E(ectronic Filing- Received, Clerk's Office, 08/10/2012 

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

AMEREN ENERGY RESOURCES, 

Petitioner, 

v. 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, 

Respondent 

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PCB 12-126 

(Variance- Air) 

NOTICE OF FILING 

To: Attached Service List 

PLEASE TAKE NOTICE that I have today electronically filed with the Clerk of the 

illinois Pollution Control Board Comments of Environment lllinois, the Environmental Law 

& Policy Center, Natural Resources Defense Council, Respiratory Health Association, and 

Sierra Club, a copy of which is attached hereto and herewith 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 __ 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

AMEREN ENERGY RESOURCES, 

Petitioner, 

v. 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, 

Respondent. 

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) 

) 

) 

) 

) 

) 

) 

) 

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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 1 04.224( d), Environment lllinois, 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 Energy Resources ("AER") with the lllinois Pollution 

Control Board ("Board") on May 3, 2012. Since filing its Petition, AER has had the opportunity 

to submit written responses to two sets of questions from the Board and present testimony at the 

Board's August 1, 2012 public hearing. Nevertheless, AER continues to fall far short of meeting 

its heavy burden in justifying a variance from lllinois' Multi-Pollutant Standard ("MPS"). 

Among the defects in AER's proposal: 

• AER has refused to commit to a definite compliance plan with the MPS' sulfur 

dioxide ("S02") emission limits, but instead 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 of the options available to it for reducing 

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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 of keeping them within their regulated distributing company, and benefited 

handsomely from their decisions for many years. 

• AER has not presented an honest appraisal of the environmental impact of its 

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, AER has failed to present a sufficient basis for the Board to upset the standard described 

by the then-Director of the lllinois Environmental Protection Agency ("IEPA") as "one of the 

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 of lllinois' variance process is that the purpose of a variance is for temporary, not 

permanent, relief from aBoard regulation. Monsanto Co. v. !PCB, 67 Til. 2d 276,286 (1977) 

1 Oeersight: EITVironmental Protection Agency's Clean Air Regulations- One Year after the CAIR and CAMR 

Federal Court Decisions: Hearing Before the S Subcomm. On Clean Air and Nuclear Safety of the S Comm. On 

Environment and Public Works, !lith Cong. 2 (2009) (written statement of Douglas P. Scott, Director, Illinois 

Environmental Protection Agency), available at 

http:/ /epw.senate. gov/public/index.cfin?FuseAction=Files. View&FileStore _id=fc4c5288-525a-4 7 d6-8!2c809d000c617b ('Scott Test.") (attached hereto as Ex. !). 

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("[T]he concept of a variance which permanently liberates a polluter from the dictates of a board 

regulation is wholly inconsistent with the purposes of the 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 of the compliance plan." 35lll. Adm. Code 104.204(±). To ensure that a 

proposed variance provides only time for compliance to be achieved, and not permanent 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 itself acknowledges is uncertain. If a 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 of its 

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 power prices rebound ... "); Petition at 21-22 ("unless and until power price 

market conditions improve ... "). 4

· See Petition, Ex. 5, Rygh Aff. at 1]11 ("Unlike their regulated utility peers, unregulated power companies do not 

enjoy the benefits of recovery 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 power prices as the key means of one 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 if power 

prices rise and AER can access third-party financing. 

In fact, AER itself acknowledges there is little certainty as to if or when power prices 

might rise sufficiently for completion of the Newton FGD project. Under questioning from the 

Board and its technical staff, Ameren Services Company's Vice President of Environmental 

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 

of alternative plans for compliance during the remaining term of the 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 are just 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, but beyond that, we really just don't !mow at this point in time. 6 

5 See Rygh Test. Tr. 49: I 0-14 ('This means AER needs time to realize the effects of returning 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 of the 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 of the 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 gas prices reflects a permanent change across the US energy sector, and 

will make it more difficult for coal to compete with natural gas as a power source 

in the firture. A rise in gas-fired power generation will not be strong enough to 

raise natural gas prices on a sustained basis." -April 20127 

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 power prices are at best 

uncertain and quite possibly will remain low, noting the "prolonged weakness of the power 

markets" and the "flattening of the 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 chief merchant generation competitor in 

downstate Illinois, Dynegy Midwest Generation, even acknowledged that power prices may not 

recover from their current lows. 10 Given all of this uncertainty over improving power prices and 

AER's financial health, and the dependence of the compliance plan on these factors, the Board 

must deny AER's Petition for lack of a definite compliance plan that assures compliance, unless 

AER can demonstrate that it has a plan through which it will definitely achieve compliance. 

7 Petition, Ex. 5, Rygh Aff. at 1]7. Elsewhere in his 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 up Illinois 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 of the 

compliance plan required by the Board's rules. 35lil. Adm. Code 104.204(±). The compliance 

plan must contain a "time schedule for the implementation of all phases of the control program 

from initiation of design 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 of its 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 meet the legal standard of a "detailed compliance 

plan" and, thus, the Board must deny the variance. 

Other factors cited by AER in support of its variance request may likewise prove 

permanent features of AER's economic picture, as well, such that any relief granted based on 

these factors would not be temporary as required by law. Monsanto Co., 67lll. 2d at 286. These 

factors include the age of AER' 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 of variance 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 now before the Board, AER's 

11 Menne Test. Tr. at 32:12-33:6. 12 Tr. at 33:2-6. 13 See Ameren Energy Generating Co. et al. v. !EPA, PCB 09-21 (Oct. I, 2008) ('2008 Petition for 

Variance"). Relief was eventually granted through a rulemaking. See In the Matter of Proposed Amendments to 35 

Ill. Adm. Code 225: Control of Emissions From Large Combustion Sources (Mercury Monitoring), R09-l 0 (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 of the Board, still unable to present a 

definite and detailed compliance plan. The Citizens Groups are aware of and acknowledge the 

severity of the economic downturn that hit illinois and the United States beginning in 2008. But 

it would frustrate entirely the goals of environmental regulation in Illinois if agreed-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 Board must 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, AER has failed to show any cognizable hardship because it has not 

explored all feasible alternatives for lowering its S02 emissions, and because any hardship AER 

now faces was self-imposed by AER and the Ameren Corporation's own business decisions to 

opt into the MPS ts and to operate their illinois generating plants through a deregulated entity 

instead of keeping 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 Act provides that the Board may grant a variance when it fmds "that compliance 

with any rule or regulation, requirement or order of the Board would impose an arbitrary or 

unreasonable hardship'' 415 ILCS 5/35(a). In order to determine whether a hardship would be 

14 2008 Petition for Variance at 10. 15 For purposes of convenience 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 (which is 80 

percent mvned by Ameren Energy Generating). 

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"arbitrary or unreasonable," the Board must balance the extent of the individual hardship against 

the environmental impact of granting the variance. Monsanto Co. v. !PCB, 67lll. 2d 276, 292 

(1977). 

A petitioner for a variance bears a "heavy" burden. Willowbrook Motel P 'ship v.IPCB., 

135lll. App. 3d 343, 349 (1st Dist. 1985). The petitioner must show "that a variance is 

necessmy to avoid arbitrary or unreasonable hardship." !d. (emphasis added). In doing so, the 

petitioner must show that all alternatives for compliance with the standard are infeasible. See 

Allaert Rendering, 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 of a 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 Willowbrook Motel 

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 of power 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 in testimony 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. Allaert Rendering, 91lll. App. 3d at 162 (upholding 

Board finding that petitioner had not shown hardship because it had not demonstrated that all 

compliance alternatives were economically infeasible); Willowbrook Motel P '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 IEP A, it should be required to meet those lower emission levels 

as a condition of any variance. 

1. AER's Scope of Analysis and Criteria for Evaluating Identified Alternative 

Compliance Strategies Were Improperly Narrow. 

Although AER addressed two additional compliance alternatives-curtailing power 

production at unscrubbed units and use of dry sorbent injection ("DSI")-when pressed to do so 

by the Board, its evaluation of those 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, AER failed to demonstrate that a 

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

16 See AER's Responses to the Illinois Pollution Control Board Technical Unit's Questions at 2-3 (July 30, 201'2) 

('First AER Response"); AER's Responses to the illinois Pollution Control Board Technical Unit's Second Set of 

Questions at 2 (July 30, 2012) ('Second AER Response"). 

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additional strategies that it failed to evaluate at all, as discussed in subsection 3, infra-would not 

at least bring AER closer to the MPS requirements so as to further reduce emissions during any 

variance period. Indeed, AER has effectively admitted that it can do better than the limited 

reductions it has consented to in connection with its variance request, because AER has admitted 

that it can and will do more when necessary in order to meet CSAPR requirements. 17 

With respect to curtailment of production, AER informed the Board that 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 of production at the unscrubbed units would 

be infeasible, or what would happen if such lesser curtailment were effectuated together with 

other strategies. 

Similarly, with respect to DSI, AER failed to investigate the possibility of installing and 

implementing DSI at a rate short of what is needed to comply with the MPS, and to do so in 

combination with other methods of emission reduction. 19 It is 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 of approaches and methods-including both 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, AER First Response at 3 ("[I]n order to comply with the proposedldPS S02 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 the MPS via sorbent injection would 

entail installation of such controls (and baghouses) at virtually all of AER'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 of control options-including, inter alia, varying 

degrees of curtailment, varying degrees ofDSI implementation, use of ultra 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, but more minimally than if each was used alone, would achieve sufficient 

results. 

Indeed, even in the absence of the analysis that AER should have done, it is clear that it 

could do better than the anemic reduction to 0.3 5-0.3 8 Ib/mmBtu it has 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 of S02 control to meet CSAPR requirements. 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. If we have to do some sort of additional 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 claim that there are only two options before the 

company, either obtain a variance or shutter one or more of its generating stations. 22 As AER 

openly concedes, there is a third option of doing more than they are doing under the variance, 

that is, what they suggest they will do to meet CSAPR requirements, but doing it now, pursuant 

to a variance or the MPS, instead of later 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 of the Feasibility of DSI was Inadequate. 

As noted above, AER rejected the compliance alternative ofDSI. AER's dismissal of 

DSf3 is based upon three claims: variable removal rates, overburdening existing electrostatic 

precipitators (''ESPs"), and cost24 Nonetheless, all of these claims are negated by (1) AER's 

report ofDSI pilot testing at its Joppa plant, attached hereto as Exhibit 2; and (2) its earlier 

commitment to 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 of sorbent used for the test were Sodium Bicarbonate ("SBC," a product 

made from Trona) and Trona, the same sorbent that is the focus of Kimberly Gray's comments in 

this proceeding, attached hereto as Exhibit 326 

First, in terms of variability, AER dismissed the feasibility ofDSI, by stating, "AER's 

evaluation of sorbent injection reflects removal levels of 10 to 90%. Such variability in removal 

efficiencies reduces the effectiveness of this technology as a compliance altemative."27 

Nonetheless, the Joppa test results indicate that the variability of S02 removal was well within 

control of the operators (or testers, in this case). To be clear, the variability in removal efficiency 

was a result of the testers varying the testing parameters including type of sorbent, injection 

location, and injection rate28 Otherwise, the removal efficiency remained consistent29 Even 

with these variations, when injection rate was controlled with a goal of 50% S02 removal, the 

removal rate was much more consistent and in the range of 42% to 67%, not the 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, EEl Joppa Generating Station Dry Sorbent Injection Test Program, Final Report 

(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 AER in 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 of about O.l2lbs S02 removed per lb of SBC is needed (8.3 tons of SBC/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 of sorbent 

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 AERG may 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) at 42 (emphasis added), available at 

http://www.sec.gov/ Archives/edgar/data/18654/000 119312511134059/d 1 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 

supported by Kimberly Gray's comments. As Ms. Gray indicated, aDSI system's S02 removal 

rate is within the control of the 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 sorbent feed 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 of operator choice-not because of any inherent unreliability 

in the technology. 

Second, in terms of ESPs, 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 of such controls (and baghouses) at virtually all of AER'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 would be 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 of the 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 of 0.13%.38 Perhaps the most significant statement in the whole report is 

the conclusion that dry sorbent injection did not impact operations of the 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 limits39 

This directly refutes AER's testimony that dry sorbent injection overburdens their ESPs. 

Furthermore, Ameren Corporation SEC filings contradict AER' s claim regarding the 

sweeping requirement for baghouses and instead suggest that no baghouse is 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 of any mention of the capital expenditure needed for a baghouse at Joppa 

when assuming the use of dry 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 sufficient to address the addition 

of a Trona system without the conversion to a fabric filter."). 42 !d. ('With the use of trona, 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 of such alternative would exceed the cost to complete the Newton Scrubber'' 43 

This statement does not give a full and complete picture of the relative costs ofDSI and scrubbers. 

As stated in an Ameren Corporation SEC filing, "[c]apital requirements for some of these 

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% of the 

cost of wet 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 of variability and ESP impairment and cost, 

and demonstrate the viability of this alternative which AER failed 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 of these, 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 CSAPR requirements. 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 of a 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 of a larger 

set of emission 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 of coal. 

"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 20 l 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 of ultra low sulfur coal from 

Peabody "will help 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, Peabody Energy ink their largest coal deal ever, ST. Lours Bus. J., Aug. 4, 2011, 

available at http:/ /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 of AER'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 new EPA standards ... These 

measures include installation of the S02 scrubber at our Sioux Energy Center, the use of ultralow 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 itself acknowledged that 

natural gas conversion is a possibility. "Electric Energy [Joppa] does produce a small amount of 

power from natural gas, but [Bill] Sheppard [President of Electric Energy, Inc.] says if ... pnces 

[of energy from coal power] don't pick up, the company may need to do a major renovation and 

completely switch over. "52 This suggestion is consistent with the national picture of fuelswitching at existing coal-fired power plants. "Aging fossil stations are gaining new leases 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 of this 

option has only increased over recent years as natural gas prices have dropped. For instance, 

Alii ant 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 Smokestack Pollution at Regional Meeting, 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 Ben Jeffords. Electric Energy Inc. Lays Off 44 Employees, WSJL TV (June 13, 2012), 

http://www. wsiltv.com/news/local/Electric-Energy -Inc-Lays-Off-44-Employees-15895 8295 .html. 53 Robert Swanekamp, Old dog ... New tricks: Gas turbine repowering rejuvenates agingfossll stations, POWER 

ENGJNEERJNG, Oct. 1 , 2004, http:/ /WW\v.power-eng.com/articles/print/volume-1 08/issue-1 0/features/old -dognewtricks.html. 

54 Daniel Cusack, Alliant to build gas-fired plant on 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 of utilities, inc! uding those once bullish on coal, to 

reconsider whether to continue investing billions of dollars in pollution controls for 

coal . 55 

Together, these trends show the viability of this alternative which, again, AER failed to explore. 

AER's Petition must be denied because it has not demonstrated there are no feasible compliance 

alternatives. 

C. Any Hardship AER Faces is Self-Imposed and The1·efm·e Not Arbitrm-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 of the 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 that no 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 if entire 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); Allaert Rendering, Inc. v. !PCB, 91lll. App. 3d 160, 162 (3d Dist. 1980) 

(upholding denial of variance when Board found that "any hardship visited upon [the petitioner] 

is largely self-imposed"). Here, AER's claimed hardships should be discounted for two reasons: 

i) AER willingly opted into the MPS, and ii) Ameren Corporation chose to operate its generating 

plants through a deregulated entity instead of keeping 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. 

AER proposed, 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 Board jurisprudence, 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-imposed hardship includes a 

hardship that is foreseeable at the time a petitioner subjects itself to regulation. See Willowbrook 

Motel P 'ship v. !PCB, 135 llL App. 343, 345 (1st Dist. 1985) (upholding Board's denial of a 

variance after Board folllld tbat petitioners' acquisition of property 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 purchased folllldry 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 of right"). Thus, where tbe 

hardship borne by a petitioner is foreseeable at the time a petitioner subjects itself to regulation, 

that hardship is neither arbitrary nor llllreasonable. In such circumstances, a request for variance 

must be denied. See Willowbrook Motel P 'ship, 135 llL App. at 345; Lindgren Foundry, PCB 

70-1 (Sept. 25, 1970) at 8-13; see also Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367, 385 

("ordinarily ... modification[s to consent decrees] should not be 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 itself to the 

MPS. AER now complains that recent modulations in power prices and market conditions, 

AER's difficulty in obtaining financing, "regulatory uncertainty," the possibility that plants 

might need to be shut down if the variance is denied, and the MPS' S02 limits themselves render 

compliance with the MPS an arbitrary and unreasonable hardship. 57 Specifically, AER argues 

that "the impact of a CSAPR stay ... coupled with the drastic changes in power prices and 

market conditions in the span of several 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 of law. To begin with, "changes in power prices 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, AER recognized 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 in to MPS); !EPA Reconnnendation at 5. 57 Petition at I 0-22. 58 I d. at 15. At the public hearing on this matter, AER elaborated on this argument, claiming that ''the lvfPS ... was 

premised on the expectation that the power market would continue to support" the costs of installation of pollution 

controls. Menne Test. Tr. 19:16-24. 59 !d. at 15-17. 60 See Table 6.8 Natural Gas Prices by Sector, Selected Years, 1967-2010, U.S. ENERGY INFORMATION 

ADMINIS1RATION (2010), available at http://www.eia.gov/totalenergy/data/annual/pdf/sec6 _19.pdf (last visited Aug. 

10, 2012). 

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

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recognize it today62 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 of pollution 

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 power prices would vary-possibly in ways detrimental to tbe 

http:/ /seekingalpha.com/article/64 704-AER-corp-q4-2007 -earnings-call-transcript?part=single (Statement of W amer 

L. Bax"ier, Executive Vice President and Chief Financial 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/arnerenforml 0-k.htrn. In the 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 in connection 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 of AER ... are based 

primarily on dynamic and competitive market-driven commodity prices for, among other things, power and fuel, 

which can be 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. I 0, 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 cents per kilowatt hour (2004 dollars) in 2004 to a low 

of 7.1 cents per kilmvatthour in 2015 as a result of declines in natural gas prices and, to a lesser extent, coal 

prices."). 

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company-and it did not make 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 of lllinois 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 of a 

contract it has 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 180 N LaSalle Owner, 

LLC, 403 lll. App. 3d 1 (impossibility of performance doctrine does not excuse nonperformance 

due to financial distress); see also Bank of 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 of the 

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 of a 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 AER from 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 of a 

variance. See Citizens Utility Co. viPCB, 134TIL App. 3d 111,115 (June 17, 1985) (affirming 

Board's denial of variance extension because, "[i]fthe speculative prospect of future changes in 

the law were to constitute an arbitrary and unreasonable hardship, then the law itself would 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 of variance.") 

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 it be 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 not be 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 of any tightening of the 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 if the 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 if so, when it will be required to be implemented at 

sources." Id. at 14,30-31. 

Here, any regulatory uncertainty AER faces 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 about the rules AER is or will be subject to. Unlike in 

ExxonMobil, where the state NO, rule was intended to implement federal law but not 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 of that rule, will go into effect in 

the next few years, and that AER will need to take measures to comply with it 69 Unlike in 

ExxonMobil, where it was uncertain that the company would ever be obligated by federal law to 

make additional NO, reductions, it is and has been clear to AER that CSAPR is 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 Proposed New Ill. Admin. Code 225 Control of Emissions from Large Combustion Sources, 

R06-25 (Sept 20, 2006) (IEP A Post Hearing Co=ents) (" ... emission reduction requirements for S02 in the MPS 

[are] more stringent than the reductions required under CAIR. ''). 

69 See Menne Test Tr.40:8-41 :23 ("But ifyoubelieve that CSAPR is going to come back, which most people do, 

that it will come back into 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 ("AER believes that either CASPR [sic] or a 

regulatory replacement vvill be in place before the expiration of the 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 AER would have to make additional S02 

reductions above those required of generators 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 of CAIR, 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 of what rules were in place 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. 

AER received significant benefits from its negotiated agreement to the :MPS obligations. 

The variance proposal is an unjustified effort to keep hold of those benefits while dispensing 

with the associated obligations. 

70 AER admits that with CSAPR, "AER may ... be competing on a more equal footing in the market place." Petition 

at 15-16. CSAPR, the replacement for CAIR which AER recognizes will be reinstated (Menne Test. Tr. 40:8-

41:23), is more stringent than CAIR-placing generators subject to CSAPR in a position more like that of AER than 

they were when AERagreed to the J\.1PS. 71 Finally, the Board should not give credence to AER's claim that, in the absence of a variance, it would have to 

shut down two or more plants to comply with the MPS. As an initial point, as discussed in Section II.B, supra, AER 

has not met its burden of establishing 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 

contemplated by AER at the time it agreed to and opted into the MPS. In fact, the MPS provides for shutdowns to 

be used as a mechanism to 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 of operation, 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 of air 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 of the [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 prudent trade-offfor Ameren 

to make from the perspective of corporate financial stability, corporate management of 

construction projects (with associated operational stability), and the creation of opportunities 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 of effective controls across 

pollutants and, at the same time, supports the goal for industry of a more stable and certain 

regulatory frarnework'' 74 AER referenced and relied upon Dr. Smith's testimony in its posthearing comments recommending implementation of the l\IIPS. 75 

Additionally, Douglas P. Scott, then-Director ofiEPA, testified before the U.S. Senate 

Committee on Environment and Public Works, Subcommittee on Clean Air and Nuclear Safety 

72 See In the Matter of Proposed New Ill. Admin. Code 225 Control ofEmissionsfi·om Large Combustion Sources, 

R06-25 ("R06-25") (July 28, 2006) (Testimony of Anne Smith), at 10. 73 fd_ at 13. 

"Id. (Testimony of Michael 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 of illinois' 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 of installing 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 relief for 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% of a 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 of S02 and NOx76 

As described by Director Scott, AER and other companies who opted in to the MPS were 

afforded the substantial benefit of a 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 of the substantial benefit of flexibility reaped by AER and the other lllinois 

companies who took advantage of the MPS, IEP A strongly emphasized to the Board in 2006 the 

importance of the "once-in, always in" provision of the MPS regulations-i.e., the requirement 

that plant units opting into the MPS comply with it for the lifetime of those units. Without such 

a requirement, IEP A warned, regulated entities could take advantage of the 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 submitted by 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 of the illinois mercury rule. Otherwise a company 

might elect to opt-in to the MPS, receive the benefits of mercUTy control 

flexibility, and then opt-out of the MPS and comply with the othemise applicable 

requirements of the proposed mercury' rule absent the additional emissions 

reducaon requirements for NOx and SO 78 

2 

AER, in requesting a variance from the 802 requirements of the 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 of Accepting the Benefits of 

Deregulation. 

As discussed above, AER is not entitled to a variance if the hardship of which it 

complains is self-imposed. An essential element of the hardship of which AER complains is the 

financial burden of deregulation. 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 of its perceived benefits by choosing to enter into the 

deregulated market. Any "hardship" from that tum of events is simply the result of a business 

decision whose benefits and risks AER fully understood. And in the end, the financial burdens 

of deregulation are outweighed by the many years of benefits that AER received 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. 

At the Board's August I, 2012 public hearing, the Citizens Groups presented the 

testimony of Robert Kelter. Mr. Kelter has more than 20 years of experience working on 

regulatory issues related to energy and electricity. Mr. Kelter was Director of Litigation for 

illinois Citizens Utility Board ("CUB"). During Mr. Kelter's tenure at CUB, he represented 

CUB on legislative issues in Springfield, including drafting of legislation 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 of deregulation 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 of the 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 Relief Law 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 that joined to 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 at http://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 of continuing 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, it transferred 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 of electricity 

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) of the 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 of the 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 how rate relief would be provided.). See also Jay Nies, U.E. Favors Gradual Move 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 of an lllinois 

coalition that drafted and supports a bill pending in the Illinois legislature to phase in choice 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/cips 1 Oq2 .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 of CILCORP, parent of Centrallllinois Light Company, .... "84 As a part of 

the purchase of CILCORP, 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 of operations or liquidity. 86 

b. Ameren benefitted from deregulation 

Even though there are inherent risks in deregulation and Ameren was aware of those 

risks, Ameren's bet on deregulation paid off extremely well. Ameren's success in the 

deregulated market was aided by the lack of competition that resulted from massive 

consolidation of the market into three main generating companies upon initiation of deregulation, 

including the newly-formed Ameren. 87 The three large generators consisted ofExelon (parent of 

Commonwealth Edison), :Midwest Generation, and Ameren (parent of Illinois 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/datai18651/000 I 002910030003 54/arne I 0 -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/18654/000 I 002910-99-000020. tx-t. 87 Mike Kroll, The Chair Was Pulled Out From 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 of Citizens 

Utility Board, Dave] Kolata said. "(The auction) was set up to create the illusion of competition 

without the reality of competition. "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 of deregulation was to allow utilities to compete 

within the free market-with the lack of actual 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. 

89 Ameren customers in Illinois brace for 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 of these utilities e;:perienced record profits during this period."). 91 See Citizens Utility Board, Ameren Corporation's Perfonnance Under the Illinois Electric Se11Jice Customer 

Choice and Rate Relief Law of 1997 (Feb. 2006) (''CUB Report") (attached hereto as Ex. 4). 

'' Id. 93 !d .. 94 Kelter Test. Tr. at 71:1-6. 

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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 of balanced view of the profits and losses 

the plants have generated over the last decade." 95 

Ameren would have us believe that the point of deregulation was to allow utilities to earn 

unlimited retums while still placing the burden of the risk squarely on the taxpayers. 

Nonetheless, Ameren chose to transfer their plants to the unregulated side of their business, and 

for many years Ameren shareholders benefitted from this transaction. Ameren wanted the 

benefits of the power plants being under the control of AER when 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 of risk, and the 

Company chose to give up that protection."96 

In summary, any hardship that AER now faces in operating as part of a 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 AER has not and cannot 

demonstrate that deregulation is a hardship of the type that entitles them to a variance. 

3. AER' s Ha1·dship is a Self-Imposed Consequence Resulting From Its Business 

Decisions Made After Deregulation. 

AER has 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 of the deregulation legislation.) However, the 

inability of the 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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AER has not demonstrated that it cannot obtain financing from its parent, but rather that 

the parent does not want to provide fmancing. Notwithstanding the implication in the Petition 

that funding from Ameren Corporation is per se impossible98, Ameren Corporation's statements 

elsewhere more plausibly indicate that it could in principle finance its subsidiary, but has chosen 

not to for business reasons. 

As stated during an Ameren Corporation quarterly earnings call, 

Q: And just 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 of the 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 to provide 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 not to 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 the preference of Ameren Corporation not 

to not provide financing to AER, not that there is any inherent prohibition on such financing. 

98 Petition at 22-23. 99 Ameren Corp., Q4 2011 Earnings Call (Feb. 23, 2012 10:00 AM ET), (transcript available at 

http:// seekingalpha. corn! article/3 8 8 891 -AER -s -ceo-discus ses-q4-2 0 11-resu!ts-earnings -call-transcript?part=single) 

(emphasis added). The question was asked by Reza Hitucki, of Decade Capital, and answered by Martin Lyons, 

SVP and CFO of AER 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/18654/000 119312512224 293/d3 28507 d I Oq.htrn. 101 Petition, Ex. 5, Rygh Aff. at 10. 

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The preference of Ameren Corporation is a self-imposed hardship that, once again, does not rise 

to the level of the necessary demonstration of hardship that entitles a petitioner to a variance. 

In this regard, AER has made other business decisions over the years-most notably the 

almost complete reliance on coal that it has now come to regret-that have contributed to the 

creation of the "hardship" of which it now complains. Amereil' s own witness so conceded in 

stating, "AER and its subsidiaries have been some of the worst performing companies in their 

sector due to high reliance on coal fired generation and lack of foe! and market 

diversification." 102 The Ameren entities are not entitled under the law to label the consequences 

of their 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 of its 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 of its shutdown of the Meredosia and Hutsonville Energy 

Centers at the end of 2011. AER argues in this proceeding that these reductions should be 

recognized as a benefit of the 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 of AER's compliance plan for the MPS itself 104 Therefore, any 

102 Petitioner, Ex. 5, RyghAff. 1 7. 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 of the variance period 

as a condition of the relief granted." Second AER Response 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 of the 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 of AER's NIPS 

responsibilities, but rather a direct result of them, 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 of these 

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

A. AER Is Required to Present Evidence of Both the Amount of Emissions 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 

of demonstrating that "the hardship resulting from a denial of the variance outweighs any injury 

to the public or the environment from a grant of the 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 of emissions, discharges, or releases of the constituent in question if the 

variance is granted, compared to those that would result if immediate compliance were 

required." 3 5 lll. Adm. Code 1 04.204(g)(1 ). Second, the petitioner must include a "qualitative 

and quantitative description of the impact of petitioner's activity on human health and the 

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environment if the requested variance is granted, compared to the impact of petitioner's activity 

if immediate 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 if it 

fails to present evidence of the 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 of proof !EPA v. !PCB, 95 Ill. App. 3d 400, 405-

06 (3d Dist. 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 of 802 Emissions That Would Be 

Allowed By its Proposed Variance. 

AER's Petition should be denied because AER has failed to present credible evidence 

regarding either the amount of excess SO, emissions that would be allowed under its proposed 

variance, 3 5 lll. Adm. Code 1 04.204(g)(l ), or the environmental impacts of those emissions. 35 

ill. Adm. Code 104.204(g)(2). fustead, AER's description of the 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 would be allowed from the beginning of the variance in 2012 through the end of the variance 

in 2020, using a consistent heat input for the emission rates of the MPS and the proposed 

variance. This is precisely the analysis requested by the questions posed in the Hearing Officer's 

orders of July 5 and July 25, 2012. What the analysis below eliminates, compared to the 

perplexing and error-laden charts submitted in 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. !EPA Recommendation at 1[1[63, 66. 

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reductions that AER attributes to its December 2011 shutdowns of Meredosia and Hutsonville106 

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 of emissions "if the variance is granted ... to those that would result if 

immediate compliance were required"). 

Assessing the actual, real-world effects of the proposed variance, it would allow AER to 

emit over 32,000 more tons of S02 for the period of 2012 to 2020-nearly an additional year's 

worth of emissions from its fleet: 

106 July 5, 2012 Hearing Officer Order (Question 3(b): "Please state the amount of S02 emissions if the requested 

variance is granted, compared to that which would result if immediate compliance is required. In particular, please 

readdress Table 1 on page 26 of the petition to provide a specific estimate of the net difference between the 

projected S02 emissions rmder the current rule and under the proposed variance if Meredosia and Hutsonville are 

not considered in the system-wide analysis."); First AER Response 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 on page 26 and Attachment I 

ofExh. 7 of the petition to also show 'Cumulative S02 Variance Reduced Tons' if 2010 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 S02 Allowed S02 

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 AER Response, it is 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 of the closure of Meredosia 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 of calendar 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 of AER's 

remaining fleet, 'Without Meredosia and Hutsonville. 109 AER First 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 of the 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 of S02 emissions between 2010 and 2020, and the MPS baseline 655,359 tons: a 

difference of 35,747 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 of Meredosia and 

Hutsonville, Or Emissions From Past Yea1·s, Cannot Be Credited to the 

Variance. 

The Board should reject AER' s attempts to claim "offsets" from the shutdowns of 

Meredosia and Hutsonville. Those shutdowns are irrelevant to a consideration of the "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 of the variance is a real and meaningful commitment with consequences'' til To the 

110 Table 2 does not remove the impact of the Meredosia and Hutsonville shutdovms, but rather removes the impact 

of calendar years 2010 and 2011 by equalizing the heat inputs and emission rates for those years. It shows that, 

without the effect of calendar years 2010 and 2011, but still giving the variance creditfor the closure of Meredosia 

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. 

AER has 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 of 2011, 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 and Hutsonville energy centers at the end of December 

2011113 

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 of dry 

sorbent injection at its E. D. Edwards energy center to comply with the CSAP R or 

MP S. 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 I 0-

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 of Meredosia 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 Ameren Corp., 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). 

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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 

AER neglects 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 of 0.43 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, AER is 

now asking the Board to pretend that Meredosia and Hutsonville are not part of its fleet for 

purposes of the 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 of Meredosia 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, IEP A contends that «providing credit for- actions (e.g., unit shutdOVi'IlS) that result in 

emission reductions is an acceptable part of the established regulatory process." (IEPA Recommendation at~ 24). 

What !EPA fails 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 AER to meet the goal of even partial 

compliance that it h.as set out in its proposed variance. 

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CSAPR118 As Mr. Menne testified at the hearing, a reinstated CSAPR would be a more 

stringent regime than AER's proposed 0.35lb/mmBtn emission rate for 2015 to 2019, requiring 

AER to 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 of AER's CSAPR compliance strategy. 

In addition, AER's statements outside of this 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 AER to 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 of that petition, AEG 

stated: "Ameren has placed the Hutsonville Power Plant on the market for sale to reduce the cost 

to Ameren of operating the plant." 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 off employees at both plants and 

118 See Tr. at 40-41 ("But if you believe that CSAPR is going to come back, which most people do, that it will come 

back into 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 ("AER believes that either [CSAPR] or a regulatory 

replacement will be in place before the expiration of the requested variance teiiiL"). 119 Menne Test. Tr. at 42:7-13. 120 In thd{atter of Proposed Rules Establishing 35 Ill. Adm. Code Subchapter J, Part 840, and Subpart A, SiteSpecific Rules Providing/or the Closure of Ash Pond D 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 Staff Reductions at 

Three Illinois Power Plants in Response to Changes in Power Markets, Tough Economy (Ang. 12, 2009), available 

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"retiring" two of four units atMeredosial 23 AER's then-President and Chief Executive 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 our power. 

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 of those plants from 2008 on. From 2008 to 2009, 

AER slashed its usage of Meredosia 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, AER virtually 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 

AER will 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 

AER to 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 123 Id. 

124Jd. 

125 Press Release, AER Energy Resources Co., AER Subsidiary Armounces Reductions in Response to Continuing 

Declines in Power Markets (May 3, 2010), available at http:/ /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\ 

128 Id.; 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 of its 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 if compliance 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 of Increased S02 

Emissions. 

By grossly understating the excess S02 emissions that would result from a grant of the 

variance, AER and IEPA both avoid any discussion of the significant negative public health 

impacts that subverting the MPS would have. When asked about the health effects of S02 

emissions by Board Member Burke at the hearing, Mr. Menne responded: "Well, although I've 

studied it for 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 of the 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 IEP A made clear that the S02 emission reductions 

required by the MPS would have a significant positive environmental impact: 

129 See Petit. at 26, Table 1; AER First 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 of removing 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 of restricted 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 of tons of additional emissions of S02 annually between 2015 and 2019, dozens of 

lllinois health professionals, representing uuiversities across the State, are now speaking out in 

defense of the 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 of S02 emissions in and of 

131 In the Matter of Proposed New 35 Ill. 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, and also 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 by the health professionals. 134 This study measured the externalities associated 

with local and global air pollution for individual coal-fired and gas-fired power plants 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 power plants during 2005 as approximately $62 billionwith 85% of those damages (or approximately $53 billion)136 being caused by so2 emissions. 137 

Almost all of the damages (94%) were due to premature mortality. 138 

As part of their analysis, the authors of NRC study calculated damages per ton of each 

criteria pollutant emitted by each coal-fired power plant in the United States-including AER' s 

fleet The spreadsheet detailing these results is attached hereto as Exhibit 6. For AER's 

remaining fleet of coal 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 of excess S02 emissions from 2012 through the end of the 

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 of the variance also were addressed in comments of Dr. 

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 I d. 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. 

AER has failed to meet its duty to show au arbitrary or unreasonable hardship, because it 

has failed to present any credible evidence of the actual environmental impact of its 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 of a variance when the petitioner did not present 

any evidence regarding the effects of its sewage effiuent discharges on the 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, AER here relies entirely on the conclusory-aud incorrectcontention that its variance will not increase emissions. By failing to properly address its 

proposed variance's environmental impact, AER has 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 beyond the 

excess S02 emissions 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 "a tremendous win-win-win for the environment, public health and the regulated 

community. "139 Quite simply, iflEPA will not defend the standards it negotiates, or the Board 

the regulations it promulgates, there will be no such future victories. 

The Citizens Groups are not alone in believing that an AER variance would destabilize 

the carefully constructed balance of the 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 of its 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: AER is asking this 

Board to pick winners and losers in the Midwest energy market, with illinois citizens bearing the 

brunt of excess S02 emissions. Because AER has failed to justify 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, 

20 12), 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 set forth in these Comments, AER has failed to meet its burden to justifY a variance 

from the MPS. Were the Board to detennine to grant AER a variance, though, any variance must 

be strictly conditioned. As set forth in Sections I and II, above, AER has 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 AER providing "updates" 

on vaguely described "engineering" work until the potential completion of the 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 of the work it will perform, and a binding schedule for its 

completion. This schedule must not be dependent on energy prices, but rather guaranteed to 

result in AER's compliance with the MPS by the end of the variance. 

Second, AER must better demonstrate that it has explored all options for lowering its 

fleet's S02 emissions rate. Specifically, as discussed in Section II, above, AER must address the 

possibility of a "suite" of pollution 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 of a reinstatement of CSAPR Mr. Menne's testimony made clear that 

AER has considered control options that, even if they 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 not be implemented in partial 

compliance with the 2015 MPS emission limits. AER's duty to explore compliance alternatives 

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must be ongoing, and its S02 emission limit conditioned on the results of its demonstration of 

available alternatives. 

Finally, AER's proposed variance term of five years is, in any case, far too long. Given 

AER' s refrain of the "uncertainty" of markets, any variance granted AER should be no longer 

than two years, so that all parties may continue to assess the prospects of AER's future 

implementation of pollution control measures, and, indeed, the ongoing viability of AER as a 

merchant generator. In granting any variance, the Board should also make clear to AER that it is 

the last such variance the company will receive from compliance with the MPS. 

V. Conclusion 

For the reasons set forth 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 East Wacker 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 
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* * * * *PC# 2409 * * * * * 

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. of Metro Chicago 

Chicago, IL 60607 

Tel (312) 628-0245 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

CERTIFICATE OF SERVICE 

I, Andrew Armstrong, hereby certify that I have served the attached Comments of Envi.-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 and by depositing said documents in the United States Mail, postage prepaid, in Chicago, 

lllinois on August 10, 2012. 

Respectfully submitted, 

Andrew Armstrong 

Staff Attomey 

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 * * * * * 

Amy Antoniolli 

Renee Cipriano 

Schiff Hardin, LLP 

6600 Willis Tower 

233 South Wacker Dr 

Chicago, IL 60606 

John Therriault, Assistant Clerk 

Carol Webb, Hearing Officer 

illinois Poll uti on Control Board 

James R. Thompson Center 

100 West Randolph Street, Suite 11-500 

Chicago, illinois 60601 

therriaj@ipcb.state.iLus 

Gina Roccaforte 

Assistant Counsel 

Division of Legal 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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* * * * *PC# 2409 * * * * * 

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 CAMR Federal 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 of Kimberly Gray (August 1, 2012) 

4. Citizens Utility Board, Ameren Corporation's Peiformance Under the Illinois Electric 

Sen,ice Customer Choice and Rate Relief Law of 1997 (February 2006) 

5. Comments of illinois 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 
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EXHIBIT 1 

Wiitten Testimony of Douglas 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 of Douglas 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 Court Decisions" 

July 9, 2009 

Mr. Chairman and Members of the Committee: My name is Doug Scott and I am the Director of 

the lllinois Environmental Protection Agency. I want to thank Senator Carper and the other 

members of the Senate Subcommittee on Clean Air and Nuclear Safety for this opportunity to 

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 with honors from the University of Tulsa in 1982, and received a 

graduate Juris Doctor law degree with honors from Marquette University in 1985. I served as 

·Assistant City Attorney and City Attorney for the City of Rockford, Illinois from 1985 to 1995. 

I also represented the City on a number of environmental issues. From1995-2001 I served as an 

lllinois State Representative for the 67th District and served on the House Energy and 

Environment Committee, and was a member of the committee that rewrote the States' electric 

utility laws. I was elected to the Office of the Mayor of Rockford in Apri1200 1 and served a 

four-year term and served as President of the Illinois Chapter of the National Brownfields 

Association. I was appointed as the Director of the lllinois EPA by Governor Rod Blagojevich 

in July 2005, and have served as Chair of the Air Committee of the Environmental Council of the 

States (ECOS), the national organization of state environmental agency leaders. 

I am pleased to be here to provide testimony on the "three pollutant" approach and Illinois' 

experience in reaching agreements with our state's three largest coal-fired power plant system 

owners. My testimony will provide background information and a broad overview of the 
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development of illinois' multi-pollutant reduction agreements. I will address some of the 

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 of about 13 million people and a gross state 

product of $522 billion. Each of these are approximately four percent of the U. S. total and ranks 

illinois as fifth among the nation in these categories. illinois obtains more than 40 percent of its 

electricity from coal-fired power plants and sits on top of38 billion tons of coal, giving it the 

third largest coal reserves in the nation. Coal-fired power plants in illinois constitute the largest 

source of man-made emissions of mercury (Hg) and sulfur dioxide (S02), and one of the largest 

sources of nitrogen oxides (NOx). illinois is horne to 2llarge coal-fired plants that operate 

electric generating units. 

Over the last several years in illinois, exceptional progress has been made in reducing 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% of illinois' 

17,007 megawatts of coal-fired electric generating capacity and account for hundreds of 

thousands of tons of air emissions each year. 

·These multi-pollutant standards (MPS) are expected to result in measurable air quality 

improvements in illinois and also in regional air quality by dramatically reducing Hg, S02, and 

NOx emissions from illinois' coal-frred power plants. The agreed-to multi-pollutant standards 

are one of the most important enviromnental and public health advances in illinois in recent 

decades. They represent the largest reductions in air emissions ever agreed to by individual 

companies in illinois under any context, whether through an enforcement action or regulation. 
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As a result of the knowledge and experience gained through Illinois' efforts, the lilinois EPA 

suppmis a comprehensive national strategy for reducing emissions of multiple pollutants from 

electric generating units. A comprehensive, integrated approach benefits both regulators and the 

regulated community. Multi-pollutant approaches should supplement, not replace, the existing 

Clean Air Act programs 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 of great concern or where concentrated emissions at a local 

scale may occur- as in the case ofHg. Any multi-pollutant strategy must also ensure that 

regions, states and localities retain their authority to adopt and implement measures which are 

more stringent than those of the 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 of public health and 

the environment, reduce pollution more cost-effectively, and offer greater certainty to 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, it makes sense to allow companies the option to 

synchronize the control of these pollutants, provided that public health and the environment are 

likewise positively impacted. Whereas the federal Clean Air Mercury Rule (CAMR) singlemindedly tackled mercury emissions, and the federal Clean Air Interstate Rule (CAIR) addressed 

S02 and NOx, illinois was able to use a multi-pollutant strategy that accomplishes the 

aforementioned benefits in a unified regulatory framework accounting for planning, engineering, 

availability of fmancing and other issues that accompany a multi-pollutant contr·ol strategy. 

Illinois believes the most feasible method of obtaining reliable emission reductions in a costeffective manner is through a combination of emission rate 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 of emissions being below the allowable emission rates. This provides an incentive for 

companies to go beyond the reductions required under the MPS in order to recover some of the 

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. Of note 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 of emissions 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 power plants by mid-2009. After the Illinois EPA presented its findings in support 

of the mercury rule during two weeks of well-attended and hotly contested public hearings, the 

Agency was approached by Ameren who expressed a desire to work with the Agency toward 

common goals. Subsequent to long hours of negotiation, 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 

power plants. 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 only for the magnitude of emissions 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 -which they did. Ultimately, the mercury rule was unanimously 

approved in 2006 by both the Illinois Pollution Control Board and the Joint Committee on 

Administrative Rules, the two governing oversight bodies for regulations in illinois. 
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Both the MPS and CPS provisions provide some flexibility on the timing of mercury reductions 

in exchange for commitments to make significant reductions in both S02 and NOx. All of the 

provisions include some level of trading restrictions on S02 and NOx allowances provided under 

CAIR. Ameren, Dynegy and Midwest Generation will install a multitude of pollution 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 with representatives of Illinois' coal-fired power plants indicate 

that they are all preparing to meet the requirements of the MPS and CPS, which initiate in 2010. 

ill doing so, a wide array of emissions control equipment costing billions of dollars 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 of many new scrubbers for S02 control will begin operation 

shortly. Fabric filter controls will accompany the installation of many of the scrubbers and result 

in the co-benefit of particulate matter reductions. Selective catalytic reduction devices and other 

new NOx controls are being scheduled for installation across Illinois. The shutdown of a few of 

the older, most polluting electric generating units began in December 2007 with two more units 

scheduled for shutdown by December 2010. 

Illinois Mercury Rule 

The illinois mercury rule is designed to achieve a high level of mercury control, based on Illinois 

EPA's finding that there exists mercury control technology that is both technically feasible and 

economically reasonable. Mercury emissions may be reduced through the application of control 

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 boiler type, there are a number of control technologies 

that will achieve 90+% removal of mercury. Mercury emissions control technology is a rapidly 

advancing field, with halogenated sorbents being an affordable and effective option for most 

applications. Although there may be some challenges to achieving 90% removal of mercury for 
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all applications, in almost every case each of these challenges can be overcome or addressed 

through technology that is economically reasonable and available today. 

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 of installing 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 relief for 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% of a 

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 retmn for companies achieving significant reductions 

in the emissions of S02 and NOx. 

Under the MPS and CPS, companies can commit to voluntarily meet numerical emission 

standards for both NOx and S02 and in return are provided additional flexibility in complying 

with the mercury emission standards. The MPS and CPS provisions also contain restrictions on 

the trading ofNOx and S02 allowances provided under CAIR. By regulating the emissions of 

NOx and S02 and restricting the trading of allowances, the MPS and CPS have obvious 

implications for the proposed CAIR NOx and S02 cap and trade program. As modeling has 

demonstrated, the benefits of these reductions will mostly impact Illinois and a few of the closest 

neighboring states (i.e., Indiana, Wisconsin and Missouri) with lesser benefits further downwind. 

While the positive impacts of the 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 of controls is likely to occur more quickly than under a command and 

control option. 

Emission Reductions 

The combination of the Illinois mercury rule, 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 power producers in illinois would only have 

been required to reduce their so2 emissions by 34%, not the estimated 76% for Ameren, 65% for 

Dynegy, and 80% for Midwest Generation required under the MPS and CPS. The emissions of 

NOx are likewise expected to be reduced beyond the levels obtained by the model CAIR. In 

addition, both the 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 

way toward helping illinois achieve attainment of the ozone and PM standards. The modeling 

demonstrates that the emission reductions are very substantial. 

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

• so2 = 233,600 tons per year eliminated 

• NOx = 61,434 tons per year eliminated 

• Mercury= 7,040 pounds per year eliminated 

Under CAMR, coal-frred 

power producers in Illinois 

would have only been 

required to reduce their 

mercury emissions by 47% 

in 2010 and 78% by 2018, 

not the 90% reduction by 

2009 specified in the 

illinois rule. The timing of 

mercury reductions for 
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those sources that opt-in to the MPS or CPS is essentially the same, and the amount of reduction 

is expected to be close to 90%, although the companies will not be required to comply with 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 of controls needed to comply with 

the corresponding S02 and NOx standards. 

Impacts of Emissions 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 of Hg 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 

deposition to Illinois' waters and fish. Such benefits include support for existing jobs and the 

potential for additional jobs resulting from the installation and operation of additional pollution 

control devices. 

The benefits of removing 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 of restricted 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 in lakes, 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 of Appeals for the District of Columbia Circuit 

vacated the federal CAMR. The illinois mercury rule is separate from the federal CAMR and 

therefore the vacatur of CAMR had minimal impact on the Illinois rule. However, this court 

action raised concerns regarding the status of certain federal provisions dealing with the 

monitoring of mercury 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 on the 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 mercury rule remains in full effect and all illinois companies began complying with 

the rule on July 1" of this year. 

In July of 2008, the U.S. Court of Appeals for the District of Colwnbia Circuit (DC Court of 

Appeals) vacated the CAIR rule 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 of reasons, the vacatur and reinstatement of Phase I of CAIR have 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 of the DC Court of Appeals vacating CAIR in part, i.e., vacating Phase II ofCAIR 

but reinstating Phase I of CAIR, has thus far had minimal impact on lilinois. CAIR Phase I 

required reductions up until the beginning ofCAIR Phase II in January l, 2015. Although 

Illinois relied upon CAIR Phase I as part of our 8-hour ozone (85 ppb) and annual PM2.5 

attainment plans, 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 significant reductions before 

2015, Illinois is not dependent on CAIR Phase II reductions for the newest 8-hour standard (75 

ppb) or the 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 implementation plan if CAIR 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 comply with CAIR Phase I due to the loss of value in S02 and NOx 

allowances. The market value of these allowances is uncertain, because there is controversy over 

whether the DC Court of Appeal's opinion has disallowed an emissions trading program. As a 

result, companies have no incentive to go beyond the reductions required by CAIR Phase I 

because the incentive to install controls early due to the cost recovery benefit of the allowances 

obtained is removed. Also, many companies have a significant number of banked allowances 

available for their use or for sale, and these banked allowances will be depleted rather than 

companies meeting the "emissions cap" through installation and operation of pollution control 

equipment, perhaps even to the extent of not operating existing or recently installed controls. 

However, we believe the MPS and CPS should keep illinois sources on track for installation and 

operation of the 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 of which 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 of the 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 CAIR replacement rule, no fmal 

recommendation to USEP A has yet been developed. The participating states disagree over the 

level of reductions that should be required, whether best available controls should be required on 

every power plant or just the larger/largest units, the timing of controls, 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 in the greatest amount of reductions 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 must be set 

such that there is 100% assurance that every affected source will be able to comply in 

consideration of the time necessary for planning, engineering and conshuction deadlines. In 

other words, there must be sufficient availability of engineering fmns, control equipment and 

construction companies to plan, engineer, build and install all of the pollution control equipment 

required for compliance. Such a regulatory compliance date would certainly be difficult to 

establish and likely result in far fewer reductions in the near term when compared to an approach 

that includes emissions trading. Also, the construction season in many of the 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 in negotiating the MPS and CPS, within the 

CAIR region, it is not practical (and may not be possible) to retrofit all coal-fired power plants of 

any significant size (e.g., 25 MWe or more) in the same 3-year window (or even 5-year window). 

A command and control strategy necessarily 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 not required. 
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As illinois discovered dming its MPS and CPS negotiations, there are very significant costs 

associated with installing pollution controls of the magnitude negotiated under Illinois' rules -

estimated in excess of 3 bill on dollars. While this cost may be seem small on a kilowatt hour 

basis, these companies must obtain a rate increase if they 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 of both 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 of a vital strategy for 

the states to achieve attainment of the 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 if the complaining state's air quality issues are largely a result of 

emissions from its own sources (area, mobile and point) and even if the targeted other state(s) 

has done mo;e to address emissions from its coal-fired power plants 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 of disagreement among the states, without being bound by 

interpretations of the scope and flexibility provided under the 1990 Clean Air Act amendments, 

and in a way that best serves the goal of obtaining 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 power plants 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 of a 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. 
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Multi-Pollutant Standard & Combined Pollutant Standard- Required Emissions Rates and % Reductions 

Midwest Generation I 

, ,, 

m1sswn o e uct:Jon Emission % Reduction Emission % Reduction Emission Rate 

Rate Rate Rate (lbs/nnnbtu) , 

(lbs/mmbtu) (lbs/nnnbtu) (lbs/mmbtu) 

0,50 52% 

2013 050 31% OA4 ]3,7% 2014 OA1 ' 19,6% OA3 56% 2015 045 34% 028 45,1% 025 76% 2016 0,195 6L8% 

2017 0.15 70,6% 0,23 78% 

2018 0,13 74,5% 2019 OAS 34% 0, II 784%' 023 78% 

t:B; Annual- 0,15 44% 0,11 62%' 0,11 52% 

2012 

Annual - 0,12 55% 0,11 62%' 0,11 52% 

2015 

Seasonal- - - 0,11 51% 0,11 22% 

2012 

1CAIR enuss10n rate numbers from page 5 of the June 28, 2005 USEPA presentation to LADCO 

(htlp:l/vr'\Y\Y.ladco.orglrcporls/mo/Regional%20Air%200uality/Jt:me28 2005/.Ttme-Workshop/CA1R%20LADC0%20.pd0. 

Percent reductions from the USEPA website that provides CAIR reductions expected in Illinois Chttp://wvvw.epa.gov/cair/il.html). 

Emissions used for calculations are from Clean Air Markets Divisions of USEP A 

280% including planned shutdowns. 

368% including plmmed shutdowns. 

Note: Ameren S02 rates reflect changes lo allowable rates as contained in proposed revision to Illinois mercury rule. 

0,24 

CU9 

0,19 

0,10 0,10 0,10 
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Percent Mercnn Reductions ft·om CAMR, Illinois Combined Pollutant Standat·d (CPS) and Multi-Pollutant Stan

Mid 2008 

2009 

2010 2011 

2018 

47% 

are 

(ACI installed on 

most 

90% 

86% 

90% 

94.4% 

mmercury 

on 

most tmits) 

86% 

93.5% 

2Several units at plant have combination of Scrubber, Baghouse, SCR and/or ACI and many units will achieve greater than 90% reduction in merc

All numbers are Illinois EPA estimates. 
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EXHffiiT2 

The Shaw Group, EEl Joppa Generating Station Dry Sorbent Injection Test Program 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 Systems Management Section 

Division of Air Pollution Control 

illinois Environmental Protection Agency 

P.O. Box 19276 

Springfield, IL 62794-9276 

Dear Mr. 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 Sorbent Injection 

Test by injecting both trona and sodium bicarbonate into the flue gas of units 5 and 

6. 

As required by Special Condition 6 of the above construction permit, I am 

submitting a summruy of EEI' 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 Office 
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* * * * *PC# 2409 * * * * * 

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_-:==_-L== 

· Energy, Inc. 

Joppa Generating Station 

SLO naw® 

The Shaw Group Inc~ 

EEI 

Joppa 

Generating 

Station 

Dry Sorbent 

Injection Test 

Program 

Final Report 

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

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

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

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 of the existing electrostatic precipitators (ESP)s would be 

successful in removing 50% or more of the S02 in the gas stream without detrimentally 

impacting the operation of the ESPs and fly ash handling system. 

The scope of work developed jointly by EEl and Shaw was a high level test program. It 

presented a l 0 day test program to determine the optimum location of DSI (before or 

after the 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 of parametric testing on Unit 6, Units 5 and 6were tested with tlue gas 

testing being performed in the combined stack. This perfommnce testing was to last up 

to 5 days on a continuous 24 hour basis to determine: 

• whether continuous SO% or better 802 reduction and continuous 90% mercUry 

removal can be achieved during normal plant operations including tum down of 

the units due to market demands; 

• whether there is an impact to the air heaters (if upstream of the 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 of the fly ash handling system, and; 

• whether there are any issues in the handling of DSI that 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. 

The Joppa station is operated by Electric Energy Inc., an independent power producer, 

and is owned by Ameren (80%) and Kentucky Utilities (20%). 

The plant's capacity factor is historically greater than 92% inclusive of all 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 of the 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 

The plant 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 of Responsibility 

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 IEP A 

• 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 power and trailer space 

• Provide office space, conference room and sanitary facilities 

• Obtain coal and byproduct samples 

• Provide PI data output 

Shaw (Shaw Power and Shaw E&D 

• Assist EEl with test program development 

• Perfonn flue gas testing 

• Obtain laboratory analysis of solid media 

• Perform a chm:acterization study of byproduct 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 of reagents 

• Provide consultation on use of reagents 

2 
printed 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 of the 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 in certain poHutants including acid gases and sol!le metals 

• detennine byproduct characteristics to assist with landflll operations; and 

• assess the impact of overaH operation on plant equipment and infrastructure. 

The conduct of the study as it was performed over portions of three weeks is shown in 

Table 2-1. Some changt:s w"n' made frum the original design as the program progressed 

in the field. Changes were judged necessary given data as it was reviewed or in some 

cases, changes were made because it was judged that results would not be meaningful. 

Sample point locations included the following locations: 

• Economizer Outlet- consisted of two parallel ducts (Duct A &B) each with a 

cross sectional area of230 square feet at the sampling location. 

• ESP Inlet- consisted of twa parallel ducts (Duct A & B) each wirh a cross 

sectional area of 230 square fe.et at the sampling location. 

• ESP Outlet- consisted of two pamllel ducts (Duct A & B) each with a cross 

sectional area of 250 square feet at the sampling location. 

• Commcm #3 Tall Stack - single annular stack with an 18 foot diameter at the 

sampling location. 

For gas samples (Hg and CEMs) selection of the 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 and the 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 of each 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 of each sampling 

location. 

3 
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* * * * *PC# 2409 * * * * * 

Electric Energy, Inc, 

Joppa Generating Station 

Joppa, Illinois 

Date Test Purpose 

Day 

June 1,2,3 Travel and 

Tuesday mobilization, 

Setup injection and 

test equipment 

June4 1 Baseline testing. 

Friday 

June 5 2 Baseline testing. 

Saturday 

June 7 3 Un-milled Trona 

Monday injection 

June 8 4 Milled Trona 

Tuesday injection 

June 9, 5. Milled Trona 

Wednesday Injection 

6 St;aw • Tho 9>-.w Oocw 

Dry Sorbcnt Injection 

Table 2-1 - DSI Test Program 

(as performed) 

Units 5 and 6-Joppa Station 

Injection Reagent Sampling Additiona

location Injected 

NA NA NA NA 

NA None Two runs. Unit 6. CEMs in/out; Test coal a

OHM in/out; PM in/out; stack· S02/MMBOHM, TM29, TM26A, TM8A; AC/Macf. 

TM30B .. Coal, ash, byproduct S03 inject

NA None Two runs. Unit 6. CEMs in/out; Test coal a

OHM in/out; PM in/out; stack· S02/MMBOHM, TM29, TM26A, TM8A; AC/Macf. 

TM30B. Coal, ash, S03 inject

Upstream of Trona Three runs. CEMs in/out; Determine 

air heater OHM in/out; PM in/out Trona inje

50% reduc

Upstream of Trona Three runs. CEMs in/out; Determine 

air heater OHM .in/out; PM in/ouL injection r

reduction. 

Down- Trona Morning runs. CEMs (only) Determine 

stream of air in/out injection r

heater reduction. 

4 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

Electric Energy, Inc, 

Joppa Generating Station 

Joppa, Illinois 

Date Test Purpose 

Day 

June 9, 5 Pre-milled SBC 

Wednesday injection 

June I 0 6 Pre-milled SBC 

Thursday injection 

June I 1, 7 Pre-milled SBC 

Friday injection 

June 14, 8 Pre-milled SBC 

Monday injection 

June 15 9 Pre-milled SBC 

Tuesday injection 

June 16, Testing terminated 

Wednesday due to Unit 5 tube 

leak outage. 

6. Sliaw" Th:l s. ... vOa..p 

Dry Sorbcntlnjectio

Table 2-1- DSI Test Program 

(as performed) 

Units 5 and 6- JoJipa Station 

Injection Reagent Sampling Addition

location Injected 

Down- SBC Afternoon runs. CEMs (only) Determin

stream of air in/out rate for 5

heater Upstream of SBC Three runs. CEMs in/out; Determin

air heater OHM in/out; PM in/out. rate for 5

After air SBC Units 5 & 6. Three runs. CEMs Parametr

heater (only) in/out determin

at v'!!)'il

After air SBC Units 5 & 6.Thrce runs. CEMs Determin

heater (only) in/out (stack CEMs) rate for 5

two unit 

After air SBC Three runs. Unit 5&6. CEMs 

heater in/out; OHM in/out; PM in/out; 

stack-OHM, TM29, TM26A, 

TM8A; TM30B. TM5 and 202; 

Coal, ash, byproduct (5 x 5 

gallons). 

---

5 
printed 07/23!20121:38PM by Sharon.Dowson p. 9135 

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

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

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 of 30-

35 microns. Typical moisture of delivered 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 of Trona 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 Car ACFX05 I 25 I -Two loads reported 

Result Unit Minimum Maximum 

Wet Trona 97.6 % 95.0 

Free Moisture 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 % 

6 
printed 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 of 39 microns. The 

milled Trona had a measured D50 of 26 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 of Sodium Sorbents. Emissions Control and Measurement Workshop. March 

24-25, 20 I 0). 

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 of the delivered SBC had clumps of material 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 of materials. Weight 

Joss as a function of time 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 of material. 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 of the sorbent feed 

system was 20,000 lbfhr. The blowers were positive displacement rotary blowers driven 

by a 40 HP motor. Each blower was capable of providing 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, cutoff ends. Lances were inserted 

at staggered lengths before the air heater. Lances after the air heater were all the same 

·length. 

2.4 Coal 

During the performance of the test program, tl1e plant bumed two Powder River Basin 

(PRB) coals; East Thunder (Jacobs Ranch) and Belle A yr. 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 of the daily samples of the coals. It should be noted that 

for coal utilization, the daily sample was taken from the . 

8 
Electric Energy, Inc, 

Joppa Generating Station Joppa, lllinois 

Coal Sample Btullb Source day 

Jacobs 6/2110 8420 Ranch 

Jacobs 6/3110 9150 Ranch 

Jacobs 6/4/10 8420 Ranch 

Jacobs 6/5/10 8370 Ranch 

Jacobs 6/6/10 8710 Ranch 

Jacobs 617/10 8630 Ranch 

Jacobs 6/8110 7840 Ranch 

Jacobs 619/10 8390 Ranch 

Jocobs 6/10/10 8470 Ranch Jacobs 6/11/10 84.30 Ranch 

Comb- 6/12110 8390 ination? 

Belle 

Ayr 6/]3/10 8380 

'll•o !!hw G<t>..!J 

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

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

Table 2-3- Coal Analyses Resnlts 

Ash Ash · s so2 Cl lb/ lbl As Ba 

MMBto % MMBtu % jlJl_m _]Jp_m 

5.96 7.08 0.48 1.14 0.02 3.01 302 

6.79 7.42 0.49 1.07 0.02 2.48 . 307 

5.85 6.95 0.5 1.19 0.01 <2 308 

__:_ 

5.5 6.57 0.48 1.15 0.02 <2 315 

5.64 6.48 0.44 1.01 0.02 <2 300 

5.7 6.60 0.49 1.14 0.01 2.21 344 

5.17 6.59 0.35 0.89 0.01 <2 377 

6 7.15 0.43 1.03 . 0.02 <2 321 

5.63 6.65 0.45 1.06 0.02 <2 311 5.79 6.87 0.45 1.07 0.02 <2 330 5.02 5.98 0.36 0.86 <0.01 <2 307 

5.04 6.01 0.24 0.57 <0,01 <2 355 

-

9 

Cd Cr 

ppm ppm 

<I 6_65 <I 6.5 <I 6.21 <I 6.0 <I 5.91 

<I 5.92 

<I 6_54 

<I 6.38 

<I 6.24 

<I 5.9 

<l 5.52 <I 4.94 

----

Dry Sorbent In

Pb Se 

_]lllm ppm 

3_16 <2 

2.43 <2 2.14 <2 

3.2 <2 

1.65 <2 

2.29 <2 

2.61 <2 

2.27 <2 

2.72 <2 

2.49 <2 2.05 <2 

1.66 <2 
Electric Energy, Inc, 

Joppa Generating Station Joppa, Illinois 

Coal Sample Btu/lb Source day 

Belle 6/14110 8350 Ayr 

Belle 6/15/10 8510 Ayr 

Jacobs 8483 Ranch 

Belle 8413 Ayr 

Percent Belle 

Ayrof 99.18 

Jacobs 

Ranch 

• TI!CJ Sl<tN 0rco..p II 107 

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

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

Table 2-3- Coal Analyses Results 

Ash Ash s so2 Cl lb/ lb/ As Ba 

% MMBtu % MMBtu % ppm ppm 

5.11 6.12 0.23 0.55 0.02 <2. 319 

-

4.59 5.39 0.26 0.61 0.01 <2. 295 

Avcra1 es 

5.80 6.84 0.46 1.07 0.017 <2..17 322 

4.91 5.84 0.24 0.58 <0.0!3 <2. 323 

84.7 85.5 53.4 53.84 76.47 92.2 100.5 

10 

Cd Cr 

ppm ppm 

<I 4.63 

<I 4.31 <I 6.23 <I 4.63 

100 74.3 

Dry Sorbcnllnjc

Pb Se 

ppm ppm 

1.72 <2 

2.19 <2 

2.50 <2. 

1,86 <2. 

74.4 100 
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 of the SBC in the bulk delivery vehicles. Trona was injected both upstream 

(un-milled and milled) and downstream (milled) of the air heater (AH). SBC was also 

injected both upstream and downstream of the air heater. The feed rates of the 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 of the 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 of the silo 

feeding event. 

I I 
Electric Energy, Inc, 

Joppa Oenerating Station 

Joppa, Illinois 

Start 

Date Run time 

4-Jun 

5-Jun 

7-Jun I 12:00 7-Jun 2 15:15 

7-Jun 3 18:00 

8-Jun I 9:45 

8-Jun 2 12:29 

8-Jun 3 15:21 

9-Jun I 10:52 

9-Jun 2 15:27 

I 0-Jun I 10:00 

I 0-Jun 2 12:45 

6 Sliaw· n..,a-Clrl:>.v 

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

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

Dry Sorbcnt Inject

Table 3-1- Average Dry Sorbcnt Injection Rates P•lr Test Event 

End Injection Average Injection DSI Rate Comm

Time Location .(LB!HrJ 

None NA NA Ba!ieline 

None NA NA Baseline T

13:00 Unmilled Before air heater 5,971 Trona -Unit 6 

17:00 Unmilled Before air heater 11,659 Trona -Unit 6 

18:34 Unmilled Before air heater 10,219 Trona -Unit 6 10:47 Milled Trona Before air heater 8,838 -Unit 6 13:35 Mi lied Trona Before air heater 8,561 -Unit 6 16:21 Milled Trona Before air heater 8,688 -Unit 6 

12:31 Milled Trona After air heater 14,237 -Unit 6 16:00 Pre-milled After air heater 11,643 SBC -Unit 6 

11:03 Pre-milled Before air heater 7,733 SBC -Unit 6 13:50 Pre-milled Before air heater 7,275 SBC -Unit 6 

12 
Electric Energy, Inc, 

Joppa Generating Station 

Joppa, Illinois 

Date Run Start time 

10-Jun 3 15:20 

ll-Jun I I 1:23 

11-Jun 2 12:14 

11-Jun 3 16:14 

14-Jun I 9:53 14-Jun 2 13:05 

15-Jun I 8:50 

IS .lun 2 12:15 

15-Jun 3 14:59 

6 SHaw· '0 '" ettru 1re 

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

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

Dry Sorbcnt Injec

Table 3-1· Average Dry Sorbent Injection Rates Per Test Event 

End DSI Injection Average lnj•:dion Time Location Rate Comm

(LB/Hr) 

16:27 Pre-milled Before air heater SBC Unit 6 6,921 

II :52 l'rc-milled After air heater- SBC Units 5 and 6 5,882 

Pre•milled After air heater- 13:31 SBC Units 5 and 6 ll,077 

17:31 

Pre-milled After air heater- added to silo 

SBC Units 5 and 6 14,665 estimates were ba

spe

12:38 Pre-milled After air heater - SBC added to silo 

SBC Units 5 and 6 9,284 estimates were ba

spe

17:07 Pre-milled After air heater- added to silo 

SBC Units 5 and 6 9,683 estimates were ba

spe

9:50 Pre-milled After air heater - added to silo 

SBC Units 5 and 6 10,200 esllmates were ba

spe

13!33 Pre-milled After air heater - SBC Units 5 and 6 9,956 

16!08 Pre-milled After air heater - SBC Units 5 and 6 I 0,438 

13 
prfnted 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 of air emissions test data. Details of the tests 

performed are found in A!tachment I. The plant's S03 injection flue gas conditioning 

system was taken out of service for all tests. Trona, like S03, is also used to increase the 

conductivity of fly ash for removal in ESPs. Trona would also remove the SO, before it 

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 of the 

OS! Test Program, PAC was injected upstream of the 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 of the base line program was to document emissions and plant operating 

characteristics prior to reagent injections. The results 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 of the 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 a somewhat higher 

sulfur content than what the plant normally fires. 

At Unit 5, particulate and mercury were 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 values presented 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 

14 
printed 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 

3,756lblhr or based 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 of non-uniformed sampling in 

the duct due to stratification of the flue gas path. Because of this 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 values presented are the 

averages of four runs taken over two days. Data indicate overall ESP efficiency of98.88 

percent. The removal 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 of four 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- Baseline Summary 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 

The purpose of this program segment was to document emissions and plant operating 

characteristics injecting un-milled (D50 of39 microns) (not milled on site) 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. The plant 

was burning coal from the East Thunder (Jacobs Ranch) mine with an approximate 0.9-

1.2 lb S02fMMBtu content. During the performance ofthe tests one of the DSI blowers 

15 
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Final Report 

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tripped on overheat for about 20 minutes (15:35- 15:55) which reduced the injection of 

Trona by one/half for that period .of time. 

Attachment 3 shows the arrangement of the 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 before the ESP and fine particulate (PM1o and PMz.s), 

mercury and S02 after the ESP. Coal was sampled !he day/night before as it was being 

loaded into the coal bunkers 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 stack before and after 

DSI with one half of !he S02 assumed 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--------·-- • ----- + • -- -- -----;:-=--------

1-----~ -~ 4 $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 of 0.093 lb S02 removed per lb of sorbent injected at 50% S02 removal. 

6. Sliaiiii• U109aw~re' 16 
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final Report 

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Table 3-5 - Summary S02 Data, Un-milled Trona Injection Upstream of Air 

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 S02 Removed!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 values p!"esented 

are tbe averages of three one-hour runs. Data indicate overall ESP efficiency of 99.44 

percent, somewhat better than tbe baseline efficiency. 

Table 3-6- Summary Particulate Matter Data, Un-milled Trona Injection 

Upstream of Air 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. The values presented are the 

averages of three runs: Calculations, discussed in Attachment l, indicate overall removal 

efficiency of 87.7 percent (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 

of Air Heater 

Juue7, 2010 

Measurement Unit Value 

Coal Lblhr 0.0223 

Coal Lb/TBtu 9.4 

ESP Outlet Unit 6 Lblhr I . 0.00273 

ESP Outlet Unit 6 LbiTBtu I 

Removal Efficiency Percent 87.7 

17 
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3.1.3 Trona, Milled Upstream of the Air heater 

The purpose of this 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 of about 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 of the 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 (PM10 and PM2,j, 

mercury and S(h after the 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 S02 concentration before DSI was 

estimated based on the S(h concentration in the stack before and after DSI with one half 

of the S02assumed to come from Unit 6. The values presented are the average of the 

injection throughout the day. The values indicate an overall removal efficiency of52.6 

percent and with an efficiency ratio ofO.lO lb S02 removed per lb ofsorbent injected. 

The ratio shows an improvement in .removal efficiency over un-milled Trona. 

Table 3-8, Summary S02 Data, Milled Trona Injection Upstream of Air Healer 

June 8, 2010 

Measurement Unit Value 

Average SCh Units 5 and 6 Before 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 of three one-hour runs. Data indicate overall ESP efficiency of98.68 

percent, not quite as good as the baseline efficiency or that for un-milled Trona. 

18 
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Final Report 

Dry Sorbcnt Injection Test Program 

Table 3-9 - Summary Particulate Matter Data, Milled Trona Injection Upstream 

of Air 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 in Table 3-10. The values presented are the 

averages of three runs. Calculations, discussed in Attachment I, indicate overall removal 

efficiency of 84.1 percent (based on coal mercury concentration). 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 3·10 • 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 of the Air Heater 

The purpose of this program segment was to document tbe S02 emissions and plant 

operating characteristics injecting milled (DSO of 26microns) (milled on site) Trona 

downstream of the AH. 

The test occurred on morning of9 June. Milled Trona was injected from 8:50 to 12:30 at 

an average injection rate 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 of the .. 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, 

S02 was 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 

19 
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Final Report 

Dry Sorbent Injection Test Program 

estimated based on the S02 concentration in the stack before and after DSI with one half 

of the S02 assumed to come from Unit 6. The values presented are from the morning 

run. The values indicate an average removal efficiency of 42.6 percent and with an 

efficiency ratio of0.049lb S02 removed per lb of sorbent injected. The ratio shows this 

scenario, injecting downstream of the AH, to be the least efficient of the Trona test 

altemati ves. 

Table 3-11- Summary 802 Data, Milled Trona Injection Downstream of Air 

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 

1 Ji70 

Removal Efficiency_ Percent 42.6 

Lb SO, Removed/Lb Sorbent Ratio 0.049 

Ton Trona/Ton SO, Removed Ratio 20.4 

It was anticipated that this test scenario would be no be better, and probably worse than 

· the injection before the AH due to the lower temperature of the 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 of this program segment was to document the S01 emissions and plant 

operating characteristics injecting SBC downstream of the 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 plant was burning 

coal from the East Thunder (Jacobs Ranch) mine with an approximate 0.9- 1.2lb 

SOz/MMBtu content. 

Attaclunent 3. shows the arrangement of the 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, 

S02 was measured at the economizer outlet "before injection" and after the ESP. Coal 

was sampled during testing. 

Summary S01 data are shown in Table 3-12. The SBC injection infonnation was 

compared to the Stack CEMs data. The Unit 6 S02 concentration before DSI was 

estimated based on the S02 concentration in the stack before and after DSI with one half 

of the SOzassumed to come from Unit 6. The results. indicate an overall removal 

efficiency of 60 percent and with an efficiency ratio of0.0841b S02 removed per lb of 

20 
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sorbent injected. The ratio and removal efficiency values were based on average J 1,750 

lb/hr reagent injection. 

Table 3-12- Summary S01 Data, SBC Injection Dovmstream of Air 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 S02 Removed!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 of this program segment was to document emissions and plant operating 

characteristics injecting SBC upstream of the AH. 

The test occurred on 10 June. SBC was injected from 8:30 to 16:55 at an 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 of the No!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 were measured at the economizer outlet "before injection". 

Particulate matter (TM5) was measured before the ESP and fine particulate (PM10 and 

PM2.s), mercury and S02 after the ESP. Coal was sampled during testing. 

Summary SOz data are shown Table 3-13. The SBC injection information 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 half of the SOz 

assumed to come from Unit 6. The results indicate an average removal efficiency of 

67.1 percent and with an efficiency ratio of0.158 lb S02 removed per lb of sorbent 

injected. The ratio shows an improvement in removal efficiency over Trona and SBC 

injection after the air heater. 

21 
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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 matter emissions data arc shown Table 3-14. The values presented 

are the averages of three one-hour runs. Data indicate overall ESP efficiency of97.80 

percent, not quite as good as the baseline efficiency. 

TableJ-14- Summary Particulate Matter Data, SBC Injection Upstream of Air 

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 shown Table 3-15. The values presented are the 

averages of three runs. Data indicate overall removal effiCiency of 85.8 percent (based 

on coal mercury concentration. This removal efficiency is not necessarily comparable to 

the baseline since this is based 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 of Air 

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 of this program segment was to document emissions and plant operating 

characteristics injecting SBC downstream of the AH. The amount of SBC added was 

adjusted throughout the day (9:10- 19:35) to obtain a trend between S02 removal and 

Sh~· ncsnwG<upld' 22 
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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) 

The test 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 of the 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 of the 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, 

502 was measured at the 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 in Figure 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 

E 0..0~ 

___ ,._ _ __ _§_ 

~ 0 

l!! 

N 

0 0 

"' ~ 

... 0.00% 10.00% 20.00% 30.00% 40;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 removed per lb of sorhent 

injected at 50% 802 removal. 

23 
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Table 3-16- Summary S02 Data, SBC Injection Downstream of Air 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 

The purpose of this program segment was to document emissions and plant operating 

characteristics injecting SBC downstream of the AH on a continuous basis. 

The test occurred on 14June. The plant was burning coal from the Belle Ayr mine with 

an approximate 0.6 Ib S02/MMBtu content. This is a coal with a lower sulfur content 

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 of the ESPs were impacted by the combination of the 

Belle Ayr coal and the SBC injection with lower power levels and an initial increase of 4-

5% in opacity. This spike stabilized and !he opacity trended down as the tests continued. 

Attachment 3 shows the arrdngement of the N olTec injection equipment and lances into 

the plant ductwork. 

CEMs measurements were taken on Unit 5 and Unit 6, at the economizer outlet, before 

injection. The plant 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 of 54.7 percent and with an efficiency ratio of0.112 lb S02 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 

24 
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3.1.9 Continued Sodium Bicarbonate Downstream of the Air Heater 

Units 5 and 6 Steady State Testing 

The purpose of this program segment was to to continue to document emissions and plant 

operating characteristics injecting SBC downstream of the 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 of tests. 

SBC was injected into Units 5 and 6 for all ofJunc 15 and into June 16. Full load 

operation of Units 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 of service around 5:00am on 

June::: 16. 

Attachment 3 shows the arrangement of the 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 shown Table 3-1 &. The values indicate an overall removal 

efficiency of 54.7 percent and with an efficiency ratio of 0.113 lb SO, removed per lb of 

sorbent injected. This feed rate and removal efficiency continued into June 16 until Unit 

5 was brought down at about 5 am. SBC injection continued at a reduced rate with just 

Unit 6 in operation with an average feed rate for Unit 6 of 4,950 lblhr, with 52.9% S02 

removal efficiency and a 0.109 Lb SOzRemoved/Lb Sorbentutilization. 

Table 3-18- Summary S02 Data, SBC Injection Downstream of Air 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 shown Table 3-19. The values presented 

are the averages of three one-hour runs. Data indicate overall ESP efficiency of99.02 

percent, better than baseline efficiency. Although the efficiency is somewhat better than 

25 
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Final Report 

Dry Sorbent Injection Test Program 

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 

Air Heater 

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 shown Table 3-20. The values presented are the 

averages of three runs. Data indicate overall removal efficiency of 93.7 percent (based 

on coal mercury concentration), which is consistent with the basehne efficiency. Tne 

removal efficiency represents the combined removal of the DSI and PAC injection 

system. 

Table 3-20- Summary Mercury (Total) Data, SBC Injection Downstream of Air 

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 of the two coals during the test period .. From a 

visual review of the data, it is not evident that SBC had an impact on metals emissions, 

either positive or negative. There is some indication that SBC may have decreased the 

amount of nickel or selenium in the emissions. 

3.1.11 Comparison of Acid Gas Emissions, During Baseline and 

SBC Injection 

Hydrochloric acid and hydrofluoric acid gases were measured 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 burned between the two test days. Table 

2·3 shows that the Jacobs Ranch coal had on average slightly greater concentrations of 

26 
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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 of chlorine and the same or 

higher concentrations of fluorine, approximately SO% of the acid gases were removed 

when comparing the baseline test results with the SBC injection results. 

Table 3-21 -Comparison of Acid Gas Emissions 

Date Test Average HCI AverageHF 

Lblhr Lb/hr 

4-5-Jun (I) Baseline 2.335 6.21 

15-Jun(2) S BC 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 Ayr PRB 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 emissions between the baseline sample dates and the DSI dates were reviewed 

to s~e if there was a discernable impact OfDSl on NOx em.issions. The data is included 

in Attachment I. Little to no reduction in NOx 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 of the amount of S02 removed against the amount and type of DSI was 

made to delineate the utilization efficiency of each of the dry sorbents used. Since the 

S02 concentration in the flue gas varied with time over the test runs a comparison of the 

dry sorbent utilized needs to be compared on an amount of S02 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 of the SBC had clumped together 

resulting in unloading problems. This clumping may be indicative of a 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. 

27 
Electric Energy, Inc, 

Joppa Generating Station Joppa, Illinois 

Injection 

Date 

Dnration 

W/Piant at 

Full Load 

7-Jun 8:45- 18:35 

8-Jun 9:10-16:40 

9-Jun 8:50-12:30 

9-Jun 14:40 - 16:00 

10-Jun 8:30-16:55 

11-Jun 9:10-19:35 

14-Jun I 0:00- 24:00 

15- 6:25- 4:55 

16-Jun (6-16) 

16-Jun 5:35-6:30 

---

"11 Xl SlliN Cic4J h 

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

* * * * *PC# 2409 * * •· * * 

Dry Sorbent Injectio

Table 3c22- SOz Removed Versus Dry Sorbcnt Utilization 

Average Injection so, LbsS02 

DS Injection Rate Removal Removed per Lb 

Location (LBIHr) Ellicicncy IlS 

Unmilled Before air heater- 3,000- > 13,000 13-59 0.093@ 50% 

Trona Unit6 SOz removal 

Milled Before air heater- 8,600 +/- 52.6 0.10 Trona Unil6 

Milled After air heater - 14,493 42.6 0.049 

Trona Unit 6 

Pre-milled After air heater- 11,750 60 0.84 SBC Unit 6 

Pre-milled Before air heater 7,380 67.1 0.158 

SBC Unit 6 

Pre-milled After air heater • 3,500- 16,000 16-53 0.121 @50% 

SBC Units 5 and 6 S02 removal 

Pre-milled After air heater - 9,980 54.7 0.112 

SBC Units 5 and 6 

Pre-milled After air heater - 9,960 54.7 0.113 

SBC Units 5 and 6 

Pre-milled After air heater • 4,950 52.9 0.109 

SBC Unit 6 L_ ___ --

28 
Electronic Filing- Received, Clerk's Office, 08/10/2012 

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

Electric Energy, Inc, 

Joppa Generating Station Joppa, Illinois 

, 

2! 

u 

0.3 

Sodium Bicarbonate Utilization Hate 

Injection After Air Heater 

<>- -> 

Dry Sorbent Injecti

yo 0.186 

R' • 0.2238 

f 0.25 

9<() 

<) 

<>- <() 

u 

Ol 

O.l 

... 

·---· ---- --· 

0 

,e 

0.15 

c. 

, 

> 

Q 0.1 

E 

"' ,.. • 0.05 0 

"" ... 0 

0.00% 10.00% 20.00% 30.00% 40.00% 50.00% 60.00% 70.00% &0.00% 

Percent 502 Removal 

Figure 3-3- Efficiency of S01 Removal Using SBC After The Air heater 

6 Stiaw · Til!l s-Cn:llf; 29 
printed 07!2312012 1:38PM by Sharon.Dowson p 33135 

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

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

Electric Energy, Inc, 

Joppa Generating Station 

Joppa, Illinois 

Final Report 

Dry Sorbcnt Injection Test Program 

Some general conclusions can be 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 of dry 

sorbent) (6.33 tons of SBCiton of SO, removed) than milled Trona (0.1 00 lbs S02 

n'rnoved per lb of dry sorbent) (I 0 tons of Trona/ton ofS02 removed) 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 of dry sorbent respectively) (10 

vs. I 0. 75 tons of Trona/ton of SOz removed) when injected before the air heater 

• The injection location (whether before or after the air heater) impacts the 

efficiency of Trona and SBC utilization, with injection before tbe air heater having 

a signitican!ly greater utiiization efficiency (About haif of the Trona was needed 

per lb of S02 removed and about 75% of SBC was needed with injection before 

tbe air heater) 

o The trend line for SBC utilization shows that the SBC utilization efficiency 

decrea.•••e..~ with increased % S02 .removal 

• When using SBC for 50% SO, removal, a utilization rate of about 0.12 lbs SO, 

removed per lb of SBC is needed (8.3 tons of SBC/ton of S02 removed) with 

injection after the air heater and a significantly greaterutilizaticm (>0.158 lbs S02 

removed per lb of dry 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 system was operated at an S02 removal 

efficiency of 50%. 

3.2.2 Impacts of Dry Sorbent Utilization on Particulate Emissions 

A comparison of the 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\vn in Table 3-23. This comparison shows an increase in total 

particulates ()[74.&3 lbs/hr with the injection of dry sorbent. This. equates to increase in 

total particulates of 295 tons/yr from Units 5 and 6 assuming a 90% capacity factor. 

30 
printed 0712312012 1_38PM by Sharo11.Dowson p. 34!35 

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

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

Electric Energy, r nc, 

Joppa Generating Station 

Joppa, Illinois 

Final Report 

Dry S orbent Injection Test Program 

Table 3-23- Comparison of Total 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 than the East Thunder 

average burned on 6/4-512010 

The type of dry sorbent utilized also affected the type of particulate emissions from the 

existing ESPs. Table 3-24 provides a comparison of the 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 of Average 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 of Air Heater 228.96 8.61 220.35 20.69 

SBC 

31 
printed 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 Sorbent Injection Test Program 

Reviewing the results provided in Tables 3-23 and 24 show that the addition of DSI to the 

fl.ue gas stream increases the total particulates leaving the ESP with the majority of 

increase being PM<! 0 microns. Injecting milled dry sorbent has the most impact on the 

increase of fine 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 what was measured on June 15 for the combined Unit 5 and 6 emissions with 

SEC injection. The least impact on particulate emissions was the injection of un-milled 

Trona which had the largest particle size of all of the test runs. 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 perfonnance (i.e. spark 

rates, secondaty 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. 

3.2.3 Impacts of DSI Utilization on Mercury Emissions 

The removal efficiency of mercury during injection ofDSl was reviewed and is included 

in Attachment I. The results indicate a baseline removal efficiency of 93% with the 

injection of a minimum of 5 Jbs activated carbon per million 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 is based on the concentration of mercury 

in the coal burned. Throughout the DSI test the activated carbon injection rate was 

unchanged. Based on the low values of mercury analyzed and the 10% variability of 

removal during injection, it is difficult to state whether DSl had any real impact on 

mercury removal. 

3.2.4 Impacts of DSI Utilization on Carbon Dioxide Emissions 

The use ofTrona or SEC to remove S~and acid gases will evolve C02 as part of the 

chemical reactions. Due to the chemical makeup of the two dry sorbents the utilization of 

SBC will evolve more CO, than Trona on a pound p.,- pound sorbent basis. Based on 

50% S02 removal and a 90% capacity factor, the use of Trona at Joppa will evolve about 

26,000-40,000 tons per year while the use ofSBC will evolve between 41,000-49,000 

tons/yr based on injection location (before or after airheater). 

32 
Electronic Filing- Received, Clerk's Office, 08/10/2012 

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

EXHIBIT3 

Comments of Kimberly G1·ay (August 1, 2012) 
Electronic Filing -Received, Clerk's Office, 08/1 0/2012 

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

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 of the Pollution 

Control Board of the State of Illinois COMMENTS OF KIMBERLY GRAY, a copy of which 

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 

Amy Antoniolli 

Renee Cipriano 

Schiff Hardin, 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 @ip cb .state .il. us 

Gina Roccaforte 

Assistant Cmmsel 

Division of Legal Counsel 

Illinois Environmental Protection Agency 

I 021 North Grand A venue, 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 of Environmental 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. 

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 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% S02 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 air toxi-Ci t•;':i·" 

Q,.Ysorbeiit Is 

in!E<;ie(! and rea«s . ••llihacietg~~e$ to 

form Q?!l;poonrt 

Add. gas. a>m1Jound 

snd partiwlate matter 

. 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% of the 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 of wet FGD and DSI. The major advantages of wet 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 of wet 

FGD is approximately 2-3 times less than that of DSI. DSI has a number of advantages 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 of DSI 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% of the cost of wet 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 I Gypsum so lin or MgS04 solution ior! 

use or disposal I 

Collected with !y ash 

1

.A.1kal!ne Reagent or Sorbent consumption. I 

·z I "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 

I Flu.e gas reheating required? Yes No 

I Ease of retrorrt to existing power station Very difficult Easy 

Table 1: Comparison of different 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

. Of sodium-based sorbents, sodium bicarbonate (NaHC03) is 

more efficient in removing S02 compared to sodium carbonate (Na2C03{ 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 * * * * * 

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 of various sorbents and their costs. 

3. Trona 

Trona (trisodium hydrogendicarbonate dihydrate), (l\a2C03•NaHC03•2H20) is a naturally 

occurring, evaporite mineral. Figure 3 shows microscopic images of trona 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 of trona 

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 N a2S03 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 

Air ..... :r--=~;--'------¥---- 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 if there is a hot-side electrostatic precipitator (ESP) upstream 

of the SCR catalyst. 

Between the SCR and Air 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 
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* * * * *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 (Na2SO,) and 

unreacted sorbent (NazCOJ). 

(iii) Na2C03 will enhance the performance of SOl 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% i 5Cmlimln 

I m ~· --->1 

CO:! 150mlfmln 

OJ---.1 

~80CM!!rnin 

Constant 

Temter:at>Jre 

C3blnat 

Vent 

Analyzar Data 

acquisition 

?ump 

Figure 7: A schem<ltic diagram of fixed 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 of trona. 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 S02 molar ratio 

As shown in Figure 8, removal efficiency increased with increasing trona concentration and 

decreased with an increase in SO, gas. 

The conversion/reactivity of trona (X,) can be theoretically calculated by: 

Where, 

R= Radius of the particle 

Rc= Radius of trona particle 

Tb= Time required to complete the conversion of trona 

X,= conversion of trona 

u = velocity ( cm.sec) 

Figure 9 shows the positive effect of temperature on removal efficiency. 

"' 

" 

~-

" " • 0 

:·d 

.. 

~ 0 

E ,, l ~ 

"] 

c I 

,_, 

0 

~_!l 

0 

•• 

~~ L ~ ::! 

TrortaiSO~ L1' . .:JI>lr rariD 

0 

"' 2!;::!' 0 :'.~~·-

• "'"-~':' 

.. :;5JF 

(3) 

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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 of size of trona 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 of inlet temperatures, 

pressures, dust volumes, and acid gas conditions. They can collect a wide range of particles 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 

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.Figure 11: Design of ESP, 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 ESP11 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 of hot-side and cold-side ESP 

Although the use of hot-side precipitators can help reduce corrosion and hopper plugging, there are 

also some disadvantages. In a hot-side ESP the temperature of the flue gas is higher, and hence, the 

gas volume treated in the ESP is larger. Consequently, the overall size of the 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 of differences 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 

of the 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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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 

i NO, (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 of the disadvantages of converting 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 of trona 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 of PM after the injection of trona. 

6. Feasibility Study of trona injection to other plants 

6.1 Existing coal power plants 

There are a number of the existing power plants that use DSI in the form of trona 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 • 

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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 of Dominion 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 of 32 experiments were conducted at 

the Mirac Potomac River generating station to test the performance of trona 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 of trona feed stoichiometry 18 

Potomac ;:!iver Tron.a lnj..etion Nov· Oec: :2005 

Compo.!iile Data All Tesw 

110'kT-· ·-·-··-·· ----·-···----·-· ··--·- • ---~.~-·-·---·•· 

I 100'\i.+----

·~+-l------------------------------------- i '"' +-. ---------------------------=-'"""=::::; 

10"1., L~----------------~~~-----------, <>'< 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 of the 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 of feed 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 of industries such as: 

(i) Babcock and Wilcox provides an S03 mitigation technology through a license with 

AEP ProServ, Inc., a subsidia1y of American 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 -Trona removes 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 of 95-99%. In addition, it is able to remove 20-70% of Hg used alone, and over 

90% in combination of activated carbon21 

Na2C03 + S03---> Na2S04 + COz 

Na2C03 + 2HC1--> 2NaCl +rhO+ C02 

Na2C03 + 2HBr--> 2NaBr + H20 + 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 of other contaminant removal by trona. 

(ii) Trona's effect on NOx- Coal-fired power plant use selective catalytic reduction (SCR) 

systems to reduce the emissions of nitrogen 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 of lung 

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 of the 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 

!rona typically 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. If Ameren were to employ DSI to achieve just 50% S02 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 or less than $200M. 

Qualifications of Professor 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 of Notre 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. Of these, 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 of physicochemical processes in environmental systems and the development 

of photocatalytic treatment technologies for air and water remediation. She is the author of over 

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 of the conversion of Trona to 

increase its reactivity with SO 2 in dry injection systems,", PhD Dissertation (Environmental 

Engineering), University of Cincinnati, 

http://etd.ohiolink.edu/view. cgi/CH0%20KYUNGMIN%20.T ACOB. pdf?ucin 1 I 85822434 

2. Dogu, T., Effect of port structure on the mechanism ofSO, sorption on activated soda. 

(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 Control Association 1984,34, (6), 651-654.) 

5. Bares, J.; .1., M.; Mocek, M.; Erdos, E., Kinetics of the 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/techno lo 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!b81 bacb577b0!6d7857 56e4a004c0393/ 

12. APTI Course SI: 428A Introduction to Boiler Operation describes boilers and heat recovery 

equipment in greater detail. 

I 3 .http://www.isesp.org/I CESP%20V%20P APERS/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-7 3-2005 

IS. http://www.genon.com/companv/env-Trona.aspx 

I 6. http:/ /www.coalpowermag.com/plant designjS03 -Control-AEP-Pioneers-and-RefinesTrona-Iniection-Process-for-S03-Mitigation 29.html 

I 7. http://www .kbr .com/Newsroom/Press-Releases/? 012/05/0 7 /KBR-Power-and-IndustrialGroup-A warded-Dominion-Resources-Inc-EPC-Contract/ 

18. http:/ I o ldtownalexandri a. patch. comltopics/Po to mac+ Ri ver+Ci enerating+Stati on 

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-905895 1/news/Tata-ChemicalsLimi ted-Tata -Chemicals-Church-Dwight -and-FM C-anno unce-j oint-venture-for-air-po 1-

13808631/ 

22. http :1 !www. so 1 vair. us/EN/products/ seiect2 00/ sol vai rirse!ect200and 15 OT 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 of Health, Office of Epidemiology & Ofiice of Environmental Health 

(June 2007). "Ilealth Effects Associated with Exposure to Trona: A Review of the 

Biomedical Literature," hllp:i ivMw.atsdr.cdc. gov /hacipha/MirantHC/ AppendixFTronaSummary.pdf 

17 
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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 I Z 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 

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

Address: 

EDUCATION 

1988 

198J 

1978 

CURRICULUM VITAE 

Kimberly Ann Gray 

(07il2) 

Department of Civil 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 of Geography 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 of Civil Engineering 

University of Miami, 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 

l 999-presem 

1998-2005 

1997-present 

1996-present 

Senior Sabbatical Fellowship - Public Interest Scientist, Environmental Law and Policy 

Cemer, Chicago, IL. 

Professor, Department of Civil and Environmental Engineering, Northwestern University 

Northwesiern Institute of Sustainable_ 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 of Envirorunental Catalysis, Northwestern University 

Member, Center for Catalysis and Surface Sc!ence,. Northwestern University 

Courtesy Appointment in the Department of Chemical & Biological Engineering1 

Northwestern University 

Page 1 of 38 
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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 of Civil 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 of Civil 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 of the Texas Higher Education Coordinating Board, evaluation of the 

Environmental Engineering program at Texas A&M University at Kingsville 

Member, Board of Directors, In1emationai Association for Urban Environment, 2009-present. 

Member, Editorial Board, The International Journal of Sustainable 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 of President Morton 

Schapiro's Inauguration, 9 October 2009. 

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 of Nanotechnology, 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 of Maryland, 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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Board or Directors, Chicago land 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 of Environmental 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 of Visitors (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 of monograph, "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. 

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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 of Physical Cbemistry, Langmuir, Physical Chemistry Chemical Physics, Energy 

& Fuels, Nanosc<1le, Carbon, Catalysis Communication, Catalysis Letters, Transportation Research, Thin 

Solid Films, Journal of Material Science, Jollmal of Colloid and Interface Science, Colloids and Surfaces, 

Journal of Membrane Science, Journal of Applied 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 of Molecular Catalysis, Journal of Solid 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 of Nature MALS- 403 (2006, 2012) 

Cities and the Environment: Past, Present and Future .• MALS-403 (2004) 

The Environmenlal Legacy of Modern Industrialized Societies, MALS-403 (200 I) 

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. 

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Kevin Sclw.•arzenberg {20 I 0- present)- Characterizing adsorplion affinity of C02 and il ef[ecl on pboloc<.talytic 

rcduttion. 

Ticzhcng Tong (20 I 0- present): Uninlended effects of nanotitania in benthic systems. 

Sarisl Macksusitom (201 0- present): Biomagnificalion of persistent 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 the Structure and Function of 

Periphylon in Urbanized SLI·eams, 

Paul Desario (June, 201 1): Cation Doped Ti02 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 Cis ton (June~ 2009, DcpL of Chemical and Biolog1cal Engineering): Photo-active Ceramic 1.-fe:mbrancs for 

the Prevention of Biofouling: 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 of chemical 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 (August1 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.) 

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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 of Colored 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 J 2): "'Mobile Testing in the Thar 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 of Chemical 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 of Chemical Engineering): "'Novel VUV Photocatalytic Reactor." 

Y. Mwende Munyasya (Novernber, 2000): "The Effects of Catal),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 of the Problem and Solution." ~ 

David Widrig (November, 1992): "Preozonation to Enhance Coagulation: The Effect of Algal Species and Water 

Quality an the Removal of Dissolved Organic Carbon" (172 p.). 

Jonathan l'ioris ( AllgusL 1994 ): "Treatment of High 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) 

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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. Am and (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 of multiple 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 of C02," 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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* * * * *PC# 2409 * * * * * 

"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 of Agricultural Runoff by Pcriphyton," 

S324,000, 8102-8/06 (PI, co-PI-Aamn Packman). 

"Titania Coated Shikkui Tiles: Determining the Role of the Support," Fuh1oka University Instilllle for Recycling 

and Environmental Control Systems, S30,000, 11/05-04/06, FastScience. 

FastScience, Characteiization or Titania 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 L1rban Deve1opmen1, $171,073, 02/00-

02/03. 

"Technical Assistance to Community Groups through the Chicago Legal Clinic,'·' US EPA, Region V, $26,250, 9/00-

1102 

'"Radiolysis on Oxide Surfaces," -National Science Foundation, $77,269, 2/00-3/0 l. 

''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 of Wetlands, $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, $53 7 ,500/(9/95-6/2000). 

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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). 

"Radio lytic Destruction of Organic Compounds", Occidenlal ChemicaL Corporatioo, S65,1J8/l year , v .. ,ith co-Pl: 

R. L. Irvine (5/92-12/9 3), 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 Per forrnance of Poly ferric 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 of Algal 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 of Notre 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, (Patent No. 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 Hers am. 

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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 of highenergy anatase mmorod.s via an intermediau~ nanotube morphology," CPLEIT, DOl 

I 0.1 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 of anthropogenic inputs on the organic quality of urbanized 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 of Titania 

Nanotubes./' Ca!alysis Science and Technology, 2 (8), 1617- 1624; DOl: 10.1039/C2CI'00538G. 

87. Baiju K. Vijayan, Nada M. Dimitrijevic, Dan it'! 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 ofTI1.:xNb..,.Oz mixed phase thin 

films; Distribution of crystal 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 of Reactor Materials on the Properties of Titanium 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 

(20 ll ). '"Elucidation of several types of binding sites for the adsorption of acetaldehyde on the surface of 

titania nanorods.," Lm1gmuir, 27, 14842-14848-. 

83. N.M. Dimitrijevic, T. Rajh, B. Vijayan, K.A. Gray (2011). "Photocatalytic Reduction of C02: Probing 

Structure ofPhotocatalysts md Mechanism of C02 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 of C02 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 of Metropolitan 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 of rutile Ti01 nanorods above 

anatase Ti02 thin films on Si-based substrates,~' Journal of Materials Research 26:1646-1652. 

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

78. Luciana Zanella, Francesca Casadio; Kimberly A. Gray, Richard \Varta, Qing Ma and Jean-Fram;:ois Gaillard 

(20 ll ). "The Darkening of Zinc Yello\v: XAN ES Speciation of Chromium 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," JVST A, 29:03 1508-3 I 515 doi: 10. I J I 6/1.3574350. 

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 of CO:! lo CI-14 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 of Residential Location on Vehicle 

Miles of Travel, 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 of global change scenarios on bioaccumu1ation patterns in 

Great Lakes Species," Global Change 810/ogy~ 17, 720-733 (DO!: I 0. 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 of zinc polnssium chromate in Georges Seurat's A Sunday on La 

Grunde Jau~ '"' 1884," Analy!h:al mnf Biocma!ytical ChemiSI)', (DO I 10. l 007/s00216-0 1 0-4264-9). 

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:l 0. I 0 16/j .tra.20 I 0.07 .003). · 

68. B. Vijayan, N. Dimitrijevic, T. Rajh, K.A. Gray. (2010) '"Effect of calcination temperature on photocatalytic 

reduction and oxidation of hydrothermally 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 of Biofilm 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 of oplimized 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 Solid Films, 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 Ti02 on ZrO~ Ceramic Membranes," Langmuir, 24:7072-7075. 

60, F. Casadio, K.A. Gray, R. Warta, I. f-ied!er(2008) '"Deterioration of Zinc Potassium Chromate: Elucidating the 

effects of paint composition and em·ironmental conditions on chromatic alteration," I COM Comminec tbr 

Conservation, 15111 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 of Tetrahedral 

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, 320:10 1-l 07. 

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 Physics Lerters, Vol 451/1-3 pp 7 5-79. 

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 nan a composite material_s,'' Chemical Physics, 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 of mixed phase titania photocata[ysts prepared 

by physical and chemical methods: The imporrance of the solid-solid interface." Journal of Molecular 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. Oceano gr. 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. 

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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: AT ool 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. 

3 7. A. Agrios, K. Gray, E. Weitz, (2004) "Narrow Band Irradiation of Homologous Series of Chlorophcnols on 

Ti01 : 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, I 08:16483-16487. 

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 of Mixed 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. 

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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." Em1fron. Sd. Techno/. 34:3401-3407. 

27. J.A. Kastel, H. Wang, A. StAmand, and K.A. Gray, (1999) «1. Use of a Novel Loboralory Stream System to 

Study the Ecologicallmpact of PCB Exposure in a Peri phytic Bioluycr," Water Research, 33: J 8:3 735-3748. 

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 of Algal-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 of TNT," 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 Radio lytic 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 of Dioxin 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. 

I 0. 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 of 4-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 of Sus1ainabillty 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, Kimberly A. 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. Dan on, B. Vijayan, K.A. Gray, P.C. Stair, E. Weitz (2011 ). "Tbe role oflhe surface lewis acid 

and basic sites in the adsorption of C02 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 of commercial nano-Ti02 to· 

Escherichia coli using high-throughput analysis: The effects of environmental 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 of photolytic and photocatalytic effluent composition on bioreaclor 

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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. of Bacterial 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 of NOM 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: Technology for !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: Technology for 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: Tcchnoldgy fer 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 of Environmental Engineers, Annapolis, MD1 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 of Water 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 Chi oro- and Nitrophenols," TiO, Photocatalytic Purification and Treatment of Water and Air, David 

Ollis and Hussain Al-Ekabi, eds., (Elsevier Publishers, 1993), 455-4 72. 

*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 of 4-Chlarophenal Degradation in Titania Slurries, 

in Proceedings of the 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 of the 210th ACS National Meeting, 35:2:484-486. 

K.A. Gray, 199 5. 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 Water and 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: Radio lytic 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, A WWA, Part 11, November, 1991, 1219-1231. 

PUBLISHED REVIEWS 

Book review of Radioactive Waste Management (Y .S. Yang and J.I-1. Saling) for Environmental Progress. 

"Report on the First International Conference on Ti02 Photocatalytic Purification and Treatment of Water 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 of Engineers, febmary, 2005. 

K.A. Gray {200 I) "Physica I, 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 of Prado 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 of Organics,'' submitted to Occidental Chemical Company, October 1991. 

SIGMA XI 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. 

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Western Washington University, Feb. 24,2009-2 lectures given. 

Western Kentucky University, Marcll2, 2009 

University of Tennessee, 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 of Northern Michigan, March 18, 2010 (2 talks) 

Rollins College, March 25,2010 (2 Lalks) 

University of Louisville, April I 5-16, 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 of Asia and the shrinking cities of the North America," 

Vision Seminnr, Dept. of Civil Engineering. Purdue University;25 April2012. 

"Li \'ing Cities: The rcdesii;n or cities inspired by ecological principles," keynote address at the Mid-west 

Environmental Leadership Summit, 15 April2012. 

"Living Cities: A vision to suStain the exploding mega cities of Asia 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 of Natural and 

Engineered Nanomatenals in the Environment Symposium (Division of Colloid & 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 of Great 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 of Newfoundland, Canada, Oct. 28,2010 

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"Sustainable Cities and tbe Many Dimensions of a 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 of Grenl- 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. of Chemical Engineering, University of Louisville, 15 April 2010. 

'"Fabricating Titania-based Nanocomposites for Solar Fuel Production. Ti02-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. 

'The Nanotechnology Revolution and its Unintended Environmental Effects,'' Encouraging appropriate use of the 

products of scientific 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. of Civil and Environmental Engineering, Rice University, Houston, TX, 21 

September, 2009. 

'"Ecology and the Green Revolution,"' 61sl Annual Meeting ofrhe Association of American Universities, Chicago 

Botanical Gardens, 20 September 2009. 

'The Feasibility of Achieving Sustainability Goals in the Near-TeLm," Annual Meeting of North American 

Management Team, Veolia Energy, 27 Aug. 2009. 

"Secrets of the 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 of Greater Chicago, Luc-Hing R&D Laboratory Seminar Series, 29 May 2009. 

"Five Myths about Nanotechnology in the Current Public Policy Debate," Searle Center Research Roundtable on 

Environmental, Health, and Safety Rish of Emerging Technologies, Northwestern University School of Law, 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 of Climate Change on Transportation," Transportation Center Business Advisory Commii.!ee Meeting, 

NU, Oct. 22,2008 

«Progress in de,•eloping photoactive nanocompositcs to improve the efficiency of artificial pholosynihesis/' seminar 

in I he Depfl[tment of Geography 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 of Sustain<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 Ti02-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 Ti02-based nanocomposites for solar fuel generation," Division of Engineering, Brown 

University, 14 April2008. 

"Second generation TiOTbased nanocomposites for solar fuel generation," Department of Civil 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 A VS 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," 

scm inar, DepL of Civil 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 of I flinois, 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 of Urban Development on Soli and Water Quality: Characterization and Remediation;• semlnar presented 

in the Department, of Environmental Science at the Ur1iversity of Illinois-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 of Environmental 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 of Applying Phytoremediation in Urban Residential Communities," presented at tbe 130111 Annual 

\1eeting of the American Public Health Association, Philadelphia, PA, November 13, 2002. 

"·Radiolytic Dechlorination of Adsorbed Pollutants in Various Matrices," presented in the Symposium on Radiation 

Chemistry at the 222th Annual Meeting of the American Chemical Sock:ty, Chicago, J L, Aug. 200 I. 

"Monitoring the Impact of Organic Quantity and Qua lily 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 of Metals 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 Radio lytic 

Treatment Methodologies for Remediation of PCB Contaminated Sites, University of Maryland, 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. 

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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 of North 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 of Illinois, 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 of the 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 of Ionizing Radiation for Reductive Dechlorination: Chemistry_. Design and Economics," presented at the 1995 

International Chemical Congress of Pacific 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, I 995, London, Ontario. 

"Use of ionizing 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 \\'ate Reuse Association of California, 25 May 1995. 

''Photocatalysis: Theory, Experiments and Models," presented 1o the DepL. of Civil Engineering, University of Texas 

at Austin, April, 1995. 

"Inorganic Polymers: Fundamental Aspects Related to their Use for Particle Removal and Dewatering," presented at 

the Annual Meeting of the Society of Mining 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 of TNT Pholocatulysis," presented at "Emerging Technologies ln 

Hazardous \\taste Management VI," ACS, l&EC Division Symposium, Atlanta, GA, Sept. 19-21, 1994. 

'"Radio lytic 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 of the 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 of Civil 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 of Natural 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. 

"Radio lytic Destruction of Dioxin 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 of AIChE 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. 

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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 of Notre 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 of American \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 of Photographic 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 of Civil 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 1h Ame-rican Chemical Society Meeting, San francisco, CA, March 21-25, 

2010. 

Baiju K. Viiayan, Paul Desario, Nada Dirnitrijevic, Kimberly Gray, ''Photocatalytic reduction of carbon 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 C02 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 of Titania 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 

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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. Graham1 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 of Adlineation Sites", Fundamentals q.fMeta! Oxide Catatvsis, The 232ndACS National 

Meeting, San Francisco, CA; September I 0, 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 Ti01 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 of flow 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- 1 0, 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 90111 Annual Meeting of the Ecological Society of America, 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," 228111 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." 22811\ 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," 22711\ 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 of Anthropogenic 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 extracellular polymeric substances from 

psctldDmonal acruginosa biofilms," 225 111 ACS National Meeting, New Orleans, LA, Mttrch, 2003. 

finster ME. Gray KA, Binns HJ. Lead levels of vegetables grown in contaminated residential soils: a field survey. 

American Public Health Association Annual Meel.ing, Philadelphia, P A, November II, 2002. 

Finster ME. Gray KA. Binns HJ. Factors in11uencing tbe creation of turf grass barders on lead-contaminated 

residential soil.s. American Public Health Association Annual Meeting, Philadelphia, PA, November J l, 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 Ti01 Surfaces." 222nd ACS 

National Meeting, Chicago, JL, Aug, 27, 2001. 

M. Bonifacic. K-D. Asmus, K.A, Gray. "Time-resolved pulse radio lysis studies on the reaction of free radicals and 

hydrated electrons with halogenated phenols," 22211 d 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, Poi tiers, 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 of Reductive 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 of PY -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 A WWA Enhanced Coagulation Workshop in 

Charleston, SC, Dec. 6, 1994. 

R.J. Hilarides and K.A. Gray, "Destruction of Dioxin on Soils: Radiolysis of Model 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 of High Selenium Wastewaters," presented at the 1994 AIChE 

Summer Meeting, 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 of Dioxin 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. 

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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. J 994. 

,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 of the 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 of TNT," presented at the 24th Annual Meeting of the 

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 of the 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 of AlChE, ~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 of the 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 of Surface 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 of Semiconductor 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. 

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J. Earlev, K. Gray, P. Garrity, ''Radio lytic DesLruction of Dioxin/' presented at the 1991 Anmml Meeting of the 

A mel 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 of Adsorbed Nitrophenolic Compounds 

on Semiconductor Surfaces," presented al Waste Management in The Chemical and Petrochemical Industries, 

lA WPRC & 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 of Total 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 of the 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 of the 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. 

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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 and Admissions, 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 ].earning Pilot and Program Dirt~ctnr, 1996-present 

S!ra!egfc Planning- 2000, 2004-05 

U11dergraduare CU!Ticulum Deve!opme~1t, 1995~preseJ?l 

University of Notre 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: 

Promo lion & TenJJre Commiflee- 2007-2009. 

Search Committee- Associate Director,lndustrial Relations, 2005 

Dean Sec/l·ch Commiftee, Spring, Fall 2004 

Freshman Advisor- 1996-2001 

McConnrck Identity Committee, 200 J -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 of Notre 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: 

Environmental Policy & Culture Facully Advising Commiltee, Weinberg CAS, 2008-present. 

School of Continuing Studies' Graduate Faculty Advisory Board, 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 

French and 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 and Policy Program (formerly, Environmental 

Science Program, WCAS), 2003-present 

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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 of Notre 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 and Engineering 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 

Select inn Cnmmitfee for Graduate Teachmg Award, 1993 

Speaker-Placement Office Graduate School lntbnnation Session, 1993, 1994 

Envlronmemal Issues Group, Kroc Institute of Peace 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 of educational laboratory module, Environmental Catalysis,; 1 0111 in a series of 

Material Worldwide Modules; designed, tested, \Vrote series of activities for students to learn about 

various principles of catalysis and the importance of catalysis for environmental protection. Field-tested 

activities in various high schools (ETHS, New Trier, Schaumburg, etc.) in Chicago area and nationally. 

Mento red 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 I 0 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 of Continuing Studies, Aug. 9-11,2006, Aug 1-3,2007, July 28-30,2008. 

Technical Advisory Committee, Friends of the 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 of Climate 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. 

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«Fabricating Titania-based Nanocomposites for Solar Fuel Production: Ti02.x. & Ti 1_"Nb,02 Tbin Films & 

Ti02 Nanotubes," 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 I 0. 

'The Modern American City: Can we ever make 1t Sustainable?" \'1cCormick Engineering Week, 

McCormick Student Advisory BoarJ, NU, May 201 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 Sustainabi lity, "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 1 unior Science 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 of Hispanic 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: If we know what to do, why aren1t we doing it?" NU Club of Virginia, 

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 of the 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 of the 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 of Urban Areas,'' NU Alumni College Program, The City: Past, Present, 

Page 35 of 38 
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* * * * *PC# 2409 * * * * * 

and Prospects. July 28, I 999. 

'·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," Earth day, SEED, NU, 23 April 1998. 

Member, Panel Discussions to Undergradt1ate and Graduate students on issues related to gender, 

environmental .qtmlity and justice, 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 I 2. 

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), 20 l 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), 20 ll. 

Lake Depue Sediment Contamination: Evaluation of OUS Ecological and Human Health Risk As.sessmenls 

(Chelsea Baldino & Anjulie Cheema), 2011. 

Restoration of Miller 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 of the 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, Jennifer Raber, 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. 

Page 36 of38 
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* * * * *PC# 2409 * * * * * 

Probing the photochemical aging of the Seural's zinc yellow pigments in Sunday at La Grand Jalle with 

Francesca Casadio al the Arl lnstitule of Chicago (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 of Thorium 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 of LEED Rated School Construction (Robert Kutter 

and Megan Johnson), 2003-2004. 

Urban Honey Production: Risk Assessment of Metal and Organic Contamination (Erin Jordan), 2003-2004. 

PMw Compliance in Southeast Chicago (Michael Goldrich and Ben Jewel), 2003-2004. 

Going Green: A Comprehensive Review of Green 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 of Remediation Alternatives for Contaminated Sediments in the Vessel Slips of Wisconsin 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), 

200 l-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), 2000-200 I. 

Evaluation and Design of Enhanced 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 of Future Remedial Action (Sarah Bender and Ted Ekkers), 1997-1998. 

Risk Assessment and Site Characterizalion of the Wisconsin Steel Works Site (Emily Fahsl and Matthew Lamb), 

1997-1998. 

Page 37 of 38 
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* * * * *PC# 2409 * * * * * 

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 Well nods 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), J 996-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 of groundwater) 

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 of Thornton, 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 of Polymeric 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) 

Page 38 of 38 
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EXHIBIT4 

Citizens Utility Board, Ameren Corporation's Performance Under the Illinois Electric 

Service Cnstomer Choice and Rate Relief Law of 199 7 (February 2006) 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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Ameren Corporation's Performance Under 

the Illinois Electric Service Customer Choice 

and Rate Relief Law 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 of Ameren Corporation's performance 

under the Illioois Electricity Restructuring Act ("the Act"). 1 Primary fmdings of this 

study include: 

(I) Investors io companies that owned Illioois assets pmchased by Ameren have 

realized $2.6 billion io value from passage of the 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 if Illioois 

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 of the rate 

reductions to consumers ofillioois Power, CIPS, CILCO and Union Electric. 

The value of rate reductions has been about $800 million, far less than the 

iovestor benefits. 

Introduction 

Ameren's Illinois operations are currently made up primarily of assets that have been 

acquired since the passage of the Act. When Ameren pmchased these assets, it paid high 

prernimns to investors of the acquired companies. Ameren's current utility holdiogs in 

Illioois include the regulated AmerenCIPS, AmerenCILCO, and AmereniP, and 

unregulated AmerenEnergy affiliates. At the 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 of merging 

with Union Electric to form Ameren. Because of the timing ofthese acquisitions as well 

as the separation of the generatiog assets ioto a subsidiary company, the performance of 

assets currently owned by Ameren carmot be gauged solely by analyziog the performance 

of Ameren' s stock price. 

Investors io companies other than Ameren have benefited by about $2.6 billion from 

realizing the proceeds of acquisition payments and from retaining generation assets. The 

primary iovestor groups who have benefited include: 

1 The Electric Service Customer Choice and Rate Relief Law 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 of the Act when 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 of keeping 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 half year time frame after passage of the 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 on their shares of $113 million 

when Ameren completed the merger at the end of 1997. This premium is over 

and above the amount CIPSCO shareholders would have received had the 

companies not merged. 

$2,500 

$2,000 

$1,500 

$1,000 

Value Recieved By Investors other than 

Ameren ($Millions) 

Despite all of these transactions and realization of profits by many different investor 

groups, Ameren still was able to realize a rate of return four times as high as the S&P 500 

2 The source of the 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 of the utility company stock index. Ameren's stock value increased 

346 percent more than the increase in value of the S&P 500. The manner in which these 

investor groups profited from the Act is described in the next section. 

Summary of Merger Activities 

As mentioned before, Ameren's current Illinois operations are the result of various 

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 of Ameren's stock price. 

• Prior to the Ameren purchase of CILCORP 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 of the Act and the AES 

acquisition. The stock price together with the dividend yielded a return of 52% 

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 of the $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 of Ameren' 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 of coal capacity. Since 

Dynegy earlier purchased all of IP 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 of capacity 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 in the 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 of Ameren's stock price below. 

• Dynegy originally purchased IP from Illinova Corporation for $33 per share or 

$4.6 billion in mid 19996 Illinova's share price was $23.785 when the Act was 

passed. Including 2 years of dividends at $0.31 per quarter, Illinova's 

3 The source of numbers 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 of a new 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 of Chevron. The effect of the transaction was payment of a premium to Illinova shareholders. 

4 
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shareholders realized a return of 49% over the two-year between passage of the 

Act and the 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 of Ameren's stock price. 

• Union Electric and CIPS were in the process of merging when the Act was 

passed. At the end of 1997, the merger was completed through a share exchange 

transaction where CIPSCO shareholders received 1.03 shares of Ameren for each 

of their original shares. Since p1ior to announcement of the merger in 1996, 

CIPSCO shares were trading at about a 6% discount to Union Electric 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 shareholders profited on a relative basis 

by more than Ameren shareholders from passage of the Act. These investors 

effectively retained the assets of Ameren and also received the premium. 

Analysis of Ameren's Financial Performance 

Unlike other beneficiaries of the 1997 Ace, Ameren's return on equity has not shown a 

dramatic increase since passage of the Act. This is because Ameren's equity base (the 

denominator of the retum on equity calculation) includes the premiums the company paid 

to the investors ofillinova, CILCORP, CIPSCO, AES and Dynegy. The returns of 

Ameren are also affected by regulatory events in Missouri and profits from the natural 

gas business. 

The retum on equity graph below shows that Ameren realized a return in 2004 (the latest 

year for which a full year of data 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 than the 

retums being allowed to utility companies elsewhere in the nation. The subsidiary 

company that now owns Illinois generation assets has a very high return of above 28%. 

This return has been consistently above 20% ever since the generating company was 

formed in 2000. In the future, the generating company should earn even higher returns as 

the market prices increase with the sustained high price of oil and natural gas. 

7 An analysis of the performance of investors and ratepayers is made in the report "ComEd!Exelon' s 

Performance Under The Illinois Electric Service Customer Choice And Rate Relief Law of 1997 And 

Beyond." 

5 
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* * * * *PC# 2409 * * * * * 

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 

itself projects rate increases of 20-35%, 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% of the 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 it paid merger premiums to the 

investors of CIPS, 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 of Ameren has been 

better than the utility and the S&P 500 index. Consider an investor who owned one share 

of Ameren at the end of 1997. At the end of 1997, the stock value was about $39/share. 

6 
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* * * * *PC# 2409 * * * * * 

This investor holding this share from 1997 through today would have realized dividends 

and capital gains yielding $72/share as shown on the time line graph below. As the 

investor in 1997 realized his or her dividends and share price increases, he or she would 

also now have a company that owns the assets of CIPS, CILCO, and Illinois Power. By 

comparison, if the investor put his or her $39 in a mutual fund consisting of S&P 500 

stocks or a mutual fund that includes a mix of utility shares, he or she would have ended 

up today with $49 and $56 respectively. 

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 put money in Ameren shares or the S&P 500 or 

the utility fund are demonstrated by computing the overall percent return and the dollar 

amount that has been realized. The graph below illustrates that Ameren investors have 

realized an 80% increase while the same investment in the S&P 500 fund would have 

generated only 23%. The Ameren return is almost four times as much as the S&P 500. 

Similarly, the investor return of 41% on utility shares is half the return realized by the 

Arneren investment. 

7 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

The table below shows how Ameren investors have fared on an aggregate basis. There 

were 13 7 million Ameren shares outstanding at the end of 1997. Multiplying these 

shares by increase in share value ($72-$3 9) 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 than the 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 provided benefits to residential ratepayers in the form of rate reductions. These 

rate reductions were higher for Illinois Power than for Union Electric, CIPS and CILCO. 

8 
Electronic Filing- Received, Clerk's Office, 08/10/2012 

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

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 of the rate decreases 

has been approximately $800 million as shown on the table below8 

Value of Rate Reductions in $ Millions 

IP CIPS UE GIL CO 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 of these rate increases pales in comparison to the $2.6 billion 

realized by investors in predecessor companies, without even considering the financial 

performance of Ameren. However, to accurately compare the rate reductions with 

investor benefits, we included the value of Ameren 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 $500 ,000 + ~~ii~i~iiii~=q 

$Ot-= 

Ratepayer Value 

Ameren 

Value \13 

Utilities, 

$2,139 

Investor Value 

8 The source of the lllinois Power figures are numbers provided in SEC documents. The source of the other 

figures are residential revenue figures from the FERC Form 1 reports. 

9 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

Summary 

Ameren has been able to generate substantial returns to shareholders despite the 

premiums the company has paid to the investors of CIPS, 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 

of the most profitable utilities in the country. 

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

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

EXHIBITS 

Comments of lllinois Health Professionals (August 10, 2012) 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

August 10, 2012 

lllinois Pollution Control Board 

c/o John Therriault 

Assistant Clerk of the Board 

James R. Thompson Center 

100 W. Randolph 

Suite 11-500 

Chicago, illinois 60601 

Re: Docket No. PCB 2012-126 

Dear Members of the 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 power plant 

emissions of sulfur 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 you to vote against any action eroding MPS standards. 

Nationally, coal-fired power plants are the largest sources of SOz and mercury emissions, and are 

among the largest single source emitters ofNOx. Emissions of these air pollutants impact human 

and ecosystem health in a number of ways. Exposure to 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 of S02 and NOx can exacerbate respiratory symptoms in 

at-risk individuals (including children and the elderly), including asthma and COPD attacks. 

Wildlife and plant species are also impacted by the toxic effects of these pollutants, (e.g. 

reproductive impacts of mercury to wildlife, SOrderived acid rain damage to foliage). 

In addition to the health impacts of directly 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 of solid and liquid particles, and a very 

large proportion of measured PM2.5 results from the chemical transformation of S02 and various 

NOx molecules in the atmosphere. Numerous scientific studies and authoritative panels have 

identified PM2_5 as harmful to human health, with causal linkages found between short- and longterm exposures and premature mortality and cardiovascular effects. According to a 20 l 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) of these costs were due to health damages associated with the transformation of S02 into 

PMz.5-
Electronic Filing- Received, Clerk's Office, 08/10/2012 

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

As it stands, the MPS is designed to require substantial reductions in the emission rates of SOz, 

NOx, and mercury. These reductions will allow for substantial gains in the public health of our 

state and surrounding regions, particularly for vulnerable populations. By maintaining the 

present MPS emission rate requirements for each of the pollntants, you will ensure that the health 

improvements behind the spirit of the law remain intact, and that the public does not bear the 

costs of polluter non-compliance. We applaud you for your decision to put the MPS in place six 

years ago, and we ask that you continue to show your 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 of Public Health 

Robert Cohen, MD, FCCP 

Director 

Pulmonary and Critical Care Medicine 

Cook County Health and Hospitals System 

Samuel Dorevitch, MD, MPH 

Associate Professor 

Division of Environmental and Occupational Health Sciences 

University oflllinois at Chicago School of Public 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 of Cook County 

Doctors Council SEIU 

Fred Martin, MD, and VP of Doctors Council SEIU 

Ann Krantz, MD 

Paula Kovarik, MD 

Lisa Henry-Reid, MD 

Simon Piller, MD 

(representing 500 health professionals throughout Cook County) 

Sarah Lovinger, MA, MD 

Executive Director, Chicago P SR 

Physicians for Social Responsibility 

*Affiliation for information only. Not to imply institutional endorsement. 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

Non·ina Allen 

Assistant Professor 

Department of Preventive Medicine 

Northwestem University Feinberg School of 

Medicine 

Susan Altfeld 

Climcal Assistant Professor 

Community Health Sciences 

University of illinois at Chicago, School of 

Public Health 

Bapu P. Arekapudi 

CEO, Lake Shore Medical Associates Ltd 

Pulmonary Critical Care Medicine (retired 

from Clinical Practice) 

Emeritus Staff Advocate illinois Medical 

Center 

Robert Bailey 

Professor 

Epidemiology and Biostatistics 

University of lllinois at Chicago, School of 

Public Health 

Cynthia Barnes-Boyd 

Director 

Great Cities Institute and School of Public 

Health 

University of illinois at Chicago, 

Neighborhoods Initiative 

Michelle Birkett 

Research Assistant Professor 

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 

Research Assistant Professor 

Department of Preventive Medicine 

Northwestern University Feinberg School of 

Medicine 

Kenzie Cameron 

Research Associate Professor 

Department of Medicine/Division of General 

Internal Medicine and Geriatrics 

Northwestern University 

Lorraine Conroy 

Professor 

Environmental and Occupational Health 

Sciences 

University of Illinois at Chicago, School of 

Public Health 

John Cronan 

Professor and Head of Microbiology; 

Professor ofBiochernisfly; Microbiology 

Alumni Professor 

Microbiology Biochemistry Insitute for 

Genomic Biology 

University of Illinois 

DavidCugell 

Bazley Professor ofPulmonmy Diseases 

Northwestem University Feinberg School of 

Medicine 

Bethany Cutts 

Assistant Professor 

Natural Resources and Environmental 

Sciences 

University of Illinois 

Ann Marie Dunlap, M.D. 

Leslie Duram 

Professor and Director 

Environmental Studies and Geography 

Southem Illinois University 

Linda Ehrlich-Jones 

Research Assistant Professor. 

Physical Medicine & Rehabilitation, InStitute 

for Public Health & Medicine, Center for 

Health Care Studies 

Northwestern University 

Nurtan Esmen 

Professor Emeritus 

Occupational & Environmental Health 

Sciences 

University of Illinois at Chicago 

*Affiliation for information only. Not to imply institutional endorsement. 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

Michael Fleming 

Public Health 

Northwestern University 

Vincent Freeman 

Associate Proftssor of Epidemiology 

Division of Epidemiology and Biostatistics 

University of illinois at Chicago, School of 

Public Health 

Willard Fry 

Professor Emeritus of Clinical Surge1y 

Northwestem University Feinberg School of 

Medicine 

Sylvia Furner 

Associate Professor-Emerzta 

Epidemiology and Biostatistics 

University of illinois at Chicago, School of 

Public Health 

Karen Gaines 

Biology Center for Clean Energy Research 

and Education 

Eastern illinois University 

Godfrey Getz 

Pathology Department 

University of Chicago 

Aida L. Giachello 

Proftssor 

Department of Preventive Medicine & 

Institute for Public Health & Medicine 

Northwestern University 

Zsuzsa Gille 

Professor 

Jennifer Gray-Stanley 

Assistant Professor 

Public Health 

Northern Illinois University 

Philip Greenland 

Professor 

Preventive Medicine 

Northwestern University 

Ravi Grivois-Shah, MD MPH 

Arden Handler 

Professor 

Community Health Sciences 

University of lllinois at Chicago, School of 

Public Health 

Ronald Hersh ow 

Associate Proftssor of Epidemiology 

Division of Epidemiology and Biostatistics 

University of Illinois at Chicago, School of 

Public Health 

Lifang Hou 

Department of preventive Medicine 

Northwestern University 

Robert Hudson 

Associate Professor Department of Natural 

Resources and Environmental Sciences 

Natural Resources and Environmental 

Sciences 

University of lllinois 

Susan Hughes 

Professor and Research Center Director 

Community Health Sciences 

University of Illinois at Chicago, School of 

Public Health 

H. Ari Jaffe 

Chief- Pulmonmy, Critical Care & Sleep 

Medicine 

Jesse Brown VA Medical Center 

Carolyn Jarvis 

Professor 

School of Nursing 

Illinois Wesleyan University 

Neil Jordan 

Assistant Professor 

Institute for Public Health & Medicine 

Northwestern University Feinberg School of 

Medicine 

Karen Kaiser 

Research Assistant Professor 

Department of Medical Social Sciences 

Northwestern University Feinberg School of 

Medicine 

*Affiliation for information only. Not to imply institutional endorsement. 
Electronic Filing -Received, Clerk's Office, 08/10/2012 

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

Linda Kaste 

Associate Proftssor 

Ped Dent and Epi/Bio 

University of illinois 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 of Public Health 

University of illinois at Chicago 

Yongliang Li 

Associate Research Professor 

Environmental and Occupational Health 

Sciences 

University of illinois at Chicago 

Darcy Majka 

Division of Rheumatology and Department of 

Preventive Medicine 

Northwestern University Feinberg School of 

Medicine 

R. Meganathan 

Distinguished Research Professor 

Biological Sciences 

Northern Illinois University 

Susan Meiers 

Associate Professor 

Biology 

Western illinois University 

Robin Mermelstein 

Proftssor and Director 

Institute for Health Research and Policy 

University of lllinois at Chicago 

Kelly Michelson 

Associate Professor 

Pediatrics 

Northwestern University Ann & Robert H. 

Lurie Children's Hospital of Chicago 

Craig Mizzen 

Associate Professor 

Dept. of Ceil & Developmental Biology, 

Institute for Genomic Biology 

University of illinois 

David Mohr 

Proftssor 

Preventive Medicine 

Northwestern University 

Darby Morhardt 

Research Associate Professor 

Cognitive Neurology and Alzheimer's Disease 

Center 

Northwestern University 

Darlene O'Callaghan 

Associate Professor 

Nursing 

Saint Xavier University School of Nursing 

Larry Ouellet 

Research Proftssor of Epidemiology 

Epidemiology and Biostatistics 

University of Illinois at Chicago 

Aaron Packman 

Professor 

Civil and Environmental Engineering 

Northwestern University 

Lucy Park 

Associate Proftssor 

Department of Pediatrics 

University of lilinois at Chicago, College of 

Medicine 

Nadine Peacock 

Associate Professor 

Community Health Sciences 

University of lllinois at Chicago, School of 

Public Health 

*Affiliation for information only. Not to 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. Nayak Professor of Pediatrics Head, 

Department of Pediatrics; University of 

Illinois at Chicago; Physician-in-Chief, 

Children's Hospital 

Pediatrics 

University of lllinois at Chicago Children's 

Hospital University of Illinois Hospital & 

Health Sciences System 

Rosalind Ramsey-Goldman 

Solovy Arthritis Research Society Professor of 

Medicine 

Medicioe!Rheumatology Institute for Public 

Health and Medicine 

Northwestem University 

John Reeve 

Associate Professor 

Zoology 

Southem illinois University Carbondale 

Eric Ribbens · 

Professor 

Biological Sciences and Environmental 

Studies 

Michael Romano 

Professor 

Biological Sciences 

Westem Illinois University 

Nan Rothrock 

Research Assistant Professor 

Medical Social Sciences 

Northwestem University 

Denise Scholtens 

Associate Professor 

Department of Preventive Medicine 

Northwestem University Feinberg School of 

Medicioe 

Karen Sheehan 

Professor of Pediatrics & Preventive 

Medicine 

Pediatrics 

Northwestem University Ann & Robert H. 

Lurie Children's Hospital of Chicago 

Donald Sparling 

Associate Professor 

Cooperative Wildlife Research Laboratory; 

Department of Zoology 

Sonthem Illinois University 

Peter Sporn 

Professor of Medicine Director, Pulmonwy 

and Critical Care Medicine Fellowship 

Program 

Division of Pulmonary and Critical Care 

Medicine 

Northwestem University Feinberg School of 

Medicine 

Wesley Swingley 

Assistant Proftssor 

Biology 

N orthem Illinois University 

Sandy Tenfield 

Assistant Proftssor; 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 of Psychiatry and Behavioral 

Sciences Health Disparities and Public Policy 

Northwestem University Feinberg School of 

Medicine 

William Thompson 

Assistant Proftssor 

Department of Medicine 

Northwestem University 

Paloma Toledo 

Instructor in Anesthesiology 

Anesthesiology 

Northwestem University Feioberg School of. 

Medicine 

*Affiliation for information only. Not to imply institutional endorsement. 
Electronic Filing- Received, Clerk's Office, 08/10/2012 

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

Bernard Turnock 

Clinical Professor and Director 

Community Health Title 

University of lllinois at Chicago, School of 

Public Health 

Joel Voss 

Assistant Professor 

Medical Social Sciences, Neuroscience 

Program 

Northwestem University 

Leah Welty 

Assistant Professor 

Department of Preventive Medicine 

Northwestem University 

Snsan Yount 

Associate Professor 

Medical Social Sciences 

Nortl1westem University Feinberg School of 

Medicine 

*Affiliation for information only. Not to 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 of damages 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, and Medicine 

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 

Please find below the invoice for the requested Public Access Files Materials. 

PROJECT: Health, Environmental, and Other External Costs and Benefits of Energy 

Production and Consumption 

PIN# BEST-K-08-02-A 

File(s): #34. Supplemental results of the committee, April 22, 2010 

Estimates of damages associated with specific coal-fired electricity-generating facilities and 

natural-gas-fired electricity-generating facilities. Two Excel spreadsheets. 

Cost of Materials/Shipping: $12.00 

Thank you for your interest in The National Academies. Please let me know if we can 

help you with anything else. 

Regards, 

s !V-.lUUW g liifuUu.J 

Suzanne Thilenius 

Public Access Records Office (PARO) 

The National Academies 

PARO@nas.edu 

The copyright law of the United States (title 17, United States Code) govern the making of 

photocopies or other reproductions of copyrighted material. Under certain conditions specified in 

the Jaw, libraries and archives are authorized to furnish a photocopy or other reproduction. One of 

these specific conditions is that the photocopy or reproduction is not to be "used for any purpose 

other than private study, scholarship, or research." If a user makes a request for, or later uses, a 

photocopy of reproduction for purposes in excess of "fair use" that use may be liable for copyright 

infringement. This institution reserves the right to refuse to accept a copying order if. in its 

judgment, fulfillment of the order would involve violation of copyright law. 

The attached material is provided in accordance with the procedures of the National Academy of 

Sciences implementing the requirements of Section 15 of the Federal Advisory Committee Act, P.L. 

105-153 5 U.S. C. App. Section 15 (1997). 

NAllONAl ACADEMY OF SOENCES • NATIONAL ACADEMY OF ENGINEERING • !NSTITIJTE OF MEDICINE • NATIONAl RESEARCH COUNCIL 
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