Introduction
There has been a lot of talk about mercury, especially as it relates to coal-fired power plants. That's because the issue of mercury – where it comes from and its impact – is complex. We at Santee Cooper know there are questions, and we want to address them responsibly and accurately.

Here's the good news: mercury isn't as daunting as some would have you believe. But because the issue of mercury is of interest to many people, we would like to shed some light on the topic.
 
Santee Cooper's Pee Dee Energy Campus Will Comply with Every Federal and State Environmental Standard, Including Mercury Emissions


It's important to differentiate between mercury emissions and mercury consumption, too. Mercury is primarily emitted into the air, but mercury consumption can only happen after it has landed in water and builds up over time into the tissues of animals such as the fish we eat.

The EPA provides guidelines on how much fish any of us should eat.  Based upon its research, the EPA believes that eating their prescribed amount of fish will result in a level of mercury consumption that is approximately one-tenth of the amount that could be harmful. To further protect the public, the South Carolina DHEC posts signs on our waterways communicating this important information to fishermen.

Even though federal regulatory agencies such as the EPA recommend limiting the amount of seafood — along with many other foods — that pregnant women consume, it does not encourage people to eliminate fish from their diets altogether. In fact, fish is widely considered to be part of any healthy, balanced diet.15 Furthermore, several studies by medical professionals have even warned that the health hazards of not eating fish are much more significant than concerns over mercury.16

With respect to state-level regulations, South Carolina has a tradition of responsible stewardship of its environment.

Our rivers and lakes, and the fish they support, are tested for mercury levels and other potential pollutants, and they measure up extremely well — compared to our neighboring states, and even compared to the national average.17 In fact, though South Carolina is smaller than our neighbors, DHEC extensively samples as much or more — 1,800 fish per year from 150 sites — than the state governments of our neighbors North Carolina, Georgia and Flordia.  In addition, our fish advisory guidelines are generally more conservative.18 19

To put the federal and state regulations and guidelines we've talked about into context, the EPA's acceptable annual emissions level for coal-fired power plants in 2007 was 115 pounds/year.  In its draft permit for the Pee Dee Energy Campus, DHEC has set its allowable level at 69 pounds/year.  The proposed Pee Dee Energy Campus will come in below even DHEC's number.

And thanks to the highest and best available environmental technology, the level of mercury emissions at our Pee Dee Energy Campus, combined with the rest of Santee Cooper's facilities, will be a small amount of the world's emissions.20 According to EPA standards, our proposed facility will have among the highest controls of any facility currently in operation.21

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15 U.S. EPA, Fact Sheet,  http://www.epa.gov/waterscience/fishadvice/factsheet.html#consumers
16 Time magazine, http://www.time.com/time/health/article/0,8599,1706623,00.html
17
  South Carolina United States SC as a % of Nation
Total River Miles 29,898
(24,115 perennial)
3,662,255
(1,298,134 perennial)
0.81
(1.9 perennial)
Total Land Area (sq. miles) 34,726 3,794,066 0.92
Mercury-Impacted River Miles 1,747 > 846,310 0.21
% River Miles Impacted 5.8 23.1 0.21

'AQVI Summary' in Center for Air Toxic Metals Technical Newsletter, volume 13, issue 2, December 2007, http://www.undeerc.org/catm/pdf/Volume13Issue2.pdf

Kentucky Division of Water, [online] www.water.ky.gov/NR/rdonlyres/68E75B67-DAF6-4B10-8D22-34DE7E16AC3C/0/98_river_miles.pdf [accessed 17 January 2008]

 

It does not appear that South Carolina's problems are unique, uniquely widespread, or due to local deposition.  According to the Post and Courier, South Carolina has mercury advisories for 1,747 miles of river, out of a total 29,898 miles of river (24,115 perennial river miles) which run through our state.  The United States as a whole has more than 846,310 miles of mercury-impacted waters out of a total 3,662,255 miles of river nationwide.  Thus South Carolina waters make up approximately 0.21% of impacted waters nationwide.  While it is unfortunate that any of the state's waters are impacted, these numbers must be placed in context.  South Carolina contains 0.92% of the nation's land area (1.11% of the contiguous United States).  South Carolina has 0.81% of the nation's river miles and 1.9% of the nation's perennial river miles (3.22% of contiguous United States).  Finally, nationwide, 23.1 % of river miles are impacted; this compares to only 5.8% of river miles impacted in South Carolina. 


18
South Carolina Department of Health and Environmental Quality, http://www.scdhec.gov/environment/water/abs.htm


19 Additional information,
http://www.hc-sc.gc.ca/fn-an/securit/chem-chim/environ/mercur/cons-adv-etud_e.html,

http://www.floridadep.org/labs/mercury/docs/fhapre.htm, http://www.epi.state.nc.us/epi/fish/technicalhealtheffects.pdf, ftp://ftp.fao.org/codex/ccfac38/fa38_37e.pdf, http://www.codexalimentarius.net/download/standards/17/CXS_193e.pdf

http://www.chem.unep.ch/MERCURY/Report/Final%20report/final-assessment-report-25nov02.pdf  (Table 4.1 on pg 51)

Other Agencies

Regulating Agency Action Level(s) Below Action Level Above Action Level
Canada
(Health Canada)
Most fish:
0.5  mgHg/kgfish

Unlimited Consumption

Not Allowed to be Sold

Large marine predator species:  1 mgHg/kgfish

(wet weight)

Young children: 

1 meal/month

Not Allowed to be Sold

Women of Childbearing Age:  2 meals/month

General population: 

2 meals/week

Florida

(DEP)

1.5 mgHg/kgfish

Women of Childbearing Age and Children:

1 meal/month

Do Not Eat

All others:  1 meal/week

0.5 mgHg/kgfish

Unlimited Consumption

Women of Childbearing Age and Children:

1 meal/month

All others:  1 meal/week

North Carolina

(DHHS)

0.4 mgHg/kgfish

Women of Childbearing Age:  2 meals/week

Women of Childbearing Age:  Do Not Eat

All others:  4 meals/week

All others:  1 meal/week

*Note:  NC has an implied action level of 0.1 mgHg/kgfish, below which fish seem to be considered "mercury-free."  It is unclear whether or not this level is used in practice, however.

US FDA
(Fish Sold in Commerce)

1 mgHg/kgfish

Unlimited Consumption Not Saleable via Interstate Commerce

World Health Organization/

Food and Agriculture Organization

All fish except predatory fish: 

0.5 mgHg/kgfish

Codex Alimentarius Guidelines: The Guideline levels are intended for methylmercury in fresh or processed fish and fish products moving in international trade.Where these Guideline levels are exceeded, governments should decide whether and under what circumstances, the food should be distributed within their territory or jurisdiction and what recommendations, if any, should be given as regards restrictions on consumption, especially by vulnerable groups such as pregnant women.

Predatory fish: 

1 mgHg/kgfish

20 U.S. EPA, Clean Air Mercury Rule, op. cit.
The U.S. EPA has stated that U.S. power plants are responsible for approximately 1% of worldwide emissions which range from 4,400-7500 metric tons/year, or 8.8-15 million pounds/year (http://www.epa.gov/air/mercuryrule/basic.htm#global).  That means that U.S. power plants would emit from 44-75 tons/year, or 88,000-150,000 lbs/year.  Santee Cooper TRI estimates indicate that Santee Cooper released 420 lbs of mercury in 2006.  (This is the most recent year for which data is available.  Although Cross Unit 3 has come online since 2006, so have significant scrubber improvements at Winyah Generating Station.  Estimates based on these changes will be available in the coming months.)  Thus Santee Cooper is responsible for about 0.5% of U.S. emissions and 0.005% of world emissions. By comparison, South Carolinians, numbering about 4.3 million people, compose .06% of the world's population.
21 The process Santee Cooper elected to pursue with DHEC will evaluate permit limits nationwide and ensure that the Pee Dee Energy Campus is performing at a very high level relative to other plants.


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