Thank you, Chairman Adolph and members of the Committee, for the opportunity to testify on the important issue of mercury pollution in Pennsylvania. As you may know, PennEnvironment is a statewide non-profit, non-partisan environmental advocacy organization with more than 18,000 citizen members across the state. PennEnvironment has been active on mercury pollution issues at the state and national level, and has worked to educate the public and decision makers on this issue. Most recently, we have been involved in the Pennsylvania Department of Environmental Protection’s (DEP) Mercury Rule Workgroup, and PennEnvironment was one of the original petitioners signed onto the petition submitted by Citizens for Pennsylvania’s Future on August 9, 2004, urging the state to take action to cut mercury pollution from Pennsylvania’s coal-fired power plants.
Summary: Given the public health and environmental threats posed by mercury pollution from Pennsylvania’s coal-fired power plants, the Bush administration’s weakening of the Clean Air Act’s federal mercury pollution reduction requirements, and the availability of mercury pollution control technologies that can significantly reduce mercury emissions from coal-fired power plants, PennEnvironment is urging state regulators to require 90 percent mercury reductions from the state’s coal-fired power plants.
In order to compliment the testimony submitted by Citizen’s for Pennsylvania’s Future at this hearing, my testimony will focus on three aspects of the mercury pollution issue: the environmental impacts of mercury pollution, the issue of mercury “hot spots”, and the mercury control technologies currently available to reduce mercury pollution from coal-fired power plants.
The Environmental Impacts of Mercury Pollution: Beyond the public health threats posed by mercury pollution to humans through the consumption of mercury-contaminated fish, mercury pollution also poses a significant threat to our natural environment.
Looking first at mercury levels in fish, a number of studies have found that mercury contamination is a widespread problem for many fish species. A recent PennEnvironment Research & Policy Center study analyzed data from the U.S.
Environmental Protection Agency’s (EPA) ongoing National Study of Chemical Residues in Lake Fish Tissue, and found that in Pennsylvania, all 52 fish tested were contaminated with mercury, and 45 percent of all composite samples and 83 percent of predator fish composite samples were contaminated with mercury levels that exceed EPA’s “safe” consumption limit for women (0.13 parts per million). Fish species tested in Pennsylvania included largemouth bass, yellow perch, carp, brown bullhead and bluegill. Additional studies have found that mercury exposure in fish can result in embryo mortality in lake trout eggs; adverse effects on growth and development in early life stages; decreased spawning success; altered schooling movements; and acute toxicity (leading to death).
But mercury’s threat to our environment extends beyond fish populations—and beyond the aquatic environment. The best example of this was illustrated in a study released in 2005 by the BioDiversity Research Institute. The four-year study analyzed mercury levels in Northeastern waterways, vegetation and a variety of animal species beyond fish.
With regard to mercury deposition—or the process by which mercury settles out of the air onto land and water—the study found that the uptake of mercury by trees may play a more critical role in the mercury cycle than previously thought. The rough foliage of trees helps to “scavenge” more mercury out of the air, and the stomata on the leaves of trees may draw in mercury through their natural gas exchange functions. This cycle is critical, because it suggests that as leaves fall from trees, their mercury content can then be ingested by insects on the forest floor as well as swept away by snowmelt into nearby waterways.
This process by which insects become contaminated with mercury helps to provide a clearer explanation for the study’s most alarming findings: mercury contamination in songbirds that do not eat fish—the animal traditionally sited as being the key point in nature’s food chain with regard to mercury pollution. Of the four songbird species tested, the Bicknell’s thrush contained the highest mercury concentrations (0.08 to 0.38 parts per million). Also, concentration levels were highest in individuals older than two years, suggesting that concentration levels in the birds are increasing over time. With regard to fish-eating bird species, the study found that these species generally had higher mercury concentrations than songbirds, with the common loon exhibiting the highest mercury concentration levels (0.1 to 8.6 parts per million).
These findings are even more alarming given the variety of negative impacts of mercury contamination on birds. Specifically, mercury contamination in birds has been linked to a variety of negative reproductive (fewer eggs produced and reduced chick survival), behavioral (decreased likelihood of hunting and exaggerated response to fright stimulus), and neurological (brain lesions, spinal cord degeneration, weight loss, and difficulty flying, walking and standing) effects in the birds.
The BioDiversity Research Institute’s study also examined mercury levels in other species, including crayfish, salamanders, mink and otters. Of the mink and otters sampled, 36 percent exceeded the mercury level threshold for adverse effects and 1 percent exceeded the mercury level threshold for acute toxicity (leading to death). Adverse health impacts in mink and otters due to mercury contamination include impairment of sensory and motor skills, and anorexia and weight loss.
Beyond the negative impacts of mercury pollution on individuals within a variety of species, the other key aspect of mercury contamination in our environment is that it bio-accumulates as it moves up the food chain. Bioaccumulation is the process by which species at the bottom of the food chain, such as smaller fish and insects, usually have lower levels of mercury. But as these species are eaten by predator species, who are then eaten by larger predator species, the mercury concentration levels—and the chance of negative health impacts—increase with each level of the food chain. For example, the amount of methylmercury in predator fish at the top of the aquatic food chain can be 1 million to 10 million times greater than the concentration of methylmercury in the surrounding water.
Mercury Hot spots: Pennsylvania’s coal-fired power plants emitted roughly 6,700 pounds of mercury in 2003, the last year for which we have complete data from EPA’s Toxics Release Inventory. This ranked Pennsylvania third among states nationally for the highest power plant mercury emissions, and Armstrong and Indiana County ranked first and fourth, respectively, out of all counties nationwide for the highest power plant mercury emissions. Four other Pennsylvania counties made the top 100 list nationally.
These statistics provide the appropriate backdrop for the discussion of mercury “hot spots,” and emphasize why it is imperative that we consider hot spots in our discussion of the need to cut mercury pollution in Pennsylvania. Mercury hot spots are those areas with mercury deposition higher than in surrounding areas, and there is both significant evidence that hot spots exist and that coal-fired power plants create hot spots in nearby communities. It follows that the communities near or in a mercury hot spot will face an increased public health threat due to increased mercury levels.
Countering the claim by some that global deposition (mercury pollution originating from outside of the United States) accounts for most of our mercury pollution problem, many studies suggest that in places where there are large local sources of mercury pollution, such sources account for 50 to 80 percent of mercury deposition. A 2003 study by Environmental Defense that examined EPA modeling data found that over 50 percent of the mercury deposition in Pennsylvania hot spots was due to local sources.
Other studies reinforce that the deposition of mercury in the areas surrounding coal-fired power plants and other large sources can be very localized. Dr. Mark Cohen of the National Oceanic and Atmospheric Administration, in a presentation before DEP’s Mercury Rule Workgroup, presented findings that upwards of 50 percent of the ionic mercury emitted from a stationary source can be deposited within 500 km (310 miles) of the source. I am submitting for the record Dr. Cohen’s Power Point presentation from DEP’s November 18, 2005 Mercury Rule Workgroup meeting.
Perhaps most significantly, initial results from an ongoing EPA study show that 67 percent of the mercury in rain collected at a monitoring site in Steubenville, Ohio originated from coal-burning power plants within 400 miles of the site. The study was conducted over two years, and is expected to be released this spring. I am submitting for the record two EPA Power Point presentations which describe the findings from this ongoing study.
Studies have also shown that when mercury emissions are reduced from a source, the surrounding environment shows lowered mercury levels. Specifically, a 2003 study by the state of Florida, the EPA and the U.S. Geological Survey found that the levels of mercury found in largemouth bass and other wildlife in the Everglades have declined about 80 percent since state and federal agencies required municipal and medical waste incinerators to cut their mercury emissions.
The threat of hot spots means that the communities surrounding Pennsylvania’s coal-fired power plants—and even those up to 400 miles away from a power plant—are at an increased risk of high mercury levels in their environment. For this reason, the environmental and public health communities have strongly opposed the mercury trading program put forth in March, 2005 by the Bush administration in their so-called “Clean Air Mercury Rule.” In this trading program, power plants can avoid reducing their mercury emissions by buying credits from other plants in different locations. Trading the right to pollute is “very risky,” according to prominent scientists in the field, and could create mercury hot spots in Pennsylvania and across the country.
It is largely because of the Bush administration’s mercury policy allowing for mercury trading—and thus endangering Pennsylvania’s environment and public health—that PennEnvironment feels a state-level mercury rule for Pennsylvania’s coal-fired power plants is needed. We obviously hope that DEP’s state-level proposal will not include a trading program or any other system that allows plants to avoid or delay reducing their mercury emissions. Given the many sources of mercury pollution in Pennsylvania and the serious threat of hot spots posed by such sources, PennEnvironment would likely oppose any state-level proposal that allowed for plants to avoid or delay reducing their mercury emissions.
Mercury Control Technologies for Coal-Fired Power Plants: Thankfully, the technology exists to drastically reduce mercury pollution from Pennsylvania’s coal-fired power plants, and mercury control technology companies are promising that technologies capable of even greater mercury reductions are on the way. But as far back as 2000, EPA stated that, “Technologies available today and technologies expected to be available in the near future can eliminate most of the mercury from utilities at a cost far lower than one percent of utility industry revenues.” Then, in 2001, EPA staff stated in a presentation before the Edison Electric Institute that current technologies could achieve 90 percent mercury reductions from coal-fired power plants by 2007, reducing power plants’ annual mercury pollution from approximately 48 tons in 2000 to approximately 5 tons per year. This testimony will walk through the mercury reduction capabilities achievable through both the use of pollution controls for other pollutants (often referred to as “co-benefits”), as well as technologies that are designed specifically for reducing mercury pollution.
With regard to co-benefits, a 2004 report by the National Wildlife Federation examined the pollution control technologies being used by coal-fired power plants to meet federal pollution reduction requirements for pollutants such as particulates, sulfur dioxide and nitrogen oxides, and then examined the mercury reductions that could be met using these same technologies. By examining EPA data, the report found that several technologies designed for controlling pollutants other than mercury, were capable of achieving a co-benefit of 90 percent mercury reductions at plants burning bituminous coal—the type of coal burned at the vast majority of Pennsylvania’s coal-fired power plants. Specifically, the report found that fabric filters, and fabric filters with wet scrubbers were capable of achieving 90 percent and greater mercury reductions from plants burning bituminous coals.
In a presentation before DEP’s Mercury Rule Workgroup, David Foerter with the Institute of Clean Air Companies examined co-benefits achievable without using fabric filters. His research found that 80 percent mercury reductions were possible using wet scrubbers with an additive to help with mercury removal, and 90 percent and greater mercury reductions were possible using wet scrubbers with selective catalytic reduction technology. Mr. Foerter’s presentation also included presentations on a number of other emerging multi-pollutant control technologies, capable of 80 to 90 percent mercury reductions as well as significant reductions in other pollutants.
Regarding mercury-specific controls, DEP’s Mercury Rule Workgroup has heard several compelling presentations as to the availability of technologies that can achieve significant mercury pollution reductions at Pennsylvania’s coal-fired power plants. The most promising of the mercury-specific technologies is known as activated carbon injection, or “ACI.” This technology injects an absorbent carbon into the flue gas, absorbing and trapping the mercury before it escapes out of the smokestack. ACI technologies have achieved 90 percent reductions in full-scale tests at several power plants nationwide that burn bituminous coal. A Workgroup presentation by Mike Durham with the Institute of Clean Air Companies also referenced a year-long test at a power plant burning bituminous coal that achieved 90 percent mercury removal. Mr. Durham also pointed out that an advantage of ACI is that it is a flexible control technology—the amount of activated carbon and the type of activated carbon used can be easily adjusted at each plant using the same hardware, depending on the desired pollution reduction levels.
The Workgroup also heard a presentation from Sid Nelson of Sorbent Technologies Corporation, which manufactures and installs mercury pollution control technologies. Specifically, Sorbent Technologies specializes in adding substances such as bromine to the injected carbon to optimize the mercury removal of ACI systems. Mr. Nelson’s presentation said that 80 percent mercury reductions would be achievable at Pennsylvania coal-fired power plants by 2008, and 90 percent reductions would be achievable and inexpensive by 2012. This is consistent with a Workgroup presentation by Thomas Feeley with the National Energy Technology Laboratory, who cited field tests at plants using bituminous coal showing 80 percent reductions using ACI technologies.
Regarding the cost of these technologies, Mr. Nelson found that using his technologies to remove mercury from Pennsylvania coal would cost roughly $5,000 per pound of mercury removed—a 90 percent cost reduction from the current technology baseline. Mr. Nelson said that the cost of achieving 80 percent mercury reductions in Pennsylvania would be roughly $70 million annually. The National Wildlife Federation’s analysis (looking specifically at the cost of ACI technologies) determined that achieving 90 percent mercury reductions from Pennsylvania’s coal-fired power plants would cost the state’s utilities $223 million annually. Pennsylvania utilities bring in roughly $11.3 billion in revenue annually.
Conclusion: Given the serious environmental and public health threat posed by mercury pollution in Pennsylvania, the availability of pollution control technologies to significantly reduce this mercury pollution, and the Bush administration’s weakening of mercury protections at the federal level, PennEnvironment is strongly urging Pennsylvania regulators to move forward with state-level regulations that will achieve 90 percent mercury reductions from Pennsylvania’s coal-fired power plants—for the sake of our environment and our public health.
