Staff Update on NRG Potomac River Generating Station Site Remediation and Groundwater Monitoring Work - November 2015
This write-up is to update the community on 1) NRG remediation effort at the former Potomac River Generating Station (PRGS) site under the requirements by the Virginia Department of Environmental Quality (VDEQ); and 2) NRG groundwater monitoring to assess the potential migration of groundwater contamination to the Potomac River under the requirements by the District Department of Energy and Environment (DOEE).
NRG’s PRGS Site Remediation Effort Under VDEQ Directive
The City received from NRG the Third Quarter 2015 CAP Implementation Monitoring Report that NRG submitted to the VDEQ. This report is a requirement stipulated by the VDEQ as part of its approval of the NRG’s Corrective Action Plan (CAP) for the Potomac River Generating Station site remediation.
- The report includes results of continuing site characterization and routine monitoring activities. TPH-DRO (Total Petroleum Hydrocarbon – Diesel Range Organics) was detected in 30 out of the 40 sampled monitoring wells, with a maximum concentration of 14,000 micrograms per liter in well # MW-08S.
- Product Recovery Management, Inc. (PRM) was previously chosen to construct the remediation system. This system was delivered on October 15, 2015 and its installation and permitting activities are still underway and will continue into the fourth quarter of 2015.
- Some progress is being made on NRG‘s application to the National Park Service (NPS) for a permit to install the offsite air sparge well and remediation system piping on the Mt Vernon Trail. NPS is still reviewing this permit application. All City permits related to the remediation system installation have been obtained. AlexRenew provided verbal approval for sanitary sewer discharges from the remediation system pending receipt of trial start-up discharge results.
- NRG consultant is discussing with the Northern Virginia Office of VDEQ the air permit requirements for the pump and treat remediation system. The City encourages NRG to install an activated carbon adsorber unit on the exhaust of the air stripper (part of the pump and treat system) to minimize potential for odors.
- The updated CAP implementation schedule indicates that: 1) the full onsite remediation system activation will be in December 2015, and that 2) the offsite remediation system activation will be in the first quarter of 2016 (pending permit from the National Park Service).
NRG’s Groundwater Monitoring Effort Under DOEE Directive
As a recap, on 5 June 2014, the DOEE issued a Compliance Directive to NRG requesting supplemental activities to evaluate potential releases to the Potomac River from the PRGS site. In a follow-up letter dated May 12, 2015, DOEE requested that NRG 1) prepare a work plan to complete additional shoreline characterization work, and 2) develop a quarterly groundwater sampling and analysis plan. After several revisions, NRG submitted the following revised documents to DOEE on September 24, 2015: 1) Additional Characterization of Shoreline Work Plan, 2) Sampling and Analysis Plan, 3) Quality Assurance Project Plan, and 4) Health and Safety Plan. These documents were approved by DOEE on November 2, 2015 and NRG immediately sent them to the City.
The objective of the Additional Characterization of Shoreline Work Plan is to delineate and evaluate the nature and extent of petroleum impacts in groundwater along the bulkhead at the PRGS site. The data collected will be used to assess potential contamination of the Potomac River by the impacted groundwater. The schedule for this work is contingent on the receipt of the permit by NPS since the work will be carried out on its land.
NRG submitted to DOEE a report titled “Groundwater Monitoring Status Report – Third Quarter 2015 ….” and dated October 30, 2015. This report summarizes the groundwater monitoring work for the last three quarters. The main conclusions for the third quarter 2015 work are as follows.
- No TPH (Total Petroleum Hydrocarbon) constituents were detected above DOEE groundwater and surface water criteria.
- Several PAHs (Polycyclic Aromatic Hydrocarbons) were detected above one or more groundwater or surface water criteria.
- No PCBs (Polychlorinated biphenyls) were detected above method detection limits in any of the samples collected.
Overall, NRG’s PRGS site remediation and groundwater monitoring effort are proceeding as planned, and City staff will continue to monitor new developments and provide updates as new information becomes available.
Virginia DEQ Approves NRG's Proposed Corrective Action Plan for Remediation at the PRGS Site
The Virginia Department of Environmental Quality (VDEQ) has completed its review of NRG’s proposed Corrective Action Plan (CAP) dated December 23, 2014. VDEQ granted approval of this CAP since the proposed remediation strategies were found to comply with VDEQ’s requirements. In its letter to NRG dated March 17, 2015, VDEQ specified the 7 additional requirements and clarifications for its approval, including requirements for NRG to work with the City, National Park Service and the District Department of Environment to ensure that the objectives of the City and these regulatory stakeholders are met satisfactorily.
- Attachment: VDEQ Letter to NRG Dated March 17, 2015
City's Comment Letter on the NRG's Proposed Corrective Action Plan for Remediation at the PRGS Site
Virginia Department of Environmental Quality (VDEQ) to hold public Meeting on NRG's Proposed Corrective Action Plan (CAP) for Remediation at the PRGS Site on February 3, 2015
As required by VDEQ, a public meeting will be held by VDEQ and NRG Energy on Tuesday, February 3 to obtain public comments regarding the NRG Energy's CAP recently submitted to VDEQ. The proposed CAP outlines remediation for two leaking 25,000-gallon heating oil tanks located underground at the PRGS site. Following this meeting, the public can submit comments to VDEQ by February 13, 2015.
Date: February 3, 2015
Time: 7- 9 p.m.
Location: City Hall, Sister Cities Conference Room #1101
For more information, please contact Khoa Tran, T&ES Infrastructure and Environmental Quality, 703.746.4076.
First Meeting of the PRGS (Potomac River Generating Station) Monitoring Group
Following the permanent closure of the GenOn PRGS power plant, City Council adopted a resolution in December 2012 establishing the PRGS Monitoring Group and reappointing the current membership of the recently-expired Mirant Community Monitoring Group (MCMG) as members of the PRGS Monitoring Group for a period of two years or until the substantial completion of the NRG PRGS deactivation/ decommissioning phase, whichever happens first.
The first meeting of this group is to be held on March 5, 2013 at 7:30 pm to 8:30 pm in the City Council Work Room at City Hall. The agenda is attached here.
GenOn and NRG Officially Merged on December 14, 2012
The name of the new company is NRG Energy, Inc.. Information about NRG and the merger can be found on NRG website www.nrgenergy.com.
Going forward, NRG contacts regarding the Potomac River Generating Station are as follows:
- Until April 1, 2013 - Misty Allen, VP Assets Management (email@example.com)
- From April 1, 2013 - Steve Arabia, VP Regional External Affairs (firstname.lastname@example.org)
GenOn and Virginia DEQ (VDEQ) Mutually Determined that PRGS Was Shut Down Permanently as of December 21, 2012
The VDEQ issued a letter to GenOn Energy on December 20, 2012 to confirm that following a PRGS facility inspection by the VDEQ which City staff also participated in, GenOn and the VDEQ mutually determined that the GenOn PRGS power plant has been shut down permanently as of December 21, 2012. Consequently, the following will apply:
1. The air permits issued for the PRGS dated July 31, 2008 and July 29, 2010, are revoked.
2. The revocation of these permits shall not relieve GenOn or its successors of the responsibility to comply with all applicable local, state, and federal statutes or regulations with regard to the PRGS.
3. The PRGS shall cease operations as an electric generating facility. No such future operations shall occur until the owner has obtained a permit pursuant to the Virginia Regulations (9 VAC 5 Chapter 80).
Please click here to see the full details of the letter.
GenOn Presentation on PRGS Phase I Deactivation Plan
Misty Allen, Vice President Asset Management of GenOn Energy - Eastern PJM Region, presented the Phase I Deactivation Plan currently being implemented at the company's Potomac River Generating Station (PRGS) at the Mirant Community Monitoring Group (MCMG) meeting on November 7, 2012. Please click here for an electronic copy of her presentation. For updates on this deactivation plan, please check information on the following GenOn PRGS website: http://www.genon.com/company/stations/potomac/new-and-events.aspx
City Recognizes Closure of GenOn Potomac River Generating Station
- Alexandria's GenOn plant shuts down, finally - Tom Jackman, Washington Post
- Alexandria power plant to close for good Monday - Hank Silverberg, WTOP.com
- Coal-fired power plant in Alexandria is poised to close, pleasing local officials -- Associated Press, Washington Post
- Alexandria power plant closes after decades-old battle -- Taylor Holland, Washington Examiner
- GenOn Plant to Cease Operations on Monday -- Drew Hansen, Del Ray Patch
- Potomac River Generating Station Ceases Operation -- Carla Branch, AlexandriaNews.org
- GenOn Power Plant Could Become Retail Space -- Derrick Ward, NBC4 Washington
- Alexandria power plant closes -- Tom Roussey, ABC7 WJLA
- Elizabeth Chimento of Alexandria, Va., was first to raise questions about plant's emissions -- Peggy Fox, WUSA9
Alexandria Significantly Improves Air Quality and Protects Public Health with Power Plant Closure
Monday, October 1, 2012, marked a significant milestone for the City of Alexandria and its residents with the permanent closure of the GenOn Potomac River Generating Station (PRGS). For several years this facility has been the single largest source of air pollutants in Northern Virginia. Its closure is a culmination of intense and unwavering efforts by the residents and the City Government for more than a decade. From the City's perspective, operation of the PRGS had been a serious public health issue. In response to citizens' concern, the City Council adopted a resolution in 2004 stating the City's policy to clean up PRGS in the short term and close it down permanently in the long term.
The City then participated in the State regulatory process which resulted in the issuance of a comprehensive permit for this plant in 2008 having tight emission limits that conform to all National Ambient Air Quality Standards. The same year, the City and GenOn also reached a Settlement Agreement requiring GenOn to spend $34 million on improved stack gas and fugitive fine particulate matter controls in addition to the $35 million the company spent on its stack merge project aimed at mitigating air quality issues in the plant vicinity. Subsequently and before the City and GenOn committed to installing the improved baghouse technology at this facility, the two parties reached an agreement on August 29, 2011 to permanently close the company's PRGS facility by October 1, 2012, in exchange for the return of about $32 million to the company.
This plant closure is consistent with the Eco-City Alexandria's Environmental Action Plan and benefits both Alexandria residents and those living in the Washington Metropolitan areas. An additional benefit is the drastic reduction in the emissions of greenhouse gas which is believed to be the major contributor to the current climate change issue.
"This plant closure is a testament to the City's commitment to environmental stewardship, public health protection, and the Eco-City Alexandria initiative" said Alexandria´s Mayor William D. Euille.
For a timeline of key milestones in the Alexandria community efforts to close down PRGS, please click here.
On September 27, 2012, GenOn notified the Virginia Department of Environmental Quality (VDEQ) that it will no longer operate any of the coal-fired boilers or generate electricity at the Potomac River Generating Station as of 00:00 on October 1, 2012. GenOn will work with VDEQ in making a mutual determination that PRGS is permanently shut down on or before December 31, 2012. As a result of this determination, all air permits issued to PRGS by VDEQ will be revoked. Click here for a copy of the GenOn letter.
About GenOn Potomac River Generating Station
The purpose of this web page is to provide the interested citizens the most updated information regarding Council's Actions, Staff's Actions, Actions taken by regulatory authorities and other relevant information of interest. The website is divided into several categories as indicated by the various links on the left side. New and updated information will be posted periodically as it becomes available. Announcements of upcoming meetings will also be posted on this website. Please click on the links below or to the left to access the most recent information available.
- City / GenOn (Mirant) Settlement Agreement of July 2008
- Potomac River Generating Station Information Archive
- GenOn Announces Its Intent to Merge with NRG
On July 22, 2012, GenOn announced that it intends to merge with NRG to form an approximately 47,000 megawatt industry leader that will keep the NRG name. Importantly, previously announced GenOn deactivations, including the Potomac River station, will stay on schedule.
- GenOn PRGS Retirement Date Confirmed
On July 3, 2012, GenOn confirmed that the retirement date for the Potomac River Generating Station facility will be October 1, 2012. This date was agreed upon by the City and GenOn as part of the Amendment to Project Schedule and Agreement signed by both parties on August 29, 2011. For more details, click on the following link:
- Virginia DEQ Issued Consent Order to GenOn PRGS
The Virginia DEQ executed a consent order issued to GenOn Potomac River LLC regarding violations of the operating permit that happened at the Potomac River Generating Station (PRGS) located in Alexandria. As a result, GenOn agrees to pay a civil charge of $280,704 within the next 30 days. Violations related to this consent order include the following:
- The CEMS (Continuous Emissions Monitoring System) data submitted by the plant indicated that on six occasions during June-July 2011, the 30-day rolling average NOx emissions were 0.28 lb/MMBtu, compared to the permitted limit of 0.27 lb/MMBtu as stipulated by the Permit Condition 28.
- No water fogging system was installed within the enclosure of the bottom ash silo, which violates the Permit Condition 10. Please note that this is different from the fogging system installed on the fly ash loading areas as part of the Phase I project.
- Grid Operator PJM (Pennsylvania New Jersey Maryland Interconnections) found no reliability issues related to the planned retirement of the Potomac River Generating Station
The City and GenOn signed an Amendment to the Project Schedule and Agreement on August 29, 2011 which stipulates the retirement of the Potomac River Generating Station (PRGS) on October 1, 2012, subject to PJM finding that the facility is no longer needed for reliability as of the date of the retirement. Per this Amendment, GenOn sent a letter to PJM Interconnection, LLC, to request the deactivation (i.e., retirement) of the Potomac River Generating Station on October 1, 2012. Responding to this request, PJM performed a detailed analysis of the PJM Transmission System and did not identify any reliability violations resulting from the requested deactivation of the PRGS facility. Similarly, PEPCO Transmission carried out the same analysis for its lower voltage system and found no reliability violations. The PJM analysis thus concluded that all five generating units of PRGS could actually be deactivated at any time. This clears the path for PRGS facility to be retired by the agreed upon date of October 1, 2012. Click here to see the written response from PJM.
- MCMG Meeting was held on September 29, 2011 to Discuss the City/GenOn Amended Agreement Signed on August 29, 2011.
- Potomac River Generating Station to Close
The City of Alexandria and GenOn Energy reached an agreement to permanently close the company's Potomac River Generating Station, which began operating in 1949. Under the terms of the agreement, GenOn agreed to retire the generating station by October 1, 2012, or, if the plant was needed beyond that date for reliability purposes, as soon as it would be no longer needed. The Mirant Community Monitoring Group met on September 29 to update members of the public on the agreement to permanently close the GenOn Power River Generating Station. For more information on the closure of the generating station, read the news release. Click here to see the signed agreement.
Mirant Community Monitoring Group (MCMG)
MCMG (MCMG) was established by the City Council in 2004 to serve as a central information-receiving and monitoring group for issues involving the Mirant Potomac River Generating Station. The group is composed of eight members: Poul Hertel, Elizabeth Chimento, a representative from North Old Town Independent Citizens Association (NOTICe), a representative from Marina Towers, a representative from the Northeast Citizens Association, a representative from the Environmental Policy Commission, and two members of Council: Del Pepper and Paul Smedberg.
The primary objectives of MCMG are to receive reports and track the progress involving Mirant's ongoing permit and regulatory issues, its compliance with the consent decree and consent order, and to act as a forum to discuss technical issues such as the downwash modeling. Members of the monitoring group provide feedback to City Council and City staff and assist in the dissemination of information to the wider stakeholder community. Such dissemination involves community meetings and/or information sessions hosted by the monitoring group.
PRGS Monitoring Group Members
- City Councilwoman Redella S. Pepper (Co-Chair)
- City Councilman Paul C. Smedberg (Co-Chair)
- Environmental Policy Commission Steve Walz, Citizen Member
- North Old Town Independent Citizens Association (NOTICe) Roger Waud, President of NOTICe,
- North East Citizens Association Steve Troxel, Member
- Marina Towers Mary Harris, Member, Marina Tower Condo Association
- Citizen member Poul Hertel
- Citizen member Elizabeth Chimento