### E(ectronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * 

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AMERENENERGY RESOURCES, Petitioner,

v. 

### ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY, Respondent 

### ) ) 

### ) ) ) 

### ) ) ) 

### ) ) PCB 12-126 (Variance- Air)

NOTICE OF FILING
To: Attached Service List
PLEASE TAKE NOTICE that I have today electronically filed with the Clerk ofthe illinois Pollution Control Board Comments ofEnvironment lllinois, the Environmental Law & 

### Policy Center,Natural Resources Defense Council, Respiratory Health Association, and Sierra Club, a copy ofwhich is attached hereto andherewith served upon you. Respectfully submitted,

Faith Bugel Andrew Armstrong Jenny Cassel Environmental Law and Policy Center 3 5 East Wacker Drive, Suite 1600 Chicago, illinois 60601



### ATTACHMENT_,_o

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

AMERENENERGY RESOURCES, Petitioner,

v. 

### ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY, Respondent. 

### ) ) ) ) ) ) ) ) ) 

### ) PCB 12-126 (Variance- Air)



### COMMENTS OF ENVIRONMENT ILLINOIS. THE ENVIRONMENTAL LAW & 

### POLICY CENTER. NATURAL RESOURCES DEFENSE COUNCIL, RESPIRATORY HEALTH ASSOCIATION, AND SIERRA CLUB Pursuant to 3 5 

### lll. Adm. Code 104.224(d), Environmentlllinois, the Environmental Law & Policy Center, Natural Resources Defense Council, Respiratory Health Association, and Sierra Club (collectively, "Citizens Groups") submit the following comments on the Petition for Variance ("Petition") filed by Ameren EnergyResources ("AER") with the lllinois Pollution Control Board ("Board") on May 3, 2012. Since filing its Petition, AERhas hadthe opportunity
to submit written responses to two sets ofquestions from the Board andpresenttestimony at the Board's August 1, 2012 public hearing. Nevertheless, AER continues to fall far short ofmeeting its heavy burden injustifying a variance from lllinois' Multi-Pollutant Standard ("MPS"). Among the defects in AER's proposal:

• AERhas refused to committo a definite compliance plan with the MPS' sulfur dioxide ("S02") 

### emission limits, butinstead states only that it will complete its
Newton flue gas desulfurization ("FGD") project as it deems economic conditions to permit.



### • In arguing that the variance is necessary to avoid an arbitrary or unreasonable

## ~~ hardship, AER still has failed to explore all ofthe options available to it for reducing 1

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its fleet's SOz emissions other than the Newton l'GD project-including emissions controls it indicates that it will use in the near future to comply with a reinstated Cross-State Air Pollution Rule ("CSAPR").

• Any hardship faced by AER from compliance with the MPS is self-imposed, because AER and its parent company made business decisions to propose, agree to, and opt into the MPS and to operate their generating plants througb a deregulated entity instead ofkeeping them within their regulated distributing company, and benefited handsomely from their decisions for many years.

• AERhas notpresented an honest appraisal ofthe environmental impact ofits proposed variance, but instead has understated the emissions it would allow and failed to acknowledge the harmful effects those increased emissions would have. In 

### short, AERhas failed to present a sufficient basis for the Board to upset the standard described by the then-Director ofthe lllinois Environmental Protection Agency ("IEPA") as "one ofthe
most important environmental and public health advances in lllinois in recent decades.' The Board should deny AER's Petition. In

### the alternative, the Board should only grant AER's Petition with strict conditions and on a markedly shorter time frame. 

### I. AER's Proposed Variance is Illegal Because It

### Lacks a Definite Compliance Plan. AER's proposal continues to lack a legally sufficient, definite compliance plan. A central principle oflllinois' variance process is that the purpose ofa variance is for temporary, not permanent, relieffrom aBoard regulation. 

### Monsanto Co. v. !PCB, 67 

### Til. 2d 276,286 (1977)

1 Oeersight: EITVironmental ProtectionAgency's Clean AirRegulations- One Year after the CAIR and CAMR Federal Court Decisions: HearingBefore the S Subcomm. On CleanAir andNuclear Safety of the S Comm. On Environment andPublic Works, !lithCong. 2 (2009) (written statement ofDouglas P. Scott, Director, Illinois Environmental Protection Agency), available at http:/ /epw.senate.gov/public/index.cfin?FuseAction=Files.View&FileStore_id=fc4c5288-525a-47d6-8!2c809d000c617b ('Scott Test.") (attached hereto as Ex. !).


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("[T]he concept ofa variance which permanently liberates a polluter from the dictates ofa board regulation is wholly inconsistent with the purposes ofthe Environmental Protection Act."); City of Mendota v. !PCB, 

### 161 lll. App. 3d 203, 212-13 (3d Dist. 1987). Thus, to ensure that a proposed variance is not, in effect, permanent relief, a petitioner for a variance must include a "detailed description ofthe compliance plan." 35lll. Adm. Code 104.204(±). To ensure that a proposed variance provides only time for compliance to be achieved, and notpermanent relief, the Board should deny a petition that lacks a "definite compliance plan." Ecko G/aco Cmp. 

### v. !EPA, 

### 186lll. App. 3d 141, 150-51 (1st Dist. 1989); Container Cmp. of America 

### v. !EPA, 

### PCB 87-183 (July 27, 1989). Here, AER's proposed compliance plan is not definite, continues to lack
necessary details, and does not ensure that the variance would provide only temporary relief from Board requirements. For those reasons, the Board should deny AER's Petition. AER's compliance plan is not definite because it is relies on a recovery in electric generation prices, a recovery that AER itselfacknowledges is uncertain. Ifa compliance plan is reliant on market conditions improving and affected facilities returning to profitability, then the compliance plan is not definite, and the variance containing it should be denied. Container Corp., 

### PCB 87-183 (July 27, 1989), at 6. In

### its Petition, AER argued that completion ofits Newton FGD project would be prohibitively uneconomical2 

### unless and until power prices rise sufficiently. 3 

### AER contends that its merchant generation business, unlike a regulated utility,
must rely on higher prices and the investor confidence they bring in order to finance significant capital improvements like the Newton scrubbers 4 

### At the public hearing, AER witnesses

2 See, e.g., Petition at 7 C'AER seeks the variance

.. because eroding fmancial conditions make compliance with those requirements untenable."). 3 See, e.g, Petition at 9 ("Assuming powerprices rebound

... "); Petition at 21-22 ("unless and until power price market conditions improve

..."). 4·See Petition, Ex. 5, Rygh Aff. at 1]11 ("Unlike theirregulated utility peers, unregulated power companies do not enjoy the benefits ofrecovery assurance for prudently incurred costs and investments. Instead, [they] can only turn to the markets to generate margins."). 

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continued to focus on higher powerprices as the key means ofone day complying with the MPS S02 requirements. 5 

### According to AER, it will eventually comply with the MPS by constructing and operating scrubbers at its Newton facility. But it will only finish that FGD project ifpower prices rise and AER can access third-party financing.
In fact, AERitselfacknowledges there is little certainty as to ifor when power prices might rise sufficiently for completion ofthe Newton FGD project. Under questioning from the Board and its technical staff, Ameren Services Company's Vice President ofEnvironmental Services, Michael 

### L. Menne, could provide no time frame or assurances as to when power prices might recover: 

### Q. In Ameren's response to the July 6, 2012 hearing, question No. 4 regarding conditions for the variance, Ameren indicated, "In the event completion of the FGD system becomes infeasible, AER agrees to advise the Board and the Agency ofalternative plans for compliance during the remaining term ofthe variance." Is there a last possible date at which point AER will know if it will not be able to complete the FGD before the proposed January 15, 2020 compliance date? 

### A Well, if

### I understand what your question is, as far as knowing when we cannot complete the scrubber

-- are you talking about ultimately and then for the '20 timeframe? 

### Q. Yes. 

### A No. I can't give you a date because things arejust changing so much every year that we don't know what position we will be in going forward. 

### I mean, our assumption is that markets will recover. We'll be in shape to construct that unit at that time, butbeyond that, we reallyjust don't !mow at thispoint in time. 6

5 See RyghTest. Tr. 49: I0-14 ('This means AERneeds time to realize the effects ofreturning to a more sustainable market economy before it will once again have access to the capital necessary to complete the Newton FGD project."). All citations to the transcript ofthe Board's August I, 2012 hearing are referenced as "[Witness] Test. Tr. at [page]:[line]". 6 Menne Test. Tr. at 37:9-38:8 (emphasis added). 

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AER's expert financial witness, Gary 

### M. Rygh, could provide no time frame or

assurances as to improvement in AER's financial health and, to the contrary, expressed certainty that AER's financial difficulties are unlikely to go away in the years ahead: AER and its subsidiaries have been some ofthe worst performing companies in their sector due to high reliance on coal fired generation and lack of fuel and market diversification. Moody's also said recently "The ongoing shift in natural gasprices reflects a permanent change across the US energy sector, and will make it more difficult for coal to compete with natural gas as apower source in thefirture. A rise in gas-firedpower generation will not be strong enough to raise naturalgasprices on a sustained basis." -April 2012 7


### Both neutral market analysts and even AER's in-state competitors also have acknowledged an uncertain and weak future for power generation prices. As recently as March 2012, the Standard & 

### Poor's ratings agency predicted that future powerprices are at best uncertain and quite possibly will remain low, noting the "prolonged weakness ofthe power markets" and the "flattening ofthe forward [price] curve." 8 

### The Moody's rating agency conditions an improvement in AER's cash flow on a "recovery in power prices, which may not occur." 9 In 

### a news story on this variance, AER's chiefmerchant generation competitor in downstate Illinois, Dynegy Midwest Generation, even acknowledged that powerprices may not

recover from their current lows. 10 

### Given all ofthis uncertainty over improving power prices and AER's financial health, and the dependence ofthe compliance plan on these factors, the Board
must deny AER's Petition for lack ofa definite compliance plan that assures compliance, unless AER can demonstrate that it has a planthrough which it will definitely achieve compliance.

7 Petition, Ex. 5, Rygh Aff. at 1]7. Elsewhere inhis Affidavit, Mr. Rygh also stated, "The business conditions for the US unregulated power sector are poor with little expectation for near-term improvement." Id.**at~** 13. 8 !d. at 1]15 (citing Standard & Poor's). 9 !d. 10 See Kari Lydersen, Ameren wants more time to clean upIllinois emissions, MIDWEST ENERGY NEWS (Aug. 6, 2012), http://www.midwestenergynews.com/2012/08/06/ameren-wants-more-time-to'-clean-up-illinois-ernissions/ CC[A Dynegy spokesman] noted that Ameren's variance request 'assumes some future power market recovery to justify the necessary investment' to comply with the state limits in the future, but there is no guarantee that recoVery will ever happen."). 

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AER's reliance on a hoped-for upswing in power prices that may never well occur renders its compliance plan wholly lacking the "detailed" and "definite" description ofthe complianceplan required by the Board's rules. 35lil. Adm. Code 104.204(±). The compliance plan must contain a "time schedule for the implementation ofall phases ofthe control program from initiation ofdesign to program completion." 35lll. Adm. Code 104.204(±)(2). Although Ameren at the hearing referenced time frames for ongoing construction activities during the variance period, it failed to provide a time schedule for the most important phases ofits FGD construction program. n Mr. 

### Menne and the compliance plan promise no more than annual updates on activities, updates that at some uncertain date will become "better defined as we go on." 12 

### Such a vague time schedule does not meetthe legal standard ofa "detailed compliance plan" and, thus, the Board must deny the variance. Other factors cited by AER in support ofits variance request may likewise prove permanent features ofAER's economic picture, as well, such that any reliefgranted based on these factors would not be temporary as required by law. Monsanto Co., 67lll. 2d at 286. These factors include the age ofAER's uncontrolled lllinois power plants and the Ameren Corporation parent company's refusal to support AER. Should these factors not change in the near termand Ameren can offer no basis to conclude that they will-there is a very real possibility that the Board and illinois residents could be subjected to a revolving door ofvariance requests. In 

### fact,

' 

### just three years ago, AER received a delay to the date it must meet the most stringent S02 

### limits under the MPS. 13 In 

### an argument strongly parallel to the Petition nowbefore the Board, AER's

11 Menne Test. Tr. at 32:12-33:6. 12 Tr. at 33:2-6. 13 SeeAmeren Energy Generating Co. etal. v. !EPA, PCB 09-21 (Oct. I, 2008) ('2008 Petition for Variance"). Reliefwas eventually granted through a rulemaking. See In the Matter ofProposedAmendments to 35 Ill. Adm. Code 225: Control of Emissions From Large Combustion Sources (MercuryMonitoring), R09-l0 (June 18, 2009). 

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2008 

### Petition likewise noted that emission control investments depend on the trajectory of market prices, which is "highly upcertain due to conditions in the capital and commodity markets." 14 

### Just a few years later, AER is back in front ofthe Board, still unable to present a definite and detailed compliance plan. The Citizens Groups are aware ofand acknowledge the severity ofthe economic downturn that hit illinois and the United States beginning in 2008. 

### But it would frustrate entirely the goals ofenvironmental regulation in Illinois ifagreed-to**pro>~sions** 

### designed to benefit public health could be put on indefinite hold during and after any period of· market uncertainty or economic weakness. The Boardmust deny AER's Petition. 

### II. AER Has Failed to Prove That Compliance With the MPS Would Impose an Arbitrary or Unreasonable Hardship. The Illinois Environmental Protection Act ("Act") places the burden on a petitioner to prove that its proposed variance is necessary to avoid an arbitrary or unreasonable hardship. 415 ILCS 5/35, 37. In 

### this case, AERhas failed to show any cognizable hardship because it has not explored all feasible alternatives for lowering its S02 

### emissions, and because any hardship AER

nowfaces was self-imposed by AER and the Ameren Corporation's own business decisions to opt into the MPSts 

### and to operate their illinois generating plants through a deregulated entity instead ofkeeping them within their regulated distributing company. 

### A. AER Bears a "Heavy" Burden In Demonst•·ating That Complying With the MPS Would Cause an Arbitrary or Unreasonable Hardship. The Actprovides that the Board may grant a variance when it fmds "that compliance with any rule or regulation, requirement or order ofthe Board would impose an arbitrary or unreasonable hardship'' 415 ILCS 5/35(a). In 

### order to determine whether a hardship would be

14 2008 Petitionfor Variance at 10. 15 For purposes ofconvenience and readability, we refer to "AER's" participation in the lv1PS rulemaking proceedings. The official Ameren Corporation affiliates in those proceedings were three AER subsidiaries, Ameren Energy Generating Co., Ameren Energy Resources Generating Co., and Electric Energy Incorporated (whichis 80 percent mvned by AmerenEnergy Generating). 

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"arbitrary or unreasonable," the Board must balance the extent ofthe individual hardship against the environmental impact ofgranting the variance. 

### Monsanto Co. v. !PCB, 67lll. 2d 276, 292 (1977). A petitioner for a variance bears a "heavy" burden. 

### WillowbrookMotel P 'ship v.IPCB., 135lll. App. 3d 343, 349 (1st Dist. 1985). The petitioner must show "that avariance 

### is
necessmyto avoid arbitrary or unreasonable hardship." 

### !d. (emphasis added). In 

### doing so, the petitioner must showthat all alternatives for compliance with the standard are infeasible. 

### See AllaertRendering, Inc. v. !PCB, 9llll. App. 3d 160, 162 (3d Dist. 1980). Additionally, the Board has discounted an impending hardship when it has been "selfimposed by the petitioner's inactivity or decision making." 

### Marathon Oil Co v.IEPA, PCB 94- 27(May 16, 1996), at 10. 

### InEkco Glacov. IEPA,PCB 87-41 (Dec. 17, 1987), at4, 

### aif'dl86lll. App. 3d 141 (1st Dist. 1989), the Board denied a variance because: [The petitioner's] problems arise from the delay caused by decisions it has made in attempting to secure compliance and its failure to commit to a particular compliance option. The Board cannot find that those problems constitute an arbitrary or unreasonable hardship, especially when the potential for environmental harm and lack ofa firm compliance plan are considered

.. The Board concluded: "any hardship in complying with the

... regulations is largely selfimposed, in that it results from prior business decisions'' 

### !d. at 6. 

### See also WillowbrookMotel P'ship, 135 ill. 

### App. 

### 3dat344;AllaertRendering, 91 TIL App. 3d at 162. 

### B. AER Has Not Shown a Hardship Because It

### Has Ignored Feasible Compliance Altematives. AER's Petition incorrectly suggests that there are only two options for the company: either obtain a variance or shutter multiple generating stations. 

### See, e.g, Petition at 2 ("Absent such stability and the improvement ofpower prices, AER will be left with no choice but to cease operations at additional energy centers as its only other viable compliance alternative.").

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However, as became clear in AER's responses to Board questions and intestimony at the hearing, AER failed to meaningfully scrutinize other compliance or mitigation options. Before a variance can be granted, these other compliance options need to be fully explored and demonstrated not to be viable alternatives. AllaertRendering, 

### 91lll. App. 3d at 162 (upholding Board finding that petitionerhad not shown hardship because ithad not demonstrated that all compliance alternatives were economically infeasible); WillowbrookMotelP 'ship, 

### 135lll. App. 3d at 349 (variance must be "necessary 

### to avoid arbitrary or unreasonable hardship") (emphasis added).Thus, the variance should be denied due to AER's failure to demonstrate a hardship that
cannot be alleviated by a means other than the variance. In 

### the alternative, given the evidence in the record that AER can and will achieve greater levels of S02 

### emissions reductions than the minimal reductions promised to IEPA, it should be required to meet those lower emission levels

as a condition ofany variance. 1. AER's Scope ofAnalysis and Criteria for Evaluating Identified Alternative Compliance Strategies Were Improperly Narrow. 

### Although AER addressed two additional compliance alternatives-curtailingpower production at unscrubbed units and use ofdry sorbent injection ("DSI")-when pressed to do so by the Board, its evaluation ofthose alternatives 

### was based on inappropriately narrow criteria. 16


### AER looked at these potential compliance strategies in a fashion that was both rigid and piecemeal: each was reviewed only in isolation, and then only to determine whether it would achieve 100% compliance with the MPS. In 

### so doing, AERfailed to demonstrate that a combination 

### ofstrategies would not work, or that such a combination of strategies-including

16 See AER's Responses to the Illinois Pollution Control BoardTechnical Unit's Questions at 2-3 (July 30, 201'2) ('First AER Response"); AER's Responses to the illinois Pollution ControlBoard Technical Unit's Second Set of Questions at 2 (July 30, 2012) ('Second AERResponse"). 9

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additional strategies that it failed to evaluate at all, as discussed in subsection 3, 

### infra-wouldnot
at least bring AER closer to the MPS requirements so as to further reduce emissions during any variance period. Indeed, AERhas effectively admitted that it can do better than the limited reductions it has consented to in connection with its variance request, because AERhas admitted that it can and will do more when necessary in order to meet CSAPR requirements. 17


### With respect to curtailment ofproduction, AER informed the Boardthat meeting the :MPS solely by curtailing production at the unscrubbed units would require drastic operational reductions, and therefore would be uneconomical. 18 

### However, this scenario is a straw man. It 

### presents no reason why a lesser level of curtailment ofproduction at the unscrubbed units would be infeasible, or what wouldhappen ifsuch lesser curtailment were effectuated together with other strategies. Similarly, with respect to DSI, AERfailed to investigate the possibility ofinstalling and implementing DSI at a rate short ofwhat is needed to comply with the MPS, and to do so in combination with other methods ofemission reduction. 19 

### Itis entirely possible that DSI could be implemented at a rate that would not overburden the existing ESPs, as AER complained,20 

### but would still effectuate significant emission reductions. Thus, AER's meticulously narrow approach to answering the Board's questions failed to

assess whether a combination ofapproaches and methods-includingboth those specifically addressed by the Board and others known to be available to it, as discussed in subsection 3

17 Menne Test. Tr. at 41:19-42:23. 18 See, e.g, AERFirstResponse at 3 ("[I]n order to comply with theproposedldPSS02 emission rates, AER would need to lower capacity factors on such units to between 22% and 38%.

. . The result is negative cash flow and an inability to fund ongoing operations... Operation curtailment ... is simply not a viable compliance alternative.") (emphasis added). 19 See, e.g., AER Second Response at 2 ("More importantly, to comply with theMPSvia sorbent injection would entail installation ofsuch controls (and baghouses) at virtually all ofAER's uncontrolled units across the system The cost of such alternative would exceed the cost to complete the Newton Scrubber.") (emphasis added). 20 See subsection 2, infra. 

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infra-could approach or meet the MPS requirement. AER should be required to conduct a thorough analysis to determine whether a suite ofcontrol options-including, 

### inter alia, varying degrees ofcurtailment, varying degrees ofDSI implementation, use ofultra low sulfur coal 

### (see infra), maximizing/optimizing existing scrubbers, maximizing operations and capacity at units with scrubbers, and/or natural gas conversions (see 

### infra)-would obviate AER's purported "hardship," and hence limit the need for a blanket variance. It is possible that using these options together, butmore minimally than ifeach was used alone, would achieve sufficient results. Indeed, even in the absence ofthe analysis that AER should have done, it is clear thatit could do better than the anemic reduction to 0.3 5-0.3

### 8 Ib/mmBtu ithas promised to achieve in connection with the variance. The company concedes as much in acknowledging that it can and will do more in the way ofS02 

### control to meet CSAPRrequirements. Mr. 

### Menne testified: Obviously, since we have been struggling to figure out how we would come up with a best way to present to you as an alternative to the MPS, we've also been looking at what else we could possibly do when CSAPR gets reinstated.

. . On the S02 

### side, we will still have to be able to take some additional measures, and we're looking at possibly reducing, bringing in more low sulfur coal or lower sulfur coal. Ifwe have to do some sort ofadditional sorbent injection, it wouldn't be enough to get us to these MPS rates but we might have to enhance it some.21 

### Further, this admission undercuts AER's claimthat there are only two options before the
company, either obtain a variance or shutter one or more ofits generating stations.22 

### As AER openly concedes, there is a third option ofdoing more than they are doing under the variance, that is, what they suggest they will do to meet CSAPRrequirements, but doing itnow, pursuant
to a variance or the MPS, instead oflater under CSAPR.

21 Menne Test. Tr. at 41:19-42:23. 22 See, e.g., Petition at 2. 

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2. AER's Evaluation ofthe Feasibility ofDSI was Inadequate.
As noted above, AER rejected the compliance alternative ofDSI. AER's dismissal of DSf 3 

### is based upon three claims: variable removal rates, overburdening existing electrostatic precipitators (''ESPs"), and cost24 

### Nonetheless, all ofthese claims are negated by (1) AER's report ofDSI pilottesting at its Joppaplant, attached hereto as Exhibit 2; and (2) its earlier commitmentto use DSI as documented in Ameren Corporation SEC filings. Perhaps most informative is AER's actual experience with the DSI test program at Joppa25 

### The two types ofsorbent used for the test were Sodium Bicarbonate ("SBC," a product made from Trona) and Trona, the same sorbent that is the focus ofKimberly Gray's comments in this proceeding, attached hereto as Exhibit 326 

### First, in terms ofvariability, AER dismissed the feasibility ofDSI, by stating, "AER's evaluation ofsorbent injection reflects removal levels of 10 to 90%. Such variability in removal efficiencies reduces the effectiveness ofthis technology as a compliance altemative." 27 

### Nonetheless, the Joppa test results indicate that the variability ofS02 

### removal was well within control ofthe operators (or testers, in this case). To be clear, the variability in removal efficiency

was a result ofthe testers varying the testing parameters including type ofsorbent, injection location, and injection rate 28 

### Otherwise, the removal efficiency remained consistent29 

### Even with these variations, when injection rate was controlled with a goal of50% S02 

### removal, the removal rate was much more consistent and in the range of42% to 67%, notthe 10% to 90%

:B In his testimony, AER ·witness lvlichael Menne referred to dry sorbent injection as simply "sorbent injection." Menne Test. Tr. at41:19-42:23. 24 AER Second Response at 2. 25 See Ex. 2, The Shaw Group, EElJoppa Generating Station DrySorbentInjection TestProgram, FinalReport (Sept. 24, 2010) ("Joppa Report"). 26 See Ex. 2 at 6; Ex. 3, Gray Connents at 5-15. 27 AER Second Response at 2. 28 Ex. 2, Joppa Report, at 15-28. 29!d. at 28. 

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suggested by AERin this proceeding. 3

# ° Further, the Joppa Report identified the exact parameters needed to achieve a 50% S02 

### removal rate: "When using SBC for 50% S02 

### removal,

a utilization rate ofabout O.l2lbs S02 

### removed per lb ofSBC is needed (8.3 tons ofSBC/ton of S02 

### removed) with injection after the air heater and a significantly greater utilization rate
... if injection is before the air heater. " 31 

### Additionally, AER's claim that variable removal rates preclude the use ofsorbent injection is belied by Ameren Corporation's earlier commitments in SEC filings to do sorbent injection to meet MPS requirements: To comply with the MPS, Genco and AERG are installing equipment designed to reduce mercury, NOx, and SOz emissions. Currently, Genco's and AERG's compliance strategies and resulting estimated environmental capital expenditures also include precipitator upgrades at Genco's Joppa energy center and the inclusion of a baghouse and 

### dry sorbent injection S02 

### reduction technology at AERG 'sED. Edwards energy center. Genco and AERGmay also need to install additional, or optimize existing, pollution control equipment to meet new emission reduction requirements under the MPS, CSAPR, or the proposed federal MACT standard as they become effective.32 

## * * *
To comply with the MPS, Genco and AERG are installing equipment designed to reduce mercury, NOx, and S02 

### emissions.

. . . Genco's estimated environmental capital expenditures assume the use of 

### dry sorbent injection S02 

### reduction technology on all coal-fired units at EEl's Joppa plant, but Genco is also reviewing other options. 33 

### Thus, Ameren Corporation's own SEC filings indicate that DSI is a technologically feasible and financially viable control technology.

30 !d.; AER Second Response at 2. 31 Ex. 2, Joppa Report, at 30. 32 Ameren Corp., Quarterly Report (Form 10-Q) (May 10, 2011) at42 (emphasis added), available at http://www.sec.gov/ Archives/edgar/data/18654/000 119312511134059/d1 Oq.htm.
33 Ameren Corp., Quarterly Report (Form 10-Q) (Aug. 9, 2011) at 48, available at http://www.sec.gov/Archives/edgar/data/18654/000119312511216568/d10q.htm.

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The conclusion that variable removal rates are not a legitimate concern is further supportedby Kimberly Gray's comments. As Ms. 

### Gray indicated, aDSI system's S02 

### removal
rate is within the control ofthe operator: DSI systems do not require major capital investment and are very robust and flexible in design. S02 

### reductions in the range of 50-80% can be achieved and reductions of as high as 95% have been documented. 

### Further, simply by adjusting the dry sorbentfeed rate, removal rates can be tuned to changes in operating conditions (i.e., changes in

### .fuels, loads, regulations, etc.). 34 

### Thus, removal rates vary as a result ofoperator choice-notbecause ofany inherent unreliability in the technology. Second, in terms ofESPs, AER rejects DSI additionally on the ground that its implementation would require baghouses (also called "fabric filters") at all uuits. The company asserts, "More importantly, to comply with the MPS via sorbent injection would entail installation ofsuch controls (andbaghouses) at virtually all ofAER's uncontrolled uuits across the system." 35 

### Nevertheless, AER failed to investigate whether DSI would in fact require a baghouse at every unit. Without such a conclusive finding, it is impossible to determine what exactly the costs associated with DSI wouldbe and whether DSI is in fact financially feasible. Once again, the Joppa Report also contradicts AER's claim that DSI would impair its ESPs and require baghouses at every unit. The report compares particulate emissions during baseline with particulate emissions during SBC inj ection36 

### Contrary to AER's claims regarding impairment, there was an improvement in ESP functioning with the injection ofthe dry 

### sorbent. 37 

### The collection efficiency was 98.88% during baseline, but was 99.01% during SBC injection with an

34 Ex. 3, Gray Comments, at 1 (emphasis added). 35 AER Second Response at 2. 36 Ex. 2, Joppa Report, at31-32. 37 Id.at31. 

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increase in efficiency of0.13%. 38 

### Perhaps the most significant statement in the whole report is the conclusion that dry sorbent injection did not impact operations ofthe ESP: It should be noted that with the addition of dry sorbent, no impacts on the operation of the ESP or opacity were observed when firing Jacobs Ranch coal. The Opacity and ESP performance (i.e., spark rates, secondary current, etc.) did change with SBC injection when firing the Belle Ayr coal with an increase in opacity of several percent. This increase did not cause the plant any issues with meeting the plant's opacity limits 39


### This directly refutes AER's testimony that dry sorbent injection overburdens their ESPs. Furthermore, Ameren Corporation SEC filings contradict AER's claim regarding the sweepingrequirement for baghouses and instead suggest that no baghouseis in fact needed to do sorbent injection at Joppa. To comply with the :MPS, Genco and AERG are installing equipment designed to reduce mercury, NOx, and S02 

### emissions.

. . Genco's estimated environmental capital expenditures assume the use of 

### dry sorbent injection S02 

### reduction technology on all coal-fired units at EEl's Joppa plant, but Genco is also reviewing other options 40


### The absence ofany mention ofthe capital expenditure needed for a baghouse at Joppa when assuming the use ofdry sorbent injection suggests that no such baghouse is needed. This is consistent with the Joppa Report, discussed above, and with current operating experiences with DSI. DSI has in fact been installed at existing plants without requiring a baghouse and simply with upgrades to existing ESPs.41 

### Under those circumstances, it has in fact improved ESP performance 42

"Id. 39 Id. at 32. 40 Ameren Corp., Quarterly Report (Form !0-Q) at 42 (Aug. 9, 2011), avazlable at http://www.sec.gov/Archives/edgar/data/!8654/000!193!2511216568/dlOq.htm.

41 Ex. 3, Gray Comments, at 11 ("Enhancements to ESPs at existing plants appear sufficientto address the addition ofa Trona system without the conversion to a fabric filter."). 42 !d. ('Withthe use oftrona, the control efficiency ofESPs improves."). 

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Finally, AER suggests, without documentation, that the cost ofDSI is prohibitive, stating that "[t]he cost ofsuch alternative would exceed the cost to complete the Newton Scrubber'' 43


### This statement does not give a full and complete picture ofthe relative costs ofDSI and scrubbers. As stated in an Ameren Corporation SEC filing, "[c]apital requirements for some ofthese technologies, such as dry sorbent injection, would be lower than for scrubbers." 44 

### Indeed, the fact that AER considered DSI at length over many months, as documented in multiple SEC filings, suggests that it is financially feasible. 45 

### Ms. Gray likewise noted, "Nonetheless, perhaps the biggest advantage ofDSI is lower cost compared to wet FGD with DSI averaging 10-25% 

### ofthe
cost ofwet FGD." 46 

### Together, the Joppa Report and Ameren Corporation's SEC filings, with the added insights from Ms. Gray's comments, undercut AER's claims ofvariability and ESP impairment and cost, and demonstrate the viability ofthis alternative which AERfailed to sufficiently investigate. AER's Petition must be denied because it has not demonstrated there are no feasible compliance alternatives. 

### 3. AER Failed to Conside1· Ultra Low Sulfur Coal and Natural Gas Conversion as 

### Compliance Options Not only did AER fail to adequately evaluate the compliance options identified by the Board, but it neglected entirely to consider and analyze two additional potential strategies for S02 

### emission reduction: ultra low sulfur coal ("ULSC") and natural gas conversion. Either or both ofthese, in combination with other strategies, could achieve siguificant progress toward or compliance with the MPS.**3** AER Second Response at 2. 44 Ameren Corp., Quarterly Report (Form 10-Q) at 42 (Aug. 9, 2011), available at http://www.sec.gov/ Arcbives/edgar/data/18654/000 119312511216568/d!Oq.htm. 45 See, e.g., Ameren Corp., Quarterly Report (Form 10-Q) at 47 (May 10, 2011); Arneren Corp., Quarterly Report (Form 10-Q) at 42 (Aug. 9, 2011). 46 Ex. 3, Gray Comments, at 3. 

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With respect to ULSC, Mr. 

### Menne specifically identified lower-sulfur coal as a potential strategy for meeting CSAPRrequirements. 47 

### Indeed, Ameren Corporation already is using that strategy extensively in Missouri-in combination with other strategies-to meet emission requirements. Ameren Missouri announced in 2011 that it would purchase 91 million tons of such coal from Peabody Energy through 2017 as part ofa package of strategies to meet federal S02 

### reduction requirements while holding rates down. 48 

### In making this announcement, Ameren Missouri made clear repeatedly that ULSC was both feasible and economical as part ofa larger
set ofemission reduction strategies. One official stated as follows: Buying regular coal, instead of the "ultra low sulfur coal" would have required Ameren to buy more of the expensive emission-fighting technology sooner, Baxter said. In 

### any given year, Ameren typically bums about 20 million to 22 million tons ofcoal. "This contract Will allow us to avoid siguificant levels of environmental expenditures by 2014 as well as defer the installation of costly clean air filtration equipment well beyond 20l 

### 7 to meet the federal government new stringent standards for sulfur dioxide emissions reductions," Baxter said. "This strategy will avoid rate increases that would have been necessary just to meet the S02 reduction requirements. Those would have been in the range of 15 to 20 percent by 2017 for our customers 49


### Another Ameren official similarly commented that use ofultra low sulfur coal from Peabody "willhelp the company minimize its environmental expenditures, defer installation of costly clean air filtration equipment, meet sulfur dioxide emission reductions and avoid rate increases." 50 

### And Michael Menne, the Ameren Services Company Vice President of

47 Menne Test. Tr. at 41:19-42:23. 48 Press Release, Ameren Missouri, « AER Missouri Amlollllces Proactive, Cost-Effective Environmental Compliance Strategy," (August 4, 2011), available at http://arneren.mediaroom.com/index.php?s=43&item=969. 49 Kelsey Volkmann,Ameren, PeabodyEnergy ink their largest coal deal ever, ST. LoursBus. J., Aug. 4, 2011, available athttp:/ /www.bizjoumals.com/stlouis/news/20 11/08/04/ameren-peabody-energy-ink-coaldeal.html?page=al1.

50 "Compliance & Standards Briefing: Ultra-Low Sulfur Coal, Water and LEED, PV and WEEE," Environmental Leader, August 9, 2011, available at http://www.environmentalleader.com/201!/08/09/compliance-standardsbriefmg-ultra-low-sulfur-coal-water-and-leed-pv-and-weee/ (last accessed August 8, 2012). 

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Environmental Services who provided testimony in support ofAER's variance petition, commented to the press a few weeks ago, "We believe the measures we've incorporated iu our pollution control strategy will comply with all current and newEPA standards

... These

measures include installation ofthe S02 

### scrubber at our Sioux Energy Center, the use ofultralow sulfur coal and enhanced particulate and mercury controls at our other energy centers in 

### Jvhssouri." 51


### With respect to natural gas, once again an Ameren affiliate itselfacknowledged that natural gas conversion is a possibility. "Electric Energy [Joppa] does produce a small amount of
power from natural gas, but [Bill] Sheppard [President ofElectric Energy, Inc.] says if

... pnces [ofenergy from coal power] don'tpick up, the company may need to do a major renovation and completely switch over. " 52 

### This suggestion is consistent with the national picture offuelswitching at existing coal-fired powerplants. "Aging fossil stations are gaining newleases on life through gas turbine repowering projects that typically add capacity, lower emissions and increase efficiency." 53 

### In 2004, 

### when the article was written, more than a dozen coal plants had been repowered in North America and two dozen more were plarmed. The viability ofthis option has only increased over recent years as natural gas prices have dropped. For instance, Aliiant Energy has undertaken fuel-switching efforts from coal to natural gas. 54 

### Alliant acknowledged that the lure of abundant and cheap natural gas has had an influence over the company's long-term strategy. The domestic gas boom, fueled by the wide-scale expansion of hydraulic fracturing of gas wells, is expected by some

51 Don Corrigan, Residents Protest SmokestackPollution atRegionalMeeting, WEBSTER-KIRKWOOD TIMES, July 6, 2012, http://www.websterkirkwoodtimes.com/ Articles-News-i-20 12-07-06-181215.114137-Residents-ProtestSmokestack-Pollution-At-Regional-Meeting.html. 52 Fanna Haile-Selassie and BenJeffords. Electric EnergyInc. Lays Off 44 Employees, WSJL TV (June 13, 2012), http://www.wsiltv.com/news/local/Electric-Energy-Inc-Lays-Off-44-Employees-158958295.html. 53 Robert Swanekamp, Olddog
... New tricks: Gas turbine repoweringrejuvenates agingfossllstations, POWER ENGJNEERJNG, Oct. 1 , 2004, http:/ /WW\v.power-eng.com/articles/print/volume-108/issue-10/features/old-dognewtricks.html. 54 Daniel Cusack,Alliant to buildgas-firedplanton site once reserved for coal, CLIMATE WIRE, Aug. 6, 2012, http://www.eenews.net/climatewire/2012/08/06/5. 

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analysts to continue to the end of the decade or longer if there are no major changes in wellhead production or regulations governing the practice

. . Such forecasts are prompting dozens ofutilities, inc!uding those once bullish on coal, to reconsider whether to continue investing billions ofdollars in pollution controls for coal

. 55 

### Together, these trends show the viability ofthis alternative which, again, AER failed to explore. AER's Petition must be denied because ithas not demonstrated there are no feasible compliance alternatives. 

### C. Any Hardship AER Faces is Self-Imposed and The1·efm·e NotArbitrm-y or Unreasonable. 

### As explained above, the Board may only grant a variance when it finds that "compliance with any rule or regulation, requirement or order ofthe Board would impose an arbitrary or unreasonable hardship." 415 ILCS 5/35(a). TheBoardhasmade clear on numerous occasions that a self-imposed hardship is neither arbitrary nor unreasonable, and thus thatno variance may be granted where the petitioner's hardship is self-imposed. See Marathon Oil Co. v. !EPA, 

### PCB 94-27 (May 16, 1996), 

### at 10-11 (variance denied even 

### ifentire refmery had to be shut down because that result "was a hardship Marathon brought on itself'); Ekco Glaco v. !EPA, 

### PCB 87- 41 (Dec. 17, 1987) (variance denied when petitioner's own business decisions led to

. noncompliance); AllaertRendering, Inc. v. !PCB, 

### 91lll. App. 3d 160, 162 (3d Dist. 1980)

(upholding denial ofvariance when Board found that "any hardship visited upon [the petitioner] is largely self-imposed"). Here, AER'sclaimed hardships should be discounted for two reasons: i) AERwillingly opted into the MPS, and ii) Ameren Corporation chose to operate its generating plants through a deregulated entity instead ofkeeping them within its regulated lllinois utilities, and benefited handsomely from this business decision for many years.

55 Jd

.. 

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1. 

### AER Agreed to, and Benefited From, Its Participation in the MPS. AERproposed, negotiated, opted into, and benefited from tbe standards it now seeks to lllldermine. As a result, any hardship AER may face in complying witb the MPS is self-imposed. Because, llllder enduring Boardjurisprudence, a self-imposed hardship is neither arbitrary nor llllreasonable, the Board must deny AER's Petition.



### a. AER's Claimed Hardships from MPS Compliance Were Fo1·eseeahle When It 

### Opted into the MPS, So They Are NotA•·bit•·ary o1· Unreasonable. Longstanding Board precedent has established that a self-imposedhardship includes a hardship that is foreseeable at the time a petitioner subjects itselfto regulation. 

### See Willowbrook MotelP 'ship v. !PCB, 135 llL App. 343, 345 (1st Dist. 1985) (upholding Board's denial ofa variance after Board folllld tbatpetitioners' acquisition ofproperty near sewage system on restricted status was "a gamble on its ability to obtain permits" to develop tbat property); 

### !EPA v. Lindgren Foundry Co., PCB 70-1 (Sept. 25, 1970), at 8-13 (hardship self-imposed, and variance denied, when tbe petitioners purchasedfolllldry witb "full knowledge, or witb reason to know, tbat tbey could not operate tbe folllldry witbout complying with tbe air pollution laws or obtaining a variance, and variances have never been a matter ofright"). Thus, where tbe hardship borne by a petitioner is foreseeable at the time a petitioner subjects itselfto regulation, that hardship is neither arbitrary nor llllreasonable. 

### In such circumstances, a request for variance
must be denied. 

### See WillowbrookMotelP 'ship, 135 llL App. at 345; 

### Lindgren Foundry, PCB 70-1 (Sept. 25, 1970) at 8-13; 

### see also Rufo v. Inmates of Suffolk CountyJail, 502 U.S. 367, 385 ("ordinarily

... modification[s to consent decrees] should notbe granted where a party relies
upon events tbat actually were anticipated at the time it entered into a decree").

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Likewise, in the present case, AER's Petition must be denied because any hardships AER faces were foreseeable in 2006,2007, 

### and 2009, 

### when-as both AER and IEPA acknowledge56

### -Ameren proposed, negotiated, re-negotiated, and agreed to subject itselfto the MPS. AERnow complains that recent modulations in powerprices and market conditions, AER's difficulty in obtaining financing, "regulatory uncertainty," the possibility that plants might need to be shut down ifthe variance is denied, and the MPS' S02limits themselves render compliance with the MPS an arbitrary and unreasonable hardship. 57 

### Specifically, AER argues that "the impact ofa CSAPR stay
... coupled with the drastic changes in power prices and market conditions in the span ofseveral months preceding this variance request make compliance with the emission rates at issue an arbitrary and unreasonable hardship." 58 

### AER further the MPS includes S02 reduction requirements more stringent than those required by federal law. 59


### AER is wrong as a matter oflaw. To begin with, "changes inpowerprices and market conditions" were entirely foreseeable when AER proposed, negotiated, and opted into the MPS in 2006-07. 

### Natural gas prices, for example, have been volatile for many years, and certainly

were volatile prior to 2006. 60 

### Indeed, AERrecognized the shifting, unpredictable nature of
energy markets and fuel prices long before it agreed to comply with the MPS,61 

### and continues to

56 Petition at 6, 12, and Ex. 4 (Arneren letter opting into MPS); !EPAReconnnendation at 5. 57 Petition at I0-22. 58 Id. at 15. At the public hearing on this matter, AER elaborated on this argument, claiming that ''the lvfPS

... was premised onthe expectation that the power market would continue to support" the costs ofinstallation ofpollution controls. Menne Test. Tr. 19:16-24. 59!d. at 15-17. 60 See Table 6.8 Natural Gas Prices bySector, Selected Years, 1967-2010, U.S. ENERGY INFORMATION ADMINIS1RATION (2010), available athttp://www.eia.gov/totalenergy/data/annual/pdf/sec6_19.pdf (last visited Aug. 10, 2012).

61 See Ameren Q4 2007Earnings Call Transcript (Feb. 14, 2008), available at 21

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recognize ittoday 62 

### AER also knew long before proposing tbe MPS that operating in illinois' deregnlated market, in which electricity generators are "entirely dependent on tbe power price market," 63 

### posed tbe risk of"lower revenues, reduced profit margins, and increased costs of capital and operations expense." 64


### For instance, AER's witnesses testified at tbe hearing tbat the MPS was "premised on tbe expectation tbat tbe power market would continue to support costly installation ofpollution control equipment over tbe schedule oftbe MPS." 65 

### This claim is wholly unsupported. Energy forecasts at the time projected near-term declines 

### in power prices. 66 In 

### short, when AER made tbe business decisions to propose, negotiate, re-negotiate, and opt into tbe MPS, it did so fully

aware that energy markets and powerprices would vary-possibly in ways detrimental to tbe

http:/ /seekingalpha.com/article/64704-AER-corp-q4-2007-earnings-call-transcript?part=single (Statement ofWamer L. Bax"ier, Executive Vice President and ChiefFinancial Officer, that AER's investor guidance is "subject to....energy market and economic conditions....and other risks and uncertainties... "); AmerenEnergy Generating Co., Quarterly Report (Form 10-Q) at 7-8(Mar. 9, 2005), available at http://www.sec.gov/Archives/edgar/data/18651/000100291005000 168/arnerenforml0-k.htrn. Inthe filing, Ameren warns that: «Statements in this report not based on historical facts are considered 'forward-looking' and, accordingly, involve risks and uncertainties that could cause actual results to differ materially from those discussed

... The following factors ... could cause actual results to differ materially from management expectations.. • prices for pov,rer in the :Midwest; • business and economic conditions, including their impact on interest rates;

... • changes in the energy markets,**environmentallaV~-'S** or regulations, interest rates, or other factors that could adversely affect assumptions inconnection with the CILCORP and IP acquisitions." 62 See Petition, Ex. 5, Rygh Aff., at 2-3 ("AER's gross margin is subject to flncl:uations in highly volatile wholesale energy prices

... "); Petition, Ex. 6, Martin Aff., at 2-3 ("the revenues and profit margins ofAER

... are based primarily on dynamic and competitive market-driven commodity prices for, among other things, power and fuel, which canbe highly volatile.") 63 Petition at 12. 64 AMEREN CORP., M1EREN 2001 ANNuAL REPORT: MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS 24 (2002), available at http://media.corporateir.net/media _files/nys/aee/reports/ar

_Ol!Financials/02MDA.pdf (last**'~sited** Aug. I0, 20 12). 65 Menne Test. Tr. at 19:16-24. 66 U.S. ENERGY INFORMATION ADMINISTRATION, DOE/E!A-0383, ANNuAL ENERGY OUTLOOK 2006: WITH PROJECTIONS TO 2030 4 (2006), available at http://www.eia.gov/oiaf!arcbive/aeo06/pdf/0383(2006).pdf. ("average delivered electricity prices are projected to decline from 7.6 centsper kilowatt hour (2004 dollars) in 2004 to a low of7.1 cents per kilmvatthour in 2015 as a result ofdeclines in natural gas prices and, to a lesser extent, coal prices."). 

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company-and it did notmake compliance with the MPS contingent on a robust power market. AER's hardship is, as such, self-imposed, and is thus neither arbitrary nor unreasonable. AER's argument that changing prices and market volatility constitute an arbitrary and unreasonable hardship is even more untenable when viewed through the lens oflllinois law on agreements. lllinois courts adjudicating contract disputes have made clear that changes in prices and market conditions are always foreseeable, 

### and do not excuse an entity from performance ofa
contract ithas entered into. See Northem 

### Ill. Gas Co. v. Energy Coop., Inc., 

### 122 

### TIL App. 3d 940, 952-53 (3d Dist. 1984) (commercial frustration defense to contractual performance does not apply to financial distress resulting from changed natural gas prices); YPI 180N LaSalle Owner, LLC, 

### 403 lll. App. 3d 1 (impossibility ofperformance doctrine does not excuse nonperformance due to financial distress); see also Bankof America, NA. v. Shelboume Development Group, LLC, 

### No. 09 C 4963, 2011 U.S. Dist. Lexis 21258, *14-15 (N.D.lll. Mar. 3, 2011). As the court

. in N011hem!ll. Gas Co. 

### eloquently explained, "as any trader knows, the only certainty ofthe

market is that prices will change. Changing and shifting markets and prices from multitudinous

causes is endemic to the economy in which we live." 122lll. App. 3d at 952. Here, AER's agreement with the State and other parties to enter into and abide by the MPS is the functional equivalent ofa contract. As AER acknowledges, the company itself approached IEP 

### A to develop the MPS and chose to opt in to that standard. 67 

### Moreover, as discussed elsewhere in the following section, AER received significant benefits in return for its agreement to comply with the MPS, which is best evidenced by AER's voluntary business decision to opt in to those standards. Because AER's agreement to comply with the MPS is
tantamount to a contract, the Board should act consistently with our courts' decisions in contract

cases and hold that changing prices and market conditions are foreseeable and, as such, do not

67 Petition at 12. 

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excuse AERfrom fulfilling its commitment to IEPA and others to meet the MPS' S02 

### emission limits by 2015 and 2017. AER's argument that "regulatory uncertainty" creates an arbitrary and unreasonable hardship likewise suffers from major flaws. illinois courts and the Board have made clear that, in general, regulatory instability does not create sufficient hardship to warrant the granting ofa variance. See Citizens Utility Co. viPCB, 

### 134TIL App. 3d 111,115 (June 17, 1985) (affirming Board's denial ofvariance extension because, "[i]fthe speculative prospect offuture changes in the law were to constitute an arbitrary and unreasonable hardship, then the lawitselfwould be emasculated with variances, as there is always a prospect for future change"); ExxonMobil Oil C01p v. !EPA, 

### PCB 11-86; 12-46 (Dec. 1, 2011), at 30 (it is a "generally true proposition" that "regulatory uncertainty cannot support [a] grant ofvariance.") The Board recently made clear in its ExxonMobil 

### decision that a variance may be granted based, in part, on regulatory uncertainty only in "unique" circumstances where uncertainty is "unprecedented." Id. In

### that case, ExxonMobil sought a variance from requirements obligating it to install NOx pollution control equipment by 2014, requesting that instead itbe permitted to wait until its plant "turnaround" in 2019 to install that equipment. Id. 

### at 1. The Board granted the variance on the grounds that, among other things, (i) the state's NOx control requirements

were intended to implement, but notbe more stringent than, federal ozone requirements, and the earliest those requirements would need to be attained was 2019; (ii) there was "unprecedented uncertainty" concerning the "status and timing ofany tightening ofthe ozone standard" after President Obama requested in September 2011 that the draft ozone standard issued by EPA be withdrawn, and that the ozone standard be revisited in 2013; and (iii) ExxonMobil would only be required, under federal law, to install and operate the pollution controls at issue ifthe RACT

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program so requires, and "[i]t is unclear what the future ozone standard will be, whether RACT will be required under that standard, and ifso, when it will be required to be implemented at sources." 

### Id. at 

### 14,30-31. Here, any regulatory uncertainty AERfaces is not remotely comparable to the unique, unprecedented uncertainty at issue in the 

### ExxonMobil proceeding. 

### In fact, it is not clear that there is 

### any material uncertainty aboutthe rules AERis or will be subject to. Unlike in 

### ExxonMobil, where the state 

### NO, rule was intendedto implement federal lawbutnot go beyond it, the MPS was designed to be more stringent than the federal regulations (CAIR) in place when · it was finalized. 68 

### The obligations AER agreed to were not contingent on federal law remaining the same, and thus any subsequent changes in federal requirements create no uncertainty affecting those obligations. Mr. 

### Menne acknowledged that CSAPR, or some form ofthat rule, will go into effect in the next few years, and that AER will need to takemeasures to comply with it69 

### Unlike in 

### ExxonMobil, where it was uncertain that the company would ever be obligatedby federal lawto make additional 

### NO, reductions, it is and has been clear to AERthat CSAPRis coming soon and that AER will need to reduce its S02 

### to comply with it Thus, federal regnlatory requirements are, in fact, substantially certain. AER's argument that compliance with the MPS is an arbitrary and unreasonable hardship because the MPS includes S02 

### reduction requirements more stringent than those required by federal law also cannot be credited. As noted above, at the time AER and IEPA agreed to the

68 See In the }..fatter of ProposedNew Ill. Admin. Code 225 Control of Emissions from Large Combustion Sources, R06-25 (Sept 20, 2006) (IEPA Post Hearing Co=ents) ("

... emission reductionrequirements for S02 inthe MPS [are] more stringent thanthe reductions required under CAIR.''). 69 See Menne Test Tr.40:8-41 :23 ("But ifyoubelieve that CSAPRis going to come back, which mostpeople do, that it will come backinto effect in '14 or '15

.... we've also been looking at what else we could possibly do when CSAPR gets reinstated.") (emphasis added); see also Petition at 15 ("AERbelieves that either CASPR [sic] or a regulatory replacement vvill be inplace before the expiration ofthe requested variance term."). 

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:MPS, it was clear that the :MPS would be more stringent than the CAIR regulations in place at the time. Thus, it was entirely foreseeable that AERwould have to make additional S02 

### reductions above those required ofgenerators operating in other states. AER could have made the decision not to opt in to the :MPS, knowing that the standard was more stringent than CAIR and did not depend on the continued viability ofCAIR, but it did not do so. In short, AER knew full well upon agreeing to the :MPS that it would be obligated to comply With those standards regardless ofwhat rules were inplace at the federal level. As such, any hardship AER may bear70 

### stemming from its duty to comply with the :MPS while generators in other states face lesser restrictions was entirely foreseeable and is not, thus, arbitrary or unreasonable. Accordingly, the Board must deny AER's petition71


### b. Any Ha•·dship AER Faces From MPS Compliance Is Outweighed By the Benefits AER Gained By Opting Into the Standard. 

### AERreceived significant benefits from its negotiated agreement to the :MPS obligations. The variance proposal is an unjustified effort to keep hold ofthose benefits while dispensing with the associated obligations.

70 AER admits that with CSAPR, "AERmay... be competing on a more equal footing in the marketplace." Petition at 15-16. CSAPR, the replacement for CAIRwhichAERrecognizes will be reinstated (Menne Test. Tr. 40:8- 41:23), is more stringent than CAIR-placing generators subject to CSAPRin a position more like that ofAERthan they were when AERagreed to the J\.1PS. 71 Finally, the Board should not give credence to AER's claim that, in the absence ofa variance, it would have to shut down two or more plants to comply withthe MPS. As aninitial point, as discussed in Section II.B, supra, AER has not met its burden ofestablishing there are not any other feasible compliance alternatives. But even if shutdOVi'IlS were necessary for compliance, Board precedent holds that, ·where a party's hardship is self-imposed-as AER's is here, for all the reasons discussed herein--even a full plant shutdown does not represent an arbitrary and unreasonable hardship warranting a variance. See Marathon Oil Co., PCB 94-27 at 10-11. Here, shutdowns were contemplatedby AER at the time it agreed to and optedinto the MPS. Infact, the MPS provides for shutdowns to be used as a mechanismto comply with the standard. See 35 Ill. Adm Code 225.233(!)(3) (regarding trade or sale or provisions resulting from over-compliance, "whether such over-compliance results from control equipment, fuel changes, changes in the method ofoperation, unit shut downs, or other reasons.") (emphasis added). As such, shutdowns were bOth foreseeable and foreseen when the lv1PS was finalized, and thus do not constitute an arbitrary and unreasonable hardship. AER's request for a variance must, therefore, be denied.


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AER expressly acknowledged these substantial benefits in the 2006 rulemaking proceeding that culminated in the l\IIPS. In 

### that proceeding, AER explicitly laid out for the Board the business planning and economic benefits it expected to achieve by agreeing to the l\IIPS. AER's witness Dr. Anne Smith, an expert on the costs and benefits ofair emission control in the electric generating sector, testified as follows concerning the benefits to AER:

The [l\IIPS] provision is more costly, and those added costs are borne by Ameren. However, there would be other important fmancial and operational benefits to Ameren in making use ofthe [l\IIPS] provision. The IL. Rule, with or without the [l\IIPS], will require Ameren (and the other Illinois generators) to make major new capital investments in control equipment . _ There are substantial benefits to companies if they can spread the capital investment costs over a longer period of time. (There are perhaps equally important benefits if companies can spread out the associated demands on construction project management.

_.) 72 

### Dr. Smith concluded that the bargained-for standard "represents a prudenttrade-offfor Ameren
to make from the perspective ofcorporate financial stability, corporate management of construction projects (with associated operational stability), and the creation ofopportunities to achieve these environmental benefits at lower ultimate total cost'' 73 

### Similarly, :Mr. 

### Menne, also serving as Ameren Services Company's Vice President for Environment, Safety, and Health at that time, concluded that the l\IIPS "balances the environmental goal ofeffective controls across pollutants and, at the same time, supports the goal for industry ofa more stable and certain regulatory frarnework'' 74 

### AERreferenced and relied upon Dr. Smith's testimony in its posthearing comments recommending implementation ofthe l\IIPS. 75 

### Additionally, Douglas P. Scott, then-Director ofiEPA, testified before the U.S. Senate Committee on Environment andPublicWorks, Subcommittee on Clean Air and Nuclear Safety

72 See In the Matter of ProposedNew Ill. Admin. Code 225 Control ofEmissionsfi·om Large Combustion Sources, R06-25 ("R06-25") (July 28, 2006) (Testimony ofAnne Smith), at 10. 73fd_ at 13. "Id. (Testimony ofMichael Menne), at 6. 75 R06-26 (Sept. 26, 2006) (AmerenPost-Hearing Connnents), at 9. 

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("EPW"), as follows, concerning the benefits to industry ofillinois' multi-pollutant approach to regulation: The illinois mercury rule provides substantial flexibility in order to reduce the costs of compliance and risk of noncompliance for power plants. This flexibility includes the ability to meet either a 90% 

### reduction or an output based standard of 0.0080 

### pounds mercury/GWh, phasing in standards over a period of 3 

### Yz years with a less restrictive standard in phase one, compliance by averaging of emissions, and the avoidance ofinstalling controls on units that will be shutdown in the near future provided companies make an enforceable commitment to shutdown those units by a date certain. Additional flexibility is provided via a "Temporary Technology Based Standard" (TTBS) that provides relieffor units that install appropriate mercury controls but do not achieve full compliance. Eligible units only need to operate the mercury controls in an optimal manner to comply. This provision is available through June 2015 

### and can be used by up to 25% 

### ofa company's generating capacity. Companies may choose to voluntarily comply with the MPS or CPS as an alternative to the otherwise applicable requirements of the mercury rule. These provisions provide additional flexibility in regards to mercury control in return for companies achieving significant reductions in the emissions ofS02 

### and NOx76 

### As described by Director Scott, AER and other companies who opted in to the MPS were afforded the substantial benefit ofa flexible phased schedule for compliance with mercury requirements, which they would have been required to meet immediately had they not accepted the MPS bargain. Director Scott concluded, "The result has been a tremendous win-win-win for the environment, public health and the regulated community." 77 

### In

### view ofthe substantial benefit offlexibility reaped by AER and the other lllinois companies who took advantage ofthe MPS, IEPA strongly emphasized to the Board in 2006 

### the importance ofthe "once-in, always in" provision ofthe MPS regulations-i.e., the requirement that plantunits opting into the MPS comply with it for the lifetime ofthose units. Without such

a requirement, IEP A warned, regulated entities could take advantage ofthe flexibility benefits of

76 Ex. I, Scott Test. at6. 77 Id. at 14. 

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the rule without the concomitant control requirements for other pollutants. This point was made clear in post-hearing comments submittedby IEPA, and signed by !EPA's present Interim Director, Jobn 

### J. Kim: Once a company opts-in to the MPS, it is required to comply with the MPS for the lifetime of the affected units, i.e., the MPS is a "once-in, always-in" provision. This provision is necessary to ensure that illinois and its citizens continue to receive the benefits of the MPS if a company elects to use this alternative to the otherwise applicable standards ofthe illinois mercury rule. 

### Otherwise a company might elect to opt-in to the MPS, receive the benefits of mercUTy control flexibility, andthen opt-out of the MPS and comply with the othemise applicable requirements of the proposed mercury' rule absent the additional emissions reducaon requirements forNOx andSO 78 2 

### AER, in requesting a variance from the 802 

### requirements ofthe MPS after taking advantage of the flexibility it afforded with mercury compliance, is attempting exactly what Interim Director Kim stated clearly six years ago must be prohibited. 

### 2. AER's Hardship is a Self-Imposed Consequence ofAccepting the Benefits of Deregulation. As discussed above, AER is not entitled to a variance ifthe hardship ofwhich it complains is self-imposed. An essential element ofthe hardship ofwhich AER complains is the financial burden ofderegulation. Deregulation does not constitute a hardship that entitles AER
to a variance, however, because AER's predecessor entities sought deregulation, and Ameren Corporation aggressively took advantage ofits perceived benefits by choosing to enter into the deregulated market. Any "hardship" from that tum ofevents is simply the result of a business decision whose benefits and risks AERfully understood. And in the end, the financial burdens ofderegulation are outweighed by the many years ofbenefits that AERreceived under deregulation.

78 R06-25 (Sept. 20, 2006) (IEPA Post-Hearing Comments), at 47-48 (emphasis added). 

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a. AER's Predecessot·s Sought Deregulation.
Atthe Board's August I, 2012 public hearing, the Citizens Groups presented the testimony ofRobert Kelter. Mr. 

### Kelter has more than 20 years ofexperience working on regulatory issues related to energy and electricity. Mr. 

### Kelter was Director ofLitigation for illinois Citizens Utility Board ("CUB"). During Mr. 

### Kelter's tenure at CUB, he represented CUB on legislative issues in Springfield, including drafting oflegislation and negotiations to
restructure the electric industry ("deregulation") and represented Illinois citizens in electric, gas, and telecommunications cases before the Illinois Commerce Commission. In 

### his testimony, Mr. 

### Kelter summarized the concept ofderegulation as follows: Under the traditional regulatory framework, utilities built power plants and recovered the costs of the plant and earned a return on the investment If 

### the plants need updating or repairs, customers paid those costs. However, the traditional structure also meant that customers received all ofthe benefits from the plants. For example, if a power plant had extra capacity that was not needed to serve the utility customers, then the proceeds of the sale of that power flowed back to the regulated customers-not utility shareholders.79


### In 1997, 

### lllinois implemented deregulation through the lllinois Electric Service Customer Choice and Rate ReliefLaw Ameren Corporation (AER's parent company) (referred to as "Ameren" within this section) both sought this deregulation legislation-through its predecessors-and also benefited immensely from it Indeed, the deregulation legislation facilitated Ameren's creation, when, 

### in December 1997, 

### CIPSCO Incorporated and Union Electric merged. 80 

### These predecessor compauies thatjoinedto form Ameren both participated in the negotiations that led to deregulation legislation, specifically seeking deregulation. 81

79 Kelter Test Tr. at 69:8-19. 80 See Ameren Corporate Fact Sheet, available athttp://vvww.ameren.com/AboutAmeren/Documents/Ameren CorporateFactSheetpdf (last visited Aug. 10, 20 12). 81 See TIL Gen. Assemb., HR, Floor Deb., 90thAssemb. May 30, 1997 atpp. 15-16, available at http://www.ilga.gov/house/transcripts/htrans90/t053097.pdf. (CIPSCO aud Illinois Power worked out a compromise 

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Following deregulation, Ameren still had the option ofcontinuing to maintain its generating assets within the distribution company, so as to be entitled to rate recovery. However, Ameren chose to both move its generating assets to a new, unregulated, subsidiary, and also to acquire additional generating assets. On May 1, 2000, ittransferred its electric generating assets and liabilities (including its coal plants) at historical net book value, to a newly-created unregulated company, Ameren Energy Generating Company ("AERG"), in exchange for a $600 million promissory note and AERG stock. 82 

### The assets transferred included the five coal-fired electric generating stations located in Newton, Coffeen, Meredosia, Grand Tower, and Hutsonville, lllinois, along with other assets and liabilities related to the generation ofelectricity
g- 

### by AmerenCIPS. ' As Mr. 

### Kelter explained, Ameren was in no way compelled by the deregulation legislation to effectuate this transfer: Section 16-111(g) ofthe new law allowed, but certainly did not require Ameren to change its structure and spin off the plants to its unregulated affiliate Ameren Generation, stating, "During the mandatory transition period, an electric utility may, without obtaining any approval ofthe Commission

... sell, assign, lease or otherwise transfer assets to an affiliated or unaffiliated entity

. . ." 220 ILCS 116-111(g). The operative word here is "may." In 

### fact, Ameren carefully weighed its options, and decided to take a calculated risk that shareholders would benefit more from moving the plants to an unregulated affiliate, than it would from keeping them with the regulated utility. Otherwise, the move never would have been made. Kelter Test Tr. at 69:20-70:11.

as to howrate reliefwould be provided.). See also Jay Nies, U.E. Favors GradualMove to Open Electric Competition, ST. Lours Bus. J., May 18, 1997, http://www.bizjourna1s.com/stlouis/stories/1997/05/19/focus4.html?page=all, ("Uuion Electric is part ofan lllinois coalition that drafted and supports a bill pending inthe Illinois legislature to phase inchoice for industrial customers by 2000, and for all customers by 2005."). 82 Cent. Ill. Pub. Serv. Co., Quarterly Report (Form 10-Q) at 5, 10 (May 15, 2000), available at http://www.sec.gov/ Archives/edgar/data/18654/000 1002910-00-000040.t>.i. 83 Cent. Ill. Pub. Serv. Co., Quarterly Report (Form 10-Q) at 2 (May 15, 2001), available at http://www.sec.gov/ Archives/edgar/data/18654/00000 186540 1-5000 12/cips1Oq2 .t>.i. 

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Similarly, Ameren Corporation acquired generating assets after the deregulation legislation was passed. Again, this was at Ameren's own initiative, presumably because Ameren perceived such acquisitions to be fmancially beneficial to the company. "In 

### 2003, Ameren grew with the acquisition ofCILCORP, parent ofCentrallllinois Light Company,

...." 84 

### As a part of the purchase ofCILCORP, Ameren acquired the E.D. Edwards and Duck Creek generating stations. 85 

### Despite seeking the deregulation legislation, Ameren acknowledged the inherent risks of the legislation: The provisions of the Law could also result in lower revenues, reduced profit margins and increased costs of capital and operations expense. At this time, the Registrant is unable to determine the impact of the Law on its futnre financial condition, results ofoperations or liquidity. 86


### b. Ameren benefitted from deregulation 

### Even though there are inherent risks in deregulation and Ameren was aware ofthose risks, Ameren's bet on deregulation paid offextremely well. Ameren's success in the deregulated market was aided by the lack of competition that resulted from massive consolidation ofthe market into three main generating companies upon initiation ofderegulation, including thenewly-formed Ameren. 87 

### The three large generators consisted ofExelon (parent of Commonwealth Edison), :Midwest Generation, and Ameren (parent ofIllinois Power and CILCO). The Citizens Utility Board ("CUB") pointed out that these few suppliers were in a position to compel "substantial rate increases through their regulated electrical delivery sister

84 Ameren Corporate Fact Sheet,**http://~¥.ameren.com/AboutAmeren/Documents/Ameren** CorporateFactSheet.pdf (last visited Aug. 10, 2012). 85 Ameren Corp., Quarterly Report (Form 10-Q) at 52 (Nov. 14, 2003), available at**http://~.**sec.gov/ Archives/edgar/datai18651/000I00291003000354/arneI0-qcomb093003 .txt. 86 Cent. Ill. Pub. Serv. Co., Armual Report (Form 10-K) at 26 (Feb. II, 1999), available at**http://~.sec.gov/** Arcbives/edgar/data/18654/000I002910-99-000020.tx-t. 87 Mike Kroll, The Chair Was Pulled OutFrom Under Cohen, THE ZEPHYR (Nov. 17, 2005), available at http://www.thezephyr.com/cubcohen.htm ("Kroll Article"). 

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companies." 88 

### Without genuine competition, the generating companies had captive customers at its sister distributing company and could sell its electric supply at higher rates. Again, CUB pointed this out: "'It 

### is essentially Ameren selling to Ameren," [Executive Director ofCitizens Utility Board, Dave] Kolata said. "(The auction) was setup to create the illusion ofcompetition without the reality ofcompetition. " 89


### Not surprisingly, the deregulated but non-competitive market provided extraordinary profit for the newly-consolidated companies, including Ameren90 

### Since the passage of deregulation, Ameren's investors have received returns far above the S&P 500. 91 

### CUB quantified these returns to be $2.1 billion more than Ameren investors would have received from investing in other utility companies. 92 

### As late as 2006, Ameren was still well-positioned to continue to increase its earnings at similar rates. CUB noted that, even iflllinois rates remained
at 2006levels, Ameren's return on equity from its generation business was 28% and still

93 

### mcreasmg. As Mr. 

### Kelter testified, "By transferring plants to unregulated affiliates Ameren was able
to reap benefits from the plants that it could have never earned under traditional regulation, and
customers were subject to market prices when the rate freeze ended. For many years Ameren's decision paid offhandsomely." 94 

### The point ofderegulation was to allow utilities to compete within the free market-with the lack ofactual competition being an additional benefit. The free market has both risks and rewards, and Ameren should not be allowed to reap the rewards while

ss

### !d. 89Ameren customers in Illinois bracefor a rate hike, ST. Lours PosT-DISPATCH{Sep. 16, 2006), available at http:/ /wv.'W.citizensutilityboard.org/pdfs/CUB!nTheNews/20060915_STPD

_AERRateHike.pdf. 90 Kroll Article ("[T]he parent companies ofthese utilities e;:perienced record profits during this period."). 91 See Citizens Utility Board, Ameren Corporation's Perfonnance Under the IllinoisElectric Se11Jice Customer Choice andRateRelief Law of 1997 (Feb. 2006) (''CUB Report") (attached hereto as Ex. 4). ''Id. 93 !d

.. 94 Kelter Test. Tr. at 71:1-6. 33

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dodging the risks. :M:r. Kelter correctly observed, "Market prices go up and they go down. Nowhere in the Petition does Ameren give any kind ofbalanced view ofthe profits and losses the plants have generated over the last decade." 95


### Ameren would have us believe that the point ofderegulation was to allow utilities to earn unlimited retums while still placing the burden ofthe risk squarely on the taxpayers. Nonetheless, Ameren chose to transfer their plants to the unregulated side oftheir business, and for many years Ameren shareholders benefitted from this transaction. Ameren wanted the benefits ofthe power plants being under the control ofAERwhen market prices were higb, environmental controls were minimal, and they were generating big profits but does not want to bear the associated risk. "Traditional regulations shielded Ameren from this type ofrisk, and the Company chose to give up that protection." 96
In 

### summary, any hardship that AERnowfaces in operating as part ofa deregulated market was self-imposed, and counter-balanced by the substantial benefits afforded to it over many years. AER's Petition, therefore, must be denied because AERhas not and cannot demonstrate that deregulation is a hardship ofthe type that entitles them to a variance. 3. AER's Ha1·dship is a Self-Imposed Consequence Resulting From Its Business Decisions MadeAfter Deregulation. 

### AERhas claimed that it cannot obtain fmancing for the pollution controls at Newton from its parent corporation, Ameren Corporation. 97 

### (As discussed supra, these entities were separated from each other and created as a result ofthe deregulation legislation.) However, the inability ofthe generating company to access financing from the parent corporation is a selfimposed hardship.

95 Kelter Test Tr. at 72:19-22. 96 Kelter Test. Tr. at 73:17-19. 97 Petition at 22. 

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AERhas not demonstrated that it cannot 

### obtain financing from its parent, but rather that the parent does notwant to 

### provide fmancing. Notwithstanding the implication in the Petition that funding from Ameren Corporation isperse 

### impossible98

, 

### Ameren Corporation's statements elsewhere more plausibly indicate that it could in principle finance its subsidiary, but has chosen
notto for business reasons. As stated during an Ameren Corporation quarterly earnings call, 

### Q: Andjust a follow-up on an earlier question, I guess the cash flow question on the Merchant segment, a lot of things can change going forward but is it in your tool box to use any cash from the corporate segment to fund any shortfalls at the Merchant segment, is that part ofthe potential equation? A: 

### Yeah, I mean it's in the toolbox. It's something that we could use to do. But as we've said repeatedly our goal is for the Merchant segment and for Genco to work toprovide for their own cash need. 

### So that remains our focus. 99


### Ameren Corporation made similar statements in a recent SEC filing: "The Merchant Generation segment and Genco seek to 

### fund their operations internally and therefore seek notto rely on financing from Ameren or external, third-party sources." 10

# ° Finally, AER's own finance expert provided similar quotes from credit agencies in his affidavit: the reduction of environmental capital spending also suggests management's lack of confidence in the longer-term economic sustainability of GenCo's business model. This reinforces our view that Ameren's support for GenCo is limited and that it expects GenCo to cover its cash needs as a stand-alone business even over the short term. (S&P March 2012). 101


### These statements taken together make it clear that it is thepreference 

### ofAmeren Corporation not
to not provide financing to AER, notthat there is any inherentprohibition 

### on such financing.

98 Petition at 22-23. 99 Ameren Corp., Q4 2011 Earnings Call (Feb. 23, 2012 10:00 AMET), (transcript available at http:// seekingalpha.corn!article/38 8891

-AER -s-ceo-discusses-q4-20 11-resu!ts-earnings-call-transcript?part=single) (emphasis added). The question was asked by Reza Hitucki, ofDecade Capital, and answered by Martin Lyons, SVP and CFO ofAER Corporation. 100 Ameren Corp., Quarterly Report (Form 10-Q) at 56 (May 10, 2012) (emphasis added), available at http://www.sec.gov/ Archives/edgar/data/18654/000119312512224293/d328507dIOq.htrn. 101 Petition, Ex. 5, Rygh Aff. at 10. 

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The preference ofAmeren Corporation is a self-imposed hardship that, once again, does not rise
to the level ofthe necessary demonstration ofhardship that entitles a petitioner to a variance. In this regard, AERhas made other business decisions over the years-most notably the almost complete reliance on coal that it has now come to regret-thathave contributed to the creation ofthe "hardship" ofwhich itnow complains. Amereil's own witness so conceded in stating, "AER and its subsidiaries have been some ofthe worst performing companies in their
sector due to high reliance on coal fired generation and lackof foe! andmarket diversification."102 

### The Ameren entities are not entitled under the lawto label the consequences oftheir business decisions and misjudgments over the years a "hardship" and expect the Board to bail them out. 

### III. AER's Proposed Variance Would Injure Public Health and the Envii·onment by Allowing AER to Emit Significantly More Harmful SOz. The Board also must deny AER's Petition because AERhas failed to present an honest appraisal ofits proposed variance's negative environmental impact. AER contends that the variance would allow less 

### S02 emissions than the MPS, mainly due to "offsetting" emission reductions AER claims because ofits shutdown ofthe Meredosia and Hutsonville Energy Centers at the end of2011. 

### AER argues in this proceeding that these reductions should be recognized as a benefit ofthe variance, because AER would voluntarily commit not to operate the plants during the variance's term. 103 

### Elsewhere, though, AER has acknowledged that the shutdowns already are part ofAER's compliance plan for the MPS itself 104 

### Therefore, any

102 Petitioner, Ex. 5, RyghAff. 

### 17. 103 AER contends: "The Hutsonville and Meredosia Energy Centers are fully permitted and AER may lawfully reopen them Hmvever

. .AER would agree not to operate the facilities during the pendency ofthe variance period as a condition ofthe reliefgranted." Second AERResponse at 7. 104 See Ameren Corp., Quarterly Report (Form 10-Q) at 50 (Nov. 8, 2011), available at http://www.sec.gov/ Archives/edgar/data/18654/000119312511302027/d238905d10q.htm (stating that AER's compliance plan v.rith the :MPS «includes the closure ofthe Meredosia and Hutsonville energy centers at the end of December 2011."). 

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emission reductions resulting from the shutdowns are not in excess ofAER's NIPS responsibilities, but rather a direct result ofthem, and will occur whether or not this variance is granted. Properly evaluated, the proposed variance would permit AER's fleet to emit much more harmful S02

### --{)ver 32,000 tons more for the period of2012 to 2019, over 87,000 tons more for 2015 to 2019 alone, and over 15,000 tons more annually for each year between 2015 and 2019. (See 

### Table 1, 

### infra.) 

### AERhas refused to address the negative public health impacts ofthese

excess emissions, and therefore failed to meet its burden tojustifY its proposed variance. 

### A. AER Is Required to Present Evidence ofBoth the Amount ofEmissions That Would Be Allowed Under Its Proposed Valiance, As Well As the Environmental Impact Those Emissions Would Have. In 

### evaluating whether AER's proposed variance is necessary to avoid an "arbitrary or unreasonable hardship," 415 ILCS 5/35, the Board must balance individual hardship against environmental impact. Monsanto Co. v. !PCB, 

### 67lll. 2d 276, 292 (1977). AER bears the burden ofdemonstrating that "the hardship resulting from a denial ofthe variance outweighs any injury
to the public or the environment from a grant ofthe variance'' Marathon Oil Co. v. !EPA, 

### 242 lll. App. 3d 200, 206 (5th Dist. 1993). The Board's regulations require a petitioner for a variance to submit two types of evidence regarding the variance's environmental impact. First, the petitioner must describe "the
nature and amount ofemissions, discharges, or releases ofthe constituent in question ifthe variance is granted, compared to those that would result ifimmediate compliance were required." 3 5 

### lll. Adm. Code 1 

### 04.204(g)(1). Second, the petitioner must include a "qualitative and quantitative description ofthe impact ofpetitioner's activity on human health and the

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environment ifthe requested variance is granted, compared to the impact ofpetitioner's activity ifimmediate compliance is required." 35 ill. Adm. Code 104.204(g)(2). A petitioner fails to meet its burden to show an arbitrary or unreasonable hardship ifit fails to present evidence ofthe variance's environmental impact. City of Mendota v. !PCB, 

### 161 

### ill. App. 3d 203,209 (3dDist. 1987). Conclusory assertions, unsupported by data and analysis,

are not sufficient to meet a petitioner's burden ofproof !EPA 

### v. !PCB, 

### 95 

### Ill. App. 3d 400, 405- 06 (3dDist. 1981); City of Mendota, 

### 16llll. App. 3d at 208; PleJtus Scientific C01p. 

### v. !EPA, 

### PCB 01-120 (Apr. 5, 2001), at 3. B. 

### AER Significantly Understates the Amount of802 

### Emissions That Would Be Allowed By its Proposed Variance. AER's Petition should be denied because AERhas failed to present credible evidence regarding either the amount ofexcess SO, emissions that would be allowed under its proposed variance, 3 5 lll. Adm. Code 104.204(g)(l), orthe environmental impacts ofthose emissions. 35 

### ill. Adm. Code 104.204(g)(2). fustead, AER's description ofthe variance's environmental impact rests entirely on a false premise: that the overall S02 

### emissions from AER's fleet would be lower under the variance than under the current MPS. 105


### Table I, 

### infra, 

### demonstrates why AER's claim is false. The table compares the emissions that wouldbe allowed from the beginning ofthe variance in 2012 through the end ofthe variance in 2020, using a consistent heat input for the emission rates ofthe MPS and theproposed variance. This is precisely the analysis requested by the questions posed in the Hearing Officer's orders ofJuly 5 and July 25, 2012. What the analysis below eliminates, compared to the perplexing and error-laden charts submittedin AER's Petition and its responses to the Board's questions, are two elements completely unrelated to the proposed variance: i) emission

105 Petition at 26. Illinois EPA also relied on this premise in concluding that no environmental harm would result from the variance. !EPARecommendation at 1[1[63, 66. 

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reductions that AER attributes to its December 2011 shutdowns ofMeredosia and Hutsonville 106


### and ii) the difference between AER's actual, historical emissions during calendar years 2010 and 2011 and the maximum emissions that would have been allowed under the MPS during those
years. 107 

### As discussed in section III. C, 

### infra, neither element should be considered when describing the "injury to the public or the environment.fi"om 

### a grant of the variance." Marathon Oil Co., 242lll. App. 3d at 206 (emphasis added). 

### See also 35lll. Adm. Code 104.204(g)(l) (requiring the comparison ofemissions "ifthe variance is granted

... to those that would result if immediate compliance were required"). Assessing the actual, real-world effects ofthe proposed variance, itwould allow AERto emit over 32,000 more tons of 

### S02 

### for the period of2012 to 2020-nearly an additional year's worth ofemissions from its fleet:

106 July 5, 2012 Hearing Officer Order (Question 3(b): "Please state the amount of S02 emissions ifthe requested variance is granted, compared to that which would result ifimmediate compliance is required. Inparticular, please readdress Table 1 onpage 26 ofthe petition to provide a specific estimate ofthe net difference between the projected S02 emissions rmder the current rule and under the proposed variance ifMeredosia and Hutsonville are not considered inthe system-wide analysis."); First AERResponse at 6-10 and Tables 2 and 3 (purporting to respond to this question). 107 See July 25, 2012 Hearing Officer Order (Question 2(1::): "Please readdress Table I onpage 26 and Attachment I ofExh. 7 ofthe petition to also show 'Cumulative S02 Variance Reduced Tons' if2010 and 2011 are not considered."); Second AER Response at 5-6 and Table 4 (purporting to respond to the question). 

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Table 1: CoiTected Comparison of Emissions Under MPS Baseline and Proposed Valiance

Year Heat Input MPS MPS Proposed Proposed Annual Cumulative (mmBtu) 108 

### Baseline Baseline Variance Variance Increase in Increase in 

## so, so, so, so, Allowed S0 2 

### Allowed S0 2 

### Emission Allowed Emission Allowed Emissions Emissions 

### Limit Emissions 

### Limit Emissions 

### Because of Because of (lb/mmBtu) (tons) (lb/mmBtu) (tons) Variance Variance (tons) (tons)
2012 312,003,694 0.50 78,001 0.38 59,281 -18,720 -18,720 2013 312,003,694 0.50 78,001 0.35 54,601 -23,400 -42,120 2014 312,003,694 0.43 67,081 0.35 54,601 -12,480 -54,601 2015 312,003,694 0.25 39,000 0.35 54,601 15,600 -39,000 2016 312,003,694 0.25 39,000 0.35 54,601 15,600 -23,400 2017 312,003,694 0.23 35,880 0.35 54,601 18,720 -4,680 2018 312,003,694 0.23 35,880 0.35 54,601 18,720 14,040 2019 312,003,694 0.23 35,880 0.35 54,601 18,720 32,760 2020 312,003,694 0.23 35,880 0.23 35,880 0 32,760


### By contrast, the tables provided by AER in its responses to the Board's questions are, to put it mildly, confusing. For both Tables 2 and 3 from the First AERResponse, itis unclear how the calculations from the last column, for "Cumulative 

### S02 

### Variance Reduced Tons," were derived. They certainly do not reflect the annual differences between the 

### "MPS Baseline 

### S02 Tons" column and the "Variance 

### S02 

### Tons" columns, as one would expect. Neither do the tables describe the scenarios AER claims they do. In

### its narrative responses, AER stated that Table 2 represents an analysis removing the impact ofthe closure ofMeredosia and Hutsonville, in response to Question 3(b) in the Hearing Officer's July 5, 2012 Order, (Resp. at 9), and that Table 3 represents an analysis removing the impact ofcalendar years 2010 and 2011 109 

### (id. at 10).

108 This heat input is taken from Table 4 oftbe Second AER Response, and reflects the heat input ofAER's remaining fleet, 'Without Meredosia and Hutsonville. 109 AERFirst Response at 9, 10. 

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However, the tables appear to be reversed. 110 

### Moreover, Table 3 actually shows, in line with the Citizen Groups' Table 1 above, that the variance will allow significantly more S02 

### emissions through the term ofthe variance, when the Meredosia and Hutsonville shutdowns and calendar years 2010 and 2011 are removed from the comparison. Table 3 

### equalizes the heat inputs and emission rates for calendar years 2010 and 2011 and, most importantly, equalizes the heat inputs for calendar years 2012 through 2020. With those adjustments-and disregarding the "Cumulative S02 

### Variance Reduced Tons" column, which seems to have been taken from an entirely different table-Table 3 actually shows that AER's proposed variance would allow 691,106 tons ofS02 

### emissions between 2010 and 2020, and the MPS baseline 655,359 tons: a difference of35,747 tons more for the variance. Thus, AER inadvertently proves the Citizens Groups' point: when irrelevant considerations are removed from the analysis, the variance will allow significantly more SOz emissions than the current MPS would. C. Any Emission Reductions From the Shutdowns ofMeredosia and Hutsonville, Or Emissions From PastYea1·s, Cannot Be Credited to the Variance. 

### TheBoard should reject AER's attempts to claim "offsets" from the shutdowns of Meredosia and Hutsonville. Those shutdowns are irrelevant to a consideration ofthe "injury to the public or the environment from a grant of the variance," Marathon Oil Co., 242 

### Til. App. 3d
at 206, because these plants will remain shuttered whether the variance is granted or not. At the hearing, Mr. 

### Menne testified that "AER's commitment to keep these plants shut down during the pendency ofthe variance is a real and meaningful commitment with consequences''til 

### To the

110 Table 2 does not remove the impact ofthe Meredosia and Hutsonville shutdovms, but rather removes the impact ofcalendaryears 2010 and 2011 by equalizing the heat inputs and emission rates for those years. It shows that, without the effect ofcalendaryears 2010 and 2011, but still giving the variance creditforthe closure ofMeredosia and Hutsonville, the variance would allow 7,700 tons less S02 emissions than the current MPS form 20 12through 2020. llJ Menne Test. Tr. at 27:6-9. 

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contrary, AER's commitment is inconsequentiaL Whatever happens in this proceeding, the plants will remain shuttered because i) the shutdowns are necessary for AER's compliance with the MPS and CSAPR and ii) the plants clearly are uneconomical for AER to operate. AERhas publicly acknowledged that shutting down Meredosia and Hutsonville is part of its compliance strategy with both the MPS and CSAPR This is made clear in Ameren Corporation's Form 10-Q 

### for the third quarter of2011, 

### filed well before AER's variance request, in which Ameren discussed the shutdowns. 112 

### Ameren stated: Under the MPS, as amended, Illinois generators are required to reduce mercury, S02, 

### and NOx 

### emissions by 2015. Genco's compliance plan includes the closure of the Meredosia andHutsonville energy centers at the end of December 2011 113 

### Elsewhere in the filing, Ameren stated: Closure of the Meredosia and Hutsonville energy centers will reduce the Merchant Generation segment's fleet emission levels. As a result, the Merchant Generation environmental compliance plan no longer includes the use ofdry sorbent injection at its 

### E. D. 

### Edwards energy center to comply with the CSAPR or 

### MPS. 

### The closure of these two energy centers has allowed the Merchant Generation segment additional flexibility in the methods to achieve compliance with environmental standards. As a result, the Merchant Generation segment has further reduced its expected 2011 

### through 2015 

### capital expenditures by approximately $70 

### million compared to those estimates disclosed in the Form I0- Q 

### for the quarter ended June 30,2011 114


### Put simply, AER is trying to double-count emission reductions. AER already is relying

on the shutdown ofMeredosia and Hutsonville to bring down its fleet-wide S02 emission rate so that it will not have to install earlier planned pollution controls-such as dry sorbent injection at E.D. Edwards-in order to comply with the MPS. Thus, crediting AER with emission reductions for shutting down Meredosia and Hutsonville would be no different from crediting

112 AmerenCorp., Quarterly Report (Form 10-Q) (Nov. 8, 2011), available at http://www.sec.gov/ Archives/edgar/data/18654/000 119312511302027 /d238905d10q.htm. 113 Id. at 50 (emphasis added). 114 ld. at 7-8 (emphasis added). 42

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AER for emission reductions it achieved by installing a scrubber at its Duck Creek facility. In 

### both cases, AER simply has partially complied with the MPS by lowering its fleet-wide rate. The error in AER's logic is made clear by its claim that the proposed variance would keep Meredosia and Hutsonville closed because its interim emissions rates are "set at a level at which uncontrolled units at [the plants] will not be able to resume operations without additional control technology being installed within the generating system." 115 

### This may be true, but what AERneglects to mention is that the MPS as it currently stands will mandate the exact same result. 

### AERhas stated that the annual S02 

### emission rate from its MPS Group in 2011, before it closed Meredosia and Hutsonville, was 0.46lb/mmBtu. 116 

### As depicted in Table 1, supra, 

### the MPS currently requires AER to comply with an S02 

### emission rate of0.43 lb/mmBtu in 2014, and with declining rates thereafter. Without keeping Meredosia and Hutsonville shut down or installing pollution controls, it would be unlikely that AER could meet even the 2014 rate, a rate for which it is not seeking a variance. So the plants will remain closed whether or not a variance is granted-and AER will have saved $70 million in capital expenditures by abandoning a DSI project at E.

### D. Edwards that would have created further S02 

### reductions. 117 

### Essentially, AERis

now asking the Board to pretend that Meredosia and Hutsonville are not part ofits fleet for
purposes ofthe MPS, and therefore that their shutdown could be used to offset non-compliance by AER's remaining fleet. AER's attempt to credit the variance with the shutdowns ofMeredosia and Hutsonville also disregards the fact that the shutdowns will be necessary to comply with areinstated

115 Petition, Ex. 7, Whitworth Aff. at**~** 3. 116 First AER Response at 7. 117 In its Recommendation, IEPA contends that «providing credit for-actions (e.g., unit shutdOVi'IlS) that result in emission reductions is an acceptable part ofthe established regulatory process." (IEPA Recommendation**at~** 24). What !EPAfails to take into account is that AER already will receive "credit" for the shutdowns under the MPS: the shutdowns have lowered .AER's overall emissions rate and are necessary for AERto meet the goal ofeven partial compliance that it h.as set out in its proposed variance. 

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CSAPR 118 

### As Mr. Menne testified at the hearing, a reinstated CSAPRwould be a more stringent regime than AER's proposed 0.35lb/mmBtn emission rate for 2015 to 2019, requiring AERto take "additional measures" to reduce its fleet's S02 

### emissions-including the use of lower sulfur coal or sorbent injection. 119 

### Thus, AER also will need to keep Meredosia and Hutsonville shut down in order to comply with a reinstated CSAPR Again, AER's commitment
to keep the plants shuttered is pointless. Whatever happens in this proceeding, Meredosia and Hutsonville will remain shut down as a necessary part ofAER's CSAPR compliance strategy. In 

### addition, AER's statements outside ofthis proceeding, as well as the historical utilization rates for the plants, indicate that Meredosia and HutsonVIlle also will remain closed because they are uneconomical for AERto operate. In

### May 2009, AER's subsidiary, Ameren Energy Generating Company ("AEG''), proposed site-specific rules related to one of Hutsonville's coal ash ponds. 120 In

### its Motion for Expedited Review ofthat petition, AEG stated: "Ameren has placed the Hutsonville Power Plant on the market for sale to reduce the cost
to Ameren of operating theplant." 121 In 

### short, AER has viewed Hutsonville as an albatross since 2009. AER made clear in an August 12, 2009 press release that it was trying to sell not only Hutsonville, but also Meredosia, too. AER could find no buyers for its aging, inefficient plants, though. 122 

### Therefore, AER reported that it was laying offemployees at both plants and

118 See Tr. at 40-41 ("But ifyou believe that CSAPRis goingto come back, which mostpeople do, that it will come backinto effect in '14 or '15

.... we've also beenlooking at what else we could possibly do when CSAPR gets reinstated.") (emphasis added); see also Petition at 15 ("AER believes that either [CSAPR] or a regulatory replacement will be in place before the expiration ofthe requested variance teiiiL"). 119 Menne Test. Tr. at 42:7-13. 120 In thd{atter ofProposedRules Establishing 35 Ill. Adm. Code SubchapterJ, Part 840, andSubpartA, SiteSpecificRules Providing/or the Closure of Ash PondD at the Hutsonville Power Station, PCB 09-21 (Rulemaking-Land) (May 9, 2009). 121 I d., available at http://www.ipcb.state.il.us/documents/dsweb/Ge11Document-65178, at 75. 122 See Press Release, Ameren Energy Resources Co., Ameren Energy Resources Amlollllces StaffReductions at Three Illinois Power Plants inResponse to Changes inPower Markets, Tough Economy (Ang. 12, 2009), available 

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"retiring" two offour units atMeredosial 23 

### AER's then-President and ChiefExecutive Officer stated: While we regret having to take this action, the challenges we face demand a new model for our merchant generation business-we must build a leaner, more streamlined organization that can more effectively compete in today's difficult h hI . " 124 

### economy w ere we see muc ower pnces 10r ourpower. Less than a year later, AER arui.ounced additional layoffs and stated that it would "also be evaluating temporarily ceasing operations at its least efficient plants

...." 125 

### Finally, in October 2011, AER announced that it would be closing the plants entirely. 126


### AER's economic circumstances surrounding Meredosia and Hutsonville are also reflected in the declining utilization rates ofthose plants from 2008 on. From 2008 to 2009, AER slashed its usage ofMeredosia and Hutsonville. 127 

### At Hutsonville, AER decreased its utilization rate from 68.3% (at 11,459, 911.9 mmBtu) to 39.3% (at 6,586,354 mmBtu). At Meredosia, AERvirtually ceased operations, cutting the utilization rate from 38.3% (at 17,070,473.5 mmBtu) to 13.7% (at 6,103,183.4 mmBtu). These depressed utilization rates remained consistent through the end of2011. 128 In 

### summary, there is no basis to conclude that AERwill in any realistic scenario seek to re-open Meredosia and Hutsonville, given that i) AER will rely on their closures to comply with the MPS and CSAPR and ii) they are uneconomical for AERto operate.

at http://www.prnewswire.com/news-releases/ameren-energy-resources-announces-staff-reductions-at-threeillinois-power-plants-in-response-to-changes-in-power-markets-tough-economy-62215822.htmL 123Id. 124Jd. 125 Press Release, AER Energy Resources Co., AER Subsidiary Armounces Reductions in Response to Continuing Declines inPower Markets (May 3, 2010), available athttp://www.prnewswire.com/news-releases/amerensubsidiary-announces-reductions-in-response-to-continuing-declines-in-po-wer-markets-92697009.html. 126 http://wvvvv.pmewswire.com/news-releases/two-ameren-merchant-generating-company-energy-centers-to-ceaseoperations-131044393.htrnl. 127 See Presentation of !EPA at ICC Meeting (Nov. II, 2011), at slides 8-9, PDF available at http://www.icc.illinois.gov/electricity/policyconnnitteemtg.aspx\ 128Id.; see also Petition, Ex. 1. Using the 2011 S02 emission rates and mass emissions provided by AER the 2011 heat inputs for Hutsonville and Meredosia were 8,755,752 nnnBtu and 9,989,090 nnnBtu, respectively. 

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Aside from claiming reductions from the otherwise-required shutdowns ofits Meredosia and Hutsonville plants, AER also asserts that its variance should be credited with the difference between its fleet's actual emissions during calendar years 2010 

### and 2011 

### and the maximum emissions that would have been allowed under the MPS for those years. 129 

### Quite simply, AER has provided no support for its assertion that wholly past emissions should be considered in evaluating a proposed variance. Instead, this argument is contrary to the basic proposition that a proposed variance should be evaluated on what its prospective effect on a petitioner's emissions would be, compared to what emissions would be allowed ifcompliance were required. Therefore, the Board should ignore AER's references to its fleet's 2010 

### and 2011 

### emissions. AER's failure to accurately describe these emissions mandates that its Petition be denied. D. AER Fails to Add1·ess the Environmental Impacts ofIncreased S02 

### Emissions. By grossly understating the excess S02 emissions that would result from a grant ofthe variance, AER and IEPA both avoid any discussion ofthe significant negative public health impacts that subverting the MPS would have. When asked about the health effects ofS02 

### emissions by Board Member Burke at the hearing, Mr. 

### Menne responded: "Well, although I've studied itfor many years, I'm not a health expert, and I'm not going to go into health
consequences." 130


### AER and IEPA's current silence on the public health benefits ofthe MPS stands in stark
contrast to their representations at the time they proposed the standard. In their Joint Statement in the original MPS rulemaking, AER and IEPA made clear that the S02emission reductions required by the MPS would have a significant positive environmental impact:

129 See Petit. at 26, Table 1; AERFirst Response at 10. 130 Menne Test. Tr. at 39:1-3. 

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Ameren and the lllinois EPA anticipate that the installation and operation of pollution control equipment as contemplated by Section 225.233 will achieve significant additional reductions of S02 

### and NO,, beyond that required from existing regulations and thereby further improve air quality

.... Emission limits of NOx and S02 that are beyond standards set forth in the Clean Air futerstate Rule ("CAIR") will further reduce ambient levels of ozone and PM2.5, and provide substantial environmental benefits to the residents of Illinois

. 131 

### Further, in testimony delivered to Congress in 2009, !EPA's then-Director, Douglas Scott, called the MPS "one of the most important environmental and public health advances in lllinois in recent decades." 132 

### He continued: The benefits ofremoving S02 

### and NO, are well established and most notably will result in reductions in both particulate matter and ozone. S02 

### is a precursor to particulate matter and NO, is a precursor to both particulate matter and ozone. Particulate matter related annual benefits include fewer premature fatalities, fewer cases of chronic bronchitis, fewer non-fatal heart attacks, fewer hospitalization admissions (for respiratory and cardiovascular disease combined) and should result in fewer days ofrestricted activity due to respiratory illness and fewer work loss days. Moreover, there should be health improvements for children from reduced upper and lower respiratory illness, acute bronchitis, and asthma attacks. 133 

### fu further contrast to AER and !EPA's current silence on the public health impacts of thousands oftons ofadditional emissions of S02 

### annually between 2015 and 2019, dozens of lllinois health professionals, representing uuiversities across the State, are now speaking out in defense ofthe MPS. Today, Dr. Peter Onis submitted to the Board a letter signed by over eighty health professionals from across the State, attached hereto as Exhibit 5, expressing concern at the present effort to weaken the MPS, and urging the Board to vote against any action eroding MPS standards. The health professionals cite to the harmful effects ofS02 

### emissions in and of

131 In the Matter ofProposedNew 35Ill. Adm. Code 225 Control of Emissions From Large Combustion Sources, PCB 06-25 (July. 28, 2006) (Joint Statement at 2). 132 Ex. 1, Scott Test., at 2. 133 Id. at 9. 

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themselves, andalso as precursors to fine particle pollution, noting that the linkages between short- and long-term exposure to PM2.5 with premature mortality and cardiovascular effects. Such negative public health impacts were quantified in a 2010 National Research Council study referenced bythe health professionals. 134 

### This study measured the externalities associated with local and global air pollution for individual coal-fired and gas-fired powerplants in the United States. 135 

### Overall, the study quantified the damage caused by emissions of S02, 

### NOx, PM2.5, and PM10 from U.S. coal-fired powerplants during 2005 as approximately $62 billionwith 85% ofthose damages (or approximately $53 billion) 136 

### being caused by so2 emissions. 137


### Almost all ofthe damages (94%) were due to premature mortality. 138


### As part oftheir analysis, the authors ofNRC study calculated damages per ton ofeach criteria pollutant emitted by each coal-fired powerplant in the United States-including AER's fleet The spreadsheet detailing these results is attached hereto as Exhibit 6. For AER's remaining fleet ofcoal plants, the damages per ton of so2 emitted in 2005 ranged from $4,850 (at Newton) to $6,580 (at E.D. Edwards). As set forth in Table 1, above, AER's proposed variance would result in 32,760 tons ofexcess S02 emissions from 2012 through the end ofthe variance in 2020. Using the costs per ton in the study as a benchmark, the cost to the public health and the environment from AER's five-year delay in compliance with the MPS' S02limits

can be estimated to range from $159 million to $216 million. The expected health impacts ofthe variance also were addressed in comments ofDr. Samuel Dorevitch (filed as PC#1919). Dr. Dorevitch concluded:

134 National Research Council, Hidden Costs of Energy: Unpriced Consquences of Energy Production**~d** Use (20 10), available at http://www.nap.edu/catalog.php?record _id=l2794 (also submitted in PC #1918). 135 Id. at 67. 136 All dollar amounts from the study are expressed in 2007 USD. 137 Id. at 87-88, 92. 138 Id. at 94. 

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In light of the health impacts of even moderate levels of S02 pollution, and the long-term health risks ofPM2.5 pollution, failure to lower (AER's sulfur dioxide emissions] on the agreed upon schedule would be expected to keep rates of asthma attacks and other health problems higher than they would be at the agreed upon, lower levels. 

### !d. at 1.

### AERhas failed to meet its duty to show au arbitrary or unreasonable hardship, because it has failed to present any credible evidence ofthe actual environmental impact ofits proposed variance. 

### See City of Mendota v.IPCB, 16llll. App. 3d 203, 209 (3d Dist. 1987). In 

### City of Mendota, the court upheld the Board's denial ofa variance when the petitioner did not present any evidence regarding the effects ofits sewage effiuent discharges onthe environment, other than the plant operator's conclusion that they were "acceptable." 

### !d. at 208. 

### See also Plexus Scientific Corp. v.IEPA, PCB 01-120 (Apr. 5, 2001), at 3 (finding variance petition deficient because it "summarily state[d]" that proposed activity was "not expected to have a measurable environmental impact"). Similarly, AERhere relies entirely on the conclusory-aud incorrectcontention that its variance will not increase emissions. By failing to properly address its proposedvariance's environmental impact, AERhas failed to carry its burden to demonstrate au arbitrary or unreasonable hardship. 

### E. AER's Proposed Va1iance Would Ha1·m Environmental Regulation in Dlinois. AER's proposed variance threatens harm to lllinois' environmental standards beyondthe

excess S02emissions allowed to AER. As discussed in the Citizen Groups' earlier objection (PC #6 at 3), allowing the variance would undercut a negotiated, statewide standard, with potential for further public health injury and a chilling effect on future negotiations. Not only would granting AER's proposed variance embolden other EGU owners in the State to seek their

own variances from the MPS and the related Combined Pollutant Standard ("CPS"), thereby


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allowing additional pollution, it also would discourage future negotiated standards between regulated entities, the State, and environmental groups. IEPA's then-Director rightly hailed the MPS as "atremendous win-win-win for the environment, public health and the regulated community." 139 

### Quite simply, iflEPA will not defend the standards itnegotiates, or the Board the regulations it promulgates, there will be no such future victories. The Citizens Groups are not alone in believing that an AERvariance would destabilize the carefully constructed balance ofthe MPS and CPS. In a news story on the proposed variance, a spokesperson for Dynegy Inc. described AER's request for a variance from the agreed standard as "challenging": 140


### Dynegy Inc., which owns four coal-fired power plants in illinois, has already invested $1 billion "funded by shareholders" allowing it to meet the state emissions limits, said spokesperson Katy Sullivan. She said it is "challenging" for a company like Dynegy when one ofits competitors seeks an exemption from rules that other players have agreed to comply with. Both Dynegy and Ameren sell power in the MISO wholesale market. "One reason that market prices are low in MISO and illinois is that there is an oversupply of power generation capacity in MISO," Sullivan said. "Prolonged low prices are typically a signal for uneconomic plants to exit the market. 

### Granting AER its variance defies the market signals and potentially wi/1 

### keep uneconomic plants in the market longer than they would otherwise operate. We believe the marketplace should determine which facilities are competitive and allowed to continue operation. Regulatory intervention, essentially picking winners and losers, serves to alter the playing field, creating unfair competitive advantages for some and not for others." In this case, the Citizens Groups can agree wholeheartedly with Dynegy: AERis asking this Boardto pick winners and losers in the Midwest energy market, with illinois citizens bearing the brunt ofexcess S02 

### emissions. Because AERhas failed tojustify the harms that its variance would cause, this Board should deny AER's Petition.

139 Ex. I, Scott Testimony at 14. 140 See Kari**Lyderse~**Ameren wants more time to clean up Illinois emissions. MIDWEST ENERGY NEWS (Aug. 6, 2012), http://www.midwestenergynews.com/20 12/08/06/ameren-wants-more-time-to-clean-up-illinois-emissions/ (emphasis added). 

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IV. If

### the Board Does Not Deny AER's Petition, Then It 

### Should Strictly Condition Any Variance 

### As setforth in these Comments, AERhas failed to meet its burden tojustifY a variance from the MPS. Were the Boardto detennine to grant AER a variance, though, any variance must be strictly conditioned. As set forth in Sections I and II, above, AERhas failed to present a definite compliance plan and failed to demonstrate that it has investigated all feasible compliance alternatives. Both issues would need to be addressed before the Board could grant AER any

vanance. First, AER's current compliance plan involves little more than AERproviding "updates"

on vaguely described "engineering" work until the potential completion ofthe Newton FGD project in 2020. 

### Menne Test, Tr. at 32:9-33:6. 

### Should the Board grant AER any variance, AER
must provide a detailed description ofthe work it will perform, and a binding schedule for its completion. This schedule must notbe dependent on energy prices, but rather guaranteed to result in AER's compliance with the MPS by the end ofthe variance. Second, AER must better demonstrate that ithas explored all options for lowering its fleet's S02 

### emissions rate. Specifically, as discussed in Section II, above, AERmust address the possibility ofa "suite" ofpollution control strategies that individually might not allow for MPS compliance, but together would result in significant emission reductions below AER's currently proposed emission limits. In particular, AER should describe in detail the measures it would implement in the event ofa reinstatement ofCSAPR Mr. Menne's testimony made clear that AERhas considered control options that, even ifthey would not yield full compliance with the MPS's requirements, would at least lower AER's emission rate below 0.35 

### lb/nimBtu. Menne Test. Tr. at 41:19-42:23. 

### There is no reason such measures should notbe implemented in partial compliance with the 2015 

### MPS emission limits. AER's duty to explore compliance alternatives
51

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must be ongoing, and its S02 

### emission limit conditioned on the results ofits demonstration of available alternatives. Finally, AER's proposedvariance term offive years is, in any case, far too long. Given AER's refrain ofthe "uncertainty" ofmarkets, any variance granted AER should be no longer than two years, so that all parties may continue to assess the prospects ofAER's future implementation ofpollution control measures, and, indeed, the ongoing viability ofAER as a merchant generator. 

### In granting any variance, the Board should also make clear to AERthat it is the last such variance the company will receive from compliance with the MPS. 

### V. Conclusion For the reasons setforth in these Comments, the Board should deny AER's Petition for Variance. Respectfully Submitted,

Faith Bugel, Senior Attorney Environmental Law and Policy Center 3 5 EastWacker Drive, Suite 1600 Chicago, IL 60661 Tel: (312) 544-4430

52 

### Ann Alexander, Senior Attorney Natural Resources Defense Council 2 N. Riverside Plaza, Suite 2250 Chicago, IL 60606 Tel: (312) 651-7905**aa!exander(~.~nrdc.org**

### Electronic Filing- Received, Clerk's Office, 08/10/2012 

## * * * * *PC# 2409 * 

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Max Muller, Program Director Environment illinois 328 S. Jefferson St., Suite 620 Chicago, IL 60661 

### Tel (312) 544-4430



# //-.>fly' /lres;se:ff 

# LAAJ ' 

### Holly Bressett Sierra Club 122 W 

### Washington Ave., Suite 830 Madison, WI 53703 

### Tel (608) 257-4994

DATED: August 10, 2012

53

# Bri~~!:/f£(

# •

Environmental Health Programs Respiratory Health Assoc. ofMetro Chicago Chicago, IL 60607 

### Tel (312) 628-0245

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CERTIFICATE OF SERVICE
I, Andrew Armstrong, hereby certify that I have served the attached Comments ofEnvi.-onment II!inois, the Envir·onmental Law & 

### Policy Center, Natural Resources Defense Council, Respiratory Health Association, and Sierra Club upon the attached service list by electronic mail andby depositing said documents in the United States Mail, postage prepaid, in Chicago, lllinois on August 10, 2012.

Respectfully submitted,

Andrew Armstrong StaffAttomey Enviromnental Law and Policy Center 35 East Wacker Drive, Snite 1600 Chicago, Illinois 60601 312-795-3738

## Electronic Filing -Received, Clerk's Office, 08/1 0/2012 

## * * * * *PC# 2409 

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Amy Antoniolli Renee Cipriano SchiffHardin, LLP 6600 Willis Tower 233 South WackerDr Chicago, IL 60606 John Therriault, Assistant Clerk Carol Webb, Hearing Officer illinois Pollution Control Board James R. 

### Thompson Center 100 WestRandolph Street, Suite 11-500 Chicago, illinois 60601 therriaj@ipcb.state.iLus GinaRoccaforte Assistant Counsel Division ofLegal Counsel 

### SERVICE LIST August 10, 2012

illinois Environmental Protection Agency 1021 North Grand Avenue, East P.O. Box 19276 Springfield, Illinois 62794-9276

1

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

### AMEREN ENERGY RESOURCES, Petitioner,

v. 

### ILLINOIS ENVIRONMENTAL 

### PROTECTION AGENCY, Respondent. ) ) ) 

### ) ) ) 

### ) ) ) 

### )

CITIZENS GROUPS' EXHIBITS 

### PCB 12-126 (Variance- Air)

1. 

### Written Testimony of Douglas P. Scott, Director, illinois Environmental Protection Agency, Before the U.S. Senate Committee on Environment and Public Works/Subcommittee on Clean Air and Nuclear Safety On the Issue of: "Oversight: Environmental Protection Agency's Clean Air Regulations

- One Year after the CAIR and CAMRFederal Court Decisions" (July 9, 2009) 2. The Shaw Group, EEl Joppa Generating Station Dry Sorbent Injection Test Program Final Report 

### (September 24, 2010)
3. Comments ofKimberly Gray (August 1, 2012)
4. Citizens Utility Board, Ameren Corporation's Peiformance Under the Illinois Electric Sen,ice Customer Choice andRate Relief Law of 1997 

### (February 2006)
5. Comments ofillinois Health Professionals (August 10, 2012)
6. National Research Council, Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use 

### (2010), Public Access File 34, Estimates of damages associated with 

### specific coal-fired electricity-generating facilities and natural-gas-fired electricity generating facilities

## Electronic Filing -Received, Clerk's Office, 08/10/2012 

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EXHIBIT 1

Wiitten Testimony ofDouglas P. Scott, Dii'ector, Illinois Environmental Protection Agency, Before the U.S. Senate Committee on Environment and Public Works/Subcommittee on Clean Air and Nuclear Safety On the Issue of: "Oversight: Environmental Protection Agency's Clean Air Regulations- One Year after the CAIR and CAMR Federal Court Decisions" (July 9, 2009)

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Written Testimony ofDouglas P. Scott Director, lllinois Environmental Protection Agency Before the: U.S. Senate Committee on Environment and Public Works/ Subcommittee on Clean Air and Nuclear Safety On the Issue of: "Oversight: Environmental Protection Agency's Clean Air RegulationsOne Year after the CAIR and CAMR Federal CourtDecisions" July 9, 2009

Mr. 

### Chairman andMembers ofthe Committee: Myname is Doug Scott and I am the Director of the lllinois Environmental ProtectionAgency. I want to thank Senator Carper and the other members ofthe Senate Subcommittee on CleanAir and Nuclear Safety for this opportunityto testify on Illinois' regulations to control sulfur dioxide, nitrogen oxides and mercury emissions from the State's coal-fired power plants.

I received a Bachelor's Degree withhonors from the University ofTulsa in 1982, and received a graduate Juris Doctor law degree withhonors from Marquette University in 1985. I served as ·Assistant CityAttorney and CityAttorney for the City ofRockford, Illinois from 1985 to 1995.

I also represented the City on a number ofenvironmental issues. From1995-2001 I served as an lllinois State Representative for the 67thDistrict and served on the House Energy and Environment Committee, and was a member ofthe committee that rewrote the States' electric utility laws. I was elected to the Office ofthe Mayor ofRockford inApri1200 1 and served a four-year term and served as President ofthe Illinois Chapter ofthe National Brownfields Association. I was appointed as the Director ofthe lllinois EPA by Governor Rod Blagojevich in July 2005, andhave served as Chair ofthe Air Committee ofthe Environmental Council ofthe States (ECOS), the national organization ofstate environmental agency leaders.

I am pleased to be here to provide testimony onthe "three pollutant" approach and Illinois' experience in reaching agreements with our state's three largest coal-fired powerplant system
owners. My testimony will provide background information and a broad overview ofthe

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development ofillinois' multi-pollutant reduction agreements. I will address some ofthe
measures the Illinois EPA took during rule development to ensure that we relied on accurate and current information as we crafted the rule.

Illinois Multi-Pollutant Regulatory Approaches illinois is a large industrial state with a population ofabout 13 million people and a gross state product of$522 billion. Each ofthese are approximately four percent ofthe U. S. total and ranks illinois as fifth among the nation in these categories. illinois obtains more than 40 percent ofits electricity from coal-fired powerplants and sits ontop of38 billion tons ofcoal, giving it the third largest coal reserves inthe nation. Coal-fired power plants in illinois constitute the largest
source ofman-made emissions ofmercury (Hg) and sulfur dioxide 

### (S02), 

### and one ofthe largest
sources ofnitrogen oxides (NOx). illinois is horne to 2llarge coal-fired plants that operate electric generating units.

Overthe last several years in illinois, exceptional progress has been made inreducing the emissions that contribute to ozone and particulate matter (PM) air pollution, as well as reducing toxic Hg emissions that deposit into and contaminate Illinois' waters and fish. In

### particular, the illinois Environmental Protection Agency (Illinois EPA) reached landmark multi-pollutant standard agreements with the three largest coal-frred power plant systems operating in Illinois: Midwest Generation, Ameren and Dynegy. These three companies represent 88% ofillinois' 17,007 megawatts ofcoal-fired electric generating capacity and account for hundreds of thousands oftons ofair emissions each year.

·These multi-pollutant standards (MPS) are expected to result in measurable air quality improvements in illinois and also inregional air quality by dramatically reducing Hg, 

### S02, and NOx emissions from illinois' coal-frred powerplants. The agreed-to multi-pollutant standards
are one ofthe most important enviromnental and public health advances in illinois inrecent decades. Theyrepresent the largest reductions in air 

### emissions ever agreed to by individual companies in illinois under any context, whether through an enforcement action orregulation.

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

As a result ofthe knowledge and experience gained through Illinois' efforts, the lilinois EPA suppmis a comprehensive national strategy for reducing emissions ofmultiple pollutants from electric generating units. A comprehensive, integrated approach benefits both regulators and the regulated community. Multi-pollutant approaches should supplement, notreplace, the existing Clean Air Actprograms such as New Source Review (NSR), Maximum Achievable Control Technology (MACT) standards and regional haze, as well as other important statutory requirements for achieving and sustaining clean air.

In meeting emission goals, the regulated community should be afforded flexibility, where appropriate, which may include an emissions trading mechanism for NOx, and S02, 

### but not pollutants where local impacts are ofgreat concern or where concentrated emissions at a local scale may occur- as inthe case ofHg. Anymulti-pollutant strategy must also ensure that regions, states and localities retain their authority to adopt and implement measures which are
more stringent than those ofthe federal government.

A 3-pollutant approach for controlling the emissions ofHg, S02, 

### and NOx from coal-fired power plants can have numerous advantages over the traditional, single pollutant schemes. For example, a well crafted multi-pollutant standard can increase the protection ofpublic health and the environment, reduce pollution more cost-effectively, and offer greater certaintyto both industry and regulators. Since Hg emission reductions can be obtained as a "co-benefit" from the control devices used to reduce S02 

### and NOx, itmakes sense to allow companies the option to synchronize the control ofthese pollutants, provided that public health and the environment are likewise positivelyimpacted. Whereas the federal Clean Air Mercury Rule (CAMR) singlemindedly tackled mercury emissions, and the federal Clean Air 

### Interstate Rule (CAIR) addressed S02 

### andNOx, illinois was able to use a multi-pollutant strategy that accomplishes the aforementioned benefits in a unified regulatory framework accounting for planning, engineering, availability offmancing and other issues that accompany a multi-pollutant contr·ol strategy.

Illinois believes the most feasible method ofobtaining reliable emission reductions in a costeffective manner is through a combination ofemissionrate based limits along with emissions trading. Although sources under the MPS are not allowed to utilize allowances to meet the

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numeric emissions standards, sources are free to sell or trade allowances that are generated as a result ofemissions being below the allowable emissionrates. This provides an incentive for companies to go beyond the reductions required under the MPS in order to recover some ofthe costs associated with the control measures taken. Moreover, emissions' trading is recognized to provide market incentives for sources to control emissions as far and as fast as reasonably possible. Ofnote is that emissions trading under a cap and trade program has historically resulted in the highest emitting plants making the deepest reductions in emissions

- a key fmding that strongly supports the inclusion ofemissions trading into any control strategy.



### Illinois Multi-Pollutant Agreements

The catalyst for Illinois' agreements was the position taken in early 2006 that Illinois would propose an aggressive mercury regulation focused on cutting mercury emissions by 90% from coal-burning powerplants bymid-2009. After the Illinois EPApresented its findings in support ofthe mercury rule during two weeks ofwell-attended and hotly contested public hearings, the Agency was approached byAmeren who expressed a desire to work with the Agency toward
common goals. Subsequent to long hours ofnegotiation, an alternative standard was proposed that involved allowing some flexibility in complying with the mercury standards in exchange for commitments to also significantly reduce S02 

### and NOx emissions from Ameren's coal-frred powerplants. This initial agreement led to similar discussions and agreements with illinois' other two large coal burning systems, Dynegy and Midwest Generation.

The agreements reached and memorialized in the Multi-Pollutant Standard (MPS) and Combined Pollutant Standard (CPS) are significant not onlyfor the magnitude ofemissions reductions that occur, but also for the rule support that accompanied the agreements. The Illinois mercury rule
was vehemently opposed by a unified coal-frred power industry. The initial agreement established that mutual goals were achievable, set the guiding principles, and opened the door for other companies to follow -whichthey did. Ultimately, the mercuryrule was unanimously approved in 2006 by boththe Illinois Pollution Control Board and the Joint Committee on Administrative Rules, the two governing oversightbodies for regulations in illinois.

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Both the MPS and CPS provisions provide some flexibility on the timing ofmercury reductions in exchange for commitments to make significant reductions inboth S02 

### and NOx. All ofthe provisions include some level oftrading restrictions on S02 

### and NOx allowances provided under CAIR. Ameren, Dynegy and Midwest Generation will install a multitude ofpollution control equipment on their boilers costing several billion dollars, including wet and dry scrubbers, selective catalytic reduction (SCR) and selective non-catalytic reduction (SNCR) devices, and fabric filters. Recent discussions withrepresentatives ofIllinois' coal-fired powerplants indicate that they are all preparing to meet the requirements ofthe MPS and CPS, which initiate in2010. ill doing so, a wide array ofemissions control equipment costing billions ofdollars will come on-line in Illinois over the next several years. Illinois coal-frred power plants have already installed and begun operating numerous halogenated activated carbon injection (ACI) systems for mercury control. The first ofmanynew scrubbers for S02 

### control will begin operation shortly. Fabric filter controls will accompany the installation ofmany ofthe scrubbers and result in the co-benefit ofparticulate matter reductions. Selective catalytic reduction devices and other
new NOx controls are being scheduled for installation across Illinois. The shutdown ofa few of the older, most polluting electric generating units began in December 2007 with two more units scheduled for shutdown byDecember 2010.



### Illinois Mercury Rule

The illinois mercury rule is designed to achieve a high level ofmercury control, based on Illinois EPA's finding that there exists mercury control technology that is bothtechnically feasible and economicallyreasonable. Mercury emissions may be reduced through the application ofcontrol technology specifically designed to control mercury (e.g., activated carbon injection), or through co-benefit from other control technologies designed to control S02 

### NOx, and PM. Depending 

### , on several variables, including coal and boilertype, there are a number ofcontrol technologies that will achieve 90+% 

### removal ofmercury. Mercury emissions control technology is a rapidly advancing field, with halogenated sorbents being an affordable and effective option for most applications. Although there maybe some challenges to achieving 90% 

### removal ofmercury for

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all applications, in almost every case each ofthese challenges can be overcome or addressed through technology that is economicallyreasonable and available today.

The Illinois mercuryrule provides substantial flexibility in order to reduce the costs of compliance and risk ofnoncompliance for powerplants. This flexibility includes the ability to meet either a 90% 

### reduction or an outputbased standard of 0.0080 

### pounds mercury/GWh, phasing in standards over a period of3 

### Yz years with a less restrictive standard inphase one, compliance by averaging ofemissions, and the avoidance ofinstalling controls onunits that will be shutdown in the near future provided companies make an enforceable commitment to shutdown those units by a date certain.

Additional flexibility is provided via a "TemporaryTechnologyBased Standard" (TTBS) that provides relieffor units that install appropriate mercury controls but do not achieve full compliance. Eligible units onlyneed to operate the mercury controls in an optimal mannerto comply. This provision is available through June 2015 and canbe usedbyup to 25% ofa company's generating capacity.
Companies may choose to voluntarily complywiththe MPS or CPS as an alternative to the otherwise applicable requirements ofthe mercuryrule. These provisions provide additional flexibility in regards to mercury control inretmn for companies achieving significant reductions in the emissions of S02 

### and NOx.

Under the MPS and CPS, companies can commit to voluntarily meetnumerical emission standards for both NOx and S02 

### and inreturn are provided additional flexibility 

### incomplying with the mercury emission standards. The MPS and CPS provisions also containrestrictions on the trading ofNOx and S02 

### allowances providedunder CAIR. Byregulating the emissions of NOx and S02 

### and restricting the trading ofallowances, theMPS and CPS have obvious implications for the proposed CAIRNOx and S02 cap and trade program. As modeling has demonstrated, the benefits ofthese reductions will mostlyimpact Illinois and a few ofthe closest neighboring states (i.e., Indiana, Wisconsin and Missouri) with lesser benefits further downwind. While the positive impacts ofthe reductions are most significant within lllinois and its closest

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neighbors, lllinois does suppmt emissions trading as the most cost effective controls will be installed and the timing ofcontrols is likely to occur more quickly than under a command and control option.



### Emission Reductions

The combination ofthe Illinois mercuryrule, CAIR, and the MPS and CPS will have enormous positive impacts, reducing mercwy, S02 

### and NOx emissions far beyond the levels required under the federal CAMR and CAIR alone.

Under CAIR, U.S. EPA estimates that coal-fired powerproducers in illinois would only have beenrequired to reduce their 

# so2 emissions by 34%, not the estimated 76% for Ameren, 65% for Dynegy, and 80% for Midwest Generationrequired under the MPS and CPS. The emissions of NOx are likewise expected to be reduced beyond the levels obtainedbythe model CAIR. In 

### addition, boththe MPS and CPS contain trading restrictions designed to ensure that the S02 

### and NOx reductions occur in illinois.

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The reductions agreed to under the MPS and CPS for S02 

### and NOx are expected to go a long waytoward helping illinois achieve attainment ofthe ozone and PM standards. The modeling demonstrates that the emissionreductions are very substantial.

The Illinois EPA estimates the total emission reductions from all three power companies at: 

# • so2 = 233,600 tons peryear eliminated
• NOx = 61,434 tons peryear eliminated

• Mercury= 7,040 pounds peryear eliminated

Under CAMR, coal-frred power producers in Illinois would have only been required to reduce their mercury emissions by47% in 2010 and 78% by 2018, not the 90% reduction by 2009 specified in the illinois rule. The timing of mercuryreductions for

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those sources that opt-in to the MPS or CPS is essentially the same, and the amount ofreduction is expected to be close to 90%, although the companies will not be required to complywith the 90% reduction requirement on a 12 month rolling basis until2015. Sources under the MPS and CPS are expected to have mercury emission reductions that exceed the required 90% after 2015 due to the co-benefit reductions achieved from the installation ofcontrols needed to comply with the corresponding S02 

### and NOx standards.
Impacts ofEmissions Reductions



### Under the agreements between the Illinois EPA and Midwest Generation, Ameren and Dynegy, the decreases in Hg, S02, 

### and NOx emissions are estimated to far exceed the reductions required under the federal CAMR and CAlR.

In

### regards to mercury, over time lllinois expects to see reductions in deposition ofHg to Illinois' lakes and streams and corresponding mercury decreases in Illinois' fish, making those fish caught in Illinois waters safer to eat. There will be several recognized benefits to the State from tighter mercury controls beyond the expected public health benefits that come with a reduction in depositionto Illinois' waters and fish. Suchbenefits include support for existingjobs and the potential for additionaljobs resulting from the installation and operation ofadditional pollution control devices.

The benefits ofremoving S02 

### and NO, are well established and most notably will result in reductions inbothparticulate matter and ozone. S02 

### is a precursor to particulate matter and NO, is a precursor to bothparticulate matter and ozone. Particulate matter related annual benefits include fewer premature fatalities, fewer cases ofchronic bronchitis, fewer non-fatal heart attacks, fewer hospitalization admissions (for respiratory and cardiovascular disease combined) and shouldresult in fewer days ofrestricted activity due to respiratory illness and fewer work loss days. Moreover, there should be health improvements for children from reduced upper and lower respiratory illness, acute bronchitis, and asthma attacks.

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Ozone health-related benefits are expected to occur during the swmner ozone season and include fewer hospital admissions for respiratory illnesses, fewer emergency room admissions for asthma, fewer days with resllicted activity levels, and fewer days where children are absent from school due to illnesses. In 

### addition, there should be ecological and welfare benefits. Such benefits include visibility improvements; reductions in acidification inlakes, streams, and forests; reduced nutrient replenishing in water bodies; and benefits from reduced ozone levels for forests and agricultural production.



### CAMR and CAIR Vacatur Impact on lllinois Regulations:

On February 8, 2008, the United States Court ofAppeals for the District ofColumbia Circuit vacated the federal CAMR. The illinois mercury rule is separate from the federal CAMR and therefore the vacatur ofCAMRhad minimal impact onthe Illinois rule. However, this court action raised concerns regarding the status ofcertain federal provisions dealing with the monitoring ofmercury emissions. Given the uncertainty surrounding federal mercury monitoring provisions, the Illinois EPA determined that a revision to the Illinois mercury rule
was appropriate. The revisions focused onthe methods used to measure or monitor mercury emissions, and did not include any revisions to tlie control standards themselves. The rule was amended to allow a source to demonstrate compliance for a three year period using stack testing. The lllinois mercuryrule remains in full effect and all 

### illinois companies began complying with the rule on July 

### 1" ofthis year.

In

### July of2008, the U.S. Court ofAppeals for the District ofColwnbia Circuit (DC Court of Appeals) vacated the CAIRrule in its entirety. After entertaining motions for reconsideration from the parties, on December 23, 2008, the same court issued an opinion stating that the federal CAIR was remanded to U.S. EPA without vacatur. U.S. EPA subsequently confirmed that it has begun implementation ofCAIR starting January 1, 2009. illinois CAIR. is in full effect. For a nwnber ofreasons, the vacatur and reinstatement ofPhase I ofCAIRhave had minimal impact
on Illinois sources and the MPS and CPS remain in effect. However, for the reasons discussed below, Illinois strongly favors federal multi-pollutant legislation to "remedy" the flaws in CAMR and CAIR.

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The decision ofthe DC Court ofAppeals vacating CAIR in part, i.e., vacating Phase II ofCAIR but reinstating Phase I ofCAIR, has thus far had minimal impact on lilinois. CAIR Phase I required reductions up until the beginning ofCAIRPhase II in January l, 2015. Although Illinois relied upon CAIR Phase I as part ofour 8-hour ozone (85 ppb) and annual PM2.5 attainmentplans, air quality in Illinois' two 8-hour ozone (85 ppb) and annual fme particulate matter nonattainment areas has improved to a very significant degree without these expected reductions. As a result, all but one monitor is in attainment for these standards, and it is expected to be in attainment in 2012. Because the MPS and CPS result in significantreductions before 2015, Illinois is not dependent on CAIRPhase II reductions for the newest 8-hour standard (75 ppb) orthe newest daily fme particulate matter standards, and for which attairnnent plans are not yet due. Despite the improvement in air quality, Illinois would have much more significant problems in demonstrating attainment in it state implementationplanifCAIR Phase I was not reinstated.

There is some concern that lilinois coal-fired power plants may delay or cancel some controls that were being installed to complywith CAIR Phase I due to the loss ofvalue in S02 

### andNOx allowances. The market value ofthese allowances is uncertain, because there is controversy over whetherthe DC Court ofAppeal's opinionhas disallowed an emissions trading program. As a result, companies have no incentive to go beyond the reductions required by CAIRPhase I because the incentive to install controls early due to the costrecovery benefit ofthe allowances obtained is removed. Also, many companies have a significant number ofbanked allowances available for their use or for sale, and these banked allowances will be depleted rather than companies meetingthe "emissions cap" through installation and operation ofpollution control equipment, perhaps evento the extent ofnot operating existing or recently installed controls. However, we believe the MPS and CPS should keep illinois sources on track for installation and operation ofthe planned control devices and reductions.

After the vacatur ofCAIR, the Northeast and Midwest states began a process, called the "State Collaborative Process", the stated intent ofwhich was to develop a multi-pollutant strategy to achieve levels ofNOx and S02 

### reductions from the electric utility sector in the 28-state CAIR

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region as expeditiously as possible that would remedy CAIR's flaws in accordance with the Court's July 11, 2008 opinion and satisfy the requirements ofthe Clean Air Act to attain the 1997 national ambient air quality standards (NAAQS) for ozone and PM. While significant progress was made in developing a framework for a CAIRreplacement rule, no fmal recommendation to USEPA has yet been developed. The participating states disagree over the level ofreductions that should be required, whether best available controls should be required on everypower plant orjust the larger/largest units, the timing ofcontrols, whether emissions trading (or even intra-state emissions averaging) is allowable under the Court's decision, and whether a replacement rule can forestall Section 126 petitions under the Clean Air Act.

It is illinois' experience that emissions trading will result inthe greatest amount ofreductions at the lowest cost. More importantly, emission trading will encourage companies to install controls earlier, and go beyond required reduction levels, as compared to a command and control strategy. Under a command and control strategy, the regulatory compliance deadline mustbe set suchthat there is 100% assurance that every affected source will be able to comply in consideration ofthe time necessary for planning, engineering and conshuction deadlines. 

### In other words, there mustbe sufficient availability ofengineering fmns, control equipment and construction companies to plan, engineer, build and install all ofthe pollution control equipment required for compliance. Such a regulatory compliance date would certainlybe difficult to establish and likely result in far fewer reductions inthe near term when compared to an approach that includes emissions trading. Also, the construction season inmany ofthe affected CAIR states is limited to a 7 to 8 month window, when electric demand is at its highest, further complicating this approach.



### In addition to regulatory compliance deadlines, sources (and the states) must be concerned with power outages. 

### In Illinois' opinion and experience innegotiating the MPS and CPS, within the CAIR region, it is not practical (and maynot be possible) to retrofit all coal-fired powerplants of any significant size (e.g., 25 MWe or more) inthe same 3-year window (or even 5-year window). A command and control strategynecessarily sets a date certain for compliance for each affected and similarly situated source. Emissions trading will allow those time frames to be compressed,
as source by source compliance is notrequired.

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As illinois discovered dming its MPS and CPS negotiations, there are very significant costs associated with installing pollution controls ofthe magnitude negotiated under Illinois' rules

- estimated in excess of3 billon dollars. While this cost maybe seem small on a kilowatt hour basis, these companies must obtain a rate increase ifthey are in a regulated state or financing if they are in a deregulated state like illinois. The ability to obtain a rate increase or fmancing for these projects is uncertain and takes time, which must be accounted for in a compliance date for any command and control strategy. Emissions trading will allow those time frames to be compressed as well, as source by source compliance is not required.

The vacatur ofboth CAMR and CAIR emphasizes the high risk associated with moving forward with federal regulations subject to widespread opposition and controversy. Federal regulations will almost certainly be challenged, potentially resulting in further delay ofa vital strategy for the states to achieve attainment ofthe federal air quality standards. Section 126 petitions will surely also be filed by any state that believes its neighbor and upwind states could do more to address nonattainment, even ifthe complaining state's air 

### quality issues are largely a result of emissions from its own sources (area, mobile and point) and even ifthe targeted other state(s) has done mo;e to address emissions from its coal-fired powerplants than the complaining state. Section 126 petitions will use precious resources that are needed to address the newest recent daily PM2.5 standard, the revised 8-hour standard (75 ppb), the newest lead standard, and the recently-armounced, revised N02 standard. Federal multi-pollutant legislation represents the best option for addressing the points ofdisagreement among the states, without being boundby interpretations ofthe scope and flexibility providedunder the 1990 Clean Air Act amendments, and in a way that best serves the goal ofobtaining the greatest reductions in S02, 

### NOx and Hg, in the shortest possible time frame, while taking into account electric costs and reliability.



### In conclusion, the multi-pollutant approach taken in illinois for controlling the emissions ofHg, S02, 

### and NO, from coal-fired powerplants has nUlllerous advantages. Whereas the federal CAMR focuses solely on mercury emissions, and CAIR concentrates on S02 

### and NO,, lllinois' has taken a combined approach that exceeds the goals in the context ofa single regulatory framework, accommodating engineering and construction issues and outage schedules, as well as

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financing issues. The result has been a tremendous win-win-win for the environment, public health and the regulated community.ElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *Multi-PollutantStandard&CombinedPollutantStandard-RequiredEmissionsRatesand%ReductionsMidwestGenerationI,,,m1sswno euct:JonEmission%ReductionEmission%ReductionEmissionRateRateRateRate(lbs/nnnbtu),(lbs/mmbtu)(lbs/nnnbtu)(lbs/mmbtu)0,5052%201305031%OA4]3,7%2014OA1'19,6%OA356%201504534%02845,1%02576%20160,1956L8%20170.1570,6%0,2378%20180,1374,5%2019OAS34%0,II784%'02378%t:B;Annual-0,1544%0,1162%'0,1152%2012Annual-0,1255%0,1162%'0,1152%2015Seasonal---0,1151%0,1122%20121CAIRenuss10nratenumbersfrompage5oftheJune28,2005USEPApresentationtoLADCO(htlp:l/vr'\Y\Y.ladco.orglrcporls/mo/Regional%20Air%200uality/Jt:me282005/.Ttme-Workshop/CA1R%20LADC0%20.pd0.PercentreductionsfromtheUSEPAwebsitethatprovidesCAIRreductionsexpectedinIllinoisChttp://wvvw.epa.gov/cair/il.html).EmissionsusedforcalculationsarefromCleanAirMarketsDivisionsofUSEPA280%includingplannedshutdowns.368%includingplmmedshutdowns.Note:AmerenS02ratesreflectchangesloallowableratesascontainedinproposedrevisiontoIllinoismercuryrule.0,24CU90,190,100,100,10%Reduction56%65%65%48%48%25%ElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* *** *PercentMercnnReductionsft·omCAMR,IllinoisCombinedPollutantStandat·d(CPS)andMulti-PollutantStandani(MPS)Mid2008200920102011201847%are(ACIinstalledonmost90%86%90%94.4%mmercuryonmosttmits)86%93.5%2SeveralunitsatplanthavecombinationofScrubber,Baghouse,SCRand/orACIandmanyunitswillachievegreaterthan90%reductioninmercuryemissions.AllnumbersareIllinoisEPAestimates.

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EXHffiiT2



### The Shaw Group,

### EElJoppa Generating Station 

### Dry SorbentInjection TestProgram Final Report (September 24, 2010)printed 07/23/20121_38PM by Sharun.Dowson p. 1135 0212812011 5:52PM A 170000128298 127855AAC ELECTRIC ENERGY INC 101 06116/2010 1,700,089 A000324 B:84343 F:504971:00000041

o1o<l2011 uNoAKuc owsno11**EMs~'f!~l"f''t'lic** 

## Filing- Received, Clerk's Office,**£o/&~** 

### * * * * *PC# 2409 * * *

# e .T. 

# R. r :A'I 

## ,5'-(7 JASONJOH 

# &{lv(to

Electric Energy, Inc.

## fFG!L~ 

# ulNJ ©/Rjl),INJG!E

October 20, 2010



### Mr. Ray Pilapil Compliance and SystemsManagement Section Division ofAir

### Pollution Control illinois Environmental Protection Agency P.O. Box 19276 Springfield, IL 62794-9276 DearMr. Pilapil: 

# RECEIVED OCT 

# 2 2 2010

On April28, 2010 Electric Energy, Inc. (EEI} received the Construction Permit (LD. 127855AAC, Application No. 10030045) for "Pilot Evaluation ofinjection System for 802 Control". Between June 4, 2010 and June 16, 2010, EEI performed a Dry 

### SorbentInjection Testbyinjectingbothtrona and sodium bicarbonate into the flue gas ofunits 5 and 

### 6. As 

### required by Special Condition 6 ofthe above constructionpermit, I am submitting a summruy ofEEI' s Dry 

### Sorbent Injection Test. If 

### you any questions on the enclosed report, please contact Bruce Parker, Senior Engineer, at (618) 543-3458. Sincerely,

William H. Sheppard President BP Certified Mail Xc: John Justice, IEPA Collinsville Officeprinted 071"2312012 1,38PM bySharon.Dowson p. 2135 

### Electronic Filing -Received, Clerk's Office, 08/1 0/2012 

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# The 

# appearance ofsome ofthe images following this page is due to**P~or** 

# Quality Original Documents

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# notthe scanning or filming processes.

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# Com Microfilm Company (217) 525-5860prirrted 07/23/2012 1:38PM by Sh<.uon.Dowson p. 3135 

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * * 

# _-:==_-L==

· Energy, Inc.
Joppa Generating Station 

# S

# LO naw® The Shaw

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# EEI Joppa Generating Station Dry Sorbent Injection Test Program



# Final Report September 24,2010printed 0712312012 1:38PM by Sharon..Dowson P- 4135 

### Electronic Filing- Received, Clerk's Office, 08/10/2012 

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Electric Energy, Inc, Joppa Generating Station Joppa, Illinois


## 1 Introduction Final Report Dry Sorbent Injection Test Program

Electric Energy, Inc (F.F.!) commissioned The Shaw Gmup (Shaw Power ;mrl Shaw Environmental & Infrastructure, collectively Shaw) to determine whether Dry Sorbent Injection (DSI) in front ofthe existing electrostatic precipitators (ESP)s would be successful in removing 50% ormore ofthe S02 in the gas stream without detrimentally impacting the operation ofthe ESPs and fly ash handling system. The scope ofwork developedjointly by EEl and Shaw was a high level test program. It presented a l0 day test program to determine the optimum location ofDSI (before or afterthe air heaters), the condition the DSI (Trona or sodium bicarbonate) should be injected as (milled or un-milled), and the DSl rate (lbslhr needed to achieve 50% S02 remo¥al). At the completion ofparametric testing on Unit 6, Units 

### 5 and 6were tested with tlue gas testing being performed in the combined stack. This perfommnce testing wasto last up to 

### 5 days on a continuous 

### 24 hourbasis to determine:

• whether continuous SO% or better 802 reduction and continuous 90% mercUry removal canbe achieved during normal plant operations including tum down of the units due to market demands; • whether there is an impact to the air heaters (ifupstream 

### ofthe air heaters was the selected DSI point); • whether there i< an impact to the ESP from either DST reagent • whether there is an impact to the operation ofthe fly ash handling system, and; • whether there are any issues inthe handling ofDSIthat would cause undue hardship on the plant operation. 

### 1.1 Joppa 

### Station The Joppa Generating Station is a six unit coal fired power plant located at 2100 Portland Road, in Joppa Illinois. The station is located on the Ohio River. Each unit is rated for 181 MW. The plant was commissioned between 1953 and 1955. The plant is currently burning various Powder River Basin Coals. TheJoppa station is operated byElectric Energy Inc., an independent powerproducer, and is owned by Ameren (80%) and Kentucky Utilities (20%). The plant's capacity factor is historically greater than 92% inclusive ofall planned and forced outages. Nonnally, all six units are continuously operating at or near their capacity. Therefore, it is imperative that any backend environmental controls implemented at the site are robust and the designs are redundant so as to be highly reliable and not cause forced outages ofthe plant technology.printed 07123120121:38PM bySharon.Dowsonp. 5135 

## l k pf; 

## Electronic Filing

- Received, C er 's Of) ,ce, 08/10/2012 * * * * *PC# 2409 * * * * *

Electric Energy, Inc, Joppa Generating Station Joppa, Illinois Final Report Dry Sorbent Injection Test Program

Theplant is currently equipped with 

### a SO, injection systems for flue 

### gas conditioning {fly ash resistivity treatment) and activated carbon injection systems for mercury removaL (The S03 injection system was not active during this test program.) 

### 1.2 Division ofResponsibility The study was a collaborative effort among several entities. Overall direction was provided by EEl with support from Shaw, Solvay, and NolTec. The generd! Division of Responsibilities was as follows: EEl • Overall program management • Plant operations • Obtain permits I approvals from 

### IEPA •**Ob:t~.in r~agents**  and**af'ffing~** deEve.ry • Obtain experimental injection equipment and operating services • Provide plant tie-ins including injection sites, electrical powerand trailer space • Provide office space, conference room and sanitary facilities • Obtain coal and byproduct samples • Provide PIdata output Shaw (Shaw Power and Shaw E&D • Assist 

### EEl with testprogram development • Perfonn flue gas testing • Obtain laboratory analysis ofsolid media • Perform a chm:acterization study ofbyproduct materials • Provide assistance wiili overall coordination • Data analysis 

### • Draft and final reports NolTec Systems • Provide, install and demobilize 

### DSI storage, milling and injection equipment • Provide operators for their equipment • Record feed rates • Analyze reagents Solvay Chemicals • Arrange for ilie procurement and delivery ofreagents • Provide consultation on use ofreagents



### 2printed 07/2312012 1:38PM by Sharon.Dowson p. 6135**~** FR 

### Electronic Filing- Received, Clerk's OJJ'ce, 

### 08/10/2012 * * * * *PC# 2409 * * * * *

Electric Energy, Inc, Joppa Generating Station Joppa, Illinois 

## 2 Conduct ofthe Study 2.1 Experimental Design
The study objectives were:

• demonstrate 50% S02 removal using DSI • determine effect ofDSI on mercury removal Final Repo1t Dry Sorbent Injection Test Program

• determine effect on ESP perfom1ance and outlet particulate emissions and opacity • quantify any changes incertain poHutants including acid gases and sol!le metals • detennine byproduct characteristics to assist with landflll operations; and • assess the impact ofoveraH operation on plant equipment and infrastructure. The conduct ofthe study as it was performed over portions ofthree weeks is shown in Table 2-1. Some changt:s w"n' made frum the original design as the programprogressed in the field. Changes werejudged necessary given data as it was reviewed orin some cases, changes were made because it wasjudged that results would notbe meaningful. Sample point locations included the following locations: • Economizer Outlet- consisted oftwo parallel ducts (Duct A &B) each with a cross sectional area of230 square feet at the sampling location. • ESP Inlet- consisted oftwa parallel ducts (Duct A & B) each wirh a cross sectional area of230 square fe.et at the sampling location. • ESP Outlet- consisted oftwo pamllel ducts (Duct A & B) each with a cross sectional area of250 square feet at the sampling location. • Commcm#3 Tall Stack

- single annular stack with an 18 foot diameterat the sampling location. For gas samples (Hg and CEMs) selection ofthe sampling point at each location was based on first traversing each location taking flow and temperature readings and selecting the point mostrepresentative for that location. For particulates the locations were traversed during sampling (2 ports for the ESP sample locations). This sampling methodology, though not totally consistent with EPA sampling protocols, was chosen based on cost considerations andthe comparative analyses needed for this engineering study. All CEMS (e.g. Oz, COz, 

### NOx) measurements were conducted at a single point centrally located inside Duct A ofeach designated sampling location, simultaneously with each wet chemistry method (e.g. PM, Hg). Wet chemistry sampling trains were located at the common #3 Tall Stack and a single centralized location inside Duct B ofeach sampling location.

3ElectronicFiling-Received,Clerk'sOffice,08/10/2012** * **PC#2409* * * * *ElectricEnergy,Inc,JoppaGeneratingStationJoppa,IllinoisDateTestPurposeDayJune1,2,3TravelandTuesdaymobilization,SetupinjectionandtestequipmentJune41Baselinetesting.FridayJune5 2Baselinetesting.SaturdayJune73Un-milledTronaMondayinjectionJune84MilledTronaTuesdayinjectionJune9,5.MilledTronaWednesdayInjection6St;aw•Tho9>-.wOocwFinalReportDrySorbcntInjectionTestProgramTable2-1-DSITestProgram(asperformed)Units5and6-JoppaStationInjectionReagentSamplingAdditionalInformationlocationInjectedNANANANANANoneTworuns.Unit6.CEMsin/out;Testcoalat-IlbOHMin/out;PMin/out;stack·S02/MMBtu.5lbOHM,TM29,TM26A,TM8A;AC/Macf.NoDSLNoTM30B..Coal,ash,byproductS03injection.NANoneTworuns.Unit6.CEMsin/out;Testcoalat-llbOHMin/out;PMin/out;stack·S02/MMBtu. 5lbOHM,TM29,TM26A,TM8A;AC/Macf.NoDS!.NoTM30B.Coal,ash,S03injection.UpstreamofTronaThreeruns.CEMsin/out;Determineun-milledairheaterOHMin/out;PMin/outTronainjectionratefor50%reduction,UpstreamofTronaThreeruns.CEMsin/out;DeterminemilledTronaairheaterOHM.in/out;PMin/ouLinjectionratefor50%reduction.Onsitemilling.Down-TronaMorningruns.CEMs(only)DeterminemilledTronastreamofairin/outinjectionratefor50%heaterreduction.Onsitemilling.4!;;;"siElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *ElectricEnergy,Inc,JoppaGeneratingStationJoppa,IllinoisDateTestPurposeDayJune9,5Pre-milledSBCWednesdayinjectionJuneI06Pre-milledSBCThursdayinjectionJuneI1,7Pre-milledSBCFridayinjectionJune14,8Pre-milledSBCMondayinjectionJune159Pre-milledSBCTuesdayinjectionJune16,TestingterminatedWednesdayduetoUnit5tubeleakoutage.6.Sliaw"Th:ls....vOa..pFinalReportDrySorbcntlnjectionTestProgramTable2-1-DSITestProgram(asperformed)Units5and6-JoJipaStationInjectionReagentSamplingAdditionalInformationlocationInjectedDown-SBCAfternoonruns.CEMs(only)DetermineSBCinjectionstreamofairin/outratefor50%reductionheaterUpstreamofSBCThreeruns.CEMsin/out;DetermineSBCinjectionairheaterOHMin/out;PMin/out.ratefor50%reduction.AfterairSBCUnits5 &6.Threeruns.CEMsParametricstudytoheater(only)in/outdetermineS02reductionatv'!!)'il![feedrates.AfterairSBCUnits5 &6.Thrceruns.CEMsDetermineSBCinjectionheater(only)in/out(stackCEMs)ratefor50%reduction,twounitinjections.AfterairSBCThreeruns.Unit5&6.CEMsheaterin/out;OHMin/out;PMin/out;stack-OHM,TM29,TM26A,TM8A;TM30B.TM5and202;Coal,ash,byproduct(5x5gallons).---•---55N'""0iprinted 07/23!20121:38PM by Sharon.Dowson p. 9135 

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * 

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Electric Energy, Inc, Joppa Generating Station Joppa, Illinois Final Report Dry Sorbent T njection Test Program


### 2.2 Reagent Characteristics 2.2.1 Trona
Trona is derived from sodium sesquicarbonate rock. Its formula is Na2C03.NaHC03.2H20. The rock is typically milled and delivered at a fmeness of30- 35 microns. Typical moisture ofdelivered product is 0.03%. (SOLVAY, 2010). Delivery sheets are found in Attachment 5. Trona materials were secured from Solvay Chemicals, Inc, Houston, Texas. The product is identified as: SOLVAir Select 2.00 BULK (Material Code 60 178). Customer Specification Number is SS200-0108. Characteristics ofTrona as delivered comes from truck invoices, as fnllows:
T hi 1**~** T r'h n ,. 

# .. -2 _e - - rn,nQ .,_,.. ..., ....,. .._, ...... "

...,•**.,._-~** -**~** ..**-..~-..._..._..__**• .,..._...,.,..,&..**..._.o.....:ou..~...,.V.I.I."l,..11!o.-U** Rail Car ACFX045644- Two loads reported Result Unit Minimum Maximum Wet Trona 97.3 % 95.0 Free Moisture 0.02 % 0.07 D(50) 31 Micron 46 +70 Micron 27 % Rail CarACFX05I25 I -Two loads reported Result Unit Minimum Maximum Wet Trona 97.6 % 95.0 FreeMoisture 0.03 % 

### O.o7 0{50) 39 Micron 46 +70Micron 

### 32 % Rail Car SHPX450385- One load reported Result Unit Minimum Maximum Wet Trona 96.9 % 95.0 Free Moisture O.D2 % O.G7 D(50) 41 Micron 46 +70 Micron 33 % Rail Car ACFX045451- One load reported Result Unit Minimum Maximum Wet Trona 97.8 % 95.0 Free Moisture 0.02 % 0.07 0(50) 46 Micron 46 +70 Micron 

### 36 %

6printed 07123120121:3BPMbySharon.Dowsonp.10135 

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Electric Energy, Inc, Joppa Generating Station Joppa, Illinois Final Repon Dry Sorbent Injection Test Program

On certain days, onsite milled Trona was used for injection. Particle size analysis was conducted by Sturtevant from samples provided by No!Tec. Laboratory data are provided in Attaclunent 5. The "as delivered" Trona had a D50 of39 microns. The milled Trona had a measured D50 of26 microns. 

### 2.2.2 Sodium Bicarbonate (SBC) Sodium bicarbonate is a downstream product made from Trona. Its formula is NaHC03. Pre-milled materials are delivered at Dgo of< 40 microns. In literature, Solvay recommends onsite milling to <20 microns prior to injection (Solvay, 2010. Dry Sorbent Injection ofSodium Sorbents. Emissions Control and Measurement Workshop. March 24-25, 20I0). The pre-milled SBC materials were secured from Solvay Chemicals, Inc, Houston, Texas. The product is identified as: BIR SOLVAIR SELECT 350 HNM BULK (Solvay Material Code 65591) also known as SOLVAIR 350 BULK. The trucks delivering the product were loaded from bnlk bags which had been storing the pre-milled SBC. Material Certifications provided wjth each delivery had descriptionsCustomer Material Specification: Sodium,as Na >= 27.00% Sodium Bicarbonate, as NaHC03 

## =99.0- 100.50% Screen Analysis % Retained

... US 200 (75 micron) 20- 100% US 325% (45 micron) 60- 100% It should be noted that much ofthe delivered SBC had clumps ofmaterial within the delivered bulk causing unloading problems. These clumping and unloading problems were not seen with d1e delivered un-milled Trona. Certifications are provided in Attachment 5. 

### 2.3 No/Tee DSI Feed Equipment
The DSI system was "Sorb-N-Ject" provided by NolTec Systems, Lino Lakes, MN. (Drawings and additional information on the NolTec provided system can be found in Attachment 3.) The system had one portable free standing storage silo. The silo capacity was 1450 cu

### ft. The silo had load cells for monitoring weight loss ofmaterials. Weight Joss as a function oftime was used 

### in the field to quantify the feed rate; When filling, a bin vent filter controlled dust !Tom displaced air and material transpolt air. Feed was controlled by dual-speed adjustable rotary feeders. The silo was filled, as needed, by bulk carrier trucks. Trucks generally contained 45,000

- 50,000 pounds ofmaterial. Silo fill time was about one hour when there was no reagent clumping.



### 7**p~nled** 0712312012 1:38PM by Sharon.Dowson p. 11135 

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * 

## * * * *PC# 2409 

## * * 

## * * *

Electric Energy, Inc, Joppa Generating Station Joppa, !llinois Final Report Dry Sorbent Injection Test Program

A portable blower trailer was also provided. The design capacity ofthe sorbent feed system was 20,000 lbfhr. The blowers were positive displacement rotary blowers driven by 

### a 40 HP motor. Each blower was capable 

### ofproviding 500 scfm 

### at 11.5 psig. The system included a heat exchanger, conveying piping and injection lances. The trailer also housed control and electric supply equipmenr and operator space. The in-line milling system was designed for use with Trona. The Sturtevant Sirnpactor was a centrifugal, pin-type impact mill. The system had dual plate rotor with one row of pms. NolTec provided lances were insened above the air heater (one unit) and below the air heater (two units). They were straight pipes with flat, cutoffends. Lances were inserted at staggered lengths before the air heater. Lances after the airheater were all the same ·length. 

### 2.4 Coal During the performance ofthe test program, tl1e plantbumed two Powder River Basin (PRB) coals; East Thunder (Jacobs Ranch) and Belle Ayr. The significant difference between these two coals was sulfur content with the Jacobs Ranch coat having almost twice the sulfur content with 1.07 lbs/MMBtu S02 versus 0.58 lb/MMBtu S02 for the Belle Ayr coal. The mercury concentration in the Jacobs Ranch coal was also higher. Table 2-3 presents the analyses ofthe daily samples ofthe coals. It should be noted that for coal utilization, the daily sample was taken from the

.

8ElectricEnergy,Inc,JoppaGeneratingStationJoppa,lllinoisCoalSampleBtullbSourcedayJacobs6/21108420RanchJacobs6/31109150RanchJacobs6/4/108420RanchJacobs6/5/108370RanchJacobs6/6/108710RanchJacobs617/108630RanchJacobs6/81107840RanchJacobs619/108390RanchJocobs6/10/108470RanchJacobs6/11/1084.30RanchComb-6/121108390ination?BelleAyr6/]3/108380'll•o!!hwG<t>..!JElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *Table2-3-CoalAnalysesResnltsAshAsh·sso2Cllb/lblAsBaMMBto%MMBtu%jlJl_m_]Jp_m5.967.080.481.140.023.013026.797.420.491.070.022.48.3075.856.950.51.190.01<2308__:_5.56.570.481.150.02<23155.646.480.441.010.02<23005.76.600.491.140.012.213445.176.590.350.890.01<237767.150.431.03.0.02<23215.636.650.451.060.02<23115.796.870.451.070.02<23305.025.980.360.86<0.01<23075.046.010.240.57<0,01<2355-9CdCrppmppm<I6_65<I6.5<I6.21<I6.0<I5.91<I5.92<I6_54<I6.38<I6.24<I5.9<l5.52<I4.94----FinalReportDrySorbentInjectionTestProgramHgHgPbSeAglb/_]lllmppmppmppmTBtu3_16<21.50.12915.322.43<21.50.09710.602.14<21.490-09811.643.2<21.470.09911.831.65<21.80.11112.742.29<21.680.0819.392.61<21.590.13116.712.27<21.460.10312.282.72<21.270.11313.342.49<21.70.16419.452.05<21.420.15118.001.66<21.40.08510.14iI""f0!gElectricEnergy,Inc,JoppaGeneratingStationJoppa,IllinoisCoalSampleBtu/lbSourcedayBelle6/141108350AyrBelle6/15/108510AyrJacobs8483RanchBelle8413AyrPercentBelleAyrof99.18JacobsRanch•TI!CJSl<tN0rco..pII107ElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *Table2-3-CoalAnalysesResultsAshAshsso2Cllb/lb/AsBa%MMBtu%MMBtu%ppmppm5.116.120.230.550.02<2.319-4.595.390.260.610.01<2.295Avcra1es5.806.840.461.070.017<2..173224.915.840.240.58<0.0!3<2.32384.785.553.453.8476.4792.2100.510CdCrppmppm<I4.63<I4.31<I6.23<I4.6310074.3FinalReportDrySorbcnllnjcctionTestProgramHgHgPbSeAglb/ppmppmppmppmTBtu1.72<21.620.0839.942.19<2\,420.0718.342.50<2.1.550.1!313.271,86<2.1.480.0809.4774.410095.770.7571.34-!;;w•rrg0I*printed 07!23!2012 1:38PM by Sharon. DolliSon p. 14135 

### Electronic Filing- Received, Clerk's Office, 08/10/2012 

## * * * * *PC# 2409 

## * * 

## * * *

Electric Energy, Inc, Joppa Generating Station Joppa, Illinois 

## 3 Test Program Results Final Report Dry Sorbent Injection Test Program

The experimental design for the program is described in Section 2.1. The program considered two reagents, Trona and Sodium Bicarbonate (SBC). Trona was injected into duct work at as delivered particle size and after onsite milling. SBC was injected as received. SBC was milled prior to shipping to the site. However, there was some clumping ofthe SBC in the bulk delivery vehicles. Trona was injected both upstream (un-milled and milled) and downstream (milled) ofthe air heater (AH). SBC was also injected both upstream and downstream ofthe airheater. The feed rates ofthe OS! were varied throughout the test program with the general intent to achieve 

### 50% SO, removal and 

### to determine DSI utilization trends versus 

### S02 removal. Table 3-l provides the average DSI feed 

### rates used throughout the tests. These average feed rates are based 

### on the No!Tec DSI storage silo load cell readings which are provided in Attachment 6. It should be noted that during some ofthe test runs DSI was added to the storage silo resulting in unusable load cell readings. During these occasions rotary feeder speeds were used to estimate average DSI rates based on available data near the time ofthe silo feeding event.

I IElectricEnergy,Inc,JoppaOeneratingStationJoppa,IllinoisStartDateRuntime4-Jun5-Jun7-JunI12:007-Jun215:157-Jun318:008-JunI9:458-Jun212:298-Jun315:219-JunI10:529-Jun215:27I0-JunI10:00I0-Jun212:456Sliaw·n..,a-Clrl:>.vElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* *** *FinalReportDrySorbcntInjectionTestProgramTable3-1-AverageDrySorbcntInjectionRatesP•lrTestEventEndInjectionAverageInjectionDSIRateCommentsTimeLocation.(LB!HrJNoneNANABa!ielineTestingNoneNANABaselineTesting13:00UnmilledBeforeairheater5,971Trona-Unit617:00UnmilledBeforeairheater11,659Trona-Unit618:34UnmilledBeforeairheater10,219Trona-Unit610:47MilledTronaBeforeairheater8,838-Unit613:35MiliedTronaBeforeairheater8,561-Unit616:21MilledTronaBeforeairheater8,688-Unit612:31MilledTronaAfterairheater14,237-Unit616:00Pre-milledAfterairheater11,643SBC-Unit611:03Pre-milledBeforeairheater7,733SBC-Unit613:50Pre-milledBeforeairheater7,275SBC-Unit612[!"0m0I"ElectricEnergy,Inc,JoppaGeneratingStationJoppa,IllinoisDateRunStarttime10-Jun315:20ll-JunII1:2311-Jun212:1411-Jun316:1414-JunI9:5314-Jun213:0515-JunI8:50IS.lun212:1515-Jun314:596SHaw·'0'"ettru1reElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *FinalReportDrySorbcntInjectionTestProgramTable3-1·AverageDrySorbentInjectionRatesPerTestEventEndDSIInjectionAveragelnj•:dionTimeLocationRateComments(LB/Hr)16:27Pre-milledBeforeairheaterSBCUnit66,921II:52l'rc-milledAfterairheater-SBCUnits5and65,882Pre•milledAfterairheater-13:31SBCUnits5and6ll,07717:31Pre-milledAfterairheater-addedtosiloduringtest,usageSBCUnits5and614,665estimateswerebasedonfeedvalvespeed12:38Pre-milledAfterairheater-SBCaddedtosiloduringtest,usageSBCUnits5and69,284estimateswerebasedonfeedvalvespeed17:07Pre-milledAfterairheater-addedtosiloduringtest,SBCUnits5and69,683estimateswerebasedonfeedvalvespeed9:50Pre-milledAfterairheater-addedtosiloduringtest,usageSBCUnits5and610,200esllmateswerebasedonfeedvalvespeed13!33Pre-milledAfterairheater-SBCUnits5and69,95616!08Pre-milledAfterairheater-SBCUnits5and6I0,43813u,[!"us.ilg0Iuprfnted 07123/20121:36PM by Sharon.Dowson p. 17/35 

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Electric Energy, lnc, Joppa Generating Station Joppa, Illinois


### 3.1 Air Emissions Test Results Final Repon Dry Sorbent Injection Test Program

This section presents surnmaiY results 

### ofair emissions test data. Details 

### ofthe tests performed are found in A!tachment I. The plant's S03 injection 

### flue gas conditioning system was taken out ofservice for all tests. Trona, like S03, is also used to increase the conductivity offly ash for removal 

### in ESPs. Trona would also remove the SO, beforeit would be effective. The plant's PAC injection mercury control system remained in operation. PAC was injected at a minimum of

### 5 lb ofPAC/mmacf. At the time ofthe 

### OS! Test Program, PAC was injected upstream ofthe air heaters on Units 

### 5 and6. Plant PI data records were secured during all tests to document plant loads and performance during the test date. 

### 3.1.1 Baseline program The purpose ofthe base line program was to document emissions and plant operating characteristics prior to reagent injections. Theresults from the test il\iections are compared to the baseline as appropriate. Baseline testing occurred June 4 and 5. Two test runs were performed on each ofthe two days. The plant was burning Powder River Basin (PRB) coal with approximate 0.9 to 1.2 lb SOz/MMBtu content (East Thunder- Jacobs Ranch ccal). This 

### is asomewhat higher sulfur content than what the plant normally fires. At Unit 

### 5, particulate and mercurywere measured before the ESP. At Unit 6, SOl, mercury and particulate were measured before the ESP and particulate, mercury, SO;, after the ESP. At the combined stack, particulate, mercury, metals, acid gases and S03 were measured. Coal was sampled during baseline testing and a five gallon ash sample was secured for comparison to mixed ash/spent reagent Plant PI data records were secured during all tests to document plant loads and performance during testing. Summary 

### S02 data are shown in Table 

### 3-2. The valuespresented are the averages of four runs taken over two days. Table 

### 3-2- Baseline Summary S02Data June 

### 4-5,2010 Measurement 

### Unit Value SO, (Unit6 , Economizer Outlet Lb!hr 1701.95 

## so1 (Unit6 , Economtzer Outlet Lb/MM:Stu 0.980 

# so2 (Unit6 , ESP Outlet Lb!hr 

### 1652.87 S02 (Unit 6), ESP Outlet Lb/MMBtu 0.958

14printed 07!23!20121 :38PM by Sharon.Dowson p. 19135 

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Electric Energy, Inc, Joppa Generating Station Joppa, Illinois Final Report Dry Sorbent Injection Test Program

These results were compared to 

### the #3 Tall Stack (units 

### 5 and 6) CEMs data for confirmation. The average 

### S02 emission from #3 Tall Stack during these test runs was 3,756lblhrorbased on the assumption that emissions from Unit 5 equal Unit 6 the emission from Unit 6 would be J,878lblhr or about 12% higher than what was read at the ESP outlet The difference in the results is likely the result ofnon-uniformed sampling in the duct due to stratification ofthe flue gas path. Because ofthis apparent bias between CEMs readings a decision was made to compare sulfur dioxide removal against the stack CEMs readings. · Particulate matter emissions data are shown in Table 3-3. The valuespresented are the averages offour runs taken over two days. Data indicate overall ESP efficiency of98.88 percent. Theremoval efficiency is used in comparing baseline operation with operation during DSI.**J'ab-1~3-3-** 

### Base!!ne Summ2:·y**Partieu!u~c ~1~ttc:-**  

### Data June 4-5 2010 Measurement Unit Value ESP 1nlct (Unit 5 & 6) Lblhr 13,685 Combined Outlet Lblhr 152.87 Removal Efficiency Percent 98.88 Total mercury emissions data are shown in Table 3-4. The values presented ate the averages offour runs taken over two days for#3 Tall Stack (units 5 and 6). Data indicate overall removal efficiency of93 percent (based on coal mercury concentration) using the plant's installed PAC injection system. The removal efficiency is used in comparing baseline operation with operation during DSI. Table3-4- BaselineSummary Mercury (Total)Data June 4-5,21110 Measurement 

### Unit Value Coal Lblhr 0.0468 Coal LbffBtu 11.22 Stack Lblhr 0.0033 Stack LbffBtu 0.97 Removal Efficiency Percent 93 

### 3.1.2 Trona, Un-milled Upstream of the Air Heater Thepurpose ofthis program segment was to document emissions and plant operating characteristicsinjecting un-milled (D50 of39microns) (notmilled onsite) Trona upstream. of

### the AH. The Trona size analysis is shown in Section 2.2. The test occurred on 7 June. Three test runs were performed on the test date. Theplant was burning coal from the East Thunder (Jacobs Ranch) mine with an approximate 0.9- 1.2 lb 

### S0 2fMMBtu content. During the performance ofthe tests one ofthe DSI blowers

15printed 07/23/20121:38PM by Sharon.Dowson p 19!35 

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Electric Energy, Inc, Joppa Generating Station Joppa. Illinois Final Report Dry Sorbent Injection Test Program
tripped on overheat for about 20 minutes (15:35- 15:55) which reduced the injection of Trona by one/halffor that period .oftime. Attachment 3 shows the arrangement ofthe NolTec injection equipment and lances into the plant ductwork. In accordance with the test program no measurements were made on Unit 5. On Un.it6, S02 and mercury were measured at the economizer outlet "before injection". Particulate matter (TMS) was measured beforethe ESP and fine particulate (PM 1 oand PMz.s), mercury and S02 after the ESP. Coal was sampled !he day/night before as it was being loaded into the coalbunkers by the autosampler located on the 33 conveyor. Summary S02 data are shown in Table 3-5. Un-milled Trona was injected from 8:45 to 18:55 at varying rates (-3,000- > 13,000 lb/hr). The Trona injection information was comparect to the**Sta~k** CEMs data to discern 2 tre!ld. The Unit 6 S02 Concentration before DSI was estimated based on the S02 concentration in the stackbefore and after DSI with one halfof!he S02assumed to come from Unit 6. The results were graphed and are shown in Figure 3-1. 

## Un-milled Trona Utilization • • y;-0.1216x 1 0.1559 

## Injected Before Atr heater**R'~o.17&s** 0.3 

## ,------------------ - - G,25

---**-··---------~..----·----·------~---** ·$>**~-------~·-** 0.2 

# • 0.15 

# • • 1--------·--

-- --- + -- -- -----;:-=--------

## -~ 4

.

## ·~ •

### 1-----~**$9~"'** 

## . .. (>:;; i () ¢**~** 0.1

0.00% 10.00% ZO.OO% 30.00% 40.00% 50.00% 60DO% 70;00% Pe..-centSOl Rernoval 

### Figure 3-1- 

### Unmilled Trona Injection Utilization The resuJts indicate an overall removal efficiency range of 13

- 59% percent and with an efficiency ratio of0.093 lb 

### S02 removed perlb ofsorbent injected at 50% 

### S02 removal. 

# 6. Sliaiiii•**U109aw~re'** 16printed 07123120121:38PM by Sharon.Dowson P- 20135 

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Electric Energy, Inc, Joppa Generating Station Joppa, Illinois final Report Dry Sorbent Injection Test Program

Table 3-5

- Summary S02 Data, Un-milled Trona Injection Upstream ofAir Heater June 7, 2010 Measurement Unit Value Average S02 Units 5 and 6 Before Lb/hr 3786 DS Injection during test Average S02 (Unit 6), before DSI Lb/hr !893 Maximum Removal Efficiency Seen Percent 

### 59 Lb S02Removed!Lb Sorbent at 50% Ratio 0.093 removal Ton Tronai Ton SQ Removed at Ratio 10.75 50% removal Sl..!rrLTTiary partk!.!late m.E!.nef'**emi~£iof1..s** dam are shown in T.e.b!e 3-6. The valuesp!"esented are tbe averages ofthree one-hourruns. Data indicate overall ESP efficiency of99.44 percent, somewhatbetter than tbe baseline efficiency. Table3-6- Summary Particulate Matter Data, Un-milled Trona Injection Upstream ofAir Heater June 7, 2010 Measurement Unit Value ESP Inlet (Unit 6) Lblhr 15,062 ESP Outlet Lblhr 84.70 Removal Efficiency Percent 99.44 Total mercury emissions data are shown in Table 3-7. Thevalues presented are the averages ofthree runs: Calculations, discussed in Attachment l, indicate overall removal efficiency of 87.7percent (based on coal mercU!)' ccncentration). This removal efficiency is not necessarily comparable to the baseline since this is based. on Unit 6 only and a comparison requires the assumption that unit 6 equals Unit 5 in emissions. Table 3-7- Summary Mercury (Total) Data, Un-milled Trona Injection Upstream ofAir Heater Juue7, 2010 Measurement Unit Value Coal Lblhr 0.0223 Coal 

### Lb/TBtu 9.4 ESP Outlet Unit 6 Lblhr 

## I

. 0.00273 ESP OutletUnit 6 LbiTBtu 

## I Removal Efficiency Percent 87.7

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### 3.1.3 Trona, Milled Upstream of the Air heater Thepurpose ofthis program segment was to document emissions and plant operating characteristics injecting milled (D50 of26 microns) (milled on site) Trona upstream of the AH. Laboratory 

### size analysis for the milled Trona can be found in Attachment 5. The test occurred on 8 June. Milled Trona was injected from 9:10 to 16:40 at an average uniform rate ofabout 8600 lb/hr. The plant was burning coal from the East Thunder (Jacobs Ranch) mine with an approximal" 

### 0.9- 1.2 lb S02 /lv1MBtu content Attachment 3 shows the arrangement ofthe NolTec injection equipment and lances into the plant ductwork. In accordance with the test program no measurements were taken on Unit 5. On Unit 6, S02 and mercury were measured at the economizer outlet "before injection". Particulate mailer (TM5) was measured before the ESP and fine particulate (PM 10 and PM2,j, mercury and S(h afterthe ESP. Coal was sampled the day/night before as it was being loaded into the coal bunkers by the autosampler located on the 33 conveyor. Summary SOz data are shown in Table 3-8. The Trona injection information was compared to the Stack CEMs data. The Unit 6 S02concentration before DSI was estimated based on the S(h concentration in the stackbefore and afterDSI with one half ofthe S02assumed to come from Unit 6. The values presented are the average ofthe injection throughout the day. The values indicate anoverall removal efficiency of52.6 percent and with an efficiency ratio ofO.lO lb S02 removed perlb ofsorbent injected. The ratio shows an improvement in.removal efficiency over un-milled Trona.

Table 3-8, Summary S02 Data, Milled Trona Injection Upstream ofAir Healer June 8, 2010 Measurement Unit Value Average SCh Units 5 and 6Before Lbfhr 3273 OS Injection during test Average S02 (Unit 6), before DSI Lb!hr 1637 Removal Efficiency Percent 52.6 Lb S02 Removed/Lb Sorbent Ratio 0.10 Ton Tronaffon S02 Removed Ratio 10 Summary particulate matter emissions data are shown in Table 3-9. The values presented are the averages ofthree one-hourruns. Data indicate overall ESP efficiency of98.68 percent, not quite as good as the baseline efficiency or that for un-milled Trona.

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Table3-9

- Summary Particulate MatterData, Milled Trona Injection Upstream ofAir Heater June 

### 8, 2010 Measurement Unit Value ESP Inlet (Unit 6) Lblhr 12 774 ESP Outlet Lblhr 168.09 Removal Efficiency Percent 98.68 Total mercury emissions data are shown inTable 3-10. The values presented are the averages ofthree runs. Calculations, discussed in Attachment 

### I, indicate overall removal efficiency of84.1 percent (based on coal mercury concentration). This removal efficiency is not necessarily comparable to the baseline since this is based on Unit 

### 6only and a comparison requires the assumption that unit 

### 6equals Unit 

### 5 in emissions

.. Table 3·10 • Summalj' Mercury (Total) Data, Milled Trona Injection Upstream of Air Heater June 

### 8, 2010 Measurement Unit Value Coal Lblhr 0.0387 Coal Lb!fBtu 16,7 ESP Outlet Unit 6 Lblhr 0.00615 ESP Outlet Vnit 

### 6 LbffBtu 

### 3.8 Removal Efficienc)' Percent 84.1 

### 3.1.4 Trona, Milled Downstream ofthe Air Heater Thepurpose ofthis program segment was to document tbe

### S02 emissions and plant operating characteristics injecting milled (DSO of26microns) (milled on site) Trona downstream ofthe AH. The test occurred on morning of9 June. Milled Trona wasinjected 

### from 8:50 to 12:30 at an average injectionrate of 14,493 lblhr once the injection rate was stabilized. The plant was burning coal from the East Thunder (Jacobs Ranch) mine with an approxnnate 

### 0.9- 1.2 lb S02 /MMBtu content. Attachment 3 shows the arrangement ofthe

..No!Tec injection equipmentand lances into the plant ductwork. In accordance with the test program no measurements were taken on Unit 5. On Unit 6, 

### S02was measured at the economizer outlet "before injection", and after the ESP. Coal was sampled during testing, Summary S02 data are shown in Table 3-11. The Trona injection infonnation was compared to the Stack CEMs data. The Unit 6 S02 concentration before DSI was

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estimated based on the S02 concentration in the stackbefore and after DSI with one half ofthe S02assumed to come from Unit 6. The values presented are from the morning run. The values indicate an average removal efficiency of42.6 percent and with an efficiency ratio of0.049lb S02 removed per lb ofsorbent injected. The ratio shows this scenario, injecting downstream ofthe AH, to be the least efficient ofthe Trona test altematives. Table 

### 3-11- Summary 

### 802 Data, Milled Trona Injection Downstream ofAir Heater June 9, 2010 Measurement Unit Value Average S02 Units 5 and 6 Before Lb/hr 3,339 DS Injection during test Average SO, (Unit 6), before DSI Lbt1u 

### I 1Ji70 Removal Efficiency_ Percent 42.6 Lb SO,Removed/Lb Sorbent Ratio 0.049 TonTrona/Ton SO, Removed Ratio 20.4 Itwas anticipated that this test scenario would be no be better, and probably worse than

· the injection before the AH due to the lower temperature ofthe flue gas. Thus no

additional parameters were sampled. This was a CEMs only test. 

### 3.1.5 Sodium Bicarbonate Downstream of the Air Heater The purpose ofthis program segmentwas to document the S01 emissions and plant operating characteristics injecting SBC downstream ofthe AH. The test occurred on afternoon of9 June. SBC was injected from 14:40 to 16:00 with the feed rate ramping up from about 7000 lbt1u up to 11,750 lbt1u. 

### The plantwas burning coal from the East Thunder (Jacobs Ranch) mine withan approximate 0.9- 1.2lb SOz/MMBtu content. Attaclunent 

### 3. shows the arrangement ofthe No!Tec injection equipment and lances into the plant ductwork.
In accordance with the test program no measurements were taken on Unit 5. On Unit 6, 

### S02was measured at the economizer outlet "before injection"and afterthe ESP. Coal was sampled during testing. Summary 

### S01 data are shown in Table 3-12. TheSBC injection infonnation was compared to the StackCEMs data. The Unit 6 S02 concentration before DSI was estimated based on the S02 concentrationin the stack before and after DSI with one half ofthe SOzassumed to come from Unit 

### 6. The results. indicate an overall removal efficiency of60 percent and with an efficiency ratio of0.0841b S02 removed per lb of

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sorbent injected. Theratio and removal efficiency values were basedon average 

### J 1,750 lb/hr reagent injection. Table 3-12- Summary 

### S0 1 Data, SBC Injection Dovmstream ofAir Heater June 9, 2010 M.easuremenl Unit Value Average S02 Units 

### 5 and 6 Before Lb/hr 3,288 DS Injection during test Average S02 (Unit 6), before DSI Lblhr 1,644 Removal Efficiency @II,750 lb/hr Percent 60 feed rate Lb S02Removed!Lb Sorbent Ratio 0.084 Ton SBC!Ton S01 Removed Ratio 11.9 

### 3.1.6 Sodium Bicarbonate Upstream of the Air Heater Testing The pmpose ofthis program segment was to document emissions andplant operating characteristics injecting SBC upstream ofthe AH. The test occurred on 10 June. SBC was injected from 8:30 to 16:55 atan average injection rate of7,380 lblhr The plant was burning coal with an approximate 

### 0.9- 1.2lb S02/MMBtu content Attachment 3 shows the arrangement oftheNo!Tec injection equipment and lances into the plant ductwork. In accordance with the test program no measurements were taken on Unit 

### 5. On Unit6, S02 and mercury weremeasured at the economizer outlet "before injection". Particulate matter (TM5) was measured before the ESP and fine particulate (PM 10 and PM2

### .s), mercury and S02 afterthe ESP. Coal was sampled during testing. Summary SOz 

### data are shown Table 3-13. The SBC injectioninformation was compared to the Stack CEMs data. The Unit 6 S02 concentration before DSI was estimated based on the SOz concentration in the stack before and after DSI with one halfofthe SOz assumed to come from Unit 6. The results indicate an average removal efficiency of 67.1 percentand with an efficiency ratio of0.158 lb S02 removed perlb ofsorbent injected. The ratio shows an improvement in removal efficiency overTrona and SBC injection after the air heater.

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### Table 3-13- Summary 

### S01 Data, 

### SBC Injection Upstream of

### Air Heater 

# r.:- June 

### 10 2010

Measurement Unit Value Average 

### S02 Units 

### 5 and 

### 6 Before Lbllu 3,474 

### DS Injection during test Average**S~** (Unit 

### 6), before 

### DSI Lbllu 1,737 Removal Efficiency Percent 67.1 Lb 

### S02 Removed!Lb Sorbent Ratio 0.158 Ton SBC!ron S02 Removed Ratio 

### 633 Summary particulate matteremissions data arc shown Table 3-14. The values presented are the averages ofthree one-hour runs. Dataindicate overall ESP efficiency of97.80 percent, not quite as good as the baseline efficiency.

TableJ-14- Summary Particulate MatterData, SBC Injection Upstream 

### ofAir Heater June 

### !0,2010 Measurement 

### Unit Value ESP Inlet (Unit 6) Lblhr 

### 10,401 .ESP Outlet Lblhr 228.96 Removal Efficiency_ Percent 97.80 Total mercury emissions data are shownTable 3-15. The values presented are the averages ofthree runs. Data indicate overall removal effiCiency of85.8 percent (based on coal mercury concentration. This removal efficiency is not necessarily comparable to the baseline since this isbased on Unit 6 only and a comparison requires the**a~sumption** that Unit 6 equals Unit 5 in emissions. Table 

### 3-15- Summary Mercury {Total) Data, 

### SBC Injection Upstream 

### ofAir Heater June 

### 10,2010 Measurement 

### Unit Value Coal Lblhr 0.0321 Coal LbfTBtu 16.7 ESP Outlet Unit 6 Lbllu 0.00455 ESP Outlet Unit 6 LbfTBtu 2.33 Removal Efficiency Percent 85.8 

### 3.1.7 Sodium Bicarbonate Downstream of the Air 

### Heater Parametric Testing T\le purpose 

### ofthis program segment was 

### to document emissions and plant operating characteristics injecting SBC downstream ofthe AH. The amount ofSBC added

### was adjusted throughoutthe day 

### (9:10- 19:35) to obtain 

### a trend between 

### S02 removal and

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SBC injected. The SBC was added to both Units 

### 5 and 6 from 3500 to about 16,000 lbslhr (or from 1,750- about 8,000 lblhr/unit) Thetest occurred on 11 June. The plant was burning coal from the East Thunder (Jacobs Ranch) mine with an approximate 

### 0.9- 1.2 lb S02fMMBru content. During the performance ofthe tests both units 5 and 6 had temporary coal feeder issues that resulted in temporary minor reductions in plant output. Attachment 3 shows the arrangement ofthe NolTec injection equipment and lances into the plant ductwork. In accordance with the testprogram no measurements were taken on Unit 5. On Unit 6, 502 was measured atthe economizer outlet "before injection"and after the ESP. Coal was sampled during testing. The SBC injection information was compared to the Stack CEMs data to discern a trend. The Unit 5 and 6 502 amount before DSI was estimated based on the S02 concentration in the stack before and after DSI. The results were graphed and are shown inFigure 3-2. 

## SBC Utilization 

## I . . Aft h. A" H j'=·O.l971x• 0.2199 

## njectlon er t 

## e 1r 

## eater R'=o.zm



## ., 0.3 

# r .!! v 0.25**~** 

### E u 

### "' 0.2 

# I "' 0**~** 0.15**~** 

## ., c. 0.1 

# , ., il**0..0~** E ___,._ _ ___§_**~** 0 l!! N 0 0 

## "'**~** 0.00% 

# ... 40;00% 10.00% 20.00% 30.00% 50.00% 60.00%**~** Percent·so:z Removed
Figure 3·2

- SBC Utilization, Injection After the Air Heater Summary 502 data are shown Table 3-16. The removal efficiency range of 16

- 53 percent was seen and with an efficiency ratio of0.12llb S02 removedper lb ofsorhent injected at 50% 

### 802 removal.

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Table 3-16- Summary S02 Data, SBC Injection Downstream ofAir Heater Units 

### 5 and 

### 6, June 

### 11 2010 Measurement Unit Value Average S02 Before DS Injection Lblhr 19833 during test Maximum Removal Efficiency Seen Percent 

### 53 Lb S02 Removed/Lb Sorbent at 50% Ratio 0.121 S02 removal Ton SBCtron S02 Removed Ratio 8.26 

### 3.1.8 Sodium Bicarbonate Downstream of the Air Heater Units 5 and 6 Steady State Testing Thepurpose ofthis program segment was to document emissions and plantoperating characteristics injecting SBC downstream ofthe AHon a continuous basis. The test occurred on 14June. The plant was burning coalfrom the Belle Ayr mine with an approximate 0.6 Ib S02/MMBtu content. This is a coal with a lower sulfurcontent than what the plant was burning during earlier test days. SBC was injected into both Units 

### 5 and 6 from 10:00- into June 15 at an average injection rate of9,9EO lblhr after initial ramp up. The operation ofthe ESPs were impacted by the combination ofthe Belle Ayr coal and the SBC injection with lower power levels and an initial increase of4- 5% in opacity. This spike stabilized and 

### !he opacity trended down 

### as the tests continued. Attachment 3 shows the arrdngement ofthe NolTec injection equipment and lances into the plant ductwork. CEMs measurements were taken on Unit 5 and Unit 6, at the economizer outlet, before injection. Theplant CEMs in #3 Tall Stack was used to**measureS~** emissions. Coal was sampled during testing. Summary 802 data are shown Table 3-17. The results indicate an overall removal efficiency of54.7 percent and with an efficiency ratio of0.112 lb S0 2 removed per lb of sorbent injected. Table 3-17- Summary S01 Data, SBC Injection Downstream of

### Air Heater Units 

### 5 and 

### 6, June 

### 14,2010 Measurement Unit Value Average S02 Before OS Injection Lblhr 2,036 during test Average SBC injection Lblhr 9,980 Removal Efficiency Percent 54.7 Lb S02 Removed/Lb Sorbent Ratio 0.112 Ton SBC/Ton S02 Removed Ratio 8.93

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### 3.1.9 Continued Sodium Bicarbonate Downstream ofthe Air Heater Units 5 and 6 Steady State Testing
The purpose ofthis program segment was to to continue to document emissions and plant operating characteristics injecting SBC downstream ofthe AH on a continuous basis. The test occurred on 15 June and into 16 June. The plant was burning coal from the Belle Ayr mine with approximate O.G lb SO,/IVfMBlu conlenl. This is a coal with a lower sulfur content than was burned in the first two weeks oftests. SBC was injected into Units 5 and 6 for all ofJunc 15 and into June 16. Full load operation ofUnits 5 and 6 began about 6:25. The average SBC injection rate was about 9,960 Ib/hr for both units during full load operation. This testing was curtailed when Unit 

### 5 developed a tube leak resulting in the unit being taken out ofservice around 5:00am on June::: 16. Attachment 3 shows the arrangement ofthe No!Tec injection equipment and lances into the plant ductwork. On Unit 5 and Unit 6, CEMs measurements and mercury were sampled at the economizer outlet. On both units, particulate matter (TMS) was measured at the ESP inlet. Mercury, metals, acid gases, S03 and particulate were measured at the common#3 Tall Stack. Summary S02 data arc shownTable 3-1 &. The values indicate an overall removal efficiency of 54.7 percent and with an efficiency ratio of0.113 lb 

### SO, removed per lb of sorbent injected. This feed rate and removal efficiency continued intoJune 16 until Unit 

### 5 was brought down at about 

### 5 am. SBC injection continued at a reduced rate withjust Unit 6 inoperation with an average feed rate for Unit 6 of4,950 lblhr, with 52.9% S02 removal efficiency and a 0.109 Lb SOzRemoved/Lb Sorbentutilization. Table 3-18- Summary S02 Data, SBC Injection Downstream ofAir Heater Units 

### 5 and 

### 6, June 

### 15,2010 Measurement Unit Value Average S02 Units 5 and 

### 6 Before Lblhr 1055.7 DS Injection during test Average SBC injection Rate Lb/hr 9,960 Removal Efficiency Percent 54.7 Lb SO,Removed/Lb Sorbent Ratio 0.113 Ton SBCffon S02 Removed Ratio 8.85 Summary particulate matter emissions data are shownTable 3-19. The values presented are the averages ofthree one-hourruns. Data indicateoverall ESP efficiency of99.02 percent, better than baseline efficiency. Although the efficiency is somewhat better than

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the baseline, the real problem is the total particulate is 75 lb/hr more than measured with the baseline testing.

Table 

### 3-19- Summary Particulate Matter Data, SBC Injection Downstream of AirHeater June 

### 15,2010 Measurement Unit Value ESP Inlet (Unit 5) Lb/hr 10,367 ESP Inlet (Unit 6) Lb/hr 12,822 Stack Lb/hr 227.70 Removal Efficiency Percent 99.02 Total mercury emissions data are shownTable 3-20. The values presented are the averages ofthree runs. Data indicate overall removal efficiency of93.7 percent (based on coalmercury concentration), which is consistent with the basehne efficiency. Tne removal efficiency represents the combinedremoval ofthe DSI and PAC injection system.

Table 3-20- Summary Mercury (Total)Data, SBC Injection Downstream ofAir Heater .June 15, ZOlO Measurement Unit Value Coal Lb/hr 0.0186 Coal Lb/TBto 8.34 Stack Lb/hr 0.00235 Stack Lb/TBto 0.65 Removal Efficiency Percent 93.7 

### 3.1.10 Comparison of Certain Metals Emissions, During Baseline and SBC Injection Ten'metals were measured in tbe stack during the baseline sampling and again when injecting SBC on the final day oftesting. Different coals were burned between the two test days. Table 2-3 shows the analyses ofthe two coals during the test period

.. From

## a visual review ofthe data, it is not evident that SBC had an impact on metals emissions, eitherpositive ornegative. There is some indication that SBCmay have decreased the amount ofnickel or selenium in the emissions. 

### 3.1.11 Comparison ofAcid Gas Emissions, During Baseline and SBC Injection Hydrochloric acid andhydrofluoric acid gases weremeasured in the stack during baseline sampling and when injecting SBC on the fmal day of testing. TI1e average emission**rat~s** are shown in Table 3-21. Different coals were burnedbetween the two testdays. Table 2·3 shows that the Jacobs Ranch coal had on average slightly greater concentrations of



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### Dry Sorbent Injection Test Program

chlorine than Belle Ayr coal, however, on the days tested the chlorine concentrations were similar. Fluorine concentrations were not sampled. Assuming the Belle Ayr coal had similar concentrations ofchlorine and the same or higher concentrations offluorine, approximately 

### SO% of the acid gases were removed when comparing the baseline test results with the SBCinjectionresults. Table 3-21 -Comparison ofAcid Gas Emissions Date Test Average HCI AverageHF Lblhr Lb/hr 4-5-Jun (I) Baseline 2.335 6.21 15-Jun(2) SBC after the air <0.53 1.23 heater Removal (3) >77.3% 80.2% "

. l'lotes: I. Burned East thunder (Jacobs Ranch) PRB Coal 2. Burned Belle AyrPRB Coal 3. Based on the assumption that the two coals have the same concentrations of chlorine and fluorine 

### 3.1.12 DSIImpacts on NOx Emissions The NOx emissionsbetween the baseline sample dates and the DSI dates were reviewed to**s~e** ifthere was a discernable impact OfDSl on NOx em.issions. The data is included in Attachment I. Little to no reduction inNOx emissions was seen 

### with the injection of dry sorbent. 

### 3.2 Comparison of Dry 

### Sorbent Utilization 3.2.1 Dry Sorbent Utilization versus S02 Removal A comparison ofthe amount ofS02 removed against the amount and type ofDSI was made to delineatethe utilization efficiency ofeach ofthe dry sorbents used. Since the S02 concentration inthe flue gas varied with time over the test runs a comparison ofthe dry sorbentutilized needs to be compared onan amount ofS02 removed to amount of dry sorbeni used. It should be noted that the SBC utilized during the test program was pre-milled. However, when it arrived portions ofthe SBChad clumped together resulting inunloading problems. This clumping may be indicative ofa general degradation in the particle size (increase in particle size from the milled state) that could impact the SBC performance. Table :J.-22 provides a tabular comparison ofthe dry sorbent injected versus S02 removed. The test results for SBC injection were graphed as provided in Figure 3-3 below.

27ElectricEnergy,Inc,JoppaGeneratingStationJoppa,IllinoisInjectionDateDnrationW/PiantatFullLoad7-Jun8:45-18:358-Jun9:10-16:409-Jun8:50-12:309-Jun14:40-16:0010-Jun8:30-16:5511-Jun9:10-19:3514-JunI0:00-24:0015-6:25-4:5516-Jun(6-16)16-Jun5:35-6:30---"11XlSlliNCic4JhElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409**•·* *FinalHcportDrySorbentInjectionTestProgramTable3c22-SOzRemovedVersusDrySorbcntUtilizationAverageInjectionso,LbsS02TonsOSDSInjectionRateRemovalRemovedperLbperTonLocation(LBIHr)EllicicncyIlSso,RemovedUnmilledBeforeairheater-3,000->13,00013-590.093@50%10.75TronaUnit6SOzremovalMilledBeforeairheater-8,600+/-52.60.10TronaUnil610MilledAfterairheater-14,49342.60.04920.4TronaUnit6Pre-milledAfterairheater-11,750600.84SBCUnit611.9Pre-milledBeforeairheater7,38067.10.1586.33SBCUnit6Pre-milledAfterairheater•3,500-16,00016-530.121@50%8.26SBCUnits5and6S02removalPre-milledAfterairheater-9,98054.70.1128.93SBCUnits5and6Pre-milledAfterairheater-9,96054.70.1138.85SBCUnits5and6Pre-milledAfterairheater•4,95052.90.1099.17SBCUnit6L____--28ism"ij"'fgwElectronicFiling-Received,Clerk'sOffice,08/10/2012* * * **PC#2409* * * * *ElectricEnergy,Inc,JoppaGeneratingStationJoppa,Illinois,2!u0.3SodiumBicarbonateUtilizationHateInjectionAfterAirHeater<>-->FinalReportDrySorbentInjectionTestProgramyo0.186R'•0.2238f0.259<()<)<>-<()uOlO.l...·---·------·0,e0.15c.,>0.1QE"'•,..0.050""...00.00%10.00%20.00%30.00%40.00%50.00%60.00%70.00%&0.00%Percent502RemovalFigure3-3-EfficiencyofS01RemovalUsingSBCAfterTheAirheater6Stiaw·Til!ls-Cn:llf;29ui>'u•"0Iuprinted 07!2312012 1:38PM by Sharon.Dowson p 33135 

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Some general conclusions canbe made from reviewing the comparisons provided in Table 3-22 and in Figure 3-3: • Greater than 50% S02 removal was obtained witb un-milled Trona, and milled Trona before the air heater and with SBC before or after the air heater • 50o/o removal was not seen with milled Trona after the air heater • SBC had a better utilization efficiency (0.158 lbs S02 removed per lb ofdry sorbent) (6.33 tons of SBCiton ofSO, removed) than milled Trona (0.1 00 lbs S02 n'rnoved per lb ofdry sorbent) (I 0 tons ofTrona/ton ofS02removed) when injection was before the air heaters. • Milled Trona was more efficient than un•rnilled Trona in S02 removal (ratio averages 0.100 vs. 0.093, lbs S02 removed per lb ofdry sorbent respectively) (10 vs. I0.75 tons ofTrona/ton of

### SOz removed) when injected before the airheater • The injection location (whether before or after the air heater) impacts the efficiency ofTrona and SBC utilization, with injection before tbe air heater having a signitican!ly greater utiiization efficiency (About haifofthe Trona was needed per lb ofS02 removed and about 75% of SBC was needed with injection before tbe air heater) o The trend line for SBC utilization shows thatthe SBC utilization efficiency**decrea.•••e..~** with increased % S02.removal • When using SBC for 50% SO, removal, a utilization rate ofabout 0.12 lbs SO, removed per lb ofSBC is needed (8.3 tons ofSBC/ton ofS02 removed) with injection after the air heater and a significantly greaterutilizaticm (>0.158 lbs S02 removed per lb ofdry sorbent) (<6.33 tons ofSBC/ton ofS02 removed) if injection is before the air heater.
o Dry sorbent injection will reduce acid gases; DSI reduced HCl and HF acid gases by approximately 80% when the DSI systemwas operated at an S02 removal efficiency of50%. 

### 3.2.2 Impacts of Dry Sorbent Utilization on Particulate Emissions A comparison ofthe Unit 

### 5 and 6 stack total particulate emissions during baseline testing (June 4-5, 2010) versus total particulate emissions during steady state SBC injection (June 15, 2010) are sho\vninTable 3-23. This comparison shows an increase in total particulates ()[74.&3 lbs/hr with the injection ofdry sorbent. This. equates 

### to increase in total particulates of295 tons/yr from Units 5 and 6 assuming a 90% capacity factor.

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Electric Energy, 

### r nc, Joppa Generating Station Joppa, Illinois Final Report Dry Sorbent Injection Test Program

Table 3-23- Comparison ofTotal Particulate Emissions #3 Tall Total Stack ESP Outlet Test Date DSI Injection Particulate Total Collection Particulate Location Inletto ESP Particulate Efficiency Emissions (Ib/hr) Emissions (Percent) (lb/MMBtu) (lb/hr) 6/4-5/2010 

### i Unit 5 6,822 (I) Baseline NA 

## i Unit 6 6,863 Total 13,685 152.87 98.88% 0.046 6/15/2010 Steady- Down UnitS 10,294 (2) State SBC Stream of Unit6 12,822 @ 10,159 Air --- Total 23,116 227.70 99.01% 0.060 !blhr avg) Heater Deltas 9,431 74.83 0.!3% 0.014 Notes: 1. East Thunder PRB Coal burned 2_ Belle Ayr PRB coal with approximately 15% lower ash thanthe East Thunder average burned on 6/4-512010 The type ofdry sorbent utilized also affected the type ofparticulate emissions from the existing ESPs. Table 3-24 provides a comparison ofthe particulate emissions by size of particulate versus the June 4-5 basefine test data. In all cases the Unit was burning Jacobs Ranch coaL Table 3-24 also provides the average DSI rate. Table 3-24

- Review ofAverage Particulate Emissions versus DSI on Unit 6 

### Test DSI Average injection Total 

### PM>lO PM<lO PM<2.5 Date DSI Location Particulate (lb/hr) (lb/hr) (lb/hr) Rate Emissions (lb/Hr) 

### (lb/hr) 6/5/10 Base Test NA NA 81.32 13.48 67.84 17 Un- Upstream of 617/!0 milled 8,502 84.7 

### 5.14 79.56 13.63 Trona Air Heater

6/8/10 Milled 8,696 Upstream of 163.99 9.14 154.85 31.75 Trona Air Heater



### Pre- Down Stream 6/10/10 milled 7,150 ofAir Heater 228.96 8.61 220.35 20.69 SBC



### 31printed 07123/2012 1:38PM by Sharon.Dowson p. 35135 

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * 

## * * * *

Electric Energy, Inc, Joppa Generating Station Joppa, 111inois Final Report Dry SorbentInjection Test Program

Reviewing the results providedin Tables 3-23 and 

### 24 show that the addition ofDSI to the fl.ue gas stream increases the total particulates leaving the ESPwith the majority of increase being PM<!0 microns. Injecting milled dry sorbent

### has the most impact on the increase offine particulates with the pre-milled SEC having a greater impact 

### than the milled Trona, though the results from the testing on June 10 are suspect since they are greater 

### than whatwas measured onJune 15 for the combined Unit 5 and 6 emissions with SEC injection. The least impact onparticulate emissions was the injection ofun-milled Tronawhich 

### had the largest particle size ofall ofthe testruns. It should be noted that with the additionofdry sorbentno impacts onthe operation ofthe ESP oropacitywere observed when firing Jacobs Ranch coal. The Opacity and ESP perfonnance (i.e. spark rates, secondatycurrent, etc.) did change with SBC injection when firing the BelleAyr coal with an increase in opacity ofseveral percent. This increase did not cause theplant any issues withmeeting the plant's opacity limits. 

### 3.2.3 Impacts of DSI Utilization on Mercury Emissions The removal efficiency ofmercury during injection ofDSl was reviewed and is included in Attachment I. Theresults indicate a baseline removal efficiency of

### 93% with the injectionofa minimum of

### 5 Jbs activated carbonpermillion acf. Doring DSI the mercury removal varied from 

### 84.1- 93.7% with 

### 93.7% removal occurring during SBC injection to both units. This removal efficiency isbased on the concentration ofmercury in the coal burned. Throughout the DSI test the activated carboninjection rate was unchanged. Based on the low values ofmercury analyzed andthe 10% variability of removal during injection, it is difficult to state whether DSlhad anyreal impacton mercury removal. 

### 3.2.4 Impacts 

### of DSI Utilization on Carbon Dioxide Emissions The use ofTronaor SEC to remove**S~and** acid gases will evolve C02 as part ofthe chemical reactions. Due to the chemical makeup ofthe two dry sorbents the utilization of SBC will evolve more CO, thanTrona on a pound p.,- pound sorbentbasis. Based on 50% S02 removal and a 

### 90% capacity factor, the use ofTrona at Joppa will evolve about 

### 26,000-40,000 tons per yearwhile theuse ofSBC will evolve between

### 41,000-49,000 tons/yrbased on injection location (before or after airheater).



### 32

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

EXHIBIT3

Comments ofKimberly G1·ay (August 1, 2012)

### Electronic Filing -Received, Clerk's Office, 08/1 0/2012 * 

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### 2409 

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD



### AMEREN ENERGY RESOURCES

Petitioner, V.



### ILLINOIS ENVfRONMENTAL PROTECTION AGENCY, Respondent

To: Attached Service List ) ) ) ) ) 

### ) ) ) ) ) 

### ) ) 

### PCB 12-126 (Variance

- Air)

NOTICE OF FILING



### PLEASE TAKE NOTfCE that on August I, 2012, I filed with the Clerk ofthe Pollution Control Board ofthe State ofIllinois COMMENTS OF KIMBERLY GRAY, 

### a copy ofwhich is attached hereto and herewith served upon you.
Respectfully submitted,

Faith Bugel Andrew Armstrong Jenny Cassel Environmental Law 

### and Policy Center 35 East Wacker Drive, Suite 1600 Chicago, lllinois 60601

### Electronic Filing -Received, Clerk's Office, 08/1 0/2012 

## * * * * *PC# 2409 

## * * * * 

## *

SERVICE LIST

August 1, 2012
AmyAntoniolli Renee Cipriano SchiffHardin, LLP 6600 Wil1is Tower 233 South Wacker Dr Chicago, IL 60606 John Therriault, Assistant Clerk Carol Webb, Hearing Officer Illinois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, lllinois 60601 theniaj @ipcb .state

### .il.us Gina Roccaforte Assistant Cmmsel Division ofLegal Counsel Illinois Environmental Protection Agency I021 North Grand Avenue, East P.O. Box 19276 Springfield, 11linois 62794-9276

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * 

## * * *PC# 2409 * * * * *

Feasibility of Dry 

### Sorbent Injection for S01 

### Control from Ameren's Coal-fired Power Plants 

### Kimberly A. Gray, Ph.D. Professor ofEnvironmental Engineering Northwestem University

Evanston, IL 60208 Dry Sorbent lnj ection (DSI) is emerging as a pollution control teclmology to address sulfur dioxide (S02) 

### emissions. Specifically, for Ameren's fleet of coal fired electric power plants (pa1iicularly, the E. D. Edwards and Joppa plants) DSI represents a technically and economically feasible strategy to reduce SO, and other acid gases (e.g., HCl and HF). DSI systems do not require major capital investment and are very robust and flexible in design. S0 2 

### reductions in the range of 50-80% can be achieved and reductions of as high as 95% have been documented. Further, simply by adjusting the dry sorbent feed rate, removal rates can be tuned to changes in operating conditions (i.e., changes in fuels, loads, regulations, etc.). Our analysis of the estimated performance of DSI at the E.D. Edwards and Joppa plants reveals that, by employing DSI to achieve just 50% S0 2 

### removal efficiency at the Edwards and Joppa plants, Ameren should be able to achieve a fleetwide average of 0.25lbs/MMBtu S02. 

### Fmiherrnore, the capital costs of DSI for both plants are estimated to be less than $200M (approximately $5UM at Edwards and $145M at Joppa).

0-rysorbent·in:fection pro,cess to remov-e m-ercury and airtoxi-Ci t•;':i·"



### Q,.YsorbeiitIs in!E<;ie(!

## and 

## rea«s

.**••llihacietg~~e$**

### to

form

### Q?!l;poonrt Add. gas. a>m1Jound sndpartiwlatematter

.**arefflt,er-~,~d** out**,.__~-'~'"·"'"--~** !l<idi\05**-®mpo~n.d**and partitu1atematter Treatedftue gas**i$emltte~.** through stack 

### Figure 1. 

### Schematic ofDSI injection and removal system. Source- US Energy Information Agency. (http://www.eia.gov/todayinenergy/detail.cfm?id=5430)

I. 

### Flue Gas Desulfurization 

### Flue-gas desulfurization (FGD) is a set of technologies used to remove sulfur dioxide (S02) 

### and other acid gases from the exhaust flue gases of fossil-fuel power plants, and other SO,-emitting l

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

processes. A variety of sorbents are used in either wet or dry FGD processes. Depending on the way in which spent sorbents are treated, FGD processes can be further divided into once-through process or re-generable process. The costs of the re-gencrable technologies, however, are more expensive compared to that of the once-through technologies; thus, the re-generable processes are not widely used to remove S02. 

### An example of a typical wet, lime/limestone FGD system is illustrated in Figure 2 and consists of three major sub-systems: I) reagent (lime or limestone slurry) preparation; 2) scrubber/S02 

### absorber and mist**eliminatm~** 

### 3) slurry/solid waste disposal systems.

Figure 

### 2. Clean Gas Systems, Inc. Wet Flue Gas Desulfurization process tr<1in. (http:/ /www.cgscgs.com/ga fgd.htm)
Nearly 90% 

### ofthe electricity capacity in the U.S. is generated by plants using wet FGD. Although wet FGD systems clearly predominate over dry sorbent injection (DSI) systems, which are discussed further below, the capital costs can be as much as 10 times greater. Table I compares the key features ofwet FGD and DSI. The major advantages ofwet systems is that very high S02 

### reduction etticiencies are achieved, in the range of 95-98%, 

### whereas removal efficiencies between 50-80% 

### are typically attained by DSI systems. Furthermore, the alkaline sorbent demand ofwet FGD is approximately 2-3 times less than that of DSI. DSI has a number ofadvantages over wet FGD, however. DSI produces dry wastes that are generally easier to dispose of than the wet wastes generated by wet FGD, which in some cases require wastewater treatment prior to discharge. Power consumption, pumping requirements, and pressure drop across absorbers for DSI systems arc lower than those for wet FGD system. Other advantages ofDSI include: shorter residence times are necessary than with wet FGD, solids are less likely to agglomerate or deposit on intemal supports, and the high resistivity problems associated with many alkali materials are 2

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

avoided. Perhaps the biggest advantage of DSI is lower cost compared to wet FGD. with DS! averaging 10-25% ofthe cost ofwet FGD.
'NetFGD**D~·** Soroentlnjection Capital Cost S200-400!Ktl

i Coal Sulfur Cont-ent for Best .A.pplicatron ! >2.% <15% 

### :so.. RPGUction Ef!idenr:v " 

## - - 

# - 

# -. 95-98% 50-80% Power Consumption.% of electric generation 1.0-25% 0.1-0.5% Bypraducts 

## IGypsum so lin or MgS04 solution ior! use or disposal I Collected with !y ash

1 .A.1kal!ne Reagent or Sorbent consumption. I
I 

## ·z "3-7 kg.lkg S02 in !ue gas 

### i 

### ' 

### !\

11/ater consumption.**m~Jhrii~Pl·/** 

### i 0..2-0.3 None

### fw·aste-~later.treatment required? Yes No 

## IFlu.e gas reheating required? Yes No 

# I Ease of retrorrt to existing power station Very difficult Easy 

### Table 1: 

### Comparison ofdifferent parameters for wet and dry FGD systems.

(http://www.mobotecusa.com/mb/technology/dry-sorbent-injection.htm) I



### !

Our analysis of the estimated performance of DSI at the E.D. Edwards and Joppa plants is consistent with the data shown in Table 1. Conservatively, employing DSI to achieve 50% S02 removal efficiency at the Edwards and Joppa plants, Ameren should be able to achieve 0.25lbs/MMBtu. Furthermore, the capital costs ofDSI for both plants are estimated to be less than $200M (approximately $50M at Edwards and $145M at Joppa).

2. 

### Dry Sorbent Injection 

### In DSI systems, calcium-based dry sorbents such as limestone (CaC03) 

### or hydrated lime (Ca(OH)o) are injected into the upper portion of a coal-fired boiler where combustion gas temperature is optimal for 

# so2 capture. 

# so2 reacts rapidly with the calcium-based sorbent to fonn stable calcium sulfate solid. Sodium-based dry sorbents such as trona or soda ash can be injected directly into the hot flue gas at multiple points as illustrated below in Figures 4 and 6. Most dry desulfurization systems use calcium-based alkali, such as lime and limestone, as sorbent for reduction of

# so2 from flue gas since these alkaline materials have a relatively lower unit price. However, since calcium-based alkali injection process has very low sorbent utilization capacities, high 

### sorbent injection rates are required to achieve significant S02 

### reduction from flue gas from coal-tired power plants, resulting in high operating and maintenance costs2 

### According to previous studies, sodium-based compounds have higher reactivity against S02 

### compared to calcium-based sorbent3

. 

### Ofsodium-based sorbents, sodium bicarbonate (NaHC0 3) 

### is more efficient in removing S02 compared to sodium carbonate (Na2

### C03{ 

### This is due to the additionalreactive surface area that is created as sodium bicarbonate converts to sodium carbonate in

### ~ hot gas stream prior to reaction with 

# sol This thermal decomposition reaction can improve
3

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * 

## * *PC# 2409 

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## * * 

## *

the utilization of sodium bicarbonate for S02 

### removal compared to sodium carbonate by as much as 40%. However, since Nal-IC03 

### is much more expensive than lime as shown in Table 2, tlse of Na!-IC03 

### as sorbent creates higher operating and maintenance costs than does lime.**Sorb~11t** Co5t ( er ton) D:r'i.' hvdr.ated lime. S40··S70 Sodium Bicarbonate**(~**aHCO-'-i 5260 :\""hcolite (2\faHCO,i 5200 5 70 

### Table 2: Comparison ofvarious sorbents and their costs.

3. 

### Trona Trona (trisodium hydrogendicarbonate dihydrate), (l\a2

### C03

### •NaHC03

### •2H2

### 0) is a naturally occurring, evaporite mineral. Figure 3 shows microscopic images oftrona powders. Although the principal use of trona is to produce soda ash for glass and powdered detergent6

, 

### research has demonstrated that it is effective in reducing the SO, 

### and other acid gas emissions from power plants'.

Trona consists of both sodium carbonate and bicarbonate (Table 3) and due to its lower cost, it has the potential to replace lime and limestone as the most widely used sorbent in the desulfurization processes. It is already the most common sodium-based dry sorbent in use. Constituent Percent(%) 46 NaHCQ, 36 

### 16 SiOz <0.4 }UO insDl-uble <2 i. 

### Table 3: Composition oftrona

4

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

3.1 Mining 

### Trona is mined underground and processed into soda ash or bicarbonate of soda for a variety of uses. Wyoming has the world's largest deposit of trona, found at depths from 600 to 3500 ft 

### over an area of approximately 2500 square miles. Wyoming supplies about 90% of the nation's soda ash8 

### Today four companies, FMC, OCI, Solvay and Green Chemical, currently mine trona in the Green River Basin, but only two, Solvay Chemicals and FMC, market trona for 

### S02 

### control9


### 3.2 Processing 

### Trona can be processed into soda ash or sodium bicarbonate. Trona decomposes by calcination at any temperature over 70"C, but most manufacturers prefer to use 13 

### O"C. The calcined material is dissolved, clarified. filtered and re-crystallized. Jt is then centrifuged to remove excess water and dried. The dried product is shipped as either a bagged or bulk product.
4. Trona Injection & 

### S02 

### emission control 4.1 

### Trona Injection 

### ln 

### a DSI system, trona is injected directly into hot flue gas(> 275°F) as shown in the Figure 4.**CO<~.** I TDF wooo**·--~-------~~-----~.·~** I

.. • - ..

, : 1**~ C~<Pb~~s:•l!'""** **~:** v i

--.· l



### '**~ ~co~ofnfze·t"'**  .' · r 

### ' I, .";,:'.:::: :: ·_Alf-:- · • ·

Prehe·atet>:**~ Mecha~ltat** **~ C~I!ec~ar·.**  Boiler Bunding 

## ., .,

,_ -·.-._-,t 

## '



## . {
..J '':d "'
..J**Ai16rC~We.r** ESPs 

## ,H..,_. 30fool _., .. 

### Figure 4: A coal power plant system with trona injection. After injection, the sorbent is calcined into porous sodium carbonate as shown in Figure 5. Upon decomposition to sodium carbonate, a significant increase in the surface area of the particle is produced in what is commonly referred to as the "popcorn effect". The high surface area enables fast gas-solid reactions between trona and 

### S02• 

### The product Na 2

### S03 

### is then collected either by electrostatic precipitators or fabric filters. The chemical reactions are shown below. Trona calcination: (I)

5

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

S02 

### adsorption:

# t*:":~~r Figure 5: 

### Sorbent is cal.cined into porous sodium carbonate- Popcorn effect (2)



### Trona can be injected at almost any location in the gas stream (Figure 6) but each location has its own advantages and disadvantages.

Boiler

Trofla silo Economizer

l



## .....**:r--=~;--'------¥---- -~**  Air Trona/air Wet FGD


### Figure 

### 6: Different locations for Trona injection. Upstream of the SCR 

### (Location 1)

• Injecting trona at this location can remove most S03 

### ahead of the SCR to eliminate the formation ofNH4HS04, or ammonium bisulfate, inside the catalyst and consequently lower the minimum operation temperature.
• This is the preferred location ifthere is a hot-side electrostatic precipitator (ESP) upstream ofthe SCR catalyst. Between the SCR andAir Heater 

### (Location 2)

• Injecting trona at this location removes S03 

### ahead of the air heater so that it can run at lower temperatures, resulting in higher plant thermal efficiency.

6

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Between the Air Heater and ESP (Location 3)

• This is the most common location to inject trona to eliminate the blue plume caused by SOJ. Between the ESP and Wei Flue Gas Desulfitrizalion (Location 4) (i) 

### Injecting trona at this location is effective in mitigating S03 • (ii) 

### A wet scrubber is needed downstream to captw-e the reaction product (Na2

### SO,) and unreacted sorbent (NazCOJ). (iii) 

### Na2

### C03 

### will enhance the performance ofSOl removal [n 

### the wet scrubber. 

### 4.2 S02 

### emission control A 

### number of researchers have investigated the efficiency of trona to control S02. 

### In one study, Cho conducted modeling and experm1ental studies in order to optimize trona's reactivity with SOl in 

### DS1 1**T-=1illn:~~vm:<> ~**  r----I:X•----, j ,__...._ 1 j Ther.mncoup!e 11Y.lrlnl'r.tin a1 rocm leml'**~(O.flB%**i5Cmlimln 

### Im**~·**--->1 CO:! 150mlfmln OJ---.1**~80CM!!rnin** Constant Temter:at>Jre C3blnat Vent

Analyzar Data acquisition

?ump



### Figure 7: A schem<ltic diagram offixed bed reactor A schematic diagram of fixed bed reactor is shown in Figure 

### 7. For Cho's study, the reac.tor was brought in steady cDndition prior to trona injection. The exhaust gas was monitored contmuously for S02 

### in real time by an infrared gas analyzer. Experimental conditions in the fixed bed reactor were as follows: the flue gas temperature was !SO"C; flue gas S02 

### concentration was 510-530ppm; and flow rate was !OOOml/min. Trona could reduce 60-80% of the S02 

### gas (Figure 8). Water is essential for the reaction oftrona. Water vapor had a high influence and caused 38-53% change in the reaction.

7

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * * 

# '"l 

# "1**~**

# "j**~ ~**  ·u**~** 

## "**~** 40;**~**

# j "' 0

i 

# ,t

--,----- I
- -----. I TmnaiSO, malm m!in 

### Figure 8: Plot describing the removal efficiency in variation with trona and S0 2 

### molarratio As shown in Figure 8, removal efficiency increased with increasing trona concentration and decreased with an increase in SO, gas. The conversion/reactivity oftrona (X,) 

### can betheoretically calculated by:

Where, R= Radius ofthe particle Rc= Radius oftrona particle Tb= 

### Time required to complete the conversion of trona X,= conversion oftrona u = 

### velocity (cm.sec) Figure 9 shows the positive effect oftemperature on removal efficiency. 

## "' "**~-** 

# " " 

# • 0 :·d


# ..**~** 0 

# ,,l
E**~** 

# "]

c I



### ,_, 0**~_!l** 0 

# ••**~~** L**~** ::!**TrortaiSO~** L1'
. .:JI>lr rariD 0



# "' 2!;::!' 0**:'.~~·-** 

# •**"'"-~':'** 

# .. :;5JF 

### (3)

8

### Electronic Filing -Received, Clerk's Office, 08/10/2012 

## * * * * *PC#'2409 

## * * * * *

Figm·e 

### 9: Plot describing the removal efficiency in variation with trona and S02 

### molar ratio with diJTerent temperatures. Figure l 0 

### illustrates the effect of size of trona on removal efficiency, where smaller particles of trona treat more 

## so2 compared to larger-sized particles.

O.iD

D.[•B 

# "'**~ o.~e**  0**~** 

## e t"



### ,, 0.04 

## g

O.D2

D.DD
Si:::e range (micromeTers} 

### Figure 10: 

### Effect ofsize oftrona on removal effrciency



### 5. ESP Upgrades 

### 5.1 Electrostatic Precipitators Particulate matter (PM) is a by-product of fossil fuel combustion used to generate steam for industrial processes. Electrostatic precipitators (ESP) are one of the major particulate collection devices used today. They can handle large gas volumes with a**v.~de** 

### range ofinlet temperatures, pressures, dust volumes, and acid gas conditions. They can collect a wide range ofparticles in dry and wet compositions. For many industries, the collection efficiency can be as high as 99%. As flue gas passes across a series of electrically charged plates and wires, PM (ash and injected sorbents) becomes stdtically charged. These charged particles collect on the electrically grOLmded plates. The plates are rceriodically "rapped" to dislodge PM, which is then collected and disposed as shown in Figure l l 0

9

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

.Figure 11: 

### Design ofESP, showing the particle capture

In 

### order to accommodate the additional PM loaded to the ESPs from trona and to improve the control efficiency of the ESPs, some modification of existing ESPs may be required, such as changing the location of the combustion air preheater ("hot-side" to "cold-side" ESP design) and!or installing high frequency transformer rectifier sets on ESPs. 5.2 Hot-side Versus Cold-side ESPs 

### ln describing ESPs installed on industrial and utility boilers, cold-side 

### and hot-side 

### refers to the placement of the ESP in relation to the combustion air preheater. The air preheater in a cold-side ESP is located before the ESP, 

### whereas in a hot-side ESP it is located after the 

### ESP 11 

### as shown in Figure 12. The air preheater is a tube section that preheats the combustion air used for burning fuel in a boiler. When hot flue gas from an industrial process passes through an air preheater, heat exchange occurs whereby heat from the flue gas is transferred to the combustion air stream. The flue gas is therefore "cooled" as it passes through the combustion air preheater. The warmed combustion air is sent to burners, where it is used to bum gas, oil, coal, or other fuel including garbage 12

"Hot-side"ESP ....**"'""'~'"'l''"­ ~"** **!•·<•i,~·o:N/**

- 

### ; ]

# (~~I~~-=:-i"~.:'n**~,..__.;.. "'"'~''** 

"Cold-side" ESP 

### Figure 12: 

### Schematic diagram ofhot-side and cold-side ESP Although the use ofhot-side precipitators can help reduce corrosion and hopper plugging, there are also some disadvantages. In a hot-side ESP the temperature ofthe flue gas is higher, and hence, the gas volume treated in the ESP is larger. Consequently, the overall size ofthe precipitator is larger, making it more costly. Other major disadvantages include structural and mechanical problems that occur in the precipitator shell and support structure as a result ofdifferences in thermal expansion. With cold-side ESPs, in contrast, the volume of tlue gas that is handled is reduced in comparison to hot-side ESPs because cold-side ESPs are operated at lower temperatures. Thus, the overall size ofthe unit can be relatively smaller, making it less costly. The decreased gas volume also increases the gas residence time in the ESP, thus increasing the control efficiency of the ESP. In addition, injection of sodium-based dry sorbents may reduce the resistivity of the fly ash resulting in improved ESP effectiveness. Experimental results shown in Table 4 demonstrates the better control achieved by cold-side ESPs 13 •

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## * * * * *PC# 2409 

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Emissions before and after cold-side com'ersion 

## i Emission ' Hot-side 

### ! Opacity(%) 

### ! 7-20 

## I Particulate (lb/mm btul 0.063 

## I

# so2 (lb/mm btu) 1 

### o.63 

## iNO, (lb/mm btu) 

## i 0.34 ' 

## I Cold-side (Estimated)

i 10 

### I

1 

### o.o3

1 

### 0.63 ! 

### 0.34
Table 4: Emissions before and after cold-side conversion from Midwest Power s Council Bluffs Energy Center experiment.
One ofthe disadvantages ofconverting ESPs from hot-side to cold-side operations, however, may be an increase in the ash loading on the air heater. The increased loading occurs because 100% of the fly ash will pass through the air healer. Since replacement and cleaning work could be diftlcult, it is recommended that dense pack baskets be replaced with loose pack baskets. Finally, the burning of low-sulfur coal makes fly ash collection by cold side ESPs alone ineffective. Fly ash produced from low sulfur coal-fired boilers has high resistivity, making it difticult to collect. Therefore, in general, cold-side ESPs are used along with conditioning agents when burning low sulfur coal. 5.3 Transformer Rectifiers Sets Transformer rectifiers supply DC voltage and current to ESPs. High-frequency transformer rectifiers supply high power, voltage and current to ESPs and, thus, may improve the dust collection efticiency of ESPs. Such enhancements to ESPs at existing plants appear sufticient !o address the increased Pl\1 load that trona systems generate, rendering additional PM control devices, such as fabric filters, unnecessary. 5.4 Effect oftrona on PM With the use of trona, the control efficiency of ESPs improves. Data from trona injection tests (Mirant's Potomac River Station on Unit 1 

### between November l2 and December 23, 2005 14 ), 

### indicated that ESP performance improved with trona injection, even though trona reaction with S02 leads to PM fonnation. The reason for this has not been studied yet, but it likely results from a lower resistivity ofPM after the injection oftrona. 6. Feasibility Study oftrona injection to other plants 6.1 Existing coal power plants There are a number ofthe existing power plants that use DSI in the form oftrona injection: (i) 

### GenOn Energies

- GenOn Energies employs trona to achieve 40-60% of S02 

### emissions reduction. A 

### dry powder fonn of trona is injected into the exhaust gas stream where it neutralizes and bonds with the S02. 

### The dry byproduct is then removed in the particulate emissions control equipment and collected with ash 15•

11

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(ii) 

### American Electric Power (AEP)

- American Electric Power (AEP) tested several sorbents and sorbent systems and selected trona as the best solution for their fleet of plants. They developed a reliable and cost-effective trona handling, conveying and injection system. Positive results include a substantial reduction in S03 

### and enhanced performance of the existing dry ESPs. Additionally, operational and maintenance costs were minimized 16
(iii) 

### Dominion Resources- Kincaid Generation LLC, a subsidiary ofDominion Resources Inc., awarded the KBR Power & 

### Industrial Group a contract to provide engineering, procurement, and construction services for a DSI system to reduce sulfur dioxide emissions at its 1,158 MW Kincaid coal-fired power plant in Illinois. The project is schedllled for completion in late 2013 17 

### 6.2 Case Studies (i) 

### Mirac Potomac River generating station- A series of32 experiments were conducted at the Mirac Potomac River generating station to test the performance oftrona obtained from the Green River, WY mine. A Continuous Emission Monitoring System (CEMS) was installed to monitor S02 

### emissions and 80% 

### sulfur removal was consistently achieved. Figure 13 illustrates the percent ofS02 

### removal as a function oftrona feed stoichiometry 18

Potomac ;:!iver Tron.a lnj..etion Nov· Oec: :2005 Compo.!iile Data All Tesw 110'kT-· ·-·-··-·· ----·-···----·-· ··--·- •**---~.~-·-·---·•·** 

## I 100'\i.+----

# ·~+-l------------------------------------- i

'"' +-.

### ---------------------------=-'"""=::::;

## L~----------------~~~-----------, 10"1., <>'< j 

### ¥ 6"ll"A 

### 1-----------------,-L**~** i**~ ~%+-·----------~~-----------------------"** **~ ~~+-!------~~-------------------·---------c**  

# ""i

1'11% 

## 1

-----·------·--··-------·----·--..------

## ''~---------------------------------~

O.D 0.5 I.D Ui 2.0. :!_S.**~-0** J.b 4.0**A.~** 5..0 li.S. 6,0 5,5 7,0 

### Figure 13: Plot showing direct relationship between S02 

### removal and trona dose. (ii) 

### Nalco Mobotcc

- Most Nalco Mobotec solutions require only minimal modification of existing furnaces and associated systems and can be implemented at a fraction ofthe cost of installing alternative air pollution control equipment. They offer furnace and postfurnace sorbent injection systems that are very easy to retrofit to existing power plants. Power consumption is low--less than 0.5% 

### of generating capacity. They have their own design for sill·bent injection system as shown in Figure 14, which consists of independent feed hoppers, various types offeed equipment, and a bin vent filtration system. This system includes several equipment advancements to ensure consistent sorbent flow-ability and accurate sorbent injection rates 19•

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Figure 14: 

### Design ofsorbent injection system by Nalco Mobotec 6.3 

### Commercialization of

### trona 

### Trona is commercialized by a variety ofindustries such as: (i) 

### Babcock and Wilcox provides an S03 mitigation technology through a license with AEP ProServ, Inc., a subsidia1y ofAmerican Electric Power (AEP/0

. 

### (ii) 

### Tala Chemicals (Soda Ash) with Church & 

### Dwight Company and FMC Corporation have signed a definitive agreement to form a pru1nership to manufacture and market sodium-based dry sorbents for air pollution control in electric utility and industrial boiler operations. Natronx will produce, sell and distlibute sorbents to users of DSl technology. USEPA estimates that DSI technology will likely be employed by nearly 20% of US coal-tired electric generation capacity as prut of compliance with air pollution regulations recently issued in March 2011. Natronx intends to invest approximately $60 million to construct a 450,000 tons-per-year facility to produce trona sorbents by the fuurth quarter of20!221

. 

### (iii) 

### Solvair Solutions markets trona not only in coal-fired power plants but also in energyfrom-waste plants, industrial boilers, muuicipal waste incinerators and other industries. 6.4 Effect of trona injection on other contaminants 

### Trona injection is also an effective technology for the removal of other coal combustion conlaminanls, such as S03 , 

### HCl and mercury (Hg). (i) 

### Field 

### Tests -Tronaremoves S02, 

### S03, mercury (Hg), HCI and HF at higher rates than lime and costs less than sodium bicarbonate. Field testing by SOLVAir Solution Compru1y showed the removal rates of S02 

### as 90%. It has routinely achieved HCl removal of95-99%. In addition, it is able to remove 20-70% ofHg used alone, and over 90% in combination ofactivated carbon21 

### Na2

### C03 

### + 

### S03---> Na2S04 + 

### COz Na2 

### C03

### + 2HC1--> 2NaCl +rhO+ 

### C0 2 

### Na2

### C03 

### + 2HBr--> 2NaBr 

### + H2

### 0 

### + C02 

### HCl and HBr can oxidize mercury, thus enhancing mercury removaL

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Economizer

1 S02 ,**SO~,** HCI, HBr,**NO~,** Hg 

# n i I Wet 

### I I scrubber i ;

# ~II



# m-u
Figure 14: 

### Schemaric diagram ofother contaminant removal by trona. (ii) Trona's effect on NOx- 

### Coal-fired power plant use selective catalytic reduction (SCR) systems to reduce the emissions ofnitrogen oxides (NO,). But for many plants, adding an SCR system has unintended consequences: greater oxidation of S02 

### to sulfur trioxide (SOJ), and a rise in stack opacity. This problem can be solved by combining trona injection with SCR systems, which results in considerable reduction ofNOx. This combination is already being used in Dunkirk generating station, CR Huntley generating station and Indian River generating station23 • 

### 6.5 Potential health effects related to trona exposure 

### The Virginia Depruiment of Health investigated the possible health effects of trona24

. 

### Since trona is a caustic substance, it can have an irritant effect on the respiratory system, mucous membranes, eyes, and skin. Excessive levels of airborne dust may irritate the mucous membranes and upper respiratory tract. Aside from these irritant effects, no chronic loss oflung function is attributed to trona in the studies examined, and interventions to reduce dust levels improved respiratory and/or skin-related symptoms. Beyond the occupational setting, available data suggest that trona is only a transient irritant. Yet, to date, there are no published epidemiologic studies of populations living near power plants where trona is used for air pollution control, nor studies examining the health effects as a result of exposure to trona dust among the general population or among special populations that may be at increased susceptibility to airborne irritants. As a food substance, refined trona is commonly added to animal feed to increase the milk yield and double-refined trona is designated by the Food and Drug Administration as safe when used appropriately. 6.6 Conclusion 

### This review ofthe literature and practice, in addition to our own analyses, supports the position that DSI is an efficient, robust, ±1exible, and cost-effective strategy to retro-fit selected Ameren plants, specifically E. D. Edwards and I

### oppa, in order to bring their fleet into compliance with the Illinois Multi-Pollutant Standard. Laboratory and full-scale tests have demonstrated that !ronatypically achieves 60-95% reduction in S02 

### emissions. Trona is particularly well suited for this application and is easily integrated into the flue:gas and the cold-side ESP system of Ameren's plants. IfAmeren were to employ DSI to achieve just 50% S0 2 

### removal efficiency at

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the Edwards and Joppa plants, it should be able to meet its fleetwide S02 limits of 0.25lbs/M'vfBtu with a total estimated capital cost orless than $200M.
Qualifications ofProfessor Kimberly A. Gray 

### Kimberly A. Gray is an environmental engineer with over JO 

### years of experience. Since 1995 she has been a professor of Environmental Engineering in the Department of Civil and Environmental Engineering at Northwestern University. Previously, she held a similar academic post at the University ofNotre Dame. She worked in industry in Paris, France and Miami, FL., and continues to work with a wide range of industrial partners on research and consulting projects. She is a qualified expert in the areas of emissions treatment teclmologies, environmental testing and analytical chemistry, contaminant fate, environmental quality a11d public health. She studied the formation and control of detached plumes in Portland Cement manufacturing plants and has provided technical assistance to the Chicago Legal Clinic on over 60 envirorunental projects in the Chicago area. Ofthese, about 20% focused on air quality issues associated with 

### fossil fuel combustion and in many cases, specifically the SOx, NOx and C02 

### emissions from coal-fired electric power generation. Gray is an internationally recognized scholar in the areas ofphysicochemical processes in environmental systems and the development ofphotocatalytic treatment technologies for air and water remediation. She is the author ofover 100 scholarly papers and reports, holds patents for photocatalyst synthesis and application, and lectures widely on energy, enviromnental and urbm sustainability issues.

15' ' 

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References I. Cho, K. J. (2007). "A modeling and experimental study ofthe conversion ofTrona to increase its reactivity with SO 2 in dry injection systems,", PhD Dissertation (Environmental Engineering), University ofCincinnati, http://etd.ohiolink.edu/view.cgi/CH0%20KYUNGMIN%20.T ACOB.pdf?ucin 1I85822434 2. Dogu, T., Effect of port structure on the mechanism ofSO, sorption on activatedsoda. (Wiley: New York, I984); p I52-162. 3. E.A. Samuel, D. A. F., R.L. Ostop, S02 removal using dry sodium compounds.Am. Inst.Eng. Semp. 

### 1981, 77, (2 I I). 4. Keener, T. C.; Davis, W. T., Study ofthe reaction ofS02 with NaHC03 and Na2C03.Journal of the Air Pollution ControlAssociation 

### 1984,34, (6), 651-654.) 5. Bares, 

### J.; .1., M.; Mocek, M.; Erdos, E., Kinetics ofthe Reaction between the Solid Sodium Carbonate and the Gaseous Sulfur Dioxide. III. Coli. Chech. Chern. Commun. 

### 1970, 35. 6.**http://v-l\~w.mii.org/minerals/photoTrona.html** 7. http://WV>w.netl.doe.gov/technolo gies/coalpower/cctc/resources/pdfs/pscollnetlll60.pdf 8. http://www.wma-minelife.com/Trona/tronmine/tronmine.htm 9. http://www.wma-minelife.com/Brochures/Trona 08.pdf 10. http://www.precip.com/index.php?option=com content&view=article&id=49<emid=60 11. http://vosemite.epa.gov/oaqps/eogtrain.nsf!b81bacb577b0!6d785756e4a004c0393/ 12. APTI Course SI: 428A Introduction to Boiler Operation describes boilers and heat recovery equipment in greater detail. I 3.http://www.isesp.org/ICESP%20V%20PAPERS/1CESP%20V%20Papers%2003%?OESP%20 USER%70EXPERIEKCE%20AND%20FIELD%20STUDIES.htm 14. http://energv. gov/oe/downloads/T rona-in'ection-tests-mirant-potomac-river-station-unit-1- november-12-december-73-2005 IS. http://www.genon.com/companv/env-Trona.aspx I6. http:/ /www.coalpowermag.com/plant designjS03-Control-AEP-Pioneers-and-RefinesTrona-Iniection-Process-for-S03-Mitigation 29.html I7. http://www.kbr.com/Newsroom/Press-Releases/?012/05/07 /KBR-Power-and-IndustrialGroup-Awarded-Dominion-Resources-Inc-EPC-Contract/ 18. http:/

### I oldtownalexandria.patch.comltopics/Potomac+ River+Cienerating+Station 19. http://www.nalcomobotec.comlmb/technologv/drv-sorbent-inj ection.htm 20.**http://w\~.babcock.com/library!brochures-environmental.html** 2 I

..http:/ /www.4-traders.com/T AT A-CHEMICALS-LIMITED-9058951/news/Tata-ChemicalsLimi ted-Tata -Chemicals-Church-Dwight-and-FMC-announce-joint-venture-for-air-po1- 13808631/ 22. http

### :1!www.so1 vair.us/EN/products/seiect200/solvairirse!ect200and 15OT rona.aspx 23.**http://\V\~.coalpowermag.com/plant** design/S03-Control-AEP-Pioneers-and-Refines16' ' 

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## *

Trona-Injection-Process-for-803-Mitization 2 9.hun! 24. Virginia Department ofHealth, Office ofEpidemiology & 

### Ofiice ofEnvironmental Health (June 2007). "Ilealth Effects Associated with Exposure to Trona: A Review ofthe Biomedical Literature," hllp:i ivMw.atsdr.cdc.gov 

### /hacipha/MirantHC/AppendixFTronaSummary.pdf

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Under penalties as provided by lllinois law, the undersigned certifies that the statements set forth in this instrument are true and correct. Executed this 

### 51 day of 

## -::1' 

# vi-, ,20 IZ 

### in 

### CniG??ifJ, 111,**Y'~_,..._** 

## . 

# I

# ~~, Kimberly Gr · 

# p?"" Professor of

# ~~n=ental Engineering Northwestern University

CERTIFICATION 

# l<;**,~I.G"-r** lv, (;<c itv, 

### appeared before me and subscribed, and swore or affirmed that the foregoing Affidavit is true, correct and executed as a knowing, free and voluntary act for the purposes stated**this~** 

### day of 

## :J V-ll:) 20 

### i J_.



### Fidelia Gaines-Mitchell

NOTARY PUBLIC My Commission expires: 

## 02 I ;).}! 

### I**~c** 

### /3

. OFFICIAL SEAL FIDEUA GAINES-MITCHELL NOTARY I'USLIC ·STATE OF ILLINOIS MY COMMISSION EXPIRES:Dili:28113

### Electronic Filing -Received, Clerk's Office, 08/10/2012 

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Address:

EDUCATION 1988

198J

1978 CURRICULUM VITAE 

### Kimberly Ann Gray (07il2) Department ofCivil and Environmen(a] Engine-ering 2145 Sheridan Road Northwestern University Evanston, IL 60208-3109 (847) 467-4252**_k:gru_y(i.{nQr.1!l\~:-~st~ni.eLU.! f11:~/** \,.**\-.Y.-''./.,~~L**vi**Lqort1I~S'!.b.;:_:r.rt_ql_!L'£.1Jl~!}l.J}11._J;,.~\Qi.K** i**nnv_e~y**

Ph.D., Depanment ofGeography and EnvironmentaL Engineering The Johns Hopkins University, Baltimore, MD Thesis Title: The Formation, Characterization, and Use of Inorganic Iron(III)**Polyt~lers** for Coagu(aliotl in Water Treatment Advisor: Dr._ Charles R. O'Mclia M.S., Department ofCivil Engineering University ofMiami, Coral Gables,.FL Advisor: Dr. Thomas D. Waite B.A., Biology, Minor Biochemistry Northwestern University, Evansron, IL

PROFESSIONAL EXPER!El':CE 2012-2013
2006-present 2008-preseot 2009

- present 2003-20 I 0
2002-present l999-presem 1998-2005 1997-present 1996-present Senior Sabbatical Fellowship

- Public Interest Scientist, Environmental Law and Policy Cemer, Chicago, IL. Professor, Department ofCivil and Environmental Engineering, Northwestern University Northwesiern Institute ofSustainable_Practices, Director. Global and Ecological Health Engineering Program, co-Director with Matthew Glucksberg Director, Environmental Science., Engineering & Policy Program (WCAS); Coordinator of Environmental Engineering and Science (MEAS), Northwestern Mem_ber, Transportation Center, Northwestern University Member, Institute of Policy Research Northwestern University Associate-Director, [nst"itute ofEnvirorunental Catalysis, Northwestern University Member, Center for Catalysis and Surface Sc!ence,. Northwestern University Courtesy Appointment in the Department of Chemical & Biological Engineering 1 Northwestern University

Page 1 of38

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1995-2006 Associate Professor, Department of Civil and Environmental Enginee1ing, Northwestern Univt:rsity
1989-1995 Assistant Professor,**D~partment** of Civil Engineering and Geological Sciences, University of Nutre Dame (promoteJ to Associate Professor) 19X7-1989 Research Engineer_ Lyormai.se de.s Eaux, Lahoratoire Centrnl. Le Pecq, Fmnce. 1983-1987 Research Assistant, Department of Geography and Environmentul Engineering, The Johns Hopkins University. 1984-1985 Instructor, Pan-Tirne Engineering, The Johns Hopkins University. 1982-1983 lnstmctor Bnd Research Assistant, Deparnnent ofCivil Engineering, University of Mian1i. 1981-1982 Environmentfll Engineer, Carr Smith Jnd Assoc., Coral Gables, FL 1980-1981 Research Hydrologist, Everglades National Park, Homestead, FL. 1979-1980 Research Assislant, Smithsonian Jnstitution Foreign Currency Program in India.

PROFESSIONAL MEMBERSHIPS
American Chemical Society American Society ofCivil Engineers Association of Environmental Engineering and Science Professors

HONORS 2011

- I11vitee, 9111 Annual National Academies Keck Futures !niliative (NAKFI), Ecosystem Servfces 2009-2010, 2010-2011 Northwestern Faculty Honor Roll 2009 Distinguished Scientist, Trinity University, San Antonio, Texas Aldo Leopold Leadership Fellow, 2008, Woods Institute for the Environment, Stanford University Sigma Xi Distinguished Lecturer, 2008-2010 2007 McCom1ick Excellence Award m Research, Teaching, & Citizenship Presidential Young Investigator, National Science Foundation, 1991-1996. Graduate School Award for Best Dissertation in the Coi.Jege of Engineering; Dissertation Director of Roger J. Hilarides, 1994. Second Place, Montgomery-Watson and Assoc. of Environmental Engineering Professors 1\.1aster Thesis Award and Honorable Menlion in AWWA Academic Achievement Award Competition, Thesis Advisor of David Widrig, 1993. Stanley E. Blumberg Alumni Association Scholarship, The Johns Hopkins University, 1986-1987. Hattie Strong Foundation Fellowship, l986-1987. American Chemical Society Graduate Student Award in Environmental Chemistry, 1986.
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American Association of University Women**Fello\~ ship,**  Alternate, 1986. American Water Works Association, Chesapeake Section, Student Paper Award, J 986.
PROFESS!Ol\'AL ACTIVITIES Panel Moderator for Infrastructure, Policy and Regulawry Considerations at The Electrification ofTransportationA Look at the Road Ahead Workshop, NU Transporatation Center, Allen**Center~** 18 April20 12. 2012- Reach the Decision Makers Program, UCSF Program on ReprodLictive Health and the En'' ironment
20 II- Consultant, Academic Affairs Division ofthe Texas Higher Education Coordinating Board, evaluation ofthe Environmental Engineering program at Texas A&M University at Kingsville Member, Board ofDirectors, In1emationai Association for Urban Environment, 2009-present. Member, Editorial Board, The International Journal ofSustainable Development & World Ecology, 2008-present. Member, Panel Discussion on Energy: Chicago's Energy Needs In 2020, Major Donor Recognition Event with Ira Flatow for \VBEZ, Chicago Public Radio, April28, 20 I 0. Panel Member, Environmental Racism: Poverty and Poflutlon in Mhwrfty Communities, 20 lO Martin Luther King**Celebration~** NU School o:fLaw, January 12.2010. Science, Ethics, and Appropriate Uses of Technology: A U.S.-France-Iran Workshop, National Academy of Science, Fondation des Treilles, Tourtour, France, Nov. 7-12,2009. "Energy & Sustainability" symposium (Panel member with Thomas L Priedman) as part ofPresident Morton Schapiro's Inauguration, 9 October2009. Member, CBEN NSEC Site Visit Review Panel, Rice Uni\•ersity, 29 July, 2009. Member, Strategic Planning Panel for the Shedd Aquarium, Sustainable Place, Practices, People, Chic-ago Oct. 8, 2008.

. Panel Member, Sustainable Water and Land Management, Clean Technologtes & Sustainability: Global Perspectives &**Opportunities~** Federal Reserve Bank of Chicago, Sept. 9, 2008., Member, Steering Committee, International Insrirute ofNanotechnology, Northwestern University, 2008-present. Panel Moderator, Sustainable Manufacturing: Balancing Environmental Benefits with Economic Costs, 2007 Manufacturing Business Conference, Evanston, IL, May 12, 2007_ Invited Participant,**Business~** Engineering, & Sustainability: Collaborative Programs for Innovation, 2007 Planning Workshop, Universi<Y ofMaryland, College Park, MD, Feb. 16-17, 2007. Panel Moderator, Next Generation Strategies for Creating Value through Sustainable Product Design and Manufacturing, 2006 Net Impact Conference, Oct. 28, 2006. Panel Member, University of Chicago Review of Environmental Science Division, Argonne National Laboratmy, Sept. l8-20, 2006. International Association for Great Lakes Research, Session Organizer and Chair, Integrative Approaches to Ecosystem Modeling, May, 2005. Canadian Foundation for Innovation, Review panel, October, 2003.
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## * * * * *PC# 2409 

## * * * * 

## *

Board 

## or Directors, Chicagoland Redevelopment Initiative (REDI), 2002-2006; Community Advisory Board, Great Lakes**R~developmenllnitiative** Fund, 2004-present. American Chemical Society, Division of Environmental Chemistry, Symposium Organizer and**co-ChE~ir** (with Bruce Logan), Amllysis ofEnvironmental Phenomena at Molecular Scales, August, 2001. Association of Em•ironmental Engineering Professors, Board of Directors, 1996-2000; Vice-President, 1997-98; President, 1998-1999, Past-President, 1999-2000. Natiomd Research Council Water Science and Technology Board, Member of Committee on USGS Water Resources Research, 1996-1999. National Science Foundation Review Panels: Environmental Engineering, 2010, 2011; Career Award, 1998,2004, 2005, 2006; NSF Young Investigator Award, 1992; IGERT, 2004,2005, 2007; Small Business Innovation Research Granl Proposals, 1990, 1994, 1996; BES 2000, 2001, 2002; Division ofUndcrgraduatc Education (UCD & lLI), July, 1993, January & July, 1994; Advisory Panel, Environmental Technology, 1995; Committee ofVisitors (BES review), 2002. Organized Workshop at the AEESP Research Needs Conference, "Gender, Diversity and Family Issues," Pennsylvania State University, July 31, 1999. Organized 1998 Annual Meeting of the Center of Catalysis and Surface Science, "New Frontiers in Environmental Catalysis," Sept. 9, 1998. Panel Member, NSF-AEEP Frontiers in Environmental Engineering Workshop, Monterey, California, Jan. 14-16, 1998. Panel Member for "Photodetox.ification and Purification of \Vater and Air" at the DOE Workshop on Research Opportunities in Photochemistry, Estes Park, Colorado, 5-8 February 1996. Panel Member for NSF Workshop, «Application of Ionizing Radiation for Decontamination of Environmental Resources," Miami, FL, June 1-3, 1994. Environmental Protection Agency. and American Academy of Environmental Engineers WASTECH Task Group 1992-1994, coauthor ofmonograph, "Chemical Treatment: Innovative Waste Treatment**Technologies~'.** Environmental Protection Agency, Member ofBioremediation Education Subcommittee, 1991-1993. American Water Works Research Foundation, Project Advisory Committee for "Destruction of Toxic Organics Using Adsorption and Photocatalytic Regeneration with Sunlight or Low Intensity Artificial Lights," 1991- 1993. American Water Works Association, Organic Contaminants Research Committee 1994-present, Coagulation Research Committee 1989-1991. American Institute of Chemical Engineen, Session Chair and Organizer: Theory and Application of Radiation Processes for the Destruction of Hazardous Compounds, 1990, 1991, 1993; Chemical and Biological Treatment of Waste, 1992; Physical and Chemical Treatment to Enhance Bioremediation of Hazardous \Vaste, 1994; Photochemical and Radiolytic Treatment Processes, 1996. Program Development Colmcil and Superfund Subcommittee for Hazardous Materials Control Resources Institute 1994-1996; Session Chair, "Laboratory & Analytical Methods" at 1994 Superfund XV Conference and Exhibitor. · Midwest Environmental Chemistry Workshop, Conference Organizer, University of Notre Dame, October 17-18, 1993.

Page 4 of38

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Fine Particle Society, Division of Aerosols, Heahh and Environment, Session Chair and Organizer, '·Free Radical Processes for Contaminant Destruction in Heterogeneous Systems," 1993. American Chemical Society, Symposium Organizer, "Polysaccharide Chen1istry in Em'iromnental Processes," April, 1992. Revicv,•er: Chemistry of Malerials, Journal of Catalysis, Applied Catalysis A & B, ACS Cnalysis, Coordination Chemistry Reviews, Environmental Science & Technology, Angewandte Chemie, Journal American Chemical SocietY., Journal ofPhysical Cbemistry, Langmuir, Physical Chemistry Chemical Physics, Energy & Fuels, Nanosc<1le, Carbon, Catalysis Communication, Catalysis Letters, Transportation Research, Thin Solid Films, Journal ofMaterial Science, Jollmal of Colloid and Interface Science, Colloids and Surfaces, Journal ofMembrane Science, Journal ofApplied**Microbiology~** AqtLatic Ecology, Chemishy and Ecology, Journal of Applied and Analytical Pyrolysis, Science of the Total Environment, Water Research, Water QLmllty Journal of Canada, Water Environment Research, Environmental Toxicology and Chemistry, Journal AWWA, Biodegradation, ASCE Journal of Environmental Engineering, CRC Critical Reviews in Environmental Science and Technology, Chemosphere, Waste Management, Industrial & Engineering Chemistry Research, Research on Chemical lntenuediates, Israel Journal of Chemistry, Journal of Solar Energy Engineering, Biotechnology Progress, Environmental Progress, Solar Energy, Journal of Advanced Oxidation Technology, Journal of Hazardous Materials, ACS Symposium Se-ries, New York Sea Grant Prugram, National Research Cuuncil, USGS

- Water Resources Center, Depl uf Energy BES, DOD

- DEPSCoR, Journal ofMolecular Catalysis, Journal ofSolid State Che01istry.

COURSES TAUGHT Undergraduate:

Graduate: Snstainability: Issues and Aclion, Near a11d Far, CEE 395 (2006-presenl) Energy**~:~nd** the Environment The Automobile, Envr Sci 203 (2005-2010) Community Based Design, CEE-398- I, 2 (!996- present) Urban Neighborhoods: Issues and Action, Soc-376 (co-tauglit, W. Espland; Cross School Initiative, 2002) Environmental Engineering Analysis CE 261 (co-taught, B. Rittmann, J-F Gaillard) Introduction to Wa.ter Chemistry and Treatment (UND) Water and Wastewater Treatment Design (UNO) Water Quality Management (UM) Sustainability ?racticum. CEE 395 (co-listed with Law School, PPTY TORT 616 SEC Practicum: Sustainabilily Solutions & lSEN 440) Sustainable Product Design and Development, DSGN 495 (2009, 2010) Physicochemical Processes in Aquatic Systems, CE-444 (NU & UNO) Physical Principles in Environmental Systems CE-440 (co-taught, J-F. Gaillard) Unit Operations in Environmental Systems CE-445 Environmental Analytical Chemistry CE-446 (cu-tanght, J-F. Gaillard) Sustainable Manufacturing, !EMS-497-40 (2005, 2006, 2007, 2008 MMM) Energy and the Environment JPLS -492 (2009) Changing Views ofNature MALS- 403 (2006, 2012) Cities and the Environment: Past, Present and Future.• MALS-403 (2004) The Environmenlal Legacy ofModern Industrialized Societies, MALS-403 (200I) Aqlllltic Chemistry/Advanced Aquatic Chemistry (UND) Water and Wastewater Treatment Design (JHU) Water Supply and Drainage (JHU)

DOCTORAL STUDENTS ADVISED- CURRENT Todd Eaton (2010- present): Ti02 /Si02 Narwcomposites for C02 Photoreduction: Synthsizing and characterizing novel intetfaciaJ structures. Page 5 of38

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Kevin Sclw.•arzenberg {20 I0- present)- Characterizing adsorplion affinity of C02 and il ef[ecl on pboloc<.talytic rcduttion. Ticzhcng Tong (20 I0- present): Uninlended effects ofnanotitania in benthic systems. Sarisl Macksusitom (201 0- present): Biomagnificalion ofpersistent orga11ic chemicals in tbe food webs of Green Bay. Danid Finkelstein-Shapiro (2008-present, Dept. of Chemistry): The effect of defect site .Structure on photocatalytic efficiency.

DOCTORAL STUDENTS ADVISED- COMPLETED Katie Ka[scheur (June, 20!2); Characterizing the Effects of Organic Quality on theStructure and Function of Periphylon in Urbanized SLI·eams, Paul Desario (June, 201 1): Cation Doped Ti0 2 Thin Films Prepared by Reactive Sputtering: Synthesis, Characterization, and Applications for Environmental Catalysis. Marsh_all Lindsey (December, 2010, Depl of Chemical and Biological Engineering): Location, Vehicle Miles of Travel, and the Environment: A Chicago Case Sludy. Shannon Ciston**(June~** 2009, DcpL of Chemical and Biolog1cal Engineering): Photo-active Ceramic 1.-fe:mbrancs for the Prevention ofBiofouling: Synthesis, Characterization & Testing Yuan Yao (Feb., 2009, Dept. of Mechanical Engineering; co-advised with Prof Richard Lueptow): Synthesizing TiOz-Carbon Nanotube Composite t1.1.aterials for Photocatalysis. Lc Chen (September, 2008): "Synthesizing Mixed Phase Titania Nanoeomposites by Reactive DC Magnetron Sputtering to Enhance Photoactivity and Photoresponse." (161 p.) Carla Ng (May, 2008); Dept. of Chemical and Biological Engineering): «integrative modeling of the cumulative effects ofchemical and biological stresses on aquatic food web structme to predict contaminant transfer." (135 p.) · Jill Kastel (June, 2006): "Periphyton Community Structure in Lotic Systems: The Interactions of Metals, PCBsl and Environmental Variables." (451 p.) Cari Ishida (September, 2005): "Strategies to Enhance Denitrification Rates in Restored Wetlands: Hydrology, Ecology, and Microbiology." (194 p.) Mary Finster (May, 2005): "Phytoremediation of Lead in Urban Residential Soils: A Study of Application, Feasibility and Effectiveness in Chicago.'' Alexander Agrios (May 2003): "'Visible Light Pholocatalysis: Adsorption, Complexation, and Reaction -of Chlorophenols on Titanium Dioxide." (168 p.) Tanita Sirivedhin (May, 2002): «Monitoring the Behavior of Organic Carbon in Surface Waters usmg Pyrolysis/GC/MS." (365 p.) G. Adam Zacheis (August 1 2000): "Degradation of Contaminants Adsorbed to Heterogeneous Surfaces Us-ing Ionizing Radiation." (296 p.)
Allen Simpson (May, 1997): "Interpret:ntion of PY-GC-MS Data to Evaluate the Behavior of Natural Organic Material in Aquatic Systems.=' (214 p.) Daniel C. Schmclling (May= 1996): "The Photocatalytic Behavior of 2:4,6-Trinitrotoiucnc in Titanium Dioxide Systems: Photochemic(!l, Electrochemical and Radiolytic Investigations. 11 (138 p.) Page 6 of38

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

Hong \Vang (May, 1996): 'The Response of a Laboratory**Strc<~m** System to PCB Exposure: Study of Pe-ripl1ytic and Sediment Dynamics." (233 p.)
Melissa Dieckmann lMay, 1995): "The Sensitized Photocatalytic Degmdation ofColored Aromatic PoiiLHants using Ti02." (192 p.) Ulick Sta/'ford (OcL, l994): '"Mechanistic Study oC Photocalalytic Dcgmdation orC/Jlorin8ted Phenols on Ti02.·· (223 p.) Roger J. Hilarides (May, 1994); "Destruction of 2,3,7,8-Tetrachlorodibenzo-p-dioxin on Soil LJSing Cobalt-60 Gamma Radirtl.ion:• (249 p.)

MASTER'S STUDENTS ADVISED- COMPLETED Tracy Yang (March 20 J2): "'Mobile Testing in theThar Desert: Assessing waLer quality with limited resomces." Blake Chasmin (hme 2012, MALS): 'The Creation Care Bubble and Evangelical Politics." Ke Gong (March 2012): '"Ecotourism" Ritu Gopal (June, 2011): Aroclor analysis of Green Bay fish and**s~diments.** David Petrone (May, 2011; Dept ofChemical and Biological Engineering): "An Application and Evaluation of theEPA Greenhouse Gas Inventory Reporting RuJe." Erin Himmelspach (Sept., 2010; Dept. of Chemical and Biological Engineering):**'~TnvestigaLlon** of Titania-Silica**Nanocomposite.,;~** Probing Interfacial Catalytic Hot Spots for the Photocatalytic Reduction of Carbon Dioxide." Kevin Schulte (June, 2009): "Synthesis and Characlerizalion ofTi02 Nafiotubes for COl Reduction." Debra Weissman (June, 2006): "Nutrient Dynamics in Riparian Wcllands.''
M. Christina Vicar!o (July, 2001, Dept ofChemical Engineering): "'Novel VUV Photocatalytic Reactor." Y. Mwende Munyasya (Novernber, 2000): "The Effects ofCatal),st Loading, Light Wavelength, and Oxygen on the PhOtocatalytic Transfonnation of 2,4,5-TrichlorophenoL" Mary Finster (October, 1999, Dept. of Chemical Engineering): "The Urban Heat ls1and, Photochemical Smog, and Chicago: Local Featufes ofthe Problem and Solution."**~** David Widrig (November, 1992): "Preozonation to Enhance Coagulation: The Effect of Algal Species and Water Quality an the Removal ofDissolved Organic Carbon" (172 p.). Jonathan l'ioris (AllgusL 1994): "Treatment ofHigh Selenium Waters'' (1 02 p.).

POST DOCTORAL FELLOWS- CURRENT
Dr. AnasShereef(2011- present) POST DOCTORAL FELLOWS- COMPLETED
Dr. Olga Lyandres (2009-2011) Dr. Baiju Vijayan (2008-2011) Dr. Gonghu Li (2005-2007) Dr. Shai Arnon (2004-2006, co-advised with Aaron Packman) Dr. Deanna Hurum (1999-2004) Page 7 of3 8

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Dr. Sung II Chang (2001-2003) Dr. l!sha Rao (1997-1999, co-advised wllh Dave Hollander) Dr. Robert Barnick ( 1995-1 997) Dr. Ann St. Amand (1 990-1 992)

RESEARCH GRANTS AND CONTRACTS- CURRENT or PENDING "Northwestern University Superfund Research Center in Reproductive Health Hazards," co-PI wilh Teresa Wuudruff, SuperfLtnd Research Program, Nallunallnstitute of Environmental Healh Services, NIH, in preparation for April submission (approx. S 7M/4 years). "The Energy HighWay," in co11aboration with Dr. Gayathri Gopalakrishnan (ANL) to National Academy Keck Future Initiatives, $1 00,000, 06/12- 06114. 'LEcological Goods and Services in Urban Development in the Asia Pacific Rim Countries," Asia Pacific Economic Forum, Business Advisory Committee, Summa Capital, Ltd.**$162~000,** 4115/11

- 12!31/ll. 'The Unintended Ecological Consequences ofNanomaterials: Effecls ofnanotitania in benthic systems,'' NSF, $357,539, 04/ll-04/!4. "Science Master's Program in Engineering and Global Hel:l\th Technologies," NSF {with Matt Glucksberg, PI), 5700,000, 09/0lil0-9/01113.

. "Ecological Forecasting: Framework to evaluate the effects ofmultiple stresses in Lake Michigan food\\'ebs and guide remediation,"**NO~-\,** $999,000, 09/09-03/13. "The Chicago Transfom1ation Teacher Institutes." NSF (with UJC), $436,768, 0 I!!0-12114. "'Institute for Environmental Catalysis", DOE, co-PI (C02 Reduction Subtask Leader) with Peter Stair (PI), $4M, 09!05-09/12; individual allocation,**~** $7DO,OOO;(currently t1nder renewal review). Dow Sustainability Innovation Competition, $350,000, 12/08-06/15. "Tailoring titania nanocomposites to LED illumination for gas phase reactions," Honeywell Corporation, SJOO,OOO, 811/08-12131/11.

- • '"Ti02-based nanocornposiles for solar fuel production: Engineering the solid-solid inteJface[or specialized photocatalytic function," NSF. $400,000 09/08-09/12. '"Second Generation Photocatalysts: Ti02-based nanocomposites by de reactive sputtering," National Science Foundation, $240,000, 07/07-12/11. "'Collaborative Research. Mediation of denitrification by algal/bacterial interactions in suearn periphyton: role of successional development and species identity," National Science Foundation, $292,240, 08/07-08/l2.

RESEARCH GRANTS AND CONTRACTS- COMPLETED "'Reactor and Reaction Optimization for the Photocatalytic Reduction ofC02," Boeing Corporation, $95,000, O!l/08- 12/08. "Reactive Membrane Technology for Water Treatment." National Science Foundation, $400,000, l 0/04-12108 (PI, Richard Lueptow). "Deleriomtion of Zinc Potassiwn Chromate Pigments: Elucidating the effects of pigment mixture and environmental conditions on changes in color and chemical speciation," Mellon Foundation,**S29~716,** 10/06-06/08.
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"Engineering Riparian Flood Events: Baseline Monitmi11g," U.S. Am1y Corps of Engineers, $41,160, 05/05-0 i/07. '"GAANN: Communily-Bflscd Urban Environmental Issues," Dept. o,f Education,$ 495,850,8/03-8/07 (PI, co-PisAaron Packman and J-F Gaillard). «Engineering an Artificial Substrate System to Accelerate the Denitrification ofAgricultural Runoff by Pcriphyton," S324,000, 8102-8/06 (PI, co-PI-Aamn Packman).
"Titania Coated Shikkui Tiles: Determining the Role ofthe Support," Fuh1oka University Instilllle for Recycling and Environmental Control Systems, S30,000, 11/05-04/06, FastScience. FastScience, Characteiization orTitania Coatings by EPR for Sundecor and Professor Kalsuyuki Nakano, Fukuoka University, and the Institute for Recycling and Environmental Contml Systems, Phase I, SlO,OOO, Phase H, $15,000, Phase Ill, $1 0,000, 3104-3/05. ''Hydraulic Effects on Biological Diversity in Wetlands," U.S. Army Corps of Engineers, £356,160,**!liD!~** 11/04. «The Fate of Carbon and Nitrogen in an Experimental Marsh," The Wetlands Initiative, $44,000, 01199-08/02, S25,005, 08/03-1-2105. "CollaboraLive Learning Communities,'' Cross-School Initiative, Northwestern University, $100,000, 09/00-6/03. ··safer Yards- Pllytoremediation of Lead-Contaminated Soils," Housing and L 1 rban Deve1opmen1, $171,073, 02/00- 02/03. "Technical Assistance to Community Groups through the Chicago Legal Clinic,'·' USEPA, Region V, $26,250, 9/00- 1102 '"Radiolysis on Oxide Surfaces," -National Science Foundation, $77,269, 2/00-3/0l. ''Radiation-fndllced Catalysis on Metal Oxide Surfaces: Preliminary Investigation of Basic Phenomena and Potentia[ Applicallons," Center for Catalysis and Surface Science, Seed Proposal, $25,000/l year 6/98-6i00. "Pavement Analysis and the Urban Heat Island Effect," USEPA, Alrnospheric Pollution Prevention Division, $111,121,7198-6/99. "Institute of Environmental Catalysis'', NSF, Environmental Molecular Science Institute Program, Assoc. Director and co-PI with Peter Stair, $7,982,692/5 yrs total; individual expenditure, $516,000, 911998-12/2004. "Community Based Projects for Teaching Environmental Engineering Design," Murphy Society, $40,9)6, 1/99- 9/99, S54,069, 01/01-01/02. "Technical Assistance to Community Organizations: Broi..Vnf1eld Cleanup using Wetlands," llSEPA, Region V. $15,000, l/98-1/99.

. "'Community Based Projects. for Teaching Environmenlal Engineering Design," Mitsubisbi Foundation, $10,000, 1/98-!199. "Detached Plume Study in Portland Cement Manufacturing Plants-Part 1," Portland Cement Association, $122,500, 7198-9199. "Carbon Cycling in a Riparian Wetland of the Des Plaines River," Wetlands Research', Inc., $13,000, 6/97-6/99; Evaluation of the Denitrification Potential ofWetlands, $55,000, 6,99-6/00. "Photocatalysis for Space Mission and Aircraft Applications," Allied Signal, S20,000/9/97-8/98. "Environmental Stress in Ecosystems: Linking Ecology and Engineering", Co-PI with Gary Lambcrli (liND), NSF Research Training Group in Environmental Biology, $537,500/(9/95-6/2000). Page 9 of 38

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·'Macrocosm Total Organic Carbon Analysis using Pyrolysls-GC-MS", Orange County \Va!er DislricJ-, S50,000**(8/94-3/96)~** Monitoring the Organic Quality of the Santa Ana River and Anaheim Lake by Pyrolysis-GC-:vrs, $50,000 (8/96-6/97). ('The Use of Pyrolysis-GC-MS to Evaluate Drinking Water Treatment Processes\ U.S. EPA, $232,813i2 years ( 19 93-1995). Extended to 6c'97. ·'lnstrumematlon and Laboratory lmprovemenl for Undergraduate Environmental Analytical Chemistry", witll CoPI, J ean-Francois Gaillard, NSF, S 137,512/3 years (6il5193-11/95). ··Removal of DBP Precursors by Granular Act(vated Carbon Adsorption", American Water Works Research Foundation, S40,000 ( 1/93-8/95). "Radiolytic Destruction of Organic Compounds", Occidenlal ChemicaL Corporatioo, S65,1J8/l year , v ..,ith co-Pl: R. L. Irvine (5/92-12/93), S73,766 as sole PI (l/94- 12!94), $55,231 ( l/95-6/97). ""Pilot and Laboratory Scale Studies of KDF Electrocl1emical Media'', KDF Fluid Treatment Jnc., $6,200/1 year ( 1994). "Characterization and Perforrnance ofPolyferric Sulfate Coagulants", Midland Resources, lnc., S7,000 ( 1191-12!91 }. "The Role of an Attached Algae Mat in the Fate of PCB.s in Artificial Stream Ecosystems", The Jesse H. Jones Faculty Research Fund, $8,500/1 year (7/91-7/92); NSF Planning Grant, $26,182/l year (4191-4/92). Presidential Young Investigator Av.,·ard, "Physiocochemical Processes iiJ Aquatic Systems", NSF, $500,000/5 years (7/91-7i96), ($312,500 from Sponsor/non .federal Matching Funds in excess of SIS7,000 h11ve been obtained). Extended to 12/97. "l\.1echanistic Studies of Photocatalytic Degnidation of Hazardous Organic Compounds In**Semi~conductor** Systems", NSF, $69,964/2 years, approved; declined due to PYT Award (1991). '(Coagulation Perfom1ance of Aqualenc'', Phone·Poulenc Chemical Company, $20,000 (l /90-6!9!). "Removal ofAlgal Material: Treatment Techniques and Mechanisms", Lyonnaise de-s Eaux, Paris, France, $1 !6,400 (4/90-12/93). "Request for Purchase of Combined Electrophoresis and Submicron Size Analyzer", Jesse H. Jones Faculty Research Equipment Fund, University ofNotre Dame, $19,050 (4/90-4/91 ). INVENTION DISCLOSURES/PATENT APPLICATIONS l. Photocatalytic Composite (Ti02 /SWCNT) for Organic Chemical Oxidation (provisional patent application NU 27068, filed), Y. Yao, R. Lueptow, K.A. Gray. 2. Mixed-phase nano-structured Ti02 composite photocatalyst for energy and energy efficiency applications, (provisional patent application NU 27093 ) G. Li & K.A. Gray. 3. Reactively sputtered Ti02 nanocompositc thin films for photoreduction and photooxidation applications under UV and visible light, (PatentNo. US 8,202,820 B2 issued 06/19/12) L. Chen, M. Graham, K.A. Gray 4. Solvent-Exfoliated Graphene-Titania Nanocomposite Photocalalysts, (provisional patent application NU20ll059), Yu Teng Liang, Baiju Vijayan, Kimberly Gray, Mark Hersam.

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JOURNAl. and PEER-RI':VIEWED PUBLICATIONS
93. Daniel Finkel stein-Shapiro, Charlie Y.-H. Ts3i, Shllyou Li, Kimberly A. Gray (2012). "Synthesis ofhighenergy anatase mmorod.s via an**intermediau~** nanotube morphology," CPLEIT, DOl I0.1 0 I6/j.cplett.20 12.07.039. 92. Kalhryn N. Kalscheur, i'diguel Raja$, Christopher G. Peterson, JohnJ. Kelly, Kimberly A. Gray(2012). "Algal Exudates and Stream Organic Matter Influence the Structure and Function ofDenilrifying Bacterial Comm1.mlties,

.. Microbial Ecology, in press. 9 J. Olga Lyandres, Pongkam Cllaktbranont, Daniel Finkelstein Shapiro, Michael Graham, Kimberly Gray (20 12). 'The effects**ofpreft~rred** orientation in sputtered Ti02 thin films on the photooxidation efficiency of acetaldehyde," Chemistry ofA1alerials, in press. 90. Y.T. Liang, B. Vljayan, 0. L)'andres,K.A. Gra)', M.C. Hersam (2012).**~'The** effectofdimensionaJity on the photocatalysis ofcarbon-titania nanosJ1eet composites: Charge transfer at nanomaterial interfaces,'' Journal of Physical Chemisiry LeJtets, 3:1760-1765. 89. K.N. Kalscheur, R.R. Penskar, A.D. Daley, S.M. Pechauer, C.G. Peterson, J.J. Kelly, K A. Gray (20 12), ''Effects ofanthropogenic inputs on the organic quality ofurbanized streams," Water Research, 46: 2515-2524 DOl: 10.10 16/j.watres 2012.01.043. 88. K. Schwartzenberg, K.A. Gray (2012). "Nanostructured Titania: The Current and Future Promise ofTitania Nanotubes./' Ca!alysis Science and Technology, 2 (8), 1617- 1624; DOl: 10.1039/C2CI'00538G. 87. Baiju K. Vijayan, Nada M. Dimitrijevic, Danit'! F. Shapiro, Kimberly A Gray (20 12). "Coupling titania nanotubes and carbon nanotubes to create photocatalytic nanocomposites," ACS Caralysis 2, 223-229. 86. P.A. DeSario, J. Wu, M.E. Graham, K.A. Gray (:i012). "Nanoscale structure ofTI 1.:xNb..,.Oz mixed phase thin films; Distribution ofcrystal phase and dopants," Journal of Materials Research, 27:94.4-950 (DOI:l0.1557/jmr.201 1.449). 85. Alan Danon, Kaustava Bhattacharyya, Baiju K. Vijayan, Jurrling Lu, Dana J. Sauter, Kimberly A. Gray, Peier C. Stair, and Eric Weitz (2012). "The Effect ofReactor Materials on the Properties ofTitanium Oxide Nanotubes,"ACS Cata/y;<is, 2 (l), 45-49. 84. D. Finkelstein-Shapiro, A.M. Buchbinder, B. Vijayan, K. Bhattacha:ryya, E. Weitz, F.M. Geiger, K.A. Gray (20ll). '"Elucidation ofseveral types ofbinding sites for the adsorption ofacetaldehyde on the surface of titania nanorods.," Lm1gmuir, 27, 14842-14848-.
83. N.M. Dimitrijevic, T. Rajh, B. Vijayan, K.A. Gray (2011). "Photocatalytic Reduction ofC0 2: Probing Structure ofPhotocatalysts md Mechanism ofC0 2 Transformation," ECS Transactions, 35 (25) 167-171. 82. Y. T. Liang, B. Vijayan, K.A. Gray, M.C. Hersam (20 II). 11Minimizing Graphene Defects Enhances Titania Nanocomposire-Based Photocatalytic Reduction ofC02 for Improved Solar Fuel PrOduction" Nano Leuers, 11, 2865-2870. 81. P.A. DeSario, K.A. Gray (2011) "Passive Systems: Using every surface in the built environment,'' in Handbook ofMetropolitan Sust.ainability: Understanding and Improving the BuiJt Environment. F. Zeman, ed. (Woodhead Publishing Ltd), Ch. 15, in press. · 80. C.G. Peterson, A.D. Daley, S.M. Hell, K.N. Kalscheur, M. Sullivan, S.L Kufta, K.A. Gray, JJ. Kelly (201 1 )

.

..Development ofmicroalga1/bacterial-denitrifier associations in streams of contrasting anthropogenic influence," FEMS Microbiology Ecology. 77,477-492. 79. J. Wu, S. Lo, K. Song, B. Bijayan, K.A. Gray, V.P. Dravid (201 1). "Growth ofrutile Ti0 1 nanorods above anatase Ti02 thin films on Si-based**substrates,~'** Journal of Materials Research 26:1646-1652.
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78. Luciana Zanella, Francesca Casadio; Kimberly A. Gray, Richard \Varta, Qing Ma and Jean-Fram;:ois Gaillard (20 ll ). "The Darkening ofZinc Yello\v: XANES Speciation ofChromium in Artist's Painls after Ligllt and**Chemic<~**I Exposures," Joumal ofAnofrrica!Atomic Spectromeny, 6, 1090-1 097. 77. P. Desario, L. Chen, M.E. Graham, K.A. Gray (2011) "The elTect of oxygen deficiency on the photoresponse and reactivity oftitania thin lllms," JVSTA, 29:03 1508-3 I515 doi: 10. IJ I6/1.3574350.
76. K.A.Oray (201 1). "Five Myths about Nanotechnology in the Current Public Policy Debate: .A science and engineering perspeclive." in The Nanotechnology Challenge: O·earing Legal lnstitntimu: for Uncertain Risks (David Dana, editor, Cambridge Press), Sept. 20 I I, Ch 2, 11-60.
75. N.M. Dimitrijevic, B. Vijayan, O.G. Poluektov, T. Rajh, K.A. Gray, H. He; P. Zapol, Peter (201 I) "Role of \Vater and Carbonates in the Photocatalytic Transformation ofCO:! lo CI-1 4 on Titania," JACS, 133:3964-3971. 74. P.A. DeSario, R.M. Gelfand, M.E. Graham, K.A. Gray. (2011) "'The effect ofNb substitntion on synthesis and-**photo-rcspons~** of Ti02 thin films prepared via reactive magnetron sputtering." Thin Solid Films. 5!9:1 1:3562-356. 73. \1. Lindsey, J.L. Schafer, P. Durango-Cohen, K.A. Gray (2011) "The Effect ofResidential Location on Vehicle Miles ofTravel, Energy Consumption and Greenl-.ouse Gas Emissions: Chicago Case Study," Transportation ReseArch, Part D, 16:1-9. 72. C. Ng, K.A. Gray (20 II) "Forecasting the effects ofglobal change scenarios on bioaccumu1ation patterns in Great Lakes Species," Global Change**810/ogy~** 17, 720-733 (DO!: I0. lll!/j.l365-2486.201 0.02299.x). 71. B. Vijayan, N.M. Dimitrijevic, J. \Vu, K.A. Gray (2D10) "The effects of Pt-doping on the struclure and visible light pholoactivity oftltania nanotubes," Jour. Phys. Chem. C, I 14. 21262-21269. 70. F. Casadio, S. Xie, S. Rukes, B. Myers, K. Gray, R. Warta, l. Fiedler (201 0) '".Elecfron E11ergy Loss Spectroscopy ducidates the elu:>ive**d<~rkening** ofzinc polnssium chromate in Georges Seurat's A Sunday on La Grunde**Jau~** '"' 1884," Analy!h:al mnfBiocma!ytical ChemiSI)', (DO I 10. l007/s00216-0 10-4264-9). 69. M. Lind..l:'.;ey, J. L. Schoif!:r, P_Durango-Cohen, K.A. Gray (201 0) "Relationship betv

..•een Proximity to Tran,.;it and Ridership for Journey-to-Work Trips in Chicago," 7l·ansporrarion Research, Part A, 44:697-709 (doi:l0. I016/j.tra.20 I0.07.003). · 68. B. Vijayan, N. Dimitrijevic, T. Rajh, K.A. Gray. (2010) '"Effect ofcalcination temperature on photocatalytic reduction and oxidation ofhydrothermally synthesized titania nanotubc," Jour. Phys. Chem. C, 14:30:12994- 13002. 67. K. Schulte, P. Desario, K.A Gray. (2010) "Effect of Crystal Phase Composition on the Reductive and Oxidative Abilities ofTi02 Nanotubes under UV and Visible Light/' Applied Catalysis B, 97:3-4:354-360. 66. S. Ciston, R.M. Lueptow, K.A. Gray (2009) "Control ofBiofilm Growth on Reactive Ceramic Ultrafiltration Membranes," Joumal of Afembrc.rne Science, 341, 263-268. 65. L. Chen, M.E. Graham, K.A. Gray (2009) ''Nitrogen stabilized reactive sputtering ofoplimized Ti02.x: photocatalysts with visible light reactivity," Journal Vacm1m Science & Technology, 27(4):712-715. 64. C. Ng, K.A. Gray (2009) "Tracking bioaccumulation in aquatic organisms: 

### A dynamic model integrating life history characteristics and environmental change," EcologicallvfodeliJJg, 220, \266-1273. 63. L Chen, M.E. Graham, G. ·Li, D. Gentner, K.A. Gray (2009) ''Photoreduction of CO, by Ti02 Nanocomposties Synthesized through Reactive DC Magnetron Sputler Deposition," Thin SolidFilms, 517:5641.-5645. 62. G. Li, N.M. Dimigtrijevic, L. Chen, T. Rajh, K.A. Gray (2008). "Photoactive CuO-TiO, Nanocomposites Prepared by a Chemical Method,'' Jour. Phys. Chern. C, IJ2, 19040-!9044.
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6J. y_ Yao, G. Li, K.A_ Gray, R.M. Lueptow (2008) "Single-walled Carbon Nanotube Facilitated Dispe1·sion of Pnrticulate Ti0 2 on**ZrO~** Ceramic Membranes," Langmuir, 24:7072-7075. 60, F. Casadio, K.A. Gray, R. Warta, I. f-ied!er(2008) '"Deterioration ofZinc Potassium Chromate: Elucidating the effects ofpaint composition and em·ironmental conditions on chromatic alteration," I COM Comminec tbr Conservation, 15 111 Triennial Meeting,**Nev~ 1**  Delhi, India (James and James Publishers) in press. 59. C.A. Ng, M B. Berg, D.J. Jude, !.Janssen, P.M. Charlebois, L.A.N. Amaral, K.A. Gmy. (2008) "Chemical amplification in an invaded tbod web: Seasonality and ontogeny in a l1igh biomass, low diversity ecosystem." Em:;ronmental Toxicology and Chemisoy, 27:145-154. 58. Y. Yao, G. Li, R.M. Lueplow, K.A. Gray, (2008) ·'Photoacfive Ti02-Carbon Nanotube Composites: Synthesis and Environmental Application," Environ. Sci. Techonol., 42:4952-4957. 57. G. L1, N.M. Dimitrijevlc, L Chen, J.M. Nichols, T. Rajh" K.A. Gray (2008) ''The Import-an\ Role ofTetrahedral Ti4.;. Sites in the Phase Transformation and Photocatalytic Acndty ofTi02 Nanocomposites," JACS, 130:5402- 5403. 56. S. Ciston, R. Lueprow, K.A. Gray, (2008) «Biotilm Attachment Studies on Reactive Ceramic Ultrafiltration Membranes," Joumal of Membrane Science, 320:101-l07. 55. G. Li, S.M. Cisron, Z.V. Saponjic, Le Chen, N. DimiLrijevic, T. Rajh, K.A. Gray (2008). "'Synthesizing mixedphase Ti02 using il bydrothenmll method for photo-oxidation and photo-reduction applications," Journal of Catalysis, 253:105-110. 54. C.K. Ishida, S. Arnon, C. Peterson, J.J. Kelly, K.A. Gray, (2008) "The influence of algal community structure on denitrification rates in periphyton cultivated on artificial substrates," J.\1icrobial Ecology, _56; 140-152.
53. G. Li, K.A. Gray (2007) "Visible Light Photocatalytic Properties of Anion-Doped Ti02 Materials Prep-ared from a Molecular Titanium Precursor," Chemical PhysicsLerters, Vol 451/1-3 pp 75-79.
52. S. Amon, C.G. Peterson, K.A. Gray, AI. Packman. (2007) "Influence of Flow Conditions and System Geometry on Nitrate Utilizati.on by Benthic Biofilms: Implications tOr Nutrient Mitigation," Environmental Science & Technology, 41:8142-&148.
51. G. Li, K.A. Gray, (2007) "The solid-solid interface; Explaining the high and unique photocatalytic reactivity of TiOTbascd nanacomposite material_s,'' ChemicalPhysics, 339:1-3: 173-187 (Jlol:l.Q.J_QJ_§ls:hemr:ll!Y§)_ 007.05.**{_!;~).** 50. G. Li, L. Chen, M. Graham, K.A. Gray, (2007) "A comparison ofmixed phase titania photocata[ysts prepared by physical and chemical methods: The imporrance of the solid-solid interface." Journal ofMolecular Catalysis A: Chemical, 275:30-35. 49. S. Amon, K.A. Gray, A.l. Packman, (2007) ''Biophysicochemica[ process coupling controls nitrogen use by benthic biofilms." Limnol. Oceanogr. 52: 1665-1671.
48. G. Lil K.A. Gray (2007). "Preparation of Mixe-d-phase Titanium Dioxide Nanocomposites via Sohothenna] Processing." Chemistly ofMalerials, 19:1143-1146.
47. S. Ciston, K.A. Gray (2007). ""'Pholocata1ysis for Water Recovery: importance of nanoslmcture in reactive membrane filtration," G.I.T. Laboratory Journal, 11:36-37.
46. C, Liu, K. Nakano, E. Obuchi, T. Oike, N. Yukihira, D. Hurom, J(.A_ Gray (2007). "Photocatalytic decomposition of formaldehyde using titania coated lime tile," Jour. of Advanced Oxidation Technolog;es 10 (1): 11-16. Page !3 of 38

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45. S. Arnon, A 

### r. Packman, C.G. Peterson, \CA. Gray (2006) "The effects of overlying velocily on periphyton structure and denitrification," Journal of Geophysical Resea!'ch, J 12.001002, doi:IO.l029/2006JG000235.
44. L Chen, tvLK Graham, G. Li, K.A. Gray (2006) "Fabricating Highly Active Mixed Phase TiO:::! Photocatalysls by Reactive DC Magnetron Sputter Deposltion," Thi11 Solid Films, 5: 5(3):I ]76-1181. 43. C.K. Ishida, J.J. Kelly, K.A. Gray, (2006) "E!Tecls 

## or variable hydroperiods and water level lluctuations on the denitrdicatiOll capacity, nitrate removal, and benthic microbinl conumtnity structure in constmcted wetlands," Ecologfca!Engineering, 28:363-373.
42. T. Slrivedhin, K.A Gray, (2006) c•factors Affecting Denitrification Rates in Experimental Wetlands: Field and LRbomtnry Studies," Ecological Engineering, ?.6: 167-181.
41. D.C. Hunn11, A. G. Agrios, S.E. Crist, !CA. Gray, T. Rajh, M.C. Thurnauer, (2.006) "Probing reaction mechanisms in mixed phase TiO:: by EPR," Jozmwl of Electron Spectroscopy, 150:2-3:155-163.
40. T. Sirivedhin, K.A. Gray, (2005) "Identifying Anthropogenic Markers in Surface Waters Influenced by Treated Effluents: ATool in Potable Water Reuse,"**H~"ater** Research, 39: 1154-1 l64.
39. T. Sirivedhin, K.A. Gray, (2005) "Comparison of the Disinfection Byprodtlct Fonnation Potentials between a Wastewater Effluent and Surface Waters,"**~'Vater** Research, 39:1025-1036.
38. D. Hurum, K. Gray, T. Rajh, M. Thumaoer,-(2005) •=Recombination Pathway!> in the Degussa P25 Formu!atinn ofTi02 : Surface versus Lattice Mechanisms," J.Phys. Chem B. 109:977-980.
37. A. Agrios, K. Gray, E. Weitz, (2004) "Narrow Band Irradiation of Homologous Series of Chlorophcnols on Ti0 1 : Charge Transfer Complex Fonnation and**Reactivit~."** Langmuir, 20, 5911-5917
36. D. Hurum, K. Gray, T. Rajh, M. Thurnauer, (2004) "Photo-initiated Reactions of 2,4,6-TCP on Degussa P25 formulation Ti02: Wavelength Sensitive Decomposition,"J.Phys. Chem.B, I08:16483-16487. 35. H.J. Binns, K.A. Gray, T. Chen, M.E. Finster, M. Peneff, P. Schaefer, V. Ovsey, J. Fernandes, M. Brown, B. Dunlop, (2004) ';Evaluation of Landscape Interventions to Reduce Potential Exposure to Lead-Contaminated soil in Urban Residential Yards; The Safer Yards Project," Envlronmenwi Research, 96:127-138.
34. M.E. Finster. K.A. Gray, H. Binns, (2004) "Lead Levels of Vegetables Grown in Contaminated Residential Soils: A Field Survey," Science of the Total Environment, 320,**24~-257.** 33. J.A. Kastel, KA. Gray A. StAmand, (2003) ''The Impact of Metal and Organic Contaminants on the Structure of Periphyton in Lotic Sediments: Observations at Various Scales," International Journal of Sediment Research, 18:2;214-222.
32. D.C. Hurum, A.G. Agrios, K.A. Gray, T. Rajh, M.C. Thumauer, (2003) "Explaining the Enhanced Photocatalytic Activity ofMixed Phase Ti02 Using EPR," J.PhysChemB, val 107, pp. 4545-4549.
31. A. Agrios, K.A. Gray, E. Weitz, (2003) "Photocatalytic Transformation of 2,4.5-Trich1orophenol on TiOz Lmder Sub-bandgap Illumination/' Langmuir, 19, 1402-1409.
30. M. Bonifacic, K-D. Asmus, K.A. Gray, (2003) '"On the Reaction of 2,4,5-Trichlorophenol with hydroxyl Radicals: New Information on Transients and their Properties,".!. Phys. Chern A, 107, 1307-1312.
29. G.A. Zacheis, K.A. Gray and P.V. Kamat, (2001) ':Radiation induced catalytic dechlorination of hexachlorobenzene on oxide surfaces,'' Journal of Physical Chemistry B, 105:4715-4720. Page 14 of38

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28. G.A. Zacheis, K.A. Gray, P.V. Kamat (2000) "Radio!ylic reduction of hex:achlorobenzene in surfactant solutions: A**stcady-st~lte** and pulse radiolysis study." Em 1fron. Sd. Techno/. 34:3401-3407. 27. J.A. Kastel, H. Wang, A. StAmand, and K.A. Gray, (1999) «1. Use ofa Novel Loboralory Stream System to Study the Ecologicallmpact ofPCB Exposure in a Periphytic Bioluycr," Water Research, 33: J 8:3735-3748. 26. H_ Wang, J.A- Kastel, A. SLAmand, and K.A. Gray, (1999) ·'2. The Response of a Laboratory Stream System to PCB ExpoSL\re: Study of Periphytic and Sediment Accllmulation Pauerns," Water Research, 33:18:3749- 3761' 25. G.A. Zacheis, K.A Gray and P.V. Kamat, ( 1999) "Radialion-lnduced Phenomena on Oxide Surfaces: Catalytic Degradation of Hexachlorobenzene on Alumina Nanoparticles," Jmwnal of Physical Chemistry B, 103:2142- 2150. 24. D.C. Schmclling, K.A. Gray, and P.V. Kamal, (1998) "Radiolylic Behavior of2,4,6-Trinitroroluenc in Aqueous Soll1tion." Environmental Science and Technology, 32:7:971-974. 13. K.A. GrJy rmd M.R. Cleland, [1998) "Environmental Radiolysis for Soil and Sediment Treatment: Comparison of Gamma and High Energy Eleclron Beam Systems.." Jovrnal of Advanced Oxidation Technologies, J:I:22-J6. 22. Ulick Stafford, Kimber!y A.· Gray and Prashant V. Ki:lmat, (1997) "'Pholocalalylic Degradation of 4- Chlorophenol. A Mudel." Research on Chem.icallnrermediores, 23:4:3j5-388. 21. D. C. Schmelling, K. A. Gray and P. V. Kamat, (1997) 1'The lmract of Solution Matrix on the Pbotocatalytic Degradation ofTNT, 1' fVafer Research, 31 ;6:1439-1 447. 20. U!ick Stafford, Kimberly A. Gray and Prashant V. Kamat, (1997) "Photocatalytic Degradation of 4- Chlurophenol. The Effects oJ" Varying**TiO~** Concenlru!ion and Light Wavelength," Journal of Catalysis, 167:25-32. ]9. D. L. Widrig, K. A. Gray and K. S. McAuliffe, "Removal ofAlgal-derived Organic Material by Preozonation and Coagulation: Monitoring Changes in Organic Quality by Pyrolysis-GC-MS, 11 (1996) Water Research, ]0;1 1:2621-2632, 18. D. C. Schmelling, K. A. Gray and P. V. Kamat, (( 996) 11The Role of Reduction m the Photocatalytic Degmdation ofTNT," Errvironmental Science & Technology, 30:2547-2555. 17. Ulick Stafford) Kimberly A. Gray and Prashant Kamat, "Photocatalytic Degradation of Organic Contaminants; Halophenols and Phenols," (1996)Helerogeneous Chemistry Reviews, Vol. 3, 77-104. 16. M.S. Dieckmann and K.A. Gray, (1996) "A Comparison of the Degradation of 4-Nitrophenoi via Direct and Sensitized Photocatalysis in Ti02 Slurries," Water Research, 30:5:1169-1183. I 5. R.J. Hilarides, K.A. Gray, J, Guzzetta, N. CorteUucci, C. Sommer, (1996) "The Radiolytic Degradation of 2,3,7,8-Telrachlorodibenzo-p-dioxin on Soil: Feasibility, System Design and Economic Evaluations," Wafer Environment Research, 68:2:178-187. 14. KA. Gray and RJ Hilarides, "Radiolylic Treatment ofDioxin Contaminated Soils," (1995) Radiation Physics and Chemistry, 46:4-6:1081-1084. 13. D.C. Schmelling and K.A. Gray, "Photocatalytic Transformations and Mineralization of 2A,6-Trinitrotoluene (TNT) in Ti02 Slurries," (1995) Water Research, 29;12:2651-2662. 12. K.A. Grny, C.R. O'Melia, and C, Yao, (1995) "Inorganic Metal Polymers; A Comparison of Aluminum and Iron(III) Polymers for Water Treatment. I. Preparation and Chardclerization of Polymers," Journal of American Water Works Association 87:4:136-146.
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II. R. Baretto, K.A. Gray, and K. Anders, "Plwtocatalylic Degradation of Methyl-ten-butyl Fther in TiO: slurries: A Proposed Reaction Scheme,'' (1995) Wafer Research, 29:5:1243-1248. I0. lt.J

. .1-lilarides, !CA. Gray, J. Guzzetta, N. Cortcllucci, and C. Sommer, ''Radiolytic Degmdation of 2,3,7,8- TCDD in Ar!Hicially Contaminated Soils," (1994) Environmenlal Science and TechT?ology, 28:13:2249-2258. 9. K.A. Gray and U. StaHord, "Probing Photocatalytic Reactions in Semiconductor Systems: Slndy 

## or Chcn1ical [ntermediares in 4-Chlorophenol Degradmion by a Variety of Methods," (1994) Research on Chemical Jnrermediales, 20:8:8]5-853. 8. R.J. Hilarides, K.A. Gray, L Guzzetta, N. Cortellucci, and C. Sommer, (1994) "Radiolytic Degradation of Dioxin on Soil: Optimal Conditions and Economic Considerations," Enviromnenta/Progress, 13:4:263-268. 7. K. Vinodgopal, U. Stafford, K.A. Gray, and P.V. J.<.mat, (1994) "Electrochemically Assisted Photolysis. II. Tbe Role or Oxygen and Reaction lnlcrmcdiales in the Degradation of 4-chlorophenol on Immobilized Ti02 Particulate Films," Jovrnal of Physical Chemistry, 98:6797-6803. 6. Ulick Stafford, K.A. Gray and P. V. Kamal, (1994) "Radiolytic and Ti02-assisted Pholocatalytic Degradation of 4-Chlorophe-noL A Comparative SLUdy," Joumu/ of Physical ChemisfJy, 98:6343-6351. 5. M.S. Dieckmann, K.A. Gray, and R.E. Zcpp, (1994) "The Sensitized Photocatalysis of Azo Dyes in a Solid System: A Feasibi 1ity Study,'' Chernosphere, 28:5:1021-1034. 4. U. Stafford, K.A. Gray, P.V. Kama4 and A. Varma, (1993) "An in situ Investigation of Photocatalytic Degradation of4-Chlorophenol on a Ti02 Powder Surface By FTIR Spectroscopy,'' Chemical Physics Lelfers, 205:1;55-61. 3. M. Dieckmann, K.A. Gray, and P. Kamat, (1992) "Photocatalyzed Degradation of Adsorbed Nitrophenolic Compounds on Semiconductor Surfaces," Water Science and Technology, Vol. 25, No. 3, 277-279. 2. K.A. Gray, (1991) "Direct Filtration of Model and Natural Waters: The removal of turbidity versus natural organic carbon," Warer Supply, 9, 521-525. l. K.A. Gray, F. Bernazeau, C. Hubele, (1989)**'~Upgrading** a slow sand filtration plant for micropollutant MANUSCRIPTS (in review) K.A. Gray, D. Farr, A. Hughes, D. Dana, W. Drucker, M. Lindsey, T. K. Kirkby, K. Gong, (2011). "Living Cities: Transfom1ing APECs Cities into Models ofSus1ainabillty by 2030." (under consideration by John Wiley). B. Sikora, J. Sirk, M. Lestina, K.A. Gray, M. Morowltz (20 II). "Estimate of the C02 emissions associated with care for pediatric appendicitis in the U.S.,'' Joumal of Pediatric Surgery, in review.
Daniel Finkdstein-Shapiro, Sarah J. Hurst, KimberlyA. Gray, Nada Dimitrijevic, Tijana Rajh, Pilarisetty Tarakeshwar, Vladimiro Mujic.a (2011). "C02 pre-activatlon vla the dectronic coupling with the charge transfer state ofTiOz.-aminosalicylic acid complexes," JACS, in review.
K. Bhaltacharyya, A. Danon, B. Vijayan, K.A. Gray, P.C. Stair, E. Weitz (2011 ). "Tbe role oflhe surface lewis acid and basic sites in the adsorption ofC0 2 on titania nanotubes and platinix.ed titania nanotubes: An in situ FT-IR study," Jour. Phys. Chem., in review.
T. Tong, C.T.T. Bihn, J.J. Kelly, J-F Gaillar, K.A. Gmy (2012). "Cytotoxicity ofcommercial nano-Ti02 to· Escherichia coli using high-throughput analysis: The effects ofenvironmental conditions," Environ. Sci. Trtchnoi., in review. Michael D. Marsolek, Mary Jo KirisiiS, Kimberly A. Gray, and Bruce E. Rittmann (2012). "Coupled photocatalyticbiodegradation of2,4,5-trich1oropheno1: effects ofphotolytic and photocatalytic effluent composition on bioreaclor Page 16 of38

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## ***proc~ss** performance, community diversity, and resistance o.nd resilience to perturbation,') Water Research, in review.
Jie Sun, John Janssen, Kimberly A. Gray, and Adilson E. Motter (20 12). "Historical Data Reveal Regular Growth Rate Fluctuations Despite Seemingly Erratic Population Abundances," :Vature Communh:arions, in review. \lONOGRAPHS AND BOOK CHAPTERS (*indicates Peer Review)
A. Agrios, K. Gray, (2005) "Beyond Photocata[y(ic Environmental Remediation: Novel Ti02 Materials and Applications;' in Environmental Catalvsis, V. Grassian, ed. (Marcel Dekker), Ch. 15, 369-390.
M. Starkey, K. Gray, SJ. Chang, M. Parsek, (2004) ''A Sticky Business: The EPS Matrix. ofBacterial Biofilms", in Microbial Biofilms, M. Ghannoum and G. A, O'Toole, eds. (ASM Pre::;s), Chapter 10.
B.A. Ankenman, K.A. Gray, (2001) "The Detached Plume Study: Statistical Analysis of Causative Factors in Portland Cement Manufacturing Plants." (Port! and Cement Association, Skokie, II) 112 pages. K.A. Gray, (2000) ''The Establishment of Stream Standards for Total Organic Carbon: Scientific and Engineering**Basis~"** testimony before Colorado \:Vater Quality Board.

*- K.A. Gray, A.H. Simpson and K.S. McAuliffe, "Use o[PY-GC-MS to Study the Nature and Behavior ofNOM in Water Treatment." In Water**Di.YiJ~fection** and Natural Organic Mauer, Roger Minear and Gary Amy, eds. (ACS SymposiumSeries649, Washington, O.C., 199fr) 159-IRl.
*R.J. Hilorides, K.A. Gray, J. Guzzetta, N. Cortellucci, and C. Sommer, "Degradotion of Chlorin'dted Dioxins on Soil using 60co Gamma Radiation: Considerations and OpLimiation," 'in Chemical O.Tidation: Technologyfor !he 90's, Vol.**4~** J, Roth and A. Bowers, eds. (Technomics, Lancaster, PA; 1996) 205-218.**~D.C.** Schmelling and K.A. Gray, "Photocatalytic Transformations of TNT in Titania Slurries: An Analysis of the Role .of Interfacial Nitrogen Reduction Utilizing g-Radiolysis," in Chemical Oxidalion: Technologyfor 1he 90's, VoL 4, J, Roth and A. Bowers, eds. (Technomics, Lancaster, PA, 1996) 173-184.
*U. Stafford, K.A. Gray, and P.V. Kamat, "Photocatalytic Oxidation of 4-Chlorophenol on Titanium Dioxide: A Comparison with g-Radiolysis," in Chemical Oxidation: Tcchnoldgyfer the 90's, Vol. 4, J. Roth and A. Bowers, eds. (Technomics, Lancaster, PA, 1996) 193-204. "'L. Weitzman, K.A. Gray, R.W. Peters, F.K. Kauahara, and J. Verbicky, {1994), Innovative Site Remediation Technology, VOl. II: Chemical Treal/ne.nt, American Academy ofEnvironmental Engineers, Annapolis, MD 1 200 p. *-K.A. Gray, P. Kamat, U. Stafford, and M. Dieckmann,

..Mechanistic Studies of Chiaro- and Nitrophenolic Degrndalion on Semiconductor Surfaces," Environmental Aspects of Surface and Aquatic Photochemistry, D. Crosby, R. Zepp, and G. Heitz, cds., (Lewis Publishcrs/CRC Press, 1994) 399-408.
D.C. Schmelling and K.A. Gray, "Feasibility of Photocatalytic Degradation of TNT as a Single or Integrated Treatment Process,"_TiO, PhotocaLalyJ,ic Purification and Treatment ofWater and Air, David Ollis and Hussain AlEkabi, eds., (Elsevier Publishers, 1993), 625-632.
K.A. Gray, U. Stafford, M.S. Dieckmann, and P. Kamat, "Mechanistic Studies in Ti02 Systems: Photocatalytic Degradation of Chioro- and Nitrophenols," TiO, Photocatalytic Purification and Treatment ofWater and Air, David Ollis and Hussain Al-Ekabi, eds., (Elsevier Publishers, 1993), 455-472. *C.R. O'Melia, K.A. Gray. C. Yao, Polymeric },fetal**Coagulant~·,** American Water Works Associalion Research Foundations, Denver, CO, 1989,
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T.D. \Vaile, K.A. Gray, "Ox1dation and coagulation of wastewater eflluent utilizing the fen1l.le(VIJ ion," in ChemisliJ'fOr Protection of/he Envirnnmenl, J•. Pawlowski, AJ. Verdier, cmd W.J. Lacy, editors (Elsevier Science Publishing Co., 1984) pp. 407-420.

CONFERENCE PROCEEDINGS
D.L. Widrig, K.A Gray and K.S. McAuliffe, 1996. Removal of Algal-Derived Orgcmic Material by Preozonation and Coagulation: Monitori11g Changes in Organic Quality hy Pyroysis-GC-MS, in Proceedings of AWW'A 1996 Armoal Conference. K.A. Gray, A.H. Simpson and K.S. McAuliffe, 1995. Use of PY-GC-MS to Study the Nature and Behavior of NOM in**W~ter** Treatment, in Proceedings of the 21Dth ACS Nalional Meeting, 35:2:635-638. U. Stafford, K.A Gray and P.V Kamat,_l995. Kinetic Modeling of4-Chlarophenal Degradation in Titania Slurries, in Proceedings ofthe 210th ACS National Meeting, 35:2:563-566. D.C. Schme!ling, K.A. Gray and P.V.**K::~mat,** 1995. The Role of Nitrogen Reduction in the**Photocatt~lytic** Degradation ofNitroaromatic Compounds, in Proceedings ofthe 210th ACS National Meeting, 35:2:484-486. K.A. Gray, 1995. Use of Ionizing Radiation to Destroy Pollutants, in Transactions of the American Nuclear Sociery, 1995 Annual Meeting, Philadelphia, PA, 72: l32-l33. K.A. Gray, 1994. Treatment of Soils and Sediments: Radiolytic Destrnction of Chlorinated Dioxins Using Cobalt60, Pages in Proceedings of NSF Workshop on Applications of Ionizing Radiation for Decontamination of Environmental Resources, Miami, FL. M.S. Dieckmann, K.A. Gray and P.V. Ka111at, 1994. The Sensitized Photocatalysis of a Mixed Reactant System of 4-Chlorophenol and 4-Nitrophenol. Pages 726-732 in Proceedings of the 1994 National Conference on Environmental Engineering "Critical Issues in Waterand Wastewater Treatment" (.I.N. Ryan and M. Edwards, eds.) American Society of Civil Engineers. K.A. Gray and R

..J. Hilarides, 1994. Innovative Treatment of Soil Contamination: Radiolytic Destnlction of Dioxin and Co-Contaminants by Cobalt-60. Pages 733-736 in Proceedings of the 1994 National Conference on Environmental Engineering "Critical Issues in \Vater and Wastewater Treatmenf) (J.N. Ryan and M. Ed\vards, eds.) American Society of Ci vii Engineers. D.C. Schmelting and K.A. Gray, 1994. Photocatalytic Transtbrmmion and Degradation of 2,4,6-trinitrotoluene (TNT) in Ti02 Slurries. Pages 751-755 in Proceedings of the 1994 National Conference on Environmental Engineering "Critical Issues in Water and Wastewater Treatment" (J.N. Ryan and M. Edwards, eels.) American Society of Civil Engineers. KA. Gray, A. St. Amand, and H. Wang, 1993. "Role of a Periphycic Biolayer in the Fate of PCBs in Artificial Stream Systems," Proceedings of the First International Specialized Conference on Contaminated Aquatic Sediments: Historical Records, Environmental Impact, and Remediation, (IAWQ), 271-280. K.A. Gray and K. McAuliffe, 1991. "Use of Pyro1ysis-GC-MS to Study the Organic Matrix of Surface Waters," Proceedings ofWaler Quality Technology Conference, AWWA, Part 11, November, 1991, 1219-1231.

PUBLISHED REVIEWS Book review ofRadioactive Waste Management (Y .S. Yang andJ.I-1. Saling) for EnvironmentalProgress. "Report on the First International Conference on Ti02 Photocatalytic Purification and Treatment ofWater and Air," published in European Photochemistry Association Newslecter (47:50-53) and the Inter-American Photochemical Society Newsletter_
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RESEARCH REPORTS
K.A. Gray (2008) "Hydrologic and Enviromncnlal EJYects of Hydraulic Conlrol Structures: Basdine Monitoring," Technical Report, The Wetlands Initiative, Chicago, II. C.K. Ishida, K.A. Gray (2005) "HydralJlic Effects on Biological Diversity and Water Qt1ality in Constructed \Vellat1ds," Final Reporl to U.S. Army Corps ofEngineers, febmary, 2005. K.A. Gray {200 I) "PhysicaI, Cilemic,ll, & Biological Characterizalion of Swam Lake Sediments," Technical Report, The \-Vetlands Initiative, Chicago, ll.
M.E. Flnster, K.A. Gray {1999)**"'Th~** Urban Heal Island, Photochemical Smog, and Chicago: Local Features oftlle Problem and Solution." Technical Report, Atmospheric Pollution Prevention Division, U.S.E.P.A. "Characterization of the Organic Matrix of the Missouri River by Pyrolysis/GC/MS," Burns and McDonnell, Febnmry, 1997.

1'Removal ofDBP PreCLirsors by Optin1ized Coagulation and Precipitative Softening: Use ofPY-GC-MS to Monitor Coagulation Effectiveness," American Water Works Research Foundation, October, [996. "Eva[Liation of Organic Qtlality in Prado Wetland and Santa Ana River by Pyralysis-GC-MS" Orange County Water Districl, April, 1996. ''Removal of DBP Precursors by Granular Activated Carbon Adsorption: PY-GC-MS Characlerization of Organic**Quality_'~** American \\.later ·works Research Foundation, Nov. [995.

11Monlhly Monitoring ofPrado Wetland Using PY-GC-MS/' Orange County \Vater District, May, 1995. "Pyro1ysis-GC-M.S Analysis of Various Contaminated Groundwater Samples;' lnstitut fUr Wasservorsorge, Universitiit ftir Bodenkllitm, (Vienna, Aus\ria), February, 1995. "Metal Ion Concenlrations in KDF Treated Ground-Waier," KDF fluid Treatment Inc., March, 1994. "Sa.fety Kleen Refinery V/aste Water Evaluation," Safety Kleen Corp., March, 1992. "Jar Test Results for Polyferric Sulfate: Comparison of Various \:Vaters and Other Coagulants," submitted to Midland Resources, February, 1992. 'The Role of Water Hardness in Perfonnance of Aqualenc for the Coagulation of Clay Turbidity,'' submitted to Rhone-Poulenc Chemical Company, July, 1991. •<Characlerization of Polyferric Sulfate**Solutions;~** submitted to Midland Resources, Inc. and Kemlron Inc., May 1991. ;'Radiolytic Destruction ofOrganics,'' submitted to Occidental Chemical Company, October 1991.

SIGMAXI DISTINGUISHED LECTURES Mercer University, Macon GA, Oct. 2,2008 Pennsylvania State University, Erie, PA, Oct. 16,2008 University ofNorthern Iowa, Oct. 23

.. 2008 Michigan SLate University, Nov. 6, 2008 Syracuse University) Nov. 13,2008 University ofWisconsin-Fox Valley, Nov. 17, 2008.. Army Research Lab, Adelphi, MD, Dec. 11, 2008 Trinily University, Jan. 26,2009 (2 talks) Pnrdue University, Feb. 3, 2009. Page 19 of38

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Western Washington University, Feb. 24,2009-2 lectures given. Western Kentucky University, Marcll2, 2009 University ofTennessee, Ylarch 17, 2009. Eastern Illinois University, April 2, 2009-2 lectures given. Cornell**Univer~ity,** April 7, 2009 PorLiand Stale Universiry, April21, 2009. Southern Oregon University, May 14,2009. Nalco, June 4, 2009 SUNY-Purchase College, Oct. 29,2009 University of'Ncbraskn, Nov. 19,2009 Mayo Clinic, Rochester, MN, Jan. 19,2010 South Dakota State University, February 25,2010 (2 talks) Youngsto\\·'n State Unh'ersity, Murch 4, 2010 Tarleton Slate University, March ll, 2010 (2 talks) University ofNorthern Michigan, March 18, 2010 (2 talks) Rollins College, March 25,2010 (2 Lalks) University ofLouisville, April I5-16, 2010 (2 talks) Rockford College, April 20, 2010 (2 talks) INVITED LECTURES "Why the energy issue is fundamenLally an environmental issue

...and why this doesn't seem to matter" State orthe Nntion: Election 2012. Alumnae Continuing Education Lecture Series, 6 Nov. 20 1.2. "'Living Cities: Avision to sustain the exploding megacities ofAsia and the shrinking cities of the North America," Vision Seminnr, Dept. ofCivil Engineering. Purdue University;25 April2012. "Li\'ing Cities: The rcdesii;n orcities inspired by ecological principles," keynote address at the Mid-west Environmental Leadership Summit, 15 April2012. "Living Cities: A vision to suStain the exploding megacities ofAsia and the shrinking cities of the Midwest," Environmental Engineering se111inar serie.c::, Marquette University, t1 March 20 12. "Living Cities: Transforming APEC Cities into Models of Sustainability by 2030," presentation to the Asia Pacific EC Business Advisory Committee, Hong Kong, 24 February 2012. "Potential Effects ofNanotitania in Benthic Systems," presented at IMI-SEE workshop, "Developing sustainable nanotechnologies: Maximizing Functionality \Vhile Minimizing Health Impact," at Sichuan University, Chengdu, China, Sept.l4,201L "Potential Effects ofNanomaterials on Human and Ecological Health," seminar at Geosyntec Consultants, Chicago, IL, 23 June 2011. "Sustainable Strides in Urbnn Design: Lessons from Chicago," Sci-Tech Seminar, US EPA Region V Science and Technology Counci' 20 April20 ll. ''The potential effects ofnanotitania in benthic systems," in Reactivity, Transformation and Detection ofNatural and Engineered Nanomatenals in the Environment Symposium (Division ofColloid & Surface Science), 241 sl ACS National Meeting, Anaheim, CA, March 27-31,2011. "Sustainable Strides: Lessons from Chicago" plenary presentation at the 2nd Xiarnen International Forum of Urban Environment, Xiamen, China, Dec. 11-13,2010. "Green Cities/Brown Lakes: The Challenge ofGreat Lakes Restoration,"**seminar~** Memorial Unl\•ersity of Ncwtoundland, Canada, Oct. 29, 2010. "Transforming our Cities: Sustainability and tbe Post Fossil-Fuel Future," Keynote.presentation, Dialogue on Advancing Global Sustainability, Memorial Unh•ersity ofNewfoundland, Canada, Oct. 28,2010 Page 20 of38

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"Sustainable Cities and tbe Many Dimensions ofa Post-Fossil fuel FutLJre," Carbon and Climate: Lessons from the Po.st, Solutions for the Ft1ture, .znd Annual Climate Change Sympositlm, NU, Oct. 18, 2010. "Green Cities!Brmvn Lakes: The Challenge ofGrenl- Lakes**Restoration,'~** The Women's Board of Northwestern, Sept. 21,2010. ·'The Debate on the Scientific Evidence of ClinH:tie Change" JL1dicial SymposiLllll on Public Nuisance Litigation sponsored by the Northwestern Law Judicial Education Program, Searle Center on Law, Regulation, and Economic Growth, Northwestern University School of**Law~** 27 April 20 [0. "Chemical and physical synthesis**oCTiO~-based** nanocomposites fOr solar energy production and other environmental applications," seminar in Dept. ofChemical Engineering, University ofLouisville, 15 April 2010. '"Fabricating Titania-based Nanocomposites for Solar Fuel Production. Ti0 2 -x,**Ti _:~-Nb),D** **,** & Titania Nanotubes/' NlMS lntemational Workshop on Photocatalysis and Envirommmta_J Remediation, TsukL1ba, Japan, 22-24 February 20!0.• "Tailoring Nanomaterials for Probing Environmental Systems: React, Identify, and Monitor,'' Workshop on Nano-Enabled Sensing Microsystems for Geosciences, Organized by the NSF Nationa: Nanotechnology Infrastructure Network (NNIN), Ann Arbor, Ml, 4 Febmary 2010 «Chemical and physical synthesis of TiOrbased nanocomposites for solar eftergy production and other enviromnental applicarion,·· Nebraska Center for Materials and Nanoscience and Physics colloquium, University of Nebraska, Lincoln. NE, 19 November. 2009. 'TheNanotechnology Revolution and its Unintended Environmental Effects,'' Encouraging appropriate use of the products ofscientific research: U.S.- Iran-France Workship, sponsored by NAS, Academic des Sciences, 7-12 November, 2009, Fondation des Treilles, France. "Progress on Synthesizing Photoactive Nanocompositc Materials to Produce Solar Fuels," Sino-U.S. Workshop on Nanostructured Materials for Global Energy & Environmental Challenges, Changzhou, China, Oct. 15-18, 2009. "What will finally spark that the Green Revolution?" One Book Science Cafe, 7 Oct 2009. •<Five Myths about Nanotechnology in the Current Public Policy Debate," CEE Seminar, 25 Sept., 2009. "Chemical and phy.!:r'ical synthesis ofTi02-based nanocomposites for solar energy production and other environmental application," Dept. ofCivil and Environmental Engineering, Rice University, Houston, TX, 21 September, 2009. '"Ecology and the Green Revolution,"' 61sl Annual Meeting ofrhe Association ofAmerican Universities, Chicago Botanical Gardens, 20 September 2009. 'The Feasibility ofAchieving Sustainability Goals in the Near-TeLm," Annual Meeting ofNorth American Management Team, Veolia Energy, 27 Aug. 2009. "Secrets ofthe Art World Unlocked: LeGrand Jatte," Chicago Council on Science and Technology, Art and Science, 8 June 2009. '"Sustainable Water Use in Cities and Industry: Future Challenges and Promising Strategies," Metropolitan Waler Reclamation District ofGreater Chicago, Luc-Hing R&D Laboratory Seminar Series, 29 May 2009. "FiveMyths about Nanotechnology in the CurrentPublic Policy Debate," Searle Center Research Roundtable on Environmental, Health, and Safety Rish of Emerging Technologies, Northwestern University School ofLaw, April 23 -24, 2009.

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"Sustainable Solutions to Energy, Water & Climate Challenges" in Globalizntion: The Next Stage, Ryan Lenrning for Life 2008 Lectures, Robert H. Lurie Medical Research Center, NU, 1\ov. 19.2008. "The Effects ofClimate Change on Transportation," Transportation Center Business Advisory Commii.!ee Meeting, NU, Oct. 22,2008 «Progress in de,•eloping photoactive nanocompositcs to improve the efficiency ofartificial pholosynihesis/' seminar in Ihe Depfl[tment ofGeography and Environmental Engineering, Johns Hopkins Un iversily, October 21. 2008. "Energy & the**Environment~** Election 2008: Inside the Issues'\ Classes v..•ithout Quizzes, Panel moderated by Les Crystal, NU, Oct. 17,2008. "Energy & the Environment The Central Challenge ofSustain<1bility," NU Club of Milwaukee, Oct. 7, 2008, «Photoactive 1\anocompositc Materi<1ls to Produce Solar Fuels," Sino-U.S, Workshop on Nanostructured Materials for Global energy & EnviromnentnJ ChnUenges, Sept 22, 2008. «Sustainable \Vnter Use in Cities and lmJustry: Future Challenges and Promising Strategles," 2008 lntemational Open Lecture Series on Business, Technology and Urban Life for a Sustainable Future, h1kuob University, Japan, July 18,2008. <"How sustainable does business need to be?" Environmental Sustainnbilily Business Club, Kellogg Business SchooL, North\\1estem, 29 May 2008, "'Solar fuel generation: Engineering photocatalytic ''hot spots" in Ti0 2-bascd nanocompositcs," Physics Colloquium, Northwestern University, 9 May 2008. •'The Sustainability Imperative: The need for interdisciplinary learning, teach.ing and research,'' Center for Environmental Studies, Brown University, 15 April 2008. «Second generation Ti0 2-based nanocomposites for solar fuel generation," Division ofEngineering, Brown University, 14 April2008. "Second generation TiOTbased nanocomposites for solar fuel generation," Department ofCivil Engineering. Duke University, 21 April 2008. "The Green Wave: Is there really anything to the sustainability buzz?" Science Cafe, Sigma Xi Scientific Research Society at Northwestern, April 16, 2008

.

..The modern American city: Can we ever make it sustainable?" seminar in Civil and Environmental Engineering at Temple University, February 27, 2008. '"What does Su!;tainahility mean for teaching, learning and living at a university?" Keynote address to Residential College Domain Dinner, Northwestern University, February 5, 2008. '"Structuring Highly Active**N<~no.scale** Photocatalytic Films using Reactive**Sputtering~"** presented in an Advanced Surface Engineering Division Session at the 54th AVS Symposium, 14-19 October, 2007, Seattle, \VA. "Progress in .synthesizing photo-active titania-based nanocomposites for C02 reduction and fuel production," seminar, Honeywell Aerospace & Environmental Quality Group, July 3, 2007. '"Probing the effects of light, humidity and acidity on th.e deterioration of a zinc potassium chromate pigment,'' Photochemical Processes in Art and other Standards, Seminar Series on Conservation Science, June 7, 2007. "Nanotechnology, Energy, and the Environment," inaugural seminar sponsored by the McConnick Graduate Student Leadership Council, Northwestern University, March 8, 2007.
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"'"Progress in synthesizing photo-active Litan**i~-baseJ** nanocomposites for C02 reduction and fuel production," scminar, DepL ofCivil and Environmental Engineering, Duke Univer.sily, 21 March 2007

_ "'The feasibility of developing sustainable energy sources for transportation;· 2007 SWE Regional conl'erence, Chicago, JL, 27 January 2007. ''Navigating the Choppy Seas of Science: Reflections on Careers in Environmental Science and Engi11eering," Women in Science & Engineering Symposium, Loyola University, July 27, 2006. "Energy and The Environ!llenl: The Central Challenge of Sustainabiiity," Keynote address at the 2006 Environmental Engineering Spring Symposium, University ofIflinois,**Urbana~Champaign,** March 31, 2006. "Detennining Structure/Ft.mction Relationships lor .Organic Carbon in Surface Waters: Reuse," presented to the Department of Hydraulics and Environmental Engineering at Catolica de Chile, Oct. 26, 2005. ApplicatiOn to Water Pontificia Univerisidad
'·Ecological Restoration in Aquatic System: The importance of understanding molecular scale phenomena in the big picture,'' Seminario lnternacional,**"Tran~;porte,** Reacci6n y Destino de Contaminante.s en Sistemas Acucittcos Narrrra!es lrnpactados "presented to Center for the Environment at the Pontilicia lJniversidad Cat61ica de Chile, Oct. 24, 2005. "Synthesizing and Characterizing Highly Active Ti02 Nanocomposite Photocatalysts" presented at TiOrlO, Chicago, JL, October, 2005.
"'Hmricane Katrina: An Ecological Perspective," presented in seminar Hurricane Katrina: Prepardtion, Response and Rebllilding, Northwestern University, Oct. 17, 2005. "Energy and Environmental Chemistry," presented at the Midwest Environmental Chen1istry Conference, October ]6, 2005.

11Nanoslructured photoactive materials for environmental applications", presented in Environmental Nanotechnology at the 23-0th ACS National Me:.-:eting, in Washington, DC, Aug 30, 2005.

11Radiation induced catalytic tmnsfonnation of organohalide contaminants", presented in Strategies and Molecular .Mechanisms of Contaminant Degradation Chemistry at the 230t11 ACS National**Meeting~** in Washington, DC, Aug 29, 2005.
''Future Cities," plenary lecture at the NSF Summer Institute on Nano Mechanics and Material, Nanotechnology, Biotechnology and Green manufacturing for Creating Sustainable Technologies, Northwestern University, June 22, 2005. "Nanocatalysis," presented at the NSF Summer Institute on Nano Mechanics and Material, Nanotechnology, Biotechnology and Green manufacturing for Creating Sustainable Technologies, Northwestern University, Jllfle 21, 2005.
"New Directions in Environmental Engineering and Chemistry:**Catalysis~** Anaiysis, Restorstion," presented at Fukuoka University, Kitakyushu, Japan, February 22, 2005.
"New Advances in the Study of Photoactive materials**for·]~nvironmental** Applications," seminar presented at the SPEA, Tndiana University, October 13,2004. "Impacts ofUrban Development on Soli and Water Quality: Characterization and Remediation;• semlnar presented in the Department,ofEnvironmental Science at the Ur1iversity ofIllinois-Urbana, March 12, 2004.
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"Environmental Engineering and Chemistry: Catalysis, Analysis, Restoration," seminar presented at Gas Technology Institute, Des Plaines, lL, Mny, 2003.
"Structure and Function ofEnvironmental Biofilms: Three Examples," seminar presented in tl1e Department of Civil Engineering at Case Western University, March, 2003. Tracking Organic Carbon Quality: Fingerprinting Techniques to Trace the Origins of Organic Material," seminar presented in 2003 Environmental Engineering Seminar Series, '·Barriers and Tncenlivc-; r-o Wastewnter Reme in Illinois," liT, March 26, 2003.
"The Impact of Metal and Organic Contaminants on the Stnrcture of Periphyton in Lotic Sediments," presented at the NSF funded US-Chinese Joint Workshop on Sediment Tnmsport and En\'iromental StL1dies, July, 2002. "feasibility ofApplying Phytoremediation in Urban Residential Communities," presented at tbe 130111 Annual \1eeting ofthe American Public Health Association, Philadelphia, PA, November 13, 2002. "·Radiolytic Dechlorination ofAdsorbed Pollutants in Various Matrices," presented in the Symposium on Radiation Chemistry at the 222th Annual Meeting of the American Chemical Sock:ty, Chicago, JL, Aug. 200I. "Monitoring the Impact of Organic Quantity and Qualily in Smface Waters: Two Case Studies," presented at IL AWWA Annual Meeting, Springfield, March, 2001.
'"The InflLJence of Organic Quantity and Quality in Aquatic Systems," seminar presented in Dept. of Chemistry, Purdue-Calumet, April, 200 L
"The Combined Effects of Metal and Organic Contaminants on a Periphytic Asselnblage in Lolic Sediments" presented in the Symposium on: The fnfluence of Hydrosphere-Biosphere Inleractions on the Speciation and Transport ofMetals at the fall Meeting of the**~merican** Geophysical Union, San Francisco, December, 2000.
"'Radiation-induced processes in the treatmenr of contaminated materials. Successes and Challenges.," Gordon Research Conference on Radiation Chemistry, Plymollth, New Hampshire, June 27,2000.
"Mechanistic lnsight into Soil Radiolysis,"· presenred in NSF Workshop, Determination of Optimum Radiolytic Treatment Methodologies for Remediation of PCB Contaminated Sites, University ofMaryland, Nov. 15-17, 1999, College Park, MD.
"Molecular Tools to Study Chemical Phenomena inn Environmental Systems," presented at the AEESP Research Needs Conference, Penn State University, Aug. l, 1999. "Jumping Through Hoops; The Promotion and Tenure of Women and**Minorities~"** presenled at the AEESP Research Needs Conference, Penn State University, July 31, 1999. "Photobiocatalysis: Optimized Treatment Strategy for Recalcitrant Pollutants," seminar presented to BP-Amoco researchers, June I, 1999.
"Detached Plumes and Visible Emissions in North American Portfand Cement Plants," presented lo MTC Semiannual Meeting, Roanoke, VA, April12, 1999. "Photobiocatalysis: fntegrating Chemical and Biological Catalysis for the Treabnent of Hazardous Chemicals," presented at the 21st Midwest Environmental Chemistry Workshop, University of Michigan, Ann Arbor, MI, Oct. !7, !998. "Photobiocatalysis: fntegralion of Photocatalysis and Biocatalysis," presented at the Center for Catalysis and Surfnce Science Annual Meeting, Evanston, IL. Sept. 9,1998. Page 24 of38

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"Environmental Applications-of Radiolysis," plenaJ)' lecture at DOE Workshop Research Needs and Opportunil·ies in R11diation Cbemistty**~** Cbeslerlon, IN, 19-22 April !998.
"NOM Structure: Pyrolysis/GC/MS versus 13C-NMR," presented in Sunday Seminar, -New Developments in Characterizing and Monitoring NOM in Water Treatment, A 'vVWA Water Quality Technology Conference, De-nver, CO. Nov. 9, 1991. '"Probing Dissolved Organic Carbon Dynamics in Natural Waters with Pyrolysis/GC/MS," presented to the Department

## or Geological Sciences, Northwestern University, Nov. 7, 1997. "Probing Dissolved Organic Carbon Character in Surface Waters," presented to the Department Of Environmental Engineering and**Scienc~,** Vnivcrsity ofNorth Carolina, Chapel Hill) .\1ay, 28. 1997.**"TiO~** Pbotocaialysis: Transfonnation of Aromatic Pollutants in**Parti~ulate** Semicondur.tor Systems." presented to the Catalysis Center, Northwestern University,**~-1ay** 9, 1997. "Probing the Organic Carbon Cycle in \Vetlands using Pyrolysis-GC-MS" presented in Natural Organic Matter in Aquatic Systems Session at American Geophysical Union 1996 Fall Meeting in San Francisco, CA, 15-19 December 1996. "Photocatalytic Behavior ofNitroarornatic Compounds in Ti01 Systems," presented to Enviromnen"k1.l Engineering at University ofIllinois, 25 April 1996. "Radiolysis at Environmental Surfaces: Radiolytic Transformation of Chlorinated Dioxins and Other Aromatic Compounds in Soils," presented at.the 44th Annual Scientific Meeting ofthe Radiation Research**Society~** April 17, 1996, Chicago, IL.
"A Comparison of Electron Beam and Gamma Irradiation to Destroy Halogenated AromHtic Contaminants on Soils,". to be**pr~se.nted** at the Second International Symposium, Environmental application of Advanced Oxidation Technologies, sponsored by EPRI and U.S. DOE, February 28-March I, 1996, San**Francisco~** CA.**"Photo~atalytic** Interactions of Nitroaromatic Pollutants in Ti02 Systems," presented to Pritzker Department of En\'ironmental Engineering at the Illinois Institute ofTechnology, 24 January 1996.
"Use ofIonizing Radiation for Reductive Dechlorination: Chemistry_. Design and Economics," presented at the 1995 International Chemical Congress ofPacific Basin Societies, December 17-22, 1995, Honolulu, Hawaii. "Predicting the· Course of 4-Chlorophenol Photocatalytic Degradation: Model Development and Design Implications," presented at the World Environmental Congress, Sept. 17-22, I995, London, Ontario. "Use ofionizing Radiation to Destroy Pollutants," presented at American Nuclear Society 1995 Annual Meeting, Juoe25-29, 1995, Philadelphia, PA. "Organic Chemical Transfonnations," presented at the Groundwater Recharge with Reclaimed Water Workshop sponsored by the \\'ateReuse Association ofCalifornia, 25 May 1995. ''Photocatalysis: Theory, Experiments and Models," presented 1o the DepL. ofCivil Engineering, University ofTexas at Austin, April, 1995. "Inorganic Polymers: Fundamental Aspects Related to their Use for Particle Removal and Dewatering," presented at the Annual Meeting ofthe Society ofMining Engineers, March 6-9, 1995, Den.ver, CO.

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"Radiolytic Transformation of Soil ContRminanls: A Comparison of Gamma and Electron Becm1 Irradia!"ion," presented to Nationallnstitu!e of'Standmds and Technology, Ionizing Radiation Division, Gaithersburg, :vlD, Dec. I, !994.
"The Wetland Environment: The Biogeochemistry a finland and Coastal Systems," presented at tbc Fall Meeting of the Indiana Academy of Sciences, Nov. 5, 1994. "Photocatalytic Oxidation of 8 :Ododel Halogenated Aromatic Compound: A Mecllanislic Study," presented to Photocatalysis, Catetlysis and EnYironment Group, Ecole Centrale de Lyon, Lyon, france, Oct. 27, 1994. "Organic and lnorganic Transformation Prodtlcts ofTNT Pholocatulysis," presented at "Emerging Technologies ln Hazardous \\taste Management VI," ACS, l&EC Division Symposium, Atlanta, GA, Sept. 19-21, 1994.
'"Radiolytic Treatmem of Dioxin Contaminated Soils," presented at the 9th International Meeting on Radiation Processing, lstanbul1 Turkey, Sept. ll-\6, 1994.
"Usc of PY-GC-MS to Fingerprint the Influences of Algal Material on NOM,' 1 presented in the seminar entitled ''N2tural Organics and Drinking Water-from Ecology to Engineering," at the 1994 Annual Meeting ofthe American Water Works Assoc., New York, NY, June 1994.
•·Gamma Radiolysis of Dioxin on Soils: Theoretical and Practical Considerations," presented at the First International Conference on Advanced Oxidation Technologies for 'Vater and Air Remediation, London, Ontario, June, !994.
"Treatment of Soils and Sediments; Radiolyric Destruction of2,3,7,8-TCDD," presented at ttie NSF Workshop on Applications of lonizing Radiation for Decontamination of Environmental Resources,**Miami~** FL. June 2 1 1994.
"Free Radicals and Excited States in Environmental Engineering: Photocatalysis and Radio!ysis," presented to the Department ofCivil Engineering, Nortbwestern University, April 12, 1994.
"Environmenlal Applications of Semiconductor Photocatalysis," presented ai 3M Corp., St Paul, MN, March 28, !994. "Pyrolysis-GC/MS Analysis ofNatural Organic Material in Water," presented to Orange County \Vater District and National \Vater Research Institute. Feb. 24, 1994.
"Characlerization of Natural Organic Material Using Pyrolysis-GC-MS: Applications in Water Treatment." presented at the U.S. Environmental Protection Agency and University of Cincinnati, Feb. 11, 1994.
"Radiolytic Destruction ofDioxin on Soils Using Cobalt-60: Theoretical and Practical Considerations," presented at Environmental, Ocean and Water Resources Division, Dept. of Civil Engineering, Texas A&M University, Feb. 3, 1994. "Radiolytic Oeslruction of Dioxin on Soils: Its Potential as a Pretreatment Method to Enhance Bioremediation," presented at the 1993 Annual Spring Meeting ofAIChE in Houston, TX. "Photocatalysis for Environmental Applications: General Aspects and Mechanistic Insights," presented at Dept of Environmental Science and Engineering, Rice University, March 29, 1993.
"Advanced Oxidation: Photocatalytic Destmction of Aromatic Compounds," Dept. of Civil Engineering, Northwestern Univ_, 3 March, 1993. Symposium on Environmental Applications of Advanced Oxidation Technologies, sponsored by Electric Power Research Institute and the National Science Foundation," San Franci..<ieo, CA, Feb. 22-24, 1993. Page 26 of38

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"Water Treatment St1.1dies at the Unive-rsity of Notre Dame" presented at the Central Research Laboratories cif' the Lyonn_aise des Eaux-Dumcz, Le Pecq, france, December 21, 1992.
''The Role of Oxygen in the Photocatalytic Degradation of 4-Chloropheno[,'' presented at the First lntemational Conference on Ti02 Photocatalytic Purification and Treatment of Water and Air, London,**Ontnrio~** November, 1992. "Photocatalysis on Semiconductor Surraces: Novel Applications for Hazardous Cheinical Destruction," presented at the RadTech '92 North America, Boston, MA, April 29, 1992.
"The Raging Dioxin Debate: Scientific and Socia[ Factors," Center for Social Concerns, University ofNotre Dame, January 31, 1992.
"Science and Emotion: The Dioxin**DeEr.:~te/'** Institute for Inlernationa_f Peace Studies, November 7, 1991. "Inorganic and Organic Polymeric Coagulants: Theory and Application," Association of Environmental Engineering Professor Seminar, presented at Annual Meeting ofAmerican \Vater Works Associatibn,**Philadelphi~** PA, June 24, l99L "'Alternative Uses of Semiconductor Systems: PhotOCittalytic Degradation of Halogenated Organic Compotlnds," presented in a symposium, Common Problems in lmagi11g Science and Photocatalysis, at the 44th Annual Conference of the Society ofPhotographic Scientists and Engineers, St Paul, MN, May 12-17, 1991.
"Influe-nces of Natural Organic Material on Water Treatment Processes," J.M. Montgomery Consulting Engineers, November, 1990. "'"Direct Filtration and Nalural Organic Material," Department ofCivil Engineering, Duke University, Ocmbe-r '1990.

PRESENTATIONS Paul A. DeSario. Le Chen, Michael E. Graham, Kimberly A. Gtay, '"'Visible Light Activated Ti02: Oxygen Vacancies and Cation Substitution," 239 1 h Ame-rican Chemical Society Meeting, San francisco, CA, March 21-25, 2010. Baiju K. Viiayan, Paul Desario, Nada Dirnitrijevic, Kimberly Gray, ''Photocatalytic reduction ofcarbon dioxide to fuel using hydrorhennally Synthesized Titania Nanotubes'', 239tl1 American Chemical Society Meeting, San Francisco, CA, March 21-25, 2010. S. Ciston, Y. Yao, R.M. Lueptow, K.A. Gray, Fouling Prevention in Rotating Reactive Membrane Filtration, Annual A!ChE Meeting, Philadelphia, PA. November, 2008. L. Chen, M. Graham, K.A. Gray, Photoreduction of C0 2 over reactive DC magnetron sputtered TiDz thin films, 234th ACS National Meeting, Boston, MA, August 19-23, 2007. G. Li. K.A. Gray, Solar Fuel Applications ofTitania Nanocomposites: Solid-Solid fnterfaces for Photoreduction of Carbon Dio<ide, 234th ACS National Meeting, Boston, MA, August 19-23,2007. S. Ciston, G. Li, L. Chen, R.M. Lueplow, K.A. Gray, Biofouling Prevention through Reactive Ceramic Ultratlltration Membranes, North American Membrane Society, May 14,2007. Y. Yao, K.A. Gray> R.M. Lueptow,Titanium DioxideiCarbon Ncmotube Composites for Photo-reactive Filtration, North American Membrane Society, May, 2007. C. Ng, K.A. Gray, Predicting Bioaccumulation in Dynamic Food Webs: Ontogeny, Seasonality, Inva.sional Successions Session T1tle: Environmental Fate and Transport Processes JI. AIChE Annual Meeting, Thursday Page 27 of38

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November 16, 2006, San Francisco. Shannon Ciston, Le Chen, Gonghu Li, Martina Hausner, Richarcl M. Lueptow, Kimberly A. Gray, "Effects ofTi01 nanostn.Jcture and v(:lrious ceramic suppons in photocatalytic membmncs for water Treatment." A!ChE Annual Meeting,**~ovember** 16) 2006. San Francisco, CA.
Le Chen, Michael E. Graham 1 Gonghu Li, Kimberly A. Gray, "Fabricating Highly Active Mi:u:d Phase TiO:; Photocatalysis by Low Angle Reactive DC Magnetron Sp1rtler Deposition." 2006 AIChE Armual Meeting, Nov_ 15, :2006. San .Francisco, CA. G. Li, L. Chen, S.M. Ciston, T. Rajh and K.A. Gray, "Titania-based Nanocomposite Materials as Highly Active Photocatalysts'', Fundamentals of Environmental Cotal_vsis. The AIChE 2006 National Meeting, San Francisco, CA; November 14,2006. A.I. Packman, S. Amon, and K.A. Gray, Structure, Transport, Transfonm1tion: Hydrodynamic controls on redox conditions and microbial metabolism in surficial sediments, invited present.ation at the**Geologic<~!** Society of America Annual Meeting, Philadelphia) Oct. 2006.
G. Li.. L. Chen, S.M. Ciston, T. Rajh and K.A. Gray, "TiOrbased Nanocomposite Materials as Highly Active Photocatalysts: The Role ofAdlineation Sites", Fundamentals q.fMeta! Oxide Catatvsis, The 232ndACS National Meeting, San Francisco, CA; September I0, 2006. Shannon Ciston, Le Chen, Gonghu Li, Martina Hausner, Richard M. Lueptow, Kimberly A. Gray, "Effects ofTi02 nanostruclure and various ceramic supports." ACS National Meeting, September 10, 2006, San Francisco, CA. A.J. Packman, J.D. Newbold, S. Arnon, and K.A. Gray, Implications ofhyporheic structure and biophysicochemical process coupling for modeling nitrogen dynamics in rivers, presentation at the North American Benthologlcal Society Annual Meeting, Anchorage, Jun. 2006. S. Amon, A. I. Packman and K. Gray. "Flow conditions and substrate geometry strongly influence benthic denitrification." North American Benthological**Society~** Anchor.:rge, AK, USA, June, 2006, L. Chen, K.A. Gray, M. Graham, «Developing photocatalytically active mixed phase Ti0 1 by magnetron sputtering deposition," [O be presented in the New Horizons in Coatings and Thin Films Symposium at the International Conference on Metallurgical Coatings and Thin Films, May, 2006.
A.l. Packman, S. Arnon, and K. A. Gray, Structure, Transport, Transformation: A framework for analysis of denitrification and other microbially mediated**process~s** in aquatic systems, presentation at the American Geophysical Union Fall Meeting, San Francisco, Dec. 2005. S.**Arnon~** A I. Packman and K A. Gray. "'The effect offlow on periphyton structure and nitrate removal" 2005 American Geophysical Union, New Orleans. LA, USA. C. Liu. K. Nakano, E_ Obuchi, T. Dike, N. Yukihira, D. Hurum, K. Gray.l. "Photocatalytic decomposition of formaldehyde using titania coated lime tile," to be presented Ti02- 10, Chicago) IL, October 24, 2005.**~** M.R Berg, K.A. Gray, LA.N. Amaral, "Complex trophic dynamics in an invaded food web," presented at the 90 111 Annual Meeting ofthe Ecological Society ofAmerica, Montreal, Canada, Aug. 2005,**~** M.B. Berg, D. Jude, J. Janssen, K.A. Gray, L.A.N. Amaral, "Complex trophic dynamics in a 'simplified' food web: Implications for contaminanttransfer,''IAGLR 2005, May 25,2005. C. Ng, M.B. Berg, K.A. Gmy, L.A.N. Amaral, "Network-centered modeling of bioaccumulation in freshwater foodwebs," 228'' ACS National Meeting, Philadelphia, PA, Aug., 2004.

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C. [shida. K.A. Gray C. Ng, "Cultivating periphyton lo accelerate rates 

## or denltri!ication in wellands," 228 111 ACS Narional Meeting, Phi!adelphin., PA, Atlg., 2004.
J.A. Kastel, K.A. Gray. "The Impact of Metal and Organic Contaminants on tl1c Structure· of Pcriphyton in Lotic Sediments." 228 11\ ACS National Meeting, Philadelphia, PA, Aug., 2004.
D.C. Hurum, A.G. Agrlos, K:A. Gray, T. Rajh, M.C. Thurnauer, ''Mixed-Phase titania photocatalysis: EPR s!udies of caralyric mechanisms," 228Lh ACS National Meeting, Philadelphia, PA, Aug. 22, 2004.
T. Rajh, M.C. Tbumaue-r, K.A. Gray, D. Hurum, ''Mechanisms of semiconductor photocatalysis revealed via eleclron paramagnetic resonance," 227 11\ ACS Ami.ual Meeting, March, 2004. Hurt1m, D.C.; Agrios, A.G.; Gray, K.A.; Rajh, T.; Thumm1er, M.C "EPR Studies of Degllssa P25 Photochemistry; fnsights into Mixed Pltase Ti02 CaLalyLic Activity"**Ti0:!~8** Conference, Montreal, Canada, Oct. 27,2003.
T. Sirivedhin, K.A. Gray. "Assessment ofAnthropogenic Influence in Indirect Potable Water Reuse." Water Retlse Annual Symposium XVIJ!, San Antonio, TX, 2003. 

### g Chang, K.A. Gray. "Chemical composition and Cu complcxationofthe extracellularpolymeric substances from psctldDmonal acruginosa biofilms," 225 111 ACS National Meeting, New Orleans, LA, Mttrch, 2003.
finster ME. Gray KA, Binns HJ. Lead levels ofvegetables grown in contaminated residential soils: a field survey. American Public Health Association Annual Meel.ing, Philadelphia, PA, November II, 2002. Finster ME. Gray KA. Binns HJ. Factors in11uencing tbe creation ofturfgrass barders on lead-contaminated residential soil.s. American Public Health Association Annual Meeting, Philadelphia, PA, November Jl, 2002. Binns HJ, Peneff N, Gray KA, Fernandes J, Finster ME; for the Safer Yards Project. Effect of an intervention to reduce soil1ead contamination in urban residential yards. American Public Health Association Annual Meeting, Philo.delphia, PA, November 13,2002.
Hun1rn. D.C.; Agrios, A.G

..: Gray, K.A.; Rajh, T.; Thurnauer, M.C "EPR Studies ofDegussa P25 Photochemistry: lnsigb Is irito Mixe-d Phase Ti02 Catalytic Activity" 222"d ACS National Meeting, Chicago, TL, Aug. 27, 200 I. AgriOs. A.G

.. K.A. Gray. "Detailing Visible Light Effects of2,4,5-Trichlorophenol on Ti0 1 Surfaces." 222nd ACS National Meeting, Chicago, JL, Aug, 27, 2001.
M. Bonifacic. K-D. Asmus, K.A, Gray. "Time-resolved pulse radiolysis studies on the reaction offree radicals and hydrated electrons with halogenated phenols," 22211d ACS National Meeting, Chicago, IL, Aug. 27,2001.
T. Sirivedhin, K.A. Gray, "The In-fluence of Organic Carbon Quality on Denitrification Rates at the Des Plaines River Wetland Demonstration**Projec~"** Society of Wetlands Scientists, 2i1 d Anmtal Meeting, Chicago, IL May, 2001.**Agrios~** A.G., K.A. Gray. "'Enhanced Adsorption and Degradation on Ti02 Due to Visible Light." Second International Conference on the Remediation ofChtorinated and Recalcitrant Compounds, Monterey, CA, May 22- 25, 2000.
T. Sirived:hin, K.A. Gray, ,Anlhropogenically ln±luenced Wetlands at the Des Plaines River Wetland Demonstration Site," IAGLR Conference, Cornwall, Ontario, May, 2000.
Jill A. Kastel and K.A. Gray] "Tbe Intlttence of Pcriphyton on· the Bioavailability of Contaminants in Lotic Sediments," IAGLR Conference, Cornwall, Ontario, May, 2000 [IAGLRfHydrolab 2000 Best Student Presentation Award].
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T_ Sirivedbin, K.A. Gray, "Identifying Anthropogenic -Markers in Dissolved Organic M01.tter using Py/GC/MS." Natural Organic Matter in Soils and \Vater, Norll1 Central Region W01kshop, St. Paul, MN, January, 2000.**L_~rivcdhin,** K.A. Gray, "Seasonal Effects on the Enhancement of Low Quality Surface Water by a Restored Riparian Wetland," Annual Conference, American Water \Vorks**A~;sociation,** Chicago, LL, June, 1999.
K.A. Gray and Robert M. Barnick, "Use of P\'-GC-MS to Characterize Natural Organic Material in an Artificial Wel!and: Issues Related to Drinking Water Quality," presenled at the Natural Organic Matter Workshop 18-19 Seplember 1996, Poitiers, France.
D.L. Widrig, K.A. Oray and K.S. McAuliffe, nRemoval of Algal-Derived Organic Material by Preozonat-ion and Coagulation: Monitoring Changes in Organic Quality by**Pyrolysis-GC-l\-15~''** at the AWWA 1996 Annual Conference, Toronto, Canada, June, 1996.
D.C. Schmelling, K..A. Gray .and P. V. Kamal, "The Importance ofReductive Transformations in the Photocata[)1.ic Destruction of Nitroaromatic Compounds,'' preserned at the 1996 A1ChE Spring National Meeting , Feb. 25-29, 1996, in New Orleans, LA.
K.A Gray , "Radiolytic Destruction of Hexachlorobenzene on Soils: Comparison of Gamma and High Energy Electron Radiolysis," presented at the 1996 AlChE Spring National Meeting, Feb. 25-29, 1996, in New Orleans, LA.
A.H. Simpson, K.A. Gray and K.S. :.vfcAuliffe, "Statistical Analysis ofPY-GC-MS Data to Improve Understanding o[NOM Chemistry in Water Treatment Processes," presented at AWWA Water Quality Technology Conference: Nov. 11-14, 1995, New Orleans, LA. Ulick Stafford, Kimberly A. Gray and Prashant V. Kamat, "Kinetic Modeling of 4-Cloropbenol Degradation in Titania Slurries,'' presented in Mechanistic Environmental Photochemistry Symposium at the 210th ACS National Meeting, Chicago, lL, August 24. 1995. K.A. Gray, A.H. Simpson and K.S. McAuliffe, "Use ofPY-GC-MS to Study the Nature and Behavior of NOM in Water Treatment,'' presented in NOM Isolation and Characterization Symposium at the 21 Oth ACS National Mt;:eling, Chicago, IL, AugLt01 23, 1995. K.A. Gray, K.S. McAuliffe and A.H. Simpson, "Monitoring Organic Removal for a Variety of Enham::ed Coagulation Processes Using Pyrolysis-GC-MS," presented at AWWA Enhanced Coagulation Workshop in Charleston, SC, Dec. 6, 1994. R.J. Hilarides and K.A. Gray, "Destruction ofDioxin on Soils: Radiolysis ofModel and Real Soils," presented at the )994 AlChE Summer Meeting, August 14,17, Denver, CO.
J.M. Noris, K.A. Gray and J-F. Gaillard, "Treatment ofHigh Selenium Wastewaters," presented at the 1994 AIChE SummerMeeting, August 14-17, Denver, CO.
M.S. Dieckmann, K.A. Gray and P.V. Kamal, "The Sensitized Photocatalysis of a Mixed Reactant System of 4- Chlorophenol and**4~Nitrophenol,"** presented at the 1994 National Conference on Environmental Engineering, July 11-!3, Boulder, CO.
K.A. Gray and R.J. Hilarides, "Innovative Treatment of Soil Contamination: Radiolylic Destruction ofDioxin and Co-Contaminants by Cobalt-60," presented at the 1994 National Conference on Environmental Engineering, July 11-!3, Boulder, CO. D.C. Schmelling and K.A. Gray, ''Photocatalytic Tn::msfbrmation and Mineralization of TNT in Ti02 Slurries," presented at the 1994 N!!.tional Conference on Environmental Engineering, July 11-13, Boulder, CO. Page 30 of38

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P.V. Kamal, K. Vinodgopal, U, Stafford and K.A. Gray, ''"Semiconductor Particulate Films for the Phot-ocatalytic Degradation of Organic Contaminants," presented at tlle 185th Electrochemical Society Meeting, San Francisco, May 25, !994.
U. Stafford, K.A. Gray, and P.V. Ka.mat,**''P~otoc<tta[ytic** Oxidation of 4-Chlorophenol on Titanium Dioxide: A Comparison with g-Radiolysis," presented at the 4th Annual Symposium on**Chemic~!l** Oxidation, Nashville, TN, feb. J994. ,R.J. Hilarides and K.A. Gray, "Gamma Irradiation of SoiLs Contaminated wlth 2,3,7,8-Tetrachlorodizenzo-p-dioxin using 60co," presented at the 4lh Annual Sympositll11 on Chemical Oxidation, Nashville, TN, Feb. 1994.
D.C. Schmelllng and K.A. Gray, "Photocatalytic Destruction of TNT Contnminated Waters," presented at the 4th Annual Symposium on Chemical Oxidation, Nashville, TN, Feb. 1994.
K.A. Grav and K.S. McAuliffe, "Pyrolysis-GC-MS Characterization ofthe Natural Organic Matrix of Waters and Soils: New Insights into Organic lniTuences on Treatment Performance,'·' presented at the 20th Annual Water Quality Technology Conference, Miami, Florida, November 14-18, 1993.
D.C. Sclunelline: and K.A. Gray, "'Photocatalytic Degradation ofTNT," presented at the 24th Annual Meeting ofthe Fine Particle**Society~** Chicago, IL, August 1993.
R.J. Hiiarides and K.A. Gray, "Radioiytic Destruction of Dioxin on Soils: Optimal Conditions and Economic Consideration," presented at the Summer Meeting of the American [nstitate of Chemical Engineers, Seatlle, WA, August 1993. K.A. Gray, A. St. Am.and and Hong VYang, ;'Role of a Periphytic Biolayer in the Fate of PCBs in Artificial Stream Systems," presented at the First International Specialized Conference on Contaminated Aquatic Sediments: Historical Records, Environmental impact, and Remediation, sponsored by the International Association on Water Quality, Milwaukee, WI, June 14-16, 1993.
K.S. McAuliffe and K.A. Gray, "Characterization ofNalural Organic Matrix Using Pyrolysis-GC-MS," presented o.t the 26th Great Lakes Regional Meeting ofthe American Chemical Society, May 27, 1993.
K.A. Gray. R. Barreto, P. Yocum, and K. Anders, "The Influence of Photocatalytic Pretreatment on the Biodegradation of1-1TBE," presented at the Summer Meeting ofAlChE,**~inneapolis,** MN, August, 1992.
K.A. Gray, '"Mechanistic Studies of Photocatalysis on Semiconductor Surfaces," poster presentation at the Gordon Conference on Environmental Sciences: Water, June, 1992.
K.A. Grav, P. Karnat, LT. Stafford and M. Dieckmann, ":\iechan.istic Studies of Chiaro- and Nilro-phenolic Degradation on Semiconductor Surfaces/' presen1ed at The Annual Meeting ofthe American Chemical Society, San Francisco, April, 1992.
K.A. Gray and K.S. McAuliffe, "Application of Pyrolysis-GC-MS to Chamcterize a Variety of Surface \Vaters:**fnflu~nc~** of Algal Dynamics," pre-sented at the Annual Meeting of the American Chemical Society, San Franci.sco, April, 1992.
K.A. Gray, "Use ofPyro1ysis-GC-M.S to Shtdy the Organic Matrix ofSurface Waters,'' presented at the 1991 Water Quality Technology Conference, American Water Works Association, Orlando. Florida, November. 1991. U. Stafford, K. Gray, P. K1ll1lat, A. Varma, "The Effects ofSemiconductor Properties Upon Photocatalytic Rates for Organic Contaminant Degradation/' presented at tbe 1991 Annual Meeting of the American Institute of Chemical Engineers; Los Angeles, CA, November, 1991. Page3l of38

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J. Earlev, K. Gray, P. Garrity, ''Radiolytic DesLruction of Dioxin/' presented at the 1991 Anmml Meeting of the Amel ican Institute oF Chemical Engineers, Los Angeles, CA, November, 1991.
K. Anders and K. Gray,**"Pbotoc<~trdytic** Degradation of Methyl-terl-Butyl Ether on Semiconductor Smfaces," presen!ed at 2nd Annual Argonne Symposium for Undergraduat-es, Argonne National Laboratory, November 8-9, 1991.
M.S. Dieckmann, K.A. Gray, and P.V. Knmat, '·Photocalalyzed Degradation ofAdsorbed Nitrophenolic Compounds on Semiconductor Surfaces," presented al Waste Management in The Chemical and Petrochemical Industries, lAWPRC & Tulane University, New OrleflnS, June, 199 L
K.A. Gray, "Specif1c Chemfcal Effecrs of The Calcium and Bicarbonate [ons on Colloidal Destabilization by an Inorganic Aluminum Polymer," presented at the Mid-West Environmental Chemistry Workshop, October; 1990.
M.S. Dieckmann, P.V. Kamat, and lC.A. Gray, <'The EfT eel· of Semiconducting Materials as Photocatalysts in Lbe Degradat1on ofNitrophenols,''presented at the Mid-West Environmental Chemistry Workshop, October, 1990.
K.A. Gray, "Direct Filtration of Model and Natural Waters: The Removal of Turbidity versus Dissolved Organlc Matter," prcscnlcd at the IAWPRC/lWSA Joint Specialist Conference on Coagulation, FloccLJlation, Filtration, Sedimentation, Flotation, Jonkoping, Sweden, 24-26 April, 1990-
K.A. Gray, "Direct Filtration on the Seine River: The Importance of Chemistry," presented at the 1st Macao Workshop on Waler Treatment, 3A November, 1989, sponsored by the Macao \Vater Supply Co., Ltc.L and the Lyonnaise de;; Eaux.
K.A.**Gray~** F. BernazeaLL, C Hubele, "Reduction ofTotal Organic Carbon by Direct Filtration: A Pilot Study on the Seine River," presented at the 7th Regional Conference of the Asian-Pa:cific Group of the International Water Supply Association (IWSA), 29 Oct.-2 Nov., 1989, Nagoya, Japan. K_A_ Gray, F. Bernazeau, C. Hubele, '-Upgrading a Slow Sand Filtration Plant for MicropoHulant Removal: Use of Direct Filtration Prior lo Granular Activated Carbon for Reduction of Total Organic Carbon," presented at the lWSAJAIDE Specialized Conference "'Organic Micropollutanls," 19-21 SepL 1989, Barcelona, Spain.
K.A. Gray, F. Bernazeau, C. Hubele, <>Direct Filtration on the Seine River: A Pilot Study," presented at the Annual Conference ofthe American Water Works Association, Los Angeles,**June~** 1989.
K.A. Gmy, C. H. Yao, C.R_ O'Melia, "Polymeric Metal Coagulants/' presented at Lhe Annual Conference of the American Water Works Association in Kansas City, MO, Jtu1e, 1987.
K.A. G@Y.. C.R O'Melia, "Use of [norganic Iron(ni) Polymers for Coagulation in Industrial Water Treatment," presented at the 18th Mid-Atlantic Industrial Waste Conference, Virginia Polytechnic Institute, Blacksburg, VA, June, ]986. K.A. Gray, C.R. O'Melia, "The Formation, Characterization and Use of Inorganic Iron(lll) Polymers for Coagulation in Water Treatment,:• presented at the Annual Conference of the American Water Works Association in Denver, CO, June, 1986.
K.A. Gray, C.R. 0'Melia, ''The Use of Inorganic Iron(III) Polymers for Coagulation in Water Treatment," presented at the 37thAnnUBl Meeting oflhe Chesapeake Section ofthe American Water Works Association, Ocean City, MD, Sept., 1985.
·K.A. Gray. T.D. Waite., "Coagulation and Precipitation Studies of the Ferrate(VI) Ion,n presented at the l86th National Meeting of the American Chemical Society, Environmental Chemistry Division, Washington, D.C., Aug., 19R1. Page 32 of38

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T.D. Waite, K.A. Gray, "Oxidation and Coagulation of Wastewater Effluenl Utilizing the Ferrate(Vl) Ion," presented at the Fourth**lntemaLion<~l** Conference on Chemistry for Environmental Proleclion, Toulouse, france, Sepl., 1983.

UNIVERSITY COMMITTEES AND RESPONSIBILITIES Department:

College: Nonhwestern University: Em.oironmenlaf Group Coor-dinator. 2002-2010. Graduafe Recruiling andAdmissions, Environmental Program, 2002-present Redesigned rVebsile- 2001-2002 Environmenlal Fact!If:}' Search Committees (1999, 2000, 200 l, 2002, 2003, 2004, 2005: 2006, 2007,2008,2009,2010) Service ].earningPilot andProgram**Dirt~ctnr,** 1996-present S!ra!egfc Planning- 2000, 2004-05 U11dergraduare CU!Ticulum**Deve!opme~1t, 1995~preseJ?l**  University ofNotre Dame: Depar!mental Seminar**Coa~·d;nator,** 1992-1995 Undergraduale Cvrricu!l!m Committee, Chair, 1989-1993 ASCE Facu/Jy Advisor, 1990-J**~93** Graduate Recruiling, 1990

Northwestern Umversity: Promolion & TenJJre Commiflee- 2007-2009. Search Committee- Associate Director,lndustrial Relations, 2005 Dean Sec/l·ch Commiftee, Spring, Fall 2004 Freshman Advisor- 1996-2001 McConnrckIdentity Committee, 200J-2002 MEOP

- Summer EXCEL Program, Designed and Supervised Community Engineering course. and integration into Leadership Program, 1998,1999. Planning Commiltee for the institute for Manufacturing and Design Technology, 1998 Speaker.IFacilitator**~** McCormick Career Night, 1995 University ofNotre Dame: Grievance Commiftee, Alternate,l994-1995 Commi!fee on Undergraduate Studies, 1989-1993 lv!inorily Men/or Program, Advisory Board (member, I993-1995) and mentor, 1989-1995 Summt::r Program in Engineering for High School Women and Minorities; Seminar Speaker, 1990-1995 University: Northwestern University: EnvironmentalPolicy & Culture FacullyAdvising Commiltee, Weinberg CAS, 2008-present. School of Continuing Studies' Graduate FacultyAdvisoryBoard, 2007-present Program Review CommiUee (2002-2005); Member Geological Sciences Internal Review Subcommittee, 2001; Chair, University Services Internal Review Subcommittee, 2003; Chair, De-partment of Family Medicine, Internal Review Subcommittee, 2004;**Chair~** Department of Frenchand Italian Internal Review Subcommitlee, 2005 University ·Re-accreditation; Faculty Self-Study on Intcrdiscip1inarity in Undergraduate Programs, 2003-2004. Facully Search Commiltees; Chemistry (2003-04), Mathematics (2004-05) Director, Environmental Science, Engineering andPolicy Program (formerly, Environmental Science Program, WCAS), 2003-present
Page 33 of38

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Plant Biology cmd Conservation GrCiduate Program in WCAS, member of Oversight Committee E17Pironmental Science Task Force, 2001-02 Committee on J.Vomen tn the Academic Community, 2001-2003 University Facu/o! Reappoinlmen!, Promotion and Tenore Denial Appeal Panel, 1999-2002 Master (1998-2002), Associate Master (1997-98) and Faculty Associate of Public Affairs**Residentie~l** Co! lege, 1996-prescot. UniversiLy ofNotre Dame: Committee_ Ia Select Proposal to Henry R_ Luce Professorship Program, 1994 Gradrtare Council, Appointed Member, 1991-1994 Planning Committee of Graduate Councif, 1992, 1993 Freshman Yectr of Studies, Discussion Group Leader Freshman Orientation, 1991-1994 Notre Dame Science andEngineering Tolen! Search, Seminar Speaker, 1991 Program to Prolllo!e lvfinority Enrollme11t in Graduate School, Seminar Speaker, 1991 Cer1ter for Social Concerns, Pilot Workshop to conSider Ethical Dimensions of Undergraduate Education, Discussion Leader, January 12-13, 1992 Reilly Center, Scholarship Review Committee, 1992, 1994,1995 Conjere11Ce. on Business Leadership in the Environmental Crisis, Panelist, Sept., 1992 lnslitutiona/Anima! Care and Use CommNtee, Member, 1991-1995 Selectinn Cnmmitfee for Graduate Teachmg Award, 1993 Speaker-Placement Office Graduate School lntbnnation Session, 1993, 1994 EnvlronmemalIssues Group, Kroc Institute ofPeace Studies Faculty Fellah' and member of Undergrad Advis01y Committee, Joan B. Kroc Institute for International Peace Studies 1993-1995 Panel 11-fember. Women in a Catholic Univer.sity; The Challenge and Promise, 1993 Participanl, Information Session for Women in Science and Engineering; Freshman Year, 1993.

EDUCATIONAL and COMMUNITY OUTREACH
K-12 Educational Outreach: Designed, organized, and taught in Middle- and High-School Teachers Workshop, Unlocking Nature's Secrets: Catalysis in !he Environment and lndustry; at Argonne National Laboratory, 2000, 2001 & 2002. Total number a[teachers was 91. Primary author ofeducational laboratory module, Environmental Catalysis,; 1 0 111 in a series of Material Worldwide Modules; designed, tested, \Vrote series ofactivities for students to learn about various principles ofcatalysis and the importance ofcatalysis for environmental protection. Field-tested activities in various high schools (ETHS, New Trier, Schaumburg, etc.) in Chicago area and nationally. Mentored 7 High School Teachers participating in the NSF REST program (Research Experience for Science Teachers) since 1999, as \Veil as over 26 REU or high school sludents working on summer research over the last I0 years. Cormnunity Outreacb Chicago Cross-Pollinator Project, panel member, 11 June 2012. The Green City: A Field Study in Chicago; organized and lectured in Summer Institute of School ofContinuing Studies,Aug. 9-11,2006, Aug 1-3,2007, July 28-30,2008. Technical Advisory Committee, Friends ofthe Chicago River, 2004-present. Advisory Board, Healthy Schools Campaign. 2004-present.
NU Alumni, Development, Student**Group~** and General University Talks "'Living Cities: An urban model ofsustainability,"' Fireside at Slivka Residential College, 10 May 2012. Undergraduate Research and Arts Exposition, Session Moderator, May 21, 2012. Guest lecture, Science ofClimate Change, NU Law School, Seminar on Climate and Energy, Jan. 10, 2012. Panel member, SustainabiliLy and Renewable Energy Panel, The Graduate School Centennial Celebration, Nov. 4. 2011. Page 34 of38

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«Fabricating Titania-based Nanocomposites for Solar Fuel Production: Ti02.x. & Ti 1 _"Nb,02 Tbin Films & Ti0 2Nanotubes," Northwestern Undergraduate Chemistry Council, M.arch 8, 2011 ··sustainable Stndes in Urban Design: Lessons from Chicago," SEED Green Cup Kick-orf, 31 January, 201!. Panel: Environmental Justice and Hurricane Katina ror Undergraduate Lecture Series on Race, Poverty, and Inequality al Northwestern U11iversity & NU Conl'crence on Huma11 Rights- November 22, 20 I0. 'The Modern American City: Can we evermake 1t Sustainable?" \'1cCormick Engineering Week, McCormick Student Advisory BoarJ, NU, May 20 1 2010. Panel: Working with the Community, Communily Research Workshop,**NU~** May 14,2010. Panel: Environmental-Racism: Poverty and Pollution in l\·1ioority Communities, in the 1\-lartin Luther King, Jr. Lecture Series, NU**Medic~tl** and Law School, January J2, 2010. Panel: Infrastructure Now and Then: Seeing the Fu1ttre At Another Level, in The lnfrastrllcture Universe: from Highways to i\-1olecules, AlummJc Continuing Education Course, Dec. 3, 2009. Domain Dinner on Sustainability, "The Elusive Concept o[Sllstainability," 16 Nov. 2009. "'Tan you have a Green City on a Brown Lake," Junior Science CafC, Arlington Heights, 4 Nov., 2009 "Making Chicago Sustainable: The Water-Energy Connection" in The Infrastmcture Universe: From

Highways to Molecules, Alumnae Continuing Education CDLrrse, Oct. l. 2009. '"'Can you have a Green City on a Brown Lake.'' Sign1a Xi 1uniorScience Cafe, 21 March, 2009 "Why this isn't your father's energy crisis," Science Cafe, Wilmette Public Library, Nov 5, 2008. Women in Science and Technology Panel, POWER Dinner, Cryicago, lL, .\1ay 22,2008. "Sustainability: Fad or Necessity?" Fireside at CCS, May 12,2008.**·'V..~lO** wants tq be a billionaire? The mad dash to find stistainabl.e alternatives to fossil fuels?"

Norlhwestern University Circle, March 13, 2008. Survival Skills for Graduate Students and Junior Faculty, Women•s Center, NU, Feb. 20,2008 "Who \vants to be a b!Jlionaire? Some thoughts on energy, geopolitics, economics, &

Lechnology." Fireside at Slivka Residential College, Nov., 2007. "Are we ever going to be able to make modem American cities sustainable'?" Twin Cities NU Club, May 23,2007. "Opportunities in Environmental Science and Engineerng," SEED, May I, 2007. "Design for the Environment- what that means" guest lecture, IDEA 398, Feb. I, 2007 "Environmental Engineering; Biology, Chemisrry and Physics for Ecological and Public Health Protection," Society ofHispanic Professional Engineers, Midweslem Expo, Nov. I, 2006. ""Energy and Sustainability: Business Opportunities," Energy Clnb·in Kellogg School of Management, Oct. 3, 2006. Domain Dinner on Energy and Environmental Issues, April l 1, 2006-, organizer, speaker. "Designing the Ecologically Sound City: New Orleans as a Case Study" Alumnae Contlntting Educalion Lecture Series, Dreams, Designs,**~nd** Developmenl, April 20,2006. "Hurricane Katrina: Preparation, Response and Rebuilding," Panel member, sponsored by

MEAS, Oct. 17, 2005. "The Sustainable City: Ifwe know what to do, why aren1t we doing it?" NU Club ofVirginia, Richmond, VA, March 18, 2005. '"'The Sustainable Ciry: Ecology, Efficiency, Equity," NU Engineers for a Sustainable World,

May,2004. «Urban Ecology and Technology: Opportunities for Sustainable Societies," ARCS lunch,

Norris Center, April, 2004. '"Sustainability: Engineering the City ofthe Future," Public Interest Alumni Assoc., John Evans

Center, Evanston, IL, Oct., 2003. "Undergraduate Research and Project Based Learning," New Student Visits, Norris Center, April, 2003. "Engineering tJ1e City ofthe Future: An Environmental Perspective," NU Alumni Association, March, 2003. "Do Enviroil.mental [ssues Really Matter," NU Alumni Association, Classes without Quizzes, Nov. 12, 2001. "Do Environmental Issues Really .Matter," Provost's Reception for Residential College Faculty Fellows, Hardin Hall, Sept 25, 200 I.**'~Environmental** Issues ofUrban Areas,'' NU Alumni College Program, The City: Past, Present, Page 35 of38

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and Prospects. July 28, I999. '·PCB Contamination and Other Threats 

### w tile Ecological and HL1man Health of the Great Lakes

Region," Seminar Day, North'Y.'estern Alumni Assoc., April 17, 1999. "''Environmental Cataly.sis," presented at Tech Review, March 23, i 999. ·'CommuniLy Sen-lee in Chicago Neighborhood,'' Lunchtime Seminar, PARC, Sepl. 15. 1998. "Local Pollution," Earthday, SEED, NU, 23 April 1998.

Member, Panel Discussions to Undergradt1ate and Graduate students on issues related to gender, environmental .qtmlity andjustice, sustainability issues.
SERVICE LEARNING AND COMMLNITY BASED PROJECTS (students supervised in parentheses)
Cook County Climate Change and Publ_ic Health Action Plan (Reau Garrett & Natalle Lake) 2012. Confined Animal Feed Operations (CAFO) Best Management Practices (Regan Radcliffe & Kaleb Tsang) 2012. Midwest Generation Trona lnjection (Anusha Vadlamanu & Bingshu Li) 2012. Ox.bow Corp. Calcined Petroleum Coke Facility -S02 Non-compliance (Lauren Lopez & Yufei Zhou) 2012. Hegewisch March (William Boulay & Xingcbeng Lu) 2012. Air Quality Evaluation for Southeast Chicago with Respect to the Proposed Universal Cement Facility (JefTGoto & Nopparat Chiangwong) 2012. Chicago Area Confined Disposal Facility (Adrienne Masterton, Yan Zou) 2012. Preli1ninary Phase Il Remedial Investigalion Report; OU3 On:,;ite Soil::; & Groundwar.er Assessment (Lauren Miller & Paige Hwnecki) 20 I2. Closure, Remediation, and Future Land Use**a~** State Line POwer Plant (Lauren Fleer & Taylor Swe.et) 2012. Clean Construction or Demolition Debris; Rllle Making (Tina Wang & Sarist Macksasitorn), 2011. 2727 South Troy Street, Little Village; Site Remediation (Dustin Grossheim & Sasha Letuchy), 2011. State Line Energy Power Plant: New Source Review (Roshni Barot & B.rian Kennedy), 20 ll. South Suburban Citizens Opposed to Polluting the Environment: Storm-water Management & Flooding in Longwood Farms (J\..1ichael Giannetto & Ke Gong), 2.011. Understanding the EPA's Greenhouse Gas Reporting Program (Ben Shorofsky & Boping Liu), 20l L Calumet CID Landfill: Future Use Recommendations (Walter Fume;s & Andrea Morgan), 2011. Methods for Attaining Aquatic Life Use A Stand_ards in the C<ilumet Area Waterways (Sara Thomas & Susan Vescovi), 20ll. Lake Depue Sediment Contamination: Evaluation of OUS Ecological and Human Health Risk As.sessmenls (Chelsea Baldino & Anjulie Cheema), 2011. Restoration ofMiller Meadow (S. Katragadda, M.**Roebuck~** J. Young), 2010. Brownfield Redevelopment in Little Vil1age: Assessing the ex.tent of contamination, remediation strategies, and future use (E. Ocb, S. Pavlik), 2010. Zero Energy Buildings (for Doug Farr & Assoc. by M. James and E. McCarthy), 2010. HVAC & Boiler Systems: Proposal for the Robert H. Lurie Medical Center (for Earthwise Environmental, Inc. by B. Sikora, J. Sirk, R. Gophal), 2010. Sustainabb Urban InfrastrUcture Systems: Lathrop Home::; (for Doug Farr & Assoc. by E. Ulion, S. Bemard, P. Slevin, S. Chahuvedl), 2010. Installing an Inflatable. Dam at Busse Woods- Assessing Environmental Impacts and Identifying Reasonable Alternatives (Robert Pickering, Mark Woodsum), 2009. Transforming the Former Celotex Industrial Site in Little ViUage to a Community Park- Design Features That Protect the Public and Create a Community Recreational Resource (Virginia Palmer, Nancy Shan), 2009. BP Whiting Refinery Permit Review (Christopher Trigg, Shuchi Talati), 2008. Robblns Community Power Plant (Maggie Fry, Erica Schle-imer), 2008. Redesignation ofthe Calumet River System (Teri McClerkUn, Cirmen Shank), 2008. Revegetation of the Calumet Cluster Site (Ahmad Harake), 2007. The City of the Future Competition, sponsored by ASCE, IBM, The History Channel, selected for Chicago competition (Julia Hand, Caitlin Freehan, JenniferRaber, Siti Abidin), 2007. Analysis of the Proposed Ford Heights Ethanol Plant (Siti Abidin, Jonathan Adams, Nur Atiah Ashar, Maya Jensen), 2006. USX Bike Path/Public Access (Duane Arnbroz, Rosemary Bush, Eva Dubey, Kevin Lee), 2006. Lake Calumet Clu:;ter Site: Future Land Use Proposal (Margaret Adsit, Allan Castillo, Douglas Groux, Megan Mann), 2006.
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Probing the photochemical aging of the Seural's zinc yellow pigments in Sunday at La Grand Jalle with Francesca Casadio al the Arl lnstitule ofChicago (Nirav Shah), 2004-2006. Natural Resource Danmges for Indian Ridge Marsh (Sara Patrawala and Sohier Dane), 2006. Contamination oflhe Celolex Site at La Villita (Chris Lee and Melissa f-.·1endez), 2006. LLJcak-Berg Pit Project (Calista Fisher and Marshall Lindsey), 2006. Proposal for Quarry Shopping Center's Stann Water Runoff(Debra Weissman and Oti Sivan), 2004- 2005. Assessment of Opacity Issues at Five Midwest Generation Coal-fired Power Plants in ths Chicago Area (Jonathan Flowers, Nyak Shidawati, Sharon Waller), 2004-2005. :Methane Production and Energy Cogeneration Potential in lhe Sediments oflhe Chicago Sanitary Canal {Colin Baret!), 2003·2004. LEEDing the Redevelopment ofBrowntields'with Green Design (Hetty Jurkowski), 2003-2004. Remediation ofThorium Contaminated Soils and Sediments: Kerr-McGee Kress Creek and Warrenville Retreat Center (Clare Frederick and Allison Wall<), 2003-2004. Healthy and High Perfmming Schools: Economic Analysis ofLEED Rated School Construction (Robert Kutter and Megan Johnson), 2003-2004. Urban Honey Production: Risk Assessment ofMetal and Organic Contamination (Erin Jordan), 2003-2004. PMw Compliance in Southeast Chicago (Michael Goldrich and Ben Jewel), 2003-2004. Going Green: A Comprehensive Review ofGreen Roofs (Aarti Ramachandran) 2003-2004. Indiana Harbor/East Chicago CDF (Todd Waldrop), 2002-2003. Fort Sheridan Closure (Polina Liberman and Don Walsf1), 2002-2003. PAH Contamination at Bridgeport Homes (Hilary Holmes), 2002-2003. Healthy and High Performance Schools (Se Jong Cho and francis Wambi-Buesso)} 2002-2003. Wastewater Disinfection Methods and Their Feasibility at. the Metropolitan Water Reclamation Plants in the Greater Chicago Area (Kirsten Dickson), 2002-2003. An Invest-igation ofRemediation Alternatives for Contaminated Sediments in the Vessel Slips ofWisconsin Steel Works and United States Steel South Works (Andrew Burnham and Travis Cobb), 2001-2002. The Suitability of Shallow Wells to Solve Lockport's Radium Problems (Cari Ishida, Todd Waldrop, Nathan Turner, Cody Prentice, Andrew Marcus), 2001-2002. Solar and Wind Ren-ewable Eneq,,:ry Systems at the Southeast Chicago Cluster Site (Todd \Valdrop), 200l-2002. The CTA's Forest Glen Bus Garage: The Air Pol1ution and Some Solutions (Jennifer Wilson), 2000-2001. Hazardous Air Pollutant Emissions from Natura] Gas-Fired Peaking Power .Plants in Northeast Illinois (Lynette Cheah), 2000-200 I. Health Risks from Radioactive Emissions from Coal Burning Power Plants (Ben Porter), 2000-200I. Evaluation and Design ofEnhanced Wetlands for the Lake Calumet Cluster Site (Jennifer Wendrowski), 1999-2000. A Guide to Identifying Communities with Health Hazards: Using the Tools of CCRI (Emily C. Anderson and Marlena M. Lacey), 1999-2000. A Cbaracterization and Assessment of Vessel Slip Contamination: United .States Steel South \Vorks Site and Wisconsin Steel Works Site (Nuria**Bertran~Ortiz** and Christina Hemphill), 1999-2000. Resource Guide: The Phytoremediation or Lead in Urban, Residential Soils (Joseph Fiegl and Bryan McDonnell), I 999-2000. Pollution Prevention in the Metal Finishing lndustry (AUison McCormick and Tracey Rissman), 1998-1999. The Chicago Cumulative Risk Initiative-Mercury Rising (Saba Fatima and Katie Sovik), 1998-1999. Lake Calumet Cluster Site: Site Characterization and Use of Experimental Wetlands for Reclamation (Michael Buller a11d Kim Sopocy), 1998-1999, Chicago Cumulative Risk Initiative- Hazard Mapping (Kelly Hirsch and Junaluska Williams), 1998-1999. Planting tl1e Seed for Recovery: Altgeld Gardens (Angela Change and Mausami Desai), 1998-1999. Regional Air Quality and Chicago's Ground Level Ozone Problem (Terah Luchey and· Shanthi Nalaraj), 1998- 1999. Wetland Remediation: Cleaning up the Lake Calumet Cluster Site (Beverly Ahoni), 1998-1999. Lake Calumet Cluster Site: An Analysis ofFuture Remedial Action (Sarah Bender and Ted Ekkers), 1997-1998. Risk Assessment and Site Characterizalion ofthe Wisconsin Steel Works Site (Emily Fahsl and Matthew Lamb), 1997-1998.
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PAH Contaminalion at Altgeld Garden';; (Kimberly Mertz and Neal**Stetl~m),** 1997-1998. An Analysis of Natmal AUenu£ltion at the United States Steel SOLith Works Site (Lisa BongiovmHli, Sanne Knudsen, Todd Wildermuth), 1996-1997, Assessing Wellnods**Crer~tion** {)Od Lnndfill Q(ls Reuse Projects ttt Site Adjacent to Indian Ridge and Big M<1rsfles (Bob Cummings and Nikki Ktyda), 1996-1997, Celotex Corporation Superfund Site (Pam Kearfott and Claire Hilger), 1996-1997. The. Lillie Village Air QLwlity AnalysiS (Jaime Hardt and Kary Hisricl1), J996-J 997. CONSULTING
Crowell & Moring, LLP (Imellectual property, plwtocalalysis patent analysis) industrial Facilities Engineering {Disinfection ofpuhlic drinking water supplies at a naval base) Cochrun, Cherry, Givens, Smith & Monlgomery, L.L.C. (environmental justice, investigated property and grOtmdwater contamination from land-fill in Michigan) !\1unday and Nathan (investigated suspected contamination ofgroundwater) Edward Scanlan Law Office (1:1quifer and soil**conl<~mination** by TCE at Lockformer .sile in Lisle, IL) Levy and Leopold Law Office (PAH contamination at CHA facility, Altgeld Gardens) Sugar Law Center for Economic and Social Justice (Soil contamination and inadequate browniield cleanup on Detroilpublic school site) City ofThornton, CO ({Organic Characterization & Sllrface Water Quality for Indirect Potable Reuse, testified before Colorado Water Board on the development of organic carbon control and in Water Court) The W'etlands Initiative (VarioLJs Restoration Projects along the Illinois and Chicago Rivers; wetland restoration, nutrient dynamics) Burlington, WI Giardia outbreak (Expert for Plaintiffs on Water Quality and Drinking Water Treatment) Cascino Vaughan, Chicago, IL (Milwaukee Cryptosporidium Outbreak, Expert for Plaintiffs un Coagulation Process and Use ofPolymeric Coagulants) Employment Research and Development, Inc. Wilmette, lL (ac-creditation testing) Bums and McDonnell Consulting Engineers, Kansas City, MO (Organic Characterization and Surface Water Quality for Drinking Water Treatment] Orange County Water District (Organic Characterization and Surface Water Quality for Indirect Water Reuse) Safety Kleen (\Vaste Characterization & Treatment) KDF fluid Trealment. Inc.• Ml (Pilol Testing Iron Removal Calalyst) Midland Resources, Inc., La\\Tence, KS (Chan1cterizatiun and Use ufPu1ymeric 1run Coagulant)

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EXHIBIT4

Citizens Utility Board,

### Ameren Corporation's Performance Under theIllinois Electric Service Cnstomer Choice andRateRelief Law of 1997 (February 2006)

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# Ameren Corporation's Performance Under the Illinois Electric Service Customer Choice and Rate ReliefLaw of 1997

Produced for the Citizens Utility Board By Edward Bodmer February, 2006

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Executive Summary This report summarizes an iodependent study ofAmeren Corporation's performance under the Illioois Electricity Restructuring Act ("the Act"). 1 

### Primary fmdings ofthis study include: (I) Investors io companies that owned Illioois assets pmchasedbyAmeren have realized $2.6 billion io value from passage ofthe Act. Predecessor companies iocluded utility companies- Illioova, CILCORP and CIPS- as well as Merchant Companies that purchased generation assets- AES and Dynegy. (2) Even excludiog profits realized by Illioova, CILCORP, CIPSCO, Dynegy and AES, Ameren's iovestors have realized returns far above both the S&P 500 and other utility companies. In dollar terms, Ameren iovestors have gaioed $2.1 billion more than they would have generated from iovestiog io other utility companies. (3) Ameren is well positioned to increase its earnings io the future even ifIllioois rates stay at current levels as its retum on equity from its generation busioess

- currently 28%

- is increasing due to high natmal gas and oil prices. (4) The aggregate amount earned by investors exceeds the value ofthe rate reductions to consumers ofillioois Power, CIPS, CILCO and Union Electric. The value ofrate reductions has been about $800 million, far less than the iovestor benefits. 

### Introduction Ameren's Illinois operations are currently madeup primarily ofassets that have been acquired since the passage ofthe Act. When Ameren pmchased these assets, itpaidhigh prernimns to investors ofthe acquired companies. Ameren's current utility holdiogs in Illioois include the regulated AmerenCIPS, AmerenCILCO, and AmereniP, and unregulated AmerenEnergy affiliates. Atthe time the Act was passed io 1997, Illinois Power (now AmereniP) and CILCO (now AmerenCILCO) were iodependent companies. As the Act was being debated, CIPS (now AmerenCIPS) was io the process ofmerging with Union Electric to form Ameren. Because ofthe timing ofthese acquisitions as well as the separation ofthe generatiog assets ioto a subsidiary company, the performance of assets currently owned byAmeren carmot be gauged solely by analyziog the performance ofAmeren's stock price. Investors io companies other than Amerenhave benefited by about $2.6 billion from realizing theproceeds ofacquisition payments and from retaining generation assets. The primary iovestor groups who have benefited include:

1 The Electric Service Customer Choice and Rate ReliefLaw of 1997. (220 ILCS 5/16-101 et seq.) 

### 2

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• Investors in illinova who realized $838 million or a 49% return in a two-year period following the signing ofthe Actwhen they sold their shares to Dynegl;

• Investors in Dynegy who were effectively able to secure Illinois Power generation assets at a discount to their market value through selling Illinois Power distribution operations to Ameren at a premium. The approximate value to Dynegy ofkeeping the Illinois Power generation assets is $1.2 billion;

• Investors in CILCORP who realized $275 million or a 52% return over the one an a halfyear time frame after passage ofthe Act from selling their shares to AES;

• Investors in AES who realized a profit of$156 million from reselling CILCO to Ameren in 2003 after purchasing the company in 1998.

• Investors in CIPSCO who realized a premium ontheir shares of$113 million when Ameren completed the merger at the end of 1997. This premiumis over and above the amount CIPSCO shareholders would have received had the companies notmerged.

$2,500
$2,000
$1,500
$1,000 

### Value Recieved By Investors other than Ameren ($Millions)

Despite all ofthese transactions and realization ofprofits by many different investor groups, Ameren still was able to realize a rate ofreturn four times as high as the S&P 500

2 The source ofthe returns and financial data are reports filed by Ameren, illinois Power, Dynegy, and CILCORP to the SEC. 

### 3

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## * * * * * and double the retum ofthe utility company stock index. Ameren's stock value increased 346 percent more than the increase in value ofthe S&P 500. The manner in which these investor groups profited from the Act is described in the next section. 

### Summary ofMerger Activities As mentioned before, Ameren's current Illinois operations are the result ofvarious mergers and acquisitions. These mergers and acquisitions include:

• Ameren purchased CILCORP assets from AES (an Enron type merchant company) in early 2003 for $1.4 billion. AES had earlier purchased CILCORP for $1.244 billion implying that AES profited by $156 from holding CILCORP for a few years 3 

### The financial benefits that accrued to AES investors are not included in an analysis ofAmeren's stock price.

• Prior to the Ameren purchase ofCILCORP fi·om AES, AES made a bid to purchase CILCORP for $65 per share in late 1998. CILCORP's shareholders did very well from the AES purchase because CICLORP's share price was $44.75 at the end of 1997 when the Act was passed. CILCORP shareholders also received a dividend of$3.08 per share between passage ofthe Act and the AES acquisition. The stock price together with the dividend yielded a return of52% over less than two years to investors who would have purchased CILCORP shares at the date the Act was passed. On a dollar basis, the AES acquisition value including debt and equity was $1.244 billion.' The value ofthe $65 share plus the $3 dividend less the 1997 stock price of$44.75 on an aggregate basis was $275 million. The fmancial benefits realized by CILCORP shareholders are not

· included in an analysis ofAmeren's stock price alone.

• Ameren purchased Illinois Power's transmission and distribution assets from Dynegy in 2004 for $2.3 billion. Dynegy kept IP's generating assets in its generation portfolio which include about 4,000 MW ofcoal capacity. Since Dynegy earlier purchased all ofIP assets for $4.6 billion and then sold the distribution assets for $2.3 billion, it effectively paid $2.4 billion for the generation. Dividing the $2.4 billion by 4,000 MW ofcapacity implies that Dynegy paid a net cost of$595/kW for the IP generation. Assuming (very conservatively) that the coal capacity is now worth $800/kW inthe market5

, 

### Dynegy has been able to realize a profit of$1.221 billion from the merger transaction. The financial benefit that has accrued to Dynegy shareholders also is not included in an analysis ofAmeren's stock price below.

• Dynegy originally purchased IP from Illinova Corporation for $33 per share or $4.6 billion inmid 1999 6 

### Illinova's share price was $23.785 when the Act was passed. Including 2 years ofdividends at $0.31 per quarter, Illinova's

3 The source ofnumbers in this section is from financial reports and merger documents presented by Ameren, CILCO, and lllinova to the SEC. 4 The value consists of$884 million in equity plus $360 million in debt. 5 The value ofanew coal plant is almost $2,000/k:W and valuations using current power prices would probably imply values above $1,000/kW. 6 The lllinova/Dynegy transaction was a compleX: share exchange transaction involving the spin-offby Dynegy ofChevron. The effect ofthe transaction was payment ofapremium to Illinova shareholders. 

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shareholders realized a return of49% over the two-yearbetweenpassage ofthe Act andthe Dynegy purchase. Since there were 71.7 million shares outstanding in 1997, the profit realized by Illinova investors was $838 million. The financial benefit that has accrued to Illinova's shareholders also is not included in any analysis ofAmeren's stock price.

• Union Electric and CIPS were in the process ofmerging when the Act was passed. At the end of 1997, the mergerwas completed through a share exchange transaction where CIPSCO shareholders received 1.03 shares ofAmeren for each oftheir original shares. Since p1ior to announcement ofthe merger in 1996, CIPSCO shares were trading at about a 6% discount to UnionElectric shares, the transaction provided CIPSCO with a 9% premium. Applying the 9% premium to CIPSCO market value implies that CIPSCO shareholders eamed a premium of $131 million above their market value before the merger was announced. The premium paid to CIPSCO means that its shareholdersprofited on a relative basis by more than Ameren shareholders from passage ofthe Act. These investors effectively retained the assets ofAmeren and also received the premium.


### Analysis ofAmeren's Financial Performance Unlike other beneficiaries ofthe 1997 

### Ace, Ameren's return on equity has not shown a dramatic increase sincepassage ofthe Act. This is because Ameren's equity base (the denominator ofthe retum on equity calculation) includes the premiums the companypaid to the investors ofillinova, CILCORP, CIPSCO, AES and Dynegy. The returns of Ameren are also affected by regulatory events inMissouri andprofits from the natural gas business. The retum on equity graphbelow shows that Amerenrealized a return in 2004 (the latest year for which a full year ofdata is available from Ameren's annual report) of just above 10%. Without the premiums paid to non-Ameren investors in merger transactions recorded as goodwill, the return would have been 12.27% --which is higher thanthe retums being allowed to utility companies elsewhere inthe nation. The subsidiary company that now owns Illinois generation assets has a very highreturn ofabove 28%. This return has been consistently above 20% ever since the generating company was formed in 2000. Inthe future, the generating company should earn evenhigherreturns as the marketprices increase withthe sustained highprice ofoil and natural gas.

7 An analysis ofthe performance ofinvestors and ratepayers is made in the report "ComEd!Exelon's Performance Under TheIllinois Electric Service Customer Choice And Rate ReliefLaw of 1997 And Beyond." 5

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30.00%
25.00%
20.00%
15.00% 

### Ameren Return on Equity

Ameren Including Goodwill Premium Amerer1 without Goodwill Premium Genco· Illinois Generation



### The most important implication from the return on equity graph above is projection of what will happen to Ameren's returns in the future once the rate freeze ends. Ameren itselfprojects rate increases of20-35%, as shown below in an excerpt from a presentation made to investors.



# Post-2006IL Revenue Im

11 

### We estimate average electric rates, on a combined basis, oould increase. by 20% to 35% over present bundled rate levels

., This rate expectation assumes:**~** August 2005 wholesale (shaped) price levels in the range of$55 per MWh
• Power prices repre,ent in the range of70% ofthe estimated 2007 average elec::tric: rate increase**~** Delivery service rates reset based on. traditional cost of service ratemaking



### Given that Ameren's profits have been depressed because itpaid merger premiums to the investors ofCIPS, Illinova, CILCORP, AES and Dynegy, who reaped substantial benefits from the Act, one would not expect Ameren's shareholders to have realized much benefit. However, despite these premiums, the stock performance ofAmerenhas been better than the utility and the S&P 500 index. Consider an investor who owned one share ofAmeren at the end of 1997. At the end of 1997, the stock value was about $39/share. 

### 6

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80.00 75.00 70.00 65.00 60.00 55.00 50.00**~5.00** 40.00 35.00 30.00 25.00 20.00 15.00 10,00 5.00 0.00 Ameren Investor Return since 1997 versus S&P 500 and Utility Index

1997 1998 1999 2000 2001 2002 2003 2004 2005



### The returns realized by an investor who putmoney in Ameren shares or the S&P 500 or the utility fund are demonstrated by computing the overall percentreturn and the dollar amount that has been realized. The graphbelow illustrates that Ameren investors have realized an 80% increase while the same investment inthe S&P 500 fund would have generated only 23%. The Amerenreturn is almost four times as much as the S&P 500. Similarly, the investor return of41% on utility shares is halfthe return realized by the Arneren investment.

7

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The table below shows how Ameren investors have fared on an aggregate basis. There were 137 million Ameren shares outstanding at the end of 1997. Multiplying these shares by increase in share value ($72-$39) produces an aggregate value of$4.4 billion. By contrast, the S&P fund on an aggregate basis would have only yielded $12 billion, implying the Ameren shareholders earned $3.1 billion more thanthe S&P 500. Similar numbers for the overall utilities fund reveals that Ameren investors realized $2.1 billion more than other utility companies.

Value Shares Value per in Value in Versus Share 1997 ($Millions) Ameren Ameren Initial Value $39.69 137.215 $5,445.72 2006 Value 71.56 137.215 9,819.11 Increase 4,373.39 0.00 S&P Initial Value 39.69 137.215 5,445.72 2006 Value 48.90 137.215 6,709.49 Increase 1,263.77 3,109.62 Utilities Initial Value 39.69 137.215 5,445.72 2006 Value 55.97 137.215 7,680.17 Increase 2,234.45 2,138.94



### Investor Value as Compared to Ratepayer Value The Act providedbenefits to residential ratepayers inthe form ofrate reductions. These rate reductions werehigher for Illinois Power than for UnionElectric, CIPS and CILCO.8

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The rate decreases for Illinois Power (15% in 1998 and another 5% in 2002) were more than the reductions for the other companies. The aggregate value ofthe rate decreases has been approximately $800 million as shown on the table below 8

Value of Rate Reductions in $ Millions IP CIPS UE GILCO Total 1998 $35.00 $5.75 $1.46 $3.13 $45.33 1999 $70.00 $11.49 $2.92 $6.25 $90.67 2000 $70.00 $11.51 $2.98 $6.29 $90.79 2001 $70.00 $11.54 $3.03 $6.34 $90.91 2002 $90.00 $11.56 $3.09 $6.38 $111.G3 2003 $100.00 $11.58 $3.15 $6.42 $121.15 2004 $101.53 $11.61 $3.21 $6.46 $122.80 2005 $103.06 $11.63 $3.26 $6.50 $124.45 Total $639.59 $86.67 $23.10 $47.76 $797.12



### The aggregate value ofthese rate increases pales in comparison to the $2.6 billion realized by investors in predecessor companies, without even considering the financial performance ofAmeren. However, to accurately compare the rate reductions with investor benefits, we included the value ofAmeren investors relative to other utility companies. This is necessary because Ameren generates returns from Missouri as well as Illinois operations. (We assume that as a regulated Missouri utility, the investors would have received about the same value as the utility index.). On this basis, the graph below demonstrates investors have received almost six times the value that has been received by ratepayers.

Ratepayer and Investor Value in$ Millions

$5,ooo

# Ti~~~~~~ $4,500 

# f $4,000 $3,500 $3,000 $2,500 

### Predecessor Company Value, $2,604

$2,000

# _j___----'::====='---------4--------,-----,-{ $1,500**+-~~~~~~~~~--!** $1 ,000

# ~~ii~i~iiii~=q

$500 

# + $Ot-= Ratepayer Value 

### Ameren Value \13 

### Utilities, $2,139

Investor Value

8 The source ofthe lllinois Power figures are numbers provided in SEC documents. The source ofthe other figures are residential revenue figures from the FERC Form 1reports. 9

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Summary Ameren has been able to generate substantial returns to shareholders despite the premiums the company has paid to the investors ofCIPS, Illinova, CILCORP, AES and Dynegy. The assets that Ameren now controls have been very profitable and, if Ameren's management's projections are accurate, the company is poised to become one ofthe most profitable utilities in the country.



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EXHIBITS

Comments oflllinois Health Professionals (August 10, 2012)

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August 

### 10, 2012
lllinois Pollution Control Board c/o John Therriault Assistant Clerk ofthe Board James 

### R. Thompson Center 

### 100 W. Randolph Suite 

### 11-500 Chicago, illinois 

### 60601
Re: Docket No. 

### PCB 2012-126
DearMembers ofthe illinois Pollution Control Board:
As health professionals living and working in illinois, we support the Multi-Pollutant Standard (MPS) adopted by the illinois Pollution Control Board in 

### 2006. By controlling powerplant emissions ofsulfur dioxide (SOz), nitrogen oxides (NOx), and mercury, the MPS helps protect the air we breathe, the local fish we eat, and the wildlife and natural spaces we love from harmful pollution. We are concerned by the present effort to weaken the MPS before the illinois Pollution Control Board. We urge youto vote against any action eroding MPS standards. Nationally, coal-fired powerplants are the largest sources ofSOz and mercury emissions, and are among the largest single source emitters ofNOx. Emissions ofthese air pollutants impact human and ecosystem health in a number ofways. Exposureto mercury, a potent neurotoxin, can result in developmental delays (e.g. speech, motor, and memory skills) in children, and cause nervous system damage in adults. High levels ofS02 

### and NOx can exacerbate respiratory symptoms in at-risk individuals (including children and the elderly), including asthma and COPD attacks. Wildlife andplant species are also impactedby the toxic effects ofthese pollutants, (e.g. reproductive impacts ofmercury to wildlife, SOrderived acid rain damage to foliage). 

### In addition to the health impacts ofdirectly regulated chemicals, S02 

### and NOx are also precursors to other harmful pollutants such as fine particulate matter and ground-level ozone. Fine particulate matter (PMz.5) is a complex mixture ofsolid and liquid particles, and a very large proportion ofmeasured PM2

### .5 results from the chemical transformation ofS02 

### and various NOx molecules in the atmosphere. Numerous scientific studies and authoritative panels have identified PM2

_ 

### 5as harmful to human health, with causal linkages found between short- and longterm exposures and premature mortality and cardiovascular effects. According to a 

### 20l 

### 0 report by the National Research Council, in 

### 2005 alone, the annual health and related damages from particulate, NOx, and S02 

### cost the public 

### $62 billion 

### (2007 USD). The vast majority 

### ($53 billion) ofthese costs were due to health damages associated with the transformation ofS02 

### into 

### PMz.5-

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As it stands, the MPS is designed to require substantial reductions in the emission rates ofSOz, 

### NOx, and mercury. These reductions will allow for substantial gains in the public health ofour state and surrounding regions, particularly for vulnerable populations. By maintaining the present MPS emission rate requirements for each ofthe pollntants, you will ensure that the health improvements behind the spirit ofthe lawremain intact, and that the public does not bear the costs ofpolluter non-compliance. We applaud you for your decision to putthe MPS in place six years ago, and we ask that you continue to showyour support for this standard by voting against any effort to weaken its protective power. Sincerely', Paul Brandt-Rauf, DrPH, MD, SeD Susan Buchanan, MD, MPH Director Great Lakes Center for Children's Environmental Health University oflllinois at Chicago School ofPublic Health Robert Cohen, MD, FCCP Director Pulmonary and Critical Care Medicine Cook County Health and Hospitals System Samuel Dorevitch, MD, MPH AssociateProfessor Division ofEnvironmental and Occupational Health Sciences University oflllinois at Chicago School ofPublic Health Peter Orris, MD, MPH, FACP, FACOEM Professor and Chief of Sen•ice Occupational and Environmental Medicine University oflllinois Hospital and Health Science System Nancy Quesada, MD Director Ambulatory Pulmonary Medicine and Rehabilitation Stroger Hospital ofCook County Doctors Council SEIU Fred Martin, MD, and VP ofDoctors Council SEIU Ann 

### Krantz, MD Paula Kovarik, MD Lisa Henry-Reid, MD Simon Piller, MD (representing 500 healthprofessionals throughout Cook County) Sarah Lovinger, MA, MD Executive Director, Chicago PSR Physicians for Social Responsibility

*Affiliation for information only. Notto imply institutional endorsement.

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Non·inaAllen AssistantProfessor 

### Department ofPreventive Medicine Northwestem University Feinberg School of Medicine Susan Altfeld ClimcalAssistantProfessor 

### Community Health Sciences University ofillinois at Chicago, School of Public Health Bapu P. Arekapudi CEO, Lake Shore MedicalAssociatesLtd 

### Pulmonary Critical Care Medicine (retired from Clinical Practice) Emeritus StaffAdvocate illinois Medical Center Robert Bailey Professor 

### Epidemiology and Biostatistics University oflllinois at Chicago, School of Public Health Cynthia Barnes-Boyd Director 

### Great Cities Institute and School ofPublic Health University ofillinois at Chicago, Neighborhoods Initiative Michelle Birkett ResearchAssistantProfessor 

### Medical Social Sciences Northwestem University Eric Bollinger Professor a_(Biological Sciences 

### Biology Eastern Illinois University Judith Bramble Associate Professor 

### Enviromnental Science and Studies DePaul University Michelle Burns ResearchAssistantProfessor 

### Department ofPreventive Medicine Northwestern University Feinberg School of Medicine Kenzie Cameron ResearchAssociate Professor 

### Department ofMedicine/Division ofGeneral Internal Medicine and Geriatrics Northwestern University Lorraine Conroy Professor 

### Environmental and Occupational Health Sciences University ofIllinois at Chicago, School of Public Health John Cronan Professor andHead of Microbiology; Professor ofBiochernisfly;Microbiology Alumni Professor 

### Microbiology Biochemistry Insitute for Genomic Biology University ofIllinois DavidCugell BazleyProfessor ofPulmonmyDiseases 

### Northwestem University Feinberg School of Medicine Bethany Cutts AssistantProfessor 

### Natural Resources and Environmental Sciences University ofIllinois Ann Marie Dunlap, M.D. Leslie Duram Professor andDirector 

### Environmental Studies and Geography Southem Illinois University Linda Ehrlich-Jones ResearchAssistantProfessor. 

### Physical Medicine & Rehabilitation, InStitute for Public Health & Medicine, Center for Health Care Studies Northwestern University Nurtan Esmen Professor Emeritus 

### Occupational & Environmental Health Sciences University ofIllinois at Chicago

*Affiliation for information only. Notto imply institutional endorsement.

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Michael Fleming Public Health Northwestern University Vincent Freeman AssociateProftssor of Epidemiology Division ofEpidemiology and Biostatistics University ofillinois at Chicago, School of Public Health Willard Fry Professor Emeritus of Clinical Surge1y Northwestem University Feinberg School of Medicine Sylvia Furner AssociateProfessor-Emerzta Epidemiology and Biostatistics University ofillinois at Chicago, School of Public Health Karen Gaines Biology Centerfor Clean Energy Research and Education Eastern illinois University Godfrey 

### Getz Pathology Department University ofChicago Aida L. Giachello Proftssor Department ofPreventive Medicine & Institute for Public Health 

### & Medicine Northwestern University Zsuzsa Gille Professor Jennifer Gray-Stanley AssistantProfessor Public Health Northern Illinois University Philip Greenland Professor Preventive Medicine Northwestern University Ravi Grivois-Shah, MD MPH Arden Handler Professor Community Health Sciences University oflllinois at Chicago, School of Public Health Ronald Hershow Associate Proftssor of Epidemiology Division ofEpidemiology and Biostatistics University ofIllinois at Chicago, School of Public Health Lifang Hou Department ofpreventive Medicine Northwestern University Robert Hudson Associate Professor Department of Natural Resources andEnvironmental Sciences Natural Resources and Environmental Sciences University oflllinois Susan Hughes Professor andResearch Center Director Community Health Sciences University ofIllinois at Chicago, School of Public Health H. Ari Jaffe Chief- Pulmonmy, Critical Care & Sleep Medicine Jesse Brown VA Medical Center Carolyn Jarvis Professor School ofNursing Illinois Wesleyan University Neil Jordan AssistantProfessor Institute for Public Health 

### & Medicine Northwestern University Feinberg School of Medicine Karen Kaiser ResearchAssistantProfessor Department ofMedical Social Sciences Northwestern University Feinberg School of Medicine

*Affiliation for information only. Notto implyinstitutional endorsement.

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * 

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Linda Kaste Associate Proftssor Ped Dent and Epi/Bio University ofillinois at Chicago Michele Kelley Associate Proftssor SeemaKhan Professor Surgery/Cancer Center Northwestern University Khash Khazaie Associate Professor Medicine Robert H. Lurie Comprehensive Cancer Center, Northwestern University AnLi Proftssor School ofPublic Health University ofillinois at Chicago Yongliang Li Associate Research Professor Environmental and Occupational Health Sciences University ofillinois at Chicago Darcy Majka Division ofRheumatology and Department of Preventive Medicine Northwestern University Feinberg School of Medicine R. Meganathan DistinguishedResearch Professor Biological Sciences Northern Illinois University Susan Meiers Associate Professor Biology Western illinois University Robin Mermelstein Proftssor andDirector Institute forHealth Research and Policy University oflllinois at Chicago Kelly Michelson Associate Professor Pediatrics Northwestern University Ann 

### & Robert H. Lurie Children's Hospital ofChicago Craig Mizzen Associate Professor Dept. ofCeil 

### & Developmental Biology, Institute for Genomic Biology University ofillinois David Mohr Proftssor Preventive Medicine Northwestern University Darby Morhardt ResearchAssociate Professor Cognitive Neurology and Alzheimer's Disease Center Northwestern University Darlene O'Callaghan Associate Professor Nursing Saint Xavier University School ofNursing Larry Ouellet Research Proftssor of Epidemiology Epidemiology and Biostatistics University ofIllinois at Chicago Aaron Packman Professor Civil and Environmental Engineering Northwestern University Lucy Park Associate Proftssor Department ofPediatrics University oflilinois at Chicago, College of Medicine Nadine Peacock Associate Professor Community Health Sciences University oflllinois at Chicago, School of Public Health

*Affiliation for information only. Notto imply institutional endorsement.

### Electronic Filing -Received, Clerk's Office, 08/10/2012 

## * * * * *PC# 2409 * 

## * * * *

Timothy Pearman Director, Supportive Oncology; Assoczate Professor Medical Social Sciences Psychiatry 

### & Behavioral Sciences Northwestem University Feinberg School of Medicioe UshaRaj Anjuli S. NayakProfessor of Pediatrics Head, Department of Pediatrics; University of Illinois at Chicago; Physician-in-Chief, Children's Hospital Pediatrics University oflllinois at Chicago Children's Hospital University ofIllinois Hospital 

### & Health Sciences System Rosalind Ramsey-Goldman SolovyArthritisResearch Society Professor of Medicine Medicioe!Rheumatology Institute for Public Health and Medicine Northwestem University John Reeve AssociateProfessor Zoology Southem illinois University Carbondale Eric Ribbens · Professor Biological Sciences and Environmental Studies Michael Romano Professor Biological Sciences Westem Illinois University Nan Rothrock ResearchAssistantProfessor Medical Social Sciences Northwestem University Denise Scholtens Associate Professor Department ofPreventive Medicine Northwestem University Feinberg School of Medicioe Karen Sheehan Professor of Pediatrics & Preventive Medicine Pediatrics Northwestem University Ann & Robert H. Lurie Children's Hospital ofChicago Donald Sparling Associate Professor Cooperative Wildlife Research Laboratory; Department ofZoology Sonthem Illinois University Peter Sporn Professor of Medicine Director, Pulmonwy and Critical Care Medicine Fellowship Program Division ofPulmonary and Critical Care Medicine Northwestem University Feinberg School of Medicine Wesley Swingley AssistantProftssor Biology Northem Illinois University Sandy Tenfield AssistantProftssor; Niehoff School of Nursing Director Women's Health Nurse Practitioner Program Loyola University Chicago Linda Teplin Owen L. Coon Professor Vice Chair of Research; Director, Health Disparities and Public Policy Department ofPsychiatry and Behavioral Sciences Health Disparities and Public Policy Northwestem University Feinberg School of Medicine William Thompson AssistantProftssor Department ofMedicine Northwestem University Paloma Toledo Instructor inAnesthesiology Anesthesiology Northwestem University Feioberg School of. Medicine

*Affiliation for information only. Notto imply institutional endorsement.

### Electronic Filing- Received, Clerk's Office, 08/10/2012 

## * * * * *PC# 2409 

## * * * * *

Bernard Turnock ClinicalProfessor andDirector Community Health Title University oflllinois at Chicago, School of Public Health Joel Voss AssistantProfessor Medical Social Sciences, Neuroscience Program Northwestem University Leah Welty AssistantProfessor Department ofPreventive Medicine Northwestem University Snsan Yount AssociateProfessor Medical Social Sciences Nortl1westem University Feinberg School of Medicine

*Affiliation for information only. Notto imply institutional endorsement.

### Electronic Filing- Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * *

EXIDBIT6

National Research Council,

### Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use (2010), Public Access File 34, Estimates ofdamages associated with specific coal-fired electl'icity-generating facilities and natural-gas-fired electricity gene•·ating facilities

### Electronic Filing -Received, Clerk's Office, 08/10/2012 * * * * *PC# 2409 * * * * 

## * 

# THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, andMedicine

Public Access Records Office INVOICE- Public Access File Records Request



### July 6, 2012 Dear Mr. Armstrong: SOD Fifth Street, N\N Washington,- DC 20001 Phone: 202 334 3543 Fax: 202 334 2158 E-mail: PARO@nas.edu www nationalacademies.org



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