BEFORE THE ILLINOIS POLLUTION CONTROL BOARDR E

CLERK'S

C E I

OFFICE

V E D

IN THE MATTER OF :

)

SEP 2 0 2666

R06-25

PROPOSED NEW 35 ILL

. ADM. CODE 225

Rulemaking - Air

CONTROL OF EMISSIONS FROM

LARGE COMBUSTION SOURCES (MERCURY) )

TO:

Dorothy Gunn

Clerk

Illinois Pollution Control Board

James R

. Thompson Center

100 West Randolph St ., Suite 11-500

Chicago, IL 60601-3218

SEE ATTACHED SERVICE LIST

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

Illinois Pollution Control Board the

POST-HEARING COMMENTS OF ENVIRONMENT

ILLINOIS AND ENVIRONMENTAL LAW AND POLICY CENTER, a copy of which is

herewith served upon you .

ENVIRONMENTAL LAW AND

POLICY CENTER

Dated : September 20, 2006

Environmental Law and Policy Center

35 E. Wacker Drive, Suite 1300

Chicago, Illinois 60601

312-673-6500

NOTICE

STATE OF ILLINOIS

Pollution

Control Board

Faith E. Bugel

Counsel for Environmental Law and Policy Center

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,pgE THE ILLINOIS POLLUTION CONTROL BOARD

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PROPOSED NEW 35 ILL

. ADM . CODE 225

R06-25

)

CONTROL

OF EMISSIONS FROM

Rulemaking -

Air

)

LARGE COMBUSTION SOURCES (MERCURY))

POST-HEARING COMMENTS OF ENVIRONMENT ILLINOIS

AND ENVIRONMENTAL LAW AND POLICY CENTER

NOW COME Environment Illinois and the Environmental Law and Policy Center

("ELPC"),

by and through their respective attorneys, pursuant to 35 III

. Adm

. Code § 102108,

and offer the following POST-HEARING COMMENTS in the above-captioned proposed rule

:

I.

Introduction

Environment Illinois and the Environmental Law and Policy Center (collectively,

"Environmental Advocates") strongly support the proposed mercury rule now before the Illinois

Pollution Control Board (hereinafter "IPCB"), including the Multi-Pollutant Standard

. The

record now before the IPCB clearly demonstrates the public health and environmental benefits to

Illinois that will be achieved by deeper, faster reductions of mercury emissions from Illinois

coal-fired power plants than under the federal CAMR alone

. This record includes the

comprehensive case presented by IEPA with the testimony of a dozen expert witnesses and

thousands of pages of supporting exhibits and other documents, the case presented by

Environmental Advocates through their expert witness and comments, and in excess of 6000

public comments

. The record is clear that these additional reductions can be achieved using

available technology and without creating disproportionate costs to electric generating units

("EGUs") or consumers, especially in light of the regulatory flexibility mechanisms of the rule

.

The feasibility of achieving these reductions is underscored by the willingness of Ameren and

I

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Dynegy, the second and third largest operators of coal-fired EGUs in Illinois, to support the

proposed rule .

Illinois EPA's rulemaking proposal is consistent with CAMR, which provides an option

for states to develop their own regulatory approaches to control mercury from coal-fired power

plants . 70 Fed. Reg. 28632; see also, 42 U .S .C. § 7416 . At the same time, Illinois EPA's

rulemaking proposal is more advanced and targeted than CAMR in protecting the health, safety

and welfare of Illinois residents, preserving and enhancing Illinois' natural environment for

future generations, and mandating deeper mercury reductions that are nonetheless achievable for

regulated entities operating in this state .

The critical issue in this case is not whether Illinois EPA is justified in regulating

mercury emissions from coal-fired power plants . After all, even CAMR, which the opponents

prefer, does this. Rather, the remaining issue is whether the Illinois EPA proposal will produce

public health and environmental benefits through deeper, faster reductions than those mandated

under CAMR in a manner that is reasonable for regulated entities to achieve

. In these

comments, the Environmental Advocates focus on evidence in the record about Illinois-specific

factors which provide ample justification for going beyond CAMR using the Illinois EPA

proposal .

These comments are accompanied by numerous documents to be added to the record of

these proceedings . In order to expedite review of these documents, the Environmental

Advocates are providing a complete bibliography of all the documents, followed by summaries

of the most important information in each document, sorted by topic

.

2

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II.

Mercury Threatens Illinois Ecosystems, Illinois Residents and Illinois Wildlife .

Long before CAMR and this rulemaking, Illinois specifically identified mercury

as a

major threat to the health of Illinois residents and the quality of Illinois ecosystems

. The Illinois

Department of Public Health has established mercury advisories for all water bodies in Illinois

due to the levels of methylmercury in predator fish . (Pre-filed testimony of James Ross, at 5, see

also TR. 6/12 at 57 ; TR. 6/14 at 97) . In addition, there are 61 river segments (1,034 miles) and 8

lakes (6,264 acres) that are listed as impaired waters due to mercury levels, triggering Illinois'

obligations to impose Total Maximum Daily Load requirements that originate in the Clean Water

Act. (Pre-filed testimony of James Ross, at 5 -

6). Up to three-quarters of tested water bodies

have fish with mercury levels that justify a fish consumption advisory

. (TR. 6/12 at 67) . This

determination is made using U

.S . Food & Drug Administration Action Levels adapted into the

"Protocol for a Uniform Great Lakes Sport Fish Consumption Advisory" by Illinois and seven

other Great Lake states . (Pre-Filed testimony of Thomas C

. Hornshaw, Ph .D., at 2). In fish

tissue sampling conducted between 1988 and 2001, two-thirds to three-quarters of all bass and

walleye from Illinois waters have mercury levels that would justify a consumption advisory

.

(TR. 6/13 at 71) .

A fish consumption advisory cautions against eating more than one fish meal per week

.

(TR. 6/13 at 31)

. However, because this is only an advisory, there is no legal mechanism

actually preventing people from eating any amount of mercury-containing fish from Illinois

waters

. Indeed, the Illinois Department of Natural Resources issues approximately 700,000

fishing licenses annually . (TR. 6/12 at 61)

. One sub-population that is especially susceptible to

mercury, children, can fish without obtaining a license . (TR . 6/16 at 63) . In his testimony, Dr

.

Thomas Hornshaw identifies several studies of the fish consumption patterns of anglers,

3

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including a study of Illinois anglers conducted between 1987 to 1993, which demonstrate anglers

will consume unhealthy quantities of fish even though advisories exist . (Pre-Filed testimony of

Thomas C . Hornshaw, Ph .D ., 4-5). Dr

. Hornshaw concludes, "This review of fish consumption

literature provides convincing evidence that sport anglers may consume amounts of sport-caught

fish that could allow them and their families to exceed health-based limits for chemical

contaminants in their catch ." Id. at 5.

Even if no consumer ate mercury-contaminated fish caught in an Illinois waterway, there

would still be a basis for regulating mercury emissions from coal-fired power plants . In his

testimony, Dr . Michael Murray identified emerging research on the destructive impacts of

mercury on a variety of animal species . Of course, unlike human receptors, animals cannot

attempt to avoid intake of mercury-containing food sources. Dr. Murray identified a Noah's

Ark of species for which research suggested a risk from mercury exposure, including mallard

ducks, loons, belted kingfishers, blue herons, ring-necked pheasants, thrush, insectivorous

passerines, 13 species of freshwater fish, many insect consuming mammals, mink, otters and

aquatic insects . (TR . 8/14 at 71-75) . Notably, this is the list for which research exists

; it is not

the list of all potentially harmed animal receptors .

Because of well-documented conditions in Illinois waterbodies and fish, and the

associated risks to Illinois anglers, fish consumers and wildlife, there is a strong justification to

develop an Illinois-specific regulatory approach to control mercury .

4

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III.

Mercury Deposition in Illinois Will Be Substantially Reduced Under the Proposed

Illinois Rule at a Rate Much Faster and Greater Than What Would Be Achieved

Under CAMR Alone .

Before considering the contribution of Illinois coal-fired power plants to mercury loading

in Illinois, it is important to emphasize that the IPCB is authorized to, and frequently will, issue

regulations that :

•

control only one source category among several that are sources of a pollutant ;

•

control emissions into only one medium like air

;

•

control emissions because of a potential threat to human health or the environment,

without any showing of actual damage that has already occurred ;

•

control emissions from a source category even if this may not lead to a direct or one-

to-one reduction in the exposure rate of any receptor or group of receptors ;

•

control emissions from a source category even if its relative contribution to

cumulative emissions of a pollutant is comparatively small

; and/or

•

implement requirements that originate under one statute, even if other statutes could

also address other aspects of controlling a pollutant .

When measured next to the facts in the record, the Illinois EPA's mercury pollution reduction

proposal greatly exceeds the threshold for regulatory activity .

Illinois' coal-fired power plants are the largest unregulated anthropogenic source of

mercury emissions in the state

. According to the National Emissions Inventory, as

much of 71

of Illinois mercury emissions are from Illinois coal-fired power plants, significantly in excess of

the U.S. average of 44% (TR. 6/12 at 47, Technical Support Document, at 33-34)

. Illinois' next

largest source of mercury emissions is the commercial/industrial boiler category, which accounts

for 11% of the total . Id

.

at 33 . By comparison to the national average and other contributing

5

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sources within the state, Illinois coal-fired EGUs are a hugely disproportionate contributor of

mercury air emissions

. This fact alone, largely uncontested in this rulemaking, provides a

powerful justification for the development of an Illinois-specific rule mandating deeper, faster

reductions from this source category than required under CAMR

.

Concomitantly, reducing mercury emissions from Illinois coal-fired power plants in a

manner consistent with the proposed Illinois rule will substantially reduce mercury deposition in

Illinois

. According to the opponents' own expert on mercury deposition, Krish Vijayaraghavan,

the Illinois rule will result in lower mercury deposition in Illinois than under the federal approach

alone

. This additional reduction will occur throughout Illinois, will occur very soon after the

Illinois rule becomes effective, and can be quantified

. More specifically, Mr

. Vijayaraghavan

testified :

•

from 2006 to 2010, if the 2010 CAIR/CAMR rule alone, is implemented there will be

a 5.3 percent decrease in mercury deposition in Illinois (TR

. 8/21 p .m. at 1422);

•

from 2006 to 2010, if the proposed Illinois rule is implemented, there will be a 9

.5

percent decrease in mercury deposition, which is an additional 4

.2 percent decrease in

deposition as compared to 2010 CAIR/CAMR (TR

. 8/21 p .m. at 1422, 1433);

•

the deeper reductions under the Illinois rule will occur throughout the entire state of

Illinois (TR

. 8/21 p .m. at 1462);

•

under the CAIR/CAMR rule alone, Illinois will have to wait 10 additional years to

experience reductions roughly equivalent to the reductions achieved under the

proposed Illinois rule in 2010 (TR

. 8/21 p .m. at 1432); and

6

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• the TEAM model predicts that, in the single year of 2010 alone, there will be 321

fewer pounds of mercury deposited in Illinois under the proposed Illinois rule than

under 2010 CAIR/CAMR alone (TR. 8/21 p .m. at 1497).

Mr. Vijayaraghavan's estimate that, in the year 2010, there will be 321 fewer pounds of mercury

deposition under the Illinois rule than under CAMR/CAIR alone is significant confirmation that

Illinois-specific benefits will be achieved . Although CAIR/CAMR eventually produces roughly

equivalent reductions by 2020, there would be ten years during which the Illinois rule would

generate greater reductions than CAIR/CAMR alone . The cumulative effect over a period of ten

years would be thousands fewer pounds of mercury deposited in the environment under the

Illinois rule. This is especially significant because mercury is persistent, bioaccumulative and

toxic in the environment

.

Illinois EPA developed a comparison between the available mercury allowances under

CAIR/CAMR until 2018 and the anticipated mercury emissions under the Illinois rule starting in

2009. This comparison is necessary to demonstrate to U

.S . EPA that the proposed Illinois rule

will meet the CAMR reduction target for Illinois

. Illinois estimates that under CAMR, Illinois

would have a 3,000-pound-per-year emissions cap that could be used or traded by Illinois coal-

fired EGUs . Under the proposed Illinois rule, mercury emissions are expected to be roughly

1,000 lbs . per year . (TR . 6/19 at 46) .

Just as importantly, reducing mercury from Illinois coal-fired EGUs is likely to have a

local impact in reducing mercury deposition . Dr. Gerald Keeler testified that mercury

deposition attributable to coal-fired EGUs can occur in close proximity to the plants themselves

.

These close-in mercury deposition levels are particularly elevated during periods of intense

precipitation, but routinely occur as dry deposition as well

. Dr. Keeler's testimony was based

7

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upon the report analyzing of mercury wet deposition in Steubenville, Ohio, of which he was one

author.

Since the conclusion of the public hearings, the Illinois EPA filed Dr

. Keeler's peer-

reviewed paper, "Sources of Wet Deposition in Eastern Ohio, USA", by Keeler, Landis, Norris,

Christianson and Dvonch, as published in Environmental Science & Technology on the web on

09/08/2006 . In keeping with Dr

. Keeler's testimony before the IPCB, this paper concludes that a

multi-year, multi-faceted analysis of mercury wet deposition in Steubenville " . . .consistently

point[s] toward the dominant influence by local and regional coal burning sources

." Id. at G.

The Steubenville study employs a receptor-based model that measures actual mercury

concentrations in precipitation, and then attributes these concentrations to source categories

using two different techniques (PMF and Unmix) that do not rely on source profiles or emission

inventories, but instead rely on sample concentrations of analytes that are closely associated with

emissions from different categories of sources

. Id

.

at B. Both the PMF and Unmix statistical

analyses determined that approximately 70% (69% and 73%, respectively) of mercury wet

deposition in Steubenville was attributable to the coal combustion source category . Id. at D and

F . By correlating mercury concentrations in precipitation with local meteorological conditions,

for example stagnant conditions that minimized any influence by distant sources, the authors

were able to conclude the data indicate " . . .a strong local and regional source influence ." Id. at

G. Mr. Vijayaraghavan testified that the results of the Steubenville study were consistent with

the results of his own modeling exercise for Steubenville . (TR . 8/21 p .m. at 1404).

Using very different methods, both the proponents through Dr . Keeler and the opponents

through Mr. Vijayaraghavan respectively, have provided important evidence that reducing

8

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mercury emissions from Illinois coal plants is likely to result in a reduction in mercury

deposition in Illinois itself .

IV.

The Proposed Rule is Technically Achievable, Economically Feasible, and

Reasonable .

As an initial matter, it is extremely difficult for the remaining opponents to this rule to

argue that the rule is not technically or economically feasible when Ameren and Dynegy, the

second and third largest operators of Illinois coal-fired power plants, now support the rule and

are committed to complying with its terms . Moreover, during the pendency of these

proceedings, on August 10, 2006, the operator of a single facility, Springfield City, Water, Light

and Power, agreed to a negotiated PSD permit which included a requirement to comply with the

output-based or percentage reduction numeric standard in the proposed rule . (Construction

Permit, PSD Approval, NSPS Emission Units, issued to City of Springfield by the Illinois EPA,

at 4-12 (August 10, 2006), available online at http://vosemite .epa.Lyov/r5/il nennit .ns.) It is also

notable that despite the opportunity to do so, the remaining opponents have presented no facility-

specific or companywide information about the projected costs of compliance . This was made

very clear during the testimony of Midwest Generation's witness, William DePriest, when he

testified that he had prepared cost estimates, but was not at liberty to share this analysis (this

information is "kind of off bounds", TR

. 08/17 p .m. at 1058 ; witness unwilling to provide

information about specific companies, Id. at 1069

; witness refuses to provide cost estimate

information that exists in work done for utilities in the state of Illinois, Id.

at 1065) .

Perhaps just as importantly, there are at least nine features in the Illinois EPA proposal

which provide substantial flexibility to regulated entities

. These mechanisms are :

1 . allowing a regulated entity to choose to comply using an output-based standard,

.008

lbs/gwh, or a percentage reduction, 90%;

9

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2 .

allowing a regulated entity to elect to comply using any combination of techniques and

technologies to meet an output-based or reduction standard, ranging from coal selection

and preparation techniques, to mercury-specific pollution control devices and sorbents,

to pollution control equipment that will reduce an array of pollutants including mercury,

to achieving compliance under multiple regulatory initiatives (proposed Section

225.233) ;

3

. providing regulated entities with almost three years before compliance is required

;

4

. allowing compliance to be determined on a 12-month rolling average

;

5

. allowing owners of multiple EGUs to choose to comply by averaging among units during

the first phase or the regulatory program (through 2013), and allowing owners of single

EGUs to average with other similarly situated operators ;

6

. allowing a complete opt-out for units the regulated entity decides to shutdown

;

7

. allowing a regulated entity to choose to use the Temporary Technology Based Standard

("TTBS") to set aside 25% of its units from meeting a numeric standard until 2015, upon

a showing that these units are optimizing ACI mercury control equipment and meeting

other operational requirements;

8

. allowing a regulated to choose an integrated pollution control strategy which will control

mercury and other pollutants through the Multi-Pollutant Standard ("MPS"),

thus

complying with the proposed Illinois rule and other near-term regulatory requirements ;

and,

9

. providing for the same alternative mercury monitoring requirements contained in the

federal CAMR, including the use sorbent trap monitoring devices as well as newer CEM

systems.

10

---

Notably, very few of the opponents' experts included any evaluation of these flexibility

mechanisms as part of their testimony

. For example, James Marcetti's testimony on economic

modeling did not account for either the TTBS or the NIPS (TR

. 8/18 p.m. at 1308-1309) .

The Illinois proposal also provides practical flexibility to regulated entities to decide how

to achieve mercury reductions

. Appropriately, the IPCB now has a very complete record on

activated carbon injection systems

. These units can be relatively inexpensive ($1-3 million in

initial installation costs), can be installed quickly (six months from order to installation, TR

. 6/22

a.m. at 137), can be installed while the plant operates

(Id),

are easily integrated with existing

pollution control equipment (often requiring only a port in the ductwork between the boiler and

existing pollution control equipment, TR

. 6/23 p .m

. at 470-71) and have relatively low operating

costs (advanced halogenated sorbents cost 90 cents/lb, TR

. 6/22 a.m

. at 85) .

Activated carbon injection units are designed to achieve in excess of 90% mercury

removal once optimized consistent with operations at specific facilities

. (Pre-filed Testimony of

James Staudt, Ph .D. at 6-7) .

There is a great deal of testimony before the Board regarding the

actual removal efficiency of ACI systems

. However, the technical feasibility of this rule is not

dependent on use of ACI alone to meet the standards imposed by the rule

. The record contains

several other examples of practical, existing technologies and techniques to reduce mercury that

can be used alone or in combination with ACI systems

. Ultimately, the proposed rule allows the

operator to decide how to combine options to meet mercury removal requirements (TR

. 6/22

a.m. at 196)

. These technologies and techniques include

:

•

Using a very low mercury coal that, coupled with a

.008 lbs./gwh emission standard, can

achieve 50-80% of the required reduction

. (TR. 6/23 at 452-452)

. Another, related

possibility is to blend with lower mercury coals

. Id.

It is already common for facilities to

11

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use coal selection, preparation (washing, for example) and blending techniques

; these

techniques could be applied in order to minimize emissions of a new pollutant, mercury

.

(Pre-filed Testimony of James Staudt, Ph .D

. at 3).

•

Employing/enhancing existing pollution control technologies

. For facilities using or

planning to install scrubbers, it is likely no additional mercury-specific controls will be

required (TR. 6/21 a.m

. at 134)

. Fabric filters, ESPs, FGD systems, and

SCR systems

can remove or enable the removal of mercury

as

a co-benefit of controlling other

regulated pollutants (Pre-filed testimony of James Staudt, Ph

.D. at 3-4) . ACI systems

would work in combination with these existing systems to provide additional mercury

removal efficiency .

•

Monitoring existing facility performance

. At every facility, there is already unmeasured

mercury removal using existing pollution control equipment

. The actual rate of removal

or emission rate has not been determined because there has been no regulatory

requirement to do so .

Because of this flexibility and the relatively low cost of installing and operating ACI

systems, it is not surprising that Dr

. Ezra Hauzman characterized the cost to owners of Illinois

coal plants as almost negligible

. According Dr

. Hauzman, the total additional annual control

costs associated with the Illinois rule are $33 million

. (Dr. Ezra D . Hausman, Pre-Filed

Testimony, at 8) . In order to provide a context, Dr

. Hausman points out that the total cost to fuel

electric power plants in Illinois is almost 2 billion dollars per year .

Id. at 12 . Also by point of

comparison, the average cost increase for Illinois coal plants under the Illinois EPA proposal is

$0.375/MWh,

a trivial amount when compared to the current retail price of electricity in Illinois,

roughly $65 .00/MWh

. There is reason to believe the impact on consumers would be close to

12

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zero

. Because Illinois utilities do not own the coal plants and the EGU's are competing in an

auction process with other generators, there is no existing means by which Illinois consumers

could be directly charged even the

de minimus

additional costs that would result from adopting

this rule . Consequently, Dr

. Hausman estimates the total additional cost to consumers to be

between $0 and $11 million . Id. at 8.

V.

The Proposed Rule Will Not Impact the Integrity of the CAIR Proceedings

The Ameren and Dynegy proposals contain a Multi-Pollutant Standard, involving

reductions of pollutants, NOx and 502, that would not be otherwise regulated under the mercury

rule at issue in this proceeding

. These reductions are obviously being proposed with an eye

toward future possible regulations of such pollutants, including proposed regulations being

considered in the upcoming

CAIR rulemaking before the Board

.

The Hearing Officer requested guidance on how the MPS and the inclusion of it in a final

mercury rule would affect the CAIR

rulemaking

. First, the MPS is one avenue of compliance in

the proposed mercury rule

. Therefore, selection of the MPS is voluntary, as regulated entities

may select any one of the proposed avenues of compliance in the mercury rule (although once an

entity selects the MPS, compliance with the limits contained therein is obviously mandatory)

.

Therefore, the mercury rule contains no mandatory NOx or SO2 reductions that must be made by

all entities subject to the rule

.

Second, while the MPS anticipates that NOx and SO2 reductions would be

.consistent

with or in excess of the requirements that will be imposed under CAIR, the MPS does not dictate

that companies undertaking the MPS be viewed as in compliance with CAIR

. Once the CAIR

limits are set, it is certainly possible or even likely that utilization of the MPS will result in

compliance with CAIR,

but that is not mandated in the MPS

.

13

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Third, while the goal of the MPS is to begin to address CAIR requirements in addition to

mercury reductions, that does not predetermine the outcome of the CAIR proceedings . The MPS

can certainly be informative as to what those reductions might be. In the joint statement, the

parties "anticipate[d] that the installation and operation of pollution control equipment required

to achieve the NOx and S02 standards under the revised Proposed New Section 225 .233 will

achieve more reductions in NOx and S02 emissions than are required under the Clean Air

Interstate Rule or 'CAIR' ." But, once again, that is only anticipated and the outcome is not

mandated in the MPS or in any way binding on the CAIR rulemaking . Through the CAIR

rulemaking, the Board is at free to make a determination as to what reductions will be required of

regulated entities

. The MPS places no restrictions on the Board as to what the reductions must

be.

Fourth, regulated entities that elect to utilize the MPS would need to comply with both

the requirements of the MPS and the proposed CAIR . Such entities would be required to comply

with both the CAIR cap and trade requirements and the numeric emission limits of the MPS .

Regulated entities will need to both hold sufficient allowances each year under CAIR and emit

NOx and SO2 at a rate equal to or less than the numeric emission limits of the MPS

. Obtaining

additional CAIR allowances would be required when necessary to comply with CAIR even if

actual emissions rates meet the requirements of the MPS . Finally, in order for the MPS to

protect air quality in fact, it does not allow the trading of allowances that are generated as a result

of measures taken to comply with the NOx and SO2 emission standards .

In sum, the MPS can inform the CAIR rulemaking and would appropriately be

considered in the CAIR rulemaking but does not predetermine any outcome of the CAIR

rulemaking. Additionally, the MPS proposal is designed to work within the CAIR requirements

14

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and regulated entities will need to comply with both, especially since different limits will be set

under both .

VI.

Conclusion

In sum, the Environmental Advocates strongly support the proposed rule now before the

Illinois Pollution Control Board, including the Mufti-Pollutant Standard

. The record before the

IPCB amply supports the rule and demonstrates the public health and environmental benefits to

Illinois of the deeper, faster reductions of mercury emissions resulting from the proposed rule

compared to those under the federal CAMR alone

. The record is clear, especially in light of

Ameren's and Dynegy's support of the proposed rule, that these reductions can be achieved with

available technology, at reasonable cost, and through utilization of the regulatory flexibility

mechanisms built into the rule

.

15

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Respectfully submitted,

ENVIRONMENTAL LAW AND POLICY

CENTER

By:

Faith E. Bugel

Howard A. Learner

Meleah Geertsma

Environmental Law and Policy Center

35 E. Wacker Drive, Suite 1300

Chicago, Illinois 60601

312-673-6500

ENVIRONMENT ILLINOIS

One of its Attorneys

Keith I. Harley

Chicago Legal Clinic

205 West Monroe Street, 4th Floor

Chicago, IL 60606

16

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CERTIFICATE OF SERVICE

I, the undersigned, certify that on this 20th day of September, 2006, I have served by

hand delivery the attached NOTICE OF FILING and POST-HEARING COMMENTS OF

ENVIRONMENT ILLINOIS AND ENVIRONMENTAL LAW & POLICY CENTER upon the

following persons :

Dorothy Gunn

Clerk

Illinois Pollution Control Board

James R . Thompson Center

100 West Randolph St ., Suite 11-500

Chicago, IL 60601-3218

And by first-class mail with postage thereon fully prepaid and affixed to the following persons :

SEE ATTACHED SERVICE LIST

Dated : September 20, 2006

---

John J . Kim

Charles E . Matoesian

Gina Roccaforte

IL Environmental Protection Agency

1021 North Grand Avenue East

Springfield, Illinois 62794-9276

Christopher W

. Newcomb

Karaganis, White & Magel, Ltd

.

414 North Orleans Street

Suite 810

Chicago, IL 60610

Bill S. Forcade

Katherine M . Rahill

Jenner & Block LLP

One IBM Plaza

Chicago, IL 60611

Kathleen C

. Bassi

Sheldon A. Zabel

Stephen J. Bonebrake

Joshua R

. More

Glenna L. Gilbert

SchiffHardin LLP

6600 Sears Tower

233 South Wacker Drive

Chicago, IL 60606

James W. Ingrain

Senior Corporate Counsel

Dynegy Midwest Generation, Inc

.

1000 Louisiana, Suite 5800

Houston, TX 77002

James T

. Harrington

David L. Rieser

Jeremy R. Hojnicki

McGuire Woods LLP

77 West Wacker, Suite 4100

Chicago, IL 60601

SERVICE LIST06-25

Daniel McDevitt

Midwest Generation

440 S . LaSalle St .

Suite 3500

Chicago, IL 60605

Dianna Tickner

Mary Frontezak

Prairie State Generating Company, LLC

701 Market Street

Suite 781

St. Louis, MO 63101

S. David Farris

Environmental, Health and Safety

Manager

Office of Public Utilities

City of Springfield

201 East Lake Shore Drive

Springfield, IL 62757

---

TABLE OF CONTENTS

SORTED BY IPCB

HEARING SCHEDULE

Chapter 1 .0 - Introduction

Chapter 2.0 - Background

Information on Mercury

Dr. Mark Cohen,

The Atmospheric Transport and Deposition of Mercury to the Great

Lakes,

Collection of Graphics for IJC Air Quality Board (2004) .

See tab 1 .

Dr

. Mark Cohen et at .,

Modeling the atmospheric transport and deposition of mercury to

the Great Lakes, Environmental Research 95 (2004) . See tab 2.

Emily Figdor, U .S

. Public Interest Research Group Education Fund, Reel Danger: Power

Plant Mercury Pollution and the Fish We Eat (2004) .

See tab 3.

Paul J . Miller & Chris Van Atten, Commission for Environmental Cooperation of North

America,

North American Power Plant Air Emissions (2004) .

See tab 4.

Supryia Ray, Illinois PIRG Education Fund,

Made in the US.A .

: Power Plants and

Mercury Pollution Across the Country

(2005) . See tab 5.

Michael Shore, Environmental Defense,

Out of Control and Close to Home

: Mercury

Pollutionn from Power Plants (2003) .

See tab 6.

Chapter 3.0- Mercury Impacts on Human Health

Proveen Amar, Northeast States for Coordinated Air Use Management (NESCAUM),

Mercury Emissions From Coal Fired Power Plants - The Case For Regulatory Action,

(2003) . See tab 7.

Joshua T

. Cohen, A Summary of the Major Studies of Prenatal Mercury Exposure and

Cognitive Function (2004) . See tab 8.

Environmental Protection Agency,

Revision of December 2000 Regulatory Finding on

the Emissions of Hazardous Air Pollutants From Electric Utility Steam Generating Units

and the Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units From

the Section 112(c) List ; Final Rule,

Federal Register Vol . 70, No. 59 15994 (2005)

. See

tab 9.

Lynn R. Goldman & Michael W

. Shannon, Technical Report : Mercury in the

Environment: Implications for Pediatricians,

Pediatrics Vol . 108 No. 1 197 (2001) .

See

tab 10.

Illinois Department of Natural Resources,

2005 Illinois Fishing Information (2005) .

See

tab 11.

---

Paul Jakus, Meghan McGuinness & Alan Krupnick, Resources for the Future,

The

Benefits and Costs ofFish Consumption Advisories for Mercury (2002) . See tab 12.

Kathryn R . Mahaffey, Robert P . Clickner & Catherine C

. Bodurow, Blood Organic

Mercury and Dietary Mercury Intake

: National Health and Nutrition Examination

Survey, 1999 and 2000, Environmental Health Perspectives, Vol . 112, No . 5, 562 (2004) .

See tab 13.

Kathryn R. Mahaffey, Methylmercury : Epidemiology Update (2004) (Presentation) . See

tab 14.

Supryia Ray, Illinois PIRG Education Fund, Made in the U.S.A. : Power Plants and

Mercury Pollution Across the Country (2005). See tab 5. '

Glenn Rice & James K . Hammitt, Economic Valuation of Human Health Benefits of

Controlling Mercury Emissions from US. Coal-Fired Power Plants (2005)

. See tab 15.

Larry Schweiger et al ., National Wildlife Federation, Getting the Job Done: Affordable

Mercury Control at Coal-Burning Power Plants (2004)

. See tab 16.

Rebecca Stanfield, IPIRG,

Mercury Contamination in Illinois, Lake Michigan Forum

(Presentation) (2006). See tab 17.

Chapter 4.0 - Mercury Impaired Waters in Illinois

Zachary Corrigan, Fishing for Trouble -How Toxic Mercuiry Contaminates Fish in US .

Waterways, U .S. PIRG Education Foundation (2004). See tab 18.

Emily Figdor, U .S . Public Interest Research Group Education Fund, Reel Danger: Power

Plant Mercury Pollution and the Fish We Eat (2004) . See tab 3.

Florida Department of Environmental Protection,

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 (2003) . See tab

19.

Illinois Department of Natural Resources, 2005 Illinois Fishing Information (2005) . See

tab 11.

Large Lakes Research Station, Lake Michigan Mass Balance Project : Mercury Results .

See tab 20.

Larry Schweiger et al ., National Wildlife Federation, Getting the Job Done : Affordable

Mercury Control at Coal-Burning Power Plants (2004) . See tab 16.

11

---

Michael Shore, Environmental Defense,

Out of Control and Close to Home

: Mercury

Pollution from Power Plants (2003) .

See tab 6.

Rebecca Stanfield, IPIRG,

Mercury Contamination in Illinois, Lake Michigan Forum

(Presentation) (2006)

. See tab 17.

Marcia T. Willhite,

Mercury Impaired Waters and the TMDL Process

(Presentation) .

See tab 21.

Chapter 5 .0 -

Deposition of Mercury

Proveen Amar, Northeast States for Coordinated Air Use Management (NESCAUM),

Mercury Emissions From Coal Fired Power Plants -

The Case For Regulatory Action,

(2003). See tab 7.

Clean Air Task Force,

Local Impacts of Mercury from Coal-Fired Power Plants (2003)

.

See tab 22.

Dr

. Mark Cohen,

Atmospheric Deposition of Mercury to the Great Lakes,

Presentation at

An Ecosystem Approach to the Health Effects of Mercury to the Health Effects of

Mercury in the Great Lakes Basin -

Clearly International Conference Center, Windsor,

Ontario,

(2003) . See tab 23.

Dr

. Mark Cohen, The

Atmospheric Transport and Deposition

of

Mercury to the Great

Lakes,

Collection of Graphics for IJC Air Quality Board

(2004). See tab 1 .

Dr. Mark Cohen,

Local and Regional Deposition Impacts of Atmospheric Mercury

Emissions,

Presentation at Mercury Rule Workgroup Meeting PA Department of

Environmental Protection, (2005)

. See tab 24.

Cohen et al .,

Modeling the atmospheric transport and deposition of mercury

to the Great Lakes,

Environmental Research

95 (2004) . See tab 2.

Hubbard Brook Research Foundation,

Comments on the U.S

. Environmental Protection

Agency's, "Proposed National Emissions for Hazardous Air Pollutants

; and, in the

Alternative, Proposed Standards of Performance

.

for New and Existing Stationary

Sources

: Electric Utility Steam Generating Units" (2004)

. See tab 25.

Large Lakes Research Station,

Lake Michigan Mass Balance Project

: Mercury Results .

See tab 20

.

Glenn Rice & James K . Hammitt,

Economic Valuation of Human Health Benefits of

Controlling Mercury Emissions from U.S

. Coal-Fired Power Plants (2005)

. See tab 15.

Larry Schweiger et al

., National Wildlife Federation,

Getting the Job Done : Affordable

Mercury Control at Coal-Burning Power Plants (2004)

. See tab 16.

iii

---

Michael Shore, Environmental Defense,

Out of Control and Close to Home

: Mercury

Pollution from Power Plants (2003)

. See tab 6.

Rebecca Stanfield, IPIRG,

Mercury Contamination in Illinois, Lake Michigan Forum

(PowerPoint Presentation)

(2006). See tab] 7.

State and Territorial Air Pollution Program Administrators (STAPPA) & Association of

Local Air Pollution Control Officials (ALAPCO),

Regulating Mercury from Power

Plants

: A Model Rule for States and Localities (2005)

. See tab 26.

Marcia T . Willhite,

Mercury Impaired Waters and the TMDL Process

(Presentation) .

See

tab 21.

Chapter 6 .0 - Regulatory Activities -

Federal and Other States

Chapter 7 .0 -

Illinois Mercury Emissions Standards for Coal-Fired Electric Generating

Units

Chapter 8 .0

- Technical Feasibility of Controlling Mercury Emissions from Coal-Fired

Power Plants in Illinois

Proveen Amar, Northeast States for Coordinated Air Use Management (NESCAUM),

Mercury Emissions From Coal Fired Power Plants

- The Case For Regulatory Action,

(2003). See

tab 7.

Emily Figdor, U .S

. Public Interest Research Group Education Fund,

Reel Danger : Power

Plant Mercury Pollution and the Fish We Eat (2004)

. See tab 3.

Paul J

. Miller & Chris Van Atten, Commission for Environmental Cooperation of North

America,

North American Power Plant Air Emissions (2004)

. See tab 4.

National Wildlife Federation,

Controlling Mercury from Power Plants

: Current state of

knowledge (2003) . See tab 27.

Supryia Ray, Illinois PIRG Education Fund,

Made in the

U.S.A.: Power Plants and

Mercury Pollution Across the Country (2005)

. See tab 5.

Larry Schweiger et al

., National Wildlife Federation, Getting the Job Done

: Affordable

Mercury Control at Coal-Burning Power Plants (2004)

. See tab 16.

State and Territorial Air Pollution Program Administrators (STAPPA) & Association of

Local Air Pollution Control Officials (ALAPCO),

Regulating Mercury from Power

Plants

: A Model Rule for States and Localities (2005) . See tab 26

.

Chapter 9.0 - Economic Modeling

iv

---

National Wildlife Federation,

Controlling Mercury from Power Plants : Current state of

knowledge (2003)

. See tab 27.

Supryia Ray, Illinois PIRG Education Fund,

Made in the U S.A. : Power Plants and

Mercury Pollution Across the Country (2005)

. See tab 5.

State and Territorial Air Pollution Program Administrators (STAPPA) & Association of

Local Air Pollution Control Officials (ALAPCO),

Regulating Mercury from Power

Plants

: A Model Rule fbr States and Localities (2005) . See tab 26 .

James Staudt, Andover Technology Partners,

Mercury Control From Coal-Fired Electric

Utility Plants- A Review ofTechnology

Status and Cost (2006) (Presentation)

. See tab

28.

Chapter 10 .0 -

Other Relevant Issues and Additional Considerations

v

---

Dr. Mark Cohen,

The Atmospheric Transport and Deposition of Mercury to the Great Lakes,

Collection of Graphics for IJC Air Quality Board (2004)

.

I . SUMMARY

In this presentation, a collection of graphics are provided that include an inventory of

receptors (great lakes and other large bodies of water in the US and Canada) that are

analyzed in a study of mercury deposition resulting from US and Canadian sources and

relying on 1996 meteorological data and 1999 source emissions data from the US EPA

.

Specifically included are graphics on the results in the Great Lakes and detailed

graphical results for Lake Erie and Lake Michigan.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 2.0

- Background Information on Mercury

•

Pie graph of sources of anthropogenic reactive gas (RGM) mercury from the great

lakes area. Id. at 7 .

Chapter 5.0 - Deposition

•

Graphs showing fraction of and total amount of deposition in bodies of water

including Great Lakes arising from US coal fired electricity utility facilities . (1999) Id. at 15,

17.

•

Graphs ranking Top 25 contributors of mercury deposition directly to the Great Lakes

broken down by individual sites

. (1999) Id. 22-27 .

•

Graph of Lake Michigan is included and many Illinois coal fired power plants are

major contributors .

•

Map of Great Lakes region showing Top 25 contributors by source of mercury

deposition directly to the Great Lakes. Id.

at 29 .

•

Map of Great Lakes region showing geographical distribution of direct deposition to

Lake Michigan . Id. at 43

. The purple and red coloring shows that Illinois is a major

contributor .

1

---

Dr. Mark Cohen et al

., Modeling the atmospheric transport and deposition of mercury

to the Great Lakes,

Environmental Research 95 (2004) .

I. SUMMARY

This paper discusses a model developed (a special version of the NOAA-HYPSPLIT 4

model) and used to estimate the atmospheric fate and transport of mercury in a North

American modeling domain

. Model results were found to be reasonably consistent with wet

deposition measurements in the Great Lakes region and with independent measurement-based

estimates of deposition to Lake Michigan

. Of particular significance is the finding that coal

combustion was generally found to be the largest contributor to atmospheric mercury

deposition to the Great Lakes (see below) and that the Chicago region "stands out" as a major

contributor to mercury deposition in Lake Michigan (see quote below)

.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 2.0

- Background Information on Mercury

•

3 Classes of Atmospheric Mercury Id

. 248 :

1) Elemental Mercury Hg[0]

2) Particulate Mercury Hg[p]

3) Water Soluble or Reactive Gas HG[II]

•

"The predominant form in the atmosphere is generally elemental mercury (Hg

0)."

Id. at 248 .

•

"The great majority of the mercury in the atmosphere

(- 95%) is in the elemental

form" Id. at 248 .

•

"Each of the above forms of mercury can be transformed into the other in the

atmosphere"

Id. at 248 .

•

Fig. 4 is a graph of the total Mercury Emissions from U

.S. and Canadian

anthropogenic sources . Id. at 252 .

Chapter 5 .0 - Deposition of Mercury

•

How is Mercury Deposited to the Great Lakes

.

- Indirectly

-

Portion Deposited into Lakes Watershed and subsequentlytransported to Lakes

.

- Directly

-

Discharge into the Lakes and its tributaries from polluting facilities

.

- Fig

. 10 shows the overall-model estimated deposition of mercury to each of the

Great Lakes . Id. at 259.

- Fig

. 13 illustrates the geographical distribution of mercury contributions ,

where

the emissions and contributions are shown as a function of distance from each

lake. Id. at 262 .

"For Lake Michigan, the contribution form

the Chicago region

stands out, due to

its significant emissions and proximity to the lake

." (referring to graph in

supplemental materials) Id. at 262

2

---

• "Overall, coal combustion in the United States was found to be the most

significant source category contributing mercury through atmospheric

deposition to the Great Lakes

." Id.

at 263-264 .

3

---

Emily Figdor,

Reel Danger

: Power Plant Mercury Pollution and the Fish We Eat, U

.S . Public

Interest Research Group Education Fund (August 2004) .

I. SUMMARY

This report analyzes the first available data from the US EPA's ongoing National

Study of Chemical Residues in Lake Fish Tissue, a four-year study of 268 chemicals in

fish from a representative sample of 500 lakes and reservoirs in the continental U

.S.

Included in the analysis are the first two years of EPA's quality-assured data, which

includes fish from 260 lakes and reservoirs collected in 1999-2000 and 2001

. Below

are the key findings from the report

. Also contained in this document is general

background information on mercury.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

•

Key findings from analyzing the data from U

.S. EPA's ongoing National Study of

Chemical Residues in Lake Fish Tissue, a four-year study of 268 chemicals in fish from a

representative sample of 500 lakes and reservoirs in the continental U

.S . are the following

:

Id. at 1 .

- All of the fish samples were contaminated with mercury

.

- Fifty-five (55) percent of the fish samples were contaminated with mercury at

levels that exceed EPA's "safe" limit for women of average weight who eat fish

twice a week

. In 29 states, mercury levels in at least half of the fish samples

exceeded this limit.

- Seventy-six (76) percent of the fish samples exceeded the safe mercury limit for

children of average weight under age three who eat fish twice a

week

; 63 percent offish samples exceeded the limit for children ages three to five

years; and 47 percent of the fish samples exceeded the limit for children six to

eight years.

-

Predator fish, or fish at the top of the aquatic food chain, had the highest average

levels of mercury

. Smallmouth bass, walleye, largemouth bass, lake trout, and

Northern pike had the highest average mercury concentrations

.

- Eighty (80) percent of the predator fish samples contained mercury levels

exceeding EPA's safe limit for women

. In 18 states, 100 percent of the predator

fish samples exceeded this limit .

Chapter 5.0 - Mercury Deposition

•

"EPA estimates that 60 percent of the mercury deposited in the U

.S . comes from

domestic manmade sources" Id. at 7.

•

"The highest deposition rates in the U .S. occur in the southern Great Lakes, the Ohio

Valley, the Northeast, and scattered areas in the South

. In regions where deposition is high,

local and regional sources

are the main cause of elevated mercury concentrations ." Id.

at 7.

4

---

Paul J

. Miller & Chris Van Atten, Commission for Environmental Cooperation of North

America,

North American Power Plant Air Emissions (2004)

.

1. SUMMARY

Contains specific air pollutant information for individual fossil fuel-fired power plants across

North America

. Also includes the environmental performance of each power plant in terms

of the amount of pollution emitted per unit of electricity produced

.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter

2.0

- Background Information on Mercury

•

Figure 3

.6 on page 19 shows the geographic distribution of power plant mercury emissions in

North America

.

•

Table 3.9 beginning on page 54 shows U

.S . mercury power plant emission for 2002, sorted

by annual emissions

.

Chapter 8.0

- Technical Feasibility of Controlling Mercury Emissions from Coal-Fired

Power Plants in Illinois

•

"Extensive field tests in the United States have demonstrated that existing pollution control

equipment,

levels of mercury

such as

controlSO2

scrubbers

. According

and

to

post-combustion

the United States

NOEPA,

x

controls,

the average

can achieve

levels

significantof

mercury

control range from 0 percent to 98 percent, depending on the exact characteristics of the

power plant and the coal used."

Id. at 19 .

5

---

Supryia Ray, Illinois PIRG Education Fund,

Made in the U.S.A.

: Power Plants and Mercury

Pollution Across the Country (2005)

.

I. SUMMARY

Analyzes 2003 EPA data on mercury air emissions from power plants

.

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 2

.0 - Background Information on Mercury

•

Appendix A

. 1, which shows the 100 counties with the highest power plant mercury air

emissions, has Illinois counties at

30, 47, 62, 66, 81, and 100. Id. at 22 .

Chapter 3 .0 -

Mercury Impacts on Human Health

•

"The Mt

. Sinai School of Medicine, which assessed the economic impact of U

.S . power plant

mercury emissions on the developing fetal brain, found that such emissions cost

$1 .3 billion

per year in diminished economic productivity due to loss of IQ ."

Id. at 19.

•

"The Harvard Center for Risk Analysis, which monetized both neurological and

cardiovascular impacts of reducing power plant mercury emissions using targets in the Bush

administration's "Clear Skies" initiative, estimated benefits ranging up to

$3 .5 billion

annually at an emissions level of 26

tons of mercury per year and $5 .2 billion annually at 15

tons per year

. The estimates included benefits associated with IQ increases

as well as

avoided cardiovascular events and premature mortality

." Id. at 19.

•

" . . .the EPA's own water office, which assessed the benefits of reducing U

.S . mercury

emissions by 30-100%

and likewise included both neurological and cardiovascular impacts,

estimated benefits in the Southeastern U .S

. ranging from $600 million to more than $2

billion." Id. at 19.

Chapter 8.0 - Technological Feasibility of Controlling Mercury Emissions From Coal-

Fired Power Plants in Illinois

•

"Numerous full-scale tests of activated carbon injection (ACI), a control technology that has

reduced mercury emissions from medical and municipal waste incinerators by more than

90% since the mid-90s, have shown similar success in reducing power plant mercury

emissions

. Examples include Alabama Power's multiunit Gaston plant, which obtained up to

90% reductions for a boiler burning bituminous coal

; Sunflower Electric's Holcomb Station

in Kansas, which reported reductions in excess of 90% on subbituminous coal

; and Great

River Energy's Stanton Station in North Dakota, which reported up to 81 % control with

untreated carbon and up to 96% control with brominated carbon on a boiler burning lignite

coal

. As two power company representatives, the Electric Power Research Institute, the U

.S.

Department of Energy, and ADA-ES, a leading pollution control company, concluded

:

"Recent full-scale field tests have proven the effectiveness of activated carbon injection for

reducing mercury emissions

. The technology is ideally suited for use on existing coal-fired

boilers. . ." Id. at 18 .

6

---

• "

. . .mercury control technology for power plants is commercially available today . Several

power plants have already agreed to install such technology to reduce mercury emissions

."

Id

. at 19

.

Chapter 9 .0 - Economic Modeling

•

"Using EPA data, the National Wildlife Federation (NWF) estimated that installing mercury

control technology to achieve 90% mercury reduction at power plants would cost the average

household about 69 cents to $2 .14 per month in five coal-dependent states : Illinois,

Michigan, Ohio, Pennsylvania, and North Dakota ." Id. at 19.

7

---

I.

SUMMARY

8

Michael Shore, Environmental Defense,

Out of Control and Close to Home: Mercury

Pollution from Power

Plants (2003) .

Analysis of emission trends and recent modeling of how mercury is transported and

deposited into soil and water, leading to the conclusion that the majority of mercury is

deposited locally.

It. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 2

.0 - Background Information on Mercury

•

Figure B on page 5 lists Illinois as the state with the fourth highest mercury emissions

.

Chapter 4 .0 - Mercury Impaired Waters in Illinois

•

Figure 2 on page 8 shows the fish advisories for all 50 states

. The impact of mercury on

Illinois is well illustrated .

Chapter 5 .0 - Deposition of Mercury

•

"Atmospheric mercury pollution that has reacted and combined with other pollutants tends to

deposit locally or regionally, while unreacted mercury (elemental) tends to enter the global

atmospheric pool, enabling it to be deposited virtually anywhere in the world

."

Id. at 11 .

•

"At hot spots, local sources within a state commonly account for 50% to 80% of the mercury

deposition (Figure 5 [which ranks Illinois as the fourth-highest state for mercury hot spots])

.

In-state sources contribute more than 50% of the pollution to sites in the top 8 worst hot spot

states." Id. at 12 .

•

"An ambitious analysis of mercury pollution, deposition and fish contamination in Florida

provides on-the-ground evidence that corroborates the importance of local sources

. Because

of tighter standards on medical and municipal waste incinerators that took effect in mid-

1992, South Florida's total estimated local emissions of mercury declined by about 93%

between 1991 and 2000

. During this same period, mercury deposited via rain and other

precipitation declined in South Florida by about 25%

. Concentrations of mercury in large

mouth bass have also decreased significantly, 60-75% since the early 1990s

. These data

strongly suggest that reducing local mercury pollution will lower concentrations in local

water

at 12 .

bodies, and in turn reduce contamination in fish and the risk of human exposure

." Id.

---

Proveen Amar, Project Manager, Mercury Emissions From Coal Fired Power Plants

- The

Case For Regulatory Action,

NESCAUM (Northeast States for Coordinated Air Use

Management) (2003) .

I

. SUMMARY

This article makes a very persuasive case for adopting a stringent mercury reduction

standard at the federal level, prior to enactment of CAMR . An outline of the information

included in this document is set forth in the TOC and specific information relevant to the

hearing schedule, particularly the issue of Human Health Impacts, Deposition, and Technical

Feasibility is below .

II. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3 .0 -

Mercury Impacts on Human Health

•

"Widespread methylmercury contamination,

primarily asaresult the deposition of

mercury from the atmosphere, has resulted in elevated levels of mercury in fish

. In fact,

methylmercury contamination in fish is so pervasive in the U .S . that health departments in 45

states and American Samoa have issued freshwater fish consumption advisories ." Id. at 1-3.

•

A survey in 1999-2000, the National Health and Nutrition Examination Survey,

conducted by the Centers for Disease Control and Prevention, "revealed that one in 12

women of childbearing age (8%), tested above EPA's safe" level of mercury

. "This

translates to 4.7

million women of childbearing age with elevated levels of mercury and

approximately 322,000 newborns who are at risk of neurological effects from being exposed

in utero to methylmercury ." Id.

at 1-6 through 1-7 .

•

"The EPA, the Centers for Disease Control and Prevention, the National Research

Council of the National Academy of Sciences, and the World Health Organization have all

determined that potentially significant public health risks exist from widespread exposure to

methylmercury." Id. at 1-2 .

Chapter 5.0 -

Mercury Deposition

•

Table 2.1 -

EPA National Emissions Inventory for Mercury by Source

.

Id.

at 2-2.

•

"EPA has estimated that roughly 66 percent of all of the Mercury deposited in the

U.S. comes form U .S. sources ." Id. at 2-4.

•

Figure 2

.2 Total Mercury Deposition - "the most highly impacted areas are the

southern Great Lakes . . ." as shown by the region in red

. Id. at 2-5 .

•

"Mercury is emitted form power plants in different chemical species, with each

species having a different fate in the atmosphere

. Climate, wind direction and terrain also

play a role in the transport of mercury . For this and other reasons, it is difficult to model

deposition patterns or to predict the transport patterns of emissions ."

Id. at 2-7 .

•

"[I]t is evident that reduction from domestic emissions sources -and power plants in

particular, are critical

." Id. at 2-7.

9

---

Chapter 8 .0

- Technical Feasibility of Controlling Mercury

•

Figure 4.2

- Percent Mercury Removal vs . Activated Carbon Injection Rate

- this is a

graph of the amount of mercury removal that resulted from ACI injection at various coal

fired power plants conducted in tests sponsored by the Department of Energy (DOE

.)

Notably, the power plants burning subbituminous and bituminous coal, the coal which most

Illinois plants use, in combination with a fabric filter demonstrated >90% capture rates . Id. at

4-5 .

•

"Full-scale demonstrations of ACI-technology indicate that mercury removal of

over 90 percent is feasible . . ." Id. at 4-9.

10

---

Joshua T

. Cohen, A

Summary of the Major Studies of Prenatal Mercury Exposure and

Cognitive Function (2004)

.

I. SUMMARY

This provides a summary of the methods and results of the major studies measuring the

effects of prenatal mercury exposure on cognitive function

. The most useful section is the

one devoted to tables, which summarizes the results of the studies nicely .

II

. INFORMATION TO THE IPCB HEARING SCHEDULE

Chapter 3

.0 - Mercury Impacts on Human Health

•

The WISC-III test, the California Verbal Learning Test (CVLT), and the Boston Naming

Test (BNT) evaluate the cognitive domain

. Id. at 5.

•

According to the Faroe Islands study, a "l OX increase in cord blood Hg effect was equivalent

to a developmental delay of

: Boston Naming - 5 mos . ; WISC-R digit span

- 8 mos. ;

mosCal[ifornia]Verbal

." Id. at 11 .

Learning [Test]

- 6-7 mos . ; Cont[inuance] Performance] Test

- 5

•

According to the Faroe Islands study, a "10-fold increase in cord-wholeblood Hg

corresponded to the equivalent of a 3-wk reduction in gestational age" in two-week-old

children . Id. at 15 .

•

According to the Seychelles Islands study, when a mother has a mercury concentration of 10

µg/g at birth, "mercury [is] associated with a two week delay in age at first walking" for male

children .

Id. at 19 .

•

In the New Zealand study, the "proportion of children in the high exposure group with

abnormal or questionable DDST [Denver Developmental Screening Tests] results

statistically exceeded the corresponding proportion in the low exposure group

." Id. at 25 .

I1

---

Environmental Protection Agency,

Revision of December 2000 Regulatory Finding on the

Emissions of Hazardous Air Pollutants From Electric Utility Steam Generating Units and the

Removal of Coal- and Oil-Fired Electric Utility Steam Generating Units From the Section

112(c) List

; Final Rule, Federal Register Vol . 70, No. 59 15994 (2005) .

I. SUMMARY

Rule and explanation for removing coal- and oil-fired Utility Units from the section 112(c)

list.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3 .0 -

Mercury Impacts on Human Health

•

"Methylmercury is a well-established human neurotoxicant

. Methylmercury that is ingested

by humans is readily absorbed from the gastrointestinal tract and can cause effects in several

organ systems ." Id. at 16011 .

•

"The best studied effect of low level exposure is the ability of methylmercury to cause subtle,

yet potentially important neurodevelopmental effects

." Id. at 16011 .

•

"Large prospective epidemiological studies have reported that prenatal methylmercury from

environmental exposures has been associated with poor performance on neurobehavioral

tests in children

. These include tests that measure attention, visual-spatial ability, verbal

memory, language skills, and fine motor function

." Id

.

at 16011 .

•

"Some recent epidemiological studies in men suggest that methylmercury is associated with a

higher risk

of acute myocardial infarction, coronary heart disease and cardiovascular disease

in some populations ."

Id. at 16011 .

12

---

Lynn R.

Goldman & Michael W .

Shannon, Technical Report: Mercury in the Environment

:

Implications for Pediatricians, Pediatrics Vol

. 108 No. 1 197 (2001).

1

. SUMMARY

Describes the process by which the various forms of mercury are taken into the body, effects,

and treatments .

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3 .0 - Mercury Impacts on Human Health

•

"Elemental mercury readily vaporizes at room temperature

. When inhaled, elemental

mercury vapor easily passes through pulmonary alveolar membranes and enters the blood,

where it distributes primarily to the red blood cells, central nervous system (CNS), and

kidneys." Id.

at 198 .

•

"At high concentrations, mercury vapor inhalation produces acute necrotizing bronchitis and

pneumonitis, which can lead to death from respiratory failure

." Id. at 198 .

•

"Early nonspecific signs include insomnia, forgetfulness, loss of appetite, and mild tremor

and may be misdiagnosed as psychiatric illness

. Continued exposure leads to progressive

tremor and erethism, a syndrome characterized by red palms, emotional lability, and memory

impairment

. Salivation, excessive sweating, and hemoconcentration are accompanying

autonomic signs

. Mercury also accumulates in kidney tissues, directly causing renal toxicity,

including proteinuria or nephrotic syndrome

. Isolated renal effects may also be immunologic

in origin."

Id. at 198 .

•

"Consumption of fish is the primary route of exposure to organic mercury for children older

than 1 year ." Id.

at 199 .

•

"Most organic mercury compounds are readily absorbed by ingestion and inhalation and

through the skin, except for phenylmercury, which is not well absorbed after ingestion or

dermal contact

. In general, organic mercury compounds are lipid soluble, and 90% to 100%

is absorbed from the gastrointestinal tract

. They appear in the lipid fraction of blood and

brain tissue

. Organic mercury readily crosses the blood-brain barrier and also crosses the

placenta

. Fetal blood mercury levels are equal to or higher than maternal levels

.

Methylmercury appears in human milk ." Id.

at 200 .

•

"Signs of toxicity from acute [methylmercury] exposure progress from paresthesias and

ataxia to generalized weakness, visual and hearing impairment, and tremor and muscle

spasticity to coma and death."

Id. at 200 .

13

---

Illinois Department of Natural Resources,

2005 Illinois Fishing Information (2005).

I. SUMMARY

An up-to-date summary of fishing regulations in Illinois to explain the intent of the Fish and

Aquatic Life Code (Chapter 515, Illinois Compiled Statutes) . Also, the booklet presents site

specific regulations organized by water area

.

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 3.0 -

Mercury Impacts on Human Health

•

"Methyl mercury is extremely toxic to humans and causes many adverse health effects

.

Health effects associated with eating methyl mercury-contaminated fish include impaired

central nervous system function, kidney damage and failure, and gastrointestinal damage

with higher methyl mercury exposure, and development delays in children with lower

exposure

. A recent report by the National Academy of Sciences concluded that the

population at highest risk for adverse health effects is the children of women who eat large

amounts of fish and seafood during pregnancy

. This is due to the greater sensitivity of the

developing nervous system of infants ." Id. at 41 .

Chapter 4.0 - Mercury Impaired Waters in Illinois

•

Page 41 also contains a table showing the Illinois bodies of water that are included in a

special mercury advisory because of high mercury levels

.

•

"In order to protect the most sensitive populations, pregnant or nursing women, women of

childbearing age, and children less than 15 years of age are advised to eat no more than one

meal per week of predator fish

. This advisory is based on recent studies of families in several

countries that eat many meals of fish having various amounts of methyl mercury, along with

the most recent mercury data from predator fish at sample points throughout the state

." Id. at

41 .

14

---

Paul Jakus, Meghan McGuinness & Alan Krupnick, Resources for the Future, The Benefits

and Costs of Fish Consumption Advisories for Mercury (2002)

.

l. SUMMARY

Estimates of cost to fisherman if health advisory for Mercury were put in place on

Chesapeake Bay. Also estimates the health effects of such an advisory

. This study is very

specific to Chesapeake Bay and offers little general information

.

II . INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3.0 - Mercury Impacts on Human Health

•

"MeHg has been associated with adverse cardiovascular effects, such as increased blood

pressure and abnormal cardiac function

. Two recent studies focus specifically on the

relationship between low-level dietary exposure to McHg and cardiovascular health, one of

which finds evidence of a link between mercury uptake and all-cause mortality

." Id. at 80.

•

"Blood pressure in childhood is an important determinant of hypertension risk later in life,

and prenatal methylmercury exposure has been linked to increased blood pressure in

children." Id. at 81 .

15

---

Kathryn R. Mahaffey, Robert P

. Clickner & Catherine C . Bodurow, Blood Organic

Mercury and Dietary Mercury Intake: National Health and Nutrition Examination Survey,

1999 and 2000,

Environmental Health Perspectives, Vol . 112, No . 5, 562 (2004) .

I. SUMMARY

Analyzes mercury intake in American women based on fish consumption and race

.

11

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 3.0 - Mercury Impacts on Human Health

•

"Based

on the distribution of BHg concentrations among the adult female participants in

1999-2000 NHANES and the number of U .S . births in 2000, > 300,000 newborns each year

in the United States may have been exposed in utero to methyl mercury concentrations

higher than those considered to be without increased risk of adverse neurodevelopmental

effects associated with methyl mercury exposure." Id. at 562 .

•

"Women who eat fish and/or shellfish at least twice' a week have average BMHg

concentrations seven times greater than women who reported no fish/shellfish consumption

in the previous 30 days ." Id. at 565 .

• "Analyses of total diet by the U .S. Food and Drug Administration (U

.S. FDA) indicate that

fish and shellfish are almost exclusively the source of Hg (specifically MHg) in the U .S . diet

(Gunderson 1995 ; U .S. FDA 2000) ." Id. at 567 .

16

---

Kathryn R. Mahaffey, Methylmercuryy: Epidemiology Update (2004) (Presentation) .

I

. SUMMARY

Update on major studies done in 2003/2004 that measure the effect of mercury on the human

body.

I. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 3.0 - Mercury Impacts on Human Health

•

"Estimate at least 300,000 newborns in US each year with in utero blood [Hg] greater than

5.8

µ1L."

Id. at 1 .

•

"Blood mercury concentrations were 7 X higher among women who reported eating 9+

fish/shellfish meals within past 30 days (i.e., 2 or more times per week) compared with

women who reported no fish/shellfish consumption in the past 30 days (Mahaffey et al .,

2003) ." Id. at 3.

•

"Cord :maternal ratio for blood [Hg] ranges from > 3 to less than 1 . Average - 1 .7 to 1 .8 .

New Japanese data indicate ratio of 1

.6 for cord : maternal pairs ." Id. at 4.,

•

"Number of US births in 2000 : 4,058,814 (National Vital Statistics Reports) . 1 : 1 ratio of

cord to maternal blood [Hg], i .e., 5.8

cord to 5.8 maternal, 7 .8% of women had total blood

[Hg] >/= 5 .8,

-

300,000 newborns each year > 5 .8 ug/L (Mahaffey et al ., 2003) . 1 .7 : 1 ratio

of cord to maternal blood [Hg], i.e. 5.8 cord to

-

3.5

maternal, 15

.7% of women had total

blood [Hg] >/= 3 .5 ug/L, - 630,000 newborns each years >/= 5 .8 ug/L cord blood ." Id. at 5 .

•

"Yokoo et al. 2003. Reduced function on tests of fine motor speed and dexterity and on tests

of verbal memory among adult Amazonian villagers exposed to methylmercury ." Id. at 5.

•

"Beuter and Edwards, 2003 . Cree Indians . Additional studies among adults showed

difficulty with accuracy and sharpness of visual fixation and pursuit in dynamic eye

movements." Id. at 5.

17

---

Glenn Rice & James K

. Hammitt,

Economic Valuation of Human Health Benefits of

Controlling Mercury Emissions from

U.S. Coal-Fired Power Plants (2005)

.

I.

SUMMARY

This report describes the results of a comprehensive study to estimate the health

benefits of reducing mercury emissions from coal-fired power plants in the United

States . Section 1

.1 contains a lot of information about atmospheric mercury deposition, but it

does not appear to be very helpful because it suggests that the majority of mercury does not

deposit locally .

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 3 .0 -

Mercury Impacts on Human Health

•

Figure ES-I shows a "Spectrum of Certainty of Causal Association of Health Effect with

Mercury Exposure with Estimated Benefit Overlay in Millions ($M) and Billions ($B) of

Dollars (2000$)," which is useful to show some of the health and economic benefits of

reducing mercury emissions. Id.

at xix .

•

"Once ingested, roughly

95%

of the methylmercury entering the gastrointestinal tract is

absorbed

. This compound passes through the lining of the gut to the liver and enters the

blood stream where it primarily binds red blood cell proteins, quickly distributing from blood

to the liver, as well as the kidney and skin

. Methylmercury appears to pass the adult blood

brain barrier by binding to a thiol group on cystiene, which is then recognized by a neutral

neurotoxicityamino

acid carrier

. In pregnant

protein (Aschner,females,

methylmercury

1989) ;

entry into

can

the

also

brain

bind

tissues

and pass

can

through

lead to adultthe

placenta tissues

; it may also enter placental tissues through an active transport process via an

amino acid carrier protein

. Stem and Smith (2003) report that methylmercury levels in cord

been

blood

fully

are higher

explainedthan

.

levels

The blood

in maternal

brain barrier

blood

;

does

the reason(s)

not effectively

for this

occlude

observation

methylmercuryhave

not

from the brain tissue of the fetus

. Entry into these brain tissues likely leads to the

neurocognitive deficits observed in some children exposed to methylmercury

." Id at 22 .

•

"Exposures to these high levels of mercury led to severe neurological effects in adults,

children

exposuresand

(i.efetuses.,

severe

; however,

cerebral

the

palsy,

neurotoxicity

delayed walking

hat was

and

associated

talking)

with

occurred

intrauterineat

lower doses

2001b,c)than

the doses

. For

that

example,

resulted

asymptomatic

in adult

mothers

effects (summary

(i

.e.,

mothers

discussions

in whom

in

no

NRC,

neurological

2000

; U

.S.

effectsEPA,

were observed) bore affected children indicating that the developing fetal nervous system

was more vulnerable to methylmercury than the mature maternal nervous system

." Id. at 26 .

•

"A statistically significant association was reported between high maternal mercury exposure

and decreased test scores on the McCarthy Scale of Children's Abilities in the perceptual and

motor domains

. Results of the linear multiple regression analyses showed significant

associations between high maternal mercury exposure and decreased performance on three

neurological tests." Id.

at 28 .

•

"In summary, NRC

(2000)

and, more recently, a subset of the committee (Stem et al

., 2004)

have concluded that, based on evidence from two of the three studies, low dose

in utero

18

---

exposures to methylmercury likely lead to subtle but measurable neurological effects in

children ." Id. at 35

.

•

"In a re-analysis of the New Zealand cohort study (Kjellstrom et al ., 1989), Crump et al .

(1998) reported a decrease of 0 .5 IQ points on the Wechsler Intelligence Scale for Children-

Revised Full Scale IQ for each increase of 1 ppm methylmercury in average maternal hair

during pregnancy." Id. at 86.

•

"We note that Mahaffey et al . (2004) report that roughly 8% of children may be born to

women whose methylmercury intake exceeds the threshold of 0 .1 µg/kg day." Id. at 91 .

Chapter 5.0 - Deposition of Mercury

•

"Thus, when a mix of Hg°, Hg " and HgP is released from an anthropogenic source, Hg u and

HgP are thought to deposit locally and regionally around the source ." Id. at 5.

19

---

Larry Schweiger et al.,

National Wildlife Federation, Getting the Job Done

: Affordable

Mercury Control at Coal-Burning Power Plants

(2004).

I. SUMMARY

Provides an alternative perspective on the economic feasibility of reducing mercury pollution

from power plant smokestacks nationwide

. NWF recaps existing studies showing the

effectiveness and availability of mercury control technology

. Using EPA data, NWF then

estimates the cost of installing and operating this technology across entire state power plant

fleets .

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 4 .0-Mercury Impaired Waters in Illinois

•

"Anglers in the Great Lakes states have faced fish consumption advisories for nearly three

decades

. Illinois' current mercury advisory applies to fish caught in all inland waters,

as well

as in the Great Lakes

. People are warned to limit consumption of popular species such as

bass and walleye

. Cleaning up mercury pollution is essential to protect Illinois' 1,237,000

anglers, and the more than $598 million dollars they spend on fishing each year

." Id. at 29 .

Chapter 5.0

- Deposition of Mercury

•

"Computer modeling done by the U .S

. EPA found that for a site in the Chicago area, 63

percent of the mercury deposition was attributable to Illinois sources, and 41 percent of

Illinois emissions were predicted to fall instate

." Id. at 29

.

Chapter 8.0 -

Technological Feasibility of Controlling Mercury Emissions From Coal-

Fired Power Plants in Illinois

•

"Tests completed to date show that

: (I) Greater than 90 percent mercury control is possible at

plants equipped with ACI and a fabric filter burning bituminous and subbituminous coals and

(2) At least 80 percent control is possible for plants burning lignite coal using ACI and a

fabric filter, with higher reductions likely with a modified activated carbon or higher

activated carbon injection rates ." Id. at 16 .

•

"We assume that activated carbon injection and a polishing fabric filter would be needed to

reliably reach 90 percent mercury capture at coal-fired boilers in Illinois

. For 10 boilers at

four plants, we assume that advanced dry scrubbers are needed

. In general, this methodology

likely results in an overestimation of costs because new technology will soon be available

.

For example, Illinois' Powerton plant was the site of a test activated carbon injection with a

COHPAC fabric filter which achieved over 90 percent mercury control

." Id. at 28 .

•

"The average Illinois residential electricity customer uses 773 kilowatt hours (kWh) of

energy per month and pays a $65 utility bill

. Illinois' 21 plants can be retrofitted to achieve

90 percent control, while costing Illinois consumers only $0

.69 more per month, on average .

Commercial businesses would pay about $5

.82 more on an average bill of $549, while the

average $28,826 industrial bill would increase $305

.47 monthly." Id. at 28-29 .

20

---

•

Estimated costs of controlling mercury at Illinois' coal-fired power plants, and the resulting

impacts on electricity bills, are given in table 10 . Id.

at 29

.

21

---

Rebecca Stanfield, IPIRG, Mercury

Contamination in Illinois, Lake Michigan

Forum(2006)(Presentation)

.

I.

SUMMARY

Excellent summary of studies that have found a significant health impact from exposure to

mercury as well as studies that explore mercury deposition

.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3 .0 - Mercury Impacts on Human Health

•

"2000 NAS report -

Concludes that risk of neurological damage to children from chronic,

low-dose prenatal exposure to methylmercury, likely to be sufficient to result in an increase

in number of children who require special ed

." Id. at 4.

•

"2004 U.S

. EPA estimates doubled previous estimates of the number of children exposed in

the womb to levels of mercury that are sufficiently high to cause neurotoxic effects to

at

630,000

4."2004

based

Harvard

on increasing

School of

evidence

Public Health

that mercury

-

Concluded

concentrates

that damage

in the

to

umbilical

children's

cordbrain."

Id.

function caused by exposure in womb is likely irreversible ."

Id. at 4."September 2005 Mt .

Sinai School of Medicine study published in American Journal of Industrial Medicine

estimates 1500 children per year born with sufficient neurological damage to cause mentally

retarded, estimated cost to economy of $2 billion annually

." Id. at 4.

•

"Mercury exposure can affect multiple organ systems, including nervous system, heart and

immune system throughout lifespan ." Id.

at 5.

•

Higher

•

mercury levels associated with increased risk of heart attacks

. Id. at 5

.

Eliseo Guallar et al, "Mercury, Fish Oils, and the Risk of Myocardial Infarction,"

New England Journal of Medicine, 347

(22), 1747-1754, November 28, 2002

.

•

Ellen Silbergeld, Dept

. of Environmental Health Sciences and Epidemiology, Johns

o

Edna

Hopkins

Yokoo

University,

et al, "Low

Bloomberg

Level Methylmercury

School of Pubic

Expsure

HealthAffects

.

Neuropsychological

Function in Adults," Environmental Health, 2(8), June 2003

.

Chapter 4.0

- Mercury Impaired Waters in Illinois

•

"13 bodies of water with "special" advisory based on monitoring- Sensitive populations

(Children under 15, pregnant or nursing women, women of childbearing age) warned to eat

no more than 1 meal per month, and EVERYONE advised to eat no more than one meal per

week." Id. at 7.

Chapter 5.0 - Deposition of Mercury

22

---

•

Report

"Air

waterwaysdeposition

to Congress)."

Idis

. at

the

10

.

.

Coal

most

burning

significant

power

contributor

plants account

to mercury

for 41

in

%

our

of the

waterwaysmercury

(Uin .Sour

. EPA

•

emissions"In

Illinois,

; power

coal

plants

combustion

emit

bears

more than

even

7000

more

lbs

of the

per

blame

year

."for Idthe

. at 1

problem

l ."Mercury

--

60%

depositsof

the air

from

locally,

U.SAND

. sourcesit

can

."also

Id.

travel

at 12.

long distances

. 66% of mercury deposited in the U.S . comes

•

"Determining factors

: When power plants emit mercury in an oxidized or particulate-bound

before

phase, it

being

deposits

oxidized

locallyand

.

depositedWhen

they

."emit Id.

Hg

at

as

12.NOAA

a gaseous

scientist

elemental

Mark

phase,

Cohen,

it travels

extensivefar

modeling work on mercury deposition into the Great Lakes

:

23

o

o

o

o

Of

16

the

are

top

coal-burning

25 contributors,

power plants22

were

.

in the region/states adjacent to the lake

.

14 were located in Illinois, Indiana, Michigan or Wisconsin

.

Id7

were

. at 13Illinois

.

plants (Fisk, Crawford, Powerton, Will County, Waukegan, Joliet

29).

---

Florida Department of Environmental Protection, 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 (2003)

.

1. SUMMARY

Presents the results of a pilot project designed to evaluate the technical feasibility, given the

present state of knowledge of mercury cycling in the environment, of calculating an

atmospherically driven total maximum daily load (TMDL) for mercury for the Florida

Everglades . This study is extremely scientific and difficult to translate to layman's terms . It

is also very specific to Florida.

II. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 4.0 - Mercury Impaired Waters in Illinois

•

"In the absence of changes to the system other than mercury loading (e.g. changes in sulfur

cycling, nutrient cycling, or hydrology), a reduction of about 80% of current total annual

mercury atmospheric deposition rates would be needed for the mercury concentrations in a 3-

year old largemouth bass at WCA 3A-15 to be reduced to less than Florida's present fish

consumption advisory action level of 0 .5 mg/kg (parts per million) ."

Id. at iii.

24

---

Large Lakes Research Station,

Lake Michigan Mass Balance Project

: Mercury Results

I. SUMMARY

Analysis of mercury in Lake Michigan based on

1994-95 data

. The study finds that the

major

useful

source

graphsof

.

mercury to the lake is atmospheric deposition

. This presentation is full of

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 4 .0 -

Mercury Impaired Waters in Illinois

•

"Mercury concentrations in lake trout have been following a similar pattern of decline as

seen in the sediment core

. Note that since the late 1970's the concentrations seems to have

leveled-off

. The U.S

. EPA target for unrestricted consumption of fish is shown here . Note

that all of the composites exceed this target

." Id. at 5 .

Chapter 5.0 -

Deposition of Mercury

•

"This graphic shows predicted atmospheric mercury deposition for

2001 from EPA's air

model called CMAQ (Community Mesoscale Air Quality Model)

. Note the higher predicted

deposition fluxes in the southern part of the Lake Michigan basin compared to the rest of the

U.S." Id. at 9 .

25

---

Marcia T. Willhite, Mercury Impaired

Waters and the TMDL Process (Presentation) .

I.

SUMMARY

Discusses the difficulty of assigning a TMDL to mercury because few impaired waterways

have point source discharges and asserts that the best way to control mercury in Illinois

waterways is to control atmospheric mercury

.

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 5.0

- Deposition of Mercury

•

Slides 11-15 contain graphical illustrations of mercury reductions in the fish populations of

other states as they have reduced mercury emissions

.

•

"Reduction of atmospheric sources of mercury from within Florida has led to -

80% declines

in mercury in Everglades fish and wildlife in less than 15 years since peak deposition

." Slide

16."To the extent that mercury emissions are in the reactive form (RGM) one can expect to

see benefits at local or regional scale within years to decades ." Slide 16 .

26

---

Clean Air Task Force,

Local Impacts of Mercury from Coal-Fired Power Plants (2003)

.

I. SUMMARY

Lists and explains various factors that affect mercury deposition and risk of exposure

.

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 5.0

- Deposition of Mercury

•

"Elemental mercury can be transported over very long distances with global air masses

. The

atmospheric residence time of elemental mercury is in the range of months to roughly one

year

. The global pool of mercury is almost entirely elemental mercury

." Id. at 1 .

•

Oxidized mercury and particulate-bound mercury have a shorter atmospheric lifetime than

elemental

Id. at 1 .

mercury and will deposit by wet or dry deposition within roughly 50 to 500 miles

.

•

Page 2 contains a table that shows the "Effect of Air Pollution Control Device on Mercury

Speciation

."

•

"Characteristics of the boiler influence the amount of mercury emitted and its dispersion in

the atmosphere

. These characteristics include the size (in MW) of the facility and how much

coal it bums, stack height and the type of air pollution control device in place

. Tall stacks

typically cause the plume to disperse further from the facility

. As noted above, different

types of control devices capture the different mercury species to varying degrees

. A large

plant

Id. at 3burning

.

coal will have more mercury emissions on a mass basis than a smaller plant

."

•

also

"More

affects

mercury

local

is deposited

depositionlocally

. Facilities

in a humid

with shorter

site compared

stacks

to

will

an

have

arid

more

site

local

. Stack

depositionheight

than those with taller stacks

. Of course, the smaller coal plants have lower emissions, so the

mass of emissions deposited locally by a small plant may still be smaller than emissions

deposited from a large plant, even though on a percentage basis the smaller plant has higher

deposition." Id. at 4 .

•

"The impact of the deposited mercury emissions depends on the proximity of the plant to an

ecosystem where the mercury will be methylated, accumulated in the food chain and ingested

by susceptible populations ." Id. at 4.

•

Table 3 on page 5 shows the "Results of EPA's Mercury Exposure Analysis for Individual

Power Plants

." Id. at 5.

27

---

Dr. Mark Cohen, Atmospheric Deposition of

Mercury to the Great Lakes, Presentation at

An Ecosystem Approach to the Health Effects of Mercury to the Health Effects of Mercury

in the Great Lakes Basin - Clearly International Conference Center, Windsor, Ontario,

(2003) .

I. SUMMARY

In this document, a bullet-point presentation of the following topics are provided

: the

atmospheric process for mercury, general questions regarding atmospheric deposition of

mercury, the methodological approach used to predict atmospheric deposition, and preliminary

results of the atmospheric modeling analysis .

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 5 .0 - Mercury Deposition

•

Three forms of atmospheric mercury- Id. at 3 .

1) Elemental

-

95% of Atmospheric Mercury

- not very water soluble

- long atmospheric lifetime ( .5 - 1 yr.)

- globally distributed

2) Reactive Gaseous Mercury (RGM)

- a few percent of total in atmosphere

- oxidized mercury Hg(II)

- very water soluble

- short atmospheric lifetime (1 week or less)

- local and regional effects

3) Particulate Mercury Hg(p)

- a few percent of total Hg

- Hg compounds associated with atmospheric particulates

-

moderate atmospheric lifetime (perhaps 1-2 weeks)

- local and regional effects

•

"Atmospheric deposition

almost certainly plays a very significant role in the

mercury contamination of the Great Lakes"

Id. at 8.

- Description of the Methodology used for modeling atmospheric deposition

.

-

Start with atmospheric mercury emissions inventory

-

Perform atmospheric fate and transport

modeling of these emissions (using a modified

version of NOAA's HSYPLIT model)

-

Keep track of source-receptor information

during the modeling

- Evaluate the modeling by comparison of the

predictions against ambient monitoring data

-

If model is performing satisfactorily, report

28

---

source-receptor results from the simulations

-

(Similar to earlier work with dioxin and

atrazine) .

•

A graph showing the percent of total emissions or Deposition of Mercury Arising

From Within Different Distance Ranges From Each of the Great Lakes (including Lake

Michigan) .

Id. at 32

. This is evidence that the percent of deposition in Lake Michigan is

greatest at shortest distances - meaning coal fired power plant emissions located nearest to Lake

Michigan, which would include Illinois plants, have the greatest effect on total mercury

deposition in Lake Michigan .

29

---

Hubbard Brook Research Foundation,

Comments on the U.S. Environmental Protection

Agency's, "Proposed National Emissions for Hazardous Air Pollutants

; and, in the

Alternative, Proposed Standards of Performance for New and Existing Stationary Sources

:

Electric Utility Steam Generating Units" (2004) .

I. SUMMARY

Provides key examples from the literature and ongoing studies regarding the cycling, effects,

and management of mercury in the environment . These comments suggest that special

attention should be paid to the timing and levels of mercury emissions reductions, as well as

any cap and trade proposal for mercury pollution .

II. INFORMATION TO THE IPCB HEARING SCHEDULE

Chapter 5 .0 - Deposition of Mercury

•

"Given its many species, mercury can be a local, regional and global pollutant with short (1-2

days) or long (1-2 years) residence times in the atmosphere

. Consequently, it can deposit

locally or travel long distances depending on its form (Dastoor and Larocque 2004)

. The

potential for mercury to act as a global pollutant does not obviate the need for local, regional

and continental control efforts in addressing the problem of mercury deposition (Engstrom

and Swain 1997) ."

Id. at 4-5 .

•

"Taken together, recent research on the dynamics of elemental mercury, including elemental

mercury emitted by domestic electric utilities, suggests that its atmospheric residence time

can be significantly decreased in certain environments, and it can therefore contribute to local

and regional mercury pollution."

Id. at 6.

•

"With respect to the oxidized forms of mercury, it is generally assumed that they are not

reduced to elemental mercury in the atmosphere

. Current infonnation suggests, therefore,

that oxidized mercury is not likely to enter the global pool, but rather is more likely to be

deposited regionally or locally

." Id. at 6 .

•

"Nevertheless, most research indicates that mercury sources in the U

.S. are the largest

contributor to mercury deposition in the

U .S ." Id. at 6.

•

"A recent project funded by the New York State Energy Research and Development

Authority (NYSERDA 2002) assessed the contributions of local, regional and global mercury

sources to mercury deposition in New York State

. For three study areas in New York (the

Adirondacks, Catskills and Finger Lakes), the report shows that mercury emissions within

the U.S

. are the largest single source of mercury deposition (NYSERDA 2002)

. . . These

results are consistent with the 1997 Mercury Report to Congress which estimated that

approximately 60 percent of the mercury deposited in the U

.S . originates in the U

.S ., with the

remaining 40 percent coming from the global reservoir (EPA 1997)

." Id. at 6.

•

"Stated another way, 46 percent of the mercury deposited within the U.S

. that originates

within the U .S. (and is therefore subject to U

.S. law) is likely to come from electric utility

emissions ." Id. at 8 .

•

Table 3 includes useful information on the wildlife effects of mercury pollution

. Id. at 9-10.

•

"Moreover, it is important to note that some ecosystems are more mercury-sensitive than

others because of substantial differences in mercury transport (ef Hurley et al

. 1995), net

30

---

methylation (Benoit et al . 2003), and bioaccumulation rates among ecosystems

. Wiener et al .

(in press) define mercury-sensitive environments as those that include wetlands, low-

alkalinity or low pH lakes, surface waters with nearby wetlands, and dark-water lakes and

streams. They note that these ecosystems can experience "significant methyl mercury

contamination of fish and wildlife in upper trophic levels" with relatively small inputs of

total mercury (<i to 10 g Hg/ha) (Wiener et al

. in press) ." Id. at 12.

•

"Lake sediments in several regions of the U .S

. document a period of mercury enrichment

from 1850 through the 1960s and 1970s (Fitzgerald et al . 1998, Engstrom and Swain 1997,

Lorey and Driscoll 1999, Kamman and Engstrom 2002)

. These studies all suggest that over

the past 20-30 years mercury deposition has decreased in association with reductions in total

U.S. mercury emissions

. These patterns demonstrate a strong relationship between emissions

of mercury from sources within the U.S. and mercury levels in U .S . lakes. This relationship

was confirmed by Engstrom and Swain (1997) by using lake sediments from a range of sites

to track the environmental response to changes in emissions

. With this method, they showed

that decreased mercury deposition in the Upper Midwest is attributable to reductions in

emissions from U .S. sources (Engstrom and Swain 1997) ." Id. at 13 .

•

". .

.two studies in northern Wisconsin also link changes in mercury deposition and ecosystem

mercury. Watras et al . (2000) observed that decreases in the mercury concentrations in a

seepage lake were related to decreases in atmospheric mercury deposition . In 2002, they

reported a rapid decline in mercury in fish as mercury inputs to the system declined (Hrabik

and Watras 2002) . Based on this and other information, Hrabik and Watras (2002) concluded

that even though there is a large reservoir of mercury in lake sediments and in decomposing

organisms, newly deposited mercury dominates bioaccumulation processes in their study

lakes (Hrabik and Watras 2002) ." Id. at 13 .

•

"This finding was confirmed by a study in Wisconsin, which indicated that inputs of "new"

mercury strongly control the level of mercury in surface waters and biota . In other words,

bioaccumulation of mercury in ecosystems such as the Wisconsin lakes is more dependent on

new inputs of mercury from the atmosphere than the recycling of previously deposited

mercury. Therefore, it is the newly added mercury from emissions that is of primary

importance in aquatic ecosystems and the sooner these inputs are reduced, the greater impact

these reductions will have on ecosystem recovery (Hrabik and Watras 2002) ."

Id.

at 16

.

31

---

State and Territorial Air Pollution Program Administrators (STAPPA) & Association of

Local Air Pollution Control Officials (ALAPCO), Regulating Mercury from Power Plants : A

Model Rule for States and Localities (2005) .

I. SUMMARY

The goal of the report is to provide state and local governments the tools needed to obtain

reductions in mercury emissions required to meet the requirements of the Clean Air Act

(CAA)

. The Model Rule would protect public health using technologies that are available

and rapidly entering the commercial market

.

I. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 5 .0 - Deposition of Mercury

•

"In some areas of the country, mercury emissions from coal-fired power plants may account

for as much as 80 percent of the mercury deposited, according to recent studies by the

Electric Power Research Institute (EPRI)

. According to EPRI, the portion of mercury

deposition from coal-fired plants ranges from 10 to 80 percent depending on the region .

EPA's own modeling shows that in many areas of the country where there are coal-fired

power plants, those plants account for more than half of mercury deposition ." Id. at 14.

•

"Gaseous elemental mercury may move long distances with air masses and resides in the

atmosphere usually until it oxidizes, which can take up to a year . The reactive and

particulate-bound forms of mercury - oxidized mercury and mercury adsorbed to particles -

stay in the atmosphere for a few days and are usually deposited within 50 to 100 miles of a

source by wet or dry deposition

." Id. at 15 .

•

"Field studies show a direct relationship between mercury deposition and mercury levels in

fish. The findings indicate that reducing domestic emissions of reactive mercury compounds

can lower mercury concentrations in fish in the United States, regardless of distribution of

contributions from natural and foreign sources ." Id. at- 15 .

•

"Changes in atmospheric mercury deposition can rapidly affect concentrations in fish,

according to a 2002 study by Wisconsin researchers . The research team found a 10-percent

decrease in deposition corresponded with a 5-percent decrease in mercury levels in fish

tissue." Id. at 15 .

• " . .

.researchers suggest that the amount of mercury added to an ecosystem from new sources,

rather than that already trapped in sediment, is the main determinant of how much mercury is

introduced into the food chain ." Id. at 15.

Chapter 8.0

- Technological Feasibility of Controlling Mercury Emissions From Coal-

Fired Power Plants in Illinois

•

"Field tests of the most highly developed mercury control technology, known as sorbent

injection, have achieved mercury capture of up to 95 percent at coal-fired power plants .

Sorbent injection (typically Activated Carbon Injection) and other advanced technologies

have not yet been permanently installed at power plants because no law requires it

. But 95-

percent capture rates have now been demonstrated in short-term tests for all ranks of coal,

32

---

bituminous, subbituminous and lignite

. Chemically enhanced sorbents make high rates of

removal of all species of mercury achievable even with low-rank coals ." Id.

at 25

.

•

"Large-scale field tests of ACI on coal-fired electric generating units have demonstrated

removal rates of 90 percent and higher. Although no ACI unit has been installed

commercially on an EGU yet, 90-percent and higher mercury capture with ACI is feasible

.

The technology involves very little capital equipment

: a silo to hold the sorbent, and hose,

nozzles and pumps to inject it into the flue gas ducts . Tests on such ACI systems continue to

show improvement. The removal rates may be further improved when the technology is used

along with such additional controls as a fabric filter, or "bag house," used for PM control .

Some vendors are currently offering ACI to electric generating plant customers and two sales

have so far been reported ." Id. at 26 .

•

"The efficiency of ACI in removing mercury from lower ranks of coal, such as

subbituminous and lignite, has clearly caught up with ACI's success rate in removing

mercury from bituminous coal. In a leading approach, the injection of halogenated sorbents

into the gas stream of units burning lower ranks of coal can enable ACI to attain results

comparable to those with bituminous coals . Carbon sorbents impregnated with bromine or

iodine compounds enhance capture of mercury on subbituminous western coals, which

contain lower chlorine levels and are therefore more challenging to clean." Id. at 26 .

Chapter 9.0 - Economic Modeling

•

"The capital costs of installing ACI are two orders of magnitude less than the capital costs of

equipment used to control oxides of sulfur or NO, Recent data from field testing sponsored

by NETL indicate that the average cost of controlling mercury will range from 0.2 to 0.8

mills/KWh. Based on this estimate, mercury control would add 15 to

60

cents per month to a

typical 750 KWh residential electric bill . Taking into account capital and operating costs of

ACI, one state agency has estimated the cost of mercury control for its ratepayers at less than

$10 per year ." Id. at 26 .

•

"At a Wisconsin state hearing, one participant may have summed it up best when he pointed

out that, having paid $20 for his annual fishing license, he would be happy to pay a similar

amount if necessary to be able to eat the fish he caught ." Id. at 27 .

33

---

National Wildlife Federation, Controlling Mercury from Power Plants : Current state of

knowledge (2003) .

I. SUMMARY

Information on the method and effectiveness of ACI for mercury capture .

I. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 8.0 - Technological Feasibility of Controlling Mercury Emissions from Coal-Fired

Power Plants in Illinois

•

"The technology that has undergone the most extensive testing is activated carbon injection

(ACI). If a plant is already operating an electrostatic precipitator (ESP), carbon is injected in

the flue gas upstream of the ESP

. Achieving 90% mercury removal from power plants will

most likely require the additional installation of a small fabric filter downstream of the

carbon injection system ." Id. at 1 .

•

"If burning bituminous or subbituminous coals, the combination of a fabric filter and ACI

can achieve 90% mercury removal ." Id. at 1 .

•

"If burning lignite, in addition to installing a fabric filter, flue gas cooling will likely be

required to achieve 90% capture ." Id. at 1 .

•

"Preliminary results at PG&E's Brayton Point plant, which bums bituminous coal and is

equipped with two electrostatic precipitators, showed 90% control at high activated carbon

injection rates." Id. at I .

•

"At Southern Company's Gaston Plant (Alabama Power), which bums bituminous coal and

is equipped with a COHPAC fabric filter, 85% control was achieved using activated carbon

on a continuous basis, with short-term removals averaging more than 90% ." Id. at 1 .

•

"At We Energies' Pleasant Prairie plant, which bums Powder River Basin subbituminous

coal and is equipped with an electrostatic precipitator, over 70% mercury control was

measured at the highest activated carbon injection rate tested . Higher capture efficiency is

likely if a fabric filter is used in conjunction with the activated carbon technology

." Id. at 2 .

•

"At Otter Tail Power Company's Big Stone plant in South Dakota, which bums

subbituminous coal, the Advanced Hybrid Particulate Collector (which combines aspects of

ESPs and fabric filters) was found to capture nearly 90% of total mercury, at a low activated

carbon injection rate." Id. at 2.

• "A North Dakota lignite-fired boiler equipped with a baghouse measured over 90% mercury

control using iodine impregnated carbon, and 70% mercury control using activated carbon at

the highest injection rate tested ." Id

.

at 2.

Chapter 9.0 - Economic Modeling

•

"ACI for all coal types is estimated to cost about

.4 mills/KWh (4% of I cent) ." Id. at 1 .

•

"Installation of a fabric filter is estimated at $40-$55/kW ." Id. at 1 .

• "It is estimated that over the long run, it will be more economical to install a fabric filter than

to use higher carbon injection rates with an electrostatic precipitator to achieve 90% removal

:

$700,000 vs . $2 million over a 20yr amortization period ." Id. at 1 .

34

---

James

Utility

Staudt,

Plants

-AAndover

Review

Technology

of Technology

Partners,Status

and

Mercury

Cost

Control

(2006)

(Presentation)From

Coal-Fired

.

Electric

I. SUMMARY

A very useful review of the capability and cost of available mercury control technologies

with emphasis on ACI

.

II

. INFORMATION RELEVANT TO THE IPCB HEARING SCHEDULE

Chapter 9.0 -

Economic Modeling

•

Slide 13 has a useful table on the cost of sorbent injection

. The table shows that ACI could

be installed in about 6 months for a cost of about $2/KW

. Id.

at 7.

•

at

Slide

8.

16 has a graph showing that the cost of sorbent is low and mercury removal is high

. Id.

•

at

Slide

12

24 has a graph showing that the cost of sorbent is low and mercury removal is high

. Id.

•

cost-mostly

"Sorbent injection

sorbentsystem

. Id. at

only12

.

-

capital cost has almost negligible contribution to generation

35

---

Dr. Mark Cohen, Local and Regional Deposition Impacts of Atmospheric Mercury

Emissions,

Presentation at Mercury Rule Workgroup Meeting PA Department of

Environmental Protection, (2005)

.

I. SUMMARY

This is a presentation given to the Mercury Rule Workgroup Meeting of the PA Department of

Environmental Protection . Included herein is a bullet point and graphical presentation of the

local and regional impacts of atmospheric mercury emissions focusing primarily on the

difficulties in detennining the exact impacts via monitoring and modeling techniques .

Specifically included is the following

: the difficulty in accurately determining local and

regional impacts of mercury deposition because of the dependency on the amount of mercury

emitted, stack height having an effect on proximal deposition, the dependency on the form

emitted, the dependency on the distance and direction of the source emitted, the episodic nature

of emissions (on a day-to day basis), the dependency on plume chemistry, the measurement

based evidence (including examples, advantages, and limitations), the modeling based

evidence (including examples, advantages and limitations)

. Of particular significance is the

evidence tending to show the overestimation of global impacts and the underestimation of local

and regional impacts in the CAMQ results used in the development of the CAMR rule (more

information provided below) .

II. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 5 .0 - Deposition

•

CMAQ results used in the development of the CAMR rule .

- Possible underestimation of local and/or regional impacts in CMAQ Mercury modeling

done in support of CAMR . Id.

at 65 .

- .36 km grid used in the development of CAMR too coarse to capture local results, they

are artificially diluted

. Id. at 65.

- Possible overestimation of local and/or regional impacts in CMAQ Mercury modeling

done in support of CAMR . Id. at 66 .

-

Strong influence of boundary conditions appears that Reactive Gas Mercruy (RGM)

may have been specified too high on the boundary due to an inconsistency in

physics/chemistry . Id. at 66.

- Two reactions included in CMAQ oxidizing elemental HG(0) to RGM may have been

significantly overestimated." Id. at 66.

36

---

Larry Schweiger et al.,

Getting the Job Done : Affordable Mercury Control at Coal-Burning

Power Plants, National Wildlife Federation (2004)

.

I. SUMMARY

This document persuasively argues, with supporting evidence, the technical feasibility and

affordability of controlling 90% of mercury emissions . This article specifically addresses the

shortcomings of CAMR prior to its enactment

.

II. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 3.0 - Mercury Impacts on Human Health

•

"In January 2004, a U .S

. EPA scientist released new research estimating that nearly one in

six

U.S

. women of childbearing age has mercury levels in her blood above what is considered

safe for an unborn child, doubling previous estimates

. This new estimate equates to

approximately 630,000 newborns each year who may have been exposed to unsafe levels of

mercury in utero." Id. at 7.

Chapter 8.0 -

Technical Feasibility

•

Key Findings . Id. at 6

"Mercury emissions can be controlled by 90 percent at power plants burning bituminous,

subbituminous, and lignite coals"

"Mercury emissions can be controlled by 90 percent at power plants burning

bituminous, subbituminous, and lignite coals"

"In our five case study states, all of which rely significantly on coal, achieving 90 percent

mercury control could cost the average residential customer 69 cents to approximately $2

.14

a month, depending on the state ."

"Commercial and industrial increases were similarly reasonable-between I and 3 percent

increases in electric bills ."

"For the most common configurations, the cost of achieving 90 percent control is only

slightly higher than achieving 70 or 80 percent control ."

"The findings reinforce similar cost estimates made by equipment manufacturers, the

Department of Energy, and the EPA ."

37

---

Zachary Corrigan,

Fishing for Trouble-How Toxic Mercuiry Contaminates Fish in

U.S.

Waterways, U .S.

PIRG Education Foundation (2004) .

I

. SUMMARY

This paper argues for 90% reduction of mercury from power plants and argues

against having less stringent requirements recommended by the Bush Administration prior to

promulgating CAMR

. Specifically included are statewide advisories on fish consumption as

well as advisories in lakes and rivers and the threat mercury contamination poses to

recreational fishing and the public health in general

.

II

. INFORMATION RELEVANT TO IPCB HEARING SCHEDULE

Chapter 4.0 - Illinois Impaired Waters

•

Table B shows that 100% of lake waters in Illinois are under advisory . Id. at 10 .

•

Table L breaks down, by State, the economic value received from recreational

fishing

. Illinois receives $598,376,000 . Id. at 19 .

38