Virginia Department of Environmental Quality's news release of Oct. 19 giving its blessing to the operation of Mirant's Potomac River Generating Station's Unit 1 brought forth a detailed letter of concern from Alexandria City officials.
Addressed to Robert Burnley, DEQ director, the five-page, letter criticized Mirant's actions, both in restarting and operating Unit 1 and their use of trona, a mineral injected into the boiler to reduce sulfur dioxide emissions. If Mirant uses this procedure, the city's letter suggests that DEQ needs to have a detailed monitoring plan in place.
"Underlying our concerns is a general uneasiness surrounding Mirant's actions in which it moves forward unilaterally with operational changes at PRGS (Potomac River Generating Station) before any of the assumptions and procedures have been verified and approved by your agency," said Richard Baier, director, Alexandria Transportation and Environment Services Department, in the Oct. 24 letter to Burnley.
"Although the use of this material by Mirant may reduce emissions of sulfur dioxide it could also increase particulate emissions. We believe that the protocols presently in place to monitor this situation are inadequate," said William Skrabak, division chief, Environmental Quality, T&ES.
Baier's letter also raised concerns with Mirant's baseline modeling and its one boiler operation. "Mirant not only continues to rely on these unresolved baseline data to show compliance for the Unit 1 operational scenario, it adds additional uncertainties to that scenario's ability to protect ambient air quality standards ...," Baier said.
He noted that Mirant had failed to provide the city and DEQ with requested information pertaining to an "operational scenario" for Unit 1 and that DEQ had not responded to "issues raised by the city" in a previous letter dated Sept. 28. Both these facts put into question DEQ's news release of Oct. 19, according to Baier.
"WITHOUT HAVING the benefit of requested information to simulate results, given the already precarious compliance situation, the city is extremely concerned about the level of review being afforded and adequacy of margins of safety provided in the analysis" by DEQ before they pronounced Mirant's Unit 1 operation safe as stated in the Oct. 19 press release, Baier stated.
In that release, "DEQ has found no indication that Mirant's current plan of limited operation of one boiler unit violates federal health-based air quality standards. DEQ's evaluation is ongoing, and additional information will be requested from Mirant as needed."
It also acknowledged, "DEQ is analyzing a proposal by Mirant to use new technology to reduce emissions of sulfur dioxide. The proposal calls for injecting a mineral called trona into the gas exhaust of one boiler to help neutralize sulfur dioxide."
William Hayden, DEQ spokesperson, said, "Based on what we have seen, no air quality violations have occurred and they can operate Unit 1. Also they have given us a proposal to operate by using a new procedure to further reduce emissions of sulfur dioxide. If that does work and further reduces air pollution they will be able to operate."
Steve Arabia, director, External Affairs, Mirant Mid-Atlantic, fully expected DEQ's reaction to the restart of Unit 1. "When we restarted Unit 1 everything was in compliance with national air quality standards. And, we are doing everything we can to get the plant operational while meeting those standards," he said.
"In Mirant we are all about one thing — starting the plant while ensuring environmental quality. All our hard work is aimed at that goal," Arabia said.
Baier also pointed out to Burnley, "The city has learned that Mirant tested lime injection on Unit 4 in April 2005 without any notice to VADEQ of its intent or outlining of procedures to do so ... The city requests here a complete report of the lime injection testing ...." He also requested that DEQ "ask for a explicit disclosure by Mirant of its plans for testing lower sulfur coal."
Mirant's testing plan "falls far short of a detailed test protocol" recommended by the U.S. Environmental Protection Agency, according to Baier's letter. Therefore, the city requested those protocols "be revised" to cover six additional items that include exact test dates, identification of the independent testing organization to be used, plus several tests aimed at specific emissions.
"Trona injection at PRGS constitutes both a physical change and change in the method of operation at PRGS ... The city therefore requests that Mirant use the results of this test to prepare a full regulatory applicability assessment for submittal to VADEQ," Baier wrote.
Noting that, "Mirant has persistently refused to address its impacts ... on the community," Baier requested that DEQ, "Before considering any approvals for further changes to the operations at the Mirant plant ... act now to resolve" the differences in the baseline scenario assumptions and "allow the city to analyze the Unit 1 operational scenario's compliance status itself by requesting that Mirant respond" to the city's Sept. 30 letter requesting additional data.
Finally, Baier asked that all matters referred in the letter be "fully addressed by VADEQ and Mirant before proceeding with any approvals for trona testing or changes in operations."
THIS REACTION by Alexandria government to Mirant's latest proposals and DEQ's after-the-fact acquiescence to the restart of Unit 1 was buttressed by the latest study completed by Sullivan Environmental Consulting, Inc., acting at the request of Elizabeth Chimento and Poul Hertel. It was their original efforts and subsequent "downwash" investigations that triggered the city/Mirant challenge.
The assumptions made by ENSR, Inc., the consultant hired by Mirant to conduct a modeling analysis of the downwash from the plant's emissions, was not sufficient "to justify the conclusions that were drawn," according to Sullivan.
He also stated, "The assumptions made to justify operation at approximately 20 percent capacity, show the plant to be just barely in compliance" with ambient air quality standards. This being the case, Sullivan said, "It would appear to be very unlikely that further increases in percent capacity could be justified" without changes in stack height, operating controls for a wide range of pollutants, and the institution of "long-term air quality monitoring."
Based on these findings, Chimento and Hertel issued a joint statement challenging the continued operation of Unit 1 and the experimental use of trona by Mirant. "We still await proof that the current operation is not jeopardizing our (the city's) health," they said.
"It is untenable that the North Old Town Community has been exposed to downwash pollutants greatly exceeding EPA standards over the course of many years. Now, with the plant's Unit 1 operation, we have once again had to ... determine if our health is being impacted by emissions from that generation. The Sullivan analysis finds that the plant fails to prove that our health is being safeguarded ...."