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Great Lakes Binational Toxics Strategy

Mercury

Consumers Energy Mercury Pollution Prevention
A Plan for the Management of Mercury Usage and Emissions and Report of Mercury Reduction Progress by Consumers Energy Company

March 1999 Update

Table Of Content

1. Introduction
2. Plan for Continued Mercury Management
3. Report of Mercury Reduction Progress
   1. Current Efforts Impacting Mercury Pollution Prevention
      1. Electric Generation Energy Sources and Fuel Mix
      2. Coal Mercury Content
      3. Use of Nuclear Energy
      4. Use of Oil and Natural Gas
      5. Use of Renewable Electric Energy Sources
      6. Use of Energy Conservation and Energy Efficiency Programs
   2. Future Efforts Impacting Mercury Pollution Prevention

Task Force Recommendations and Consumers' Responses

1. Finalization of USEPA Mercury and Utility Studies - Determine the Scientific Basis to Promulgate National Standards for Mercury Emissions From Electric Utility Boilers
2. MPSC/MDEQ/Michigan Utilities - Support Additional Research Efforts
3. Michigan Utilities Should Continue to Support Projects on Evaluating Renewable Energy Sources
4. Utilities Requested to Factor in Costs and Benefits in Future Environmental Impact Statements
5. Michigan Utilities Requested to Develop a Plan to Further Reduce Mercury Usage or Emissions and Provide Report Progress in Achieving Mercury Reductions
   1. Electric Power Generation
   2. Non-Coal Combustion-Other Potential Mercury Pollution Sources
      1. Company Actions
      2. Mercury Management Options
      3. Selecting Appropriate Mercury Pollution Prevention Options and Implementation and Schedules
      4. Additional Considerations
      5. Progress in Achieving Non-Coal Combustion Mercury Reductions

I. Introduction

This Mercury Pollution Prevention Plan and report of management processes associated with mercury usage and emissions is a direct response to the March 8, 1996 Final Report of the Michigan Mercury Pollution Prevention Task Force. Sections 4.0 and 5.0 of that report addressed electric utility operations to be included in ongoing pollution prevention assessments. Specific utility sector recommendations (recommendations number 35 through 39) were provided in the report's Conclusions and Recommendations section.

Consumers Energy has a long-standing history of corporate environmental stewardship and commitment to environmental quality. The ongoing management of mercury through practicable usage and emissions options continues to be an important element of that commitment.

II. Plan for Continued Mercury Management

The burning of coal which contains trace amounts of mercury and the use of mercury in equipment results in the actual and potential release of mercury to the environment. There has been and will continue to be scientific review and debate over the effects of mercury on human health and the environment. There also will likely be continued efforts to increase regulation of mercury in fuels, and products and equipment containing mercury.

Consumers' Plan is to continue to use low mercury coal. Consumers also plans to continue the use of a mix fuels such as; nuclear, oil, natural gas and renewable electric energy sources (hydro, wood, landfill gas, mass burn incineration, etc) to meet its customers' demands. We plan to continue to provide electric energy to our customers in strict adherence to applicable regulations and cost-effective management practices. Within these same constraints Consumers will continue to evaluate the use of renewable electric energy sources and energy conservation and efficiency programs. The Plan also includes future efforts to cooperate with appropriate state agencies to support additional research, projects evaluations, renewable electric energy sources and to honor a commitment to factor mercury emission control cost/benefit analysis into future coal-fueled Electric Generation Plant Construction Environmental Impact Statements.

Consumers' Plan also includes continued implementation of a Company-wide non-coal combustion Mercury Pollution Prevention initiative to: 1) identify other potential mercury pollution sources; 2) identify where and in what quantities the Company uses mercury and mercury-containing equipment and; 3) implement and support programs to systematically reduce the use of mercury and mercury containing equipment. (Reference Table 1).

III. Report of Mercury Reduction Progress

A. Current Efforts Impacting Mercury Pollution Prevention

1. Electric Generation Energy Sources and Fuel Mix

To meet customer demand the Company provides customers with electrical energy that we generate, we purchase from non-utility generators (purchase power) or we purchase from other utilities (interchange power). In 1997 about 56.4 percent of the customer demand was met with energy generated by the Company, 32.3 percent by purchase power and 11.3 percent by interchange power.

Based on a preliminary review and analysis of readily available data it is estimated that 53.5 percent of the Company's customer electric load in 1997 was met by coal-fired electric units. For purposes of this discussion, we assumed that 96 percent of the 1997 interchange power was produced by coal. Additionally, over 24.7 percent of the customer demand was met by oil or natural gas fueled units, 15 percent by nuclear and about 4.7 percent from renewable or other sources comprised of: 1.8 percent hydro, 2.3 percent wood, 0.4 percent landfill gas, 0.2 percent mass burn incinerators, and 2.1 percent from other sources.

An article in a March 6, 1999 issue of the New York Times estimates national fuel sources for US electricity to consist of 56.9 percent coal, 20.8 percent nuclear, 7.5 percent natural gas, 11.6 percent hydroelectric, and 3.2 percent other. A comparison of Consumers Energy's total electrical generation fuel mix with the national electrical generation fuels used in 1997 indicates a slightly lower use of coal (53.5 percent vs 56.9 percent), higher use of natural gas and oil (24.7 percent vs 10.7 percent), a lower use of nuclear (15 percent vs 20.8 percent), lower use of hydro (1.8 percent vs 11.6), and a slightly higher use of other sources (5.0 percent vs 3.2 percent).

2. Coal Mercury Content

Coal-fired electric units generated an estimated 21,543 of the total 40,269 million kWh needed to meet Consumers Energy's customer demand in 1997. About 79 percent of the estimated coal-fired energy (16,741 million kWh) was supplied by Company units.

To estimate mercury emissions resulting from the 16,741 million kWh of electricity generated by Company units, the most recent draft of the United States Environmental Protection Agency's (USEPA) Utility Study to Congress and Michigan Mercury Task Force data were reviewed. The most recent analyses of coal for mercury concentration (over 450 coal samples) provides averages of mercury content for the three principal types of coal used by Consumers Energy. (Eastern low sulfur 0.089 ppm/Eastern USEPA Quality 0.060 ppm/Western 0.075 ppm). These averages were then used, with the actual quantities of each type of coal burned and an assumption that 70 percent of the coal mercury content was emitted, to estimate mercury emissions from Company coal-fired plants. Because mercury content data are not available for coal burned in earlier years, the averages in the 1995 shipments were also used for 1985 and 1990 mercury emission calculations. Results indicate mercury emission reductions from an estimated 1,034 pounds in 1985 to 995 pounds in 1990, 927 pounds in 1995, and 901 pounds in 1996. The trend for emission reduction has continued in 1997 with an estimated 817 pounds of mercury emissions.

Consumers has gone from zero use of western coal in 1985 to about 31 percent (2.35 million tons) of over 7.5 million tons burned in 1997. The Company is limited in attempting to increase the level of western coal use by the fact that western coal has a lower BTU content then eastern coal and therefore more coal must be fed to the boilers to obtain the required heat release. Consumers is also limited by coal handling equipment capabilities and the physical size of the existing plant boilers.

Studies show that washing coal reduces the mercury content. In general, Consumers burns more washed eastern coal than in the past, however, records of the quantities of washed coal used were not maintained; therefore, this factor was not used in our analysis.

3. Use of Nuclear Energy

The Company's use of a mixture of fuels to generate electricity to meet its customers' demand in 1997 included some 6,040 million kWh of power generated from Company nuclear plants. Generation of the same amount of energy provided by the Company's nuclear plants rather than by coal-fired units can be viewed as resulting in reduced mercury emissions of an estimated 295 pounds in 1997. Assuming that 96 percent of 1997 interchange power was produced from coal, this estimate is conservative.

4. Use of Oil and Natural Gas

An estimated 9,944 million kWh of electrical energy generated by oil and natural gas fired plants was used to meet Company customer demand in 1997. A key component of this total and 25 percent of the Company's total load were met by 9,921 million kWh generated by the Midland Cogeneration Venture (MCV) natural gas-fueled units. Had Company coal-fired units of similar design and fuel use been used to replace the MCV power, an estimated additional 484 pounds of mercury would have been emitted in 1997. Energy supplied by coal-fired units owned by others would have likely increased this estimate. The use of oil and natural gas rather than coal units could be assumed to reduce mercury emissions by at least 485 pounds annually.

5. Use of Renewable Electric Energy Sources

Review of 1997 generation data indicate that an estimated 2,560 million kWh of energy for Consumers' customers were produced by renewable energy sources such as hydroelectric, wood fuel, landfill gas and mass burn incinerators, and other sources.

The Company's Campbell plant is using a supplemental fuel comprised of sawdust material from a wood product manufacturer. Approximately 20 tons per day (5 days a week) are burned. Samples were tested for various parameters and mercury was not detected at a 0.002 ppm detection level. It is estimated that this supplemental fuel replaced over 6 million pounds of blended coal which would have emitted 0.32 pounds of mercury.

The use of hydroelectric, wood fuel and landfill gas and other sources in place of coal-fired energy can be viewed as reducing mercury emissions in 1997 by 120 pounds. The use of mass burn incinerators may increase the probable mercury emissions over that which would have occurred from coal plant use.

6. Use of Energy Conservation and Energy Efficiency Programs

Within the constraints of Michigan Public Service Commission (MPSC) regulations, the Company has been supportive of demand side management programs which promote energy efficiency in addition to developing new programs to help customers make the best use of electricity. The reduction of electrical usage resulting from demand side management programs has helped limit the increase in emissions from generating plants burning coal.

Consumers Energy has implemented an initiative to place Engineering staff in several automotive plants for the purpose of recommending and implementing energy conservation measures. This initiative, which began in 1995 has resulted in energy saving recommendations and reductions for these plants totaling more than 14 million dollars since inception.

The Company also has a program that provides information to schools. Representatives of Consumers Energy visit local schools and make presentations to students on how to conserve energy. Since 1995 over 65,000 students have seen this program. Sixty percent of these students complete a home energy audit. It is an educational program that brings energy conservation back into the residential user category for current and future energy users.

The Company continues to support a customer lighting replacement program to promote energy efficient lamp systems and help reduce the generation of mercury-containing lamp waste. Additionally, the Company's internal pollution prevention programs include the use of lamp recyclers in lieu of disposal of regulated quantities of lamps.

The Company has also been supportive of research and development of the use of natural gas powered vehicles and refueling stations. We remain hopeful that there will be an expanded use of such vehicles.

B. Future Efforts Impacting Mercury Pollution Prevention

Section 4.4 of the Michigan Mercury Pollution Prevention Task Force Report contained specific recommendations for future mercury pollution prevention efforts. The report states:

It has been well established that mercury emissions from utilities are significant and at this time are uncontrolled for mercury. Because the emissions and subsequent deposition of mercury impact not only Michigan, but bordering states as well as Canada and because of industry deregulation, a national and binational approach is recommended. The M2P2 Task Force does not want to place Michigan utilities at a disadvantage over neighboring states.

The M2P2 Task Force discussed, at length, the feasibility of incorporating environmental costs and impacts ("internalizing externalities"), relative to mercury emissions and, subsequent deposition, as part of the utilities future resource planning and fuel choice. A consensus did form around the need for further study of environmental costs and impacts, none was achieved as to their role in resource planning, fuel choices or the regulatory process before the MPSC.

The M2P2 Task Force believes there are several options that exist for Michigan utilities to be proactive in taking a role to help reduce the over 2,000 pounds of mercury released from Michigan utilities.

The report followed this discussion with five specific recommendations that are addressed in the Company's Plan and in its initial report of mercury pollution prevention progress.

1.  Finalization of USEPA Mercury and Utility Studies - Determine the Scientific Basis to Promulgate National Standards for Mercury Emissions From Electric Utility Boilers

"The M2P2 Task Force, the MDEQ and the MPSC should encourage USEPA to finalize the mercury and utility studies and ensure that significant resources are allocated to determine the scientific basis to promulgate national standards for mercury emissions from electric utility boilers."

Consumers' Response

The Mercury Study was finalized in December, 1997. The Utility Study was finalized in February, 1998. Neither report made a regulatory recommendation for control of mercury emissions from utilities at this time.

Consumers continues to align with those who emphasize that any new national standards must be based on a strong scientific basis and an accurate cost benefit analysis.

2. MPSC/MDEQ/Michigan Utilities - Support Additional Research Efforts

"The MPSC and the MDEQ, working in cooperation with Michigan utilities, should support additional research efforts to evaluate the full environmental costs and impacts of mercury emissions and subsequent deposition from electric power generation."

"A study should be conducted that includes an evaluation of the costs and benefits of various reductions in the emissions of mercury from existing coal-fired power plants. The study should evaluate the full costs by mercury contamination to Michigan's and the Great Lakes region's economies, including impact on the health of people, wildlife, fisheries and the recreation and tourism industries. The study should evaluate the environmental and economic benefits that might be expected to accrue to Michigan and the Great Lakes region, including reduced health risks to people consuming fish, as a result of reduction in mercury emissions from electric power generation. This study should be coordinated with the ongoing Agency for Toxic Substances and Disease Registry (ATSDR)-funded research in Michigan on mercury levels in women of childbearing age. The study should also include such other areas of inquiry as deemed appropriate by a committee composed of representatives of the Governor's Relative Risk Air Quality Issues Task Force, the Office of Regulatory Review, the MPSC, the MDEQ and interested stakeholders including representatives of the public, environmental organizations and power companies."

Consumers' Response

The recommended scientific areas of inquiry associated with the effects of mercury on components of ecological systems and associated evaluation of "full environmental costs" appears to have an unlimited scope of study and an associated unlimited cost.

These complex issues are national topics and should not be addressed on a state by state basis. The recommended study of the impacts of mercury in various concentrations on "the health of people, wildlife, fisheries and the recreation and tourism industry" and associated environmental economic benefits analysis, clearly cannot be appropriately accomplished in one short-term regional study. If the type of study recommended is to be undertaken and used as a basis for setting environmental standards, there is a need for a much larger national involvement and associated funding support.

3. Michigan Utilities Should Continue to Support Projects on Evaluating Renewable Energy Sources

"Michigan utilities should continue to support Projects on evaluating renewable energy sources, including wind and solar energy. The results of all applicable studies should be shared with the MPSC and the MDEQ and if determined to be economically and technically feasible additional reliance on renewables should be implemented."

Consumers' Response

As discussed in Section III, A.1 of this report, approximately 6 percent of the energy generated to serve Consumers Energy's customer load in 1997 was generated from hydroelectric power, wood fuel, landfill gas and mass burn incinerators. Additionally, Section III, A.5 provides a further breakdown of renewable electric energy sources and highlights the use of an estimated 4,800 tons of sawdust as a supplemental fuel at the Campbell Plant. We continually review our generating facilities, plant capacities, use of fuels and future needs as part of our business planning functions. Consumers will continue to support the evaluation and use of renewable energy sources that are reasonable, cost effective, and determined by customer choice.

4. Utilities Requested to Factor in Costs and Benefits in Future Environmental Impact Statements

"The M2P2 Task Force calls upon electric utilities to factor in the costs and benefits of mercury emissions control into all Environmental Impact Statements (EIS) required under federal and state law."

Consumers' Response

The Company agrees that future Environmental Impact Statements (EIS) required under federal and state law for construction of coal-fired electric generation plants should include an analysis of the costs and benefits of mercury emission control.

5. Michigan Utilities Requested to Develop a Plan to Further Reduce Mercury Usage or Emissions and Report Progress in Achieving Mercury Reduction

"The M2P2 Task Force calls upon Michigan utilities to develop a plan with timetables and goals that are measurable, in quantitative or other terms, as well as means to achieve the goals, to further reduce mercury usage or emissions from the generation of electricity and/or other sources. This plan should be submitted to the MDEQ and the MPSC and progress in achieving mercury reductions should be reported on an annual basis."

Utilities have the flexibility to reduce mercury usage and emissions through any of a number of options. Individual utilities or utilities acting in concert will report annually to MDEQ and the MPSC on activities which result in the reduction of mercury usage and/or emissions at the state, regional, national, or global scales. These types of activities may include, but are not limited to:

• Investigating opportunities for fuel switching
• Investigating opportunities for increasing the use of washed coal or coal with a lower mercury content
• Increasing the use of renewable energy sources
• Purchasing policies aimed at low to zero mercury content products
• Participation in the USEPA's National Mercury Task Force process
• Participation in a comprehensive education/outreach campaign on mercury reduction, with an emphasis on energy conservation
• Advocating and/or participating in utility industry research activities related to mercury impacts on the ecosystem, improvement of emissions inventory techniques, or emission reduction technology
• Advocating and/or participating in energy conservation programs aimed at developing economies, world-wide, which benefit reductions in a variety of pollutants, including mercury
• Demand side management
• Participation in USEPA's Green Lights Program
• Evaluate available control technologies

Selection and implementation of any voluntary measures would be based on utility's flexibility in determining the most cost-effective mix of prevention initiatives that result in a reduction of mercury usage and emissions."

Consumers' Response

a. Electric Power Generation

As initially discussed in Section III, A.1. through A.6. of this report, Consumers has taken numerous steps in the recent past regarding fuel switching, coal washing, use of lower mercury content coal, supplemental fuels, use of available renewable energy sources and research and energy conservation. Combined with ongoing efforts and the various electric generation energy sources and fuel mix now used, these actions have had a significant effect in reducing the emissions of mercury while continuing to meet customer electrical demand. Consumers Energy continues to support efforts to implement programs which cost effectively provide environmental benefits.

b. Non-Coal Combustion - Other Potential Mercury Pollution Sources

(1) Company Actions

In late January 1996 Consumers began a Mercury Pollution Prevention (P-2) Initiative designed to: 1) identify on a Company-wide basis non-coal combustion mercury sources and identify where and in what quantities mercury and mercury-containing equipment is used; 2) determine how the equipment is disposed after it is no longer useful and; 3) determine if there are more appropriate pollution prevention management options that should be recommended for use by line organizations.

The first step in the initiative was a preliminary facility specific inventory of all Company locations. This was provided for internal review and verification on April 26, 1996. The inventory identified mercury sources and quantities of each source or type of equipment used or in stock. Estimates were then made of the weight (in pounds) of mercury in each source and the total quantity of mercury in all types of sources. Based on the review and verification comments received on the preliminary inventory, significant revisions were made in the estimated quantity of mercury used in older gas regulators and in quantities of mercury used in electric substation equipment. The inventory was updated in June 1996 and finalized in December 1996. A chart depicting 1996 quantities and sources of mercury and mercury containing equipment is included in the Attachments section of this document as a baseline for our Mercury P-2 initiative.

(2) Mercury Management Options

Consumers Energy has offered to partner with the Environmental Assistance Division of the MDEQ to provide assistance to business and industry in their efforts in identifying and reducing mercury and mercury containing equipment.

Stock Mercury and Mercury-Containing Equipment

Disposition of Excess Inventory

Company efforts through the Mercury P-2 initiative have reduced stock mercury by 351 pounds or 76.7% since the beginning of the program.

The Mercury Inventory included substantial amounts of both elemental mercury stock and spare equipment stored at many Company facilities. Although some mercury and mercury containing equipment will likely always be required for replacement and general maintenance, much of the elemental mercury and some of the spare equipment in stock has been consolidated and made available for reuse, resale or disposal.

Consolidation of Required Inventory

A recommended business practice that the Company's individual Electric, Gas and Operating Services Strategic Business Units (SBU's) have implemented is the establishment of centralized locations for singular storage of nominally required stock mercury and mercury containing equipment deemed necessary for equipment maintenance and emergency replacement. Consolidation is now practiced at strategically located service centers and gas transmission and storage facilities.

Mercury Equipment in Use

Gas Regulator Retirement

The Company's Gas SBU's have reestablished a program for the systematic reduction of older style mercury containing gas regulators from customers' homes and businesses. This program will proceed as operating budgets allow. According to the initial, 1996 Inventory Report, the small amount of mercury contained in an estimated 2,000 regulators represented the Company's single largest source of equipment related mercury. It was also estimated that these 2,000 regulators involved 0.15% of Consumers Energy Gas customers. Historically, we have experienced a small number of releases from regulators in customers' homes resulting in costly remediations. There have been releases documented by other utilities that caused extreme problems resulting in the demolition of residences and relocation of customers. Potential customer exposures in rare events of mercury releases are extremely difficult to quantify and can pose considerable costs.

The reinstituted replacement program for older mercury containing gas regulators involves several key elements:

• Identification of the most probable locations of the mercury containing regulators.
• Continued training of field crews and meter readers to recognize the older style regulators.
• Incentives to identify and replace mercury containing units with mercury free units.
• Reinforcement of training of field crews in the safe removal, handling and transport of these regulators.
• Consolidation and controlled locations for temporary storage of removed units.
• Available disposition support for the safe and correct recycling of the units and associated mercury.

With the concerted effort described above and relatively few regulators being discovered, we will reevaluate our 1996 estimate of Mercury Regulators in customer homes. It is probable that our original estimate of 2,000 units was conservatively high. A proposed goal for 1999 will be to more accurately assess the number of Mercury Regulators remaining with the intent of reestablishing our baseline and current progress.

Mercury Operated Flame Sensor Switches

During 1998 all of these types of flame sensor switches were removed from stock and sold. Replacement of switches in customer furnaces and other appliances currently utilize a non-mercury oil filled flame sensor switch.

Replacement of Company Equipment Containing Mercury

Consumers plans to continue mercury equipment replacement programs for the systematic collection of failed switches, relays, timers, thermostats, and other similar equipment. The Company currently utilizes a replacement collection program at the Metering Technology Center for mercury wetted switches and relays in both gas and electric meters.

We are developing additional criteria for the replacement of other types of failed mercury containing equipment. Individual SBU facility management have conducted evaluations of each type of mercury containing equipment still in use and where practicable, have developed procedures for the cost-effective replacement of this equipment as budgets and replacement equipment become available. This process includes evaluations of:

• Cost comparison of existing mercury containing equipment and non-mercury replacement equipment.
• Labor cost for safe removal of the equipment and replacement with new non-mercury options.
• Cost for the safe collection, transport, and dispositioning of the removed equipment and associated mercury.

Education Initiatives

Informational communications to field employees stressing the importance of safe mercury management and the need to minimize the potential for exposure and release are part of the Company's ongoing training program. This information highlights the many positive steps taken to appropriately manage mercury in use in Company operations.

Purchasing Criteria Modifications

Criteria for the procurement of cost effective and environmentally safe non-mercury containing replacement equipment has been evaluated with the Company's Purchasing Department. Equipment procurement policies have been developed to minimize mercury use as new purchases are required. Mercury containing equipment is not selected as part of the competitive bid process for Electric Systems operations.

(3) Selecting Appropriate Mercury Pollution Prevention Options and Implementation Schedules

Each Company responsibility area has an important role to play in developing additional mercury pollution prevention initiatives. We are continuing to concentrate on mercury management options for the largest areas of potential mercury pollution associated with Company operations.

Timetables for implementing any new management selected options are dependent on the particular mercury source and management options selected. The ease of implementation, environmental sensitivity, location of the mercury and mercury containing equipment, and the cost effectiveness of replacement are key consideration factors for scheduling phaseout or more timely equipment removal and replacement.

(4) Additional Considerations

Mercury Disposal Regulations

The Federal Universal Waste Rule now allows mercury containing waste batteries and thermostats to be managed outside of the Resource Conservation and Recovery Act (RCRA) hazardous waste management requirements. Under the USEPA Universal Waste Regulations, petitions to expand the types of materials to be included as universal waste are encouraged. There are petitions submitted to the USEPA by the Utility Solid Waste Activities Group (USWAG) to expand the Universal Waste Rule to include other mercury-containing materials such as fluorescent tubes, lighting, relays, timers, switches, and other equipment. The potential cost savings and relative ease under a revised Universal Waste Rule should be considered in establishment of timetables for equipment replacement. Michigan's Hazardous Waste Management Rules have included the Federal Universal Waste Rule in the revised State rules which were approved in mid-October 1996. The Michigan Rules also included fluorescent tubes and other types of mercury containing equipment as a universal waste. We remain hopeful that USEPA will expand the applicability of the Universal Waste Rule to allow for management of small quantities of mercury in equipment.

(5) Progress in Achieving Non-Coal Combustion Mercury Reductions

Inventory Reductions

The Company's Mercury Pollution Prevention (HgP2) Initiative has provided significant progress during the first 2 years of implementation by causing a heightened Company wide awareness of mercury uses and of uses of mercury containing equipment. Additionally, all levels of Company employees are more keenly aware of mercury containing equipment, its uses and locations. Nearly every internal organization has inventoried, accumulated and reevaluated their stock mercury and mercury containing equipment. Some have decided to reduce inventories while others have consolidated storage for future management consideration.

The following table represents a cumulative summary of elemental mercury reductions through 1998.

Stock Mercury Reductions:

In Summary

Since the introduction of the Company's Mercury Pollution Prevention Initiative in early 1996 there has been a total reduction in non-coal combustion mercury in use or in storage throughout the Company of an estimated 587 pounds (about 20% of the original 2,933 pounds estimated in the Company's 1996 inventory). We anticipate a similar rate of reduction over the next few years although the rate of mercury use and storage reduction will likely decrease in subsequent years due to cost effectiveness factors associated with mercury replacement options. A graphic comparison of the initial 1996 inventory and current (1998 year end) inventories is included in the Attachments section of this document.

Ongoing Management Options

Batteries: The Company's Purchasing and Materials Management Department developed a purchasing strategy in 1992 to procure only "low mercury" batteries from suppliers. These reduced mercury content batteries are safer for the environment and more cost effectively managed for recycling. In addition, the Company has developed and implemented a program to recycle collected batteries since 1992. Consumers Energy facilities recycled over 25,000 pounds of batteries in 1998.

Electric Lamps: As part of the Company's Waste Minimization program and in support of the HgP2 Initiative, Consumers Energy has developed and implemented a Lighting Waste recycling program since 1994. Many Company facilities collect their lighting waste for off site recycling under this program. The Universal Waste Rule has also resulted in enhancement of this recycling program. Consumers Energy facilities recycled over 47,000 lamps in 1998.

Early in 1998, the Company's Purchasing Department modified procurement contracts with lighting suppliers to supply low mercury florescent lamps. These lamps which test below the EPA's Toxicity Characteristics Leachate Procedure (TCLP) for mercury are now a standard stock item and available to all Company facilities.

Gas Operations: As previously discussed, the Company's Gas Distribution Operations organization reinstated and enhanced a strategy to identify and systematically remove mercury containing gas regulators from customers' homes in 1996. Through the end of 1998, this activity has resulted in the removal of an estimated 181 regulators that contain a total of approximately 110 pounds of mercury.

Through the Company's House Call Program any mercury containing thermostats that are removed from customer homes are replaced with an electronic (non-mercury) thermostat.

Electric Transmission: The Electric Transmission group developed and issued the "Electric Transmission Mercury Pollution Prevention Plan" in August 1996. The Plan contained information about the location and sources of mercury devices, current management practices, equipment procurement modifications and additional initiatives. Electric Transmission has utilized services from the Environmental and Laboratory Services (E&LS) Laboratory group in the systematic removal of mercury containing equipment such as Adlake timers and auxiliary relays. These devices are being removed by lab personnel during routine maintenance and replaced with mercury-free devices that provide the same function.

General Metering: For a number of years the General Metering Department has removed mercury-containing relays, timers, and switches from customer meters as they are processed for inspection, service, and maintenance for restoring and recycling, rather than disposal. This activity resulted in collection of approximately 200 pounds of mercury containing equipment removed from service during 1996. The Metering Technology Center (MTC) has had this removal process in place for the past several years and has removed over 1,720 pounds of small mercury containing devices from the Company's systems during the course of the program. These devices are shipped for off site recycling. The MTC provides service to both the Electric and Gas SBU.

Environmental and Laboratory Services: The Instrument Calibration and Chemistry sections have accumulated, centralized, and inventoried stock mercury for evaluation of possible reduction. There is considerable expertise that has already been shared with other SBU's in the applicability and availability of mercury free electronic equipment that can serve as a reliable substitute for older style mercury containing devices. The Instrument Calibration and Repair groups continue to be key participants in the Company's HgP2 Initiative by providing their experience and expertise in the identification and replacement of mercury devices. As an example, it is estimated that about 50 units including Adlake timers and carrier relays have been replaced in serviced equipment since the HgP2 initiative began.

Fossil and Hydro Operations: In addition to the significant inventory reduction at the Karn/Weadock Complex, the Campbell Plant staff have initiated an evaluation of mercury-containing manometers for replacement with electronic mercury free devices of similar function. Support for this feasibility study has been provided by the Instrument Calibration section of the Company's Environmental and Laboratory Services Department.

Universal Wastes: As part of the Company's HgP2 Initiative, an effort to influence adoption of the Federal Universal Waste Rule and to influence expansion of the rule to include electric lamps, batteries, and mercury containing devices (in addition to thermostats) was considered a strategic part of the Initiative. Consumers' inventory list was provided to USWAG in order to show an example of a "typical" electric and gas utility and the types of mercury containing equipment being used. USWAG's petition to the USEPA to expand the Universal Waste Rule contained the Company's 1996 inventory. The concepts included in proposed federal rule revisions were developed to make inventory evaluations and voluntary removal and replacement of this type of equipment more manageable for utilities.

The State of Michigan's adoption of the Universal Waste Rule in Act 451, part 111 has also resulted in the inclusion of mercury-containing equipment, electric lamps and batteries as Universal Waste. Consumers is managing lamps, batteries, and mercury containing devices as Universal Waste where practical. Under the 1996 regulatory changes the Company has continued programs to centralize the collection and storage of these materials for off site recycling.

Mercury P-2 Initiative Education and Outreach

• January 1998, provided presentation on Consumers Energy Mercury P-2 Initiative Status to Michigan Mercury P-2 Task Force in Lansing, MI.
• November 1998, provided presentation on Consumers Energy Mercury

P-2 Initiative to attendees of Binational Toxics Strategy meeting in Chicago, IL.

• November 1998, responded to USEPA Region 5 request to use Consumers Energy Mercury P-2 Initiative information as example of utility Mercury P-2 activity and accomplishments. Provided permission to utilize graphs, charts and inventory.

 

 

TABLE 1:  CONSUMERS ENERGY'S PLAN FOR MERCURY MANAGEMENT
 

	1996    1997    1998    1999   2000
A. Current Efforts Impacting Mercury Pollution Prevention   1. Use of Electric Generation Energy and Fuel Mix   2. Use of Low Mercury Content Coal   3. Use of Nuclear Energy   4. Use of Natural Gas   5. Use of Renewable Electric Energy Sources   6. Use of Energy Conservation and Energy Efficiency Programs	Continued Use-----------------------> Continued Use-----------------------> Continued Use-----------------------> Continued Use-----------------------> Continued Assessment -------------> Continued Assessment ------------->
B. Future Efforts Impacting Mercury Pollution Prevention   1. Cooperation with MPSC and MDEQ to Support Additional Research   2. Support Projects Evaluating Renewable Electric Energy Sources   3. Factor Mercury Emission Costs/Benefit Analysis into Future Include Cost/Benefit Analysis in Future Environmental Impact Statement Electrical Power Plant EIS Documents ---------------------------> 4. Non-Coal Combustion - Other Potential Mercury Pollution Formal HgP2 Continuation of HgP2 Initiatives -------------> Sources Initiative Startup 5. Develop a Plan to Further Reduce Mercury Usage or Emissions Develop & Plan Continued Plan Implementation to Further Reduce Mercury Usage --------------> 6. Submit Plan to MDEQ with Report of Mercury Reduction	Continue to Support Additional Research Effort -------------------->

 

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