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Federal Assessment Favors Mirant

Mirant "Wind Tunnel Study" faulted by Alexandria T&ES.

William H. Vanderbilt, one of America's 19th century robber barons, is apparently alive and well within the federal government he so disdained. On Oct. 2, 1882, in reply to a reporter's question about his lack of concern for the public interest, he said, "The public be damned."

That now appears to be the accepted approach of the U.S. Department of Energy (DOE) and the U.S. Environmental Protection Agency when it comes to their responsibilities in properly monitoring the operations of Mirant's Potomac River Generating Station (PRGS), according to the city's legal counsel and citizen activists. This is the conclusions they drew from DOE's recently released Special Environmental Assessment (SEA) report of the North Old Town, coal fired, aging power plant.

"Alexandria is deeply disappointed and troubled by the SEA. It has been close to a year since DOE issued the Administrative Compliance Order (ACO) and in that time the DOE has produced a document that amounts to little more than an academic exercise undertaken to ratify the actions taken by and intended to be taken by DOE," said John H. Britton, Alexandria's outside legal counsel on the Mirant situation, in a letter dated Jan. 8, to Anthony J. Como, Office of Electricity Delivery and Energy Reliability, DOE.

"Alexandria residents have faced a year of operation of the PRGS under the Order, pursuant to which the PRGS has emitted pollutants at concentrations that exceed health based standards and that are known to be harmful to Alexandria residents," Britton said in speaking for the City's residents and government.

"The SEA fails to recommend even one concrete measure to mitigate this impact. The SEA ensures that the burden of DOE's stated ‘emergency’ will continue to fall entirely on Alexandria residents," Britton stated.

ALEXANDRIA GOVERNMENT'S reaction to this report was buttressed and mirrored by another letter to Como from Elizabeth C. Chimento, one of two citizen founders, along with Poul Hertel, of the effort to close the Mirant power plant. She took DOE's apparent "public be damned" approach a step further in her letter of Jan. 8, by accusing them of watering down any harmful effects on Alexandrians.

"My first objection to the SEA is DOE's extending the radius of the PM 2.5 and SO2 receptor grid to 36 miles, thereby also extending the health effects to 240,581 people within the larger geographic area. By doing so, the 4,000 people living very close to the plant and impacted by the highest PM 2.5 pollutants are not the focus, yet they are the most seriously affected," Chimento stated.

"These microscopic particles are the most dangerous to public health since they are breathed directly into the lungs. By neglecting to include the larger health effect categories, the SEA commentary minimizes the intensity of health effects caused by PM 2.5," she said.

"The DOE should have addressed those living closest to the plant and most affected to demonstrate a true scientific evaluation of the environmental impacts of the facility. Instead, by extending the receptor grid radius, the analysis smoothes out the high impacts of all criteria pollutant excesses affecting those immediately surrounding the plant," Chimento emphasized.

What is even more disturbing is that in Dec. 2006, from the first to the 20th, a planned Pepco line outage occurred. When these take place, the Mirant plant goes into full operational mode as a backup for "reliable electricity." However, the City is to be notified when that is about to occur.

As noted by Chimento, "Neither the City of Alexandria, nor the residents near the plant, were notified of the event, even though their public health was put at risk." None of the controlling agencies notified City officials of the potential health risks. "This failure of all these agencies can only be interpreted as negligence," she wrote.

BRITTON CITED the fact that SEA imposes the burden of determining an "emergency" on Alexandria residents as "perhaps the greatest failure of the SEA." He explains that "while it [SEA] acknowledges the operations at PRGS under the Order have resulted and will continue to result in emissions that exceed the NAAQS for SO2 and particulate matter, and that such emissions cause illness and increase incidence of premature death, the SEA fails to fulfill its core mission of identifying potential mitigation measures."

The SEA should have, but did not, identify specific emergency and non-emergency load reduction programs in the District of Columbia to compensate for electricity generation or transmission reduction at PRGS, according to Britton. "Most critically, the SEA fails to offer any mitigation measures that will protect Alexandria residents from known health hazards that continuation of the Order will cause," he stated.

In conclusion, he told Como, "Once the additional transmission lines [by Pepco] are installed for the supply of electricity for the District of Columbia, there is absolutely no need for the PRGS to operate for reliability reasons. At the very least, the DOE should then terminate the Order and declare that the PRGS should only operate if in strict compliance with all air quality standards."

In questioning the very rationale for the study, Britton expressed the feeling that, "This is not a true environmental review. It is more a rationalization for decisions already made and will continue to be made. This will only allow Alexandria residents to continue to suffer."

Britton emphasized that the "main point of the SEA should be that the emergency order which permits the Mirant plant to operate as a backup for reliable power should be totally rescinded in June when Pepco has completed its new transmission lines. "Mirant should be left to fend for itself," he said. Pepco itself has stated that once those lines are complete it did not need the Mirant plant for electricity reliability.

IN A RELATED MATTER, Richard J. Baier, director, Alexandria Transportation & Environmental Services, sent a letter to Donald S. Welsh, regional administrator, EPA Region 3, and David K. Paylor, director, Virginia Department of Environmental Quality, questioning the reliability of Mirant's "Wind Tunnel Study" to determine flow of airborne particulates from the plant.

"Since the use of these dimensions will lead to higher output rates from PRGS and the EPA's Administrative Compliance Order by Consent, you should withhold approval of the Wind Tunnel Study ... pending a full review and resolution of the issues," Baier stated.

He also noted, "Even without fully accounting for all the possible worst-case conditions, the Wind Tunnel Study demonstrates that PRGS's current operational scenarios pose significant risk to the health of nearby residents."

In that Jan. 5 letter, Baier cited a dozen areas of concern with the Mirant study including:

* Mischaracterization with real-world wind flow;

* No simulation of "range of loads" and "worse-case operational scenarios;"

* Failure to identify roof-top receptors on nearby buildings;

* Surface roughness inconsistent with actual conditions for both water and land; and

* Failure to identify wind direction for each stack.

His greatest criticism was directed at the "failure of the ACO to adequately protect public health against NAAQS violations." Baier also requested that both the federal and state agencies reject the Mirant Wind Tunnel Study results and that a new study be conducted.