Excerpt of
comment submitted by RCCA:
For decades
Rockland County has been a host community to the Lovett Generating
Station, a coalfired facility. Over the years this plant has appeared
on the nation’s and state’s dirtiest polluter list. This distinction
engenders great concern for the health and well-being of our families.
Mercury is a known, potent neurotoxin that bioaccumulates. Rockland
is unique, in that we obtain our drinking water from within our
borders. Therefore, we are acutely vulnerable to the effects of
local impacts, as well as atmospheric exposures of mercury.
Studies show
that local power plants are a significant portion of the mercury
contamination problem. The most recent information comes from
an EPA-funded study in Steubenville Ohio, which found that about
70 percent of the mercury pollution from local coal plants fell
within 60 miles.i This puts a finer point on EPA's
1997 estimate that these types of mercury emissions travel 50-500
miles.ii The data make it clear that local controls
will mean less mercury pollution falling into local waters.
According to the
United States Geological Survey (USGS), “Mercury has been well known
as an environmental pollutant for several decades. As early as the
1950's it was established that emissions of mercury to the environment
could have serious effects on human health. These early studies demonstrated
that fish and other wildlife from various ecosystems commonly attain
mercury levels of toxicological concern when directly affected by
mercury-containing emissions from human related activities. Human
health concerns arise when fish and wildlife from these ecosystems
are consumed by humans.”iii
RCCA encourages
a more robust enforcement program that imposes greater fines for
noncompliance. In an effort to ensure compliance we support continuous
monitoring of emissions, especially for mercury. There are well
recognized questions of “hot spots” where local output sources
exist.
“EPA brought
significant scientific, technical, and modeling expertise to bear
in developing a specific methodology to consider the potential
for mercury hotspots. Several uncertainties associated with key
variables in the analysis could affect theaccuracy of the Agency’s
conclusion that the Clean Air Mercury Rule (CAMR) will not result
in “utility-attributable” hotspots. We noted:
-
gaps in available data and science for mercury emissions estimates,
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limitations with the model used for predicting mercury deposition,
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uncertainty over how mercury reacts in the atmosphere, and
-
uncertainty over how mercury changes to a more toxic form
in waterbodies.”iv
Given the
void of available data it is reasonable to follow precautionary
measures to safeguard the public and environment from a known
dangerous neurotoxin. Homes in the vicinity of the Lovett Generating
Station are known to have fine dust particles on the outside,
believed to be from the emission stacks. Analysis of this dust
compared to what is emitted from the plant may be a good source
review to begin filling those gaps of data.
As far back
as 1306, King Edward I attempted to regulate the burning of coal
in London. “In 1775, Percivall Pott, a London physician, suggested
that the very high rate of scrotal and nasal cancers among chimney
sweeps was a result of their exposure to soot. This was the first
indication that exposure to certain chemicals in the environment
could be an important factor in cancer.”vvi There are no secrets
that avoidance of exposure to toxins supports well-being.
i
Gerald J. Keeler, Matthew S. Landis, Gary A. Norris, Emily M.
Christianson, and J. Timothy Dvonch. Sources of Mercury Wet Deposition
in Eastern Ohio, USA, Environmental Science & Technology 40 (19).
September 8, 2006.
ii U.S. Environmental Protection Agency. Volume III:
Fate and Transport of Mercury in the Environment. 1997
iiiMercury Contamination of Aquatic Ecosystems http://water.usgs.gov/wid/FS_216-95/FS_216-95.html
ivUSEPA Office of Inspector General; At a Glance May
15, 2006 Monitoring Needed to Assess Impact of EPA’s Clean Air
Mercury Rule on Potential Hotspots http://www.epa.gov/oig/reports/2006/20060515-2006-P-00025-glance.pdf
5National Institutes of Health Cancer Institute Cell Biology and
Cancer, Teacher’s Guide http://science.education.nih.gov/supplements/nih1/cancer/guide/intro1.htm