EPA mercury rules for electricity generating units are based on false science and economics
Guest post by Craig Rucker
The Environmental Protection Agency claims its “final proposed” Maximum Achievable Control Technology (MACT) rules will eliminate toxic pollution from electrical generating units, bring up to $140 billion in annual health benefits, and prevent thousands of premature deaths yearly – all for “only” $11 billion a year in compliance costs.
This may be true in the virtual reality of EPA computer models, linear extrapolations, cherry-picked health studies and statistics, government press releases and agency-generated public comments. However, in the real world inhabited by families, employers and other energy users, the new rules will bring few benefits, but will impose extensive costs that the agency chose to minimize or ignore in its analysis.
Emissions of mercury and other air toxics from power plants have been declining steadily for decades, as older generating units have been replaced with more efficient, less polluting systems or retrofitted with better pollution control technologies. While a few older plants still violate EPA’s draconian proposed rules – the new rules are not based on credible scientific and epidemiological studies.
As independent natural scientist Dr. Willie Soon and CFACT policy advisor Paul Driessen pointed out in their WallStreetJournal and Investor’sBusinessDaily articles, and in Dr. Soon’s 85-page critique of EPA’s draft rules, US power plants account for only 0.5% of the mercury in US air. Thus, even if EPA’s new rules eventually do eliminate 90% of mercury from power plant emission streams, that’s still only 90% of 0.5% – ie, almost zero benefit. The rest of the mercury in US air comes from natural and foreign sources, such as forest fires, Chinese power plants and the cremation of human remains (from tooth fillings that contain mercury and silver).
EPA fails to recognize that mercury is abundant in the earth’s crust. It is absorbed by trees through their roots – and released into the atmosphere when the trees are burned in forest fires, fireplaces and wood-burning stoves. In fact, US forest fires annually emit as much mercury as all US coal-burning electrical power plants. Mercury and other “pollutants” are also released by geysers, volcanoes and subsea vents, which tap directly into subsurface rock formations containing these substances.
The agency compounds these errors by claiming fish contain dangerous levels of mercury that threatens the health and mental acuity of babies and children. In making this claim, the agency commits four more grievous errors. First, it ignores the fact that selenium in fish tissue is strongly attracted to mercury molecules and thus protects people against buildups of methylmercury, mercury’s more toxic form.
Second, EPA based its toxicity claims on a study of Faroe Islanders, who eat few fruits and vegetables, but feast on pilot whale meat and blubber that is high in mercury and polychlorinated biphenyls (PCBs) – but very low in selenium. Third, it ignored a 17-year Seychelles Islands evaluation, which found “no measurable cognitive or behavioral effects” in children who eat five to twelve servings of fish per week.
Fourth, it used computer models to generate linear extrapolations from known or assumed toxic levels down to much lower levels. Not only is this method contrary to sound science and epidemiology; it resulted in politicized “safety” levels that are twice as restrictive as Canadian and World Health Organization mercury standards, three times more restrictive than US Agency for Toxic Substances and Disease Registry, and four times tougher than US Food and Drug Administration recommendations. No wonder the Centers for Disease Control says blood mercury levels in US women and children are already well below excessively “safe” levels set by EPA.
Simply put, EPA grossly exaggerated the health benefits of its proposed mercury rules – and then claimed additional mercury benefits based on double counting of reductions in particulate matter. It also ignored the adverse effects that its rules will inflict. Not only is EPA’s anti-mercury campaign scaring mothers and children into not eating nutritious fish that is rich in Omega-3 fatty acids. It is also raising electricity heating, air conditioning and food costs, impairing electrical reliability, costing jobs, and thereby harming the health and welfare of countless Americans.
Energy analyst Roger Bezdek has calculated that utilities will have to spend $130 billion to retrofit older plants – and another $30 billion a year to operate, maintain and power the energy-intensive pollution control equipment they will be forced to install. Moreover, under its MACT rules, EPA intends to micromanage every aspect of power plant operations. It will now cite companies for violations even if emissions fully comply with air quality standards, if operators merely deviate from new agency “work practice standards” and “operational guidelines,” even under unusual weather conditions or equipment malfunctions that are beyond the operators’ control.
While it is true that older power plants are more significant sources of toxic air emissions, those plants are mostly in key manufacturing states that burn coal to generate 48-98% of their electricity. Many utility companies cannot justify those huge costs – and thus plan to close dozens of units, representing tens of thousands of megawatts – enough to electrify tens of millions of homes and small businesses. Illinois alone will lose nearly 3,500 MW of reliable, affordable, baseload electricity – with little to replace it.
Electricity consumers could pay at least 20% more in many states within a few years. According to the Chicago Tribune, Illinois families and businesses will pay 40-60% more. That will severely affect business investment, production and hiring – and family plans to repair cars and homes, save for college and retirement, take vacations, or have health physicals or surgery.
Chicago public schools will have to pay an additional $2.7 million annually for electricity by 2014, says the Tribune. Hospitals, factories and other major electricity users will also be hard hit. Many poor and minority families will find it increasingly hard to afford proper heating and air conditioning. Further job losses and economic stress will lead to further reductions in living standards and nutrition, more foreclosures and homelessness, and additional drug, alcohol, spousal and child abuse.
The very reliability of America’s electricity grid could be at risk, if multiple power plants shut down. Brownouts, blackouts and power interruptions will affect factory production lines, hospital, school, farm and office operations, employment, and the quality of food, products and services.
The impact on people’s health and welfare is patently obvious. But EPA considered none of this.
EPA insists there was strong public support for its rules. However, its rules were clearly based on false, biased or even fraudulent information. Furthermore, EPA itself generated much of that public support.
The agency recruited, guided and financed activist groups that promoted its rulemaking. Over the past decade, it gave nearly $4 billion to the American Lung Association and other advocacy organizations and various “environmental justice” groups, according to a Heritage Foundation study. EPA Administrator Lisa Jackson and members of her staff also visited historically black and other colleges – giving speeches about “toxic emissions,” providing templates for scare-mongering posters and postcards, and making it easy for students to send pro-rulemaking comments via click-and-submit buttons on websites.
This EPA action does nothing to improve environmental quality or human health. In fact, by advancing President Obama’s goal of shutting down power plants and raising electricity costs, it impairs job creation, economic recovery, and public health and welfare. It is intrusive government at its worst.
It is a massive power grab that threatens to give EPA nearly unfettered power over the electrical power we need to support our livelihoods and living standards.
Congress, states, utility companies, affected industries, school districts and hospitals, and families and citizen groups should immediately take action to postpone the MACT rules’ implementation. Otherwise, their harmful impacts will be felt long and hard in states that depend on coal for their electricity.
___________
Craig Rucker is CEO of the Committee For A Constructive Tomorrow.
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A physicist says:
“Modern CFL lamps do substantially reduce mercury emissions, and that’s a fact.”
So by adding mercury… mercury is reduced. ???
Dear: The Piractical Captain Dallas says: December 26, 2011 at 3:13 pm
Where you state:
“Hang on a second. 12.5% of all US power plants already meet the regulation limits. about 63 or 10.5% of the older power plants don’t stand a chance. Most of those are already planned to be replaced. With the allowable time and the permissible extension, these plants will shut down on schedule. Most of the remaining power plants have access to available technology to upgrade to meet the new limits. Some just need co-generation which could be low temperature hot water for a variety of processes, like pulp which is overly impacted by the regulation”
I’m afraid I don’t agree. Point by point.
1) Where you state: ” 12.5% of all US power plants already meet the regulation limits. ” I don’t agree. the 12.5% figure comes from an assumption that the standards are created based on the performance of the best 12.5% of existing power plants. The facts are the EPA used 12.5% of plants for individual pollutants… not all pollutants at the same time. Even the EPA could find only a single U.S. plant in the U.S. that was able to meet all of its emission requirements … and it’s not at all clear that this plant is representative given that it utilized a dry FGD using medium sulfur coal. Because coal varies the performance of a single plant is, frankly, meaningless.
2) Where you state: “About 63 or 10.5% of the older power plants don’t stand a chance. Most of those are already planned to be replaced.” Dead wrong again. I am part of a team that made the decision to close 2,700 MW of capacity. Not a single unit would have be closed if the EPA’s “toxic rules” had not been issued. Moreover it appears likely we will be announcing more closures. (We just didn’t have all the facts until the new rules were issued).
3) Where you state: “Most of the remaining power plants have access to available technology to upgrade to meet the new limits.” Partially wrong . See item one above. It not at all clear we actually be able to meet all of the emission requirements, although changing the proposed 2.5 PM standard helps. With regard to applying the new plant standards, we can’t find a single construction company willing to guarantee they can meet all of the EPA’s newly proposed emission requirements. In other words… the technology does not exist. (And just wait until you see the proposed NSPS for green house gases).
4) Where you State: “Some just need co-generation which could be low temperature hot water for a variety of processes, like pulp which is overly impacted by the regulation”. I am truly sorry to have to say this, but, I’m afraid you don’t understand the scale of power operations. Co-generation is not going to address the problem. Moreover, I don’t think you understand the EPA regulatory process. Generally, if you produce electricity for sale your plant becomes subject to the EPA rules for electric generating units (EGUs). Generally, the standards for EGUs are tighter than the rules for other industries. Short version, no relief there. (Just the opposite, I’m in the process of closing co-generating units supplying steam to a major industry.)
Mr. Rucker has it dead right. Nothing the EPA says is close to the truth or truly involves acting for the public good.
Regards, Kforestcat
A physicist says:
December 26, 2011 at 2:12 pm
“Short summary: There is ample scientific evidence that power that is cheap at the plug can be exceedingly dear at the doctor’s office.
The appropriate trade-offs are not easily decided.”
Short and clear response: There is irrefutable evidence that unaffordable power ‘at the plug’ will cause one to freeze to death in the cold and dark, during a Wisconsin winter. The appropriate trade offs are so easily decided that even a child understands this… but apparently they are beyond calculation by ‘A physicist’.
Rather than condemning the old, frail, or innocent babies to this easily preventable form of myopic murder, ‘A physicist’, why don’t you conduct the experiment yourself? Enjoy a few months of powerless exposure to a Wisconsin winter! It will be good for the Planet and good for you! No man made power sources. No fire. No synthetic clothes or shelter. No hot food and no hot water. No CO2 emissions….. Think of it as ‘a teaching moment’. I guarantee it will be instructive. The physics of freezing to death are quite interesting, once you get past the difficult hygiene, excruciating pain of frost bite, pleurisy, and malingering pneumonia.
Ah well, as we all tell our children, be very sceptical of that which you read on blogs. It amazes me how all the climate sceptics (of whom I am one: I am sceptical about everything) that bear their scepticism with such pride swallow everything they read here on WUWT like it’s mother’s milk. It only needs to be published here for every reader to believe every word. Now, let me be clear, I am not saying a single word of it is untrue. No I’m not. I am simply asking you all why you all believe it to be 100%, 1000% true, just because it is published here? And why do you so many of you get so angry about blog posts, when you should know that, whisper this, *they are not necessarily 100% true*.
Now, to hopefully calm things a little, we’ll switch on the cold water credulity hose to see how that sobers things up. Let’s see: The article says that “The agency recruited, guided and financed activist groups that promoted its rulemaking”. Oh, but whoopie-do, the same article forgets to point out that according to Exxon’s own accounts 1998 – 2007, the Committee For A Constructive Tomorrow (CFACT), of which Craig Rucker, author of this piece, is the co-founder, received $582,000 in direct funding from ExxonMobil Corporate Giving and the ExxonMobil Foundation.
Willie Soon, “independent natural scientist”, may not perhaps be as independent as all that, as he has been bankrolled to the tune of over $1,000,000 by big energy and big oil, including Tea Party Charles Hoch last year – although it should be said that the like of Exxon and Southern have been crossing the street to avoid him when they’ve seen Willie coming in recent years.
Naturally, dear old Craig and fine fellow Willie would like us to suspend our scepticism, turn a blind eye, when it comes to them rolling over and playing tickle-tummy for Big Oil, as long as we are the cheerleaders for their attacks on those that threaten the very same Big Oil etc.
Lastly, I personally used to work in a town with a mercury mine. Idrija, in Slovenia. It has its own special hospital for the ex-miners. The debilitations they suffer from, physical and mental, are those you would not wish on your worst enemy. I think Rucker, Soon et al, those seem to think that mercury is not a health hazard, should be forced to work there for an extended period. They would go to sleep at night weeping into their pillows.
Before I retired from paid employment I was the senior chemist at a large industrial site and was the site’s contact with the UK version of the US EPA. When the site was being built we had to discuss with our Regulator about levels of various chemicals that might be allowed to be discharged into the sea (tidal). The Agency was keen on writing into our consent that we were to “minimise” our discharges. I was vigorously opposed to this because there is only one minimum value – zero. And this could not be technically justified and if applied literally could have closed the site down before we even started!
After much discussion it was agreed that we should “limit” our discharges which, I think, was what they wanted. That is, they did not want us to operate up to our statutory limit just because we could. Instead, we would keep well within the values, the exceeding of which would lead to prosecution, without needing to do costly and stupid things with no environmental benefit.
Overall, our relationship was workman-like (not cosy/cosey) to the benefit of all. It helped that I brought in a policy (fully supported by the site manager) that we would be totally and brutally honest with our Regulator. If anything went wrong (even if there was no way he would be able to tell) the bad news came from me to him the same day. This applied to near misses as well:
What had happened.
The implications (if any)
What we had already done to control the problem
What we had put in place to prevent it recurring or to prevent a near miss from becoming a full blown incident.
All this was before the extremes of environmentalism but I believe the environment and the public were effectively protected from harm.
“Smokey says:
December 26, 2011 at 12:52 pm
Askgerbil Now,
Try to pay attention. You postewd a link to Austrailian emissions, which has no relevance to the EPA.”
IMO there is a big danger that not much from CSIRO these days has any relevance to anything much
John Billings, you are missing the point about funding (I have no idea if your figures are correct, but it doesn’t matter anyway).
In a free country, people are allowed to spend their own money as they please, including funding research or advocating for causes.
Using taxpayers’ money to advocate for causes that the funding agency supports is a very different thing. And we are not talking about nickels and dimes here. At a time when the US has a massive public debt problem, the EPA has given away almost $4bn of public money to its pals – pals who will advocate for the continuing expansion of the EPA.
While bad practices in mercury mines in Slovenia are to be deplored, I fail to see what they have to do with this discussion, which is about minute quantities of mercury emissions from coal fired power stations.
John Billings says:
“I think Rucker, Soon et al, those seem to think that mercury is not a health hazard, should be forced to work there for an extended period.”
No-one has said that mercury has zero health risk – what has been stated is EPA’s health claims at these extremely low Hg levels strain credulity. Further the costs associated with compliance, it is argued, create perverse consequences of far greater risk.
Using workers at the world’s largest mercury mine- Idrija- as a risk comparison to EPAs new Hg standards is a bit dishonest- don’t you think?
This is just more of the EPA’s war on carbon, and particularly against coal, which is carbon-rich. Remember John L. Lewis and his coal miners’ strike many years ago? Where is he when we need him most?
If enough of those old coal-fueled power generators recieve EPA’s coup de grace, how about some rotating blackouts, starting with all of Washington D.C.?
Posting:
GeoLurking says:
December 26, 2011 at 3:42 pm
Zeke says: December 26, 2011 at 2:00 pm
“OSHA Permissible Exposure Level for Mercury is about 0.5 mg/m³. A CFL contains somewhere between 2 to 4 grams of Mercury. Break one and you have enough to contaminate (per OSHA guidelines) 4000 to 8000 cubic meters of your house.”
Sorry, Zeke or GeoLurking, but the statement “A CFL contains somewhere between 2 to 4 grams of Mercury” is out by a factor of 1000. According to Wikipedia (which tallies with what I have read elsewhere): “Most CFLs contain 3–5 mg per bulb, with the bulbs labeled “eco-friendly” containing as little as 1 mg.”
Milligrams, not grams…..
IanM
[Apologioes if this has already been commenting on. It takes time to read through every comment, so I have jumped ahead several hours.]
johanna says:
December 27, 2011 at 2:00 pm
John Billings, you are missing the point about funding (I have no idea if your figures are correct, but it doesn’t matter anyway).
Yes, my figures are correct, and it is entirely inappropriate for Rucker to raise the issue of EPA funding without revealing his own dirty laundry. If he wishes to bring funding into the discussion, he can expect others to do so to his detriment. He brought it up.
I mentioned the mercury mine in Slovenia because the whole thrust of the article is that mercury is relatively harmless. It’s a poison piece about a poison.
Pat Moffitt says:
December 27, 2011 at 2:02 pm
Using workers at the world’s largest mercury mine- Idrija- as a risk comparison to EPAs new Hg standards is a bit dishonest- don’t you think?
No. it’s not at all dishonest. What’s dishonest is to say that “independent natural scientist Dr. Willie Soon and CFACT policy advisor Paul Driessen pointed out in their WallStreetJournal and Investor’sBusinessDaily articles, and in Dr. Soon’s 85-page critique of EPA’s draft rules, US power plants account for only 0.5% of the mercury in US air” – without reference to their claim, how it was formulated so that anyone else can check it, and certainly without reference to what the EPA says about the matter. What’s dishonest is to say “The rest of the mercury in US air comes from natural and foreign sources, such as forest fires, Chinese power plants and the cremation of human remains (from tooth fillings that contain mercury and silver)” without any reference to where the data comes from so that it can be checked.
What’s dishonest is to put an emotive piece in front of a bloodthirsty, gullible audience.
What’s downright unpleasant is to have to answer your pointed, personal jibes. Please look at the article again and ask yourself if it holds water before accusing me of dishonesty. Sometimes the atmosphere here stinks, it really does.
Johanna is entirely correct, Mr. Billings. It’s one thing for private companies to use their money to fund advocates, it’s quite another when the government takes my money by force, and then uses it to buy the ALA [and other NGOs] to advocate for the EPA. Now excuse me while I wipe the blood from my gullible jowls. So glad you don’t stoop to pointed, personal jibes.
EPAs new Hg standards is a bit dishonest- don’t you think?
the1bob paglee says:
December 27, 2011 at 2:11 pm
This is just more of the EPA’s war on carbon, and particularly against coal, which is carbon-rich. Remember John L. Lewis and his coal miners’ strike many years ago? Where is he when we need him most?
If enough of those old coal-fueled power generators recieve EPA’s coup de grace, how about some rotating blackouts, starting with all of Washington D.C.?
===================
I wonder if there’s a coal-powered electricity supplier for EPA headquarters..? If I owned it… I consider raising the cost to those anti-coal powered electricity, to, oh astronomically high tariffs.
Walter Cronanty says:
December 27, 2011 at 3:11 pm
“when the government takes my money by force”,… so, there you are with your gun in your bunker in Montana, refusing to pay for any societal good such as the police, army, street lighting, highways, elementary education so that the poorest of the poor can at least speak English before your market forces are unleashed upon them in a tidal wave…
To wipe the blood from your gullible jowls may take some time, since you choose to mention it.
Maybe the EPA should look into Hg mining practises in Slovenia (they’d have to work out the jurisdictional issues) rather than fund its pals environmental/AGW campaigns. I bet that $4billion funded a whole lot of California & Maryland 6 figure environmentalist salaries.
Enneagram says:
“Democracy has gone too far, driven by the maddening idea of “not discriminating minorities” as to allow those totally unfitted to reach positions of decision and power. Thus the most complete menagerie of fools, idiots and sick people are dictating the laws and measures for the rest of the society. This is absolutely insane.”…….
Umberto Eco’s latest novel echos (small pun) your sentiments. One of the narrators (a gormand, by the way) recalls the imperialists’ (Napolean III) belief that the best way to defeat democracy/republicanism is to grant universal suffrage. That is just one of many topical observations disguised in in a twisted account of European politics before WWI.
Justa Joe,
I’m in Colorado right now. But you mention “California & Maryland 6 figure environmentalist salaries”. Does that mean I am safe? I don’t want to pay “6 figure environmentalist salaries”, because the only 6-figure salary I know is if you include the numbers after the decimal. I’m scared, Justa Joe. Should I go find Walter Cronanty in his bunker? What if he’s only got beans to eat up there?
My apologies for engaging what is obviously an ignorant, bomb-throwing troll.
Ian L. McQueen says:
December 27, 2011 at 2:31 pm
“…Sorry, Zeke or GeoLurking, but the statement “A CFL contains somewhere between 2 to 4 grams of Mercury” is out by a factor of 1000…”
Not a prob. The EPA took care of the “factor of 1000” thing by placing the prolonged exposure limits at 300 ng/m³ rather than the OSHA PEL limit of 0.5 mg/m³ (500,000 ng/m³)
John Billings says:
“What’s dishonest is to say that “independent natural scientist Dr. Willie Soon and CFACT policy advisor Paul Driessen pointed out in their WallStreetJournal and Investor’sBusinessDaily articles, and in Dr. Soon’s 85-page critique of EPA’s draft rules, US power plants account for only 0.5% of the mercury in US air” – without reference to their claim, how it was formulated so that anyone else can check it, and certainly without reference to what the EPA says about the matter.”
I found 171 references and notes in Soon’s report- so I have no idea what you are talking about
http://scienceandpublicpolicy.org/images/stories/papers/reprint/scientific_reply.pdf
And the dose makes the poison.
Walter Cronanty,
Pay no attention to the troll.
To Smokey and Walter Cronanty:
You call me a “troll” for asking genuine questions. What are you doing here? What purpose do you hope your posts serve?
Pat Moffitt says:
December 27, 2011 at 4:05 pm
“I found 171 references and notes in Soon’s report- so I have no idea what you are talking about”
Pat, none of the 171 references were visible in the article. The article was/is a leap of faith. Believe “it” if you believe WUWT. You dug out Soon’s paper because you wanted to believe. I’m saying that we should all apply the same standards of scepticism to everything. I said in my original post that I did not doubt anything it said – except that I doubted everything, as that is the true nature of scepticism. It is not to doubt this or that – it is to doubt everything. So when you present a case, an argument, a something, we, the audience, the appraisers, should not, cannot say “It’s good” or “it’s bad” without something to back it up. That’s all. So I neither agree nor disagree with you. Your comment “so I have no idea what you are talking about” – you will have to look at that, as I cannot. I am not presenting any point for or against anything – except that we should all be very harsh, and not sympathetic, to anyone who puts anything up for our inspection. I do hope you understand.
John Billings says:
December 27, 2011 at 2:33 pm
So, are you complaining about non-AGW-agenda research receiving from private sources about 0.04% as much funding as what is given by EPA of public funds, to promote AGW?
John Billings says:
December 27, 2011 at 3:53 pm
I’m in Colorado right now. But you mention “California & Maryland 6 figure environmentalist salaries”. Does that mean I am safe?
_______________________
I honestly don’t get what you’re trying to say. You may not make a 6 figure salary… so what? Are you suggesting that the higher-ups in environmental/AGW campaigning oufits don’t make 6 figure salaries, while Federal tax dollars for “blah, blah, blah awareness” flow into their organizations?These groups’ lawyers also generate a lot of big legal fees paid by the tax payers for “sueing” the EPA.
To read Dr. Soon’s comment submission:
go to regulations.gov
in key word search enter: “EPA-HQ-OAR-2009-0234”
then search within results for “soon”
Dr. Soon’s 85 page comment is the first document you’ll get. It contains 171 references.
I haven’t read his submission yet, but for all those wanting citations, you’ll probably find them there.
(Sorry, I don’t know how to provide a direct link to the docket document.)