After years of studies, law suits, action by Alexandria Planning Commission and City Council, Mirant's Potomac River Generating Plant may at last face extinction or significant upgrading. That's the essence of an edict presented to Mirant last Friday by the Virginia Department of Environmental Quality.
"Because of the serious violations of the human health-based NAAQS (National Ambient Air Quality Standards) ... I am writing on behalf of the board to request that Mirant immediately undertake such action as is necessary to ensure protection of human health and the environment, in the area surrounding the Potomac River Generating Station, including the potential reduction of levels of operation, or potential shut down of the facility," said Robert G. Burnley, director, DEQ, in a letter to Lisa D. Johnson, president, Mirant Potomac River, LLC.
Burnley gave Mirant until 2 p.m. Aug. 24 (presstime for the Gazette) to provide "A summary of the actions being taken and their progress toward eliminating NAAQS violations."
In response Mirant stated, "If no acceptable short-term solutions can be found, Mirant will shut down all five units at the power plant no later than midnight Wednesday, Aug. 24, until a solution can be identified and implemented."
Shutting down operations was a self-imposed solution by Mirant. DEQ, in all its correspondence and contact with Mirant, did not require that action at this time, according to William Hayden, DEQ spokesman, and Amy Owens, DEQ Director of Enforcement.
"DEQ's letter is not saying shut down. We want to hear what Mirant is going to do to correct the situation. This is standard procedure for DEQ when serious violations occur," Owens said.
"What happens next depends on what their proposal says and how we react to that. This is a very data intense undertaking and future actions are impossible to predict at this point. After years of experience in this role I have found that speculation is not useful," she said.
"We expect that whatever steps Mirant proposes it will bring about significant improvement in the air quality," Hayden said.
AS OF LAST SUNDAY night Mirant had reduced output at the plant from 500 mega watts to 175 mega watts, a 65 percent reduction, according to Owens.
Mirant's immediate response was to issue a press release in which it stated, "Mirant does not expect to return the plant to full service until appropriate solutions are implemented. However, Mirant may be required to operate the plant to meet mandatory system stability obligations, or if there is a legal obligation to operate the plant at higher output levels than would otherwise be in effect."
As noted in its release, "The plant has been designated by PJM Interconnection, the entity responsible for the reliability of the transmission system from the Mid-Atlantic states as far west as Chicago, as a facility critical to electric system reliability in the Washington, D.C. area."
Removing this plant from the system "could result in a strain on the transmission system and potential electrical outages if other key generation and transmission facilities become unavailable during high demand periods," according to the release.
In discussing the potential shutdown and reduction of output, Steve Arabia, Mirant media contact person, said, "We have taken these actions out of an abundance of caution pertaining to the health concerns raised. This is a Mirant initiative."
ALL OF THIS RESULTED from DEQ's receipt of the results of Mirant's "downwash" modeling study to determine the level of pollutants emanating from the plant and impacting nearby high rise buildings. It was provided to the department pursuant to the consent special order between the State Air Pollution Control Board and Mirant.
The study was conducted as a requirement of a consent order signed in 2004 relating to alleged air quality violations at the plant. Mirant agreed to conduct the study to determine whether key pollutants exceeded health-based standards, and to reduce pollution if violations were found.
Mirant's computer modeling analysis shows that under certain conditions "pollution from sulfur dioxide, nitrogen dioxide and particles in the vicinity of the plant are higher than the national ambient air quality standards allow." This was based on data collected from 2000 to 2004.
Within this same time span a private study pertaining to the "downwash" situation on high rise buildings, particularly Marina Towers, near the north Old Town plant was undertaken by Sullivan Environmental and financed by Poul Hertel and Elizabeth Chimento.
"We did a screening level analysis for them in March 2004 which found that people living in Marina Towers were exposed to higher levels of pollutants. And we are going to review the modeling that was recently done as well as conduct further studies," said Dave Sullivan of Sullivan Environmental.
Hertel sees DEQ's action as a boon to the case now before the federal court in Alexandria and a vindication of all the efforts he and Chimento have put into their efforts to correct the downwash situation. "This action seriously helps the city in that action," he said
Arabia takes a different point of view. "We saw the results (of the report) and we acted quickly because of public health concerns. We believe our actions strike the right balance," he said.
"We are prepared to do what has to be done. We are working with all the stakeholders and we are confident that there is a long-term solution. I am confident everyone will work toward a common goal," Arabia said.
"However, it is important to understand the nature of the study. The computer model was designed to analyze local air quality levels using a "worst case" set of assumptions, including the operation of all five units at maximum permitted output with maximum emissions, combined with unfavorable wind conditions," said Curt Morgan, executive vice president and COO, Mirant.
Under this "worst case" scenario, the study concluded that the plant could be emitting eight times the allowable level of sulfur dioxide, approximately twice the levels of allowable particulate matter, and twice the allowable level of nitrogen dioxide. It also looked at mercury pollutant.
The report states, "The analysis incorporated several conservative assumptions to ensure that the absolute maximum pollutant concentrations are predicted." Primary among these was the assumption "That all combustion sources at the plant are operating at maximum load for the entire year." In fact, the plant operates at approximately "60 percent capacity in a typical year," according to Mirant.
"These combined circumstances do not typically occur all at once, so the model works with hypothetical conditions. Nevertheless, we do take these findings extremely seriously," Morgan said.
IN HER COVER LETTER transmitting the study to Michael G. Dowd, DEQ Air Enforcement manager, Johnson stated, "The modeling showed that carbon monoxide concentrations comply with the NAAQS, and mercury concentrations comply with the applicable state standards."
In the new release she stated, "The decision to curtail and possibly halt power production involves many complex issues, including important electric system reliability in the Nation's
Capital and throughout the Mid-Atlantic Region. However, the overriding factor in our decision has been and will continue to be, protection of public health."
Mirant is "looking at all the options," according to Arabia. "And, that includes raising the stacks," he said. When the plant was built in 1949 the height of the stacks was limited by the Federal Aviation Administration due to air traffic in and out of what was then Washington National Airport.
Flights are now limited in their approach and take off to following the river well before and after the plant site. This may allow an increase in the height of the stacks which would carry some of the particles above nearby high rise buildings.
Regardless of the height of the stacks, Mirant's modeling study also notes, "Marina Towers ... was constructed without considering the effects of pre-existing emissions from the power plant and the building of this structure adjacent to the existing power plant increased the downwash effect."
Mirant takes credit for placing receptors at all levels of Marina Towers "to ensure that maximum air pollutant impacts are identified." The last sentence of the report's introduction states, "Ground-level air pollutant concentrations are predicted to be considerably lower than impacts on the tower."
However, on page 5-1 under PM 10 results, they state, "Most of the highest predicted impacts ... are predicted on the flagpole receptors at the top of Marina Towers. Two of the highest impacts are predicted at the fenceline along the southern plant boundary."
This area is in the immediate area of the Canal Plaza complex.
The chorus urging closure increased Tuesday afternoon with Chimento and Hertel making their feeling known to DEQ. "I have called Burnley and told him we want the plant shut down now," Chimento said.
They were joined by U.S. Rep. James P. Moran (D-8) who stated in a release, "This report confirms our longstanding view that the Potomac Plant was operating at dangerously high levels. We now have the scientific proof to shut down this dangerous dinosaur of a plant and will continue to press the issue with the state to either get real, lasting changes in the plant's emissions or have it closed forever."