September 20, 2006
Office of the Clerk
Illinois Pollution Control Board
100 West Randolph
Chicago, IL 60601
Re: Comments on Proposed New 35 ILL
. ADM. CODE 225, Control of Emissions from
Large Combustion Sources (Mercury) ; R06-25
Honorable Members of the Board :
American Bottom Conservancy, based in the Metro East St . Louis area, supports the proposed
rule ("the rule") filed with the Illinois Pollution Control Board by the Illinois Environmental
Protection Agency-although we have reservations as to the amendments on the Ameren and
Dynegy proposals (see below)
. This rule is necessary to protect the health of the citizens of the
Metro East and throughout the State
. It is both technologically feasible and cost effective
.
The rule is necessary to protect the health of Illinois citizens, especially our children
. Mercury is
a neurotoxin that passes through the placenta and poisons fetal brain development
. Every day,
thousands of developing fetuses, newborns and young children are exposed to mercury when
either pregnant and nursing women eat contaminated fish or the children themselves eat fish
. In
the Metro East, we have many families that rely on fish caught at our area lakes and rivers for
their main source of protein, because it is free
. And while there may be a warning as to limiting
consumption because of mercury on the Illinois Department of Health website, many of those
people do not have access to a computer . There are no signs at the river or lakes, even though
the lakes are owned by the State and part of a state park
.
Six to ten percent of women of childbearing age in the U .S
. are estimated to have mercury levels
high enough to put their developing children at increased risk for developmental problems from
mercury poisoning
. That translates to more than 100,000 women of childbearing age in Illinois
whose blood mercury levels may exceed the federal recommended limit
. This is all the more
tragic when combined with the many toxics to which they are exposed, both airbom from the
many industrial plants both in the Metro East and across the river in St
. Louis, and contaminants
such as lead found in the paint in our older homes . We have no idea as to the cumulative
impacts from all the toxins on the intelligence and behavior of our children
.
Coal-fired power plants in Illinois have resulted in severe mercury hot spots in the state
. We
have one such hot spot in East St . Louis
. Illinois is ranked fourth in the nation for having the
most severe mercury pollution hot spots
.
A Aerie aw Bottom Congaivaney
P.O
. Box
4242, faiwiew HaigAtg, 71 . 62208
RECEIVED
SEP 2 0 2006
Pollution
STATE OF
Control
ILLINOIS
Board
The southern Great Lakes region experiences one of the highest deposition rates in the U .S. In
this region, local and regional sources are the main cause of elevated mercury concentrations,
with the great majority of mercury contamination coming from coal-fired powers plants . Coal
plants produce 71 % of the mercury pollution emitted in Illinois and the 60% in Great Lakes
states as a whole . Fish in Lake Michigan and all Illinois waterways are contaminated with
mercury. The Illinois Department of Public Health has issued "fish advisories" warning pregnant
women, women of childbearing age and children to limit their consumption of fish from every
lake, river and stream in Illinois. But, there are no signs posted at the bodies of water. Our
waters locally also have advisories for PCBs and farm chemicals, adding to the toxic burden of
children and their parents .
Consequently, regulating the leading source of mercury pollution in Illinois-coal-fired power
plants-will reduce mercury exposure and the resulting ill health effects of that exposure .
Studies show a direct relationship between mercury deposition and mercury levels in fish
. These
studies conclude that reducing emissions of mercury lowers mercury concentrations in fish,
regardless of contributions from natural or foreign sources
. One study has shown that a
reduction in local atmospheric mercury emissions led to a decline of more than 80% of mercury
contamination in fish .
The Illinois rule is necessary because the federal rule proposed by the Bush administration is
inadequate to address the problem of mercury contamination in Illinois . The Bush
Administration's rule will perpetuate mercury hot spots such as those in East St
. Louis and
throughout the State by allowing coal plants to continue using older technology and also to
purchase the right to continue polluting at high levels rather than installing equipment to clean up
their plants and protect our health and environment .
ABC has concerns that the new Peabody Prairie State plant at Marissa-even though it has not
even begun construction-might be given extra time to come into compliance with the Illinois
Rule. According to the Prairie State permit, they would emit some 280 pounds of mercury per
year. That is unacceptable
. Prairie State should be required to comply with the originally
proposed timeline or revise their design and control technology
. Likewise, Dynegy's Baldwin
plant emits some 260 pounds of mercury per year . Our organization intervened in the U
.S .EPA
lawsuit against Dynegy which resulted in the Consent Decree setting a timeline for compliance
.
The IEPA Dynegy agreement will not have a significant positive impact on those citizens who
live in the Metro East
. Baldwin was required to install more protective control technology by the
Consent Decree . From our reading of the Agreement,
there will be no improvement at all at the
Wood River facility . The Metro East is nonattainment for both ozone and fine particulates
. Our
citizens and especially our children and elderly are significantly impacted by our air quality that
does not meet federal standards
.
Ameren's plants affecting the air quality of the Metro East are, alas, for the most part located in
Missouri-at Rush Island, Meramec and Portage des Sioux . While we welcome Ameren's
announcement that it will install stricter controls at the Sioux plant-and that should have a
positive impact on the air quality and nonattainment status of Jersey County, that plant is located
considerably north of the Metro East counties of Madison and St
. Clair and others in the
nonattainment area
. We can only hope that Ameren will continue its efforts to decrease its
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considerable emissions with increased controls at their other plants
. We are encouraging the
State of Missouri to adopt a rule similar to the proposed Illinois rule
.
The Illinois rule will be effective
. States such as Georgia, Maryland, Massachusetts, Michigan,
Minnesota, New Jersey and Pennsylvania, among others, have initiated proposals with mercury
reductions from power plants similar to those in the Illinois proposed rule, demonstrating that
this rule is reasonable and the bases for the rule are sound
. IEPA and proponents made the
necessary showing at the hearings and in filings that the rule is both technically feasible and
economically reasonable .
•
The technology for controlling mercury in accordance with the requirements of the rule is
readily available
. Activated carbon injection
("ACI"), with brominated or halogenated
sorbents where appropriate, has been shown to achieve 95-percent capture rates in short-
term tests for all ranks of coal burned in Illinois
.
•
The technology is also economically reasonable
. The reductions required by the
proposed rule could be achieved while costing Illinois residential consumers only $0
.69
more per month, on average
. Commercial businesses would pay about $5
.82 more on
average, while the average industrial bill would increase $305
.47 monthly. The cost of
ACI per unit is approximately is less than one million dollars
.
•
Where 90% is not achievable with ACI alone, other pollution control options can be used
to achieve 90%, including controls for other pollutants that provide additional mercury
reductions .
The rule as written and amended offers sufficient flexibility in the rule for operators to choose a
compliance pathway that is appropriate for them in terms of both means and timing of achieving
the necessary reductions
. The flexibility built into the rule includes
:
•
The initial averaging period,
•
The output based standard,
•
The temporary technology-based standard, and
•
Ameren and Dynegy's proposed multi-pollutant standard
.
Ameren and Dynegy's support for the rule demonstrates that facilities within the State of Illinois
can achieve the required reductions contained in the proposed rule in a cost-effective manner
. It
also demonstrates that they will benefit from the deal with respect to the timeline and other
pollutant requirements
. We regret that such a compromise had to be made in order to get the rule
passed
. Nevertheless, we believe in this case we must support the proposed rule
. We ask the
Board to vote in favor of the rule
.
Sincerely,
Kathy Andria
Kathy Andria
President
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