

simulate atmospheric mercury deposition in

the central and eastern United States, in

particular over Illinois.

Five different emission scenarios

for coal-fired power plants were modeled.

Ninety percent controls of Illinois EGU

Illinois rule are simulated to achieve a

4.4 percent additional decrease in mercury

deposition compared to the 2010 CAIR/CAMR

scenario.

Most of Illinois experiences a 1

to 5 percent decrease in deposition, but a

few areas in the northeastern and central

parts of the state exhibit between 5 and

15 percent decreases and a few isolated areas

between 15 to 35 percent decrease.

As mentioned earlier, deposition

reductions in the vicinity of EGUs are likely

over-estimates due to artificial plume

L.A. REPORTING (312) 419-9292

1421

dispersion and there is also potential Hg

reduction happening in power plant plumes.

Note that there are no hot spots

in the 2010 CAIR/CAMR scenario when compared

to the 2006 base. Thank you.

(Whereupon, after a short

break was had, the

following proceedings

were held accordingly.)

MS. TIPSORD: Back on the record. I

believe we're ready for question number six.

MR. AYRES: I think there's some

questions that occur as a result of the slide

show.

MS. TIPSORD: Okay.

MR. AYRES: First, the percentage

numbers that you've given in the slides that

you've shown to the Board just a moment ago,

those numbers are strongly dependent on the

size of the grid cell, aren't they?

MR. VIJAYARAGHAVAN: Right. In

theory, the percentage numbers change,

increase, with the size of the grid cell.

But, again, when you go to find a grid cell

L.A. REPORTING (312) 419-9292

1422

at the size of the grid cell because of

artificial vertical dispersion you might

actually be over-estimating your

contribution. So if the model shows, say,

35 percent in the vicinity of a power plant,

it may actually in reality may be lower than

that.

MR. AYRES: Would it be appropriate to

conclude from your slides that the Illinois

rule about doubles the reduction over the

2010 CAMR/CAIR rule -- reduction in

deposition in Illinois I meant. I believe

you say it's about a 5 for CAIR and CAMR and

another 5 percent for Illinois rule?

MR. VIJAYARAGHAVAN: Yeah. If you

take the first significant digit --

MS. TIPSORD: I'm sorry. I didn't

hear all of that.

MR. VIJAYARAGHAVAN: I'm sorry. If we

take it to the first significant digit, the

2010 CAIR/CAMR gives you a 5.3 percent

decrease in deposition and the Illinois rule

gives you an additional 4.2 percent. And

that gives us a sense of how much additional

L.A. REPORTING (312) 419-9292

1423

decrease in deposition we can expect given

the limitations on the over-estimates that

we've mentioned before -- given the inherent

uncertainties that have been discussed

before.

MR. AYRES: I'd like to get to the

uncertainties in a few minutes. So it

approximately doubles?

MR. VIJAYARAGHAVAN: Well, 5.3 to 4.2,

which is I would say if you went -- so you do

not get as much as you get going from the

base to 2010 CAMR, but 80 percent of that

extent. Does it make sense? So if you get

5.3 percent with the CAIR/CAMR scenario, you

get an extra 4.2 percent with Illinois rule

scenario.

MS. TIPSORD: Just so I'm clear -- and

I'm not a mathematician at all -- you get 5.3

and then plus 4.2?

MR. VIJAYARAGHAVAN: Correct. So the

4.2 is the additional, exactly.

MR. BONEBRAKE: And then just for

further clarification, we're talking about

comparisons as of 2010 as opposed to any

L.A. REPORTING (312) 419-9292

1424

comparison to the effect of CAIR/CAMR as of

2020?

MR. VIJAYARAGHAVAN: Yes. We are

talking about 2010.

MS. TIPSORD: Mr. Harley, do you have

a follow-up on that?

MR. HARLEY: Yes. For the record,

Keith Harley. My follow-up question to that

is that 4.2 percent additional reduction that

would be achieved, that would be achieved

every year between 2010 and when CAIR/CAMR

would eventually be fully implemented in

2020?

MR. VIJAYARAGHAVAN: One would have to

model year-specific emissions to actually

determine that. And that's what chemistry

transport models are used for. What one can

state with this information is in 2010 that

is the additional reduction that you will

see.

MR. HARLEY: Have you modeled the

annual reductions that would be expected 2011

through --

MR. VIJAYARAGHAVAN: No, sir.

L.A. REPORTING (312) 419-9292

1425

MR. HARLEY: -- 2020?

MR. VIJAYARAGHAVAN: No.

MR. HARLEY: Thank you.

MS. TIPSORD: Mr. Ayres?

MR. AYRES: Your, I believe it's

figure eight, appears to show that most of

the benefits of the Illinois rule are in

Illinois; isn't that correct?

MR. VIJAYARAGHAVAN: Yeah. But if you

look at figure 9, which shows a percent,

which is the same figure but as a percent

change, one can see impacts in Missouri,

Indiana, Michigan and so on. And there is a

small -- as the plume gets diluted, you see

smaller and smaller impacts so that some of

that is hidden in the white color which is

not displayed so it's less than a percent

change.

MR. AYRES: And if you could look at

figure -- I believe it's figure ten, although

I'm not sure I kept up with the blur of

figures, but it varied --

MR. BONEBRAKE: For clarification, can

you tell us what the page number is in the

L.A. REPORTING (312) 419-9292

1426

PowerPoint presentation?

MR. VIJAYARAGHAVAN: Or do you have

the title of the figure?

MR. AYRES: No.

MR. VIJAYARAGHAVAN: Which figure are

you referring to.

MR. AYRES: Maybe it's in here.

MR. VIJAYARAGHAVAN: It's also in the

testimony. Can you tell us what figure in

the testimony.

MS. TIPSORD: It's on Page 23 of

PowerPoint. It's figure ten.

MR. VIJAYARAGHAVAN: So I have a

change in total deposition of mercury between

Illinois rule scenario and 2020 CAIR/CAMR.

MR. AYRES: Yes. Figure ten in the

testimony, which I guess is on Page 23 of the

slide show --

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: -- which shows a

difference between Illinois rule and 2020

CAIR/CAMR.

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: Would it be correct to

L.A. REPORTING (312) 419-9292

1427

read that as indicating the Illinois rule is

essentially providing the benefits of the

2020 CAMR rule in 2010?

MR. VIJAYARAGHAVAN: Pardon me?

MR. AYRES: That perhaps together with

figure nine on Page 21.

MR. VIJAYARAGHAVAN: Can you clarify

your question.

MR. AYRES: Yes. Would it be

appropriate to conclude -- maybe that's the

way to put it -- that the Illinois rule is

providing the benefits -- largely the

benefits of 2020 CAMR rule in Illinois in

2010 comparing the --

MR. VIJAYARAGHAVAN: Well, it's not --

MR. AYRES: -- comparing Page 23 where

you indicate what the 2020 CAMR rule does

with Page 21 where you indicate what the

Illinois rule does.

MR. VIJAYARAGHAVAN: Well, the

Illinois rule does not give you the benefits

of 2020 CAIR/CAMR because as seen in figure

10, in the southern parts of the state and

part of the western areas of the state you

L.A. REPORTING (312) 419-9292

1428

have higher depositions in the Illinois rule

scenario.

MR. AYRES: But if you'll look at Page

23 again, figure ten?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: It appears to me, at

least, that this is a difference in

comparison, right? It's the difference

between the Illinois rule scenario and the

2020 CAIR/CAMR rule scenario?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And what it seems to show

is that there is essentially no difference in

the state of Illinois between those two? Is

that a misreading of what it's saying?

That's what that white areas means, isn't it?

MR. VIJAYARAGHAVAN: Right. But, you

see, several of the areas in the southern

part of the state, south central and the

western parts of the state that show between

1 and 5 and if you look at the next slide

that shows --

MR. AYRES: I do see that. But most

of the territory is white, is it not?

L.A. REPORTING (312) 419-9292

1429

MR. VIJAYARAGHAVAN: Right. And if

you look at the next slide, which shows the

percent change, so now I'm looking at figure

11 in my testimony, you can see there is

between a 1 and 5 percent change in almost

all of the state and parts of the state are

higher than 5 percent. So the 1 to 5 number

is an absolute number in figure ten. If you

look at a percent change, you'll see between

1 and 5 percent change in most of the state.

MR. AYRES: All right. That's about

all we can say based on those PowerPoint

presentations.

MS. BASSI: I have a follow-up,

please.

MS. TIPSORD: Ms. Bassi?

MS. BASSI: Krish, what is the best

use of a deposition model in demonstrating

how a control technology will work? Is it in

the presentation of the absolute amounts that

are being deposited or is it in showing the

change that results from the application of

controlled technology?

MR. VIJAYARAGHAVAN: Yeah. One would

L.A. REPORTING (312) 419-9292

1430

be more interested in the change or the

relative change in deposition that arises out

of the controls.

MS. TIPSORD: I only heard part of

that. I'm sorry.

MR. VIJAYARAGHAVAN: Sorry. One would

be more interested in the change or the

relative change in deposition that is arising

out of a result of those controls.

MS. TIPSORD: So I guess the bottom

line is the figure that you say shows a 1 to

5 percent difference in CAIR/CAMR as in 2020,

you're saying that under CAIR/CAMR in 2020

there would be 1 to 5 percent less deposition

in mercury in Illinois --

MR. VIJAYARAGHAVAN: Yes.

MS. TIPSORD: -- than under the

Illinois rule?

MR. VIJAYARAGHAVAN: Yes, Madam

Hearing Officer.

MS. TIPSORD: And that's modeling the

federal CAIR rule and CAMR, correct?

MR. VIJAYARAGHAVAN: Yes, ma'am.

MS. TIPSORD: Mr. Harley?

L.A. REPORTING (312) 419-9292

1431

MR. HARLEY: Is that under the

Illinois Rule 2010?

MR. VIJAYARAGHAVAN: Right. To

clarify, as I mentioned in my presentation,

we are looking at the Illinois rule under

2010, so one should keep that in mind when

comparing.

MR. HARLEY: So by 2020, if we wait

for CAMR/CAIR to fully roll out, we will

experience a 1 to 5 percent reduction in

mercury deposition in Illinois --

MR. VIJAYARAGHAVAN: Which is more

than what you would get going from CAIR/CAMR

in 2010 to Illinois rule.

MR. HARLEY: I need to complete my

question.

MR. VIJAYARAGHAVAN: Please.

MR. HARLEY: Are you comparing 2010

Illinois rule to 2020 CAIR/CAMR?

MR. VIJAYARAGHAVAN: That is correct.

MR. HARLEY: Thank you.

MR. AYRES: So the conclusions that

you can draw to the extent that you believe

the predictions of the model are that the

L.A. REPORTING (312) 419-9292

1432

Illinois rule will about -- and I'll say it

this way again -- about doubled the

deposition benefits of the 2010 CAIR rule

when it goes into effect in about 2010 and

that by 2020 the federal CAIR/CAMR rule will

catch up and slightly pass the impact of the

Illinois rule; is that a fair statement?

MR. VIJAYARAGHAVAN: I would rephrase

that. No, that would not be a fair

statement. Let's rephrase. You are on the

right track but let me rephrase it.

MR. AYRES: Please.

MR. VIJAYARAGHAVAN: So we are

comparing three scenarios here. We're

starting from today in 2006, we are looking

at 2010 CAIR/CAMR, and then we're looking at

the additional reduction you would get with

Illinois rule, and then the additional

reduction you would get with the 2020

CAIR/CAMR.

So, again, you would get a 5.3

percent reduction going from now to 2010

CAIR/CAMR, an additional 4.2 percent

reduction going to Illinois rule and about an

L.A. REPORTING (312) 419-9292

1433

additional 4 percent going to CAIR/CAMR in

2020.

MS. TIPSORD: Can I ask you a question

right there?

MR. VIJAYARAGHAVAN: Yes, ma'am.

MS. TIPSORD: So 5.2 (sic) percent

plus four point --

MR. VIJAYARAGHAVAN: Uh-huh.

MS. TIPSORD: So from 2006 to 2010, if

the Illinois rule is implemented --

MR. VIJAYARAGHAVAN: 9.5 percent.

MS. TIPSORD: And then in 2020?

MR. VIJAYARAGHAVAN: 14 percent.

MS. TIPSORD: 14 percent?

MR. VIJAYARAGHAVAN: Yes.

MS. TIPSORD: But that 4.2 that we've

had from 2010 to 2020 disappears if we don't

do the Illinois rule, right? So you come

back to -- at 2020 then you would have

10 percent?

MR. VIJAYARAGHAVAN: (Witness

nodding.)

MS. TIPSORD: And have had 10 years

where you didn't have any additional

L.A. REPORTING (312) 419-9292

1434

reduction from the Illinois rule?

MR. VIJAYARAGHAVAN: That is correct.

MS. TIPSORD: And I'm sorry for

interrupting in the middle of your question,

but I'm finding myself extremely confused by

this. I apologize.

MR. GIRARD: Can I ask a question,

though? Going back to figure 9 in your

testimony, which was the percent change in

total deposition of mercury, Page 18,

deposition of mercury between Illinois rule

scenario and the 2010 CAIR/CAMR. This figure

shows the 4.2 percent reduction in the

Illinois area on up where our wind blows.

But can you tell me why down in northeast

Texas this would show an increase in the

mercury deposition?

MR. VIJAYARAGHAVAN: Right. See, you

have a slight change in the allowance markets

for mercury --

MS. TIPSORD: You need to speak up,

please.

MR. VIJAYARAGHAVAN: So a change in

the allowance markets for mercury, SO2 and

L.A. REPORTING (312) 419-9292

1435

NOx suggests a delay in the retrofitting

of -- retrofits in plants at these locations

and that is what's causing these increases in

deposition. But they are minimal and they're

expected to disappear by 2015.

MR. AYRES: So is that the result then

of the training program? Is that what you're

saying?

MR. VIJAYARAGHAVAN: At this stage, I

think I should state, again, that the

emissions were developed by CRA International

and these questions are of better interest to

them.

MS. TIPSORD: Anything else on the

slide presentation?

MR. AYRES: No.

MS. TIPSORD: Mr. Harley?

MR. HARLEY: Approximately, how many

grid cells -- 20 kilometers square grid cells

are there in the state of Illinois?

MR. VIJAYARAGHAVAN: Between 400 to

500.

MR. HARLEY: Roughly how many grid

cells in Illinois would experience greater

L.A. REPORTING (312) 419-9292

1436

mercury reduction under CAMR 2010 than they

would under the proposed Illinois rule?

MR. VIJAYARAGHAVAN: There is no such

grid cell. You're talking higher in CAMR

than -- higher reductions in 2010 --

MR. HARLEY: No. Higher deposition.

Higher mercury deposition --

MR. VIJAYARAGHAVAN: Higher mercury

deposition.

MR. HARLEY: -- under CAMR 2010 than

they would under Illinois rule.

MR. VIJAYARAGHAVAN: Under 2010

CAIR/CAMR, yeah, for that we can look at

slide -- or figure eight in my testimony,

which would also be slide 17, which compares

the Illinois rule scenario and the 2010

CAIR/CAMR scenario. So you can see that

there are no such -- we can see that all of

Illinois has, on average, between .5 to 2

lower in Illinois rule scenario than in the

2010 CAIR/CAMR scenario. So there is no grid

cell there that CAIR/CAMR scenario would

result in greater reductions in deposition.

Or to put it another way, CAIR/CAMR would be

L.A. REPORTING (312) 419-9292

1437

higher deposition.

MR. HARLEY: CAIR/CAMR would be higher

deposition in 2010 for virtually the entire

state of Illinois?

MR. VIJAYARAGHAVAN: That is correct.

And the changes are minimal in most of

Illinois but the answer is yes.

MR. HARLEY: Thank you.

MS. TIPSORD: Anything else on the

slides? Why don't we take a ten-minute break

and we'll come back after that.

(Whereupon, after a short

break was had, the

following proceedings

were held accordingly.)

MS. TIPSORD: I just want to note that

the joint statement that was admitted as

Exhibit 125 has been entered in the clerk's

office as public comment 6283, so it is in

the record.

Also, for those of you who saw

that Monday's and Tuesday's transcripts have

arrived, Wednesday's and Thursday's

transcripts are here and available and, as we

L.A. REPORTING (312) 419-9292

1438

speak, Don Brown is trying to get them linked

on the web. So the transcripts from last

week up to Friday are available on the web

page. And with that, I think we're ready for

question number six.

MR. AYRES: Actually, I would like to

ask some questions before we get to question

number six.

MS. TIPSORD: Please do.

MR. AYRES: Mr. Vijayaraghavan, you

testified prior to the slide slow to the

assumptions and projections that are

necessary in order to run the model that you

have run. And those I would just repeat for

the Board, if I might, that those are

boundary and initial conditions, emissions

from power plants, speciation of emissions,

atmospheric chemistry and meteorology. At

least those are the ones we discussed,

correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: In your testimony you say

that your TEAM model can account for about

50 percent of the variance observed in wet

L.A. REPORTING (312) 419-9292

1439

deposition across the U.S. on Page 8?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: So you are attempting to

correlate the output of your model with

actual monitored mercury deposition across

the U.S.?

MR. VIJAYARAGHAVAN: Yes, wet

deposition. That is correct.

MR. AYRES: How many monitors are

there across the U.S., by the way?

MR. VIJAYARAGHAVAN: About 50-plus

monitors.

MR. AYRES: Fifty?

MR. VIJAYARAGHAVAN: Plus.

MR. AYRES: If you were to correlate

the output of your model with monitored

mercury deposition over a smaller geographic

area, say Illinois, how would that affect the

model's abilities to explain the variance?

MR. VIJAYARAGHAVAN: When we compare

the model deposition with the measured wet

deposition in Illinois, the measured wet

deposition is 10.1 micrograms per square

meter and the model deposition is 12.7. So

L.A. REPORTING (312) 419-9292

1440

there is an over-prediction by 26 percent.

MR. AYRES: This is for Illinois?

MR. VIJAYARAGHAVAN: Yes, sir. It's

the MDN monitoring site in Illinois.

MR. AYRES: How many monitoring sites

are there in Illinois?

MR. VIJAYARAGHAVAN: There is one

site.

MR. AYRES: One. Okay. And if you

were to take the output of your model for a

single month and correlate it with the

monitor date of, say, August or July, one of

the summer months, how would that affect the

predictive capability of your model?

MR. VIJAYARAGHAVAN: We have not

compared specific months so one would have to

do such analysis to see what kind of a

comparison is obtained.

MR. AYRES: Wouldn't it tend to reduce

the ability to predict?

MR. VIJAYARAGHAVAN: I don't see why.

MR. AYRES: What does it mean to say

that your model accounts for 50 percent of

the variance?

L.A. REPORTING (312) 419-9292

1441

MR. VIJAYARAGHAVAN: When you compare

model deposition with wet deposition, the

R-squared or the coefficient determination is

statistical quantity that lets you come up

with a correlation between the model

deposition and measured deposition. So what

we are saying is with the level of science

and other mechanisms in the model, we're able

to capture 50 percent of the measured wet

deposition or the variance, if you will. So

in essence it's saying you can attribute or

know for sure that your model captures

50 percent of the wet deposition. In this

particular instance, the wet deposition of

the monitored stations.

You know, we should also note for

the record that we looked at air

concentrations of mercury which have also

been published and, again, we've compared

with monitoring wet deposition data in

Illinois where you get, say, between 10 and

25 percent error. So this gives us a sense

of what are the limitations of the model, as

all models do, what limitations they have,

L.A. REPORTING (312) 419-9292

1442

and as to when new data becomes available, we

try to see how the model can be evaluated

against those data.

MR. AYRES: So your statement about

the variances is equivalent to saying that

you find an R-squared value of about .5?

MR. VIJAYARAGHAVAN: Yes. That is

mathematically correct.

MR. AYRES: That's a statistical

matter?

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: Would you describe that in

statistical terms as a strong correlation?

MR. VIJAYARAGHAVAN: Strong is a

subjective term.

MR. AYRES: I think it's a statistical

term.

MR. VIJAYARAGHAVAN: Right. It is

a -- I do not know the answer to the

question.

MR. AYRES: Okay. Wouldn't an

R-square of 90 percent be evidence of a great

deal stronger correlation?

MR. VIJAYARAGHAVAN: Yes, sir.

L.A. REPORTING (312) 419-9292

1443

MR. AYRES: Isn't it also true that if

you have an R-square of 50 percent, that

means that 50 percent of the variance across

the U.S. is not explained by your model,

correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: In your testimony, you

provide single point estimates of the effects

on mercury deposition of the Illinois control

program and the EPA CAIR/CAMR programs and so

forth and we've discussed earlier to two

decimal -- or two significant figures the

numbers that output from your model.

Wouldn't it be more appropriate in light of

the relatively poor correlation of .5

R-squared to include confidence bands around

those point estimates?

MR. BONEBRAKE: I'm going to object to

the characterization as to poor correlation

that Mr. Ayres has put in his question. I

think he's suggesting that the witness agreed

with that characterization.

MR. VIJAYARAGHAVAN: And I did not.

MR. AYRES: I'll withdraw the word

L.A. REPORTING (312) 419-9292

1444

poor. But let me just ask the question

again, if I may?

Wouldn't you agree that given the

R-squared of .5, it would be informative to

the reader to include confidence bands around

those point source estimates?

MR. VIJAYARAGHAVAN: Yes, it might be

informative. I mean, it depends on the

situation.

MR. AYRES: If you were to put a

confidence band representing the 90 percent

confidence level around the deposition

numbers in your testimony, would it be likely

that they would actually overlap?

MR. VIJAYARAGHAVAN: I would have to

do that analysis to give you an answer.

MR. AYRES: So it would, however --

the 90 percent confidence interval would show

a range rather than a single point source

estimate for each of those numbers, correct?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And with an R-squared

of .5, wouldn't that range be fairly broad?

MR. VIJAYARAGHAVAN: Keep in mind that

L.A. REPORTING (312) 419-9292

1445

this R-squared of .5 that you're talking

about represents one particular evaluation

model and we also evaluate against air

concentrations, also evaluated model output

with estimates of mercury deposition over

Lake Michigan, for example, done by

Drs. Landis and Keeler where the percent

difference between the two estimates are

within 10 to 20 percent.

MR. AYRES: But it is the one that you

offered to the Board in your testimony,

correct?

MR. VIJAYARAGHAVAN: I already stated

in my testimony that deposition estimates are

also comparable with Lake Michigan. And as

some pointed out in the hearings today, the

contributions at Steubenville are within

80 percent and the contribution at the wet

deposition and -- actually, since you bring

it up, in response to a subsequent question,

I have another comparison. In Chicago, at

IIT Chicago, measure wet deposition versus

the model wet deposition. We had

23 micrograms modeled versus 20 measured. So

L.A. REPORTING (312) 419-9292

1446

it's within about 10 to 15 percent higher.

MR. AYRES: Since you mentioned

Dr. Keeler's work, let me ask you a few

questions about that, if I may? When air

quality modeling can account for only

50 percent of the variance on the national

scale, isn't it useful to examine actual

measured data in an attempt to gain insight

from that?

MR. VIJAYARAGHAVAN: Yeah. We do look

at measured data.

MR. AYRES: That's what Dr. Keeler and

his group have done, isn't it?

MR. VIJAYARAGHAVAN: Pardon me?

MR. AYRES: That is what Dr. Keeler

and his group have done, isn't it?

MR. VIJAYARAGHAVAN: What is it that

they have done? I'm not asking a question.

Could you rephrase.

MR. AYRES: Well, in the work that he

testified to, he measured actual deposition,

did he not?

MR. VIJAYARAGHAVAN: That is what he

said in his testimony, yes.

L.A. REPORTING (312) 419-9292

1447

MR. AYRES: At Steubenville?

MR. VIJAYARAGHAVAN: Yes. That is in

his testimony, correct.

MR. AYRES: And that is what he did,

isn't it, to your knowledge?

MR. BONEBRAKE: Objection. He already

commented on what he testified to. Now

Mr. Ayres is asking for this witness to talk

about what Mr. Keeler has done beyond and

above what's in his testimony. I think

that's unfair of this witness. And there's

no foundation that this witness could testify

about what Mr. Keeler has done above and

beyond what Mr. Keeler testified to.

MR. AYRES: Isn't this witness an

expert in this area?

MR. VIJAYARAGHAVAN: Right.

Unfortunately, there is --

MS. TIPSORD: Excuse me. We're

arguing over the objection right now. Just

wait one moment.

MR. AYRES: Isn't this witness an

expert in this area and wouldn't he,

therefore, be familiar with the work done by

L.A. REPORTING (312) 419-9292

1448

Dr. Keeler and others in the area?

MS. TIPSORD: And if I may ask a

question? Were you not present during the

testimony of Dr. Keeler in Springfield?

MR. VIJAYARAGHAVAN: Right. I was.

But what I was going to say was typically

when you're in the field we are familiar with

work done by others in your profession. And

I'm not aware of any publications of Dr.

Keeler regarding the work at Steubenville.

And so my knowledge goes to what he discussed

in his testimony.

MR. AYRES: Okay.

THE COURT REPORTER: Excuse me. It's

better if you don't use the microphone.

MS. TIPSORD: But you need to speak up

then.

MR. AYRES: So he testified that he

measured actual deposition in Steubenville,

correct?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: And then he said he used

sophisticated empirical techniques to

establish footprints identifying different

L.A. REPORTING (312) 419-9292

1449

kind of sources, such as coal-fired power

plants, didn't he?

MR. BONEBRAKE: I'd --

MR. VIJAYARAGHAVAN: But he also --

MS. TIPSORD: Mr. Bonebrake, I'm going

to allow this line of questioning. I think

he's getting to a point and we're going to

give him a little bit of leeway. All he's

asking is if the witness recalls what was

testified to and he's already said he was

present for the testimony. And I assume

we're getting to that point here?

MR. AYRES: We are.

MS. TIPSORD: Thank you. You can

answer the question.

MR. VIJAYARAGHAVAN: Yes. Dr. Keeler

testified that he looked at chemical

footprints of coal-fired power plants. But

he also stated that he would not be able to

differentiate between different types of

coal-fired -- the same type of coal-fired

power plants which varied by location. And I

believe he also stated in that a serious

limitation was the fact that they could go

L.A. REPORTING (312) 419-9292

1450

back only three days in the meteorology. So

these were some of the things I recall about

Dr. Keeler's testimony.

MR. AYRES: And you find his source

apportionment technique consistent with good

scientific practice in the field?

MR. VIJAYARAGHAVAN: One of the

limitations of his source apportionment

technique was that it not account for sources

whose emissions were transported more than

three days away, which is very typical for

mercury. So that would be a serious

limitation of the model.

MR. AYRES: But with that limitation,

you would regard it as good scientific

practice the way he went about it?

MR. VIJAYARAGHAVAN: Keeping that

limitation in mind and also limitations such

as the inability to distinguish between

sources emitting similar types of mercury,

it's hard to quantify it as best scientific

practice. That is a subjective term.

MR. AYRES: All right. But these

methods all have their limitations and your

L.A. REPORTING (312) 419-9292

1451

modeling method does, too, correct?

MR. VIJAYARAGHAVAN: Yes. That is

correct.

MR. AYRES: Okay. And you agree with

Dr. Keeler's conclusion that reductions in

emissions of mercury will result in

reductions in the deposition of mercury.

MR. VIJAYARAGHAVAN: Well, that would

depend on the type of mercury that is

controlled and the type of source.

MR. AYRES: But doesn't your testimony

say that if emissions are reduced, deposition

will be reduced? I thought that's what those

charts showed.

MR. VIJAYARAGHAVAN: Right. I just

said the level of reductions in deposition

would depend on the type of source.

MR. AYRES: I'm just speaking of

direction, not level, at this point.

MR. VIJAYARAGHAVAN: So to answer,

yes, typically, reductions in emissions seem

to indicate that there would be some

reductions in mercury deposition.

MR. AYRES: Okay. Now, Dr. Keeler's

L.A. REPORTING (312) 419-9292

1452

method has certain advantages over air

quality modeling for understanding

deposition, doesn't it.

MR. VIJAYARAGHAVAN: Yes. As you just

pointed out, both models have their

advantages and limitations. A serious

limitation of Dr. Keeler's method is it

cannot be used for predictive modeling.

MR. AYRES: But there's no need to

make an assumption about the initial

conditions or the boundary conditions in his

method, is there?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: And there's no need to

estimate emissions from power plants either,

is there?

MR. VIJAYARAGHAVAN: I'm not aware of

such.

MR. AYRES: And it's also not

necessary to make assumptions about the

atmospheric chemistry of mercury plumes from

power plants, is it?

MR. VIJAYARAGHAVAN: Well, there is an

inherent assumption in the mercury chemistry

L.A. REPORTING (312) 419-9292

1453

when you look at mercury that comes from afar

and get transformed and deposited at, say,

Steubenville. There is an inherent

assumption. Dr. Keeler, for example,

referred to his review of the literature in

coming up with his best understanding of what

the mercury chemistry was.

MR. AYRES: But in order to measure

the mercury deposited as he did, you don't

need to know that?

MR. VIJAYARAGHAVAN: To make a

measurement of mercury deposition, no, you do

not.

MR. AYRES: And in order to do the

analysis of the source type that he did, you

don't need to know that either, do you?

MR. VIJAYARAGHAVAN: Well, again, the

chemistry of mercury is inherently present in

assumptions in his model. So, for example,

Dr. Keeler mentioned how when he did a source

apportionment, mercury that's coming from

afar would probably get oxidized and washed

down before it hits Steubenville. So there

is an inherent assumption of the mercury

L.A. REPORTING (312) 419-9292

1454

consumption so one cannot really separate

mercury chemistry from any type of modeling

that you do.

MR. AYRES: Also, there's no need to

postulate dividing up the atmosphere in the

grid squares or developing layers or anything

of those things either, is there?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: So would it be correct to

say that a major difference between

atmospheric modeling that you present and the

method presented by Dr. Keeler in his

testimony is that his conclusions are based

on real observations, while the output of the

TEAM's model depends heavily on a series of

assumptions?

MR. VIJAYARAGHAVAN: Well, Dr.

Keeler's modeling is based partly on

observations, but it's partly based on

several assumptions that may be erroneous.

For example, the assumption that sources --

there is no long-range transport of mercury,

whereas it has been demonstrated by, say, a

Professor Dan Jaffe at the University of

L.A. REPORTING (312) 419-9292

1455

Washington that their mercury does get

transported over long distances.

MR. AYRES: That's elemental mercury,

isn't it?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: And if that were washed

out of the stratosphere and deposited, that

wouldn't be reactive, would it?

MR. VIJAYARAGHAVAN: To get washed

out, it would have to be reactive.

MR. AYRES: Okay. That's the end of

my questions.

MS. BASSI: Could I follow-up, please?

MS. TIPSORD: Sure.

MS. BASSI: I forgot what I was going

to say. Never mind.

MS. TIPSORD: Mr. Harley?

MR. HARLEY: I'd first like to ask you

a couple questions to make sure that the

record is very clear on a couple points that

were made during the break.

MR. VIJAYARAGHAVAN: Please.

MR. HARLEY: The first question is, is

it your testimony that virtually all of

L.A. REPORTING (312) 419-9292

1456

Illinois will experience lower mercury

depositions under the Illinois rule than

under CAMR/CAIR 2010?

(Witness peruses

documents.)

MR. HARLEY: Without reference to a

table or a chart. I think that you're

well-acquainted with your testimony. I think

you're well-acquainted with the presentation

you gave. Is it your testimony that

virtually all of Illinois will experience

lower mercury deposition under the Illinois

rule than under CAMR/CAIR 2010?

MR. VIJAYARAGHAVAN: We look at

regions where there is less than a -- or

there's greater than a .5 micrograms change

or greater than a 1 percent change. So when

you look at the regions represented in the

find range, the answer may be no. But,

otherwise, its seems to be yes. So that

would be my answer. So it's both yes and no,

depending on the range of deposition you look

at.

So by and large, in most of

L.A. REPORTING (312) 419-9292

1457

Illinois, one could say yes. But it's hard

to tell without actually looking at the data

for every grid cell. And that is not

something I can do at this point.

MR. HARLEY: Is it your testimony that

mercury deposition on average across the

state will decrease between 4 and 5 percent

more under the Illinois rule than under

CAIR/CAMR 2010?

MR. VIJAYARAGHAVAN: Yeah. The

modeling results, the simulated mercury

deposition results, indicate that you would

get an additional roughly 4 percent

reductions in deposition on average in the

Illinois rule when compared to the 2010 CAMR

rule.

MR. HARLEY: Thank you. A few other

questions.

As part of your testimony, have

you quantified mercury emissions from an

individual coal-fired power plant in

Illinois?

MR. VIJAYARAGHAVAN: The emissions

were provided by CRA International and were

L.A. REPORTING (312) 419-9292

1458

directly inputted to the model.

MR. HARLEY: Does your testimony

include any information about mercury

emissions from any individual coal-fired

power plant in Illinois? Not in terms of its

input data, but in terms of your testimony?

MR. VIJAYARAGHAVAN: My written

testimony does not.

MR. HARLEY: Does your testimony

include any information quantifying mercury

emissions from any subgroup of coal-fired

power plants in Illinois? And by way of

explanation what I mean by a subgroup, to

illustrate, in the Chicago air quality region

we have five coal-fired power plants operated

by Midwest Generation, Waukegan, Fisk,

Crawford, Joliet and Romeoville. By a

subgroup, I mean a smaller group of

coal-fired power plants. Do you quantify

mercury emissions from any subgroup of

coal-fired power plants in Illinois in your

testimony?

MR. VIJAYARAGHAVAN: No.

MR. HARLEY: As part of your

L.A. REPORTING (312) 419-9292

1459

testimony, do you characterize the deposition

of mercury from any individual coal-fired

power plant or subgroup of coal-fired power

plants in Illinois?

MR. VIJAYARAGHAVAN: Only to the

extent what we discussed in my presentation

when we looked the at the specific cells that

Madam Hearing Officer was interested in.

MR. HARLEY: But you do not trace

individual grid cell deposition patterns to

any individual source, do you?

MR. VIJAYARAGHAVAN: No, I do not.

MR. HARLEY: Or any subgroup of

sources, do you?

MR. VIJAYARAGHAVAN: No, I do not.

MR. HARLEY: Are you familiar with the

term hot spot?

MR. VIJAYARAGHAVAN: Yeah. There has

been some discussion of that phrase, yes.

MR. HARLEY: Generally, what does that

term mean to you?

MR. VIJAYARAGHAVAN: The term hot spot

has never been clearly discussed or

explained. There have been instances where

L.A. REPORTING (312) 419-9292

1460

people referred to red areas on a color map

as hot spots. There have been instances

when -- I believe it was the U.S. EPA that

related hot spots to a certain methylmercury

level. So there is really no clear

understanding or definition of what a hot

spot is.

MR. HARLEY: Would you agree that

generally a hot spot means a geographic area

disproportionately impacted by deposition of

a pollutant like mercury?

MR. VIJAYARAGHAVAN: I don't mean

to digress here, but if you go back to why do

we call it a hot spot, my understanding is --

and I may be wrong here -- is, again, the

word hot is associated with high levels

because the color red, fire, flame, and so

on, anything that's brighter or more heavily

impacted than other spots. So in that sense,

a hot spot -- it's hard to give an exact

answer to your question. But if your

question was is a high area of deposition --

could it be classified as a high area of

deposition? Yes. But what is a hot spot?

L.A. REPORTING (312) 419-9292

1461

No. I mean, we don't really --

MR. HARLEY: Could a high area of

deposition, as you've just described it or

defined it, be smaller than an area which is

20 kilometers square?

MR. VIJAYARAGHAVAN: I think we went

over this earlier today with Mr. Ayres'

questions. So do you want to go over it

again.

MS. TIPSORD: I don't remember that.

MR. AYRES: I don't think that

question was asked.

MS. TIPSORD: Yeah. I don't remember

that.

MR. VIJAYARAGHAVAN: Okay. So the

issue here is the higher area of deposition

could -- it is possible that a higher area of

deposition could be in a certain location in

a 20 kilometer grid cell, yes.

MR. HARLEY: In light of the fact that

you have not quantified emissions, modeled

dispersion patterns or determined mercury

deposition related to any Illinois coal plant

or subgroup of plants, how can you discount

L.A. REPORTING (312) 419-9292

1462

the potential for hot spots in areas smaller

than 20 kilometers?

MR. VIJAYARAGHAVAN: That's a

mischaracterization of my testimony.

MR. HARLEY: I'll strike the question.

MS. TIPSORD: Okay. Dr. Girard?

MR. GIRARD: I have a quick question

then. Mr. Vijayaraghavan, looking back at

Exhibit 127, which is part of the diagrams

from your PowerPoint -- I'm looking on Page

18 here, figure nine, which is the percent

change in total deposition of mercury between

Illinois rule scenario and 2010 CAIR/CAMR.

Looking at that diagram there, doesn't that

diagram show that under the Illinois rule,

most of Illinois would have a reduction in

mercury deposition when compared to the 2010

CAIR/CAMR?

MR. VIJAYARAGHAVAN: That is correct.

MR. GIRARD: Thank you.

MS. TIPSORD: Ms. Bassi?

MS. BASSI: I had just a couple of

follow-ups to Mr. Ayres' line of questioning

a few minutes ago.

L.A. REPORTING (312) 419-9292

1463

Krish, is there a difference in

purpose or result between deposition modeling

and deposition measurements, such as

Dr. Keeler was performing?

MR. VIJAYARAGHAVAN: Yes. Deposition

modeling, the purpose is predictive modeling.

We are trying to predict or estimate to the

extent that is possible scientifically what

the impact on deposition would be caused by

controlled technologies whereas a deposition

measurement is a snapshot in time, if you

will.

MS. BASSI: Would it be fair to say

that these two approaches are two ways that

examining mercury deposition compliment each

other?

MR. VIJAYARAGHAVAN: Yeah. That is

correct.

MS. BASSI: Thank you.

MS. TIPSORD: Are we ready for

question number six then?

MR. VIJAYARAGHAVAN: Question six: On

Page 16 of his testimony, Mr. Vijayaraghavan

notes that because incinerators emit a higher

L.A. REPORTING (312) 419-9292

1464

fraction of Hg2+ and have shorter stacks than

coal-fired power plants, that it is

inappropriate to extrapolate the results of

an incinerator program to the potential

effects of a coal-fired power plant emission

reduction program.

Question A: Is it likely that

most of the Hg2+ emitted from a coal-fired

power plant unit deposits within 150

kilometers of the emission point? If there

are water bodies in the path of that plume,

would you expect deposition to those water

bodies?

Answer to A: The deposition of

Hg2 would depend on the height of the stack

and the meteorology. Also, there is some

evidence that some fraction of Hg2 may get

transformed to Hg0. In coal-fired power plant

plumes as discussed in the peer-reviewed

literature. The reference was one I had

given before, Edgerton, E-D-G-E-R-T-O-N,

Edgerton, et al., 2006. Thus, one cannot

conclude whether it is likely or unlikely

that most of the Hg2 emitted from a

L.A. REPORTING (312) 419-9292

1465

coal-fired deposits within 150 kilometers of

the emission point. Based on our work

published in the Journal of Air & Waste

Management Association, Seigneur, et al.,

2006(b), less than 7 percent of emissions

from a power plant are estimated to deposit

within 50 kilometers. This is so because the

plume is typically released at an altitude

higher than 100 meters, thereby delaying the

dry deposition; also, wet deposition occurs

only in the presence of precipitation.

And the answer to the second

subquestion: Yes. If water bodies are in

the path of the plume, there would be some

dry deposition to those water bodies. Wet

deposition would depend on the occurrence of

precipitation when the plume crosses the

water body.

MR. AYRES: Can I follow up on that?

MS. TIPSORD: Sure.

MR. AYRES: Is it not true also that

in the literature that there are indications

that there are reactions transforming the

elemental mercury to the reactive form of

L.A. REPORTING (312) 419-9292

1466

mercury as well in the plume in the

atmosphere? The reaction goes in both

directions?

MR. VIJAYARAGHAVAN: Yeah. And the

reactions transforming elemental mercury to

gaseous mercury are by ozone, OH and bromine.

And these oxidants are in limited quantities

in the power plant plume, especially in the

earlier stages of the plume. And so, yes,

the reaction does happen, but to a very

limited extent.

MR. AYRES: But as the plume travels

further away, there are oxidizing agents in

air --

MR. VIJAYARAGHAVAN: Right. But

also --

MR. AYRES: -- that would have that

effect?

MR. VIJAYARAGHAVAN: That is correct.

But also as the plume travels further away,

the plume is more diluted so the mercury

concentrations are also lower

correspondingly.

MR. AYRES: You said that you could

L.A. REPORTING (312) 419-9292

1467

not conclude that most of the Hg2 from a

power plant plume would be -- most of the dry

deposition would occur within 150 kilometers.

If there were a storm that occurred at a

given point while the plume was traveling

along, wouldn't that bring most of the

reactive mercury to the ground there?

MR. VIJAYARAGHAVAN: It would wash out

a lot of the mercury.

MR. AYRES: Okay. Thank you.

MS. TIPSORD: Question B.

MR. VIJAYARAGHAVAN: Question B:

Would you expect there to be a point of

maximum deposition of Hg in the plume of

power plant emissions.

Answer: Yes, there would be a

point of maximum deposition in the plume of

power plant emissions. Note that the maximum

point of deposition varies with time as the

meteorology affects the plume rise and

direction.

Question C: If a deposition model

predicts a point of maximum mercury

deposition from incinerator emissions in a

L.A. REPORTING (312) 419-9292

1468

water body that is close to the source and

predicts a point of maximum mercury

deposition from a coal-fired power plant that

is relatively close to the source, would

there be any difference in the significance

of that information, other than the impact

point from the power plant is probably

further from the source? What I'm trying to

get at here is that Hg2+ from incinerators is

not different from Hg2+ from coal-fired power

plants. The difference is the proportion in

the emission and the distance it will be

transported due to difference release

parameters. Once it comes down, if it comes

down in an impaired water body, it makes no

difference where it came from. If you reduce

the mercury emissions by 90 percent, whether

it's an incinerator or a coal-fired power

plant, wouldn't you expect a 90 percent

reduction in deposition at the point of

maximum impact?

Answer: Yes. There is a

difference in the significance of the

information because, one, the plume is more

L.A. REPORTING (312) 419-9292

1469

diluted when further away from the source

and, two, there is some evidence that some

Hg2 may be reduced to Hg0 in coal-fired power

plant plumes. Reductions in deposition do

not vary linearly with reductions in mercury

emissions because of the contribution of

other sources and the global atmospheric

mercury pool so, no, I would not expect a

90 percent reduction in deposition at the

point of maximum impact but a lower

percentage because the source being

controlled contributes only a fraction of the

total mercury deposition.

MR. AYRES: May I ask a follow-up

question?

MS. TIPSORD: Yes.

MR. AYRES: I ask you to imagine maybe

it's a changeable source. I'm not sure quite

how to describe it but a power plant with a

let's say 300 meter tall stack or a 500

meter, if you wish, tall stack, and an

incinerator with a 150 meter tall stack.

MR. VIJAYARAGHAVAN: It's likely

shorter than that.

L.A. REPORTING (312) 419-9292

1470

MR. AYRES: A shorter stack?

MR. VIJAYARAGHAVAN: Yeah.

MR. AYRES: And you imagine them right

next to each other, let's say. Each is

emitting a plume with mercury in it, but one

much higher than the other. Downwind a few

hundred meters, let's say, there's a

thunderstorm, would you expect the reactive

gaseous mercury in both plumes to be washed

to the ground to a large extent?

MR. VIJAYARAGHAVAN: Right. Some of

the reactive gaseous mercury there is some

evidence that it gets converted to elemental

mercury in the coal-fired power plant plume.

But that which does not get released, yes,

you would expect that to get washed down.

MR. AYRES: So the stack height really

wouldn't make much difference in that

circumstance I described, would it?

MR. VIJAYARAGHAVAN: That is correct.

MR. AYRES: Okay.

MS. BASSI: I have a follow-up on

that.

MS. TIPSORD: Ms. Bassi?

L.A. REPORTING (312) 419-9292

1471

MS. BASSI: Would the velocity of the

emissions going up the stack make a

difference?

MR. VIJAYARAGHAVAN: Yeah. If the

velocity is higher, the plume rises higher

and so the plume gets transported further

aloft so that would make a difference. So

that would lead to lower deposition.

MS. BASSI: Which of those two types

of stacks would you expect to have lower

velocity?

MR. VIJAYARAGHAVAN: I'm not sure

about that.

MS. BASSI: Okay. If the shorter

stack -- he said 150 meters for an

incinerator stack and you said shorter. What

would you expect?

MR. VIJAYARAGHAVAN: I would say less

than 100.

MS. BASSI: Less than 100?

MR. VIJAYARAGHAVAN: Yeah.

MS. BASSI: And was there someplace in

your testimony where you were saying

100 meters was some kind of a magic line?

L.A. REPORTING (312) 419-9292

1472

That stacks that are taller than 100 meters

tend to emit mercury that travels further

away than a stack that is shorter than

100 meters?

MR. VIJAYARAGHAVAN: Well, there is --

I don't think there is a magic number but

typically the ones that are higher would get

transferred aloft and get transported over

longer distances.

MS. BASSI: And so given those two

stacks side-by-side and the types of sources

that are behind those stacks, would you

expect the emissions from the incinerator to

travel as far as the emissions from a power

plant?

MR. VIJAYARAGHAVAN: No, I would not.

MS. BASSI: Thank you.

MR. AYRES: Except in the case where

there's a rainstorm downwind, correct?

That's what you testified earlier.

MR. VIJAYARAGHAVAN: Yeah. At any

given point in space and time whether it is

100 meters away or 10 kilometers away, if

L.A. REPORTING (312) 419-9292

1473

there was rain it would wash out the reactive

gaseous mercury. But we have to keep in mind

that the mercury concentrations are diluted

the further away you are from the stack,

which is typically the case with a taller

stack.

MR. AYRES: Okay. Madam Hearing

Officer, because this is related to the

incinerator issue, it may be a good time to

raise some -- to ask some questions about his

comments on the Florida study and the

usefulness of that study as a -- to inform

the Board's decision.

MS. TIPSORD: Go ahead.

MR. AYRES: In the case of the Florida

study, the source of the emissions which were

affecting the Everglades area was

incinerators, was it not?

MR. VIJAYARAGHAVAN: Part of the

sources were incinerator emissions. But a

paper by

Dr. Guentzel, G-U-E-N-T-Z-E-L, points out

that a monitoring site right there in the

Everglades showed no decrease or very little

L.A. REPORTING (312) 419-9292

1474

decrease in mercury wet deposition in spite

of the large reductions in incinerator

emissions, thereby postulating that sources

that were further away and possibly global

accounted for some of the deposition in

Florida in the Everglades.

MR. AYRES: Well, you're getting

toward the question I wanted to ask. You

mentioned the -- I think it's the Dvonch

study --

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: -- which indicated that

71 percent of the measured deposition was the

result of emissions from local sources; is

that correct?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: Do you know how that study

was done? Was that based on actual

monitoring sites?

MR. VIJAYARAGHAVAN: Well, I believe,

first, there were monitoring sites and also

they estimated what the background was by

looking at monitoring data in a rural site to

get a sense of what is the local contribution

L.A. REPORTING (312) 419-9292

1475

versus a contribution that's more remote.

MR. AYRES: Were there about 17

monitoring sites in that area?

MR. VIJAYARAGHAVAN: I do not recall

the exact number.

MR. AYRES: Okay. Now, in that study

they attempted to explain the pattern of

deposition on a fairly short time basis, did

they not? Meaning short time intervals.

MR. VIJAYARAGHAVAN: Yeah. That is

correct.

MR. AYRES: And on relatively small

spatial areas, as well, correct?

MR. VIJAYARAGHAVAN: Over small areas,

correct.

MR. AYRES: Yeah. And they found

different patterns under different airflow

conditions?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: Could your model have

explained the pattern of deposition that

we're seeing in that study with 20 kilometer

grid cells?

MR. VIJAYARAGHAVAN: Well, our model

L.A. REPORTING (312) 419-9292

1476

does show reasonably good prediction that the

southern Florida Everglades sites I believe

is within about 20 percent, so --

MR. AYRES: Is that --

MR. VIJAYARAGHAVAN: I'm talking about

a comparison of model wet deposition with the

monitored wet deposition.

MR. AYRES: And this is on, what, a

long term average and --

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: -- larger spatial basis.

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: So isn't it true that a

model of this sort you're talking about would

not be appropriate to use if you were talking

about a four to five kilometer distance scale

like some of these measurements?

MR. VIJAYARAGHAVAN: As addressed in

the first question in my testimony, a plume

model is most appropriate to assess Hg

deposition close to an emission source.

MR. AYRES: Of the other studies that

you sited, the studies that you site indicate

that the deposition from localized sources

L.A. REPORTING (312) 419-9292

1477

may have been less. Are any of those from

your shop?

MR. VIJAYARAGHAVAN: Seigneur, et al.,

2004.

MR. AYRES: Just the one.

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: Okay. And as to the --

did you say Guentzel?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: The Guenztel study, how

was that study done?

MR. VIJAYARAGHAVAN: This is part of

the FAMS study, F-A-M-S, where they measured

deposition in precipitation at several sites

in southern Florida and tried to estimate the

contributions again to deposition from those

measurements.

MR. AYRES: And were those based on

monthly deposition samples?

MR. VIJAYARAGHAVAN: I do not recall

if they were based on a particular event base

on different modeling.

MR. AYRES: You don't remember?

MR. VIJAYARAGHAVAN: Yeah. I could

L.A. REPORTING (312) 419-9292

1478

look it up.

(Brief pause.)

MR. VIJAYARAGHAVAN: So it's monthly

integrated precipitation and weekly

integrated particulate samples.

MR. AYRES: So in that instance what

they did, if I may put it crudely, is they

put a bucket out to collect rain samples for

a month and then analyzed that bucket?

MR. VIJAYARAGHAVAN: That would be one

way of crudely putting it.

MR. AYRES: It captures of essence,

though, doesn't it? Doesn't it rain every

other day in the Florida in the Everglades

area?

MR. VIJAYARAGHAVAN: Pardon me?

MR. AYRES: Doesn't it rain about

every other day in the Florida Everglades?

MR. VIJAYARAGHAVAN: It is a very wet

place.

MR. AYRES: So it would be very

difficult to analyze the direction from which

the mercury in the bucket came based on

monthly samples, wouldn't it?

L.A. REPORTING (312) 419-9292

1479

MR. VIJAYARAGHAVAN: But keep in mind

that there, -- for example, there is one

location in Florida which showed no change in

the deposition over the time period they

looked at. So, in essence, what you're

trying to look at is the changes in

deposition that are happening over a period

of time because methylation -- the final

impacts of the mercury that is falling to the

earth is not seen over a period of hour or

days but over a much longer period of time.

MR. AYRES: The Seigneur study, the

one from your shop.

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: Is that a modeling study?

MR. VIJAYARAGHAVAN: Yes, sir.

MR. AYRES: And then the Selin study.

I don't know how you say that.

MR. VIJAYARAGHAVAN: Yes. That's out

of Harvard University. Yes, Selin,

S-E-L-I-N.

MR. AYRES: Yes. I didn't see that

reference. Maybe I missed it in your list.

There is a document that you referred to?

L.A. REPORTING (312) 419-9292

1480

MR. VIJAYARAGHAVAN: Right. That is

in -- so that's in my reference list. That's

the third from the end.

MR. AYRES: Okay.

MR. VIJAYARAGHAVAN: So, yes, it is in

my reference list.

MR. AYRES: And is that study a

modeling study?

MR. VIJAYARAGHAVAN: Yes, sir, that's

a modeling study out of Harvard.

MR. AYRES: So the Dvonch study is the

only one that used a method which is

appropriate to smaller grid squares or

smaller areas of deposition and took

monitored samples on a regular and frequent

basis; is that correct?

MR. VIJAYARAGHAVAN: No, it would not

be correct to say that was the most

appropriate method because the method they

used to determine the local versus regional

contribution is flawed in the sense that they

look at deposition at a remote site and

quantified that as the background, if you

will. So, no, I would not -- the answer

L.A. REPORTING (312) 419-9292

1481

would be no.

MR. AYRES: But that's the only one

that's based on regular --

MR. VIJAYARAGHAVAN: No. The study by

Guentzel is also based on measurements.

MR. AYRES: On monthly measurements.

Not on short term measurements.

MR. VIJAYARAGHAVAN: Yes. And, again,

we are looking at effects that are happening

over a period of time and not over a period

of hours or days.

MR. AYRES: On the conclusions of that

study, of the Florida study that you discuss,

we know that the source of the emissions --

well, maybe you won't agree with this. I

don't know. But certainly the state of

Florida believed that the source of emissions

which were affecting the Everglades that they

measured were primarily local; is that

correct?

MR. VIJAYARAGHAVAN: Well, I do not

believe -- I do not know what the state of

Florida believes or not. But there is

evidence that, for example, you have these

L.A. REPORTING (312) 419-9292

1482

intense thunderstorms that you just talked

about, again, wash out the global pool of

mercury and there are sites in southern

Florida which had -- a site, for example,

which had no decrease in deposition with the

changes in incinerator emissions. So it

would be not an easily-justifiable

conclusion.

MR. AYRES: We don't have a lot of

natural experiments, so to speak, that allow

us to look at the effects of large reductions

in mercury emissions, do we? Wouldn't this

be about the only one where there were large

reductions in mercury emissions and we had

the ability and did, in fact, carry out

studies of mercury in the tissue of animals

and birds?

MR. VIJAYARAGHAVAN: I'm not aware of

any study or a natural event which involved a

large reduction in mercury.

MR. AYRES: But in Florida there was a

large reduction in localized emissions over a

short period of time, wasn't there?

MR. VIJAYARAGHAVAN: There was a

L.A. REPORTING (312) 419-9292

1483

reduction -- a significant reduction in

incinerator emissions, yes.

MR. AYRES: About 93 percent during

the early '90s perhaps?

MR. VIJAYARAGHAVAN: Yeah. About

90 percent over a period of several years.

MR. AYRES: And the investigators in

Florida who were taking samples of fish and

bird feathers -- fish flesh and bird feathers

concluded that there were large reductions in

the mercury in that tissue that occurred

afterward, but within a fairly short period

of time afterward of these large emission

reductions, did they not?

MR. BONEBRAKE: I'm going to object to

that question to the extent that Mr. Ayres is

asking the witness to opine about what some

individual or individuals may have concluded.

If your question is relating to a particular

section or a part of a report, you may ask

him about that report. That seems to me to

be an appropriate question. But as framed,

you seem to be asking him to speculate about

what people may have thought about results in

L.A. REPORTING (312) 419-9292

1484

Florida.

MR. AYRES: I'm sorry if I gave that

impression. I'm referring to a report which

was issued by the Florida Department of

Environmental Protection, which I'm sure the

witness knows.

MS. TIPSORD: Excuse me, Mr. Ayres.

Is that in the record here?

MR. AYRES: It is not in the record, I

don't think. But we can certainly make it

available.

MR. BONEBRAKE: There was a --

MR. AYRES: The witness is aware of

that, isn't he?

MR. BONEBRAKE: I think there was a

Florida report that was put in the record, if

I recall correctly, from the first set of

hearings in Springfield. I don't happen to

know what the number is.

MR. AYRES: It would be that one, yes.

MR. VIJAYARAGHAVAN: There may have

been an exhibit. I don't recall the exhibit

number.

L.A. REPORTING (312) 419-9292

1485

MR. AYRES: I don't either. But if

that was put in evidence, it would be that

report that I'm speaking of.

MS. TIPSORD: All right. Let me check

because I'm not comfortable with you asking

him questions about a report that's not a

part of the record. I have Exhibit 20,

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 from the Florida Department of

Environmental Protection, October 2002.

MR. AYRES: That's correct. That's

the testimony I'm speaking of.

MS. TIPSORD: Thank you.

MR. AYRES: Now may I go ahead and ask

my question?

That report reports a large

reduction in the measured mercury content of

fish and bird specimens over a fairly short

period after these emission reductions were

made, does it not?

MR. BONEBRAKE: I'm going to object to

L.A. REPORTING (312) 419-9292

1486

the characterization of the report. It

speaks for itself and I believe there was

testimony that was provided at the first

hearing in Springfield about the fact that

there were some increases and decreases. So

I think that the question inaccurately

characterizes the report as described in

testimony provided in the June hearings.

MR. AYRES: I believe the report shows

that there were about 80 percent reductions

in the measured mercury concentration of fish

and bird samples in large parts of the

Everglades.

MR. BONEBRAKE: But I guess my problem

here is -- I'll finish my objection -- is

we're talking about a report and the report

is not before any of us. We all have

recollections about what the report said that

we have from two months ago when we read it

and there was testimony about it. And I

think it's unfair for Mr. Ayres to be

characterizing the report as it was described

in testimony two months ago without

presenting a copy of the report to the

L.A. REPORTING (312) 419-9292

1487

witness.

MS. TIPSORD: I think that's

legitimate because I can't --

MR. AYRES: I'll withdraw the

question.

MS. TIPSORD: I mean, if you want to

ask him if he recalls the report and a

specific question about the report, if he can

answer that. But I think to characterize

that the report says this, is that correct, I

think is unfair without presenting it.

MR. AYRES: All right. Let me do it

the other way.

MS. TIPSORD: Okay.

MR. AYRES: Do you recall this report,

the Florida report in question?

MR. VIJAYARAGHAVAN: Yes, I do.

MR. AYRES: And does that report, in

your view, report reductions of 80 percent or

more in the concentrations of mercury found

in the flesh of fish and the feathers of

birds in the Everglades?

MR. VIJAYARAGHAVAN: I do not recall

the specific numbers.

L.A. REPORTING (312) 419-9292

1488

MR. AYRES: Okay.

MS. TIPSORD: Question number seven.

MR. VIJAYARAGHAVAN: Question seven:

You are employed as a paid consultant, are

you not? Who is funding the modeling study

you described in your testimony.

Answer: Yes, I am employed as a

paid consultant. The Illinois Utilities

funded our modeling study. Note, however,

that AER's work is a scientific modeling

study that draws upon our research published

over the years in the peer-reviewed

literature. Also, AER's compensation does

not depend on the results of the study.

Question eight: On Page 3 of your

testimony, you state that U.S. coal-fired

power plants contribute less than 1 percent

to the worldwide emissions of mercury. What

do coal-fired power plant contribute to just

the total emissions of mercury in the U.S.?

Are coal-fired power plants the largest

category of mercury emissions in the U.S.?

Coal-fired power plants are

estimated to contribute 44 percent to the

L.A. REPORTING (312) 419-9292

1489

anthropogenic emissions of mercury in the

U.S. The percentage would be lower if one

includes natural emissions of mercury in the

U.S.

Answer to the second subquestion:

Yes, coal-fired power plants are the largest

identified category of mercury emissions in

the U.S. I included the fact that U.S.

coal-fired power plants contribute less than

1 percent to the worldwide emissions of

mercury in my testimony because mercury can

be transported and deposited globally, for

example, to the U.S. from other continents

such as Asia. Measurements that demonstrate

the transport of mercury from Asia to the

U.S. have been, for example, published about

Professor Dan Jaffe, J-A-F-F-E, at the

University of Washington.

Question nine: On Page 6 of your

testimony, you mention the Mercury Deposition

Network. Could you please describe the

Mercury Deposition Network? How many

monitors in the U.S.? How many monitors in

Illinois? Are the monitors located in urban

L.A. REPORTING (312) 419-9292

1490

areas or rural areas? Who operates the

network? Does it measure both wet and dry

deposition? Is the network designed to

measure regional deposition or deposition

from specific sources? Are there any

monitoring data in Illinois that can be used

to evaluate local-scale deposition?

Answer: The Mercury Deposition

Network is a national measurement network of

mercury concentrations in precipitation and

wet deposition and is part of the National

Acid Deposition Program or NADP. There are

about 80 monitoring sites in the U.S. and I

believe seven in Canada and two in Mexico.

There is one monitor in Illinois

at Bondville in Champaign County. The

monitors are typically located in rural

areas. There are a few urban monitors such

as in Indiana, New Jersey, Wisconsin,

et cetera. The MDN monitors are operated by

the Illinois State Water Survey. And they do

a rather good job, if I may add. They

currently measure wet deposition and

concentrations in precipitation and not dry

L.A. REPORTING (312) 419-9292

1491

deposition. The main reason for this is that

dry deposition measurement methods have more

uncertainty than wet deposition methods

because dry deposition measurements are based

on indirect measurements of speciated

mercury, while the latter, that is wet

deposition measurements, are based on actual

collected samples of rainfall. However, the

MDN is currently working on a proposal for a

dry deposition network. Initially, 12

stations in the U.S. would measure speciated

mercury concentrations and then estimate the

Hg dry deposition rates. The MDN network is

typically designed to measure regional

deposition.

Yes, there are data in Illinois

that can be used to evaluate local-scale

deposition. Wet deposition simulated by TEAM

is slightly, i.e., about 15 percent, higher

than the wet deposition measured at IIT

Chicago by Landis, Vette, V-E-T-T-E, and

Keller during the Lake Michigan Mass Balance

Study.

Question ten: On Page 7, you

L.A. REPORTING (312) 419-9292

1492

mentioned that the model you used has a grid

resolution of 20 kilometers. Please describe

the effects of grid resolution on model

performance. What factors influence your

selection of the model's resolution? Is

20 kilometers adequate for regional modeling?

Is 20 kilometers adequate for local-scale

modeling? What would the model show with

respect to mercury deposition near power

plants if finer grid resolution were used?

Answer: Model performance could

improve or degrade with a finer grid

resolution. In theory, model performance

should improve with a finer spatial

specification resolution or grid spacing.

However, there may be some compensating

effects. For example, the overestimation of

vertical diffusion, that was discussed

earlier, in a grid model may be compensated

by horizontal dilution at a 20 kilometer

resolution but not as much at a finer

resolution. We had to consider this factor

as well as the computer CPU time required

when selecting the model's resolution. A

L.A. REPORTING (312) 419-9292

1493

finer grid spacing, of course, would entail

more CPU time. The 20 kilometer grid offers

a good balance and is adequate for regional

modeling in the central and eastern United

States.

As discussed above, or earlier in

this testimony, a plume model is more

appropriate for local-scale modeling than a

grid-based model. Using a grid model,

though, regardless of its spatial resolution,

leads to artificially increased mercury

deposition at the model's spatial resolution

immediately downwind of large point sources

such as power plants.

This work has also been published

in the peer-reviewed literature. The

reference would be Seigneur, et al., 2006(b).

There are two main reasons why a grid model

tends to artificially increase mercury

deposition downwind of elevated point sources

such as power plants and thus the estimates

of deposition may be over-estimates; one,

incorrect enhanced vertical dispersion to the

ground and, second, some evidence of

L.A. REPORTING (312) 419-9292

1494

reduction of Hg2 to Hg0 power plant plumes.

MR. AYRES: You testified a moment ago

that, in theory, a smaller grid resolution

should give greater accuracy, correct?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: But that it might be

counterbalanced by vertical diffusion issues?

MR. VIJAYARAGHAVAN: Yes.

MR. AYRES: Could those be compensated

for by changing the emissioning height or the

size of the vertical grids that you put into

your model?

MR. VIJAYARAGHAVAN: Yeah. We've

actually done -- changed the vertical spacing

in another model called CMAQ-MADRID, which is

again done by our company or it's another

model that's been published in the

literature. And there we see that even with

a change in the spacing, you still see the

artificial vertical dispersion.

MS. TIPSORD: Question number eleven.

MR. VIJAYARAGHAVAN: Question number

eleven: On Page 9 you describe the modeling

scenarios you ran. Is there a reason you did

L.A. REPORTING (312) 419-9292

1495

not run a 2020 scenario with CAIR/CAMR and

with Illinois' proposed 90 percent control?

In your summary of the results on Page 11,

you stated that the 2020 CAIR/CAMR scenario

provides lower mercury deposition than the

2010 scenario with CAIR/CAMR and with

900 percent mercury control in Illinois.

Wouldn't you also expect lower mercury

deposition in 2020 with CAIR/CAMR and with

90 percent mercury control in Illinois than

with just CAIR/CAMR in 2020?

Answer: We selected our modeling

scenarios based on the rules proposed by U.S.

EPA and Illinois EPA. The 2020 CAMR scenario

was based on the rule proposed by the U.S.

EPA and the 2010 scenarios were selected

based on the rules proposed by the Illinois

EPA. Note that fewer differences are

expected to be seen between the 2020 CAMR and

the 2020 CAMR with Illinois controls rather

than between the 2010 CAMR and the 2010 CAMR

with Illinois controls and, hence, we did not

model the 2020 CAMR scenario with 90 percent

Illinois controls.

L.A. REPORTING (312) 419-9292

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MS. TIPSORD: Mr. Harley?

MR. HARLEY: You had more. I'm sorry.

MR. VIJAYARAGHAVAN: I was just going

to complete, but please go ahead.

MR. HARLEY: I would like to call your

attention to Page 14 from your presentation

earlier in the afternoon.

MS. TIPSORD: Exhibit 127.

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: In this table you

contrast the reductions which would be

expected under the 2010 CAIR/CAMR rule with

the reductions which would be expected if

CAIR/CAMR were in effect as well as the

Illinois controls; is that correct?

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: And you actually provide

an estimate through your model of the total

reduction in mercury that would be deposited

between those two programs; is that correct?

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: And the total reduction

that you estimate that would be deposited in

Illinois would be 321 fewer pounds of

L.A. REPORTING (312) 419-9292

1497

mercury; is that correct?

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: So your model predicts

there will be 321 fewer pounds of mercury

deposited in Illinois under the Illinois rule

than under CAIR/CAMR 2010 alone; is that

correct?

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: I want to test your

willingness to take a look beyond 2010 in

light of your expertise as to how that trend

might play out then in 2011. What would you

expect to see in 2011 in terms of reduction

of mercury deposited in Illinois under the --

if we were talking about CAMR/CAIR in 2011

versus the Illinois program?

(Whereupon, a discussion

was had off the record.)

MR. VIJAYARAGHAVAN: I was hesitating

because the modeling study is derived from

emissions that were developed by CRA and one

would really need to conduct the analysis to

answer that question.

MR. HARLEY: You've testified that in

L.A. REPORTING (312) 419-9292

1498

2010 there would be an additional 321 pounds

and you testified that in 2020 the difference

would be much smaller between the two

programs; is that correct?

MR. VIJAYARAGHAVAN: Yes.

MR. HARLEY: That suggests that

between 2011 and 2020 we would see decreases

in mercury deposited in Illinois every year,

but at a smaller amount; is that correct?

MR. VIJAYARAGHAVAN: That makes sense.

MS. BASSI: I'm going to object. The

reason why I'm objecting to this, Mr. Harley,

is because the emissions inputs were provided

to him by CRA International, which he's

testified to and I think that you're asking

him to provide you with numbers between 2010

and 2020 that are -- I mean, those questions

should have been more appropriately addressed

to Dr. Smith.

MR. HARLEY: I'm not asking --

MR. AYRES: These numbers were not

available at the time that Dr. Smith was

available, as I recall.

MR. HARLEY: Ms. Bassi, I'm not asking

L.A. REPORTING (312) 419-9292

1499

for him to provide any numbers. I'm asking

for him to provide an opinion about a general

trend.

MR. VIJAYARAGHAVAN: Right. I can

answer that. I mean, it is difficult to

estimate a trend. It could be flat and then

drop significantly. It is difficult to

quantify or to expect or to estimate a

certain trend without actually doing the

analysis.

MR. HARLEY: It's possible, though,

isn't it, that the benefits to be achieved

through the Illinois rule would continue on

in 2011 in terms of reduced mercury

deposition in Illinois?

MR. VIJAYARAGHAVAN: Again, that would

depend on what the CAIR/CAMR scenario

emissions are from 2011.

MR. HARLEY: You have no opinion on

that?

MR. VIJAYARAGHAVAN: Yeah. My opinion

is that if the CAIR/CAMR scenario emissions

were comparable to the Illinois rule scenario

emissions in 2011, then the reductions, or

L.A. REPORTING (312) 419-9292

1500

the benefits as you called them, would not be

as significant. On the other hand, if the

CAIR/CAMR emissions were not as -- if the

emission were lower in the CAIR/CAMR -- let

me rephrase.

If the CAIR/CAMR emissions in 2011

were comparable to the Illinois rule

emissions in 2011, then the reductions would

not be as much as what we see here. And on

the other hand, if they're not comparable,

then the reductions may continue to occur.

MR. HARLEY: Thank you.

MR. AYRES: May I ask one follow-up

question?

MS. TIPSORD: Please do.

MR. AYRES: Since we're talking about

these reduction figures on Page 14 of his

slide slow, when I asked you earlier whether

you could calculate confidence intervals for

these point estimates, you said that you

couldn't do it right here, you'd have to go

home and calculate it. Could you calculate

the 90 percent confidence levels for the

benefit of the Board and the Illinois EPA?

L.A. REPORTING (312) 419-9292

1501

MR. BONEBRAKE: Are you meaning after

this hearing?

MR. AYRES: After this hearing, yes.

MR. VIJAYARAGHAVAN: This is the kind

of analysis that -- let me think about this

for a second.

MR. AYRES: Well, you did provide us

with a statistical characterization of the

data that explained 50 percent of the

variance and I'm simply asking for you to

provide us also with an additional

statistical characterization that relates to

the likelihood that the numbers that you give

us will be within 90 percent confidence.

MR. BONEBRAKE: I think he's also

explained, Mr. Ayres, a number of other

pieces of information that provides some

confidence regarding his predictions. So I

guess part of what we're wrestling with here

is your question I think is assuming reliance

upon a single statistical test when his

testimony deals with a number of other

corroborating factors.

So I think when you talk about

L.A. REPORTING (312) 419-9292

1502

statistical analysis, I think you're perhaps

ignoring some of the other testimony that the

witness has already put into the record

regarding corroborative points and analyses

that he's done.

MR. AYRES: Well, I'm only asking for

a statistical expression. The 90 percent

confidence level is a statistical term --

MR. BONEBRAKE: I guess if we don't

know whether this kind of statistical

analyses can be done or has been done in this

kind of setting before, I guess that's a

question we can take a look at and then

respond to. I guess I'm getting some

reticence from you and so that's a question

we're going to have to take a closer look at.

MR. AYRES: Okay. Thank you.

MS. TIPSORD: Excuse me. I'm still

really hung up on this difference between

2010 and 2020. It's my understanding, and I

believe the Agency would agree with this,

that we're sort of on a belt curve that

we're going to get 90 percent in 2010 and

everybody else will get there in 2020.

L.A. REPORTING (312) 419-9292

1503

MR. JOHNSON: Seventy percent, right?

MS. TIPSORD: Seventy percent. I'm

sorry. I stand corrected. But Illinois is

doing it faster. That's what this proposal

will do is get us lower emissions faster, I

think. After 14 days-plus, 20 days now of

hearings, I think I've got that much of an

understanding. So, in effect, in 2010 there

is 361 --

MR. HARLEY: Three-hundred-twenty-one

pounds.

MS. TIPSORD: -- 321 pounds less

deposition of mercury?

MR. JOHNSON: Do it as a percentage,

too, like you did before.

MS. TIPSORD: And 4 percent

additional?

MR. JOHNSON: Right.

MS. TIPSORD: So from the years 2010

to 2020 when we level out and the Illinois

rule gives about the same amount of total

amount of deposition as the CAIR/CAMR 2020

and the same percentages as CAIR/CAMR, during

that 10-year period presumably we will have

L.A. REPORTING (312) 419-9292

1504

at least have had the benefit of the

difference -- as CAIR/CAMR comes down, it

will level off throughout the next 10 years,

correct?

MR. VIJAYARAGHAVAN: That is correct.

MS. TIPSORD: So for approximately

10 years, there will be that much less

mercury going into the waters and into the

environment in Illinois, correct?

MR. VIJAYARAGHAVAN: Well, yeah. We

should note that the -- I'm not familiar with

the details but you do see emission

reductions happening significantly in 2015.

So the general trend you're reporting is

correct but it's not necessarily a gradual

trend.

MS. TIPSORD: So let's assume that the

Florida report did say that there was an

80 percent reduction in methylmercury in fish

tissue in that seven-year period, that would

mean then that if that were to carry -- and I

know there are thousands of reasons why it

might not carry through to Illinois but let's

assume that it does, and I know this is a

L.A. REPORTING (312) 419-9292

1505

huge assumption for a scientist and an

engineer -- then that would mean that

Illinois could conceivably see a reduction in

methylmercury in fish earlier than if we wait

until the reduction of CAIR/CAMR in 2020?

MR. VIJAYARAGHAVAN: Yes. But only to

the extent that power plants contribute to

that level of methylmercury.

MS. TIPSORD: Okay. Thank you.

Mr. Harley?

MR. HARLEY: One follow-up question.

Isn't it true that one of the consequences of

CAMR/CAIR in 2020 is that Illinois will also

experience fewer pounds of mercury deposition

because of reductions in other states?

MR. VIJAYARAGHAVAN: That is correct.

MR. HARLEY: Thank you.

MS. TIPSORD: I think maybe I've got

it now.

MR. VIJAYARAGHAVAN: I want to finish

up the answer to question 11. Additional

modeling would be required to predict whether

mercury deposition in 2020 with CAIR/CAMR and

90 percent Illinois mercury control would be

L.A. REPORTING (312) 419-9292

1506

lower than with just CAIR/CAMR in 2020.

Chemistry transport models such as TEAM offer

this predictive modeling capability unlike

receptor models.

MR. AYRES: Madam Hearing Officer,

could we say by now perhaps this question has

been asked and answered? It's been asked in

various pieces, I think.

MS. TIPSORD: Yeah. I think so.

Unless you want to add something additional?

MR. VIJAYARAGHAVAN: Question 12:

What is the importance of precipitation in

deposition? Is it important to ensure that

precipitation is handled properly in the

model, both amounts and locations.

MR. AYRES: I think I'd say the same

of this one.

MS. BASSI: Do you agree?

MR. VIJAYARAGHAVAN: Yeah.

MS. TIPSORD: Question 13.

MR. VIJAYARAGHAVAN: Question 13: On

Page 15, you noted that large convective

storms may extend to the upper troposphere.

L.A. REPORTING (312) 419-9292

1507

What is the typical height of these storms in

the Midwest? Are large convective storms

important for mercury deposition? How are

they handled in grid-based modeling? What is

the height of the top of the model's highest

grid layer? Is it high enough to model large

convective storms? If not, wouldn't the

performance of the model be compromised with

respect to wet deposition from these events?

Large convective storms are

important for mercury deposition sometimes

because they tend to wash out the global pool

of atmospheric mercury. They typically go up

to the tropopause in the Midwest, so you're

looking at roughly 12 to 13 kilometers, but

sometimes these penetrate the stratosphere.

These are typically handled in grid-based

modeling only if the input meteorology

accounts for them. The height of our model's

highest grid layer is six kilometers. This

is not high enough to model large convective

storms.

So the model does not take into

account the deposition of mercury from the

L.A. REPORTING (312) 419-9292

1508

upper atmosphere and the model may,

therefore, underestimate the contribution of

global sources of mercury and conversely may

over predict the U.S. power plant

contributions to deposition.

MR. AYRES: I have no further

questions.

MR. GIRARD: I have a question.

Mr. Vijayaraghavan, do you know of any models

that would have predicted the reduction in

mercury in the fish or bird tissues in south

Florida when the incinerator mercury

condition regulations were changed down

there?

MR. VIJAYARAGHAVAN: I know they used

a mercury cycling model, but that is outside

the area of my expertise.

MR. GIRARD: So you don't know if

anyone tried to go back after we had this

data in hand and tried to see if there were

any models that would have predicted this or

tried to alter any models to show any

relationship between atmospheric mercury and

mercury levels in, say, you know, predator

L.A. REPORTING (312) 419-9292

1509

fish or predator fish and birds?

MR. VIJAYARAGHAVAN: From what I

recall, the mercury modeling study of the

report released by the Florida DEP does

address that but, again -- and they do

discuss some methylation and mercury cycling

in the lake, some modeling of that. But,

again, I'm not familiar with the details.

MR. GIRARD: Thank you.

MS. TIPSORD: I note that Prairie

State Generating also filed some questions,

so if we could go through those.

MR. VIJAYARAGHAVAN: Question one:

Did the TEAM results presented in your

testimony contain any conversion of ionic

mercury to elemental mercury in the plume.

Question A: Are you aware that

measurements by Eric Edgerton,

E-D-G-E-R-T-O-N, at Atmospheric Research &

Analysis, Incorporated, indicate this

conversion occurs?

Question B: How would your

results have been affected if the mercury

conversion were added?

L.A. REPORTING (312) 419-9292

1510

Answer: No. The TEAM results do

not account for any conversion of ionic

mercury to elemental mercury in the power

plant plume.

Answer to A: Yes, I am aware of

measurements made by Eric Edgerton at

Atmospheric Research & Analysis that indicate

that some ionic mercury may be converted to

elemental mercury in plumes from coal-fired

power plants. This work was published in the

peer-reviewed literature, Edgerton, et al.,

2006.

The authors measured air

concentrations of Hg0, Hg2 and Hgp at three

sites in southeastern U.S. They were then

able to associate these Hg measurements with

plumes from six different coal-fired power

plants. And results for such -- for 21 such

plume events showed that total Hg was

conserved, but the Hg0 fraction increased

from 42 percent at the source to 84 percent

in the plume. And one of the possible

reasons suggested by the authors is that some

Hg2 is reduced to Hg0 during transport in the

L.A. REPORTING (312) 419-9292

1511

plume.

We should note that the authors

also suggest three other possible reasons;

loss due to dry deposition, errors in

emission estimates and measurement errors.

However, they explain that each of these

three reasons is unlikely or unlikely to be

the sole explanation.

Answer to B: If this conversion

of ionic to elemental mercury were added in

our model, we would predict lower

contributions of Illinois coal-fired power

plants to local and regional mercury

deposition because elemental mercury has a

much lower deposition rate than ionic

mercury. The exact decrease in the

contributions would depend on the chemical

conversion rate used in the model.

MS. TIPSORD: Question two.

MR. VIJAYARAGHAVAN: Question two:

Have you reviewed the testimony of Dr. Keeler

and the limited information that is available

on his receptor modeling at Steubenville?

Question A: Are Dr. Keeler's

L.A. REPORTING (312) 419-9292

1512

results different and unexpected from the

earlier modeling results of AER or EPA? That

would be U.S. EPA.

Question B: Can a receptor model

be used to make predictions about the future

effects of a regulatory program?

MS. BASSI: Have these been answered

already?

MS. TIPSORD: I don't think they have.

MS. BASSI: Okay.

MR. VIJAYARAGHAVAN: Yes, I have

reviewed the testimony of Dr. Keeler.

Answer 2a: Dr. Keeler in his

testimony reports that according to a

receptor modeling analysis, coal-fired power

plants within about 1000 kilometers are

estimated to contribute about 70 percent of

mercury by deposition in Steubenville in 2004

with an uncertainty of about 15 percent.

TEAM predicts that U.S. coal-fired power

plants contribute 62 percent of mercury

deposition in the grid cell where

Steubenville is located. And this value is

within the range proposed by Dr. Keeler via

L.A. REPORTING (312) 419-9292

1513

receptor modeling. And, therefore, the two

results are somewhat consistent thereby

providing some confirmation that these

results are comparable.

One must note, however, that TEAM

and the receptor modeling techniques have

uncertainties and they are both likely to

overestimate mercury deposition due to the

reasons cited earlier. U.S. EPA, using CMAQ,

predicted that U.S. coal-fired power plants

contributed 43 percent to mercury wet

deposition in the grid cell where

Steubenville is located. However, EPA also

reports that a neighboring cell has a

contribution of 71 percent, thus agreeing

with Keeler's results.

Answer 2b: No. A receptor model

cannot be used to make predictions about the

future effects of a regulatory program. This

fact has also been confirmed by Dr. Keeler in

his testimony.

MS. TIPSORD: Question three.

MR. VIJAYARAGHAVAN: Question three:

Have you reviewed Exhibit 65, Preliminary

L.A. REPORTING (312) 419-9292

1514

Modeling Results for June 2002.

MS. BASSI: Madam Hearing Officer, I

have additional copies of Exhibit 65, if

you'd like them.

MS. TIPSORD: I don't think I have one

with me.

(Document tendered to the

Board.)

MR. VIJAYARAGHAVAN: Question three:

Have you reviewed Exhibit 65, Preliminary

Modeling Results for June 2002? If yes, what

is your interpretation of the data.

Yes, I reviewed Exhibit 65 which

presents results of Illinois EPA's mercury

modeling study for the Illinois rule. The

exhibit consists of a few maps of the U.S.

showing deposition in a base case scenario

and changes in deposition due to the Illinois

rule.

The deposition reductions obtained

in Illinois EPA's modeling study seem to be

lower than those simulated by AER using TEAM.

For example, the maximum reduction anywhere

in the state in summer is about 10 percent

L.A. REPORTING (312) 419-9292

1515

and this is a maximum across the state. The

averages tend to be much lower. Note,

however, that we cannot quantify this more

accurately because of the poor resolution of

the maps and the lack of accompanying text so

it's hard to quantify exactly what is

happening.

MS. TIPSORD: Thank you very much,

Mr. Vijayaraghavan. It's been a pleasure.

MR. VIJAYARAGHAVAN: Thank you.

MR. AYRES: Thank you,

Mr. Vijayaraghavan.

MR. VIJAYARAGHAVAN: Thank you,

Mr. Ayres.

MS. TIPSORD: It's about quarter to

5:00. Let's go off the record for just a

second.

(Whereupon, after a short

break was had, the

following proceedings

were held accordingly.)

MS. TIPSORD: Given the lateness of

the hour and that Mr. Peter Chapman is

available only tomorrow morning, rather that

L.A. REPORTING (312) 419-9292

1516

proceed with Ms. Charnley we will start with

Mr. Chapman in the morning and then with

Ms. Charnley tomorrow afternoon. I thank you

for your patience.

And then after that, if we can get

to Mr. McRanie tomorrow afternoon, we will

attempt to do that. Otherwise we will do on

Wednesday the Dominion Kincaid testifiers,

which are C.J. Saladino, Andy Yaros and

finish with Mr. McRanie. Thank you very

much. We're recessed.

(Which were all the proceedings

had in the above-entitled cause

on this date.)

L.A. REPORTING (312) 419-9292

1517

1 STATE OF ILLINOIS )

) SS.

3 COUNTY OF WILL )

I, Tamara Manganiello, RPR, do hereby

7 certify that I reported in shorthand the proceedings

8 held in the foregoing cause, and that the foregoing

9 is a true, complete and correct transcript of the

10 proceedings as appears from my stenographic notes so

11 taken and transcribed under my personal direction.

______________________________

TAMARA MANGANIELLO, RPR

License No. 084-004560

SUBSCRIBED AND SWORN TO

19 before me this ____ day

of _______, A.D., 2006.

_______________________

22 Notary Public

L.A. REPORTING (312) 419-9292