20100628_JointEARTHWORKSmercuryCommentsToEPA

June 28, 2010

Air and Radiation Docket and Information Center,

Environmental Protection Agency, Mail code: 2822T,

1200 Pennsylvania Ave., N.W.

Washington, DC 20460

Attention: Docket ID No. EPA–HQ–OAR–2010–0239.

Thank you for the opportunity to comment on the proposed mercury air emission regulations for gold and silver processing facilities. These comments are submitted on behalf of

EARTHWORKS, Great Basin Resource Watch, Montana Environmental Information Center, The Lands Council, The Spokane River Keepers, Rivers Without Borders, Friends of the Kalmiopsis, Friends of Great Salt Lake, Defenders of the Black Hills and Save Our Sky Blue Waters.

EARTHWORKS is a nonprofit organization working to protect communities and the

environment against the adverse impacts of hardrock mining.

We commend the Environmental Protection Agency for initiating this important rule-making to develop MACT standards for gold and silver processing facilities. Given the significant public health effects related to mercury exposure, and the very large amounts of mercury released by some gold and silver mines, the development of federal MACT standards is an important step in reducing mercury air emissions from this industry.

Earthworks has a number of comments on the proposed rule which are listed in greater detail below, but I would like to highlight our most significant concern.

The emission limits for pretreatment for new mines is set the same as the pretreatment emission limits for existing operations, and it would allow an unacceptably high level of mercury to be released into the air. For example, the proposed pretreatment emission limit (149 pounds/million ton) would allow the Donlin Creek Mine, proposed in southwest Alaska (at 22 million tons per year), to release more than 3,200 pounds of mercury into the atmosphere per year. This is 40 times more than the amount of mercury that is currently released into the air by all industries in

Alaska!1 And, this does not account for the amount of mercury that will be released by other mine processes at Donlin.

We are particularly concerned that these emission limits are not protective of public health, particularly the subpopulations in the U.S. that consume higher than average amounts of fish. The Donlin Creek mine is an important example. This mine is located in the Kuskokwim River watershed, and the communities there rely on a subsistence diet high in fish – consuming up to 699 pounds of non-salmon fish species a year.2 The impact from additional mercury loading in this region is particularly troublesome given that the Kuskokwim River supports one of the largest subsistence fisheries in Alaska and Alaska Natives in the region rely on subsistence fishing for approximately 60% of their diet.3

Mercury concentrations in fish tissue are already an issue in this region due to historic mercury mining. Thus, new sources of mercury air pollution are particularly a concern. According to a 1997 study of mercury concentrations in fish provided by subsistence fishermen who live in the lower Yukon-Kuskokwim Delta, 16 of 66 fish contained mercury above the "level of concern" established by the Environmental Protection Agency.” Overall, 24% of the fish exceed the critical value for human consumption and 58% the wildlife critical value.4

Mercury exposure is a tremendous public health concern, particularly for children. Exposure to mercury can cause significant neurological and developmental problems such as attention and language deficits, impaired memory and impaired vision and motor function.

We urge the EPA to make changes in the draft regulations to better protect public health from existing and new sources of mercury air emissions. Our detailed comments on this element and other elements of the rule-making are below.

Thank you for considering our comments. With these comments, we also reference comments submitted by Center for Science and Public Participation, Northern Alaska Environmental Center and Solutions Statistical Accounting.

Sincerely,

Bonnie Gestring

1 U.S. EPA, Toxic Release Inventory (TRI) data for 2008 – the most recent data available for all industries. The total point source and fugitive mercury air emissions for Alaska for all industries is 71 pounds. 2 Verbrugge, Lori, for the State of Alaska, Division of Public Health, Fish Consumption Advice for Alaskans. October 15, 2007. 3 Alaska Community Action on Toxics & Reducing Environmental Destruction on Indigenous Lands, “Mining and Toxic Metals: A case study of the proposed Donlin Creek mine,”citing Alaska Department of Fish and Game, Division of Subsistence, 2001, Alaska Subsistence Fisheries–1999 Annual Report at 154 (2001). 4 Duffy et al. “Regional health assessment relating to mercury content of fish caught in the Yukon-Kuskokwim Delta rivers system.” 1998 Oct-Dec; 40 (4):75-7, 89.

EARTHWORKS

140 South 4th Ave. West Unit 1

Missoula, MT 59801

406-549-7361

Jim Jensen

Executive Director

Montana Environmental Information Center

P.O. Box 1184

Helena, MT 59624

Mike Petersen

Executive Director

Lands Council

25 West Main Avenue

Spokane, WA 99201-5090

Rick Eichstaedt

Spokane Riverkeeper/Attorney

35 West Main, Suite 330

Spokane, Washington 99201

Barbara Ullian

Friends of Kalmiopsis

Grants Pass, Oregon 97527

John Hadder Executive Director Great Basin Resource Watch 85 Keystone St. Reno, NV 89503 Lori Andresen Save Our Sky Blue Waters PO Box 3661 Duluth Minnesota 55803 http://doc.guandang.net Will Patric Executive Director Rivers Without Borders PO Box 1968, Port Town …… 此处隐藏：39090字，全部文档内容请下载后查看。喜欢就下载吧 ……