2001 July 8

PRESS RELEASE

for Citizens of Northern Kentucky

Review of Otte Report on Cinergy Power Plant Proposal

While the Otte Report may be irrelevant, it is flawed by incorrectness both at the level of "the forest" and at the level of "the trees". To the extent the Otte Report was publicized as relevant and correct, this Review enables proper use by Citizens of Erlanger who paid for the Report, and by Citizens of Kenton County who may be affected by it. The Report was requested, without support from any member of CHEER, by Attorney Phil Taliaferro in behalf of his client, Dr. Lee Otte, in an impassioned plea before City Council on May 1.

The Author of the Otte Report provides no written statement of credentials. The claim of "independent" in the first sentence of the Report is not consistent with Otte's testimony, after presenting his Report to the Citizens Committee on 2001 06 01, in response to question by Crestview Hills City Administer Kevin Celarek, that he accepted input from an unnamed "expert" who he stated has consulted for Cinergy.

While some references are provided in appendices, generally, critical facts are introduced without citation (footnotes are not used), or are indicated to be from Cinergy, taken from Permit V00-009 issued by the Kentucky Division of Air Quality, based on an Application completed by Cinergy -- found to be disrespectful of factual accuracy. This Permit is under appeal by Northern Kentucky Cities and Citizens.

Comparing 8-hour workplace exposure levels to 24-hour, residential, ambient air quality is not a justifiable comparison and is insensitive to 500 residents and visitors within 500' of the proposed site.

Comparisons between regional emission totals and point-source emissions, without averaging over area, is not a justifiable comparison.

Not consistent with Otte's Report, the Chief Scientist of the Forecast Systems Laboratory of the National Oceanographic and Air Administration, Thomas Schlatter, states local humidity will increase, subject to wind conditions, when 120,000 pounds per hour of water is injected into the local atmosphere by the proposed plant. Schlatter also states atmospheric inversions increase the probability of heightened ground-level air pollution from the proposed plant.

The model used by Otte, SCRN3, is based on software technology more than 20 years old and is considered nearing obsolescence by the administrator of this software at U.S. EPA, Dennis Atkinson, citing availability of newer models, such as AERMOD.

Referencing particular Report statements cited by page:

Page-1: Referring to citizen focus on issues of (1) noise, (2) aesthetics, and (3) air quality, the Otte Report overlooks the most critical issues regarding the proposed plant: (4) siting, and (5) safety. These matters are addressed on our web site at NCAD.net. Specifically, reports entitled "Unacceptable Risk" and "Merger Madness" address primary safety issues. While we may anticipate additional study of siting issues, it is noteworthy that nowhere else in America is so much combustion so close to so many innocent lives.

Page-4: bulleted points indicate the absence of monitoring during the most critical periods of release: start-up and shut-down. These conditions are not addressed elsewhere in the report and are of critical concern with regard to ground-level pollution. The report is based only on continuous operation under cool weather conditions not commonly found in Erlanger summer.

Daily startup occurs at the early morning time, frequently characterized by "nocturnal inversion" (according to Schlatter). Initially, combustion is relatively incomplete, emissions are relatively cool, and velocity is relatively low, conditions increasing ground-level concentrations of toxic emissions.

Page-6: Natural Gas composition, according to General Electric (GER-3942), has degraded over the past decade as a result of deregulation, such that the percentage of methane, CH4, in Natural Gas today, is generally closer to 90% (compared to 96%). The remaining content includes higher-carbon forms contributing to higher concentrations of toxins in emissions.

Tables 4 and 6 are flawed with multiple occurrences of incorrect computations resulting in understated values for toxin concentrations by 2 and 3 times. Thus the report assesses impact of only one of the two 500,000,000 BTU engines. These understated results are then compared with 8-hour workplace limits having little bearing on ambient air quality considerations. Nevertheless, after correction of Otte's computations, formaldehyde is output at a level 5.7 times the rate that meets the Time Weighted Average workplace standard by NIOSH.

While emissions data is presented for all of Northern Kentucky, this obscures the more local impact of concern. The plant would affect primarily humans in Kenton County.

Comparing existing point source emissions in Kenton County to emissions by Cinergy:

Cinergy would add 245 Tons of Carbon Monoxide to existing levels of 7 Tons.

Cinergy would add 165 Tons of smog-forming nitrogen oxides to existing levels of 21 Tons.

Comparing existing area emissions averaged over the 162 square mile area of Kenton County, per sq mile, Cinergy would produce, from its 13Acre site, 48 times the existing levels of carbon monoxide and 149 times existing levels of nitrogen oxides. More precisely, we may compare vehicular emissions derived from 24-hour traffic counts (adjusted to 90% precluding night-hours 10pm - 7am) on the major roadways bounding the proposed site. The per hour rate of traffic emissions for this 1.5 square mile area is 1.2 lb/Acre/hr of Carbon Monoxide. Cinergy production at its 13 Acre plant would be more than 6.1 lb/Acre/hr, a rate more than 5 times the local area emission rate.

In summary, while Air Quality concerns are significant, safety and siting matters are much more significant. But especially if we pay for a Report assessing the impact of a 1-Billion-BTU inferno, we expect accurate results presented clearly. Instead we have inaccurate results presented obscurely for a half-Billion-BTU plant.

More importantly, we continue to waste valuable time regarding more productive investments toward the important goal of protecting residential air quality where it is most challenged. The first step in addressing the problem of pollution is to factually determine the problem. Technology is available to accurately measure actual air quality parameters, in parts per million concentration, for the primary pollutants of concern: carbon monoxide, nitrogen oxides, and volatile organic compounds.

While Otte, Cinergy and the Division of Air Quality may lead us to believe we can "take" regular doses of toxins in trifling concentrations, we should understand the degree to which we breath large quantities of air, increasing over 5 times the normal rate during exercise. Our system is unaffected by Nitrogen and Argon. We typically trade carbon dioxide for oxygen.

But each molecule of carbon monoxide we inhale is 200 times more effective than oxygen at getting to and permanently displacing the ability of our red blood cell to carry one molecule of oxygen, for the life of the red blood cell -- about 90 days. It may not sound like much carbon monoxide if the concentration is "only" 1 part per million (ppm) of air, but that translates to 5 ppm of O2 in air and (multiplied by 200) 1000 ppm getting to red blood cells, 5000 ppm during exercise. Symptoms of Carbon Monoxide overdose are headache and fatigue, as you may recall after sitting in stalled traffic during inversions. With Cinergy's proposal you can have the same dose without leaving the comfort of your home.

While Cinergy would produce smaller quantities of volatile organic compounds (VOCs), even if the concentration is only 1 part per billion of air, that translates -- in each normal breath of one-half liter of air -- to over 3,000,000,000 molecules of carcinogens carried into the blood through the lungs. However, unlike carbon monoxide, many VOC molecules are not finally shed from the body, but accumulate and ultimately interfere enough to cause widely various forms of illness, common and uncommon, including allergies, asthma, cancer and transmissible birth defects.

An investment of less than $7000 enables us to begin continuously loading a database of measurements, processed by available analytic software, by which we may assess our current level of pollution. Just as a scale is to a dieter, pollution measuring provides important feedback enabling better decisions about impacts to our pollution "diet". The same measuring tools enable us to respond more precisely to occurrences of spills and accidents.

We might assume "the government" is doing this for us, but the Kentucky Division of Air Quality, representing US EPA, states that the only monitor currently tracking air quality in Kenton County is located in Covington. I have proposed this investment in air monitoring capability to our government, Erlanger Council, and encourage you to show your support for getting a handle on pollution before you or your loved ones succumb to it. By beginning to build a knowledge base we will be better able to assess baseline status and impacts on air quality, and respond to changes brought on, for example, by Cinergy, just in case we fail in our defense against the Bully. Better knowledge enables better decisions.

For your better health,

Respectfully serving,

John R. Schmidt, M.S.

President, NCAD Corporation

www.ncad.net ?Power

859 727-9999

C H E E R

Citizens for Healthy Environment Everywhere Residential