"The estimated large discharge of mercury alone is reason to oppose the requested permit"



Sierra Club Western Lake Erie

May 26, 2004

Dear Elected Official:

The Great Lakes make up the world's most abundant fresh water supply. The Western Basin of Lake Erie is one of the most productive areas for fish. These are important resources to preserve and to protect now and on the future. The 2000 Lake Erie Lakewide Management Plan specifically designates mercury as a critical contaminant in Lake Erie and includes maps showing high concentrations of mercury in the sediments of the western basin, including the Maumee River Area of Concern. In the International Joint Commissionís 2001-2003 Priorities Report, the Science Advisory Board Recommends that the governments "further reduce mercury emissions, including those from coal combustions, because mercury levels in fish are still above levels to fully protect human health and wildlife and because there are over 2,000 fish consumption advisories for mercury in the United States and Ontario." The SAB further notes that "coal combustion appears to be the largest unregulated source of mercury air deposition to the Great Lakes area" and that "due to widespread mercury contamination of sportfish, all Great Lakes states and the province of Ontario have general fish consumption advisories covering all inland waters."

The Science Advisory Board also provides the following brief summary of mercuryís health effects even in very low amounts. "Mercury causes subtle, adverse neurological impacts at very low doses. Recent studies suggest that mercury may be associated with increased risk of myocardial infraction in men. Mercury exhibits characteristics similar to lead toxicity and as more information is discovered regarding mercury toxicity, the exposure level at which mercury causes adverse health effects has been lowered."

According to the permit application, the FDS facility would discharge up to 680 pounds of mercury into the air annually, making it one of the largest sources of mercury in the Great Lakes basin and fifth largest in the State of Ohio. The draft permit has no monitoring provisions for mercury and includes no limits for mercury and other hazardous air pollutants.

It is important to note that a currently operating facility similar to the one proposed in Oregon, Ohio, states that the estimated annual mercury emissions are 719 pounds. Furthermore the Indiana Harbor coke plant is seeking a permit modification for 69 days per year to openly discharge pollutants rather than the 14 stated in the permit. The FDS facility also states 14 days.

Alex Sagady, pollution expert for the Sierra Club, prepared the attached information [61 KB pdf]. Please review the information. While the coke plant poses many risks to human health, Lake Erie, the air and land, the estimated large discharge of mercury alone is reason to oppose the requested permit.

Please call with any questions.

Sincerely,

Sandy Bihn
Sierra Club
6565 Bayshore Road
Oregon, Ohio
(419) 691-3788